PFAS CERCLA Exemption Letter Submitted Electronically to: https://www.regulations.gov
The Honorable Michael Regan, Administrator U.S. Environmental Protection Agency
Re: Addressing Per- and Polyfluoroalkyl Substances in the Environment, Advance Notice of Potential Rulemaking (ANPRM); Docket ID No. EPA-HQ-OLEM-2022-0922
Last year, NWRA and SWANA submitted comments on EPA’s proposal to designate perfluorooctanoic acid (PFOA) and perfluorooctane sulfonic acid (PFOS) as CERCLA hazardous substances. They also submitted comments in May in response to this ANPRM jointly with other “passive receivers” of per- and polyfluoroalkyl substances (PFAS). Both associations reiterate and append those comments to what is contained in this letter, urging EPA to ensure that landfills and other passive receivers are afforded relief from CERCLA contribution litigation prior to designating PFAS as hazardous substances.
Join SCS Engineers professionals at the SWANA Florida chapter’s Summer Conference and Hinkley Center Research Forum, July 23-25 in Daytona Beach, FL.
Don’t miss this opportunity to network with some of the best minds in the solid waste industry at this important solid waste conference and tradeshow in the southeast, while earning continuing education hours and enjoying beautiful and exciting Daytona Beach.
The program committee is developing an interesting and educational agenda about the latest developments in the solid waste industry. The conference will explore important topics, such as solid waste management, rate analyses, recycling, zero waste, landfill design & operations, waste-to-energy conversion technologies, disaster debris management, and more!
Several SCS Engineers professionals are presenting at the conference, including
We hope to see you there!
Meet SCS Engineers professionals at BOOTH 403 at the Air & Waste Management Association’s (A&WMA) 116th Annual Conference & Exhibition (ACE 2023), June 5-8, 2023, at the Hyatt Regency in Orlando, Florida.
“Smart Growth: Balancing Development, Restoration, and Resiliency” is this year’s theme. Florida’s abundant coastline, diverse ecosystem, and perennial vacation destination faces unique challenges with respect to impacts from weather, sea-level rise, and other pressures brought on by a growing population. Florida is committed to meeting this challenge through many diverse minds working to plan and adapt to change—in short, to grow smarter and build a more resilient world. The Air & Waste Management Association (A&WMA) will welcome the world’s leading environmental experts, thinkers, and practitioners to Orlando to address environmental challenges, discuss strategies and solutions to climate change, sustainability, new contaminants, and other issues that call for balancing growth with sustainability and resiliency.
Several professionals from SCS Engineers are presenting at the conference, including:
ACE 2023 will unite professionals from major industry, private sector, consulting, government and academia for an exciting event that will explore the ever-expanding environmental challenges and provide solutions to becoming and remaining resilient for tomorrow. This is an ideal opportunity for professionals to share their knowledge to advance the industry, and for environmental companies to showcase their products, services, and solutions with professionals motivated to build a more resilient and sustainable world.
Visit https://www.awma.org/ace2023 for registration information and conference details.
Meet SCS Engineers professionals at the A&WMA/ASME Waste Information Exchange, April 11-12, 2023, at the Doubletree Hilton Washington DC-Crystal City Hotel, in Arlington, Virginia.
This conference will cover the latest on a broad range of waste-related topics including regulations and research in an interactive, discussion-focused format. This is an excellent learning and networking opportunity to hear directly from experts at EPA, NGOs, industry, and academia who are working together to develop solutions to creating a cleaner and healthier environment. The technical program will cover policy updates and regulatory changes, as well as current and late-breaking research on hot topics such as:
• Solid Waste
• Landfill Issues and Greenhouse Gas Emissions Monitoring
• Resource Management
• PFAS Emissions and Controls
• Environmental Justice
• RCRA Requirements for Open Burning
Managers, practitioners, policymakers, and researchers involved in waste management, public works, operations, maintenance, manufacturing, transportation, technology, compliance, collections, and other environmental roles will benefit from the technical content and networking available at this conference.
Sponsorship and display opportunities are available at this conference! Discover how your company can maximize exposure, generate leads, and support the industry.
Visit www.awma.org/waste for registration information and evolving conference details.
SCS periodically prepares Technical Bulletins to highlight items of interest to our clients and friends who have signed up to receive them. We also publish these on our website at https://www.scsengineers.com/publications/technical-bulletins/.
Our most recent Bulletin summarizes the
This Bulletin provides information on these revisions, as follows:
Scientists and experts agree that climate change is a present-day threat to communities across the U.S., manifesting in both predictable and unpredictable ways. As detailed in the National Climate Assessment Vol. 4 (NCA4), coastal storms are increasing in strength and frequency, forest fires are becoming much larger and more destructive, annual precipitation is changing and increasing in variability, and widespread flooding is becoming more common both in the interior of the nation and along the coasts.
These changes present complex challenges to the waste management industry that must be addressed and planned for. For example, one challenge is an increasing frequency of large-scale weather events and natural disasters, which are creating more debris that must be managed and which affects the characteristics of landfilled waste. Landfill design needs to incorporate precipitation changes and increased threats due to weather variability, flooding, and sea-level rise. Precipitation changes affect gas generation rates and require a diligent reaction to maintain effective gas collection. Because of weather pattern changes, risks of cover material erosion and swales have increased for landfills in both wet and dry climates, which may require stronger natural caps or the use of emerging technologies for alternate cover. Additionally, landfills are affected by an increase in the variability of precipitation and rapid changes between weather extremes.
It is clear that waste management facilities must adapt to these changes in addition to scenario building for pandemics to maintain effective operations. Adaptations available include making changes to landfill design and planning, such as incorporating precipitation changes into the modeling of leachate and gas generation or increasing the distance between the bottom liner and groundwater.
Systems should be regularly evaluated and areas needing repairs should be corrected quickly and diligently. Gas generation models should be updated regularly and collection systems need to be expanded or adjusted to account for precipitation increases or decreases.
More frequent and intense storms are creating challenges for cover material management, liquids management, and maintaining slope stability. Facilities should implement innovative uses of both existing technology and new or emerging technologies.
Communities with waste management facilities should include waste management infrastructure in emergency management plans, including maintaining landfills and collections operations and using landfills as both temporary debris storage and as an option for final disposal.
Since climate change effects vary by region and locale, many facilities are developing a specific plan for adaptation and management. To reduce the inevitable costs of adaptation and maintain responsiveness to weather changes, a reactive approach is being abandoned in favor of a proactive approach.
About the Author: Jacob Shepherd is a Senior Project Professional specializing in air compliance and reporting within EPA Region III. He is experienced in environmental engineering, air compliance, renewable energy, landfill and landfill gas engineering, and environmental services throughout the mid-Atlantic region, and is a licensed P.E. in Virginia.
Resources and Recovery
Get started with these resources and recovery success studies; click to read, download, or share each:
Planning for Natural Disaster Debris – help for communities to develop or revise a disaster debris management plan. Many aspects of disaster debris planning can be relevant to communities demolishing abandoned residential buildings and remediating properties.
Guidance about Planning for Natural Disaster Debris – much of the construction or demolition waste can be recovered and recycled. SCS Engineers designs and builds these facilities so we can help locate the nearest C&D debris recyclers as part of your plan.
Planning Financial Response and Recovery – the SCS Management Services™ team offers services to support financial planning and to quickly access budget and operational financial impacts. Eliminate concerns about the upcoming fiscal year expectations and anticipated medium-term impacts of pandemics and natural hazards on local government operations and revenue streams. Address issues such as:
Inductive Automation® announced the software firm now recognizes SCS Engineers as a Premier Integrator. Premier Integrators have a high level of commitment, professionalism, and competency using the Ignition software. They must consistently produce high-quality work and must consistently demonstrate successful projects with very satisfied end-users.
SCS uses Inductive Automation’s Ignition supervisory control and data acquisition (SCADA) software in their solution because it is a proven state of the art software, which works well with cloud-based systems and the internet of things (IoT). It allows clients to easily control, track, manage and report on their processes.
Large landfills, counties with multiple landfills, and private waste management firms have been waiting several years for SCADA software to catch up to their business needs. Landfill operations are extremely complex and expensive since they monitor and manage multiple systems to protect the public from contamination to the air, water, or soil. There are typically multiple operations active on many sites, such as waste recovery, recycling, composting, Gas Collection and Control Systems (GCCS), and renewable energy plants.
SCS Remote Monitoring and Control®, or SCS RMC® provides a next-generation option to monitor and control systems, and see the data collected and the systems in action. It allows users to control their systems remotely, collect data and use the data to enhance their productivity, reduce their operations and maintenance (O&M) costs, and reduce their environmental risk. Other offered services include 3D imaging from drones and virtual reality (VR). SCS uses aerial data collected via drones to compose topographic mapping, 2D images, 3D renderings, GIS, thermal, infrared (IR), and methane leak detection for waste facilities. The SCS RMC® team can take rendered models and apply them into virtual reality (VR) headset as well, which allows decision-makers at waste management facilities and organizations to “walk the site” from anywhere.
Current clients save Operating & Monitoring (O&M) costs and reduce human error by generating internal and regulatory reports automatically, using data automatically collected by the system. They can also receive instant notification of malfunctions and can troubleshoot these notifications remotely.
Not only for landfills, until recent years the public did not realize the long-term value of recycling nor the associated costs. Some clients use SCS RMC® to monitor dumpsters and recycling receptacles for collection. This helps keep waste and recycling inside the container, collection schedules more efficient, and overall operations less costly.
Manufacturing, industrial facilities, and ports use remote monitoring and control for real-time viewing, analysis, and control of equipment and systems critical to production and safe operations, often for air monitoring.
Galen Petoyan, Senior Vice President of Field Services states, “We fully embrace SCS RMC® within SCS Field Services® because the software allows us to provide more value to our clients; our technicians and engineers can avert problems, and when needed, provide rapid, efficient, and accurate analysis and action.”
I read your informative blog regarding recommendations for jet cleaning leachate collection pipes. I have a question.
QUESTION: Say a landfill only has access to one end of a leachate pipe. This would be a situation where a new cell was built, where the uphill side of the cell butts up against an existing, pre-subtitle D cell with no leachate collection pipe. In other words, the uphill side of the new leachate pipe simply terminates rather than tie into an existing pipe.
To add to the issue, no vertical cleanout/riser pipe was installed on the uphill end (as this may impede waste operations in the area). There are of course riser and cleanout pipes and a sump on the downhill side for normal leachate collection. I would imagine that pumping water from the accessible side would push out any solids through the perforations into the leachate aggregate bedding, and may cause clogging there.
Is it possible, or reasonable, to flush this new leachate line?
ANSWER: There is always a possibility that a portion of dislodged material from the interior walls of the pipe will pass through pipe perforations and enter the gravel bedding around the pipe. However, due to the pipe slope, the great majority of the separated material flows down the pipe to the lowest point where it can be removed using a vac-truck.
Keep in mind also that, it’s true that leachate can partially flow through the bedding gravel toward the sump, but the role of the gravel is primarily protecting the pipe against compressive loads of waste above. Partial clogging of gravel around the pipe should not be considered as a malfunction of the system. Partial clogging of gravel normally may occur near the bottom portion of the gravel pack, which still allows leachate flow through gravel to pipe perforations above any clogged zone below.
In several instances, when a portion of a leachate collection pipe was opened up after being in service for a while, it did not support the idea of a clogged zone in the gravel pack. What was observed, included discolored gravel due to fine particles settling (from filtered leachate through geotextile) on gravel particles and a bit of the same particles near the bottom of the gravel pack.
I’ve never observed severe clogging of the gravel pack.
About the Author: Ali Khatami, PhD, PE, LEP, CGC, is a Project Director and a Vice President of SCS Engineers. He is also our National Expert for Landfill Design and Construction Quality Assurance. He has over 40 years of research and professional experience in mechanical, structural, and civil engineering.
Understanding the entire range of wastewater management and disposal alternatives can be a daunting task, particularly as increasingly stringent surface water discharge standards take effect or as zero discharge facilities find the management of their waste liquid needs changing over time. Former solutions are no longer options or may be too costly. One alternative that is rapidly gaining traction is deep injection wells.
Deep well injection is a viable leachate management option in many parts of the United States, yet it is often screened out as a possible alternative due to a lack of understanding of the technology or gross misconceptions about its acceptance or applicability. The purpose of the Monte Markley’s paper The Basics of Deep Well Injection as a Leachate Disposal Option is to present the basic technical, economic and regulatory considerations of deep well injection as a technology a facility should evaluate when considering the applicability of geologic sequestration of leachate.
Technical criteria discussed are potential disposal volumes, geologic suitability, chemical compatibility, pre-treatment requirements, and leachate chemistry. The economic considerations are evaluated based on the technical criteria noted above, management of public perception/relations, current leachate management expenditures, the service life of the asset and risk to develop accurate capital, O&M costs, and return on investment. Regulatory considerations include the role of state vs. federal primacy for each state, the general stance of regulatory acceptance in specific areas of the United States, and a discussion of the permitting process and typical reporting requirements.
These key considerations are then integrated into an overall suitability evaluation that an owner can utilize to accurately determine if deep well injection is a viable option and, if so, how to educate other stakeholders and manage the process of implementation as a project moves forward.
About the Author: Monte Markley, PG, SCS Engineers
More than 500,000 people call Volusia County home. Situated on the east coast of Central Florida, the county has 47 miles of Atlantic Ocean beaches and beachfront cities including Daytona Beach, Ormond Beach and New Smyrna Beach. Volusia County has an abundance of natural beauty and some of the most beautiful parks in the United States.
Green Volusia is the county’s long-term initiative designed to provide residents and visitors with information about green, or sustainable, practices to reduce the impact on the environment. Green Volusia provides information about environmentally responsible practices that benefit the whole community as well as encouraging stewardship and conservation of our natural resources.
Despite the best green practices, it came time to expand the county’s landfill. The City Council approved a contract for Professional Construction Quality Assurance (CQA) and Engineering Services with SCS Engineers. SCS is an award-winning environmental consulting, engineering and construction company known for sustainable environmental solutions. The Council selected SCS for their in house expertise in MSW cell construction, and successful record of delivering the highest quality environmental engineering services.