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:
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:
Dr. Charles Hostetler is presenting on Wednesday, February 28th (11:00 am – 11:30 am, Century).
“Pore Space Conflicts: Class VI Injection into Previously Utilized Pore Space”
Class VI projects (involving underground injection control (UIC) wells for the geologic sequestration of carbon dioxide) can have a surprisingly large footprint in terms of the lateral extent of pore space occupied by supercritical carbon dioxide as well as pressure increases in the injection zone. A limited amount of subsurface pore space is available in certain economically important sedimentary basins and there can be difficulties in finding unutilized pore space.
Interactions among neighboring UIC projects can be an important consideration in the scoping and design of Class VI projects. Class VI project design has largely focused on examining the extent of the subsurface supercritical carbon dioxide plume and ensuring access to and control over the pore space physically occupied by the plume. The pressure buildup during injection also influences subsurface pore space. The existence of pressure buildup from neighboring injection projects can be an important limitation in efficiently utilizing pore space resources across multiple projects.
In this study, we examine the factors that affect the injectability of a supercritical carbon dioxide stream near a preexisting Class I (liquid waste) UIC well. We consider the factors that influence the pressure distribution in the injection zone, such as the compressibility of water and supercritical carbon dioxide, the properties of the aquifer materials, and the geometry of the injection zone and injection wells. We conclude by summarizing the general factors that should be considered in project scoping and Area of Review delineation—additional authors: Kacey Garber and Lindsey Hawksworth, SCS Engineers.
Additional Resources:
SCS Engineers is participating in Auburn University 2024 Civil & Environmental + Biosystems Engineering ASCE/ASABE Career Fair on February 13, 2024.
This event is a great opportunity for all students and alumni to connect with a diverse array of employers, from corporations to nonprofits, for internships, part-time, and full-time positions.
SCS is an employee-owned, award-winning environmental engineering, consulting, and construction firm with offices nationwide. We are seeking a wide variety of dedicated, hard-working professionals with Science, Technology, Engineering, and Mathematics (STEM) backgrounds.
Students can register on Handshake.com
In Dane County, three initiatives took diverse approaches to engage specific communities with education, engagement, and access to reduce waste, with resulting tools useful in other communities to increase broader engagement in recycling efforts.
In the spring of 2023, the Latino Academy of Workforce Development launched a bilingual Recycle Better Program in collaboration with Sustain Dane. In Spanish and English, it is culturally relevant to the Latinx community. Empowerment is a central theme of the program. The 13 bilingual Recycle Better leaders teach additional family, friends, and community members recycling knowledge, creating a ripple effect of over 1,000 people.
Collaborating with school districts involves diverse teams: district board, administration, custodians, principals, food staff, teachers, students, and volunteers. After piloting and securing support, Madison School District sped up recycling in 2023-24 across elementary and middle schools. The program aims to extend beyond initiation, striving to educate and empower staff and students for waste reduction and recycling habits at home and in the community.
Recycling food scraps and keeping them from landfills has been a priority in Madison. Sustain Dane coordinated two free farmers’ market food scrap drop-off sites over the past two years. Experiences in launching the program, educating the public on allowable food scraps vs contamination, and tracking the success of over 25,000 lbs. of food scraps kept from the landfill will be shared. Food scrap collection is more accessible to community members in Madison through education and engagement.
Learn more at the 2024 Wisconsin Integrated Resource Management Conference when Chris Jimieson co-presents “Engaging New Strategies and New Audiences to Increase Waste Reduction” with Samantha Worden of Sustain Dane and Baltazar De Anda Santana of Latino Academy of Workforce Development, Inc.
Meet Project Manager Chris Jimieson at WIRMC or contact him at or on LinkedIn. Mr. Jimieson has over 20 years of experience as a geological engineer and hydrogeologist on a wide variety of civil and environmental engineering projects. He manages environmental compliance projects as well as municipal solid waste and sustainable materials management projects.
Connect with SCS experts at the 2024 CT Compost Conference presented by the Connecticut Compost Alliance at Connecticut College on March 14th in New London, CT. This free, one-day event features engaging in-person sessions where attendees can learn more about how composting benefits local communities, businesses, residents, farms, the environment and improve climate resiliency.
SCS National Expert on Organics, Greg McCarron, PE, will present and exhibit.SCS is proud to be a Silver sponsor for this exciting event. Registration is free and open to the public.
Capturing carbon dioxide and injecting it into a Class VI well for permanent geologic carbon sequestration, or CO2 storage, is a practice that industry leaders use to decarbonize manufacturing processes. Manufacturers use CO2 storage to reduce their greenhouse gas emissions and carbon footprint. There has been an uptick in proposed projects, both commercial hub-scale and single emitter-affiliated scale, particularly within the last year. The catalyst for the uptick in proposed projects is primarily the associated financial incentives, including federal tax credits and grant monies.
In this educational webinar, Professional Geologist Kacey Garber describes what manufacturers interested in geologic CO2 storage can expect the project landscape to look like in 2024. The video includes a discussion of the following:
Understanding the current project landscape and how and when future project opportunities might evolve is important for manufacturers considering the geologic storage of their CO2 stream, whether through a larger commercial hub or a smaller on-site project.
Additional Resources:
About the Presenter: Kacey Garber is a professional geologist experienced as a groundwater project manager for active and closed industrial client sites. Her responsibilities include groundwater monitoring and statistical analyses; reports and permit applications; designing sampling and analysis plans; special groundwater studies; and conducting groundwater well construction planning and design. She has also been involved in PFAS work groups and publishes on the topics of UIC and geologic carbon sequestration.
Join SCS Engineers professionals at the Recycling Association of Minnesota/SWANA Annual Conference, April 2-3 at the Mystic Lake Center in Prior Lake, MN.
The RAM/SWANA Conference & Show is the premier recycling and waste management conference in the Upper Midwest. This is a great opportunity for professional development, networking and on-site tours.
Click for more details and registration information
Join SCS Engineers professionals, at Wisconsin’s Safety Council’s Annual Conference, April 15-17 at the Kalahari Resort in Wisconsin Dells.
Wisconsin’s Safety Council’s Annual Conference is Wisconsin’s premier event highlighting health, safety and human resource best practices challenges and solutions. The conference features 50+ educational sessions, 200 exhibitors and 5 pre-conference professional development courses. In its 82nd year, the conference provides a unique opportunity for professionals to share resources and experiences with colleagues, and to discuss views and concerns with a wide range of stakeholders. You can expect to hear from the same top-notch speakers and attend sessions with the latest safety information.
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Join SCS Engineers professionals, including our National Landfill Expert, Betsy Powers, for the Solid Waste Landfill Design Course, April 1-3 at the Pyle Center in Madison, WI.
During the course you will have the opportunity to learn about the critical factors of solid waste landfill design, operations, evolving industry issues, and economics. Learn from expert and diverse course faculty (top-flight researchers, owners at the cutting edge of evolving practice, industry experts). Get a firm grasp of the background and design specifics to compete in this industry, including industry-leading information on the principles and practices of solid waste landfill development, design, construction, operations, and management. Understand practical emerging technologies including:
This course will guide you through the development process of a successful solid waste landfill, from cradle to grave. Industry experts will share critical factors and insights. Interactive discussion and idea exchange will be emphasized. Click to learn more and enroll today.
Meet SCS Engineers professionals at the Iowa Society of Solid Waste Operations (ISOSWO)’s Spring Conference, March 14 – 15, at the Rock Island Inn & Suites in Marshalltown, Iowa.
The conference will feature networking opportunities, tours, exhibits, and educational sessions.
Click for more details and registration information
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