About CALRC
It’s time for the California Land Recycling Conference (CALRC) in Carson, California, September 26-28. The Center for Creative Land Recycling (CCLR) is hosting the conference, and this year’s event theme is “People, Partnerships, Progress.”
SCS Engineers is exceptionally proud of our relationship with CCLR and of our clients who are winning Phoenix, EBJ, and other awards for their valuable contributions to their communities across all 50 states.
Environmental Justice
Achieving environmental justice means taking a sustainable, holistic approach to site remediation and land recycling. One that meets each party’s social, environmental, and economic goals. These experts can help; they’ve been in the business of sustainability for decades and are always open to knowledge sharing about funding, permitting, and remediation processes that will keep your project on track.
Headline Presentations
Should it Stay or Should it Go? In-situ vs. Ex-situ Solutions with Michael McLaughlin of SCS Engineers, Senior Vice President of Environmental Services and National Specialist on Brownfields & Landfill Redevelopment
Tuesday, September 26th at 3:15 PM in the Community Hall Section A
With numerous approaches and examples of pilot studies, innovative technologies, and work done to execute alternatives to excavation, this session will help you overcome the practical challenges of sustainable remediation. With an overview of conducting pilot tests and examples of innovative technologies, this session will help project managers and site owners take the next steps in bringing sustainable solutions to clean up contaminated sites and answer the question, can in-situ technologies be used to avoid costly excavation and disposal?
Getting to the Finish Line: Navigating Projects Through the Water Board Process with Jim Ritchie, Vice President, SCS Engineers.
Wednesday, September 27th at 10:30 am in the Community Hall Section A
We aim to get your remediation or brownfields project done sustainably, meeting economic and environmental goals such as the mission of the Water Boards to preserve the quality of California’s water resources and drinking water to protect the environment, public health, and beneficial uses. Join Jim and company to learn the best practices.
It’s time for the California Land Recycling Conference (CALRC) in Carson, California, September 26-28. The Center for Creative Land Recycling (CCLR) is hosting the conference, and this year’s event theme is “People, Partnerships, Progress.” SCS Engineers is a Visionary Sponsor and will have our experts presenting at the conference and discussing best practices for those in California and nationwide. Please stop by our booth to discuss the various land recycling possibilities for your site, funding, and permitting.
We are exceptionally proud of our relationship with CCLR and our clients who are winning Phoenix, EBJ, and other awards for their valuable contributions to their communities across all 50 states.
Achieving environmental justice means taking a sustainable, holistic approach to site remediation and land recycling. One that meets each party’s social, environmental, and economic goals. These experts can help; they’ve been in the business of sustainability for decades and are always open to knowledge sharing about funding, permitting, and remediation processes that will keep your project on track.
Should it Stay or Should it Go? In-situ vs. Ex-situ Solutions with Michael McLaughlin of SCS Engineers, Senior Vice President of Environmental Services and National Specialist on Brownfields & Landfill Redevelopment
Tuesday, September 26th at 3:15 PM in the Community Hall Section A
With numerous approaches and examples of pilot studies, innovative technologies, and work done to execute alternatives to excavation, this session will help you overcome the practical challenges of sustainable remediation. With an overview of conducting pilot tests and examples of innovative technologies, this session will help project managers and site owners take the next steps in bringing sustainable solutions to clean up contaminated sites and answer the question, can in-situ technologies be used to avoid costly excavation and disposal?
Getting to the Finish Line: Navigating Projects Through the Water Board Process with Jim Ritchie, Vice President, SCS Engineers.
Wednesday, September 27th at 10:30 am in the Community Hall Section A
We aim to get your remediation or brownfields project done sustainably, meeting economic and environmental goals such as the mission of the Water Boards to preserve the quality of California’s water resources and drinking water to protect the environment, public health, and beneficial uses. Join Jim and company to learn the best practices.
This year’s National Brownfields Conference in Detroit, Michigan, was notable. The evening before the conference began, the United States Environmental Protection Agency (USEPA) hosted an ‘Environmental Justice’ caucus in which over 150 people from both the public and private sectors came together to learn more about what Environmental Justice is and how it informs our work in economic development efforts.
USEPA defines Environmental Justice (often called ‘EJ’) as “the fair treatment and meaningful involvement of all people regardless of race, color, national origin, or income, with respect to the development, implementation, and enforcement of environmental laws, regulations, and policies.” We’ll achieve this goal when everyone enjoys the same degree of protection from environmental and health hazards and equal access to the decision-making process to have a healthy environment to live, learn, and work.
Distilled to its core, EJ is a call to action for all individuals and entities engaged in helping sustain and grow their communities. It posits that multiple demographics (including but not limited to people of color, inhabitants of rural areas, and people with less access to education and well-paying jobs) are disproportionately subject to harmful impacts from exposure to toxins and pollutants. Accordingly, it is incumbent upon those engaged with those populations to pay heed to find ways to mitigate or reduce those exposures.
EPA formally established the Office of Environmental Justice and External Civil Rights on October 6, 2022, and since that time, has engaged over 200 people across the agency to perform tasks specifically addressing EJ, including “processing grant applications from communities with environmental justice concerns, reaching out to residents to understand their concerns, and enforcing civil rights.” The EPA also established the Environmental Justice Thriving Communities Grantmaking (EJ TCGM) program in direct response to two Executive Orders issued by the Biden administration (EO 14008 and 13985) and will soon award ~$550 million to 11 distinct entities (which must be community-based nonprofits or partnerships between community-based nonprofits and either Tribal government or institutions of higher education) to spearhead more inclusive and easily accessible resources/support for communities seeking EPA funding to address EJ concerns.
EPA also established 16 technical assistance centers across the nation under the EJ Thriving Communities Technical Assistance Centers Program (EJ TCTAC), aimed at “providing technical assistance, training, and related support to communities with environmental justice concerns and their partners. The services provided will include training and assistance on writing grant proposals, navigating federal systems such as Grants.gov and SAM.gov, effectively managing grant funds, community engagement, meeting facilitation, and translation and interpretation services for limited English-speaking participants.”
Furthermore, the 2022 Inflation Reduction Act created the Environmental and Climate Justice Block Grant program in section 138 of the Clean Air Act (CAA). It provided EPA with $2.8 billion in grant funding for the program for projects to benefit communities with environmental justice concerns.
All told billions of dollars are currently available to communities that seek to spur environmental cleanup and revitalization efforts. SCS specializes in helping communities connect with this funding (even providing in-house Brownfields grant writing services) and has a proven track record of forming successful partnerships which result in timely and meaningful rejuvenation projects.
Two of the projects SCS teamed on this past year are awardees of the EPA’s prestigious 2023 Phoenix Award. The first of such projects, performed in EPA Region 6, involved the restoration of the historic First National Bank Building in downtown Oklahoma City, OK. This project created a mixed-use space, including apartments in the heart of the bustling business district, to help revive a struggling downtown and create jobs for residents. The second project, performed in EPA Region 9, provided affordable housing in San Diego, CA, and included upgrades to storm drains, water and sewer lines, underground powerlines, and streetscape improvements, significantly enhancing area infrastructure.
In both these projects and countless other projects performed under federal and state Brownfields programs, SCS is a trusted partner providing technical expertise and conscientious approaches to community engagement and planning that align with EJ protocols. SCS is a Foundational Member and Advisor of the Center for Creative Land Recycling (CCLR), which aims to turn abandoned land into thriving spaces that serve communities meaningfully.
This year’s Brownfields Conference theme was “Sustainable Communities Start Here,” in sync with SCS’s long culture and mission of achieving sustainability through holistic processes. The most successful remediation projects are when all stakeholders have a voice and redevelopment efforts are thoughtfully, creatively, and deliberately planned and implemented.
Additional Resources:
About the Author: Rachel McShane, LEP, has over 15 years of experience in environmental due diligence projects (Phase I, II and III Environmental Site Assessments) as well as Brownfields redevelopment, risk-based corrective action, and remediation projects. She is also familiar with National Environmental Policy Act (NEPA) environmental assessments, vapor investigations and mitigation, radon, asbestos, and lead based paint surveys, and leachate monitoring/solid waste management. You may reach her at or via LinkedIn.
To a wastewater treatment engineer, at least during workdays, it seems like everyone is talking about forever chemicals, all of the time. There’s a good reason for that, because the huge group of man-made chemicals has climbed in priority to be at the top of most wastewater treatment regulatory considerations. Forever chemicals are also known as per and polyfluoroalkyl substances (PFAS) and have rapidly become the latest of the emerging contaminants in drinking water to be treated. So, while there is still a lot of toxicology research to do, PFAS destruction and even which PFAS actually needs to be addressed, there is very little doubt regarding the future need to treat PFAS in landfill leachate and other wastewaters. Everyone is in agreement, the environment needs to be protected from forever chemicals.
PFAS chemicals can withstand high heat without becoming unstable as well as repelling oil and water, making them ideal for inclusion in fire-fighting foam, lining non-stick pans, or water resistant clothing. But unfortunately, PFAS can persist in the environment – water, fish, humans, etc. – for a long time. So, having efficient and cost-effective methods of treating wastewater, drinking water, bio-solids, etc., to reduce/remove PFAS is becoming increasingly important. Luckily, some traditional and very available treatment methods are effective at treating PFAS as well as some newer, non-traditional treatment methods that appear to be promising.
One effective management technology is using deep injection wells to store the PFAS contaminated wastewater deep, far below drinking water sources and within high total dissolved solids groundwater. Deep injection wells are only allowed where the deep geology and subsurface conditions can allow for the PFAS wastewater to be contained where it is injected.
Additional management options are granular activated carbon (GAC) or ion exchange (IX), which are adsorption treatment methods that use a media, through which the PFAS contaminated wastewater can pass, and the charged PFAS molecules become bound up in the opposite charged GAC or IX media.
Reverse osmosis (RO) and foam fractionation (FF) treatment methods use separation, either through very small pores in a membrane (RO) or applying aeration to create a PFAS concentrated foam (FF), to allow the treated, cleaner water to discharge the treatment process and the concentrate (RO) or foamate (FF) is left and can be dealt with more efficiently, because after treatment the concentrate/foamate is a much smaller volume than the original wastewater flow.
These PFAS management methods simply move the PFAS chemicals out of the way and don’t actually destroy the PFAS. PFAS destruction generally requires more effort and cost because high pressure and/or high heat are required to break the carbon – fluorine (C-F) bonds. A regenerative thermal oxidizer (RTO) or supercritical water oxidation (SCWO) are PFAS destruction methods that can be employed. An RTO typically operates at high temperature (e.g., 1,800 F) and SCWO utilizes both high temperature (>705 F) and high pressure (>3,210 psi) within a process to, again, break the C-F bonds. Electrocoagulation, advanced oxidation processes and plasma are also treatment methods that could be employed to destroy PFAS.
These are just a few of the many PFAS management and destruction options. It can be hard to decide what’s right for your project. That’s where SCS can help. We’re technology agnostic – so you can trust our recommendations are appropriate for your project and goals. Contact us today to learn more about what’s possible.
About the Author: Sam Cooke, PE, CEM, MBA, is a Vice President and our expert on Industrial Wastewater Pretreatment. He has nearly three decades of professional and project management experience in engineering with a concentration in environmental and energy engineering. Mr. Cooke works within SCS’s Liquids Management initiative to provide services to our clients nationwide.
Additional PFAS Management and Treatment Resources:
As you may recall, in September 2022, EPA issued a proposed rule to designate two per- and polyfluoroalkyl substances (PFAS) — perfluorooctanoic acid (PFOA) and perfluorooctanesulfonic acid (PFOS), and their salts and structural isomers — as hazardous substances under the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA), also known as “Superfund.” EPA is currently reviewing comments received on this proposed rule.
On April 13, 2023, EPA issued an Advance Notice of Proposed Rulemaking (ANPRM) asking the public for input regarding potential future hazardous substance designations of additional PFAS substances under CERCLA. The ANPRM includes:
The ANPRM announcement in the Federal Register is available at: https://www.govinfo.gov/content/pkg/FR-2023-04-13/pdf/2023-07535.pdf
More solutions and information at Liquids Management.
Since the 1990s, USEPA has provided risk-based Regional Screening Levels (RSLs) to assist in evaluating environmental monitoring and contaminant levels – e.g., in soil, air, and water at residential and industrial properties. EPA periodically updates the RSL tables to reflect new contaminants of concern and new chemical toxicity data. The May 2022 RSL tables have been expanded to include 14 per- and polyfluoroalkyl substances (PFAS). PFAS are a large family of emerging contaminants that are garnering significant interest due to their significant toxicity and widespread use in industrial and consumer products such as fire-fighting foam, fabric treatment, and some food packaging. The latest EPA RSL tables are available at: https://www.epa.gov/risk/regional-screening-levels-rsls-generic-tables
Additional info regarding ongoing efforts to address and treat PFAS are available by searching this website: https://www.scsengineers.com/ and then using the filter to narrow down returns to your interests.
Join EPA, SCS Engineers, and the GWPC for the 2022 Annual GWPC & UIC Conference in Salt Lake City, from June 21 through June 23. This year’s event features two experts from SCS, Kacey Garber and Stephanie Hill. In today’s blog, we take a dive into their presentations, where both women use case studies to highlight safely using deep injection wells, and what can happen during operations to plan for more sustainable operations.
Thursday, June 23 at 8:30-10:00 Class VI UIC
“Sensitivity of Aquifer Chemistry to Changes in Carbon Dioxide Partial Pressure: Implications for Design of Groundwater Monitoring Protocols,” Kacey, Julie O’Leary, and Charles Hostetler are all with SCS Engineers. The team will discuss Carbon Sequestration and Storage (CSS) solutions. Great care is taken in the design and operation of the injection of carbon compounds to ensure that the sequestration is effective and permanent. Each injection site also has permitting requirements for groundwater monitoring in any overlying aquifer as a protective measure. Because the duration of the injection and sequestration periods are long, it is essential for CSS projects to have a cost-effective groundwater monitoring program with a robust sensitivity to detect any leakage.
In this case study, the SCS team has examined the sensitivity of aquifer chemistry (major and minor cations and anions) to the partial pressure of carbon dioxide using an aqueous speciation/solubility/sorption model. They examined a number of hydrochemical facies, both natural and synthetic, to determine which geochemical parameters are most likely to be affected by changes in the partial pressure of carbon dioxide. The team anticipates that the regulatory framework and practice for CSS will be similar to that of Municipal Solid Waste (MSW) and Coal Combustion Residue (CCR) disposal sites. Prior to the injection of carbon compounds, the overlying aquifer is characterized and background values for key parameters are established. During the injection and post-injection phases of the project, there is periodic monitoring of the groundwater parameters, which they anticipate will be compared to the established background. When Statistically-Significant Increases (SSIs) are found, an Alternate Source Demonstration (ASD) will have to be prepared that attributes the SSIs to the CSS operation or to some other source. By establishing a groundwater monitoring protocol that is specific to the site, sensitive to changes in the partial pressure of carbon dioxide, and relative insensitive to natural variability and hydrochemical facies changes, optimal and cost-effective groundwater protection can be implemented.
Kacey Garber is an experienced groundwater project manager for active and closed landfills, including routine groundwater monitoring and statistical analyses; reports and permit applications; designing sampling and analysis plans; special groundwater studies; and conducting groundwater well construction planning and design. She has also been involved in PFAS workgroups. Ms. Garber has a Master’s in Geoscience from the University of Iowa, and a BS in Geology from Illinois State University Her field experience includes collecting groundwater, surface water, landfill leachate, industrial and municipal wastewater, and soil; oversight of groundwater monitoring well installation; logging and sampling soils for well-drilling operations; groundwater well maintenance and development; inspection of final landfill covers for post-closure care; and routine wetland monitoring and delineation activities.
Thursday, June 23 at 10:30 – 12:00 Class I UIC
“Microbially Influenced Corrosion in Injection Wells: A Case Study in a Class I Well for Coal Combustion Residuals,” with Stephanie Hill. Stephanie will discuss microbially influenced corrosion (MIC) is known as a direct cause of mechanical integrity failure in injection wells. While premature failures of expendable components, such as casing and packers, are inconvenient and expensive, this is not the only reason to proactively address downhole biological issues. Stringent control and mitigation of biological activity are imperative to minimizing borehole fouling and subsequent plugging of an injection reservoir. If left untreated, a well’s long-term reservoir health and operational efficiency may be jeopardized.
This presentation will summarize a case study of MIC-related failure in a Class I injection well used for leachate disposal from a coal combustion residuals facility. The well failed to maintain internal mechanical integrity just six months after being commissioned. We’ll walk through the investigation process, which includes annular pressure testing, downhole caliper logging, casing thickness detection, injection fluid analysis, and metallurgical analysis to identify the cause of failure. Following the replacement of the injection casing and packer, injection tests were conducted to assess the potential impacts of MIC on the reservoir’s ability to accept injected fluids. A proactive disinfection plan was customized based on the unique investigative results and implemented to prevent future MIC-related issues.
Stephanie Hill is a hydrogeologist, program leader for SCS Engineers’ Carbon Sequestration and Deep Well Injection practice, and licensed Professional Geologist. She earned a BS in Geosciences at the University of Texas, emphasizing hydrogeology and geomorphology. Stephanie’s early career focused on environmental compliance for mineral and fossil fuel industries at the Texas Commission on Environmental Quality (1996 to 2000) and the Railroad Commission of Texas (2000 to 2012). Currently, she leads a team of geologists and engineers to advise SCS clients of various industries on geologic storage options for carbon neutrality and disposal solutions for liquid residuals.
Approved
The EPA issued a newly approved alternative test method (ALT-143) for compliance with the enhanced monitoring provisions in the National Emission Standards for Hazardous Air Pollutants (NESHAPs) for MSW Landfills (40 CFR 63 Subpart AAAA updated March 26, 2020). The approved alternative method instead of Method 10 allows for direct monitoring of CO at a landfill gas well using a portable gas analyzer. The NESHAP requires weekly monitoring of CO at the landfill gas well if the gas temperature is over 145F and the regulatory agency has approved no higher operating value under the NSPS/EG rules or NESHAPs. The Solid Waste Working Group (SWWG) coordinated with landfill gas meter manufacturers (QED, Elkins Earthworks) to prepare this method.
EIL approved sharing a flow chart and Excel file that can be used for monitoring/documentation purposes when using this approved alternative “field instrument method.” Don’t hesitate to get in touch with your SCS air emissions/compliance expert or contact us at for details.
EPA will post the alternative test method to the Broadly Applicable Approved Alternative Test Methods | US EPA website page. Take note that the hyperlink in EPA’s letter is out of date.
Pending Approval
The Solid Waste Working Group (SWWG) also submitted two alternative methods in lieu of Method 10 to EPA for approval using grab sample (canister, foil bag) and laboratory analysis, one with GC/FID and the other GC/TCD instrumentation. The SWWG coordinated with several national laboratories on the methods. EPA is completing its review of the two proposed methods, anticipating EPA approval before September 27, 2021, the effective date of the enhanced monitoring provisions.
May 27, 2021, from two separate U.S. Environmental Protection Agency (EPA) announcements:
EPA intends to reconsider and revise the 2020 CWA Section 401 Certification Rule
Congress provided authority to states and Tribes under CWA Section 401 to protect the quality of their waters from adverse impacts resulting from federally licensed or permitted projects. Under Section 401, a federal agency may not issue a license or permit to conduct any activity that may result in any discharge into navigable waters unless the affected state or Tribe certifies that the discharge is in compliance with the Clean Water Act and state law, or waives certification.
EPA intends to reconsider and revise the 2020 CWA Section 401 Certification Rule to restore the balance of state, Tribal, and federal authorities while retaining elements that support efficient and effective implementation of Section 401. While EPA engages with stakeholders and develops a revised rule, the 2020 rule will remain in place. The agency will continue listening to states and Tribes about their concerns with implementing the 2020 rule to evaluate potential administrative approaches to help address these near-term challenges.
The agency’s process of reconsidering and revising the 2020 CWA Section 401 Certification Rule will provide an opportunity for public and stakeholder input to inform the development of a proposed regulation, and will include sustained dialogue with state and Tribal co-regulator partners and local governments around these issues. EPA will begin a stakeholder engagement process in June to hear perspectives on this topic and how to move forward. More information will be available at: www.epa.gov/cwa-401.
EPA, Region 7, public listening sessions on the RMP Rule
Section 112(r) of the Clean Air Act Amendments requires EPA to publish regulations and guidance for chemical accident prevention at facilities that use certain hazardous substances. These regulations and guidance are in the Risk Management Plan (RMP) rule, which requires facilities using extremely hazardous substances to develop a Risk Management Plan that:
These plans provide information to local fire, police, and emergency response personnel to prepare for and respond to chemical emergencies in their community.
The Region 7 EPA announced two upcoming virtual public listening sessions on the Agency’s Risk Management Plan (RMP) rule. The RMP rule has been identified as an action for review under Executive Order 13990: Protecting Public Health and the Environment and Restoring Science To Tackle the Climate Crisis.
The listening sessions will give people the opportunity to present information, and provide comments or views pertaining to revisions made to the RMP rule since 2017. The Occupational Safety and Health Administration (OSHA) will also participate in the listening sessions and receive comments on their Process Safety Management (PSM) standard, which contains similar requirements to the RMP rule.
Virtual public listening sessions will be held on:
For more information on the public listening sessions:
https://www.epa.gov/rmp/forms/virtual-public-listening-sessions-risk-management-program-rule.
Submit written comments via the docket at: http://www.regulations.gov, Docket ID: EPA-HQ-OLEM-2021-0312 until July 15, 2021.
EPA Region 7 serves Iowa, Kansas, Missouri, Nebraska, and Nine Tribal Nations.
SCS Engineers periodically prepares SCS Technical Bulletins – short, clear summaries of U.S. Environmental Protection Agency (EPA) rules and plans. On May 21, 2021, the EPA published a Federal Plan to implement the new Emission Guideline (EG) rule for municipal solid waste (MSW) landfills. The Federal Plan is published under Title 40 of the Code of Federal Regulations (CFR) Part 62, Subpart OOO.
Read, share, download the Federal Plan for Landfill EG Rule Tech Bulletin here.
