PFAS

May 10, 2024

SCS Engineers is again hosting our popular half-day Solid Waste Seminar in Harrisburg, Pennsylvania on June 5.  Lunch is included.

This annual seminar covers the latest regulatory, policy, and technology developments in solid waste, landfill, landfill gas, and sustainable materials management.  It is designed for solid waste management professionals, landfill managers, waste/recycling managers, supervisors, and operators.

This year’s presentations will be

Smart Landfills: Transforming Waste Management with Remote Monitoring,
by David Hostetter, PE, LEED AP, Vice President, RMC Business Manager, SCS

Overview of Methane Sensing Technologies and the Future of Emissions Quantifications,
by Chris Woloszyn, Senior Project Professional, SCS

PFAS: The Saga Continues,
by Jennifer Robb, Vice President, SCS

Planning, Operating and Maintaining Bottom-Up Caisson Wells,
by Justin Stevenson, PE, Project Manager, SCS & Dan Faby, Senior OM&M Superintendent, SCS

Pennsylvania 2024 Regulatory Update,
by Jason Dunham, Department of Environmental Protection | Bureau of Waste

Site Assessment for Glass Recycling,
by Josh Krumski, Staff Professional, SCS

 

Please see the flyer for registration information. We hope to see you there!

 

Posted by Laura Dorn at 2:15 pm

April 16, 2024

Join SCS Engineers at the SWANA SC Spring Conference, hosted at the Hilton DoubleTree in Myrtle Beach, South Carolina. SCS’s own J Morgan, PE, SWANA SC Palmetto Chapter President, and the planning committee prepared an engaging agenda of technical sessions, including PFAS analytical methods, landfills and earthquakes, and environmental justice. Attendees will enjoy the annual spring golf outing, held at the Aero Club Short Course, and fun networking opportunities during Casino Night.

SCS experts are expected to present this year, with more details to come!

Registration is open to SWANA Members and non-members. Register today!

Posted by Brianna Morgan at 8:53 pm

April 8, 2024

Timothy Smith, PE, will now lead the firm’s specialty practice in Leachate and Industrial Wastewater, Anaerobic Digestion (Liquids Management).

 

SCS Engineers, a leading global environmental solutions provider, announces that Timothy Smith, PE, will lead the firm’s Leachate and Industrial Wastewater, Anaerobic Digestion (Liquids Management) specialty practice.

SCS’s Liquids Management practice includes the management and treatment of landfill leachate, industrial wastewater, groundwater, and anaerobic digestion (AD) for converting livestock manure, municipal wastewater solids, food waste, industrial wastewater, FOG (fats, oils, and grease), or various other organic waste streams into biogas.

Smith, a Professional Engineer (PE) in nine states, has over twenty-five years of experience in civil and environmental engineering, focusing on waste and environmental services. His background experience comes from his work in leachate and industrial wastewater management and treatment, groundwater and stormwater management, remediation and biogas gas construction projects. His experience covers all project phases, from assessment to design and construction to implementation of treatment systems on industrial or municipal sites. Smith’s sector experience includes working with landfills, industrial facilities, military sites, petroleum, aerospace, transportation, municipalities, and food manufacturing/processing plants.

Smith, already an integral member of SCS’s Liquids Management practice for years, is ardent about reusing what society discards as waste into useful products and services again. His teams help conserve natural resources and reduce a business or municipality’s carbon footprint.

Timothy Smith’s custom teams of hydrogeologists, geologists, scientists, and engineers develop treatment solutions to meet the strictest federal, state, and local requirements to treat wastewater, leachates, groundwater, and other liquids for reuse. These systems can remove or destroy contaminants, including PFAS, per- and polyfluoroalkyl substances of synthetic organofluorine chemical compounds found in some drinking water resources.

These specialized teams also work with manufacturers, food processing plants, and the agricultural industries to turn what was formerly considered organic waste into renewable energy. These Ag-Gas or AD solutions can power production, create energy to sell back to the grid, or become renewable fuels. All offer the benefits of lowering greenhouse gases.

Senior Vice President Nathan Hamm says, “Tim is a talented strategic thinker, an effective collaborator, a builder of people, and has dedicated his career to solving our clients’ liquids management challenges. The team will thrive under his direction.”

You may reach Tim Smith at or on LinkedIn.

 

Additional Resources:

 

 

 

Posted by Diane Samuels at 6:00 am

March 26, 2024

Join SCS Engineers at the 2024 Pennsylvania Brownfields Conference, presented by the Pennsylvania Department of Environmental Protection in partnership with the Engineers’ Society of Western Pennsylvania (ESWP). Taking place from March 25th to 27th at the Penn Stater Hotel & Conference Center in State College, PA, this conference is a key event for environmental professionals, developers, and stakeholders involved in brownfield redevelopment across the state.

The Pennsylvania Brownfields Conference is a premier platform for exploring innovative solutions and best practices in brownfield redevelopment, environmental remediation, and community revitalization. Attendees will have the opportunity to engage in insightful discussions, gain valuable industry insights, and network with experts and peers from various sectors.

Don’t miss this opportunity to connect with professionals passionate about transforming blighted properties into vibrant community assets. Visit the 2024 Pennsylvania Brownfields conference website for registration details, agenda information, and more!

Get more information on Brownfields and Grants.

 

Posted by Brianna Morgan at 11:15 am

March 14, 2024

The ABA Annual Spring Conference on Environmental Law, April 3-5 in Chicago, IL., is where you join leading environmental, energy, and resources law professionals for knowledge-sharing, networking, and inspiration in the Windy City. The conference provides timely, topical updates on the latest opportunities and challenges facing the field of environmental law, with a deep dive into the fields of environmental compliance, energy, and resources law. Join – SEER – the Section of Environment, Energy, and Resources, to learn about the latest developments shaping the practice today and the long-term trends that will drive the future.

Look for the SCS Engineers’ and
talk with  Senior Vice President, Mike McLaughlin, PE, JD, about your environmental challenges.

Click for more details and registration information

What to Expect

Lively discussions with leading practitioners, including state and federal regulators, leading scholars, and in-house counsel. Each day will kick off with a plenary session diving into key topics: one on forthcoming Supreme Court decisions that could reshape environmental law, and one on the evolution of EPA’s enforcement tools. A special track of panels will focus on the challenges of regulating across multiple jurisdictions. Panels in this series will help attendees understand how state priorities shape Clean Air Act and Clean Water Act implementation, parse through competing frameworks steering the energy transition, and make sense of global ESG trends influencing U.S. policy. The conference will also feature a litigation workshop focused on cutting-edge strategies for using unique types of evidence, like Indigenous Knowledge, in the courtroom.

Panels will examine liability mechanisms for historical PFAS, explore how regulatory pathways for emerging contaminants will impact clients, and consider practical approaches to environmental justice through the lens of a real case study in Chicago. Top speakers will weigh in on balancing the energy transition against national security and the ethical implications of artificial intelligence for lawyers. In addition to insights and practice tips from top practitioners, two panels will begin with case summary presentations by law students and young attorneys that attendees can use in their own practices.

Whether you are an experienced practitioner or in the beginning stages of your practice, join us in Chicago to create new connections, exchange perspectives, and get inspired by your fellow environmental, energy, and resources law professionals.

Posted by Laura Dorn at 11:14 am

February 22, 2024

Join SCS Engineers at the 40th Annual VWEA Industrial Waste and Pretreatment Conference, with the theme “Storytelling Through the Four P’s: People, Pollutants, Pretreatment, and Perspectives.” On March 4-5 at the Hotel Madison in Harrisonburg, VA, this conference will be an enlightening and enriching experience for professionals in the field.

The conference offers a comprehensive program, including technical sessions, workshops, and networking opportunities aimed at exploring the latest trends, innovations, and challenges in industrial waste management and pretreatment processes. As a participant, you’ll have the chance to engage with industry experts, regulatory authorities, and fellow practitioners to exchange insights, best practices, and practical solutions.

Join thousands of your peers at the forefront of industrial waste management and pretreatment practices. Whether you’re seeking to enhance your knowledge, expand your professional network, or showcase your company’s expertise, the Industrial Waste and Pretreatment Conference is the premier platform to achieve your goals and drive positive change in the industry.

Click here for schedule, registration, and other event details.

 

 

Posted by Brianna Morgan at 9:28 am

February 19, 2024

PFAS-RCRA-Landfills-SCS-Engineers
EPA proposes adding nine PFAS compounds to the list of “hazardous constituents” to be considered in RCRA facility assessments.

 

In response to its PFAS Strategic Roadmap, the Environmental Protection Agency (EPA) initiated two regulatory actions under the Resource Conservation and Recovery Act (RCRA) to tackle PFAS pollution. Once implemented, these measures will empower federal and state agencies with advanced tools for PFAS remediation.

The initial proposed regulation intends to designate specific PFAS as “hazardous constituents” within RCRA’s framework, making them subject to detailed scrutiny and cleanup actions at sites handling hazardous waste.

The second proposed rule aims to affirm that new contaminants, including certain PFAS that are not currently classified as “hazardous wastes” yet align with the definition of “hazardous waste” in RCRA section 1004(5), should be managed equivalently to traditional hazardous wastes in the context of corrective actions. Listing these PFAS as RCRA hazardous constituents does not make them, or the wastes containing them, RCRA hazardous wastes.

Appendix VIII to Part 261 – Hazardous Constituents

On February 8, 2024, the EPA proposed to add nine PFAS compounds to the list of “hazardous constituents” to be considered “in RCRA facility assessments and, where necessary, further investigation and cleanup through the RCRA corrective action process.” Appendix VIII to Part 261 – Hazardous Constituents shown at right.

If finalized, this hazardous constituent listing would form part of the basis for any future action the EPA may take to list these substances as hazardous waste.

EPA’s criteria for listing substances as hazardous constituents under RCRA require that they have been shown in scientific studies to have toxic, carcinogenic, mutagenic, or teratogenic effects on humans or other life forms.

Entities potentially affected by the proposed rule include hazardous waste treatment, storage, and disposal facilities (TSDFs) with solid waste management units (SWMUs) that have released or could release any of the PFAS proposed to be listed as RCRA hazardous constituents. EPA has identified 1,740 such facilities, which could be subject to additional corrective action requirements. “Waste Management and Remediation Services” had the highest number of facilities (359) with a high likelihood of handling PFAS.

The primary goal of the suggested amendment is to update 40 CFR 264.101 so that it accurately mirrors the requirements for corrective action cleanups at hazardous waste Treatment, Storage, and Disposal Facilities (TSDFs) as specified by RCRA sections 3004(u) and (v). The modifications are designed to clarify that the management of hazardous waste releases, including those not categorized as hazardous under current regulations but fitting the broader definition in RCRA section 1004(5), should adhere to the established protocols for hazardous waste under the corrective action program. Focusing on Per- and Polyfluoroalkyl Substances (PFAS), this regulatory action is a crucial part of the EPA’s PFAS Strategic Roadmap.

Should this proposed regulation be adopted, it would mean that PFAS would be specifically included as hazardous constituents to be considered during facility assessments and, where necessary, further investigation and cleanup under the RCRA corrective action process at hazardous waste TSDFs.

The proposed regulation states that “solid waste disposal facilities, such as those for municipal waste or construction and demolition debris, would not be subject to RCRA corrective action requirements unless they also function as hazardous waste TSDFs.”

Subtitle D of RCRA covers non-hazardous solid waste management, including municipal solid waste landfills, which are subject to different regulations than hazardous waste facilities (regulated under Subtitle C).

Although the recent proposal by the EPA to revise RCRA does not aim at mandating corrective actions at municipal solid waste (MSW) landfills, it sets the stage for probable future amendments under Subtitle C that might classify certain PFAS-containing waste streams, currently considered non-hazardous, as hazardous waste (e.g., listed or characteristic wastes).

While it is premature to predict the impact of future hazardous waste regulations on MSW landfills, it is appropriate to begin collecting information on PFAS waste and assessing potential effects now. Landfills that have implemented special waste review programs (for example, for non-hazardous industrial wastes like wastewater treatment sludge) are advised to expand their waste characterization efforts within these programs to include requests for data on the presence and concentration of the nine PFAS constituents highlighted in the proposed RCRA rule. Additionally, landfills without such review programs are encouraged to consider establishing them.

 

Additional Resources/Legislation:

  • The proposed rule would be established under the authority of sections 3004(u) and (v) of the Solid Waste Disposal Act of 1965, as amended by subsequent enactments including the Resource Conservation and Recovery Act of 1976 (RCRA), as amended by the Hazardous and Solid Waste Amendments of 1984 (HWSA).
  • This proposed rulemaking is in response to the three petitions and, if finalized, will list specific PFAS as RCRA hazardous constituents subject to corrective action requirements at hazardous waste treatment, storage, and disposal facilities (TSDFs).
  • PFAS: Landfills and CERCLA
  • PFAS: Landfill Compliance
  • Technical Bulletin: EPA Proposes 9 PFAS Hazardous Constituents Under RCRA

 

About the Authors: Connect with our authors and experts at 

Jeff MarshallJeff Marshall, PE, is a Vice President of SCS Engineers, Environmental Services Practice Leader for SCS offices in the Mid-Atlantic region, and our National Expert on Emerging Contaminants and Innovative Technologies. His four decades of experience include a diversified project engineering and management background, emphasizing environmental chemistry, hazardous materials, waste, and human health risk issues. Focus areas include environmental permitting, regulatory compliance, and hazardous materials treatment and remediation. He is a licensed professional engineer in Virginia, Maryland, West Virginia, North Carolina, and South Carolina.

David PalmertonDavid L. Palmerton, Jr., PG, has more than 35 years of experience in environmental consulting in environmental liability assessment, investigation, remediation, due diligence, and construction quality control. His experience includes consulting with large commercial, industrial, and academic entities. He also has extensive experience with the energy industry, specifically oil and gas upstream operations. He has managed strategic and technical environmental consulting issues for Fortune 100 companies throughout the United States. Mr. Palmerton is a professional geologist in several states and a former Certified Hazardous Materials Manager.

 

 

 

 

Posted by Diane Samuels at 6:00 am

February 7, 2024

EPA alert

 

Proposed PFAS Hazardous Constituents Under RCRA

The Environmental Protection Agency (EPA) is proposing to amend its regulation under the Resource Conservation and Recovery Act (RCRA) by adding nine specific per-and polyfluoroalkyl substances (PFAS), their salts, and their structural isomers to its list of hazardous constituents. EPA’s criteria for listing substances as hazardous constituents under RCRA require that they have been shown in scientific studies to have toxic, carcinogenic, mutagenic, or teratogenic effects on humans or other life forms.

Entities potentially affected by this action include hazardous waste treatment, storage, and disposal facilities (TSDFs) with solid waste management units (SWMUs) that have released or could release any of the PFAS proposed to be listed as RCRA hazardous constituents. EPA has identified 1,740 such facilities, which could be subject to additional corrective action requirements (under RCRA section 3004(u) and (v)) to address releases not already subject to corrective action under EPA’s corrective action regulations.

The nine PFAS and common uses are as follows:

  1. Perfluorooctanoic acid (PFOA; CASRN 335-67-1). PFOA is an eight-carbon molecule with seven fully fluorinated carbon atoms, and one carboxylic acid functional group used as a processing aid to produce fluoropolymers found in cleaning agents, waxes, aqueous film-forming foam (AFFF), and other products.
  2. Perfluorooctanesulfonic acid (PFOS; CASRN 1763-23-1). PFOS is a fully fluorinated eight-carbon molecule with one sulfonic acid functional group used in AFFF surface treatments of textiles to provide oil and water resistance, metal plating, and other uses and industries.
  3. Perfluorobutanesulfonic acid (PFBS; CASRN 375-73-5). PFBS is a fully fluorinated four-carbon molecule with one sulfonic acid group. It has been used as a replacement for PFOS used in manufacturing paints and cleaning agents, metal plating, AFFF, to provide oil and water resistance, and other uses and industries.
  4. Hexafluoropropylene oxide-dimer acid (HFPO-DA or GenX; CASRN 13252-13-6). HFPODA is a six-carbon molecule consisting of five fully fluorinated carbon atoms, one ether functional group, and one carboxylic acid functional group. HFPO-DA is a chemical associated with GenX processing aid technology used to make fluoropolymers without PFOA.
  5. Perfluorononanoic acid (PFNA; CASRN 375-95-1). PFNA is a nine-carbon molecule with eight fully fluorinated carbon atoms and one carboxylic acid functional group. It has been used as a processing aid to produce fluoropolymers and has been used or found in metal plating, cleaning agents, waxes, AFFF, energetic materials, and other products.
  6. Perfluorohexanesulfonic acid (PFHxS; CASRN 355-46-4). PFHxS is a fully fluorinated six-carbon molecule with one sulfonic acid functional group used in AFFF surface treatments of textiles to provide oil and water resistance, in metal plating, and in other uses and industries.
  7. Perfluorodecanoic acid (PFDA; CASRN 335-76-2). PFDA is a ten-carbon molecule with nine fully fluorinated carbon atoms and a carboxylic acid functional group. It has been used as a processing aid to produce fluoropolymers and has been used or found in metal plating solutions, cleaning agents, waxes, AFFF, and other products.
  8. Perfluorohexanoic acid (PFHxA; CASRN 307-24-4). PFHxA is a six-carbon molecule with five fully fluorinated carbon atoms and a carboxylic acid functional group. It has been used or found in metal plating solutions, cleaning agents, waxes, AFFF, and other products.
  9. Perfluorobutanoic acid (PFBA; CASRN 375-22-4). PFBA is a four-carbon molecule with three fully fluorinated carbon atoms and one carboxylic acid functional group. It has been used or found in metal plating, cleaning agents, waxes, AFFF, energetic materials, and other products.

 

EPA will collect comments on this PFAS to RCRA’s hazardous constituents proposal for 60 days once published in the Federal Register. Read a prepublication copy of this proposal.

Submit your comments on the Federal eRulemaking Portal: https://www.regulations.gov and identified by Docket ID No. EPA-HQ-OLEM-2023-0278.

 

As a result of this proposed rule, if finalized, when imposing corrective action requirements at a facility, these PFAS would be among the hazardous constituents expressly identified for consideration in RCRA facility assessments and, where necessary, further investigation and cleanup through the RCRA corrective action process at RCRA treatment, storage, and disposal facilities. Contact SCS Engineers for guidance about your facility at .

 

Additional Resources:

For additional information regarding EPA’s proposed RCRA PFAS rules, see:

 

 

 

Posted by Diane Samuels at 12:52 pm

January 11, 2024

Join SCS Engineers stormwater professionals, including our National Stormwater Expert, Jonathan Meronek,  at StormCon 2024, August 27-29 at the Grand Sierra Resort and Casino in Reno, NV.

Jonathan Meronek
Jonathan J. Meronek, QISP-ToR, ENV SP, CPESC, QSP/D, SCS Engineers National Stormwater Expert

StormCon 2024 is the stormwater industry’s premier event connecting stormwater and surface water managers, erosion control specialists, and engineers from around North America for idea-sharing, information exchange, and networking. Featuring a multi-track conference program led by top leaders in the industry, StormCon 2024 provides exceptional opportunities to learn, engage and build key contacts.  Topics this year may include:

  • Industrial Stormwater Management
  • Green Infrastructure
  • Flood Modeling & Mitigation
  • Programs, Permits and Compliance
  • Transportation & Construction Stormwater
  • BMP Monitoring
  • PFAS

The StormCon 2024 conference provides plenty of networking opportunities, certification courses, and an exhibit hall.

Click for more conference details and registration information.

 

 

Posted by Laura Dorn at 10:27 am

August 17, 2023

Meet SCS Engineers professionals at the Iowa Society of Solid Waste Operations (ISOSWO)’s Recycling & Solid Waste Management Fall Conference, October 2-4, at the Waterloo Convention Center in Waterloo, Iowa.

The conference will feature networking opportunities, a solid waste tour and a sustainability walking tour, exhibits, and auction, and educational sessions.

Click for more details and registration information

 

Posted by Laura Dorn at 3:15 pm