Regulatory movement around PFAS is picking up; this year and next could be monumental around managing these toxic compounds in landfills and leachate. Operators should look out for proposed U.S. Environmental Protection Agency (EPA) rules in 2022 and final rules in 2023. Most notably, two PFAS categories, PFOA and PFOS, could be classified as hazardous wastes under the Resource Conservation and Recovery Act (RCRA) and the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA), aka Superfund. Also, expect rules on monitoring and limiting PFAS in drinking water.
Amidst this regulatory activity, PFAS treatment research advances, which will be critical to landfill operators when they are charged with managing this very challenging stream. With existing options, it’s near impossible to destroy these “forever chemicals,” known for their carbon-fluorine bond, considered one of the strongest in nature.
SCS Engineers’ Gomathy Radhakrishna Iyer advises operators on what to look for to brace for regulatory change and advises them on their best defense—the treatment piece. She explains current options and potential technology breakthroughs on the horizon.
“On the legislative front, standardized guidance might not happen overnight. There’s much to learn, as leachate is not the same, including as it pertains to PFAS. Concentrations and compounds vary. So, EPA is gathering data and knowledge to inform policy and mitigation options moving forward,” Iyer says.
Today’s focus entails developing and validating methods to detect and measure PFAS in the environment. The EPA is evaluating technologies to reduce it and is trying to understand better the fate and transport of PFAS in landfills (including landfill gas, leachate, and waste).
While PFAS concentrations in leachate sent to publicly owned treatment plants (POTW) are unknown, the EPA 2023 rule aims to fill in the missing pieces. What is learned and subsequent decisions will be critical to landfill operators who depend on POTWs as a final destination for leachate and at a time when POTWs meet stringent guidelines on what they can accept. The EPA’s focus will begin with guidance on monitoring and reporting figures, including a list of PFAS to watch for in 2022.
In the meantime, the agency published interim guidance on destroying and disposing of PFAS, which it plans to update in fall 2023. The interim guidance identifies the information gap with regard to PFAS testing and monitoring, reiterating the need for further research to address the FY20 National Defense Authorization Act NDAA requirements. Operators can also look to SWANA treatment guidelines to help prepare for new rules.
Get ahead of the game by doing your homework on treatments, Iyer advises. POTWs have discharge limits, and once PFAS in leachate is weighed in with the existing constituent limits on permits, ensuring a disposal destination will call for proactive measures.
The discussion on treatments will be important. Iyer advises on staying up with expectations that may be in the pipeline, beginning by focusing on today’s commercially available options:
Comparing these methods, Iyer says, “Biological treatments work better simply as a pretreatment method, removing PFAS to some extent. Their performance may also only apply to non-biodegradable organic matter. Considering these limitations, the alternative of physical-chemical treatments is most often recommended by industry experts; they appear to be more effective as supported by data,” Iyer says.
Her preference is RO, the membrane-enabled separation process, which many treatment plants already use, or are considering, to remediate other constituents. “Because we know RO to be effective with other contaminants and PFAS, I think it’s a great gainer, especially if plants already use this method to treat leachate for other contaminants successfully,” she says.
RO requires relatively little operational expertise, while other physical-chemical methods, such as GAC and ion exchange, require some chemistry knowledge.
“With granular activated carbon and ion exchange, resins attach to contaminants in leachate. These approaches require pretreatment for organics removal, process understanding, and operator involvement. Conversely, with RO, you learn a fairly straightforward process and move through the steps,” she says.
But while physical-chemical treatments are the best readily available options today, each has limitations. RO leaves a residue requiring further treatment; then, the material is typically recirculated in landfills as a slurry or hauled to a POTW, meaning there is no guarantee they will not need to be addressed later. Other methods, such as GAC, are more energy-intensive and have limited sorbent capacity. Ion exchange, in particular, has difficulty removing short-chain PFAS, which persist in the environment.
When the time comes that PFAS have stringent discharge limit requirements, no one of these technologies may work as a standalone, so the search is on for more robust systems.
Several new treatments are under research; unlike their predecessors, they appear to break the chemical bond.
Iyer shares her take on each option:
“I’m especially interested in seeing how plasma treatment works in the real world versus the lab. The building costs can be higher, and leveraging electricity to break the bond is expensive. But the maintenance should be easy and relatively inexpensive compared to other technologies. It will be interesting to see how economical it would be for landfills over the long run.”
There is more to learn about each of these new technologies. Researchers are working to identify the adsorbents that best suit PFAS compound removal, whether short or long chains. With photocatalytic reaction, a research direction is exploring combining UV rays, a catalyst, and an oxidant to degrade PFAS.
“We know that the absorption options and photocatalytic concepts work well on strong contaminants,” Iyer says. She moves on to her thoughts on thermal treatment. She wants to know more about this particular option before weighing in. “I’m not sure how feasible this method will be for the operators. PFAS get destroyed at a temperature greater than 1,000 degrees Celsius. But for high quantities of leachate, this option could be expensive.”
Most EPA-funded research is based on these developing treatment processes. But there is plenty to evaluate to identify the best solutions in a given scenario. With that understanding, the agency is trying to understand the types and volumes of PFAS generated, how they change or degrade as they enter landfills, and where they originate. EPA is building a database to track this information to consider key characteristics of individual PFAS to help guide forthcoming guidance on treatments.
In the meantime, Iyer advises operators to pay close attention to evolving developments and communications from EPA.
We recently saw the memorandum from EPA on addressing PFAS discharges in EPA-issued NPDES permits. We will look for guidance to the state permitting authorities to address PFAS in NPDES permits soon and more information from the EPA’s roadmap.
At SCS, we use our time to learn about technologies, including what’s still under investigation and explore what seems to work. In addition, watch for guidance documents, not just from EPA but from research organizations such as EREF and universities. Do your due diligence and keep your eyes and ears open for EPA and your state regulatory authority announcements. Staying informed is the best strategy for landfill operators at this point.
In a letter to Congress, SWANA and NWRA associations request that regulation under the Comprehensive Environmental Response,Compensation, and Liability Act (CERCLA) for addressing per- and polyfluoroalkyl substances (PFAS) contamination assign environmental cleanup liability to the industries that created the pollution in the first place. Both associations note that MSW landfills and solid waste managment, an essential public service do not manufacture nor use PFAS. The industry, and ultimately the general public should therefore not be burdened with CERCLA liability and costs associated with mitigating PFAS from water and wastewater.
May 10, 2022
Re: Relief for Municipal Solid Waste Landfills from CERCLA Liability for PFAS
Dear Chairman Carper, Ranking Member Capito, Chairman DeFazio, Ranking Member Graves, Chairman Pallone, and Ranking Member McMorris Rodgers:
The municipal solid waste (MSW) management sector strongly supports the goal of addressing per- and polyfluoroalkyl substances (PFAS) contamination and holding accountable manufacturers and heavy users of these compounds. We are concerned, however, that regulation under the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) instead would assign environmental cleanup liability to essential public services and their customers. We therefore request that Congress provide MSW landfills and other passive receivers with a narrow exemption from liability if certain PFAS are designated as hazardous substances under CERCLA. Doing so would keep CERCLA liability on the industries that created the pollution in the first place.
• Landfills neither manufacture nor use PFAS; instead, they receive discarded materials containing PFAS that are ubiquitous in residential and commercial waste streams. MSW landfills and the communities they serve should not be held financially liable under CERCLA for PFAS contamination, as landfills are part of the long-term solution to managing these compounds.
• Landfills are essential public services that are subject to extensive federal, state, and local environmental, health, and safety requirements. Further, MSW landfills are important to managing and limiting PFAS in the environment, as recognized by the Environmental Protection Agency (EPA) in its December 2020 draft Interim Guidance on the Destruction and Disposal of [PFAS] and Materials Containing [PFAS].
• Just as certain airports are required by law to use firefighting foam containing PFAS, permitting authorities often require landfills to accept waste streams containing PFAS.
• Most landfills rely on wastewater treatment facilities for leachate management. Wastewater and drinking water facilities increasingly rely on landfills for biosolids management and disposal of PFAS-laden filters. Efforts to address PFAS at MSW landfills and drinking water and wastewater facilities must avoid disrupting this interdependence among essential public services to communities.
• Landfill leachate typically represents a minor proportion of the total quantity of PFAS received at wastewater treatment facilities from all sources. PFAS manufacturers or users, by comparison, contribute PFAS at levels that can be orders of magnitude higher than landfills.
Significant Economic Impacts
• Removing PFAS from landfill leachate requires advanced treatment techniques which are prohibitively expensive. Estimated capital costs to implement leachate pretreatment at a moderate-sized landfill to the extent necessary to significantly reduce PFAS range from $2 million to $7 million, with nationwide costs totaling $966 million to $6.279 billion per year for the solid waste sector. Trace concentrations of PFAS nevertheless would remain in leachate following pretreatment, exposing landfills to CERCLA liability.
• Absent relief from CERCLA liability, manufacturers and heavy users of PFAS compounds will bring claims for contribution against landfills and other passive receivers, generating significant litigation costs. EPA’s exercise of enforcement discretion will not insulate landfills from this litigation.
• These costs will be passed along to communities, water and wastewater treatment facilities, and biosolids management, all of which rely on the services of MSW landfills.
Broad Unintended Consequences
• CERCLA regulation will impel landfills to restrict inbound wastes and/or increase disposal costs for media with elevated levels of PFAS, including filters, biosolids, and impacted soils at Department of Defense facilities. The mere prospect of regulation in this area is already disrupting the interdependence of the drinking water, wastewater, and solid waste sectors.
• Food waste compost may contain PFAS due to contact with PFAS-lined packaging materials. As a result, a CERCLA designation could result in communities diverting food waste from organics recycling programs, hindering federal, state, and local climate and waste reduction goals.
• Cost increases likely will have a significant disproportionate impact on low-income households that rely on the affordability of services that the solid waste sector provides.
Although our sector is simultaneously pursuing “no action assurance” from EPA, the agency historically has been very hesitant to provide this relief given its policy that assurances should be given only “in extremely unusual cases.” As such, and acknowledging that EPA may have limited authority to act on our request, we recommend providing the following narrow exemption from CERCLA liability that affords relief to landfills and other passive receivers of PFAS1:
(a) IN GENERAL.—No publicly owned or operated community water system (as defined at 42 U.S.C. 300f), publicly owned treatment works (as defined at 33 U.S.C. 1292), or municipal solid waste landfill (as defined at 40 C.F.R. 258.2) shall be liable under the Comprehensive Environmental Response, Compensation, and Liability Act of 1980 (42 U.S.C. 9601 et seq.) for the costs of responding to, or damages resulting from, a release to the environment of a perfluoroalkyl or polyfluoroalkyl substance designated as a hazardous substance under section 102(a) of such Act that resulted from the discharge of effluent, the disposal or management of biosolids, the disposal of filtration media resin, or the discharge of leachate where such actions are in compliance with Federal or State law and all applicable permits.
(b) EXCEPTION.—Subsection (a) shall not apply with respect to any discharge described in such subsection that results from any gross negligence, willful misconduct, or noncompliance with any Federal or State law or permit governing the discharge of effluent, disposal or management of biosolids, disposal of filtration media resin, or waste disposal.
Thank you for your consideration of our request, and we look forward to continuing to partner with the federal government to ensure the safe and effective management of waste streams containing PFAS.
National Waste & Recycling Association
Solid Waste Association of North America
cc: Senate EPW Committee Members
House T&I and E&C Committee Members
1 The exemption would not extend to underlying soil and groundwater contamination from a MSW landfill or to facilities other than MSW landfills that accept waste streams with elevated concentrations of PFAS.
Clients, regulators, and environmental engineers participated in the SCS December forum. Samuel Cooke, PE/chemist; Nathan Hamm, PE/landfill liquids engineer; and Monte Markley, PG/deep disposal well expert, deliver valuable information and insights in this 70-minute session. They answer your questions about how leachate treatment and disposal preplanning can uncover efficiencies and open up options for managing landfill leachate and PFAS.
You work hard to stay on top of a diverse and complex mix of leachate contaminants — heavy metals, ammonia, and biochemical oxygen demand, among them. Lately, we have even more to think about, including keeping concentrations of these contaminants within the wastewater treatment plant’s tightening discharge limits and addressing compliance pressures as the list of constituents on regulators’ radar grows.
Exploring leachate treatment options to find the most fitting and cost-effective one takes vetting by a team of experts and field experience. For SCS’s December discussion and Q&A, our panelists brought their decades of expertise helping landfills, manufacturers, and waste facilities find more options and the most sustainable solutions and practices.
Additional Resources for Planning, Managing, Monitoring, and Treatment
Monitoring leachate, pumps, pressures, and more:
Scientific & Technical Studies/Resources
Michael Simms – Appointed by the Governor to the Louisiana Board of Professional Geoscientists
The Louisiana Board of Professional Geoscientists oversees the approvals of hydrogeologists and like scientific professionals in the state. This is quite an honor for Mike, a hydrogeologist with more than 30 years of experience. He learned of the appointment earlier this month and just had his first meeting.
Hydrogeologists are attempting to solve some of the big questions facing the world today, including sustainable water supply, food and energy production; environmental protection; and coping with climate change. They work closely with a wide range of industries to protect groundwater and much, much more.
SWANA is optimistic regarding the positive role modern MSW landfills can play in managing solid waste – such as carpeting and clothing – containing PFAS. By disposing of these products in landfills and effectively treating landfill leachate for PFAS removal, the solid waste industry can provide society with an effective and proven method of managing PFAS wastes.
In support of members, the SWANA Applied Research Foundation (ARF) has issued a report summarizing and analyzing management options and treatment technologies that can address PFAS chemicals contained in landfill leachate on November 10, 2021. PFAS Management and Treatment Options for Landfill Leachate is available to SWANA ARF subscribers.
The research findings presented in the resulting report are based on a comprehensive review of the literature and an analysis of the commercially-available PFAS treatment systems and other management options for landfill leachate.
The new report serves as a companion report to one published by the ARF in June 2021 on PFAS Fate and Transport in WTE Facilities, available in SWANA’s Reports List.
Accumulating liquids are problematic for landfills taking sludges and other wet wastes not traditionally part of the incoming waste stream. Add to the mix increasing precipitation, and operators could be staring down the perfect storm—especially as they work to optimize their gas extraction systems. Here’s the challenge, explains Pete Carrico, SCS Engineers Senior Vice President and national expert on liquids management:
“Trash is porous, and the soils used for daily and intermediate cover usually aren’t, so liquid gets trapped between alternating trash layers as the landfill fills. These “perched” liquids can drain into well columns and block the slotted portion of the extraction well piping that withdraws gas from waste and into the gas collection system.”
Even a robust vacuum on the wells will not pull gas once pipes fill with fluid. With no path to move it from trash into the collection infrastructure, operators work harder to stave off odor and slope stability issues, among potential resulting problems.
The good news is they have a recourse to remove the liquids, unblock well perforations, and extract more gas. They do it by installing dewatering systems: an intricate network of pneumatic pumps, air lines to power them, and conveyance lines, also known as force mains, to remove liquid.
Manufacturers have designed and redesigned their pumps to try and address problems specific to landfill gas extraction systems. And the equipment does the job but requires meticulous attention and skill to keep all the moving parts going. These liquids are rough on pumps due to their harsh nature. The suspended solids and biological material they contain are the biggest challenges, and if the landfill has high temperatures, these liquids can heat up, further taxing the system, Carrico says.
“No pump indefinitely survives the challenging conditions you have in landfills. So, where we can make the biggest difference is with these maintenance programs,” Carrico says. You’re spending O&M budget on what provides the most impact.”
SCS uses dedicated, factory-trained pump crews who focus solely on operating and maintaining gas extraction dewatering systems. These crews help ensure the infrastructure functions as it should, and gas moves through well piping slots, into the gas header piping, and to the blower/flare station for beneficial end-use.
“Operations run more smoothly with these crews in place. An SCS field crew is as unique as each landfill. Our specialists have various skill sets, i.e., gas collection system monitoring, surface emissions monitoring, or pump maintenance expertise. That’s how we produce better outcomes in terms of pump performance. If you effectively maintain and repair the pumps, you will restore them to their designed specifications, pump more liquids, and with greater ease,” Carrico says.
The teams, who work on landfills across the country, stay busy. One site can have five to 300-plus pumps, each with multiple components, and they must be removed and cleaned frequently.
Replacing worn, fouled, or damaged components is an especially tedious and complex job.
Some wells are 70 to 100 feet deep. Pulling air lines, liquid lines, and pumps out from that depth is hard and requires special equipment to do safely. SCS crews know how to take them apart and put them back together; they don’t just lower them back in the ground after working on them. But hook them up to air and water lines and watch them work at capacity before returning them to service.
It’s a value add; with a good maintenance plan and the right crew, pumps can be kept at their designed specifications and run efficiently for many years. They can typically be cleaned and reset for a fraction of their replacement cost.
“We leverage our size and resources. We have a deep bench of in-house experts and engineers willing to share information to help with problems, which is important as conditions vary at each site, as can problems and solutions. So, it’s important not to do this in a silo but rather pull from our broader knowledge base,” Carrico says.
Technology helps too, especially with tracking, maintaining, and reporting progress to clients. A geographical information system (GIS) maps each well’s location, and pump technicians upload data corresponding to each one from wireless tablets almost instantaneously.
The ability to automate tracking and display critical information right away on a dashboard has increased our program’s efficiency. Technicians spend less time tracking and look at analyses of all the landfill conditions to know where to concentrate their efforts, Carrico says.
A few landfills are working to avoid pumping liquids altogether. They are building large gabion rock structures at the landfill’s base, with piping that connects to the extraction well system, creating a conduit. Liquids automatically drain to the bottom where leachate is intended to go while effectively pulling more gas into the gas collection system.
“This is a newer trend that some of our clients are already doing. And we are involved supporting the well designs,” Carrico says.
For now, in most cases, achieving the best outcomes is about investing in pumps and a good maintenance program.
“Monitoring and regularly measuring—checking stroke-counters, which show how many times a pump cycles, and checking flow meters to know how many gallons a day a system produces are key to finding savings. It’s how you reduce or prevent catastrophic failures,” says Greg Hansen, Senior Project Manager with SCS Field Services Operations, Maintenance & Monitoring.
To execute properly, Hansen provides this advice for operators setting up a pump program:
Have pump maintenance areas with water, electricity, disposal means for waste liquids, and storage facilities for spare parts and tools. More specifically:
Operators planning on doing maintenance in-house should train their technicians on cleaning, servicing, and testing pumps. Either SCS or the pump manufacturer can provide this training.
Above all, Hansen says, “You need a comprehensive OM&M program. The better the job tuning pumps, the better they do in the field, and the longer they work before being cleaned or repaired. It’s a continual process.”
Landfill operators forever work to stay on top of a diverse and complex mix of leachate contaminants—heavy metals, ammonia, and biochemical oxygen demand, among them. But lately, they have more to think about, for one: how to keep concentrations of these contaminants within the wastewater treatment plant’s tightening discharge limits. Add to this concern the possibility of more compliance pressure as the list of constituents on regulators’ radar grows. Some operators are preparing for what may be down the pike, from microplastics to PFAS and PFOA—with the latter sometimes called the “elephant in the room.”
Among the strategies, some are exploring on-site leachate treatment options, and there are several. Finding the most fitting, sustainable, and cost-effective one takes vetting. Here is the study of a Florida landfill’s informed decision-making process.
A landfill serving an exploding residential and commercial population recently found itself in a predicament when the overburdened municipal wastewater treatment plant stopped accepting leachate from all county waste operations. Pressed to find a credentialed treatment facility quickly, this SCS Engineers client contracted with a private plant, but the arrangement came with a steep price tag. Overnight, the site’s leachate hauling and disposal costs rocketed from just over three cents a gallon to almost 16 cents a gallon. So, the operator turned to SCS Engineers for help vetting a robust and financially sustainable solution. Ultimately, the client wants to eliminate dependence on a third party and better control its destiny to avoid landing in the same predicament.
In answer, SCS is looking into the feasibility of a system that would clean leachate to drinking water standards to be discharged directly to groundwater. The team is wrapping up a comprehensive study of the site’s current operations, system, and leachate composition as it prepares the client to go out to bid.
“Our goal is to position the landfill to be as independent as possible while providing a cost-effective solution to their leachate treatment,” says SCS Engineers Project Lead Kollan Spradlin. He and the SCS liquid management experts backing him have kicked into high gear because time is money. Right now, the landfill generates about 70,000 gallons a day of leachate through much of the year. In the wet season, that figure spikes to about 150,000 gallons a day. At roughly 16 cents, the landfill can shell out over $24,000 a day for leachate disposal during the wet season.
SCS Engineers’ preliminary work begins with compiling crucial information around current leachate generation and future projections and around site-specific characteristics of the liquids. Next, the team vets multiple leachate treatment systems, sizing up each one against the client’s individual needs to ultimately make a recommendation. And, as important, the team makes sure the operator is very clear on how much upfront capital they need to build an effective, reliable system to do the job.
Spradlin and SCS’s liquid management experts are working on an interim solution while developing a long-term plan. The interim remedy is an evaporator fueled by landfill gas, heats and evaporates water molecules.
“With the evaporator, our client’s private disposal volume is reduced by 50,000 gallons a day, significantly cutting disposal costs. But that’s not enough. We want to reduce that expense further and to manage all or the vast majority of the leachate on-site,” Spradlin says.
The ultimate plan is to design a plant that can treat almost 120,000 gallons a day to a quality that can discharge across a spray field at the facility to groundwater. The landfill saves on disposal costs and owns the system rather than paying for an outside operator’s treatment technology.
This Florida landfill relies on SCS’s site knowledge and its past liquids management experience. SCS’ understanding of the systems and daily operations helped the team develop operational measures already reducing leachate generation to make on-site treatment an option.
“We have completed plan design and construction of their collection, storage, treatment, and disposal systems. And that helped to provide insight into reliable, long-term leachate disposal recommendations,” says Bob Gardner, a 41-year veteran of SCS and part of the team supporting this particular project.
“We had knowledge of site fill sequencing, site conditions, and constraints. And this sped up the process of coming up with a modification that works within their operations and infrastructure,” he says.
All of this foundational background is key to identifying client-centered solutions and presenting a comprehensive data package to vendors. “We give bidders the details they need so they can size their equipment appropriately and provide a more accurate budget estimate. We are trying to eliminate bidder change orders resulting from inadequate background information,” Spradlin says.
The team is thinking ahead, evaluating treatment processes that address a wide range of leachate properties and consider constituents that may be regulated in the future.
“We may put in a reverse osmosis system, a membrane bioreactor, or ultrafiltration to reduce constituent concentrations and take out particulates. We design for flexibility to add more treatment technology on the front end or back end to save the client infrastructure costs in years to come,” Spradlin says.
What differentiates SCS from some other environmental engineering firms is its full-service model and deep bench.
“We touch everything at this landfill. And we have a multidisciplinary team, including national liquid management experts whose knowledge we can tap into at any time. So, we can be one-stop, saving the client from having to go to multiple vendors,” Spradlin says.
Sam Cooke is the lead liquid management expert for this Florida landfill. Like his colleague, Gardner, he knows the wastewater treatment problems landfill operators face; he knows the vendors and their technology. And he understands the importance of relationships—with the client, the state agencies, and every party who is key to the client’s success and the community they serve.
“We fully realize that the wastewater-leachate treatment system we design needs to do its job close to 24/7/365. Moreover, it must do it effectively, sometimes under difficult conditions. So, as we design treatment systems and work with equipment suppliers, facility owners, environmental managers, and treatment system operators, we strive to provide added value and support,” Cooke says.
“In this case, we’re using our knowledge to help our client develop a bid package that addresses specific technical requirements but also meets and helps protect their business and financial goals.”
The team has already met with the regulatory agencies to develop a clear permitting path to accelerate plant deployment and ensure the landfill is fully compliant before making the large transition to direct discharge.
By working with vendors and regulatory representatives well before releasing bid documents, SCS has paved a path to leachate treatment independence.
When Melissa Russo’s boss Phil Carrillo told her he thought she should get her drone pilot license, she thought he was kidding. At the time, she worked on SCS’s Remote Control (RMC) team; selling drone services was a part of her job, but she had not thought of flying these unmanned vehicles herself.
Her thirst for competition kicked in when he turned the proposition into a bet. He was going after his pilot license himself; she bet she’d beat his score. They finished in a dead heat, but what started as friendly rivalry ended up bringing a new dimension to Russo’s job— a job that continues to expand in breadth as new opportunities turn up.
Today she not only flies, sells drone services, and teaches others how to sell and fly, but she’s helped bring geographical information systems (GIS) into RMC’s portfolio. How these technologies fit together is RMC remotely collects data from drones and different landfill systems. Then the GIS translates that data into maps, capturing a visual picture of how clients’ facilities’ systems are performing. The GIS piece is one of the latest chapters in the story of Russo’s evolving role (more to come on that).
Piloting is what especially gets her juices going.
“I love working with my team, supporting them in what they do. But when it comes to drones, I like the hands-on experience of flying myself more than telling other people how to do it.”
She controls these small aircraft from a device on the ground, sharply focused on her surroundings while keeping the drone in her sight at all times.
“You have to make sure there are no manned vehicles around; they have the right of way. And there’s a lot of continuous movement on landfills. You’re constantly aware of your surroundings. Is a truck coming? Am I in line with where dumping is going on?”
Flying drones takes muscle and mechanical aptitude.
The drone and case can weigh 45 pounds. And there are a lot of moving parts to assemble and calibrate.
Sometimes it’s manual work, pointing and rotating a remote controller to send a radio signal to tell the drone what to do. But more often, she pilots automated flights that she maps in advance and uploads the flight path specs into software that interfaces with the drone.
“When I’m flying drones, I can access areas where if I had boots on the ground, I couldn’t. I can go and explore just about anywhere, similar to when I dream— only it’s real,” she says.
With any task, she’s laser-focused, concentrating on one part of the picture at a time to grasp the details. She steps back and uses critical thinking, accumulated knowledge, and imagination to take on what’s before her.
The innovation process
“We’re pretty lucky with our timing; new and proven technologies are emerging quickly. I’m one of many SCSers with a deep knowledge of technology and practical experience in the solid waste industry. Together, we can make a difference because we understand the business and operational challenges very well. When I need an expert in another industry, I just reach out to a colleague. The learning process never ends, and each project helps me and my team constantly find better answers.
“My boss is more of a big-picture person; his ideas are huge and amazing. He comes to me with new ideas, and I figure out how to make them work and implement them,” Russo says.
She points to his idea to use proven GIS technology within RMC. She was already using GIS to map methane data, process topographic maps, and stockpile calculations. For instance, she integrates methane values into the GIS and overlaps them with imagery so her clients can zoom in on one well or get a large-scale view of the overall health of the gas collection system. But integrating GIS in new ways to incorporate multiple landfill systems would solve some expensive problems and, better yet, prevent even more expensive mitigation and repairs.
Expanding GIS applications to illustrate multiple landfill systems
“I know drones and how to process drone data. But now that we are expanding applications, I add more layers of landfill data, such as liquids, soil, the gas collection and control system (GCCS), SCADA, and surface emissions, to bring them into the RMC GIS platform. My colleagues are demonstrating these technologies at the SCS June Client Webinar.”
“I created a team of hand-picked SCS staff with both GIS and waste management backgrounds (and a whole lot of drive) to make the vision come to life,” she says. “That’s how we innovate, tight teams with access to nationwide expertise.”
Within six months of the project’s genesis, Russo and her team had integrated gas and liquid collection systems, other landfill systems, and asset management into the RMC GIS platform. She and her team now sell these applications nationwide.
Russo’s come a long way since joining SCS at age 21
In her mind, she grew up at the company. Before coming on board, she managed a shop in Manhattan Beach, California, while she began thinking about what to do next.
“I learned a lot about business and people. It was a stepping-stone – I discovered how to earn trust, build rapport, and sell. But in time, I decided I wanted a more professional job,” she recalls.
She went to work for a real estate company managing the SCS Engineers Long Beach office, where she would soon take an entry-level Accounts Payable position in SCS Field Services.
In time, she transitioned to the Health and Safety group, assisting in creating training material and managing truck fleets. Soon she was managing assets, among other firsts for her. By this point, she had developed enough software, accounting, and other administrative skills to step up fast.
Part of the job was keeping up with vehicle maintenance, so she often spoke with field staff. Many of them she already knew from her days working in the accounting department.
Growing with her SCS colleagues
“When I was in my first administrative roles, I supported many colleagues who were field techs or supervisors; they are project managers now. It feels as though we’ve grown up together, and we know and trust each other. We collaborate well and know that when we bring projects to each other that we will take care of each other,” Russo says.
She especially likes the RMC concept because remote control and automation enable her, her clients, and her team to work smarter, not harder because they leverage the technology to work for them.
“That means we can usually work from anywhere, giving all of us more time for family, friends, or allocating the time saved towards other needed to-dos. I’m up at five a.m. and, at times, may not finish work until nine at night. Somehow, us working women find the balance in between meetings, writing proposals, and answering emails; I have lunch with my two boys or take them to a park,” she says.
Bambi Lance, a veteran SCSer and her mother, works in the same business unit as Melissa does. “Mom’s been here for 16 years, and it’s interesting to have her perspective not only as my mom but as someone who knows SCS. She knows my department, and she knows me. She sees what I am doing and she along with management encourage me to do more and believe in myself.”
Russo reflects again on the concept of stepping-stones on the way to knowledge and maturity. I’m competitive and take on challenges, which has been a driving force in all I do today. It’s helped me take a personal inventory of how I am now versus the young Melissa,” she says.
She uses it to gauge her direction. And she uses it to connect to her staff. “I try to help them see you can turn almost any experience, into a positive. I want my team to see we are all learning and growing. They can, as I can, comfortably bring new ideas to the group and company, which often turn into new ways to help clients.”
She circles back to her decision to fly drones, explaining how it aligns with her career path from her first steps to today. “Becoming a pilot was a natural fit because it’s a new challenge. The craving to take on new tasks is how I grew from an accounting administrator to a project coordinator up to a business manager. It’s wanting to expand my knowledge, tackle new feats, and accomplish what I was not sure I could do. I like the challenge.”
The SCS Culture is Driven by Client Success
Managing oil and gas waste is challenging, even when practicing due diligence. The job requires impeccable skill and attention and sometimes outside support, which Colorado operators recently learned when they found high oil content in leachate coming out of their sump. They turned to SCS, knowing through their longstanding relationship with the engineers and that their liquids management team could deal with oil-laden wastewater.
Ensuring sustainable outcomes begins with collecting and analyzing comprehensive data that become the building blocks for a feasibility study. The study helps with immediate challenges and builds a more holistic approach to tackle increasingly expensive operation challenges at landfills.
“First, we talk about the site’s leachate history, including quality and quantity. What is the source of the waste generating the leachate, and where is it deposited? How are liquids used in current operations? The current practice used the liquids on the landfill surface for dust control, leaving an unsightly oily sheen.
Once we talk about how the site currently manages these liquids, we discuss options for future handling for improvement,” says Neil Nowak, SCS Engineers project director. “You’ve got to have a holistic understanding of day-to-day operations with the data to solve the problem cost-effectively.”
Neil’s preliminary research led to one recommendation to meet all the criteria – separate oil and water from leachate as the liquid exits the pump. The separation process can reduce the oil-laden leachate volume by 70 percent.
The technology works by separating the leachate into oil and water portions using an oil/water separator, such as a gun barrel tank, which is low cost and effective. After piping the water to an evaporation pond, the collected oil is sent offsite for future handling, usually disposal.
“This method gives the operator a better option for dealing with the leachate over the current practice of spraying it on the landfill surface for dust control,” Nowak says.
Spraying usually provides an alternative for liquids while reducing disposal time and cost. However, he explains, oil-laden leachate is a different beast than typical MSW liquids and calls for a more creative solution to remain within regulatory compliance.
Oil and water separation eliminates the aesthetics issues at the site with its previous practice. The greater value is that this method gives operators full control of oil’s movement, which can otherwise be very hard to accomplish.
“Oily leachate can adhere to the wheels of equipment that move dirt over the landfill surface; consequently, it ends up in places operators do not want it to go. Oil and water separation technology is a reliable way to keep it out of surface drainage areas and ensure it does not infiltrate into groundwater outside of the lined space,” Nowak explains.
Operators avoid short- and long-term consequences springing from compliance issues, but beyond today, the technology that SCS sizes operates for 20-plus years and helps prepare them for the long haul.
This option enables waste pros who take on growing demand from the oil and gas industry to protect the environment and public health, even as volumes increase. Oily liquids are particularly challenging for wastewater plants. Separation technology provides greater assurance that the landfill will still have a home for their leachate as wastewater treatment plants raise the bar on what they will allow.
The remaining question…
What is the most cost-effective and safe way to eliminate the filtered oil?
The solution for the immediate need is straightforward and simple. Depending on geology, local regulatory policy, and cost factors, solidification or injection are the most common, safe practices now, but reuse options are under development. Reuse and prevention are part of a longer-term landfill strategy, so Neil draws on his colleagues’ expertise.
Nowak’s expertise comes from years of experience supporting the oil and gas industry. Backing him is national liquid management expert Nathan Hamm, who lends technical expertise and insight on best practices for reducing leachate.
Commonly the best bang for your leachate management dollar is to reduce the volume of leachate or wastewater to treat in the first place. Operators can begin by diverting stormwater away from active portions of the landfill, then installing a better cover system. Depending on the landfill’s need and location, reducing the size of new cells and timing those new cells to come online during low precipitation seasons is practical. Leachate minimization practices such as these directly reduce the treatment system capital and ongoing operational costs.
The Colorado operator now has oil and gas waste management options and has a comprehensive, site-specific review of leachate management with a clear understanding of where there is room for improvement.
As far as their immediate priorities, says Nowak, “We have left them with enough thought-out information to make informed decisions, and for now, they are leaning toward the oil and water separation technology. Though they can keep operating without it, they are looking to get ahead of possible compliance issues by making changes voluntarily, which are usually less costly in the end and demonstrates social responsibility to the Colorado Department of Public Health and Environment and the EPA.
Lately, landfill operators are putting stock in onsite landfill leachate treatment systems as a strategy to stay on top of increasing requirements in their already demanding regulatory world. Leachate treatment systems help meet tightening restrictions on liquids that landfills send to municipal wastewater treatment plants or discharge directly. And onsite leachate treatment gives operators a leg up should they one day have to deal with any emerging contaminants found on an expanding list.
With their eyes on compliance, landfill owners and operators are looking to leachate treatment systems that can ease the impact of soaring leachate disposal costs. Of course, the more contamination, the harder the hit since higher contaminants can mean higher municipal treatment plant surcharges or the landfill having to haul its leachate longer distances to a treatment plant that will accept it. Both examples usually result in higher treatment, disposal, and hauling costs.
A spike in its ammonia concentrations was enough impetus for one Oregon landfill operator to turn to SCS Engineers a few months ago. At its highest levels, the ammonia climbed to 50-fold what many small wastewater treatment plants, like the one in the Northwest, will take over the long-term.
Project Director Shane Latimer and Technical Lead Sam Cooke got on the stick to figure out how their client could keep hauling and disposing of leachate at the local wastewater treatment plant it has routinely relied on for years.
Coming up with a plan is a complex, multi-step process that requires looking through many lenses. To design a cost-effective, efficient treatment facility, Latimer and Cooke use an in-house multidisciplinary team of co-workers from Project Management, Chemical Engineering, Civil Engineering, and Geotechnical Engineering. The team performs in-depth analyses to identify the most economical and feasible technology. A design that in this case not only addresses ammonia but prepares the operator for emerging contaminants, such as the possible need for per and polyfluoroalkyl substances (PFAS) reduction, which Cooke describes as a train that has not yet arrived in Oregon but has left the station and is heading down the track.
Starting with the most immediate concern, Cooke says, “Our client had seen ammonia concentrations between 500 and 1,500 mg per liter, which is high. Acceptable ammonia levels can vary depending on the type of facility and how much leachate they expect to get compared to their total flow. But small treatment plants like the one our client depends on will set ammonia limits of about 25 or 30 mg per liter,” he says.
SCS begins with a leachate pretreatment options analysis to dive into details beyond ammonia levels – spikes in ammonia call for close attention. Still, there’s more to consider in masterminding a robust and fitting plan to manage the complex process.
“These are biological treatment systems, and there is no one-size-fits-all answer. You need to know how these systems will react to whatever is in your leachate, so you have to account for more than ammonia, or whatever your constituents of concern are,” Latimer says.
SCS’s leachate contaminant analyses use the landfill’s historical data along with what they learn from tests that SCS orders to understand alkalinity, pH, and carbon, among other leachate chemistry puzzle pieces.
“We look at concentrations of raw leachate, flow rate, pretreatment requirements, and other factors. We want to get a comprehensive picture of the problem and ultimately make the best treatment decision to get compound concentrations down to acceptable discharge levels,” Latimer explains.
What customized solution did the team design for the client in Oregon? The system of choice is a membrane bioreactor (MBR), which combines membrane separation technology with traditional activated sludge technology with optional reverse osmosis treatment. The design is a compact, efficient, biological wastewater treatment plant.
“An MBR is an elegant solution. We found it to be a good choice for this application for several reasons. It takes up relatively little space and fits well within the available plant footprint. It produces a relatively low-volume waste sludge stream. And it can cost-effectively treat multiple constituents of concern, so should new leachate chemistry issues arise, an MBR can address many of them,” Cooke says.
Being able to handle multiple concerns if and when they arise is key here. Cooke and Latimer wanted not only to get the immediate problem in check but see that the client has a dynamic and robust system to tackle whatever new challenges may be down the road.
When SCS goes into design mode, they plan ahead by engineering modular systems to add additional treatment methods if and when they’re necessary.
“For instance, MBR treats the leachate to reduce ammonia, other nutrients, organics, and suspended solids. By leveraging this treatment method first, you eliminate a lot of the bulkier constituents. But we left room for a modular addition such as reverse osmosis for “polishing,” treating MBR discharge for other minor constituents including PFAS,” Cooke says.
The client who came to SCS for a relatively inexpensive remedy for an ammonia problem now has a feasible, economical asset for leachate management.
“These investments are good security for landfill operators,” says Latimer. “If a municipal wastewater treatment plant is struggling to meet its standards, eliminating one contributing source of wastewater, like a landfill, could potentially solve several issues, such as ammonia, biochemical oxygen demand, and total suspended solids.”
But these treatment systems provide added security for more than the landfill.
“When disposal sites invest in sound leachate treatment systems, it’s also good for municipal wastewater treatment plants. It assures them that landfill operators will help them with the overall regulatory burden. We are helping them both to prepare for present and future challenges,” says Latimer.