Join SCS on June 10 for another client webinar. Using case studies, we show you how our clients tackle common challenges using proven GIS technology to reduce expenses and run more productively.
Property Development: Time is money on development projects. Environmental engineers use GIS to more accurately pinpoint potential contamination sources, conduct site assessments, strategize remediation solutions, and see sampling results weeks faster. Infographics and dashboards show if and exactly where to continue sampling without waiting weeks or months for reports.
Landfills: Operators make diagnostic and forensic use of GIS to address maintenance tasks faster. We’ll cover modeling 3D wells and liquid level data, showing how GIS embedded dashboards and infographics pinpoint exactly where to assign staff. At the same time, supervisors monitor completed assignments seeing real-time results and what still needs attention.
Siting Solid Waste Facilities: Decision-makers use multi-criteria decision analysis incorporated into a geographic information system to account for relevant technical data, environmental, social, and economic factors during the site selection of a waste transfer station. The resulting maps and infographics are useful at public meetings too.
May 27, 2021, from two separate U.S. Environmental Protection Agency (EPA) announcements:
EPA intends to reconsider and revise the 2020 CWA Section 401 Certification Rule
Congress provided authority to states and Tribes under CWA Section 401 to protect the quality of their waters from adverse impacts resulting from federally licensed or permitted projects. Under Section 401, a federal agency may not issue a license or permit to conduct any activity that may result in any discharge into navigable waters unless the affected state or Tribe certifies that the discharge is in compliance with the Clean Water Act and state law, or waives certification.
EPA intends to reconsider and revise the 2020 CWA Section 401 Certification Rule to restore the balance of state, Tribal, and federal authorities while retaining elements that support efficient and effective implementation of Section 401. While EPA engages with stakeholders and develops a revised rule, the 2020 rule will remain in place. The agency will continue listening to states and Tribes about their concerns with implementing the 2020 rule to evaluate potential administrative approaches to help address these near-term challenges.
The agency’s process of reconsidering and revising the 2020 CWA Section 401 Certification Rule will provide an opportunity for public and stakeholder input to inform the development of a proposed regulation, and will include sustained dialogue with state and Tribal co-regulator partners and local governments around these issues. EPA will begin a stakeholder engagement process in June to hear perspectives on this topic and how to move forward. More information will be available at: www.epa.gov/cwa-401.
EPA, Region 7, public listening sessions on the RMP Rule
Section 112(r) of the Clean Air Act Amendments requires EPA to publish regulations and guidance for chemical accident prevention at facilities that use certain hazardous substances. These regulations and guidance are in the Risk Management Plan (RMP) rule, which requires facilities using extremely hazardous substances to develop a Risk Management Plan that:
These plans provide information to local fire, police, and emergency response personnel to prepare for and respond to chemical emergencies in their community.
The Region 7 EPA announced two upcoming virtual public listening sessions on the Agency’s Risk Management Plan (RMP) rule. The RMP rule has been identified as an action for review under Executive Order 13990: Protecting Public Health and the Environment and Restoring Science To Tackle the Climate Crisis.
The listening sessions will give people the opportunity to present information, and provide comments or views pertaining to revisions made to the RMP rule since 2017. The Occupational Safety and Health Administration (OSHA) will also participate in the listening sessions and receive comments on their Process Safety Management (PSM) standard, which contains similar requirements to the RMP rule.
Virtual public listening sessions will be held on:
For more information on the public listening sessions:
https://www.epa.gov/rmp/forms/virtual-public-listening-sessions-risk-management-program-rule.
Submit written comments via the docket at: http://www.regulations.gov, Docket ID: EPA-HQ-OLEM-2021-0312 until July 15, 2021.
EPA Region 7 serves Iowa, Kansas, Missouri, Nebraska, and Nine Tribal Nations.
All landfills regulated under the NESHAP air program must comply with updated federal regulations by September 2021, including new requirements for landfill gas beneficial use treatment systems and gas system design plans. Additionally, the EPA is finalizing a federal plan implementing new NSPS air rules for landfills modified or constructed before July 2014, and not yet covered under an approved state plan.
At the state level, as part of a continued focus on greenhouse gas (GHG) reduction, Maryland MDE is expected to publish new regulations this year addressing landfill methane control.
Jacob Shepherd, P.E., will cover what landfills need to do to comply with the updated federal regulations and will discuss anticipated new requirements under the MDE regulatory initiative as an example of the direction states are moving.
This discussion takes place at REVISION 2021, an online conference.
For additional information, see our recent blog: Regulatory Alert: MSW Landfills Federal Plan to Implement the Emission Guidelines (EG) and Compliance Times.
SCS Engineers periodically prepares SCS Technical Bulletins – short, clear summaries of U.S. Environmental Protection Agency (EPA) rules and plans. On May 21, 2021, the EPA published a Federal Plan to implement the new Emission Guideline (EG) rule for municipal solid waste (MSW) landfills. The Federal Plan is published under Title 40 of the Code of Federal Regulations (CFR) Part 62, Subpart OOO.
Read, share, download the Federal Plan for Landfill EG Rule Tech Bulletin here.
It goes without saying: landfill operators are forever working to stay on top of odors, especially when the community smells something and points to the landfill or when regulators come calling. This blog shares two odor stories: one around landfill gas and another around trash. Then it looks at what happened when an operator got a permit restriction over alleged hydrogen sulfide emissions; odor was not the problem here. It was a perceived health risk; learn how SCS proved a predictive model was off the mark.
Is Landfill Gas a Source of Community Odors? And Ensuring Compliance
Living up to landfill odor nuisance standards is tough. The underlying premise is that odors must limit peoples’ ability to enjoy life or property to create a public nuisance, but it’s a subjective call. How strong an odor is and sometimes even if it exists depends on perception, so the question becomes: when they aren’t sure what they are being measured against, how do operators comply and prove compliance?
SCS recently helped a client figure out how to accomplish this after receiving odor complaints from the community, ultimately leading to a state agency-issued violation.
“We needed to thoroughly investigate to identify and mitigate odors, then prove compliance to the state regulator. Making a strong, valid case without having a numeric standard to go by takes both creativity and a scientific approach,” says Pat Sullivan, SCS senior vice president.
Sullivan, a biologist and his team of meteorologists, air dispersion modelers, and engineers, had a good starting point. They knew landfill gas was the source of the problem. But they needed more data to get to the root of that problem, and the operator’s required surface monitoring did not tell enough of the story.
The team launched a series of studies relying on multiple investigative tools.
“When we may have to put in more gas collection components, as we did here, we want to be sure we install them exactly where they are needed. This entails going above and beyond the standard modeling with a more rigorous methodology to get a comprehensive landfill gas emissions footprint,” Sullivan says.
SCS began by bringing out a drone to reach more landfill areas than technicians on foot for better coverage. The drone can fly over slopes, areas too dangerous to walk due to constant movement of heavy equipment, and areas inaccessible because of snow and ice. As it flies, it shoots a laser, which identifies methane based on the light refraction by methane molecules—then incorporates the data into a map for a comprehensive, visual picture.
Knowing methane concentrations at specific locations is important, but determining where to be more vigilant in controlling landfill gas also requires knowing hydrogen sulfide (H2S) concentrations. Sometimes overall methane levels are within acceptable limits, but the hydrogen sulfide in it is elevated, which could be a problem, Sullivan explains.
Getting a good grasp on H2S’s potential impact is tricky, as levels can vary radically from one area of the landfill to another. Pat Sullivan, SCS senior vice president, has seen them range from 100 parts per million to as high as 100,000 at different locations.
SCS used a Jerome meter, a highly sensitive tool that precisely quantifies H2S down to low-level part per million levels. SCS took it across the landfill and then into the community in search of H2S hot spots.
At the same time that the team investigated surface emissions of H2S, they went deeper down, sampling each landfill gas extraction well for levels of this volatile sulfur compound to identify potentially problematic spots within the landfill gas system.
“For this, we used Dräger sampling tubes, a resourceful tool in that rather than sending 100 samples to the lab, we analyze them ourselves and get immediate results,” Sullivan says.
Technicians get accurate quantitative results within plus or minus about 20% and can view concentration readings out in the field. Results are recorded on field logs and entered into a database for future analysis.
SCS overlaid the methane data from the drone study with the H2S data on both surface emissions and wells to develop a roadmap to design a landfill gas system upgrade. It includes new wells and piping in focused areas and more blowers for increasing the vacuum to pull more gas.
“We saw immediate results,” Sullivan says.
“Total gas collected went up 15 to 20 percent. Complaints went down significantly, and our client has not received another violation since.”
Of course, as the landfill takes in more trash, it will generate more gas, so due diligence is ongoing.
“Problem-solving is a phased approach. You do what you determine to be most effective; evaluate; then do additional work to improve. We will continue to follow this site and fine-tune where needed to keep the system running efficiently and keep the community and regulators happy,” Sullivan says.
Taking Down Landfill Odors from Trash
New garbage on a landfill’s active face can be a source of offsite odors, but determining if the waste facility is responsible, and determining when, where, and how odors travel, takes forensic work. Landfill odor experts rely on multiple data sets and tools to understand what can be complex issues and ultimately devise the most effective odor mitigation program when necessary.
In a couple of recent scenarios in Southern California, SCS combined complaint data, meteorological data, and smoke studies to get a full picture that verified the decomposing waste was the odor source. Then staff helped nail down specific times the problem occurred and under what conditions; providing a concise window can save operators labor and other resources because they can execute proactive measures only when needed.
“We look at complaint data to learn the location, day, and time of the complaint, but these accounts are not reliable by themselves. So, we overlay this information with meteorological data to determine the wind conditions during those days and times. Weather-related data is important in vetting offsite odors because if the landfill is not upwind of the location when the complaints happen, there likely is another source,” says Pat Sullivan, SCS senior vice president.
Sullivan and his team begin their investigations in two possible ways – setting up meteorological stations at strategic areas on the landfill to capture wind-related data or capturing data from already situated stations. Then they produce wind roses from their findings, which graphically represent wind speed; how often the wind blows from certain directions; and how these two correlate. In these two scenarios, graphing wind data times during each day helped determine exactly when specific wind conditions are prevalent.
In one of the two cases, odors occurred in the summer and almost always in the morning. The data not only showed where the winds were coming from at those times, but also showed they were traveling at low to moderate speeds.
“We matched that information to complaints and confirmed that the wind conditions were indeed driving the odors,” Sullivan says, explaining the speeds were just enough to carry the odor molecules into the community but not high enough to disperse and dilute them.
“Now we have painted a picture of wind conditions that we can focus on to get more information. We are getting closer to designing a multi-tiered odor mitigation program,” he says.
The next step was a smoke study, which reveals how odors move offsite, identifying the exact pathways and movement trajectory. These details are important because to treat or disrupt odor molecules; operators need to intersect the odor plume before it leaves the site.
SCS odor experts release colored smoke at the time and location they believe odors are, based on the meteorological data. They film from a drone to get a bird’s eye view of the smoke plume as well as get a camera filming from a different angle, following the plume movement to identify its path out of the landfill. This method enables them to determine where to intersect the odors as they move through the air before leaving the site.
From this research came three recommended measures to take during unfavorable wind conditions:
One of the landfill operators now has the problem under control and has received no further violations.
The other site made many of the same changes and plans to open a second disposal area for smelly loads. This client has seen a significant reduction in complaints and violations, but it’s a work in progress. The next true test will come when Sullivan and his team reevaluate in the summer.
“We will see then if any improvements are needed and tweak the solution if needed.”
And as with our other clients, we are training operators on how to be proactive. We teach them how to identify and grade odors and how to follow set procedures. And we help them with strategy implementation,” he says.
Odor mitigation is an ongoing undertaking. The team continually assesses and quantifies emissions and potential impacts.
“We look for changes that will control odors or prevent them in the first place. And we provide clients with the know-how and support to stay ahead today and into the future. Landfills and waste volumes are growing and changing. It’s a dynamic scenario. And we continue to build on what we have proven and adjust to keep up to make more progress,” Sullivan says.
Showing That a Model Can Over Predict H2S Emissions
Hydrogen sulfide (H2S) can be problematic even at very low concentrations, so this volatile sulfur compound is on federal, state, and local regulators’ radar. Some jurisdictions require the evaluation of air toxic emissions to determine potential health impacts to nearby communities.
They are also calling for these evaluations during permitting or to decide when controls are needed. To make these impact determinations, regulators typically rely on standard H2S risk assessments leveraging air dispersion modeling that predicts concentrations at locations away from the source.
However, this methodology, which includes estimates of emissions and predicts offsite concentrations based on algorithms that mimic how air moves, is not always accurate. Inaccuracy proved to be the case at one SCS client’s site. The model overpredicted offsite measurements of H2S that the state and local agency classifies as toxic.
Ultimately, the client entered into an enforcement agreement with the state because the operator had a permit limit, based on results of the risk assessment that it could not meet.
“Respectfully, the agency came in maintaining that the levels were out of compliance; it came as a surprise and seemed questionable to our team given our experience. We felt that the air modeling and risk assessment results derived from this modeling were not accurate,” says Sullivan.
First, his team tried to adjust model inputs and variables that would yield what they believed would be more accurate data. Even though they could show improvements, the model adjustments could not obtain readings that showed compliance with the risk-based limits.
Next, they began going out monthly and measuring real concentrations at receptor locations. The team used a Jerome sensor, a highly sensitive handheld device that detects H2S down to single-digit parts per billion levels with good accuracy.
When they compared the predictions from the standard model to their readings on the same days of each month and same times of day, they confirmed the concentrations were well below the acceptable risk threshold.
“Because we did this over an extended period, we have continuous readings and a large data set from many locations that give a history and statistical validity,” Sullivan says. Every monitored value was substantially lower than the values predicted by the model.
“What that means is we could show that while there were onsite emissions, they were not escaping the landfill at levels that would exceed risk-based thresholds. That was useful in proving to the regulators that the landfill was actually in compliance with the standard, even when the model suggested it was not,” Sullivan says.
Now SCS is asking for revising its client’s permit and that the limitations are made more flexible based on real-time, longer-term findings. While the team is still waiting on the final permit decision, they’re confident they have proof that the site complies with the risk-based limit.
The outcome of this project has potential beyond possibly changing one permit for one operator, Sullivan surmises.
“We think the data developed from this study showing how the models can overestimate real-world conditions can ideally help other operators build a sound case in circumstances where they truly are in compliance.”
Related Resources
Staying Ahead of Odor Management at Solid Waste Facilities – This video recording is from a live session about the challenges of odors, including measuring them and the science behind them. Throughout the recording, the speakers’ field questions as they make recommendations for assessing and avoiding odors, regulatory issues, litigation, and responding to complaints.
The presentation and Q&A run for 1 hour 41 min. It’s well worth your time, with plenty of questions posed by solid waste facility operators, landfill managers, and composting operators answered.
SCS Engineers encourages you to share this video or any from our Learning Center. You can embed them at events and use them for in-house training. Look for our
(40 CFR Part 60, Subpart OOO)
On May 21, 2021, EPA published the final MSW Landfills Federal Plan, which implements the 2016 Emission Guidelines (EG Subpart Cf) under 40 CFR Part 62 Subpart OOO. The Federal Plan becomes effective June 21, 2021, and impacts landfills that have not triggered NSPS Subpart XXX requirements and landfills located in states and Indian country without EPA-approved EG Cf rules.
Affected are MSW landfills that commenced construction on or before July 17, 2014, and have not been modified or reconstructed since July 17, 2014.
The Federal Plan requires existing landfills that reach an annual emissions threshold of 34 metric tons of nonmethane organic compounds (NMOC) or more to install a system to collect and control landfill gas (GCCS). It also implements various emission limits, compliance schedules, testing, monitoring, reporting and recordkeeping requirements for GCCSs established in the 2016 Emission Guidelines for MSW Landfills.
The Federal Plan also establishes a definition for “legacy controlled landfills.” These are landfills that have previously satisfied the requirement to submit an initial design capacity report, initial (or annual) NMOC emission rate reports, and collection and control system design plan under 40 CFR part 60, subpart WWW; 40 CFR part 62, subpart GGG; or a state/tribal plan implementing 40 CFR part 60, subpart Cc.
If you are subject to the Federal Plan and are not a “legacy controlled landfill,” you must submit a design capacity report by September 20, 2021. And if the design capacity report indicates a capacity equal to or greater than 2.5 million Mg and 2.5 million m3 of solid waste, you must also submit an initial NMOC emission rate report within 90 days after the effective date of the Federal Plan (September 20, 2021).
SCS is working to develop a Technical Bulletin for distribution to our mailing list and on social media. The Bulletin will consolidate the Final Rule into several pages highlighting significant dates and key impacts for you.
SCS Engineers is expanding its environmental expertise with Nathan Williams, PE, as an Environmental Engineer in the firm’s Portland, Oregon office. Williams will support SCS’s growing client base in the region to meet and remain compliant with local, state, and federal regulations that impact their business or municipality, with particular emphasis on stormwater compliance and management.
Washington, Oregon, and Idaho clients have regulatory requirements that include Compliance Audits, Spill Prevention and Countermeasure Plans (SPCC), Stormwater Pollution Control Plans (SWPCP), Air Pollution Control Discharge Permits, Risk Management Plans, Form R reports and Resource Conservation and Recovery Act (RCRA) Part B. These plans and permits address regulatory requirements and help protect watersheds and wetlands that provide drinking water to downstream communities, habitat for fish and wildlife, and countless other public and economic benefits.
Williams brings expertise and credentials to provide comprehensive stormwater management services to support businesses in the region ranging from vineyards to landfills. His experience includes working on permitting and remediating contaminated sites for industrial, residential, and power generation reuse across Oregon and Washington.
As a Certified Erosion and Sediment Control Lead, Williams has extensive experience in erosion and sediment control projects, from design, permitting, implementation, and project closeout with final stabilization. Combining these skillsets helps businesses continue to deliver products and services on schedule as they encounter increasingly rigid compliance regulations.
As with all SCS Engineers employee-owners, Nathan Williams engages in industry associations and his community. Learn about Nathan and how his work on the SCS team helps municipalities, all citizens, and businesses thrive.
About SCS Engineers
SCS Engineers’ environmental solutions and technology directly result from our experience and dedication to industries responsible for safeguarding the environment as they deliver services and products. For information about SCS, watch a short video, visit our website, or follow us on your favorite social media.
$2 million in cooperative agreements is available for local governments to host Community Compost and Food Waste Reduction (CCFWR) pilot projects. The cooperative agreements support projects that develop and test strategies for planning and implementing municipal compost plans and food waste reduction plans. They are part of USDA’s broader efforts to support urban agriculture.
USDA’s Office of Urban Agriculture and Innovative Production will accept applications on Grants.gov until 11:59 p.m. Eastern Time on July 16, 2021. Projects should span two years, with a start date of September 25, 2021, and a completion date of September 25, 2023.
Local governments may submit projects that:
NRCS will assist in conservation-related activities.
Priority will be given to projects that include economic benefits; provide compost to farmers; integrate other food waste strategies, including food recovery; and collaborate with multiple partners.
The deadline for applications is July 16, 2021.
Project Example: The Department of Sanitation of New York and nonprofit Big Reuse establishes food scrap drop-off locations while New York City Parks Department is diverting wood chips and leaves from landfill disposal to create compost. GreenThumb, Brooklyn Grange, Hellgate Farms, Gowanus Canal Conservancy, and other urban farms distribute the compost for food production in the boroughs of Queens and Brooklyn, diverting approximately 600,000 pounds of food scraps and green waste from landfills and providing 350 cubic yards of compost to food producers.
Get Started with SCS’s ASP Composting Pilot Program
• Low-cost opportunity to test ASP composting feasibility
• Ability to test different feedstock mixes
• Assess the quality of the finished compost
• Assess odor control and process control
• Test footprint is 5000 sqft or less on your site
Webinar
A pre-recorded webinar will provide an overview of the cooperative agreements’ purpose, project types, eligibility, and basic requirements for submitting an application. The webinar will be posted at farmers.gov/urban.
More Information
Questions about this cooperative agreement opportunity can be sent to .
The Office was established through the 2018 Farm Bill and is designed to be a USDA-wide effort. Representatives from agencies throughout USDA play a critical role in successfully servicing urban customers. Other grant and engagement opportunities are available in addition to the CCFWR agreements. More information is available at farmers.gov/urban.
Additional resources that may be of interest to urban agriculture entities include NIFA grants, FSA loans, and AMS grants to improve domestic and international opportunities for U.S. growers and producers.
Partial Reprint from EPA Announcement
The U.S. Environmental Protection Agency (EPA) is announcing the selection of 151 communities to receive 154 grant awards totaling $66.5 million in Brownfields funding through its Multipurpose, Assessment, and Cleanup (MAC) Grants.
This funding will support underserved and economically disadvantaged communities across the country in assessing and cleaning up contaminated and abandoned industrial and commercial properties. Approximately 50 percent of selected recipients will be receiving EPA Brownfields Grant funding for the first time and more than 85 percent are located in or serving small communities.
The grant announcement includes:
The list of the fiscal year 2021 applicants selected for funding is available here: https://www.epa.gov/brownfields/applicants-selected-fy-2021-brownfields-multipurpose-assessment-and-cleanup-grants
Please spend some time with our experts as they help you negotiate funding, regulatory compliance, and helpful tools that will help your community prepare to remediate brownfields and other properties with a past into affordable housing, mixed communities bolstering economic development, stadiums, recreation facilities and parks, logistics centers…
SCS Engineers is expanding its environmental expertise hiring Richard Southorn, PE and PG, as Project Director in the firm’s St. Charles, Illinois office. Richard is a Professional Engineer in 13 states and a Professional Geologist in Illinois and Delaware. He will support SCS clients with their coal combustion residual (CCR) and municipal solid waste projects, including facilities for composting and the safe management of hazardous wastes.
As a Project Director, he runs teams providing comprehensive services ranging from construction plan development to full-scale design services. His client responsibilities include the coordination and supervision of the project teams made up of professional engineers, geologists, technicians, planners, and support staff.
Richard has expertise in developing site layouts and analyzing designs for multiple landfill facilities. These designs fit within the comprehensive environmental services landfill operators need to manage these complex, integrated systems. Richard’s design approach for landfill infrastructure integrates the elements that all play a role in environmental due diligence, including the landfill base and final cover liner systems, leachate extraction and cleanout systems, landfill gas control systems, and stormwater management controls.
As a licensed Professional Geologist, Southorn also oversees geotechnical stability evaluations, stormwater modeling, and the design and evaluation of landfill gas systems that minimize greenhouse gases. He has overseen many hydrogeological investigations that characterize subsurface stratigraphy, hydrology and hydrogeology, protecting groundwater for safer and more efficient facilities.
As with all SCS Engineers employee-owners, Richard engages in industry associations and his community. Learn about Richard Southorn and how SCSs’ work protects all citizens.
About SCS Engineers
SCS Engineers’ environmental solutions and technology directly result from our experience and dedication to industries responsible for safeguarding the environment as they deliver services and products. For information about SCS, watch a documentary, or follow us on your favorite social media. You can reach us at .
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