Per- and poly-fluoroalkyl substances (PFAS) are receiving increasing attention from regulators and the media. Within this large group of compounds, much of the focus has been on two long-chain compounds that are non-biodegradable in the environment: PFOS (perfluorooctane sulfonate) and PFOA (perfluorooctanoic acid). Long detected in most people’s bodies, research now shows how “forever chemicals” like PFAS accumulate and can take years to leave. They persist even when excreted through urine. Scientists have even tracked them in biosolids and leafy greens like kale. Recent studies have linked widely used PFAS, including the varieties called PFOA and PFOS, to reduced immune response and cancer. PFAS have been used in coatings for textiles, paper products, cookware, to create some firefighting foams and in many other applications.
Testing of large public water systems across the country in 2013 through 2015 found PFAS detected in approximately 4 percent of the water systems, with concentrations above the USEPA drinking water health advisory level (70 parts per trillion) in approximately 1 percent (from ITRC Fact Sheet.) Sources of higher concentrations have included industrial sites and locations were aqueous film-forming foam (AFFF) containing PFAS has been repeatedly used for fire fighting or training.
Source identification is more difficult for more widespread low-level PFAS levels. For example, in Madison, Wisconsin, PFAS have been detected in 14 of 23 municipal water supply wells, but the detected concentrations were below the USEPA’s health advisory levels for PFOA and PFOS. A study of potential PFAS sources near two of the Madison wells identified factories, fire stations, landfills, and sludge from sewage treatment plants as possible sources, but did not identify a specific source.
With the EPA positioned to take serious action on PFAS in late 2019 and 2020, regulators in many states have already started to implement their own measures, while state and federal courts are beginning to address legal issues surrounding this emerging contaminant. State actions have resulted in a variety of state groundwater standards for specific PFAS compounds, including some that are significantly lower than the USEPA advisory levels. These changes mean new potential liabilities and consequences for organizations that manufacture, use, or sell PFAS or PFAS-containing products, and also for the current owners of properties affected by historic PFAS use.
Questions for manufacturers, property owners, and property purchasers include:
If remediation is required, a number of established options to remove PFAS from contaminated soil and groundwater are available, including activated carbon, ion exchange or high-pressure membrane systems. On-site treatment options, including the management of reject streams where applicable, are also available.
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SCS Engineers welcomes Mark Pearson, P.E, to the firm’s environmental engineering practice. As a Project Director, he and his team will provide water and wastewater engineering and consulting to public and private entities in the region and the U.S. from SCS’s Overland Park office.
Mark brings decades of expertise in environmental engineering, with an emphasis on wastewater design for water treatment plants, wells, pumping stations, and including sewers and waterlines. His experience includes project management through facility planning, design, and construction phases; a good fit for SCS’s comprehensive solutions.
A Professional Engineer licensed in three states, he supports clients with the design, construction, and implementation of environmental treatment systems for water and wastewater plants and post-industrial use, reuse, and the disposal of liquids. Mark helps support industries and landfills facing increasing regulatory policies, higher standards required by water treatment plants, and the rising costs associated with protecting water supplies.
Mark has worked on a wide range of projects around the world and in the United States. He is a certified Envision Sustainability Professional (ENV SP) and a member of the National Council of Examiners for Engineering and Surveying (NCEES). He earned his bachelor’s degree in civil engineering from the Missouri University of Science and Technology, and his master’s degree in environmental engineering from California State University-Long Beach.
“Mark’s expertise and knowledge enhance SCS’s ability to provide sustainable process treatment design and wastewater solutions to industrial and landfill clients who are responsible for leachate and liquids management, which is a significant operational expense for them,” stated Nathan Hamm, a Vice President of SCS Engineers and Central region lead in the Liquids Management program.
Join SCS Engineers’ professionals at WEFTEC, the Water Environment Federation’s Technical Exhibition and Conference addressing a diverse and comprehensive list of contemporary water and wastewater issues and solutions including:
Collection Systems – Management, operations and maintenance, infrastructure, overflow reduction, wet weather planning, watershed approaches, and regulations
Energy Conservation and Management – Resource recovery, combined heat and power, biogas optimization
Membrane Technologies – Application in wastewater and water reuse, innovations, enhanced performance, regulatory compliance
Plant Operations and Treatment – Innovations, technologies, processes, and proven solutions in water and wastewater treatment; including nutrient removal and odor control
Regulations – CMOM/SSO Rules, TMDL/Watershed Rules, Nutrient Trading, and NPDES Phase II
Research – Leading-edge process applications in water and wastewater treatment and recent developments
Residuals & Biosolids – Incineration, disposal, reuse through land application, research, regulations, politics, and public perception
Stormwater – Treatment, green infrastructure, wet weather management, modeling
Utility Management – Asset Management and financial planning for infrastructure, technology, regulatory compliance, and security; including environmental management systems (EMS)
Water Reuse/Recycling – Research, regulations, emerging technologies, proven processes
Water Quality & Watershed Management – Stormwater, wet weather, and watershed issues
This EREF Summit will bring together practicing engineers, academics, industry professionals, government personnel and policymakers to facilitate discussion and provide various perspectives on the management, issues, and policies related to PFAS.
Per- and polyfluoroalkyl substances (PFAS) are a group of compounds that are man-made and are commonly used in industrial processes and consumer products such as food packaging, fire-fighting foams, metal plating, outdoor gear, popcorn bags, food wrappers, facial moisturizers, mattresses, carpeting, and cookware. Despite the widespread use of PFAS in everyday products, there are still significant knowledge gaps associated with the management of these compounds.
SCS Engineers is a sponsor of this EREF Summit. Liquids Management at SCS Engineers
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
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.
Meet SCS Professionals and visit us at Booth 311, get inspired, and find the answers to your waste & recycling challenges at WasteExpo, May 6-9, at the Las Vegas Convention Center.
Enjoy an interactive conference program. With technology and innovation as the underlying themes, expect a conference program that dives deep into recycling/landfill, fleet management/collection, organics, safety, food recovery, and more! The WasteExpo Conference Program, in partnership with the National Waste & Recycling Association (NWRA) and Dr. Stu Buckner, is designed to sharpen your skills to help you run your business or department smarter, safer, and more streamlined.
Monday, May 6, Highlights!
Composting, Organics Recycling, Biogas Track
10:45 am – 12:15 pm
Composting Infrastructure Development, Public-Private Partnerships, Air Permitting Requirements, Technology Innovations
Featuring Patrick Sullivan‘s discussion Survey of Air Permitting Requirements for Composting Facilities Across the U.S.; tools for composting partnerships; managing high solids digestate; the financial and operational benefits of pilot scale recycling projects.
Processing & Disposal Track
3:15 pm – 4:30 pm
Swiping Right: Which Leachate Management Solution Best Suits Me?
Join this panel of experts comprised of leading experts from SCS Engineers, Waste Management, John Zink, WEHRLE, and landfill operators for an all-inclusive review of present designs, operational practices, and technologies considered as part of a sustainable long-term solution for leachate management. Expect to learn the leachate management solutions that best suit your own operations and facilities. Learn about best practices, holistic approaches to leachate and liquids management using flow rate and leachate chemistry, membrane bioreactor (MBR) technology, leachate evaporation, and deep well injection. Plus what to watch out for in 2019 and beyond.
Tuesday, May 7, Highlights!
Composting, Organics Recycling, Biogas Track
9:00 am – 10:15 am
Composting: Increasing Processing Capacity, Improving Process Management, Minimizing Contamination
Join Tracie Onstad Bills for her presentation Methods to Achieve .5% Contamination in Organics; along with improvements to maximize processing capabilities; and a look at high-tech composting.
Food Recovery Forum Track
4:30 pm – 5:45 pm
Source Separation and Collection in Commercial and Municipal Programs: BMP’s, Data Collection and Evaluation, Lessons Learned, Case Studies
In this lively session, Lisa Coelho presents Split-Cart Food Scraps Recycling; plus how to achieve continuous program improvements; capture more and reduce contamination at the source; followed by BMPs for collection from customers.
Wednesday, May 8, Highlights!
Processing & Disposal Track
10:30 am – 11:45 am
Data, Drones & Case Studies: The Latest Trends in Landfill Management
This fast-paced session addresses the latest tools and trends being used in landfill management and focuses on four different case studies including SCS Engineer’s SCS Remote Monitoring and Control® – SCS RMC® system for landfill systems including flares, landfill gas, and leachate systems to identify, troubleshoot, and solve real problems effectively and efficiently. The session continues with how the World Bank recently utilized drone technology for the St. Maarten landfill; the City of Barrie’s municipal solid waste landfill reclamation and remediation; and EREF results from the first comprehensive analysis of leachate quantity and quality and management practices across the U.S.
Deep injection wells (DIW) mean different things in different parts of the country. In the midwest DIWs have been used for decades to dispose of industrial wastewaters, mining effluent, and produced water from oil and gas production activities and are from 3,500 feet to more than 10,000 feet deep. In Florida, deep injection wells have been used since the 1960s; however, they are used to dispose of treated municipal wastewater, unrecyclable farm effluent, and in some cases landfill leachate. DIWs in Florida range from 1,000 feet to around 4,500 feet deep.
This is a two-part blog, the first part discussing what constitutes a DIW, their general features, their cost relative to other wastewater management alternatives, and the range of industrial wastewaters suitable and safe for disposal. The second part, covered in the next SCS Environment issue, will be on the challenges for deep well developers created by public and environmental organizations, and strategies to counter misinformation and means to obtain consensus from stakeholders.
A DIW construction is a series of casings set in the ground where the initial casing starts out large and subsequent casings become smaller in diameter, progressively telescoping downward. Casing materials are typically steel alloys or fiberglass for better chemical resistance. As a casing is set and rock is drilled out, the next casing is set and cemented with a chemically resistant grout. The process continues with each progressively deeper casing. These redundant “seals” are what keep the injected liquid from escaping into the protected aquifers.
A DIW typically has three upper casings to protect the aquifers and isolate the wastewater to the desired disposal zone. The inner casing, called the injection tube, extends to the injection zone. Mechanical packers seal the space between the injection tube and the last casing with the annular. The resulting annular space is filled with a non-corrosive fluid. This fluid is put under pressure to demonstrate the continuous mechanical integrity of the well. The annulus is monitored for potential leaks, which would register as a loss in pressure and promptly stop the injection. Figure 1 is a simplified view of a DIW casing system used in south Florida.
Vertical turbine pumps working in conjunction with a holding tank, which is a used to smooth out the fluctuating flow of the wastewater feed pumps, propel the liquid down the well. As part of the permitting efforts, a chemical compatibility study is conducted to determine the level of pre-treatment if any to protect the well components and minimize downhole plugging. Municipal wastewater effluent is regulated differently and must receive at least secondary treatment before injection.
In the Midwest, DIWs are constructed to the same EPA criteria with a wide range of operating conditions. Some wells take fluid under gravity with no pumping, while others require higher pressure pumps that exceed 2,500 psi for injection. This blog focuses on wells used in Florida and typical fluid types and operational parameters.
In central and south Florida the injection zone lies below the underground sources of drinking water (USDW) which is the depth at which water with a total dissolved solids (TDS) concentration exceeds 10,000 parts per million (ppm); or the “10,000 ppm line”. This water is considered to be unusable in the future as a drinking water source. In parts of Florida, the injection zone is dolomite overlain by a series of confining units up to 1,000 feet thick made up principally of limestone with permeability several orders of magnitude less than the injection zone. (1)
In central and south Florida the target injection interval is the “Boulder Zone,” reportedly named because drilling into the formation often broke off pieces of the formation and made drilling difficult. The Boulder Zone is also known as the lower portion of the Floridan Aquifer. Later down-hole imaging technologies revealed this zone to be characterized by highly fractured bedrock and large karstic caverns, and the ability to inject relatively high flow rates with relatively little backpressure. It is not uncommon for Florida DIWs to have well flow rates exceeding 15 million gallons per day (MGD) and backpressures ranging from 30 up to 100 pounds per square inch (psi).
The versatility of the DIW in Florida to accommodate numerous different types of wastewater is an advantage. DIWs are being used on a large variety of waste streams that continues to expand, including:
Any wastewater considered for disposal must be compatible with the target formation and the final casing material. Therefore, depending on the wastewater, it may be straightforward to use existing industry references to confirm compatibility. In some cases, laboratory bench tests may be necessary to confirm compatibility.
Compatibility also includes the potential for creating unwanted microbial growth and scale formation within the injection interval. Growth and scale can happen with effluent containing sulfur or ammonia, two food sources for microorganisms or wastewaters supersaturated with minerals. Unless planned for and evaluated properly, both of these items have the potential to grow and clog the formation around the well, significantly reducing flow and increasing back pressure. This can result in higher energy costs, regulatory action and significant, unplanned costs to rehabilitate the well.
Another significant aspect of municipal wastewater is that they are primarily composed of freshwater and thus when injected into the highly saline Boulder Zone or similar saline zones, will tend to have a vertical migration component because of the density difference and greater buoyancy than the target zone. A few wells have been taken out of service because the seals designed to prevent this migration failed and allowed wastewater to seep upwards into the USDW.
The US EPA Underground Injection Control (UIC) program is designed with one goal: protect the nation’s aquifers and the USDW. There are several protective measures in a DIW that are intended to meet this objective;
The U.S. EPA conducted a study in 1989-1991 of health risks comparing other common and proven disposal technologies to deep wells injecting hazardous waste. The U.S. EPA concluded that the current practice of deep well injection is both safe and effective, and poses an acceptably low risk to the environment. In 2000 and 2001 other studies by the University of Miami and U.S. EPA, respectively, suggested that injection wells had the least potential for impact on human health when compared to ocean outfalls and surface discharges(3). William R. Rish examined seven potential well failure scenarios to calculate the probabilistic risk of such events.These scenarios included four types of mechanical failures, two breaches of the confining units, and the accidental withdrawal of wastes. The overall risk was quantified by Rish as from 1 in 1 million (10-6) to 1 in 100 million (10-8) (4), which is no greater than the current EPA risk criteria for determining carcinogen risk. As a comparison, 10-6 is the same risk level used by EPA for contaminants in soil or groundwater that are a known carcinogen.
There are several studies in Florida conducted by researchers and practitioners in the deep injection well field to assess the actual potential for municipal wells to contaminate the USDW. The maximum identiﬁed risk associated with injection well disposal of wastewater in south Florida is the potential migration of wastewater to aquifer storage and recovery (ASR) wells in the vicinity of injection wells (Bloetscher and Englehardt 2003; Bloetscher et al. 2005).
In a 2007 study, 17 deep wells in south Florida, used for municipal waste disposal, that had known upward migration into the USDW, were evaluated to develop a computer model to simulate these phenomena and extrapolate vertical migration over longer time periods. The results indicated that the measured vertical hydraulic conductivities of the rock matrix would allow for only minimal vertical migration. Even where vertical migration was rapid, the documented transit times are likely long enough for the inactivation of pathogenic microorganisms (5).
In a 2005 study of 90 South Florida deep injection wells, the authors took actual field data and constructed a computer model calibrated to actual operating conditions. The intent was to model performance of two injection wells in the City of Hollywood, Florida that the authors were familiar with and to determine the likelihood of migration, and what might stop that migration. Density differential and diffusion were likely causes of any migration. No migration was noted in Hollywood’s wells. The preliminary results indicate that Class I wells can be modeled and that migration of injectate upward would be noticed relatively quickly (3).
A deep injection well lifecycle cost compares favorably with other traditional waste treatment and disposal techniques. A life-cycle cost includes the capital cost and operating and maintenance costs for the useful life of the system. On a recent project, the wastewater for disposal was groundwater contaminated with ammonia nitrogen from a former landfill. The estimated groundwater recovery rate and the deep injection well disposal rate was calculated to be 1.2 million gallons per day (MGD). The proposed deep well was designed to have a final casing of 12-inch diameter, an 8-inch diameter injection tubing to a depth of 2,950 feet, and below that approximately 550 feet of open bore hole. The lifecycle cost estimate comparison to other viable technologies is shown in the Table below.
In this case, there were no projected revenues, so the alternative with the lowest net present value (NPV) would technically be the preferred alternative. Even though the aerated lagoon had the lowest NPV, it was ultimately judged too risky with a long break-in treatment period and significantly more space for treatment ponds needed.
The increasingly stringent surface water discharge standards are an ongoing challenge for industries generating a wastewater stream. DIW’s should be considered as a potentially viable option for long-term, cost-effective wastewater disposal, where a viable receiving geologic strata exists and when wastewater management alternatives are evaluated. In Florida, they currently provide an environmentally sound disposal option for many regions.
Within the SCS Engineers’ website, you will find the environmental services we offer and the business sectors where we offer our services. Each web page offers information to help you qualify SCS Engineers and SCS’s professionals by scientific and engineering discipline.
We provide direct access to our professional staff with whom you may confidentially discuss a particular environmental challenge or goal. Our professional staff work in partnership with our clients as teams. We are located according to our knowledge of regional and local geography, regulatory policies and industrial or scientific specialty.
It’s been 10 years since the first Research, Development, and Demonstration (RD&D) Plans were approved allowing liquids to be applied to municipal solid waste landfills in Wisconsin. What have we learned?
Under an approved RD&D Plan, landfill operators can apply liquids other than recirculated leachate to the waste at municipal solid waste landfills. The RD&D Rule was published by US EPA in 2004, and states had the option of adopting the rule and issuing RD&D approvals. Wisconsin was an early adopter, and 13 of the approximately 30 landfill sites in the US with RD&D approvals are in Wisconsin.
This presentation will look at data from the Wisconsin landfills with RD&D Plans. Each site is required to report annually on a very detailed basis. For this presentation we will zoom out and look at the data on an aggregated basis to address big-picture questions. What are the trends in volumes applied for leachate recirculation versus RD&D Liquids? How do these volumes compare with precipitation? What liquid waste streams have been accepted and how have they been applied? How has RD&D liquid application affected landfill gas generation?
We will also provide an update on the regulatory status of the RD&D rule. On May 10, 2016, a final federal rule was published that revised the maximum permit term from 12 years to 21 years; however, WDNR will have to adopt this change in order for it to be available to Wisconsin landfills.
SCS Engineers offers innovative, cost-effective wastewater solutions supporting leaders in solid waste, construction, manufacturing, and mining overcome their liquids management challenges. Click to read and share our interactive brochure, or click directly to your industry below:
Landfill Leachate Engineering
Our innovative use of landfill assets and technology means we can provide superior upstream solutions to reduce leachate production, as well as cost-effective downstream solutions for leachate management and treatment. We also offer a powerful tool for tracking and analyzing leachate information from multiple data collection points. SCSeTools® Leachate Module enables our clients to evaluate disposal trends and effectively manage disposal costs.
Dewatering Contaminated Sites
Our responsiveness, experience on large and complex projects, and strong relationships with regulators means our clients can avoid costly delays on construction projects, where contaminated groundwater is discovered.
Industrial Wastewater Pre-treatment
We deliver comprehensive solutions for our clients’ industrial wastewater pre-treatment requirements, from feasibility studies to permitting, designing, operating and monitoring treatment systems.
Deep Well Injection
We have extensive experience in providing this often overlooked but highly effective solution for treating and managing liquid waste.