We recommend reading this article series to stay abreast of relevant knowledge from Bryan Staley, president and CEO of the Environmental Research & Education Foundation (EREF); Anne Germain, vice president of technical and regulatory affairs for the National Waste & Recycling Association (NWRA); Viraj deSilva, SCS Engineers wastewater treatment director; and testing results from New Hanover County whose capital investment in landfill infrastructure has proven to successfully treat effluent water to meet higher standards.
NWRA, SWANA, NERC, and ISRA jointly developed the “Think Twice” poster to help communities and individuals recycle materials in safe and appropriate ways. The poster is free and allows users to add their own website URL to provide more useful information.
Ask SCS about waste characterization, education, and outreach programs.
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.
SWANA provides free resources on its Safety Matters webpage, which contains valuable tools for both collection and post-collection. SWANA will also host numerous safety events this year, including a live safety webinar on January 29 at noon EST. Safety issues will also be discussed at SWANApalooza in Boston, Massachusetts, February 25-28, as well as at SWANA’s 7th Safety Summit at WASTECON in Phoenix, Arizona, October 21-24.
Safety is a top priority for National Waste & Recycling Association and its members. NWRA offers a wide range of comprehensive safety programs for its member companies, including these resources online:
National Waste and Recycling Association is sponsoring a FREE 90-minute webinar on December 6 at 3:00 pm ET. The webinar is highlighting the programs, strategies, and best practices of their six 2017 Recycling Award Winners.
The recipients will describe their unique blend of technologies, outreach, and program management that made a difference in their communities. The audience will have a chance to ask questions and find out how to implement these innovative ideas into their own operations and businesses.
More Solid Waste Management resources and success stories here.
EPA is proposing a GHG SER of 75,000 tons per year (tpy) Carbon Dioxide equivalent (CO2e) and requesting comment on it as well as two lower levels, specifically 30,000 tpy and 45,000 tpy CO2e, respectively.
The Associations do not believe there is sufficient information to support lowering the GHG SER below the proposed 75,000 tpy CO2e level and provided a table utilizing equivalent criteria pollutants from combustion sources (i.e., NOx, CO) yields CO2 emissions as high as 780,000 tpy CO2.
EPA already concluded in USEPA, Proposed PSD Revisions Rule, 81 FR 68137 that the burdens of regulation at a GHG SER level between 30,000 and 75,000 tpy CO2e would yield a gain of trivial or no value from both a programmatic and individual project-level perspective. Therefore, NWRA and SWANA strongly recommend EPA retain proposed GHG SER of 75,000 CO2e (or higher), and resist pressure to lower the GHG SER.
On the Topic of Biogenic GHG Emissions, the EPA’s final rule requires clarification to remain consistent with previous documentation and research to prevent significant permitting delays and increased costs that will not result in meaningful emission reductions.
The Associations encourage the EPA to ensure that waste-derived biogenic CO2 (e.g., from municipal solid waste (MSW) landfills) is treated as carbon neutral under the final PSD Permitting Revisions Rule to be consistent with prior Agency determinations specified in this memorandum and documents as follows:S. EPA, Memorandum Addressing Biogenic Carbon Dioxide Emissions from Stationary Sources, McCabe, Janet, November 19, 2014.
S. EPA, Memorandum Addressing Biogenic Carbon Dioxide Emissions from Stationary Sources, McCabe, Janet, November 19, 2014. The documents highlight waste-derived, biogenic CO2 as a type of “carbon neutral” feedstock based on the conclusions supported by a variety of technical studies and conclusions of the Agency’s latest draft Framework for Assessing Biogenic Carbon Dioxide for Stationary Sources, which was released with the memo. The Agency memo stated that “the Agency expects to recognize the biogenic CO2 emissions and climate policy benefits of such feedstocks in [the] implementation of the CPP.”
US EPA, Emission Guidelines for EGUs, 80 FR 64855. Both the revised Framework, and the EPA’s Scientific Advisory Board (SAB) peer review of the 2011 Draft Framework, found “that the use of biomass feedstocks derived from the decomposition of biogenic waste in landfills, compost facilities, or anaerobic digesters did not constitute a net contribution of biogenic CO2 emissions to the atmosphere.”
S. EPA, Appendix N. of Revised Framework for Assessing biogenic Carbon Dioxide for Stationary Sources, November 2014, pg. N-25. In Appendix N. of the Framework, entitled Emissions from Waste-Derived Biogenic Feedstocks, EPA calculated negative Biogenic Accounting Factors (BAF) for various examples of treatment of landfill gas via collection and combustion. EPA explains, “Negative BAF values indicate that combustion of collected landfill gas feedstock by a stationary source results in a net CO2e emissions reduction relative to releasing collected gas without treatment.”
US EPA, Carbon Pollution Emission Guidelines for Existing Stationary Sources: Electric Generating Units; Final Rule [Emission Guidelines for EGUs], 80 FR 64885. “[T]he use of some biomass-derived fuels can play a role in controlling increases of [in] CO2 levels in the atmosph The use of some kinds of biomass has the potential to offer a wide range of environmental benefits, including carbon benefits.”
US EPA, Emission Guidelines for EGUs, 80 FR 94855. Types of waste-derived biogenic feedstocks may include: landfill gas generated through decomposition of MSW [municipal solid waste] in a landfill; biogas generated from the decomposition of livestock waste, biogenic MSW, and/or other food waste in an anaerobic digester; biogas generated through the treatment of waste water, due to the anaerobic decomposition of biological materials; livestock waste; and the biogenic fraction of MSW at waste-to-energy facilities.
NWRA and SWANA believe the final PSD Revisions document should follow the approach to waste-derived feedstocks enshrined in the Final Clean Power Plan, and as recommended by the SAB, and ensure that waste-derived biogenic CO2 is treated as carbon neutral. Based on EPA’s own lifecycle assessments for the Renewable Fuels Standard program, its U.S. GHG Inventory, and confirmed by the SAB, EPA has sufficient analysis to support exclusion of selected categories of biogenic emissions from PSD permitting, including those from managing landfill gas and organic components of MSW.
The EPA does not seem to consider the regulatory treatment of biogenic CO2 from stationary sources to be a key issue in the context of the PSD revisions rule, based on a comment found in a Summary of Interagency Working Comments on Draft Language. Instead, the EPA continues to believe this rulemaking to establish a GHG SER under the PSD program is not the appropriate venue to address the broader concern of the regulatory treatment of biogenic CO2 from stationary sources.
The Associations strongly disagree and are concerned that because EPA remains silent on this important issue, some permitting authorities might improperly require landfills to incorporate biogenic CO2 emissions in the PSD permitting process. Historically, few landfills triggered PSD because non-methane organics emissions rarely reached the threshold. However, if biogenic CO2 emissions become subject to PSD, many landfill projects, which are “anyway sources” due to renewable energy projects, would also be forced to do BACT analysis for GHG. Biogenic CO2 is emitted from:
From the perspective of developing new renewable transportation fuel or energy projects, subjecting biogenic emissions from landfills to PSD could be an enormous barrier. The Associations would like the EPA to clarify in its final rule that the emissions of biogenic CO2 from treating or controlling landfill gas does not increase the CO2 levels in the atmosphere, but instead, has positive emission reduction and climate benefits. Failing to clarify this important point could subject landfills to significant permitting delays and increased costs that will result in no meaningful emission reductions.
On June 1, 2016, the National Waste & Recycling Association (NWRA), the Solid Waste Association of North America (SWANA), and the Coalition for Renewable Natural Gas (RNG Coalition) provide comments on Pipeline Safety: Safety of Gas Transmission and Gathering Pipelines (FR20722) proposed rules to Mr. Mike Israni, Deputy Associate Administrator for Pipeline Safety – Field Operations at U.S. Department of Transportation. Comments by the three not-for-profits were made on behalf of the solid waste industry including companies, municipalities, and professionals.
The letter reflected the solid waste industry support for the efforts made by the Pipeline and Hazardous Materials Safety Administration (PHMSA) to ensure pipeline safety and included comments on the Advance Notice of Proposed Rulemaking, (ANPRM) as follows:
The revised definition for gathering line (onshore) as the basis for determining the beginning and endpoints of each gathering line requires further clarification. The definition remains too broad for applications that do not have the same level of risks since they are not accessible to the public.
PHMSA has elected not to propose rulemaking for landfill gas systems. However, it notes that pipelines that transport landfill gas away from the landfill to another facility are transporting gas and that PHMSA may consider this in the future.
The associations pointed out that the same rulemaking for landfill gas systems should apply to all forms of biogas that are collected and managed in a similar manner to landfill gas. Also noted was that low-pressure gas lines delivering biogas off-site to a dedicated end user need not be considered for further regulation as they do not present the same level of risk that natural gas or other high-pressure gas lines do. Landfill gas/biogas systems fall under federal, state and local regulators. Because landfill gas/biogas systems are regularly inspected for safety, generally use plastic piping, and do not present a substantial risk to the public the Associations feel that it is not necessary to consider additional regulation.
Contact NWRA, SWANA, RNG Coalition or SCS Engineers for more information.
The National Waste & Recycling Association (NWRA) and the Solid Waste Association of North America (SWANA) returned comments and recommendations on the Environmental Protection Agency’s (EPA) draft Part 71 Operating Permit for Ocean County Landfill and MRPC Holdings LFGTE Operations, Permit Number: P71-0CMH-001 (Draft Permit) to EPA Region 2 Permitting Section, Air Programs Branch. The letter was sent on January 28, 2016, to Mr. Steven C. Riva of the EPA.
NWRA and SWANA expressed concerned that the EPA’s issuance of the Draft Permit, and the circumstances under which it has been prepared, represent a significant departure from practical permitting policies and will constitute a disincentive to expand existing and develop future landfill gas-to-energy (LFGTE) projects around the country.
The jointly submitted comments from both not-for-profit Associations on the Draft Permit were intended to convey their members’ strong interest in these projects, which represent an economic investment in alternative renewable energy sources and the reduction in greenhouse gas (GHG) emissions. Both Groups have expressed concern that the EPA’s actions should not undermine those investments and the benefits derived from these LFGTE projects.
The main points of the letter cover the Associations’ disagreement with the EPA’s approach to common control. NWRA and SWANA support the position that the OCL and MRPC are two separate sources that are not under common control, and they oppose the position proposed by EPA Region 2 in the Draft Permit. Both Groups are urging EPA to re-evaluate this decision and utilize an environmentally beneficial approach when making common control determinations for landfills and third-party LFGTE plants both now and in the future. Other portions of the letter address the uncertainty that EPA’s position would create for affected facilities and how it could re-open already settled compliance expectations.
Members of NWRA and SWANA have access to the letter and may continue directing comments and questions through either Association.
Questions directed to SCS Engineers should be addressed to Pat Sullivan, Senior Vice President and the SCS National Expert on the Clean Air Act.
SCS Engineers and their clients appreciate the support. The National Waste & Recycling Association (NWRA) and the Solid Waste Association of North America (SWANA) sent the Environmental Protection Agency (EPA) supportive comments on the proposed revisions to the Research, Development and Demonstration (RD&D) Permits Rule for Municipal Solid Waste Landfills (80 FR70180, November 13, 2015).
EPA’s proposed extension to the RD&D Rule would afford landfill owners the opportunity to continue to operate and develop new data and information that would influence future decision-making by regulators and industry alike. The time extension will provide additional time to help landfill owners evaluate and realize the financial value of the RD&D projects, thus increasing landfill owners’ confidence in implementing related large scale projects. These investments would be for the design, construction, additional monitoring and data collection and reporting that accompany long-term research projects, such as those associated with bioreactor landfills.
The RD&D rule provides the ability to obtain data on best practices to address both the advantages and challenges associated with bioreactor landfills. Operating these types of landfills have many advantages, they are not without their challenges. A bioreactor landfill is much more complex than a typical landfill.
NWRA, SWANA, and SCS Engineers believe this proposed rule will promote new research demonstration projects and support the continued research at existing projects so that EPA will have the information necessary to consider changes to the MSW landfill operating criteria.
On Monday, October 27, 2015, the Solid Waste Association of North America–SWANA and the National Waste & Recycling Association– NWRA submitted joint comments to the U.S. Environmental Protection Agency– EPA on the proposed revisions of the Emissions Guidelines– EG and Compliance Times for Municipal Solid Waste Landfills and to the supplemental proposal to the Standards of Performance for Municipal Solid Waste Landfills.
SCS Engineers has also submitted comments pertaining to the proposed EG and compliance revisions to the EPA. SCS leaders are involved in many outreach activities to help landfill owners and operators understand and prepare for the impact of the proposed modifications.