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.
Learn more about SCS Clean Air Act Services, or Greenhouse Gas Services, or
Landfill Gas to Energy Services
SCS Engineers along with Waste Management, Republic Services, Advanced Disposal, National Waste & Recycling Association, Solid Waste Association of North America, The Sanitation Districts of the County of Los Angeles, and other consultants have submitted additional comments to the U.S. Environmental Protection Agency (USEPA), Fuels & Incineration Group, Sector Policies and Programs Division regarding the Supplemental Proposal for the New Standards of Performance (NSPS) for Municipal Solid Waste (MSW) Landfills and the Proposed Emission Guidelines (EG).
The USEPA solicits comments from industry, state officials and other organizations to clarify key points in proposed policy prior to enacting the policy. Although the Agency is not required to consider additional comments after the closing period for such comments, these solid waste industry participants wanted to provide additional findings supporting portions of the policies and guidelines and asking for clarification in areas where there appears to be inconsistency with other federal rules or a lack of data.
The eighteen-page letter was submitted on January 22, 2016, to Ms. Hillary Ward. Since last Friday inclement weather has forced a closing of Federal Agencies in the Washington, D.C. region.
Click for SCS Engineers compliance information.
Click to contact Pat Sullivan, SCS National Expert on EPA Landfill Clean Air Act; NSPS/EG
by Tracie Onstad Bills, Northern California Director, Sustainable Materials Management at SCS Engineers
For many years source separation was the primary method for recycling. However, technology has changed how recyclables are collected and processed. China, the largest importer of materials for recycling now strictly enforces regulations on importing contaminated materials for recycling into the country. China’s Operation Green Fence puts restrictions on what material China will accept, rejecting materials that don’t meet higher standards of cleanliness; that means rejected materials get buried in a landfill instead of being recycled.
Regardless of the type of recycling program, the biggest challenge here at home is now minimizing contaminated recycling material. Communities are struggling to meet diversion goals and provide materials to local recyclers that are free of common contaminants such as liquids left in containers or motor oil. My SCS team has assisted communities in the last few years to address contamination issues and I’d like to share what works best to kick start addressing the issue at home.
Recycling Assessments: Conduct a visual and physical characterization study to identify contamination levels using one of these two methods for the evaluation:
Recycling Technical Assistance: Meet with local businesses and perform a walk-through of their facility to collect baseline waste assessment and material collection infrastructure information. This information can then be used to provide customized recycling and composting recommendations, and implementation support such as employee training sessions, providing signage and collateral, referrals, and multi-lingual outreach services.
Review and Analysis of Community Recycling Programs: Review and analyze your recycling program. An environmental engineer can provide recommendations and assessments on how a recycling program can be enhanced to reduce the quantity of contaminated materials. Services typically include everything from examining outreach materials to the flow of the recycling from generation to transport to processing.
Planning and Implementation of Behavior Change Programs: There is value in providing comprehensive programs and explicit outreach materials for increasing the probability of cleaner recycling. Behavior change programs focus on planning and implementing programs that identify key triggers to encourage action in the community. These programs help communicate the importance and value of specific activities to the community and cross any age and cultural barriers.
Contamination is a global problem and is challenging, but there are steps to minimize the problem in your community.
About Tracie Onstad Bills
Tracie Onstad Bills has been in the Environmental and Resource Material Management Field for over 20 years. Her expertise revolves around commercial recycling technical assistance, environmental purchasing, large venue and event zero waste programs, research and sustainability planning, garbage hauler franchise compliance and review, construction and demolition program / ordinance analysis and writing, climate inventory compilation, research and feasibility studies to help clients with comprehensive waste prevention and zero waste programs. Ms. Bills has a BA in Environmental Science from San Jose State University, is a CRRA Board member and belongs to the SWANA Gold Rush Chapter, National Recycling Coalition and the Northern California Recycling Association. Contact Tracie here.
Learn more on the SCS service pages and read SCS project case studies from across the nation to help fine tune your program:
Have you ever found in the sleeve or the pocket of a new shirt the “Inspected By…” piece of paper? You probably don’t think twice about it. You simply look at it and throw it away. However, if you were to think about it, what might the process be to inspect the garment? To be sure the sleeves are the same length, or the collar is sewn on correctly, or that it has all the buttons. That tag is intended to signify that the product was reviewed and has met its required standards to be placed in service.
Ever wonder if anybody reviews the bottom of a landfill? When is it ready to be placed in service?
When I was a kid, a landfill was, for the most part, a hole in the ground filled with trash. Well, we still dig a hole, but since the early 1990’s, municipal solid waste landfills (MSWLF) require a containment system on the bottom and sides of the landfill beneath the waste. These containment systems, i.e. liner systems, are designed to protect human health and the environment by serving as a barrier between the waste and liquid in the landfill from the soil and groundwater outside the landfill. These liner systems are typically constructed of compacted clay liners and geosynthetic materials which are documented and inspected to ensure the liner system was built in accordance with the permit requirements and its overall purpose of protecting the environment.
The landfill liner inspection process is usually called Construction Quality Assurance (CQA) and is an important and integral component of protecting the environment. CQA is generally performed by a third party firm to provide an unbiased evaluation of the liner construction independent of the owner or the contractor.
SCS provides Landfill CQA services across the country. We have proven, experienced field staff that observe, document and test specific physical properties of the soil liner and geosynthetics. Our engineers are experienced and licensed to certify that the liner was built in accordance with the permit requirements.
Landfill CQA is not limited to the liner system. SCS provided CQA for final cover systems, leachate forcemain systems, and methane extraction systems.
If you are wondering more about landfill CQA or have a need for your facility, give us a call. We’d be happy to discuss in more detail and assist with your project. SCS is ready to serve, and help to bring your project in service.
Learn more about Jeff Reed and Construction Quality Assurance services at SCS, or see a matrix of CQA projects completed.
Contact Jeff Reed
Meet Chuck Pryatel, the newly appointed Industrial Environmental Association (IEA) Secretary.
Chuck Pryatel is a Senior Project Advisor for SCS Engineers with over 30 years of experience in environmental regulatory compliance. He manages projects that include hazardous materials and waste compliance audits, preparation of spill prevention control and countermeasure plans, hazardous waste tank system assessments and certifications, and assists as a regulatory liaison resolving complex environmental issues. His experience includes completing environmental site assessments, subsurface investigations, preliminary endangerment assessments, health risk assessments, and environmental mitigation and clean-ups.
Prior to his private sector work Chuck served in positions of leadership at the County of San Diego Department of Environmental Health including Chief of the Hazardous Materials Division and Chief of the Site Assessment and Mitigation Division.
Chuck has a Masters of Business Administration from San Diego State University and a Bachelors of Arts in Biology from the University of California San Diego. He is a Registered Environmental Health Specialist in the State of California.
Congratulations Chuck!
The Industrial Environmental Association was formed in 1983 to promote responsible, cost-effective environmental laws and regulations, facilitate environmental compliance among member companies and provide related education activities for the community at large. The IEA’s evolution, however, has included an expanding role as the “voice” for manufacturing and associated companies in San Diego and Southern California, not only on legislative matters but on a variety of environmental issues that affect the quality of life of businesses in the region.
The Industrial Environmental Association actively insists on strong environmental compliance efforts among member companies as a matter of written policy. The IEA organizes a number of educational opportunities for member companies and the greater community including information exchanges, technical workshops, written papers, committees, and an annual conference.
IEA activism aims to prove with deeds as well as words that industrial companies care about the community, both environmentally and economically. IEA believes that industry must be involved in the process of environmental policy-making, and urges reliance on scientific, analytical data to evaluate regulations. The IEA willingly works closely with city and county government officials in an effort to realize environmental and community health protection.
Organic materials management is of high interest in our industry. This interest is being driven by state and city regulations and other government policies for diversion of organics from disposal facilities. Five states have food waste disposal bans, including Massachusetts, California, Vermont, Connecticut and Rhode Island, which are in various stages of implementation. Some cities have food waste disposal bans, including San Francisco, Seattle, Portland (Oregon), and Austin. Many states and government agencies have organic diversion policies and goals; e.g., USEPA has a 50 percent reduction goal for food waste sent to landfills, nationwide, by 2030.
SCS is helping public and private entities evaluate their organic waste streams and the applicability of established and emerging technologies (e.g., composting, anaerobic digestion) to their specific communities and circumstances. Current and recent project examples include the following:
SCS is actively pursuing work in the organics materials management sector and has a staff devoted to staying current with the latest trends and technologies. SCS can evaluate, design, permit, construct and operate organics facilities, using varying technologies. Compost technologies that SCS is considering for implementation include:
Anaerobic digestion (AD) technologies that SCS is considering for implementation include high solids (dry) or low solids (wet) systems. High solids/dry systems are applicable for food and yard waste. Dry systems for food and yard waste generally use tunnels, which are gas-tight, concrete, garage-like chambers and are loaded using front-end loaders. Low solids/wet systems are applicable for manure, sludges, and liquid industrial waste. Wet systems generally use vessels, which are mixed and are fed using pumps.
Learn more about these SCS services.
John F. Hartwell, Ph.D., PE., CHMM, and Senior Consultant at SCS Engineers recently successfully defended his dissertation and earned his Ph.D. An abstract of Dr. Hartwell’s dissertation follows:
METHODOLOGY FOR ASSESSING MUNICIPAL SOLID WASTE USING A LARGE-DIAMETER BOREHOLE
LTC John F. Hartwell, Ph.D., P.E.
University of Nebraska, 2015
Municipal solid waste (MSW) landfills are permanent repositories of society’s non-hazardous wastes. Landfill facilities are becoming harder to site, resulting in increasing pressure to maximize the use of available airspace. Increasingly, this results in developing additional airspace by way of vertical expansion. This expansion imparts greater stress on the landfill mass and the containment infrastructure.
The engineer’s understanding of the geotechnical properties of MSW has been limited to sampling of relatively shallow test pits and reconstitution of disturbed MSW samples in the laboratory. Deeper assessment using small diameter borings is difficult and produces poor low volume samples for ex-situ testing. Some researchers have synthesized MSW with obvious limitations. Landfill failures have provided opportunities for back calculation of MSW properties including shear strength, but these estimates are based on limited understanding of unit weight and moisture content with depth.
The recent trend for the harvesting of methane produced by the anaerobic degradation of MSW has resulted in the need for nearly full-depth, large-diameter, landfill gas collection wells. Prior to completion, these boreholes provide excellent opportunities for directly observing and measuring the condition of MSW in its buried, variably degraded state at depths that are far greater than previously accessible.
The large diameter MSW gas well borehole assessment methodology presented in this paper is shown to be an efficient and valuable means for characterizing MSW. This means that the cost of the assessment is relatively low as the drilling costs are negligible and therefore limited to the cost of labor to sample and perform field observation and laboratory testing. The assessment methodology, which includes scaled full coverage photography and videography, allows precise analysis of a number of geotechnical properties such as wet and dry unit weight, moisture content, specific gravity, void ratio, % saturation of MSW and buried soil layers throughout the depth of the borehole. Further, MSW constituents and biologic degradation can be measured. The orientation / alignment of tensile reinforcement within the waste mass is readily observable. Zones of perched leachate and the effects of mechanical creep on borehole diameter can also be measured.
Contact John Hartwell or Contact SCS Engineers
Learn more about MSW Landfill Services from SCS.
Two EPA landfill gas rules were published in the Federal Register in August 2015. The proposed EG Guideline rule affects “new” and “existing” landfill sites. Remember, these are guidelines only. Your local and state government agencies will use them to develop and implement the actual rules by which you do business.
Learn more in one place by reading the recent article in Waste Advantage Magazine, the SCS Engineers Technical Bulletin, and a slide set from a recent webinar about what you can expect for your business. All authored by Pat Sullivan, Senior Vice President at SCS and our National Expert on the Landfill Clean Air Act; NSPS.
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.
ISWA President David Newman report from Paris on the United Nations Climate Change Conference (COP21). In his report on the various negotiations and activities in Paris, David Newman highlights the work ISWA is doing with the international organisation Climate and Clean Air Coalition (CCAC). This includes the establishing of work plans for developing country’s major cities including Sao Paulo and Dar Es Salaam and holding the first Finance Workshop on to support cities seeking access to finance for municipal solid waste projects.
SCS Engineers is proud to participate in the Climate and Clean Air Coalition to Reduce Short-Lived Climate Pollutants (CCAC). SCS participates in the CCAC’s initiative to mitigate Short-Lived Climate Pollutants (SLCPs) from the Municipal Solid Waste sector.
The CCAC is a voluntary international framework that encourages countries and organisations to take concrete steps to reduce SLCPs in order to protect the environment and public health, promote food and energy security, and address near-term climate change. The initial focus is on methane, black carbon, and many hydrofluorocarbons (HFCs). Fortunately, as their name indicates, SLCPs have a relatively short lifetime in the atmosphere, and therefore, determined efforts to mitigate them now can significantly reduce their concentrations in a relatively short period of time. Many cost-effective technologies and practices have already been implemented in key sectors around the world and benefits are being seen.
To learn more about the CCAC program contact Dana Murray, a Vice President and the CCAC-SLCP Project Director at SCS Engineers.
David Newman’s report from Paris
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