SCS Tracer Environmental has a diverse staff of instructors who provide practical, cost-effective ammonia refrigeration training and certification review courses. Training can be provided on-site, at our new training classroom in Oakdale, Minnesota, or at one of our nationwide sessions. Our training programs incorporate RETA, IIAR, manufacturers, field materials, facility-specific standard operating procedures, and/or piping and instrumentation diagrams.
Ammonia Refrigeration Operator Training Programs use the applicable RETA Industrial Refrigeration (IR) 1 & 2 manuals, which participants keep at the conclusion of the classes. These intensive four-day classes are provided in locations across the nation (convenient for attendees to participate locally) or in our new Minnesota classroom.
Operator I: This course is based on the materials in RETA IR-1 Course and is designed as an entry-level training program for a refrigeration operator, manager, and/or safety personnel with limited refrigeration training, or experienced operators who have never received the basic fundamentals of refrigeration principles. Operator I training is also offered in Spanish.
Operator II: This course is based on the material in RETA IR-2 Course and is designed for a refrigeration operator, manager, and/or safety personnel who have successfully completed the Operator I class and have a desire to further their knowledge in industrial refrigeration systems and principles using ammonia as a refrigerant.
PSM/RMP Introduction Training Class uses ammonia refrigeration-focused material specific to your PSM/RMP program and facility, RETA, IIAR, manufacturers, and field materials, as well as facility-specific standard operating procedures. We highlight the responsibilities of the various PSM/RMP Team Members that may include, but not be limited to, maintenance, safety, management, environmental, and/or facilities personnel:
PSM/RMP Advanced Training Class is geared for experienced PSM Program Managers, Plant Managers, ammonia refrigeration facility compliance personnel, and safety-EHS staff who want a detailed review of the more complex regulatory requirements included in the PSM and RMP regulations. The class focuses on the complex details of the following elements: Process Safety Information (RAGAGEP), Standard Operating Procedures, Management of Change (Project planning through Pre Startup Safety Review (PSSR)), and Mechanical Integrity.
RETA CARO/CIRO Review Classes are intensive training designed for operators who are pursuing their RETA CARO or CIRO certification. Each course includes a review of the pertinent materials. During Day 2, participants receive a voucher to take the RETA Practice Test, a $60 value. Our instructors use the practice test results to customize the curriculum on Day 3 to focus on the more difficult concepts.
According to the U.S. Geological Survey Circular 1344, the United States uses 79.6 billion gallons per day of fresh groundwater for public supply, private supply, irrigation, livestock, manufacturing, mining, thermoelectric power, and other purposes. This blog is intended for businesses that must meet groundwater monitoring regulatory compliance according to EPA and state mandates, which are becoming increasingly stringent.
Have you had a regulatory compliance issue due to the condition of your groundwater monitoring wells or adequacy of your monitoring network? Are you confident compliance issues won’t arise in the future? Groundwater monitoring networks—including wells and dedicated sampling equipment—are often:
What if you managed your groundwater monitoring network like your other equipment assets? By taking a systematic asset management approach to maintaining your groundwater monitoring network you can:
Not concerned? Consider the likely results of the “if it ain’t really broke, don’t fix it” approach:
Regulatory Non-Compliance: Failure to comply with state and federal monitoring well regulations may result in a notice of non-compliance, fines, or legal action.
Repair and Maintenance Costs: Ignoring minor repairs and maintenance can lead to significant well repair or replacement costs. Simple repairs like lock replacement or ground surface seal repair are quick and low cost. Don’t let these minor items put you at risk for notification of non-compliance due to neglect. Other repairs such as protective casing or near-surface well casing repair may cost more but are a fraction of the cost of replacing a well that becomes unstable due to neglect.
Well Replacement Costs: Abandoning and replacing a single well that can no longer be repaired can cost $3,000 to $10,000+ depending on the depth and construction of the well.
As with many assets, you save time and money in the long run by addressing problems before they arise. So what does monitoring well asset management look like? It doesn’t have to be complicated, costly, or time-consuming. We recommend starting with a simple inventory following these basic steps:
1. Identify needed repairs and replacements of existing wells
2. Develop a plan to repair, replace, or abandon wells as needed
3. Identify deficiencies in the coverage of your well networks
Schedule inventory Steps 1-3 yearly. Download SCS Engineers’ useful well inspection checklist to record monitoring well conditions, identify well maintenance needs and identify the regulatory status of each well. Your trained staff or your environmental consultant can perform the yearly well inventory.
Contact SCS at for a groundwater expert near you.
About the Authors: Tom Karwoski, PG, has 30 years of experience as a hydrogeologist and project manager. He has designed and managed investigations and remediations at existing and proposed landfills; and industrial, Superfund, military, and petroleum sites. Mr. Karwoski was a hydrogeologist with the Wisconsin Department of Natural Resources prior to becoming an environmental consultant.
Meghan Blodgett, PG is a project professional with over eight years of experience in the environmental consulting field, including soil, groundwater, and soil vapor investigation and remediation; brownfield redevelopment; and solid waste landfill development. She is experienced in planning and performing soil and groundwater contamination investigations, monitoring well design and installation, hydraulic aquifer testing, and soil and groundwater sampling.
REPRINT FROM THE EPA PRESS RELEASE
EPA Finds That Financial Risks from Petroleum and Coal Products Manufacturing Industry Does Not Warrant Additional Federal Requirements
WASHINGTON (Dec. 4, 2019) — Today, the U.S. Environmental Protection Agency (EPA) is proposing to not impose burdensome and potentially duplicative financial responsibility requirements for the petroleum and coal products manufacturing industry (the industrial sector that transforms crude petroleum and coal into usable products) because the financial risk to the federal government from those facilities is already addressed by various existing federal and state technical and financial requirements and modern material management practices. EPA’s proposed action would not drop existing federal requirements, rather it is a proposal to not impose additional requirements.
“After a thorough evaluation, EPA has determined that the petroleum and coal manufacturing industry’s current practices, along with existing federal and state regulations, adequately address potential financial risks to the federal government and American taxpayer,” said EPA Administrator Andrew Wheeler. “As part of President Trump’s commitment to protecting our environment and growing our economy, we are committed to responsible regulation while not imposing additional and unnecessary requirements on key sectors of the economy when the current regulatory framework is working.”
In the 39 years since the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) was enacted, a comprehensive regulatory framework has developed. Existing monitoring and operation standards have consistently worked over time to decrease the risk in this industry that if a hazardous waste cleanup is needed, the federal government will have to bear the cost of cleanup.
Further, this proposed finding does not affect, limit, or restrict EPA’s current authority to take a response action or enforcement action under CERCLA at any facility in this industry, to include requirements for financial responsibility as part of such response action, or to take appropriate action under various other federal environmental statutes that may apply to individual facilities, such as the Clean Air Act, Clean Water Act, Resource Conservation and Recovery Act, and Toxic Substances Control Act. These existing regulations, including financial responsibility requirements, continue to apply to facilities in this industry.
This proposal is consistent with the analysis EPA undertook in developing its final action for the hard rock mining industry. In that case, EPA’s approach was unanimously upheld by the D.C. Circuit Court of Appeals in July 2019. EPA has evaluated the degree and duration of risk of the possible cost to cover the cleanup of hazardous substance releases associated with the production, transportation, treatment, storage, or disposal of hazardous substances in the petroleum and coal products manufacturing industry. EPA also examined the industry’s economic trends and the financial health of the sector and found the industry to be in a relatively stable financial position with low default risk. EPA’s evaluation showed that existing regulatory programs and voluntary practices reduce the need for federally financed response action at facilities in this industry.
Background
Section 108(b) of CERCLA, also known as Superfund, directs EPA to develop regulations requiring classes of facilities to establish and maintain evidence of financial responsibility to cover the costs associated with releases or threatened releases of hazardous substances from their facilities.
In December 2016, EPA described its plan to consider financial requirements under CERCLA for the electric power industry, the petroleum and coal products manufacturing industry, and the chemical manufacturing industry. On July 2, 2019, EPA proposed to not issue financial responsibility requirements for the electric power industry. EPA is currently working on a proposal for the chemical manufacturing industry.
Today’s proposal for the petroleum and coal industry will be published in the Federal Register, and EPA invites stakeholders and the public to provide comments during the 60-day public comment period.
For more information, visit: https://www.epa.gov/superfund/superfund-financial-responsibility, or contact SCS Engineers at for help.
Wednesday, December 11, 10:45 am – 11:45 am, Room 403A
Track 2: Financing Options, Real Estate, & Economic Development
This interactive panel will discuss the nexus between brownfields development and affordable housing and will explore various policy, funding and incentive programs that have been successfully deployed in the US, including a forgivable loan and grant program in California, with an emphasis on creating affordable housing. A case study focused on Comm 22, an award-winning affordable housing project complements the policy and funding conversation. Dan Johnson, Evans Paull, and Jeff Williams share the complexities of tax credit based affordable housing finance of a 200 unit affordable housing and brownfield redevelopment project and the role that brownfields funding played. The premise is that if early-stage project funding were more widely available, combined with informed policy and regulatory approach, that the housing stock in California and elsewhere could be expanded, possibly significantly.
4:30 pm – 6:00 pm, Exhibit Hall, West Hall A
Jim Ritchie and Amy Dzialowski present on the City of West Sacramento and the SCS Brownfields Toolbox that helps take advantage of economy of scale to improve both cost and schedule outcomes, and can result in better buy-in from regulatory agencies, due to an emphasis on an overall vision rather than just a transactional approach. Flexibility is another key concept for reuse planning and as a tool for brownfields sites. SCS demonstrates their expansive experience with an array of brownfields tools including, grant funding and leverage, environmental insurance, and other risk-shifting tools such as “CLRRA” agreements.
At the SCS booth 417, meet Mike McLaughlin, SCS Engineers’ Senior Vice President of Environmental Services and a National Specialist on Brownfields & Landfill Redevelopment and Electric Utilities. He is a licensed engineer and attorney with over 30 years of professional experience providing advice on environmental matters. He is an expert on environmental compliance, remediation, and allocation of response costs.
Mr. McLaughlin advises developers, contractors, lenders and land development professionals on the technical and regulatory requirements for construction on Brownfields’ sites nationwide. His combined engineering and legal background provides an unusual perspective on land development where hazardous wastes or other environmental challenges are present. Redevelopment of closed landfills is an area of special interest; he worked on his first such project in 1976.
Mr. McLaughlin has worked at some three dozen Superfund National Priorities List sites in 17 states, and on scores of regulatory compliance, voluntary cleanup, and remediation projects for commercial, industrial, municipal, and military clients.
Thursday, December 12, 3:30 pm – 4:45 pm, Room 411
Track 1: Sustainability, Livability, Resiliency
This 75-minute clinic provides a fun and engaging hands-on experience that will inspire you to tackle the challenges of stormwater flooding using GSI on brownfields. Experts, including Jonathan Meronek, will explain the applications, techniques, and benefits of using GSI on any project site, including the challenges of implementing GSI on Brownfield Sites. During the guided exercise, participants will break into small think tanks, and each think tank will have an opportunity to design their own solution. Come to this session to soak up information on techniques and strategies for integrating GSI into your community’s overall planning efforts.
Inductive Automation® announced the software firm now recognizes SCS Engineers as a Premier Integrator. Premier Integrators have a high level of commitment, professionalism, and competency using the Ignition software. They must consistently produce high-quality work and must consistently demonstrate successful projects with very satisfied end-users.
SCS uses Inductive Automation’s Ignition supervisory control and data acquisition (SCADA) software in their solution because it is a proven state of the art software, which works well with cloud-based systems and the internet of things (IoT). It allows clients to easily control, track, manage and report on their processes.
Large landfills, counties with multiple landfills, and private waste management firms have been waiting several years for SCADA software to catch up to their business needs. Landfill operations are extremely complex and expensive since they monitor and manage multiple systems to protect the public from contamination to the air, water, or soil. There are typically multiple operations active on many sites, such as waste recovery, recycling, composting, Gas Collection and Control Systems (GCCS), and renewable energy plants.
SCS Remote Monitoring and Control®, or SCS RMC® provides a next-generation option to monitor and control systems, and see the data collected and the systems in action. It allows users to control their systems remotely, collect data and use the data to enhance their productivity, reduce their operations and maintenance (O&M) costs, and reduce their environmental risk. Other offered services include 3D imaging from drones and virtual reality (VR). SCS uses aerial data collected via drones to compose topographic mapping, 2D images, 3D renderings, GIS, thermal, infrared (IR), and methane leak detection for waste facilities. The SCS RMC® team can take rendered models and apply them into virtual reality (VR) headset as well, which allows decision-makers at waste management facilities and organizations to “walk the site” from anywhere.
Current clients save Operating & Monitoring (O&M) costs and reduce human error by generating internal and regulatory reports automatically, using data automatically collected by the system. They can also receive instant notification of malfunctions and can troubleshoot these notifications remotely.
Not only for landfills, until recent years the public did not realize the long-term value of recycling nor the associated costs. Some clients use SCS RMC® to monitor dumpsters and recycling receptacles for collection. This helps keep waste and recycling inside the container, collection schedules more efficient, and overall operations less costly.
Manufacturing, industrial facilities, and ports use remote monitoring and control for real-time viewing, analysis, and control of equipment and systems critical to production and safe operations, often for air monitoring.
Galen Petoyan, Senior Vice President of Field Services states, “We fully embrace SCS RMC® within SCS Field Services® because the software allows us to provide more value to our clients; our technicians and engineers can avert problems, and when needed, provide rapid, efficient, and accurate analysis and action.”
To support the growing use of technology by municipalities, in waste management, and by industrial and manufacturing clients, SCS Engineers is opening new offices. The newest office is in Lancaster, Pennsylvania. The office provides environmental engineering, consulting, and is the base for the east coast SCS Remote Monitoring and Control® (RMC) professionals.
The office is the third SCS location in Pennsylvania, and is located at:
SCS Engineers
1861 Charter Lane
Suite 107
Lancaster, PA 17601
Tel: +1-717-550-6330
SCS RMC® works closely with the firm’s business sectors developing software, applications, and support services, which harness technology to capture, track and evaluate environmental data, provide remote monitoring and controls, and drone services with advanced capabilities.
The SCS RMC® platform and applications help public and private clients control their equipment remotely, collect data and use the data to enhance their productivity, reduce their operations and maintenance costs, and reduce their environmental risk. The tools are versatile; SCS programmers, engineers, and scientists are available to develop custom applications meeting a spectrum of industrial environmental objectives for groundwater, leachate, air monitoring, and landfill gas management.
SCS RMC® uses a network of sensors and Machine-to-Machine (M2M) applications to help minimize equipment downtime by alerting staff to maximize production or to an operational safety issue. The system supports additional monitoring components as operations grow, providing facility owners and operators with a single secure application for their supervisory control and data acquisition (SCADA), data management, and reporting needs.
SCS RMC® is experiencing exponential growth, as industrial operations need technology most when reaction time is essential to avoid production downtime and continue operations within regulatory mandates to maintain public safety standards.
To discover how these and other next-generation technologies can support your operations, contact SCS at , or use the links below to explore:
The U.S. Environmental Protection Agency (EPA) earlier this year proposed changes to the federal coal ash rule, saying it would eliminate requirements for onsite dry storage of coal ash, along with limiting environmental protections on large fill projects, except for those with what the agency calls “geologic vulnerabilities.” Under the original version of the rule, companies with fill projects larger than 12,400 tons had to ensure that the ash did not impact the soil, air, and water around the sites.
The power generation industry has said those changes could allow coal ash to be more easily recycled, opening more pathways for what’s known as “beneficial use” of ash, which includes the use of ash in construction materials such as concrete and wallboard. Environmentalists have said the proposal would lead to more untracked and unregulated coal ash. The EPA has been working with the utility industry since March 2018 to streamline the 2015-enacted Coal Combustion Residual (CCR) rule, which was issued after years of debate in the wake of large coal ash spills in Tennessee and North Carolina. The rule establishes technical requirements for CCR landfills and surface impoundments under subtitle D of the Resource Conservation and Recovery Act (RCRA), the nation’s primary law for regulating solid waste.
SCS Engineers closely follows developments relating to coal ash disposal, helping landfill operators, utilities, and others who deal with CCR meet the challenge of proper waste management as regulations evolve.
In addition to keeping up with rule changes, utilities are facing new challenges under the original CCR rules as time goes by, and CCR sites move through the regulatory timeline. Many utilities that began groundwater monitoring at CCR units under the rule in October 2017 and identified groundwater impacts are now entering the stage of remedy selection.
If groundwater monitoring shows that pollutants exceed groundwater protection standards (GWPS), then a response is required unless it can be shown that a source other than the CCR unit is responsible for the impacts, as documented in an Alternate Source Demonstration (ASD). The determination of what is best for a particular site is based on several factors and begins with what is known as an Assessment of Corrective Measures (ACM). The ACM is the first step in developing a long-term corrective action plan designed to address problems with pollutants in groundwater near areas of ash disposal. The ACM is pursuant to the EPA’s CCR rule.
“Obviously people are still looking at what things cost, but in our experience, working with utilities, the concern for the surrounding community and the environment is uppermost,” says Tom Karwoski, a vice president with SCS Engineers. Karwoski has 30 years of experience as a hydrogeologist and project manager, designing and managing investigations and remediations at existing and proposed landfills, as well as clean-ups of industrial, military, petroleum, and Superfund sites. Karwoski says his group has “no preconceived notions about what is best for all sites.”
Utilities working to satisfy requirements of the CCR rule have performed ACM and ASD projects, and several are moving into the “Remedy Selection” phase of the process. SCS Engineers is working with these utilities to determine the best remedies for CCR disposal, drawing on the company’s experience in providing solutions across the spectrum of waste management. SCS designs solutions for municipal solid waste (MSW)—in effect, trash and garbage, or what the EPA calls “everyday items such as product packaging, yard trimmings, furniture, clothing, bottles and cans, food, newspapers, appliances, electronics and batteries”—and also develops management programs for electric utility (EU) waste, such as CCR, which is far different in terms of scope and pollutants.
Eric Nelson, a vice president with SCS Engineers, one of the company’s national experts for electric utilities, and an experienced engineer and hydrogeologist, knows the challenges of establishing a successful program for managing CCRs. “The CCR rule quite literally borrows language from MSW rules; word for word in some instances. The stark difference, in my view, is the varied participation by regulators. In general, the states have not picked up the ball to oversee the rule as EPA has suggested they do, which is no small burden. However, many states had existing CCR management rules or have since enacted their own rules adding layers of regulation.” The EPA in June of this year supported a Georgia plan for CCR disposal, with EPA Administrator Andrew Wheeler saying, “EPA encourages other states to follow Georgia’s lead and assume oversight of coal ash management within their borders. EPA is committed to working with the states as they establish coal ash programs tailored to their unique circumstances that are protective of human health and the environment.”
Said Nelson: “My understanding was that when similar rules were introduced for MSW sites, the owner, their consultant, and a regulator [state or EPA] worked through the remedy selection process. There is no real-time regulatory feedback in many cases with the requirements in the federal CCR rule.”
Nelson is familiar with the process of establishing a program to manage CCRs. “The groundwater monitoring and corrective action portion of the CCR rule allows for specific timeframes for establishing a monitoring system, obtaining background samples, identifying statistically significant increases [SSI] in groundwater concentrations, assessing alternative sources of those SSI, completing assessment monitoring, and then assessing corrective measures for groundwater impacts above groundwater protection standards,” he says. “Stacking all of those timeframes onto one another has us where we are today [sites recently completing ACMs and working on remedy selection]. We are about to repeat this same cycle, starting with identifying SSIs, with groundwater monitoring of inactive surface impoundments that were previously exempt from groundwater monitoring under [rule section] 257.100, an exemption removed with previous rule revisions.”
At the moment, remedies for CCR units that have not already undergone closure will include some form of source control. The most likely controls include closure-in-place, sometimes called cap-in-place, or closure-by-removal of coal ash. Closure-in-place involves dewatering the impoundment—or converting wet storage to dry storage—stabilizing the waste, and installing a cover system to prevent additional water or other material from entering the impoundment. Closure-by-removal involves dewatering and excavating the CCR, then transporting it to a lined landfill.
In addition to these source control and closure strategies, remedies for groundwater impacts from CCR units might also include approaches from two other categories of corrective measure – active restoration and plume containment. The options available and those appropriate will depend on many site-specific factors including the size of the source, the groundwater constituents and concentrations, and the receptors at risk.
These factors, more remedies, and the selection process will be discussed in more detail as this blog series continues.
Mr. Karwoski has 30 years of experience as a hydrogeologist and project manager. He has designed and managed investigations and remediations at landfills and for industrial, superfund, military, and energy firms.
Eric J. Nelson, PE, is a Vice President of SCS Engineers and one of our National Experts for Electric Utilities. He is an engineer and hydrogeologist with over 20 years of experience. His diverse experience includes solid waste landfill development, soil and groundwater remediation, and brownfield redevelopment. He is a Professional Engineer licensed in Wisconsin and Iowa.
Mark Huber is a Vice President and Director of SCS’s Upper Midwest Busines Unit. He is also one of our National Experts in Electric Utilities. Mark has nearly 25 years of consulting experience in civil and environmental engineering. His experience working on a variety of complex challenges for utilities allows him to quickly identify key issues and develop smart, practical solutions. He also has expertise in urban redevelopment projects with technical expertise in brownfield redevelopment, civil site design, and stormwater management.
SCS Engineers is pleased to announce the opening of our newest location in Oakdale, Minnesota. Located approximately 15 miles from the Minneapolis-Saint Paul International Airport, this SCS office also boasts a training facility dedicated to specialized compliance training related to risk and process safety-based EPA and OSHA regulations. The new location is:
SCS Engineers
7300 Hudson Boulevard North, Suite 135
Oakdale, MN 55128
1 (800) 767-4727
SCS Tracer Environmental, a specialty practice of SCS Engineers, will continue to offer custom onsite training and nationwide training sessions, in addition to ammonia refrigeration operator training, CIRO review classes, CARO review classes, and Process Safety Management and Risk Management Plan (PSM/RMP) training in our new classroom.
To better serve the unique needs of their clients, SCS employs experienced staff with backgrounds in oil, petrochemical/chemical industries, aerospace, and manufacturing companies. Tracer’s service professionals are strategically located across the nation to meet the environmental needs in a wide range of industries using ammonia refrigeration such as dairy, food, and beverages; ice arenas and ice manufacturing; cold storage warehouses; and for facilities using ammonia for metal/tooling heat treating, and fossil fuel plants with NOx systems.
As an added service, SCS provides consultation on ammonia detection systems based on the IIAR 2-2014 Standard and Recognized and Generally Accepted Good Engineering Practices (RAGAGEP).
Click here for more details regarding training.
Welcome to the SCS Advice from the Field blog series.
Airspace is a golden egg, the equivalent to cash that a waste operating company will have overtime in its account. With each ton or cubic yard of waste received at the landfill, the non-monetary asset of airspace converts positively to the bottom line of the waste operating company’s books.
The larger the airspace, the larger the non-monetary asset, and the larger future cash potential in the account.
Therefore, it is extremely important to design landfill footprints optimally in consideration of planned operations at the site, and design landfill features maximizing airspace within the selected landfill footprint.
Optimization takes into consideration the land available for development, including the various facilities and systems necessary for operations. The type of design, depth of landfill, base slopes, leachate collection pipe slope, perimeter berm geometry and size, slopes of landfill side slopes, terraces on slopes, and many other parameters determine the airspace volume available to the landfill operator. The designer’s goal is to provide the most volume to the landfill operator.
How does the operator know that a proposed design is maximizing airspace?
If SCS is the site designer, the maximization of airspace is inherent in proposed designs for permitting. On numerous occasions, when SCS is not the site engineer, our designers have proposed a re-design of landfill features to maximize the airspace within its permitted footprint. Under these circumstances, it is not easy to convince a landfill operator of the benefits of SCS’s proposal. Naturally, one assumes a designer would not propose a lesser design on paper and carry it through the high cost of permitting, so it is common for the landfill operator to express doubts about our proposed changes. Once the operator and SCS review the technical design changes in detail, the demonstrated value becomes apparent. It is not a simple process, but on every occasion, we have successfully increased the airspace for the client, increasing potential revenue for millions of dollars beyond the originally permitted amounts.
Driven by the success of our clients, it is our culture to serve our clients completely as trusted professionals making your challenges our own. SCS is proud to say that at the date of this publication, our designers have created over $400,000,000 of additional financial benefit out of thin air for clients at a dozen landfills with more efficient landfill base grades that maximize airspace and cost less to construct.
As we move toward our 50th year, we hope to continually improve, evolve, and strive to maximize airspace at more landfills, adding value to our clients’ bottom line. Contact our nearest office if you are interested in a landfill evaluation for maximizing airspace and reducing construction costs. As always, our SCS authors are available to answer your questions or comments.
About the Author: Ali Khatami, Ph.D., PE, LEP, CGC, is a Project Director and a Vice President of SCS Engineers. He is also our National Expert for Landfill Design and Construction Quality Assurance. He has nearly 40 years of research and professional experience in mechanical, structural, and civil engineering.
Per- and poly-fluoroalkyl substances (PFAS) are receiving increasing attention from regulators and the media. Within this large group of compounds, much of the focus has been on two long-chain compounds that are non-biodegradable in the environment: PFOS (perfluorooctane sulfonate) and PFOA (perfluorooctanoic acid).
Long detected in most people’s bodies, research now shows how “forever chemicals” like PFAS accumulate and can take years to leave. Scientists have even tracked them in biosolids and leafy greens like kale. Recent studies have linked widely used PFAS, including the varieties called PFOA and PFOS, to reduced immune response and cancer. PFAS have been used in coatings for textiles, paper products, cookware, to create some firefighting foams and in many other applications.
Testing of large public water systems across the country in 2013 through 2015 found PFAS detected in approximately 4 percent of the water systems, with concentrations above the USEPA drinking water health advisory level (70 parts per trillion) in approximately 1 percent (from ITRC Fact Sheet). Sources of higher concentrations have included industrial sites and locations were aqueous film-forming foam (AFFF) containing PFAS has been repeatedly used for fire fighting or training. Source identification is more difficult for more widespread low-level PFAS levels.
With the EPA positioned to take serious action on PFAS in 2020 and beyond, regulators in many states have already started to implement their own measures, while state and federal courts are beginning to address legal issues surrounding this emerging contaminant. State actions have resulted in a variety of state groundwater standards for specific PFAS compounds, including some that are significantly lower than the USEPA advisory levels. These changes mean new potential liabilities and consequences for organizations that manufacture, use, or sell PFAS or PFAS-containing products, and also for the current owners of properties affected by historic PFAS use. If you operate a landfill or own a site with PFAS history this may be something you need to discuss and plan now.
Questions for property owners, property purchasers, and manufacturers include:
If PFAS treatment or remediation is required, a number of established options to remove PFAS from contaminated soil and groundwater are available, including activated carbon, ion exchange or high-pressure membrane systems. On-site treatment options, including in-situ or ex-situ alternatives, the management of reject streams with concentrated PFAS waste where applicable, are also available.
Do You Need Help?
Need assistance with PFAS or have an idea that you would like to discuss? Contact , or find the SCS Engineers location nearest you.
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