Inside SCS Engineers, an award-winning environmental services firm, are practices that specialize in permitting, designing, implementing, and performing the operational maintenance and monitoring of modern solutions for essential public services that impact climate change.
Focusing their efforts and investment on solid waste management efficiencies for municipalities leads to better customer service and helps lower emissions that impact communities. For example, the Solid and Hazardous Waste Management Division in Collier County, FL, uses SCS on a variety of progressive solid waste and resource management projects. These projects include sustainable materials management, facilities and operations planning, and landfill optimization.
The County also reaches out to SCS Engineers as a resource to answer questions that only an expert environmental engineer can safely answer. Think of searching Google but only getting advice from qualified professional engineers and scientists who know your specific geology, environmental systems, and regulations.
Environmental Expertise On-Demand
For example, the County’s Division Director called Daniel Dietch, its SCS Engineers client service manager, to inquire about a specific contractor’s plan to excavate stormwater ponds within 1,000 feet of the County’s new deep injection well (DIW). Dietch is not a DIW expert, but with a single call to his colleague, Monte Markley, he could address the Division Director’s question in detail.
The client learned about SCS’s DIW knowledge and expertise in the process.
Knowing SCS’s DIW capabilities, the County’s Division Director contacted SCS again with a different concern and need. The County planned a ribbon-cutting ceremony for their new DIW and asked if SCS could quickly prepare several informational boards to display at the public ceremony.
With SCS’s expertise, Dietch contacted SCS resources, engaging Marketing Manager Renee Roman and Carbon Sequestration and Injection Well Services Leader Stephanie Hill to develop simple yet informative images that helped the County “tell the story” of their DIW. You can view the infographics here!
Outreach with all stakeholders, including community organizations, regulatory agencies, the public, and local environmental advocacy groups, about well-installation plans and the science behind them leads to smoother-running projects. It helps everyone understand how safe DIW technology is and why the EPA and state regulatory agencies approve it.
The work was fast-paced and collaborative, and the finished product showcased how knowing the client, understanding the subject matter, and collaboratively working as OneSCS are successes.
The County’s Division Director shared this with the SCS Team: Thank you for your guidance along the way, offering experts and project management teams, as this project hit bumps along the path. Finally, the much-needed, resilient infrastructure is in place, and not without a team of professional and technical experts, even those that were able to offer support in times of uncertainty.
SCS Educational Resources:
The U.S. Environmental Protection Agency (EPA) focuses on strengthening the regulation of PFAS chemicals, potentially including establishing enforceable limits on these substances in drinking water and other environmental media. Enhanced monitoring and reporting are also part of this initiative to understand PFAS prevalence and impact better.
Under the Comprehensive Environmental Response, Compensation, and Liability Act of 1980 (CERCLA or Superfund), the EPA is progressing towards officially classifying two PFAS constituents – perfluorooctanoic acid (PFOA) and perfluorooctane sulfonic acid (PFOS) – as hazardous substances (HSs). This action aims to simplify the process of cleaning up contaminated sites and minimizing human exposure to these persistent chemicals.
Proposed CERCLA Requirements
With PFOA and PFOS designated hazardous under CERCLA, facilities will be required to report on releases at or exceeding the reportable quantity (RQ) assigned to these substances. Under the proposed rule, this would be a one-pound or more release in 24 hours. Once PFOA and PFOS are designated hazardous substances, the EPA will no longer need to show an immediate threat. As a hazardous substance, that threat is already assumed, prompting the investigation and remediation of PFAS releases and allowing the EPA and private entities to recoup costs for cleaning up these contaminations.
Once the CERCLA HS designation becomes final, EPA plans to issue a CERCLA PFAS Enforcement Discretion Policy. Preliminarily, we understand that the enforcement policy will focus more on manufacturers, federal facilities, and industrial facilities that have released significant PFAS, resulting in significant public health and environmental impacts, as opposed to community water utilities, POTWs, and landfills.
The CERCLA HS public rulemaking notice was issued in September 2022, with the comment period closing in November 2022 (https://www.govinfo.gov/app/details/FR-2022-09-06/2022-18657). Over 64,000 comments filed indicate a very high degree of public interest. The finalization of the rule is expected in March 2024.
CERCLA Impact on Landfills and Facilities
PFAS, prevalent in a myriad of consumer products like nonstick cookware, carpets, upholstery and fabrics, toilet paper, and food packaging, has been part of the waste stream for a long time. Addressing their contamination is challenging and expensive due to the evolving nature of treatment and destruction technologies.
The CERCLA classification of PFOA and PFOS as hazardous will profoundly affect landfills, particularly those with contamination. Landfill operators might bear the fiscal responsibility for remediation efforts under CERCLA.
Waste management companies should be especially concerned, given that PFAS is found in most landfills due to the prevalence of chemicals in consumer goods. These companies could face legal action for contributing to cleanup costs should PFAS migrate outside the landfill. The potential for broader PFAS classification raises concerns about re-openers for these sites in the future.
Landfills accepting PFOA and PFOS waste will face stricter regulations, including more rigorous monitoring, reporting, and management to prevent environmental release. This may lead to changes in waste acceptance policies to limit or prohibit PFAS-containing waste streams.
Landfills with a history of PFAS waste may undergo investigations into past disposal methods and potential past contamination. Enhanced containment and leachate management systems may be necessary to prevent PFOA and PFOS from leaching into the environment.
Industry organizations like the Solid Waste Association of North America and the National Waste and Recycling Association have expressed concerns about the substantial fiscal impact of this designation on landfills, with potential cost pass-through to ratepayers and broader unintended consequences.
Leachate Treatment
The regulation of PFAS under CERCLA will have notable impacts on leachate treatment. Facilities that handle leachate may need to implement more advanced and effective treatment technologies to remove PFAS from leachate.
Facilities may need to implement supplemental treatment processes to reduce the concentration of PFAS in the waste stream before it reaches the leachate treatment stage or perhaps after primary treatment. EPA is working on proposed regulations to address PFAS in wastewater under the Effluent Limitations Guidelines program and the National Pollutant Discharge Elimination System permitting program.
The need for more sophisticated treatment technologies and processes will lead to higher operational costs for waste management facilities. Costs include installing new treatment systems and ongoing expenses related to their operation and maintenance.
Overall, the regulation of PFAS will cause significant changes in how leachate is treated and managed, with implications for costs, technology, compliance, and overall waste management practices.
Conducting comprehensive risk assessments to find and address potential sources of PFAS contamination within their operations can help manage and mitigate risks effectively. Waste management companies should consider reviewing their liability insurance coverage to account for potential risks associated with handling PFAS-contaminated waste.
If waste management companies incur significant expenses in managing PFAS waste, exploring legal avenues for cost recovery from PFAS producers might be a long-term strategy to consider.
Remember, PFAS degradation is exceptionally slow or non-existent under normal environmental conditions, so businesses can be held accountable for contamination that occurred years ago. Cases that were closed years ago could reopen.
Landfill Operations
In summary, the CERCLA classification of PFOA and PFOS as CERCLA hazardous substances marks a significant shift in landfill management, emphasizing the need for more aggressive waste practices to safeguard public health and the environment from these persistent chemicals.
Our engineers will discuss technologies to treat and remove PFAS now and the technologies that show the most promise to scale efficiently as we keep you aware of the impact of pending regulations. Please look on LinkedIn for more posts, papers, and webinars to come.
Additional Resources:
About the Authors: Connect with our authors and experts at
Jeff 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.
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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