Infrastructure Week (May 16–23) is a national week of events, media coverage, education, and advocacy efforts to bring the state of the nation’s infrastructure to the attention of all Americans. Forester Media, the publisher of MSW Management magazine, is an Infrastructure Week affiliate. John Trotti, MSW Managing Editor recently surveyed Jim Walsh, P.E., BCEE, President and CEO of SCS Engineers and long-time friend of the magazine on the topic. Jim is first out of the blocks to answer the four questions John asked of respondents from MSW and Forester’s other publications, Business Energy, Erosion Control, Grading & Excavation Contractor, Stormwater, and Water Efficiency.
MSW Management (MSW): Which infrastructure projects should be given priority? Roads and bridges? Dams and levees? Water supply? Electrical grid? Waste management?
James Walsh (JW): Typically public safety, cost, and benefit determine the priority for infrastructure projects, and different political jurisdictions have different priorities. Where highways and bridges are new but waste management facilities are old, the priority might be waste management facilities, and vice-versa. Some types of infrastructure are more amenable to private sector solutions, which can allow the government to focus on other types of infrastructure. The trend in waste management, for example, has been to rely on the private sector in the last decade
Each segment faces difficult challenges; the most significant is funding. Waste management does not necessarily have priority over other projects, but has progressed by regionally identifying the infrastructure necessary. Thus, each region avoids the pitfalls of competing for funding with other regions and other projects.
SCS Engineers focuses on waste management, but there are opportunities to interact with other segments in sustainable ways. For instance, we have energy clients who supply coal ash to specialty cement companies who use it to make “green” cements that last longer in applications such as road construction. We design and construct facilities that take the byproduct gases from the decomposition in landfills to generate electricity reducing their dependence on fossil fuels, or directly use the gas for energy to power wastewater plants simultaneously cleaning and conserving water. We find ways to safely redevelop contaminated property supported by existing infrastructure, thus reducing the need to build new infrastructure.
In short, we work toward helping clients find sustainable solutions to infrastructure projects.
MSW: Is there a solution to long-term infrastructure funding?
JW: With respect to the waste management infrastructure, waste systems require significant capital investment in land, equipment, facilities, and infrastructure. While many governments have decided to rely on private industry instead of financing new governmental facilities, others have become much more sophisticated in adopting private sector approaches to financing. Pro-Forma Economic Life-Cycle Models can assist governmental entities to identify the critical variables that can impact the success of an infrastructure project. Moreover, economic models evaluate how various components of a waste system and variable assumptions integrate together into a sensible approach. Pro Forma Economic Models allow for a careful analysis of the life-cycle costs and potential revenue sources and identify factors that will influence the waste system costs and demonstrate how to adequately and equitably fund the system. These Models provide different scenarios and eliminate options that are not financially feasible or do not fit a region’s short- and long-term needs or priorities. Sensitivity analysis can be conducted to understand better the impact these variables have on capital costs, operating expense, and the overall system economics. By assessing the economic and regional benefits first, we can focus on designing and building infrastructure solutions that are safer, longer lasting, and affordable. Other benefits include adjusting the Model if there is a major change in the commodity market, such as plastics’ recycling is experiencing now and when considering the use of new technologies.
Every industry segment and every region have a different blend of socio-political conditions, geography, and monetary resources—we assess and design to their particular needs. Adopting new waste management technologies, such as anaerobic digestion or waste diversion, as part of an overall waste management program can be integrated into the Model to study how, and if, they sensibly integrate within the existing program. New technologies are typically more expensive than mature technologies such as recycling facilities and landfills, but that condition alone is not why they are considered valuable to a region. The framework considers elements key to integrating anaerobic digestion for example into a long-term program. Capital investment, a significant centralized source of high-quality organic waste, power costs and economic utility incentives, limited land suitable for composting, lack of conventional waste-to-energy facilities, or a ban on organics disposal in landfills are some of the considerations.
Many states are developing organics diversion initiatives, discouraging or banning organics from landfills; they will want to develop separate capacity for diversion within their overall program to build a sustainable plan for the long-term. In some states there is plenty of environmentally sound landfill capacity, recycling facilities have adequate capacity, and the socio-political climate has different ideals. What works in Iowa might not be suitable for California.
MSW: What kind of harm is the current state of our infrastructure doing to the economy and the community?
JW: Every four years, the American Society of Civil Engineers releases a “Report Card for America’s Infrastructure” depicting our nation’s infrastructure condition and performance. In a traditional school report card format, individual infrastructure segments are assigned letter grades—solid waste has the highest grade of B- in the most recent report published in 2013. The waste management infrastructure in the United States is robust, diverse, and significantly supports our economy and communities by providing safe and cost-effective management of the materials that we discard on a daily basis.
MSW: What can various government entities—from local to Federal—do to attract private sector support and investment?
JW: In the United States, private solid waste facilities manage 75% of the municipal wastestream. The waste management industry has many examples of public/private partnerships and significant investment by the private sector. Just look at firms like Waste Management Inc., Republic Services Inc., Waste Industries, Waste Connections, WCA Waste Corporation, Covanta, and Wheelabrator, which own and operate numerous landfills, compost facilities, waste-to-energy facilities, transfer stations, processing facilities, alternative technologies, and hauling companies. These facilities require significant private investment. Allowing private industry to participate in the management of waste management infrastructure brings needed fiscal discipline and accountability to the overall waste system infrastructure.
The private sector is attracted to markets that are predictable and that provide an appropriate return on investment. Jurisdictions with a reputation for making sudden unpredicted changes in regulations that adversely affect the return on investment will find it difficult or impossible to attract private sector support.
The waste management sector and SCS Engineers have seen our share of magic technologies that are literally too-good-to-be-true, yet somehow attract governmental support both financial and otherwise. It is fine for government agencies to provide grant support for research related to promising new technologies, but adopting an unproven technology as the sole means of waste management is inviting a public health crisis. Private sector investment is not attracted to jurisdictions that have unrealistic expectations.
About James Walsh, PE, BCEE, President and CEO of SCS Engineers
Jim has worked at the forefront of sustainable waste management for more than 40 years. He has authored numerous publications, technical support documents, presentations for the USEPA, US DOE, the Gas Research Institute while serving the Solid Waste Association of North America (SWANA), National Waste and Recycling Association (NWRA), and the Environmental Research and Education Foundation (EREF), among others.
Taken as a whole, mixed MRFs have operated well since their reincarnation in the early 1990s and continued refinement through today. The sorting technology, which has been evolving for the last 25 years, has been proven to work and is reliable. Complete, pre-engineered integrated systems have been available now for years from a growing selection of established companies dedicated to the solid waste industry that can provide planning, engineering, manufacturing, controls, and startup, whether for new facilities, or retrofits of existing older facilities.
With that said, the following conclusions are offered for consideration:
Contact the authors: Bruce Clark and Marc Rogoff
Dr. Dale W. Daniel, an Associate Professional with SCS’s Oklahoma City office, recently published a summary article of his dissertation research through the U.S. Department of Agriculture’s Conservation Effects Assessment Project. The primary goal of the research was to provide under-standing of the potential climate mitigation services provided through wetland conservation and restoration in the High Plains region of the United States. Focus was placed on greenhouse gas (GHG) emissions from wetlands and adjacent upland landscapes as well as identifying some of the drivers of GHG flux that are influenced by various land management practices. The project also sought to understand how sediment removal from wetland basins influenced Carbon and Nitrogen content as well as Carbon sequestration services.
In 2007, the Society for Ecological Restoration International (SER) stated that global climate change is a real and immediate threat that requires action, and ecological restoration is one of the many tools that can help mitigate that change (SER 2007). However, recent debate within the conservation science community has arisen concerning whether restoring ecosystems for C offset projects may shift focus away from other important benefits to society (Emmett-Mattox et al. 2010). Indeed, not all ecosystem restorations make viable ecological offset projects for industries seeking to reduce their C emissions, and those that do, may not always occur in areas where restoration funding is needed the most. This study demonstrated that management practices focused on restoring natural landscape functions, including native species plantings and basin sediment removal, can increase climate mitigation services provided by wetland and upland ecosystems within a region heavily impacted by land use change.
Long story short, an escapee from San Quentin and any uncontrolled methane air molecule may be more similar than we may presume. In fact, a common LDAR practice is to use an infrared imaging camera; similar to the camera often used in search of fugitive criminals.
On a serious note, fugitive emissions are something that both industry and regulators have been focused on for decades, and the past and present efforts made to limit them are no less than remarkable.
Specific to Onshore Oil and Gas Exploration & Production, the Federal Regulations applicable to fugitive emissions are fairly young. Finalized in 2012, NSPS OOOO is no longer a toddler and is in the middle of growing into NSPS OOOOa (Public Comment Deadline March 11, 2016). On a national scale, NSPS OOOOa will expand fugitive emission monitoring and control requirements (VOC’s and methane) to several facility types associated with the industry and is expected to be finalized before the close of 2016.
In California, fugitive emissions from Onshore Oil and Gas Exploration & Production have been regulated for a long time. In fact, the O&G industry in Santa Barbara County has dealt with fugitive emission requirements since 1979. Since then SCS Engineers has been assisting with fugitive emission monitoring for our valued clients. Today, SCS Engineers provides the Oil and Gas Exploration and Production industry with efficient and effective LDAR services.
So fear not, SCS Engineers is ready to supply the knowledge and skill set you need to stay compliant, maintain your operations, and respect your bottom line. Remember, unless the doors are closed, pumps are turned off, and equipment is flushed and plugged; fugitive emissions requirements and LDAR will likely still apply.
Applicability: Determining Federal vs. State oversight is the first step. Non-Major Source Oil and Gas Production facilities are either subject to NSPS OOOO (soon to be OOOOa) or a related State specific rule (i.e. Colorado Regulation 7). Once oversight is determined, then there may still be exemptions for your facility (i.e. facility constructed before August 23, 2011). And finally, once regulatory oversight is confirmed and you determine that LDAR is required for your facility, then the last step is to figure out which equipment is applicable (i.e. VOC content > 10% by weight). Basically, an applicability determination can be daunting.
Equipment: EPA’s Method 21 is historically and currently referenced in all LDAR regulations. Method 21 requires an instrument such as the Flame Ionization Detector (FID) or Photo Ionization Detector (PID). More recently the Optical Gas Imaging (OGI) Camera has been included in LDAR regulations and utilized in LDAR programs. Presently, there are several instrument technologies that exist and are in the works, but not yet mainstream in Oil and Gas sector. Ultimately, if you were to find yourself conducting LDAR monitoring at your oil and gas facility tomorrow per an established regulation, you would most likely need to use an FID or OGI.
Recordkeeping: Personally, I like the simplicity of using paper forms for field notes; however, the old-fashioned way comes with risk. The up-front and ongoing data involved with an LDAR program is too much for maintaining a paper to computer process, regardless of how organized you think you are. Therefore, a computer database platform is recommended and necessary for managing your LDAR recordkeeping. Beyond just recordkeeping, a database platform can organize schedules, alerts, generate reports, extract trends, and many other applications to help keep your LDAR program compliant. One such platform worth considering is SCSeTools™. This cloud-based software can provide the database capabilities used on the desktop, but almost more importantly, provides mobile data input capabilities with the SCS MobileTools™ application fit for Android and IOS systems. Keep the fugitives from escaping, and document containment for the authorities!
About Lucas Marsalek: Lucas has been an Environmental Consultant for over 8 years; he applies his expertise as a leader for oil and gas production environmental and regulatory compliance projects. Marsalek has a B.S. in Forestry and Natural Resource Management from California Polytechnic State University, San Luis Obispo, CA.
Whether you want to discuss LDAR or Dodger baseball, don’t hesitate to contact me, or SCS Engineers.
Resources:
Learn more on the SCS service pages and read SCS project case studies from across the nation to help fine tune your program.
Outside links to the EPA proposed rulemaking website:
Thirty-four senators and 171 representatives argue in a brief filed February 23, that the EPA overstepped its boundaries in creating the carbon-cutting Clean Power Plan. In short, the brief states that they feel that Congress never gave the EPA a clear statutory directive or authority to transform the nation’s electricity sector. The brief points out that the EPA seeks to make “decisions of vast economic and political significance” under a “long-extant statute,” and in doing so must point to a “clear statement from Congress.”
Yesterday’s brief comes just two weeks after the U.S. Supreme Court ruled the EPA cannot begin enforcing the rule until legal challenges filed by 25 states and four state agencies are resolved.
The D.C. Circuit Court of Appeals will hear oral arguments on the merits of the states’ case on June 2.
With the brief it is clear that the Clean Power Plan is not only facing legal challenges but also political ones. It may be left for the next Administration to pick up this pieces and decide the fate of the Plan.
As a designer, I’ve been hired to correct inconsistencies between the gas system and the landfill too many times. Today’s blog is about the most important factors that all landfill gas designers should consider for a gas system to coordinate efficiently with the landfill design as permitted. This is a partial list of best practices developed at SCS Engineers.
Considerations for Design of Gas Collection Systems for Landfills:
1. Include the final cover layers in the gas design details where gas wells are installed near the landfill final surface. This inclusion will help the designer to specify proper heights for gas wells, proper depths for gas headers and lateral pipes, and proper heights for condensate sumps within the lined area of the landfill. Otherwise, locations of these elements may end up being in conflict with the location of various layers of the final cover system to be constructed later.
2. Always leave pipes exiting the liner boundary at the perimeter of the landfill at least 1 ft above the anchor trench shoulder. When the final cover is installed, it would be impossible to install a geomembrane boot over at the cover geomembrane penetration point of a pipe that is in contact with the bottom lining system geosynthetics over the anchor trench shoulder.
3. If flow control valves are located below the final cover near the perimeter of the landfill, design a vertical casing around the valve tall enough that future final cover can be booted to the vertical casing and access to the valve would be possible. Do not use corrugated material as casing because it would be difficult to place a geomembrane boot over corrugated casings. The designer should require sealing the void inside the casing pipe to prevent landfill gas release or oxygen intake through the void. If the control valve is located above the final cover, the designer should specify a proper height for the casing pipe that access to the valve stay above the final cover surface.
4. Locating flow control valves near the landfill perimeter and within the lined area should be in consideration with the future location of a rainwater toe drain system at the toe of the slope that will be constructed when the final cover is constructed.
5. Condensate sumps installed before construction of the final cover should be tall enough to accommodate construction of the final cover system around the condensate sump with sufficient space to boot the final cover geomembrane to the exterior walls of the condensate sump. Miscellaneous stub outs on the condensate sump should be designed in consideration of having enough space for the geomembrane boot in the future.
6. Pipes connected to a condensate sump (such as compressed air line, discharge force main, power conduits, etc.) should be positioned such that boots can be placed on each line at the penetration point of the pipe through the final cover geomembrane. Boots may not be placed on pipes clustered together. If boots are placed on a pipe cluster, the designer should require sealing the voids between the pipes within the boot to prevent landfill gas release or oxygen intake through the voids.
7. Gas pipes located above the final cover geomembrane and crossing terraces on landfill side slopes may create conflict with rain water toe drain at the terrace. The designer should design terrace crossings such that future conflicts can be avoided.
8. Gas pipes crossing an access road on the landfill slope may cause conflict with a ditch adjacent to the access road at the final cover surface. Location of the gas pipes, either below or above the final cover geomembrane, should be designed in consideration of the final cover features that will exist in the crossing area in the future.
9. Gas pipes located above the final cover geomembrane and crossing an access road on the landfill slope may cause a conflict with a rainwater toe drain system above the final cover geomembrane running parallel to the access road at the toe of the slope next to the access road.
10. Gas pipes located above the final cover geomembrane and crossing the access road on the landfill slope may cause road grade problems at the final surface. Specific depressions across the access road width may have to be designed for larger pipes to prevent grades problem at the finish surface.
11. Gas pipes located above the final cover geomembrane may cause conflict with storm water downchutes that will be installed above the final cover geomembrane. Special depressions may have to be designed to place downchutes below gas pipes on the slope. Placing gas pipes above downchute may cause a problem with the flow of condensate in the line.
12. Sometimes horizontal gas collection pipes come out of the landfill side slopes and extend down the slope to a gas header or some other component of the gas system. If the pipe segment on the slope is going to be below the final cover geomembrane, then it must be placed deeply enough in the waste that it would not have any conflict with the final cover system components, such as leachate toe drain systems, terraces, access road ditches, etc. If the pipe segment is going to be above the final cover geomembrane, extension of the horizontal pipe connecting to the pipe segment on the slope will be designed such that the horizontal pipe can penetrate the final cover geomembrane and extend down the slope while located above the final cover geomembrane. Extension of the pipe on the slope above the final cover geomembrane should not cause any conflict with the final cover components, such as rainwater toe drains at terraces or at the toe of the slope next to the perimeter berm, downchute pipes, terrace or access road grades, etc. The elbow at the connection of the horizontal pipe to the pipe segment on the slope and above the cover geomembrane is critical because a geomembrane boot must be installed at the penetration point.
13. If tack-on swales are used on the landfill slopes, gas pipes on top of the final cover geomembrane may cause conflict with the flow line inside the tack-on swales. Large headers should cross tack-on swales at the high-end point of adjacent swales to prevent flow problems in the swale.
14. If tack-on swales are used, the location of wells for drilling purposes should be chosen to be outside the tack-on swale structure.
15. If a gas header located above the final cover geomembrane and crossing a terrace or access road where the terrace or access road is sloping toward the landfill, condensate flow through the gas header may become an issue. Special depressions across the terrace or access road may need to be designed such that condensate can flow in the proper direction.
SCS Engineers is a leader in the design of landfill gas and landfill lining and final cover systems. We evaluate these issues and many others during our landfill gas design work; our clients pay only once for construction of the system and do not have to spend additional money in the future to fix a system that could have been constructed correctly in the first place. Learn more here.
Dr. Khatami has acquired extensive experience and knowledge in the areas of geology, hydrogeology, hydrology, hydraulics, construction methods, material science, construction quality assurance (CQA), and stability of earth systems. Dr. Khatami has applied this experience in the siting of numerous landfills and the remediation of hazardous waste contaminated sites.
Dr. Khatami has been involved with the design of gas management systems, hazardous waste impoundments, storage tank systems, waste tire processing facilities, composting facilities, material recovery facilities, landfill gas collection and disposal systems, leachate evaporator systems, and liquid impoundment floating covers. He has also been involved in the design and permitting of civil/environmental projects such as surface water management systems, drainage structures, municipal solid waste landfills, hazardous solid waste landfills, low-level radioactive waste landfills, leachate and wastewater conveyance and treatment systems.
Contact Dr. Khatami directly to answer questions and comments.
The Industrial General Permit is an NPDES permit that regulates discharges of stormwater associated with industrial activity. Based on the projected revenue and the predicted surplus, SWRCB is working to refine program funding and plans to adjust the current IGP permit fee structure.
Glen Osterhage, Fee Branch Manager for the California State Water Resources Control Board (SWRCB), Division of Administrative Services, met with industry leaders on November 3, 2015, to discuss potential changes to the stormwater Industrial General Permit (IGP) fee structure. Meeting attendees included: SCS Engineers, the Industrial Environmental Association (IEA), California Stormwater Quality Association (CASQA), the California Taxpayers Association (CTA), California Chamber of Commerce, the Independent Energy Producers Association (IEPA), and the host – California Manufacturing and Technology Association (CMTA).
The SWRCB funds eight core permit programs through the Waste Discharge Permit Fund, which pays for over 800 staff. California has cut allocations for agency staff funding by approximately $30 million dollars, forcing SWRBC to distribute its cost burden across the permit fee base. Currently, IGP permit fee revenue is $14.4 million (a single permit fee of $1,791 multiplied by approximately 8,035 permittees). However, SWRCB projects higher revenues due to increased enrollment when all newly required permittees file. Core programs are also subsidized with excess funds coming from the Construction Permit fees (excess of $2M over required $2M last year). Based on the current projected revenue and the predicted surplus the SWRCB is working to refine the IGP program funding and plans to adjust the structure of the permit fee from a flat rate to a rate adjusted for facility size, project complexity, and the threat to water quality.
Following the 2017 to 2018 year permit periods, the SWRCB will have better estimates with which they can accurately adjust fees. The SWRCB is exploring the potential for providing fee discounts for benefits or subsidizing other permit compliance cost burdens. For now, the No Exposure Certification (NEC) IGP Permits are likely to remain a flat fee, but their value may change following additional baseline permit data results.
The SWRCB’s revenue goal is, as always, to break-even; any proposed change to the fee structure is not intended to boost agency revenue over expenses. Another goal is to have data readily available for selecting a permit fee tier from the information submitted on the IGP’s online database application (Storm Water Multiple Application & Report Tracking System, SMARTS, smarts.waterboards.ca.gov).
The SWRCB will have additional meetings to collect comments on the proposed change in hopes of creating a consensus with permittees on these impending changes.
SCS Engineers will provide information as it becomes available. Our professionals are available to assist newly required permittees with filing and compliance requirements.
Contact SCS’s Stormwater Manager, Cory Jones at 1-858-571-5500 or .
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