On December 5, 2022, the EPA released a memo providing direction under the NPDES permitting program to empower states to address known or suspected discharges of per- and polyfluoroalkyl substances (PFAS). Note that the list of Applicable Industrial Direct Discharges (page 2, paragraph A.1) includes landfills. The memo cites state programs in Michigan and North Carolina that other states may want to replicate. These approaches and others could help reduce PFAS discharges by working with industries, and the monitoring information they collect, to develop facility-specific, technology-based effluent limits.
As stated in its memo, the EPA’s goal is to align wastewater and stormwater NPDES permits and pretreatment program implementation activities with the goals in EPA’s PFAS Strategic Roadmap. The memo recommends that states use the most current sampling and analysis methods in their NPDES programs to identify known or suspected sources of PFAS and to take actions using their pretreatment and permitting authorities, such as imposing technology-based limits on sources of PFAS discharges.
The Agency hopes to obtain comprehensive information by monitoring the sources and quantities of PFAS discharges, informing other EPA efforts to address PFAS. The EPA will need this information since new technologies and treatments are in development but remain unproven to work successfully in specific industries.
Other proposed actions by the Agency include designating two PFAS as Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) hazardous substances and an order under EPA’s National PFAS Testing Strategy requiring companies to conduct PFAS testing and nationwide sampling for 29 PFAS in drinking water starting in 2023.
In a letter to Congress, SWANA and NWRA associations request that regulation under CERCLA for addressing PFAS contamination assign environmental cleanup liability to the industries that created the pollution in the first place. Both associations note that landfills and solid waste management, an essential public service, do not manufacture nor use PFAS. Therefore, the general public should not be burdened with CERCLA liability and costs associated with mitigating PFAS from groundwater, stormwater, and wastewater.
Resources:
FREE ON-DEMAND WEBINAR & Q/A – RECORDED JAN.21, 2021
Landfills, compost facilities, transfer stations, and renewable energy plants are cognizant of odor issues and strive to minimize odors. Proactive odor management is critical to the continued success and operation of these facilities.
More so than ever before, the solid waste industry faces complex and challenging odor issues based upon public, regulatory, and legal actions. Since odors are generally enforced through nuisance regulations, compliance can be difficult to achieve, not to mention almost impossible to define. Enforcement of odor nuisances is subjective, usually at the discretion of an environmental inspector or Air Pollution Control Officer, and often based upon citizen complaints. When citizen complaints mount, and enforcement action is leveraged, lawsuits often surface as an added ongoing challenge to waste facility operations. Now politicians are demanding action and using alleged odor violations as part of their environmental platforms. Facing odor issues can be costly and threaten the intended land-use designs that waste facilities require to serve their local communities.
SCS Engineers’ January webinar was for those who want to learn more about the proactive strategies and practices you can implement at your critical solid waste facilities. This free webinar will help you develop capabilities to assess the potential for odor issues and, by doing so, set realistic benchmarks toward cost-effective and meaningful mitigation measures.
Our panelists bring comprehensive expertise to the table, including facility design and planning, technical experience in air quality compliance and pollutant dispersion and air measurement programs, atmospheric dispersion and transport of airborne pollutants, particularly in the area of complex terrain. They will provide decades of strategies, resources, and best practices and technologies based on successful solutions that help support your facility as you prepare for, and likely will, experience odor complaints.
The team answers questions throughout the presentation, and the second portion of the program is devoted to Q&A and idea exchange.
Register for SCS Engineers’ January webinar to learn more about the proactive strategies and practices you can implement at your critical solid waste facilities. This free webinar will help you develop capabilities to assess the potential for odor issues and, by doing so, set realistic benchmarks toward cost-effective and meaningful mitigation measures.
FREE LIVE WEBINAR & Q/A
Landfills, compost facilities, transfer stations, and renewable energy plants are cognizant of odor issues and strive to minimize odors. Proactive odor management is critical to the continued success and operation of these facilities.
More so than ever before, the solid waste industry faces complex and challenging odor issues based upon public, regulatory, and legal actions. Since odors are generally enforced through nuisance regulations, compliance can be difficult to achieve, not to mention almost impossible to define. Enforcement of odor nuisances is subjective, usually at the discretion of an environmental inspector or Air Pollution Control Officer, and often based upon citizen complaints. When citizen complaints mount, and enforcement action is leveraged, lawsuits often surface as an added ongoing challenge to waste facility operations. Now politicians are demanding action and using alleged odor violations as part of their environmental platforms. Facing odor issues can be costly and threaten the intended land-use designs that waste facilities require to serve their local communities.
Register for SCS Engineers’ January webinar to learn more about the proactive strategies and practices you can implement at your critical solid waste facilities. This free webinar will help you develop capabilities to assess the potential for odor issues and, by doing so, set realistic benchmarks toward cost-effective and meaningful mitigation measures.
DATE: Thursday, January 21, 2021 TIME: 2 p.m. ET
Our panelists bring comprehensive expertise to the table, including facility design and planning, technical experience in air quality compliance and pollutant dispersion and air measurement programs, atmospheric dispersion and transport of airborne pollutants, particularly in the area of complex terrain. They will provide decades of strategies, resources, and best practices and technologies based on successful solutions that help support your facility as you prepare for, and likely will, experience odor complaints.
The team answers questions throughout the presentation, and the second portion of the program is devoted to Q&A and idea exchange.
Pat Sullivan discusses two case studies that provide examples of two different approaches to odor management. The proactive approach resulted in a more positive outcome than the reactive approach. Although the odor issues never go away completely, the proactive facility has avoided lawsuits and regulatory enforcement and continues to have a positive working relationship with the community.
SCS Engineers freely shares our articles and white papers without imposing on your privacy.
Click to read Part I of this two part series. We’ll let you know when Part II is published soon.
Reprinted from SWANA Alert:
On Tuesday, August 1, the U.S. Environmental Protection Agency (EPA) will be holding a public hearing in Washington, DC on the proposed rule, ‘‘Renewable Fuel Standard Program: Standards for 2018 and Biomass-Based Diesel Volume for 2019.’’ In keeping with SWANA’s previous advocacy efforts in regards to the renewable fuel standard (RFS) program, we intend to submit a short written statement to be introduced into the hearing record.
The RFS program is a national policy that requires a certain volume of renewable fuel to replace or reduce the quantity of petroleum-based transportation fuel, heating oil or jet fuel. These amounts are set by EPA each year and the proposed rule will set those levels for 2018. One of the four fuel category amounts that will be set by the RFS is cellulosic biofuels, which includes compressed and liquefied renewable natural gas (RNG) produced from landfill biogas.
As a member of the SWANA Core Advocacy Group, we are notifying you that SWANA intends to submit comments to EPA on the RFS program as part of the August 1st hearing, and in post-hearing comments that EPA will be accepting through August 31st as necessary. These comments will support the testimony of other solid waste industry leaders and ask the EPA set the 2018 RVO standard for cellulosic biofuel at a level that takes into account increased generation of fuel from both existing registered projects and from new projects that will begin generating fuel in 2018. By setting the levels based upon actual current and future capacity instead of on historical data and trends, EPA will ensure that the levels set actually spur demand consistent with increased production. A failure to set the levels high enough would result in a lack of appropriate demand for these fuels, which would undercut the purpose of the RFS program
By setting the levels based upon actual current and future capacity instead of on historical data and trends, EPA will ensure that the levels set actually spur demand consistent with increased production. A failure to set the levels high enough would result in a lack of appropriate demand for these fuels, which would undercut the purpose of the RFS program.
If you or the Chapter or Technical Division members have any questions or concerns about these comments, or if you would like to discuss them further, please contact David Biderman at SWANA.
For years, Wisconsin landfills have relied on compliance with the storm water (stormwater) management requirements in the Chapter NR 500 code series to achieve compliance with the NR 216 storm water standards. Effective June 15, 2016, the Wisconsin Department of Natural Resources (WDNR) changed their policy, and now requires landfills and associated non-commercial borrow sites to obtain separate industrial storm water permit coverage.
Read the SCS Engineers Technical Bulletin to determine what action you may be required to take and by what date.
If you have questions or need help filing or developing a plan, please contact:
Betsy Powers, PE
(608) 216-7347
Sherren Clark, PE, PG
(608) 216-7323
Do you have NSPS or EG sites per the new definitions of “new” and “existing”?
Does your EG site have any upcoming planned or permitted expansions, or will it be commencing construction on an expansion permitted after July 17, 2014?
Will you need to submit/resubmit Design Capacity and NMOC reports to establish your sites status as subject to the new NSPS? Over, or under 34 Mg/year of NMOCs?
Are you a candidate for Tier 4? In the closed landfill subcategory?
For EG sites contact the SCS state representative by sending a request to
SCS Engineers will be publishing Pat Sullivan’s Technical Bulletin Summary of Final NSPS/EG Rules for Landfills as soon as it is published in the federal register. Meanwhile, please contact your SCS Project Manager or for answers to your questions or advice. Follow SCS Engineers on your favorite social media site or check our events for new presentations, publications, and webinars explaining the rules in more detail.
