Meet SCS Engineers professionals at the A&WMA/ASME Waste Information Exchange, April 11-12, 2023, at the Doubletree Hilton Washington DC-Crystal City Hotel, in Arlington, Virginia.
This conference will cover the latest on a broad range of waste-related topics including regulations and research in an interactive, discussion-focused format. This is an excellent learning and networking opportunity to hear directly from experts at EPA, NGOs, industry, and academia who are working together to develop solutions to creating a cleaner and healthier environment. The technical program will cover policy updates and regulatory changes, as well as current and late-breaking research on hot topics such as:
• Solid Waste
• Biosolids
• Landfill Issues and Greenhouse Gas Emissions Monitoring
• Reuse/Recycling
• Resource Management
• Waste-to-Energy
• PFAS Emissions and Controls
• Environmental Justice
• RCRA Requirements for Open Burning
Managers, practitioners, policymakers, and researchers involved in waste management, public works, operations, maintenance, manufacturing, transportation, technology, compliance, collections, and other environmental roles will benefit from the technical content and networking available at this conference.
Sponsorship and display opportunities are available at this conference! Discover how your company can maximize exposure, generate leads, and support the industry.
Visit www.awma.org/waste for registration information and evolving conference details.
Meet SCS Engineers and SCS Field Services professionals at BOOTH 1704 at WasteExpo 2023, May 1-4, in New Orleans.
WasteExpo is the place to be! The conference program is your professional development opportunity of the year! The education and training that you’ll receive is guaranteed to sharpen your skills to help you do your job better. WasteExpo’s conference program is unparalleled. 2023 Conference Tracks include:
A Bird’s-Eye View: Using Satellites and Drones to Detect and Monitor Emissions, Bob Dick, Sr. VP (Moderator) and Chris Carver, GIS Developer and FAA licensed drone pilot.
Monday, May 1
8:00 AM – 9:15 AM
Room: 275, Session Number: MTECH1
Why is Multifamily Recycling So Hard? with Michelle Leonard, Sr. VP and National Expert on SMM
Monday, May 01, 2023
8:30 AM – 9:45 AM
Room: 279, Session Number: MRECYC1
PFAS: Price to Fix Adulterants will Soar with Nathan Hamm, VP and National Expert on Liquids Management
Monday, May 01, 2023
10:15 AM – 11:30 AM
Room: 279, Session Number: MRECYC2
Minimum Recycled Content: Challenges and Opportunities with Vita Quinn, National Expert on Solid Waste Finance and Rate Studies
Tuesday, May 02, 2023
8:00 AM – 9:15 AM, Room: 289, Sustainability Track
Seizing an Opportunity: The Rise of MRF Investments with Bob Gardner, Sr. VP Solid Waste
Tuesday, May 02, 2023
12:00 PM – 1:15 PM
Room: 279, Session Number: TRECYC3
There’s an App for That! with Chris Carver, GIS Developer and FAA licensed drone pilot.
Wednesday, May 03, 2023
10:45 AM – 12:00 PM
Room: 275, Session Number: WTECH2
Click for more conference details and registration information
Reducing CO2 is essential for our planet to thrive. At SCS Engineers, we’ve been helping all industries, cities, and states do just that for over 50 years. We focus solely on environmental solutions; in the industry, it’s called pure environmental, along with industry rankings that consistently rank our results in the top tiers.
Our culture is one of sharing. Our professional staff are involved in their communities and global industry associations where we speak, publish and share what works openly with you. Our newest blog series Preventing and Reducing CO2 publishes monthly, bringing you the latest papers, presentations, and case studies on reducing CO2 and targeting climate change.
We hope you find this collection of article, papers, videos, and opinion pieces helpful. The opinion pieces raise logical questions and help us create sustainable solutions rather than quick fixes that don’t stand up economically over time. We include a broader range of topics for landfills, as they diligently work toward reducing CO2 and using proven wastewater treatment options.
Sustainable Living Key to Tackling Climate Change Tackling Climate Change: ISWA’s James Law explains how changing people’s mindsets and behaviors impacts climate change …
The Wise Way to Fight Inevitable Climate Change This opinion piece in the Pittsburgh Post-Gazette by Joseph Duckett describes two major reasons why we need to rethink a country-by-country strategy to fight climate change …
Landfill PFAS Study: Concentrations After Leachate Treatment The objective of this study was to evaluate a cross-section of full-scale on-site landfill treatment systems to measure changes in PFAS concentrations. Leachate samples were collected before and after treatment from 15 facilities and were evaluated for 26 PFAS, including 11 perfluoroalkyl carboxylic acids (PFCAs), 7 perfluoroalkyl sulfonic …
Design to Maximize Landfill Air Space – Your Landfill’s Golden Egg Free Webinar and QA Forum: Modern Landfill Design for Siting and Maximizing Air Space The trend to go larger necessitates more landfill design sophistication and master planning to recoup the growing capital investment upfront. During this month’s SCS Engineers webinar and open forum, our panel will discuss how extending the life of a landfill is a greener option …
EPA’s Brownfields Cleanup Grants $60M – Deadline November 22 Brownfields redevelopment and land recycling cleans up past activities that occurred on properties impacting local ecosystems. These properties help revitalize areas economically while making them safe again. When you’re looking at energy as well as environmental costs, remediation is often greener. The FY 2023 Brownfields Multipurpose, Assessment, Revolving Loan Fund, and Cleanup Grant Guidelines are now available (go to Open Solicitations). The application submission deadline is November 22, 2022.
SCS respects your privacy – you may share these resources individually using social media and email icons on each page. You may share all of the resources by sharing this blog. Look for our next Preventing and Reducing CO2 blog in October! If you missed our August issue – no problem, click here.
Since the 1990s, USEPA has provided risk-based Regional Screening Levels (RSLs) to assist in evaluating environmental monitoring and contaminant levels – e.g., in soil, air, and water at residential and industrial properties. EPA periodically updates the RSL tables to reflect new contaminants of concern and new chemical toxicity data. The May 2022 RSL tables have been expanded to include 14 per- and polyfluoroalkyl substances (PFAS). PFAS are a large family of emerging contaminants that are garnering significant interest due to their significant toxicity and widespread use in industrial and consumer products such as fire-fighting foam, fabric treatment, and some food packaging. The latest EPA RSL tables are available at: https://www.epa.gov/risk/regional-screening-levels-rsls-generic-tables
Additional info regarding ongoing efforts to address and treat PFAS are available by searching this website: https://www.scsengineers.com/ and then using the filter to narrow down returns to your interests.
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.
Context
• 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.
Recommendation
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.
Sincerely,
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.
EPA Requires Reporting on Releases and Other Waste Management of Certain PFAS, Including PFBS
As part of EPA’s Strategic Roadmap, the Agency announced the automatic addition of four per- and polyfluoroalkyl substances (PFAS) to the Toxics Release Inventory (TRI) list.
As of January 1, 2022, facilities that are subject to reporting requirements for these chemicals should start tracking their activities involving these PFAS as required by Section 313 of the Emergency Planning and Community Right-to-Know Act. Reporting forms for these PFAS will be due to EPA by July 1, 2023, for the calendar year 2022 data.
In April 2021:
EPA previously updated the Code of Federal Regulations with PFAS that were added to the TRI on January 1, 2021, under section 7321(c) of the NDAA and regulated by an existing significant new use rule (SNUR) under the Toxic Substances Control Act (see 40 CFR 721.10536).
In addition to continuing to add PFAS to the TRI, the EPA will soon announce a series of PFAS test orders requiring PFAS manufacturers to provide the Agency with toxicity data and information on PFAS.
If you have questions or concerns about reporting requirements, contact one of our environmental chemistry – hazardous materials/waste professionals at .
Anna Cerf conducted research at the Environmental Research and Education Foundation, had an internship at the Environmental Defense Fund, and worked for SCS Engineers. Now she’s off to Germany.
Cerf graduated from UVA in 2020 with a degree in civil engineering and a minor in urban and environmental planning. The course work for her program will cover three fundamental disciplines: sanitary engineering, groundwater remediation, and hydraulic engineering.
She is a Rotary Global Grant Scholar, using an award to fund her two-year master’s program in water resource engineering and management at the University of Stuttgart. “With the support of ISWA professors and access to University of Stuttgart’s premier research facilities, I will research the transport and treatment of emerging contaminants for my master’s thesis.”
Cerf feels having a master’s in water resource engineering and management will further her career at the intersection of environmental issues and public health. “The University of Stuttgart has top-of-the-line water research facilities,” Cerf said. “It is also home to the Institute of Sanitary Engineering, Water Quality, and Solid Waste Management.
“By the end of the program, I will be able to anticipate, understand and evaluate water management-related issues,” Cerf said. “As climate change exacerbates existing water scarcity issues and environmental degradation damages water quality, these skills become increasingly important.”
Read more about this accomplished SCS Young Professional.
The findings of the studies reviewed in this report are encouraging concerning the ability of today’s U.S. WTE facilities to effectively treat solid waste that contains PFAS and not emit detectable levels of PFOA in the process. For the formation of PICs, the pilot-scale investigation conducted at the Karlsruhe Institute of Technology is encouraging in its findings that the combustion of PTFE did not create any of the 31 types of PFAS suspected of being potential PICs produced during the combustion process.
In conclusion, based on this research, SWANA is cautiously optimistic regarding the role of WTE facilities in the destruction of PFAS in MSW. The thermal destruction of PFAS in high-temperature combustion systems such as WTE facilities may represent one of the few commercially proven options available to society to destroy these problematic, forever chemicals.
The full report, PFAS Fate and Transport in Waste-to-Energy Facilities, is currently only available to SWANA ARF subscribers. SWANA members receive free access to ARF industry reports one year after publication; the abstract is available online and worth reading.
Landfill operators forever work to stay on top of a diverse and complex mix of leachate contaminants—heavy metals, ammonia, and biochemical oxygen demand (BOD), among them; but lately, they think about even more. For one: how to keep concentrations of these contaminants within wastewater treatment’ plant’s tightening discharge limits. Add to this concern the possibility of more compliance pressure as the constituents’ list on regulators’ radar grows. From microplastics to PFAS and PFOA, the latter sometimes called the “elephant in the room” –some operators are preparing for what may be down the pike.
Among strategies, some are looking at are on-site leachate treatment options, and there are several. Finding the most fitting, sustainable, and cost-effective one takes vetting. This continuing blog series explores studies conducted by SCS Engineers for operators nationwide. Here you will get an inside look at what these leachate management experts found, what treatment system they recommend in each scenario, and why.
A Solution to a Nebraska Landfill’s Rising Leachate Volumes
A Nebraska landfill needs to manage its rising volumes of leachate, causing disruptions to operations. The liquid goes into a 20,000-gallon tank, is pumped into a tanker, and is driven to the municipal wastewater treatment plant. The tank was filling so fast that the operator has trouble staffing and scheduling its few commercial driver’s-licensed operators to haul it. This logistical task has become a near-daily necessity. Sometimes the liquid level indicator will go off on the weekend. Management has to move quickly, sometimes on a dime, find someone to come in, and pay overtime.
“The staffing challenge is the main issue that brought the operators to SCS. They want to understand the whole leachate management structure better, and as we answer their questions, they want to know how we can improve the overall system in the long-term, says Zach Mahon, the SCS staff professional who works on the project. “After an extensive assessment, we provide options whereby the operator no longer has to pump leachate to a holding tank and then truck it to the wastewater treatment plant. And we provide site-specific recommendations to take their leachate management practices further,” he says.
Mahon and the SCS team of leachate management experts headed to the landfill to talk to operations staff and get their historical generation records, which is the basis they start with for their assessment. “We correlate the landfill information with our research to determine yearly generation figures as well as a peak generation number over the landfill’s projected life. This site is expanding, and we want to size the equipment so that when it reaches capacity, the system can handle the higher volume,” Mahon says.
SCS plans in other ways to ensure the recommended technology will take its client into the future on solid footing. For instance, accounting for the reality that operators may one day have to remove per- and poly-fluoroalkyl substances (PFAS) to send their multi-thousands of gallons of leachate to their wastewater treatment plant each year. Operators are keenly aware that utilities and regulators are looking with more scrutiny at PFAS and other emerging contaminants of concern.
Through due diligence, SCS engineers came up with three treatment options. Mahon explains each:
Install a leachate force main. This system includes a pipe with a pump that pushes the liquid through the force main, directly to the sewer line and, ultimately, to the municipal treatment plant. The pump kicks in automatically, negating the need to have drivers in the wings at all times. This system is quick to build and fairly simple to operate. It is the least expensive of the modifications that SCS vetted.
Install a leachate evaporator, which heats the liquids and evaporates the water molecules. This system reduces leachate volume by 90%. Managing liquids on-site eliminates dependency on drivers, but on the wastewater treatment plant too. The gas-fueled system is suited for sites with surplus landfill gas to help cut their operational costs.
Install a reverse osmosis treatment (RO) system where material passes through a membrane, which separates contaminants. RO treatment can reduce contaminated water by 90%, typically rendering it clean enough to discharge directly to surface water with appropriate permits. Or, it can be discharged to the city sewer, eliminating the permitting step.
“For each leachate treatment option, we looked at cost, the feasibility of short- and long-term implementation, and regulatory acceptance,” Mahon says. “We deliver the data with these priorities in mind, make our recommendations, and leave it to our client to decide.”
What did the SCS team recommend in this scenario?
“We suggested the force main. It solves the primary operational issue around staffing. And the economics of this comparatively inexpensive system make sense in these times when landfills are dealing with astronomical leachate management costs, among other increasing operating and capital expenses,” he says. This option does more than meet the client’s most immediate needs at a minimal cost. It provides the option to upgrade should regulators’ requirements around leachate change or should the wastewater treatment plant tighten its discharge limits. We design the modular system to add on reverse osmosis if necessary in the future. Thus, we help ensure that our client will continue having a home for its leachate.
A value-add, regardless of the operators’ decision, is more knowledge. SCS clients have a deeper understanding of industry standards. They are also more aware of how the industry is shifting in managing leachate and how these shifts could affect them. We follow up with technical bulletins explaining proposed and final federal rules in plain language influencing their operations, deadlines, and how to provide feedback to the appropriate agencies.
“We provide a lot of data to continuously inform our clients and to help them compare their operational costs now to what they would be if they invest in a new leachate management strategy. We ensure they fully understand each option’s capabilities to decide if it pencils out for their budget and operations. They have what they need to make informed decisions for a hands-off system to take them into the future,” Mahon says.
Leachate and Liquids Management
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.
Explains Hamm:
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.
Liquids and Leachate Management
