Tag Archives: EPA

EPA Solid and Hazardous Waste Updates and Summaries

September 10, 2019

Proposed Amendments to the Coal Ash Regulations, Public Hearing Registration Open 

EPA is proposing further amendments to the regulations governing the disposal of coal combustion residuals, commonly known as coal ash.

The proposal addresses two issues remanded by the courts back to EPA for action. EPA is proposing a modification to one of the criteria used to determine if coal ash is being beneficially used or would be considered disposal. The second proposed change is to the requirements for managing piles of coal ash. Other proposed changes include revisions to enhance public access to information.

In addition to accepting written comments on this proposal, EPA is holding two public hearings – one in person in Arlington, Virginia on October 2, 2019, and a second one that will be held virtually.

To learn more about this proposal and the public hearings, learn how to comment and register to speak or observe, visit: https://www.epa.gov/coalash/coal-ash-rule#July2019proposal.

 

Upcoming e-Manifest Fiscal Years 2020-2021 User Fees

EPA announced the new e-Manifest user fees for fiscal years 2020-2021 (October 1, 2019-September 30, 2021). These user fees are set based on the manifest usage and processing costs for each manifest type.

EPA encourages the hazardous waste industry to adopt fully-electronic manifesting as soon as possible so that industry members can take maximum advantage of the benefits and cost savings of electronic manifesting. However, EPA acknowledges that it will take time for industries and receiving facilities to fully transition to electronic manifests. EPA supports the wide adoption of electronic manifesting by the regulated community as soon as it is feasible.

For more information and to view the new user fees, visit https://www.epa.gov/e-manifest/e-manifest-user-fees-and-payment-information#2020fees.

 

Comment Period Open for Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) 108(b) Electric Power Industry Proposal 

EPA is seeking public comment on a proposed rule not imposing financial responsibility requirements under CERCLA Section 108(b) for Electric Power Generation, Transportation, and Distribution facilities.

The comment period for the proposed changes is open for 60 days, through September 27, 2019. To learn more, view the proposal, and how to submit comments visit: https://www.epa.gov/superfund/proposed-action-financial-responsibility-requirements-under-cercla-section-108b-classes.

 

Incremental Sampling Methodology (ISM) at PCB Cleanup Sites

ISM has been shown to be a valid and effective method for determining the concentrations of contaminants, including PCBs, in heterogeneous soils when designed appropriately. This document has a brief description of ISM and provides EPA’s policy of reviewing and approving site-specific applications to use ISM at PCB cleanup sites: https://www.epa.gov/pcbs/incremental-sampling-methodology-ism-pcb-cleanup-sites.

 

New and Updated Pharmaceutical Frequent Questions Posted

EPA recently updated several frequent questions about the final rule establishing management standards for hazardous waste pharmaceuticals and amending the P075 listing for nicotine. Additionally, EPA added a section about the sewer ban, which was effective August 21, 2019.

Check out the frequent questions out here: https://www.epa.gov/hwgenerators/frequent-questions-about-management-standards-hazardous-waste-pharmaceuticals-and.

 

Use these EPA resources to learn more, or contact SCS at service@scsengineers.com and we’ll help answer your questions.

 

 

 

Posted by Diane Samuels at 6:03 am
Tag Archives: EPA

MSW Landfills EG Comment Period Ends October 7, 2019

August 22, 2019

 

EPA 40 CFR Part 62

 

This proposed MSW Landfills Federal Plan includes the same elements as required for a state plan: identification of legal authority and mechanisms for implementation; inventory of designated facilities; emissions inventory; emission limits; compliance schedules; a process for the EPA or state review of design plans for site-specific gas collection and control systems (GCCS); testing, monitoring, reporting and record-keeping requirements; public hearing requirements; and progress reporting requirements. Additionally, this action summarizes implementation and delegation of authority of the MSW Landfills Federal Plan.

This proposed action addresses existing MSW landfills and associated solid waste management programs. For the purpose of this regulation, existing MSW landfills are those that accepted waste after November 8, 1987, and commenced construction on or before July 17, 2014.

Tables 1 and 2 in the publication list the associated regulated industrial source categories that are the subject of this action and the status of state plans. The EPA tables are not intended to be exhaustive but do provide a guide for readers regarding the entities that this proposed action is likely to affect. The proposed standards, once promulgated, will be directly applicable to the designated facilities.

The document contains the full text and how/when to comment or appear at the public hearing. Feel free to share this document or page with others using the icons at left.

Download (PDF, 381KB)

 

Contact SCS Engineers

 

 

 

 

 

Posted by Diane Samuels at 11:53 am
Tag Archives: EPA

Waste360 Article Series – The Impacts of PFAS and a Push for Nationwide Standards

August 7, 2019

We recommend reading this article series to stay abreast of relevant knowledge from Bryan Staley, president and CEO of the Environmental Research & Education Foundation (EREF); Anne Germain, vice president of technical and regulatory affairs for the National Waste & Recycling Association (NWRA); Viraj deSilva, SCS Engineers wastewater treatment director; and testing results from New Hanover County whose capital investment in landfill infrastructure has proven to successfully treat effluent water to meet higher standards.

Read Part One

Read Part Two

 

Posted by Diane Samuels at 6:01 am
Tag Archives: EPA

EPA Announces Policy to Enhance Enforcement and Compliance Assurance Partnerships with States

July 11, 2019

EPA announced today a final policy to enhance effective partnerships with states in civil enforcement and compliance assurance work. The memorandum from EPA’s Assistant Administrator for Enforcement and Compliance Assurance Susan Bodine articulates the final policy procedures and practices for effective coordination between EPA and states when carrying out shared responsibilities under environmental laws.

The final policy memorandum is divided into three sections. The first section details requirements for joint planning and regular communication between EPA and states to promote enhanced, shared accountability. The second section of the policy provides greater detail on EPA and state roles and responsibilities in implementing authorized programs. The third and last section of the policy provides a process for the elevation and resolution of issues.

The issuance of today’s final policy replaces the interim guidance memorandum on enhanced planning and communication between EPA regional offices and states issued by Susan Bodine on January 22, 2018.

If you have questions about the final policy, please contact your SCS Project Manager, or send an email to service@scsengineers.com.

 

 

 

Posted by Diane Samuels at 3:27 pm
Tag Archives: EPA

Post-Closure Care Terms – RCRA Subtitle D

June 10, 2019

The EPA Resource Conservation and Recovery Act (RCRA) requires landfill operators to maintain post-closure care for 30 years, though states will adjust the term according to when they determine ending this care will not threaten human health or the environment. Industry stakeholders say it’s not enough guidance because it does not provide how states should assess for impact on human health or the environment, nor how to determine when to transition from active post-closure care to custodial care. Regulators tend to default to an extension of terms. Again data collection plays a significant role in determining the post-closure care term.

“The whole purpose of the post-closure care term is to provide enough time for landfills to become stable. One way to assess is by determining if functional stability has been achieved, which entails looking at performance metrics like leachate management, settlement, landfill gas control, and groundwater monitoring,” says Bob Gardner, of SCS Engineers.

Looking at these metrics, once it’s determined that functional stability has been achieved, these active systems may be able to be turned off, with only passive controls like cover remaining in place.

Monitoring may be done less frequently or not at all. “EPA acknowledges that back in the 1980s, it did not know how systems, primarily liner systems, would perform under new Subtitle D rules. But based on monitoring of these systems over the past 25 years, we know that they perform well to prevent migration of contaminants to groundwater,” says Gardner.

Read the Waste360 article Stakeholders Call for More Certain Landfill Post-closure Care Terms

Investigate why over 600 landfills use SCS eTools® to track, report, and store important data.

 

 

 

 

Posted by Diane Samuels at 6:00 am
Tag Archives: EPA

Revisions to Criteria for MSW Landfills to Address Advances In Liquids Management – ANPRM

June 4, 2019

Comments were submitted to the EPA from NWRA/ SWANA regarding the EPA’s Advance Notice of Public Rule Making (ANPRM) for revisions to Subtitle D, and in particular potential revisions regarding the bulk liquids addition. Subtitle D prohibits bulk liquids additions with the exception of leachate recirculation, and the RD&D permit process allows bulk liquids. Bob Gardner of SCS Engineers was involved in the development of the joint NWRA/SWANA comment letter.

EPA has indicated that they are considering adding a “wet landfill” definition to Subtitle D; however, the Industry strongly advised against doing so. The letter addresses this issue and the reasons for recommending against a separate “wet landfill” definition.

Industry Association’s Comments

 

 

 

 

 

Posted by Diane Samuels at 6:00 am
Tag Archives: EPA

Federal Judge Rules Against EPA on the Landfill EG Lawsuit

May 10, 2019

Before the Court: EPA admits that it has failed to meet its nondiscretionary obligations to implement the Landfill Emissions Guidelines, as compelled by the CAA. The only questions before the Court were whether the Plaintiffs have standing and, if so, how long to give EPA to comply with its overdue nondiscretionary duties under the Landfill Emissions Guidelines. The Plaintiffs are the States of Illinois, Maryland, New Mexico, Oregon, Rhode Island, California, Vermont, and the Commonwealth of Pennsylvania.

Ruling: Plaintiffs have standing, and the EPA must approve existing submitted plans by September 6 and issue the federal plan by November 6.

Impact on Landfill Owners/Operators: This will create some confusion, as landfills will be working on getting revised rules in place while at the same time start complying with the old EG rule. We are already doing that with XXX sites, but this ruling adds complexity. If EPA keeps to the schedule and we have final approved revised rules by March 2020, landfills won’t have to do as much under the old rules before new ones take effect.

Stay tuned.

Contact your SCS Project Manager for more information, email us at service@scsengineers.com, or follow SCS on your preferred social media.

 

 

 

Posted by Diane Samuels at 6:00 am
Tag Archives: EPA

48th ABA SEER Spring Conference in Denver March 27-29

March 18, 2019

Speakers include Andrew Wheeler, Administrator, U.S. Environmental Protection Agency discussing regulatory policy about the environment, energy, and resources.  SCS a proud sponsor looks forward to seeing you there!

A few of the topics of this year’s conference will include water law, brownfields, public service, fracking, enforcement, grid resiliency, PFAS, mineral exploration, and more, even the environmental implications of the new cannabis industry.

Find conference details and registration at https://www.scsengineers.com/event/aba-seer-48th-spring-conference/

Register now.

 

 

Posted by Diane Samuels at 6:00 am
Tag Archives: EPA

EPA Announces PFAS Action Plan to Protect Public Health

February 20, 2019

 

As a national environmental consulting and contracting firm specializing in managing hazardous substances, SCS Engineers is helping our clients now. Start by reading The Environmental Dangers of PFAS and Technologies for Removing Them, published in WasteAdvantage magazine for use in the solid waste industry and other industrial applications in support of EPA’s Action Plan.

 

On February 14, 2019, the U.S. Environmental Protection Agency (EPA) Acting Administrator Andrew Wheeler announced EPA’s Per- and Polyfluoroalkyl Substances (PFAS) Action Plan. The PFAS Action Plan is in response to public interest and input the EPA has received over the past year. EPA’s Action Plan identifies both short-term solutions for addressing these chemicals and long-term strategies for states, tribes, and local communities need to provide clean and safe drinking water to their residents and to address PFAS at the source. These actions include:

  • Moving forward with the maximum contaminant level (MCL) process outlined in the Safe Drinking Water Act for PFOA and PFOS—two of the most well-known and prevalent PFAS chemicals. By the end of this 2019, EPA states the agency will propose a regulatory determination.
  • EPA has already begun the regulatory development process for listing PFOA and PFOS as hazardous substances and will issue interim groundwater cleanup recommendations for sites contaminated with PFOA and PFOS. The EPA feels this will provide additional tools to help states and communities address existing contamination and enhance the ability to hold responsible parties accountable.
  • Enforcement: EPA will use available enforcement tools to address PFAS exposure in the environment and assist states in enforcement activities.
  • EPA will propose to include PFAS in nationwide drinking water monitoring under the next Unregulated Contaminant Monitoring Program. The agency will also consider PFAS chemicals for listing in the Toxics Release Inventory.
  • Research: EPA will develop new analytical methods so that more PFAS chemicals can be detected in drinking water, in soil, and groundwater. EPA’s research efforts also include developing new technologies and treatment options to remove PFAS from drinking water at contaminated sites.
  • Risk Communications: EPA will work across the agency—and the federal government—to develop a PFAS risk communication toolbox that includes materials that states, tribes, and local partners can use to communicate effectively with the public.

 

Contact a local SCS professional at Service@scsengineers.com or visit our website.

 

 

 

 

Posted by Diane Samuels at 11:46 am
Tag Archives: EPA

A New ERA in Industrial Stormwater Regulation

February 18, 2019

Read Considerations, Strategies and Lessons learned for NPDES Regulated Industrial Dischargers within the Exceedance Response Action Models of Stormwater Regulation

Stormwater Regulation is evolving, pushing more responsibility on to the dischargers by holding them accountable through categorization based on a discharger’s ability to meet numeric benchmarks. Additionally, how a discharger responds and applies effective BMPs determines their status. Ultimately, it is up to the industrial permittee to take the initiative, with an eye to priorities and feasibility for the future of their stormwater compliance program.

Stormwater managers and facility compliance personnel have only just begun to come to terms with the tiered ERA Response paradigm. However, as the tiered escalation becomes more common and ERA Level 1 and Level 2 reporting is performed, facilities are beginning to reach an equilibrium of stormwater compliance in terms of strategy, feasibility, budget and allocation of resources.

Jonathan Meronek of SCS Engineers.

In his whitepaper, Jonathan Meronek, QISP, ToR, takes readers through the fundamental components of the ERA, Exceedance Response Action, or tiered Corrective Action compliance mechanism already in place, and currently being implemented in the States of California, Washington and the most recent General Permit in Oregon. ERA has wide-reaching implications for future NPDES permittees of industrial stormwater discharges. The escalation or “tiered” response standards is based on EPA Benchmark Levels and potential for future Numeric Effluent Limits (NELs). The three western states are viewed as “precursors” of what may be expected throughout the United States, as several key components of the forthcoming Multi-Sector General Permit  (MSGP) will push other states to move towards similar ERA response scenarios and regulations.

 

 

 

Posted by Diane Samuels at 6:00 am
SCS Address

Corporate Headquarters

3900 Kilroy Airport Way Ste 100
Long Beach, CA 90806-6816

Telephone

1 (800) 767-4727
1 (562) 427-0805 | FAX
service@scsengineers.com

Required Posting