SCS Engineer’s Long Beach Headquarters sponsored and participated in the U.S. Vets Storm the Beach 5K/10K Run, Walk & Roll for Veterans event in Long Beach, CA.
U.S. Vets is an impressive organization supporting our Veterans in Long Beach, many of whom are homeless. These men and women who have served our country receive housing, employment opportunities, and counseling services from this private non-profit organization.
Participating this year, left to right: Sonia Aguirre, Wendy Mendoza, Sara Garcia and husband, Brendan McGarrity, Jennifer McCafferty, Stacey Dolden, Deidra McGrew and Hanna Suh and friend.
Visit our website and look for careers with our award-winning team of professionals.
When the Federal Coal Combustion Residual (CCR) rule went into effect in 2015, it was a new regulatory layer on top of a widely varying landscape of state regulations affecting CCR management in impoundments and landfills. Some states already had significant regulations on the books for CCR impoundments and/or landfills, while others did not.
Where state regulations existed, they varied widely from state to state. While a few states have moved toward closing the gap between state and Federal CCR requirements, many utilities continue to face confusing and conflicting requirements coming from different regulatory programs as they move ahead with managing their CCR facilities.
In her paper entitled State vs Federal CCR Rule Regulations: Comparisons and Impacts, Nicole Kron shares state-versus-federal regulatory challenges utilities have encountered during landfill design and management, impoundment closure, and groundwater monitoring and reporting since the implementation of the Federal CCR rule. For example, some sites have completely distinct groundwater monitoring programs under state-versus-federal rules, with different well locations, well depths, and monitoring parameters for the same facility. She highlights unique approaches to bridging regulatory gaps and resolving regulatory conflicts between state and Federal CCR requirements. Ms. Kron also provides insights gained on the long-term potential for regulatory resolution of these issues based on discussions with state regulators in multiple states.
About the Author: Nicole Kron has nearly a decade of experience in the environmental consulting field. Her experiences focus on groundwater quality analysis of sites contaminated with coal gasification byproducts, coal combustion byproducts, chlorinated solvents, petroleum products, metals, and PCBs. Her experience includes managing team task coordination, groundwater modeling, and statistical analysis of CCP/CCR sites. She is experienced in planning and performing soil and groundwater contamination investigations, air monitoring, well design and installation, and soil and groundwater sampling.
SCS Engineers’ Arizona office is continuing to grow with the addition of Dana Justice, a marketing specialist, who previously worked at the award-winning firm’s office in San Diego.
“Dana brings fresh ideas, strong problem-solving skills, and creative business development tactics to the Arizona office,” said Dan Sola, Arizona project director of SCS Engineers.
Justice is responsible for supporting marketing and business development in Arizona, Nevada, and California for environmental services. Her job responsibilities include engaging in business development outreach and continuing to strengthening the firm’s client success culture. As an employee-owned environmental consultant and contractor, SCS excels at accomplishing specific technical needs and high quality but also strives to provide a superior working relationship with their clients.
“SCS has great company culture with a sense of family among the staff,” Justice said. “I’m thrilled to take on a larger role in the Southwestern region and new responsibilities at SCS.”
Justice earned a bachelor’s and master’s in business administration from California State University San Marcos. She lives in Mesa.
The Arizona office has completed 3,500 projects during the last 30 years for the solid waste industry, government, and other industries responsible for safeguarding the environment as part of doing business.
Understanding the entire range of wastewater management and disposal alternatives can be a daunting task, particularly as increasingly stringent surface water discharge standards take effect or as zero discharge facilities find the management of their waste liquid needs changing over time. Former solutions are no longer options or may be too costly. One alternative that is rapidly gaining traction is deep injection wells.
Deep well injection is a viable leachate management option in many parts of the United States, yet it is often screened out as a possible alternative due to a lack of understanding of the technology or gross misconceptions about its acceptance or applicability. The purpose of the Monte Markley’s paper The Basics of Deep Well Injection as a Leachate Disposal Option is to present the basic technical, economic and regulatory considerations of deep well injection as a technology a facility should evaluate when considering the applicability of geologic sequestration of leachate.
Technical criteria discussed are potential disposal volumes, geologic suitability, chemical compatibility, pre-treatment requirements, and leachate chemistry. The economic considerations are evaluated based on the technical criteria noted above, management of public perception/relations, current leachate management expenditures, the service life of the asset and risk to develop accurate capital, O&M costs, and return on investment. Regulatory considerations include the role of state vs. federal primacy for each state, the general stance of regulatory acceptance in specific areas of the United States, and a discussion of the permitting process and typical reporting requirements.
These key considerations are then integrated into an overall suitability evaluation that an owner can utilize to accurately determine if deep well injection is a viable option and, if so, how to educate other stakeholders and manage the process of implementation as a project moves forward.
About the Author: Monte Markley, PG, SCS Engineers
SCS Engineers is proud of the level of community involvement that many of our professional and technical staff provide to municipal governments, professional associations and organizations, charitable organizations, scholarship programs, youth mentoring programs, and similar endeavors.
We appreciate the commitment and care that local organizations such as 4-H offer within our communities nationwide. SCS continues its support of publications used by the 4-H Geology program, for example, a STEM component of the 4-H program in Kansas. 4-H provides educational materials, field trips, and mentoring to over three hundred families with children participating in this unique program. SCSers always look forward to the feedback from kids and parents, especially our future geologists and hydrogeologists!
This year the special fossil publication went into its second printing. 4-H gives these to each new family enrolled in 4-H Geology to help them with fossil identification. The 4-H State Field Trip Guidebooks are also very popular.
Rock on 4-H!
To learn more about 4-H Science, Technology, Engineering, and Math visit their website
Landfill gas (LFG) fired leachate evaporation is a novel technology attracting the attention of landfill owners because it can offer an operational win-win. The technology uses a readily available resource at landfills, LFG, to remove liquid from landfill leachate via evaporation, thus abating this environmental liability onsite, often at a lower cost than conventional leachate treatment options. In addition, combusting LFG to evaporate leachate converts methane, a highly potent greenhouse gas, to carbon dioxide, which reduces overall greenhouse gas emissions.
Landfill owners seeking to implement LFG-fired leachate evaporation must undergo the necessary air permitting and follow applicable emissions regulations. In this regard, air permitting and regulatory requirements for the combustion-related component of LFG-fired evaporation are similar to those applicable to conventional LFG flares. However, in addition, there are permitting considerations for evaporation-related emissions too. As this is uncharted territory for regulators, it is important to work closely with your agency to ensure you or your consultant is properly addressing these technology-specific requirements.
Read Landfill Leachate, Just ‘Evaporate’ the Problem …or Permitting Issues for Using Landfill Gas to Reduce Leachate Volume by David Greene, PE, SCS Engineers. Published by em, the Magazine for Environmental Managers, A&WMA, issue June 2019.
About the Author: David Greene is a project manager at SCS Engineers with a multiplicity of solid waste related environmental engineering experience, including air permitting, landfill gas, financial analysis, due diligence efforts, regulatory development and analysis, compliance planning, greenhouse gas monitoring, emission inventory including emission factor development, SPCC and SWPPP development. Mr. Greene also consults internationally in Southeast Asia focusing on the areas of planning and implementing training and evaluating the feasibility of LFG energy and renewable energy projects at solid waste disposal sites. He is a Professional Engineer in North and South Carolina.
The EPA Resource Conservation and Recovery Act (RCRA) requires landfill operators to maintain post-closure care for 30 years, though states will adjust the term according to when they determine ending this care will not threaten human health or the environment. Industry stakeholders say it’s not enough guidance because it does not provide how states should assess for impact on human health or the environment, nor how to determine when to transition from active post-closure care to custodial care. Regulators tend to default to an extension of terms. Again data collection plays a significant role in determining the post-closure care term.
“The whole purpose of the post-closure care term is to provide enough time for landfills to become stable. One way to assess is by determining if functional stability has been achieved, which entails looking at performance metrics like leachate management, settlement, landfill gas control, and groundwater monitoring,” says Bob Gardner, of SCS Engineers.
Looking at these metrics, once it’s determined that functional stability has been achieved, these active systems may be able to be turned off, with only passive controls like cover remaining in place.
Monitoring may be done less frequently or not at all. “EPA acknowledges that back in the 1980s, it did not know how systems, primarily liner systems, would perform under new Subtitle D rules. But based on monitoring of these systems over the past 25 years, we know that they perform well to prevent migration of contaminants to groundwater,” says Gardner.
Read the Waste360 article Stakeholders Call for More Certain Landfill Post-closure Care Terms
Investigate why over 600 landfills use SCS eTools® to track, report, and store important data.
Comments were submitted to the EPA from NWRA/ SWANA regarding the EPA’s Advance Notice of Public Rule Making (ANPRM) for revisions to Subtitle D, and in particular potential revisions regarding the bulk liquids addition. Subtitle D prohibits bulk liquids additions with the exception of leachate recirculation, and the RD&D permit process allows bulk liquids. Bob Gardner of SCS Engineers was involved in the development of the joint NWRA/SWANA comment letter.
EPA has indicated that they are considering adding a “wet landfill” definition to Subtitle D; however, the Industry strongly advised against doing so. The letter addresses this issue and the reasons for recommending against a separate “wet landfill” definition.
Industry Association’s Comments
The Office of Information and Regulatory Affairs announced the release of the Agenda of Regulatory and Deregulatory Actions. The Agenda reports on the actions administrative agencies plan to issue in the near and long term. Of note:
The EPA published an Advance Notice of Proposed Rulemaking (ANPRM) regarding possible revisions to the Resource Conservation and Recovery Act (RCRA) Subtitle D part 258 regulations for municipal solid waste (MSW) landfills that may provide regulatory flexibility to encourage accelerated waste decomposition in the presence of water. In light of advances in landfill technology, the EPA is considering whether to revise part 258 to create new national standards for the management of liquids in “wet” landfills and bioreactor landfills, including the possibility of removing the prohibition on the addition of bulk liquids, to foster accelerated waste decomposition. Through the ANPRM, the EPA requested information and data on the performance of bioreactor landfills and wet landfills, including information on appropriate liquids management. In addition, the EPA requested comments on whether new national standards for bioreactor landfills and wet landfills are appropriate, and if so, what regulatory changes the EPA should consider in developing any proposal.
This proposal address the agency’s residual risk and technology review (RTR) of the National Emission Standards for Hazardous Air Pollutants (NESHAP) for Municipal Solid Waste (MSW) Landfills. The MSW Landfills NESHAP, subpart AAAA, was promulgated pursuant to section 112(d) of the Clean Air Act (CAA) on January 16, 2003. The NESHAP established emission limitations based on maximum achievable control technology (MACT) for controlling emissions of hazardous air pollutants (HAP) and helped implement the Urban Air Toxics Strategy developed under section 112(k) of the CAA. The HAP emitted by MSW landfills includes, but are not limited to, vinyl chloride, ethylbenzene, toluene, and benzene. This action implements the residual risk review requirements of CAA section 112(f)(2) and the technology review requirements of CAA section 112(d)(6). The statute directs the EPA to promulgate emission standards under CAA 112(f)(2) if such standards are required to provide an ample margin of safety to protect public health or to prevent, taking relevant factors into account, an adverse environmental effect. Any such standards are to be promulgated within 8 years after the promulgation of MACT standards under CAA section 112(d). CAA section 112(d)(6) requires the EPA to review and revise the MACT standards as necessary, taking into account developments in practices, processes and control technologies, no less often than every 8 years. Pursuant to a court order, the EPA is obligated to complete the final action by March 13, 2020. In consideration of this deadline, which also applies to 19 other RTR source categories, we established an internal schedule for this RTR to be proposed and finalized prior to the consent decree deadline. The EPA currently plans to complete this action by July 2019.
The EPA finalized the Emission Guidelines and Compliance Times for Municipal Solid Waste Landfills on August 29, 2016 (81 FR 59276). The requirements for state and federal plans implementing the Municipal Solid Waste (MSW) Landfills Emission Guidelines are specified in subpart B – 40 CFR 60.20-60 (referred to as the implementing regulations), which is cross-referenced in the emission guidelines issued by the Agency.
In August 2018, the EPA proposed changes to the implementing regulations governing emission guidelines under a new 40 CFR part 60, subpart Ba. This action aligns the regulatory text in the MSW Landfills Emission Guidelines with a cross-reference to the new subpart Ba for the timing requirements of state and federal plans.
Wendell, a Senior Project Professional in the SCS Engineers Sacramento office became interested in photography 35 years ago. He had broken his ankle and needed something to do because he felt grumpy not being able to play tennis. His tennis partner loaned him a camera, some film, and his dark room.
Wendell was hooked.
Wendell’s beautiful photos capture the reason we work with our clients to protect our environment. See a few pieces of his organic work, and look for more soon.
Mr. Minshew has over 30 years of engineering experience. He specializes in civil engineering services in the planning, design, permitting, and construction management of solid and hazardous waste facilities. He is a licensed Professional Engineer in California and Nevada.
Thank you for sharing, Wendell.
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