The annual Environmental Compliance Conference returns to North Carolina in Raleigh-Durham on January 30. Join your fellow environmental professionals in an insightful event that focuses on regulations and ways to ensure compliance. This conference dives deep into legislation and policies currently impacting the air, water, waste, and natural resource industries. Build your network of resources, register for the event today.
EPA updated its Compliance and Emissions Data Reporting Interface (CEDRI) for the electronic reporting of air emissions under the NESHAP related to MSW landfills. Three new reporting templates were added on October 15, 2024, each linked to its corresponding Excel spreadsheet template. These include the
The Semi-Annual report is the most significant because MSW landfills have 90 days to begin using the Excel template. Reports due January 13, 2025, or any time after that must include this electronic filing.
EPA’s color-coded template provides a bit of instruction.
The gray tab (Company Information) contains general information likely to be unchanged from report to report. After completing the gray tab, you may save the workbook as a site-specific template to use in subsequent reports to limit subsequent data entry.
Complete the green tabs (Certification, CMS Info, Description of Changes, Exceedances, and Number of Exceedances) as appropriate to complete the semi-annual report.
Complete the blue tabs (Deviation Detail, Deviation Summary, CMS Detail, and CMS Summary) if deviations or CMS out-of-control periods or downtime periods occur according to §63.10(e) and as defined in §63.1990.
The orange tabs (Well Expansion, Operational Statements, Site Specific Treatment, Enhanced Monitoring, Bypass CDT Not Operating, and Corrective Action Analysis) cover information required by the semi-annual report requirements of §63.1981(h); be sure to complete the requisite tabs.
Professionals at SCS Engineers will post more guidance but plan to continue preparing our clients’ semi-annual reports as we do now, and completing and submitting this spreadsheet. Please work with your air emissions specialist or project manager, or contact us for support.
Additional Resources:
Based on your feedback, SCS is excited to thank you for the 2024 CX Award. It is a pleasure and privilege to help you with your environmental needs. At SCS Engineers, we recognize that a substantial part of the value we deliver is how well we serve our clients. To that end, we have in place several long-standing programs to make it easy for you to reach us, find help, and provide feedback.
Reach Out Toll-Free +1 (800) 767-4727
Our receptionists answer calls between 8:30 am ET through 5:00 pm PT. We promptly answer voicemails and messages sent to our general email () 24/7.
Client Feedback Tool
SCS solicits feedback from clients during ongoing projects via short (2-3 minute) surveys using our electronic Client Feedback Tool (CFT). These surveys are designed to ensure we are on track to deliver project solutions to your satisfaction. Surveys are less than ten questions, and space is available for additional comments. Your Project Manager will work to establish a convenient schedule for you if you’d like to participate. This is not a marketing survey. It is a way to check in with you regularly to ensure your project is on track, in addition to regular communications with your Project Manager. Your participation is greatly appreciated.
Quality Management
SCS maintains a stringent, comprehensive Quality Management program. Quality Management ensures that SCS staff professionals, scientists, technologists, and field technicians, including administrators and subcontractors, have the necessary training, tools, and skills to employ sound, ethical processes on every environmental solution.
Our robust program includes apps built by SCS for our staff to continuously improve our services and communications. SCS staff have access to thousands of resources at the touch of a button, including libraries, compliance documents, safety information, training, and our National Experts and specialists nationwide to maintain the highest level of quality in our products and services. We make many of our resources available on our website, too.
The Website
SCS’s website is a rich resource for our clients and visitors. The site has two primary filters: one to find local staff with specific environmental experience. The second is a search filter that results after a search to help you target our resources, available on demand. Service descriptions, articles, whitepapers, blogs, events, and videos can be resources. Each page enables you to print or share the resource privately with others or on social media.
Free Environmental Educational Videos
The SCS Engineers Learning Center contains recorded open forums where participants ask questions throughout. The video recordings are available in our Learning Center to watch at your convenience. These are educational videos, not sales pitches, as we share our experience and expertise in environmental fields with individuals and businesses to enhance a clearer understanding of modern environmental solutions and technologies available.
This Air & Waste Management Association specialty conference is the perfect event to provide an important basis for future development and advancements in the air quality modeling field. It will also provide in-person opportunities for stakeholders and regulators to discuss the challenges and techniques to model ever-tightening air quality standards.
The technical program will include an opening plenary session devoted to invited presentations by EPA’s Office Air Quality Planning and Standards (OAQPS) Air Quality Modeling Group (AQMG). Multiple sessions will cover key modeling topics, and the popular Town Hall Meeting will include an interactive Q&A format with high-level regulators and stakeholders.
Determining actual fugitive landfill gas/methane emissions from the landfill surface is hard to quantify. Drone methane and surface emission monitoring conducted on the landfill surface can determine methane concentrations at receptor points around the landfill surface. These receptor concentrations can be used to run an air dispersion model in reverse to solve for the emission rate of the entire landfill surface. This method also allows you to determine a more accurate control efficiency of the gas collection and control system at the landfill based on landfill gas/methane flow to the combustion device. Want to know more?
Jeff Leadford, PE, of SCS Engineers, is presenting “Modeling Fugitive Methane Emissions With Drones” – a not to miss session! Jeff puts his years of experience in the air quality field, with a focus on air dispersion modeling, air permitting and GIS together with advanced drone technology and modeling techniques demonstrating the effectiveness of combining them, especially for landfill owners and operators.
Other session topics include:
A revision to AP-42 regarding Municipal Solid Waste (MSW) Landfills was finalized on August 15, 2024. AP-42 is the Compilation of Air Pollutant Emission Factors guidance developed by the U.S. Environmental Protection Agency (EPA) to evaluate air pollution emissions from various sources. EPA drafted new emission factors for the MSW Landfill portion of AP-42 on January 12, 2024 and offered a 60-day public comment period that ended March 12, 2024.
Highlights of this final action include:
For additional information, please contact SCS Engineers, or visit the EPA Air Emissions Factors and Quantification website.
Anecdotes on stormwater design, management, and regulation by a non-engineer
The purpose of this series is to present case studies and general thoughts on stormwater. When possible, I want to share interesting examples that may offer opportunities to challenge existing paradigms and spark discussion. As an ecologist/toxicologist, I have very much enjoyed this now 20+ year foray into what is often an engineer’s wheelhouse. My hope is that I can offer a different angle on stormwater, as we seem to be increasingly affected by high storm intensities and more stringent regulations across the country.
A Little Historical Context…
Stormwater has, and continues to be, largely the purview of engineers. Engineered designs for managing stormwater have existed for thousands of years and can be seen in both the “ancient” old (Mesopotamia) and new (Mayan and Aztec) world. Designs were empirical and began out of necessity for safety and to protect land uses, such as residences and agriculture. In modern times, empirical observations have been converted into modeling tools to simplify the process greatly.
These days, stormwater issues are getting more complex. Heavy, widespread water pollution generally began in the mid-1800s with the Industrial Revolution but became a more obvious problem following World War II. The first major U.S. water quality law was enacted in 1948 and became much more prominent in 1972 as the Clean Water Act (CWA) we know today. The CWA addresses stormwater because it clearly has the potential to carry pollutants, particularly when it originates from large industrial sites.
More recently, we have become much more aware of the key role of long-term planning when it comes to stormwater. Trying to engineer your way out of a stormwater problem will likely be much more expensive than simply planning well and maintaining a properly designed system.
Although stormwater engineering was once simply about preventing stormwater from being destructive, it has now become at least as much about maintaining water quality. As pollutants become more prevalent in more confined and constrained systems, effects on human health and the environment are likely to be more pronounced, especially when existing ecosystem services are inadequate to mitigate impacts. Moreover, ecosystems expected to treat stormwater, such as wetlands and streams, are now likely protected themselves, and opportunities for “dilution being the solution to pollution,” while still a valid concept, are becoming rarer. Our ecosystems simply do not have the capacity to handle everything we are throwing at them.
That’s the context for this series: How we control and treat stormwater in the context of interesting observations and experiences. The intent is to share stories and thoughts to create conversation and reflection on stormwater played against the regulatory background.
Authors Note
I am an ecologist with a postdoctoral background in environmental toxicology and have been professionally engaged as a consultant in water quality issues since 1989. Recently I have become engaged in a number of legal discussions and disputes regarding water quality; in particular, industrial stormwater, and I continue to be interested by issues that come up during the course of a general stormwater practice.
I am a pragmatist: I have practiced long enough that I have left idealism behind. Idealistic approaches are valid as a theoretical baseline, but anything beyond that must have scientific or well-documented empirical support. Otherwise, idealism is just sort of adorable, if not misguided, and can lead to real problems.
As an ecologist, I respect our ecosystems as much as anyone. Our goal is to protect human health and the environment. Some parts of this series may appear to some that I’m “siding” with industry or other client concerns, but my intent is always to balance idealism against practical and scientific reality.
In summary: “The road to hell is often paved with good intentions.”
Let’s walk the road together and see what we can figure out.
On July 16, 2024, the Volusia County Council approved a contract with SCS Engineers to develop a new 271-acre Class I landfill. The landfill, located at the southeast expansion area (SEA) of the Tomoka Farms Road Landfill, is part of the County’s long-term plan to meet its Class I sanitary solid waste disposal needs for over a century. The Public Works will oversee the project, Solid Waste Division, under the guidance of the County’s Project Manager.
SCS Engineers will provide a range of engineering services, including developing a solid waste permit application package for the Florida Department of Environmental Protection. They will design the landfill gas collection and capture system, supporting infrastructure, geotechnical needs, and leachate collection to protect groundwater and soil. Additionally, they will provide support services for selecting a construction contractor for the first 20-acre disposal cell at the new landfill.
SCS will collaborate with the County to identify any constraints that may impact the cost or constructability of future projects. They will also explore potential opportunities associated with this project to ensure the design complements and maximizes future development opportunities.
Landfills are complex systems integrating liquid and gas management systems to protect the environment. Volusia County selected SCS Engineers for their expertise in designing modern landfills that adhere to strict state and federal regulatory and quality control guidelines. The firm’s understanding of how current landfill operations interrelate with the development of SEA was a key factor in their selection.
Modern landfills are ecosystems that isolate waste from surrounding environments, such as groundwater, air, and rain. While the County’s reuse, recycling, and organics management programs significantly reduce waste in landfills, the SEA development provides an essential service that will continue uninterrupted as communities transition to even more sustainable programs and infrastructure to reuse landfill gas and other byproducts.
Vice President Dan Cooper, P.E., expressed his gratitude, stating, “SCS is privileged that Volusia County has entrusted us as a partner to sustainably engineer SEA’s safe and efficient development. We’re honored to assist the Solid Waste Division in their mission to support the citizens and the environment.”
Additional Resources:
On July 24, the U.S. Environmental Protection Agency (EPA) proposed to designate five chemicals as High-Priority Substances for risk evaluation under the nation’s chemical safety law, the Toxic Substances Control Act (TSCA). If EPA finalizes these designations as proposed, the agency would immediately move forward with the risk evaluation process. According to the current Administration this step is consistent with a commitment to understand and address environmental and toxic exposures to ensure that every community has access to clean air and water while bolstering efforts to make progress on delivering environmental justice and tackling plastic pollution.
The five chemical substances EPA is proposing to designate as High-Priority Substances are:
EPA will accept public comments on the proposed designations for 90 days after publication via docket EPA-HQ-OPPT-2023-0601 at the Regulations.gov page. Upon publication of the Federal Register notice, supporting documents will also be available in the docket.
Chemicals Proposed as High-Priority Substances for Risk Evaluation
All five chemicals were selected from the 2014 TSCA Work Plan, which is a list of chemicals identified by EPA for further assessment based on their hazards and potential for exposure. In proposing these five chemical substances as High-Priority Substances for risk evaluation, EPA had to consider the chemicals’ conditions of use and production volume or changes in conditions of use and production volume over time, impacts to potentially exposed or susceptible subpopulations including children and workers, and the chemicals’ potential hazards and exposures. EPA also considered more specific criteria such as the chemical’s bioaccumulation and environmental persistence and whether the chemical is stored near significant sources of drinking water.
Vinyl chloride is used primarily in the manufacturing and processing of plastic materials such as polyvinyl chloride (PVC), plastic resins, and other chemicals. Many of these materials are used for pipes and insulating materials. This chemical was also involved in the Norfolk Southern train derailment in East Palestine, Ohio. Vinyl chloride is a known human carcinogen and can cause liver, brain, and lung cancer in exposed workers. Short-term exposure to vinyl chloride can also result in other health effects such as dizziness, nausea, and eye and skin irritation. Vinyl chloride exposure can also damage genetic material in cells, which can lead to numerous adverse health effects. In the 1970s, the White House Council on Environmental Quality and EPA officials raised serious concerns about the health impacts of vinyl chloride as an example when the Nixon Administration asked Congress to write a law to ensure chemicals were made and used safely, which led to passage of the “original” TSCA in 1976.
Acetaldehyde is used primarily in the manufacturing and processing of adhesives, petrochemicals, plastic and other chemicals, as well as intermediates for products such as packaging and construction materials. Acetaldehyde is a probable human carcinogen. Specifically, animal studies have shown that exposure to acetaldehyde can result in the formation of nasal and laryngeal tumors. Short-term exposure can also result in health effects such as irritation of the respiratory system and reduced heart function. Data further shows that acetaldehyde exposure can damage genetic material in cells, potentially leading to numerous adverse health effects.
Acrylonitrile is used primarily in the manufacturing and processing of plastic materials, paints, petrochemicals, and other chemicals. Acrylonitrile is a probable human carcinogen and can cause lung and brain cancer in exposed workers. Short-term exposure to acrylonitrile can also result in health effects such as eye, skin, and respiratory irritation. Long-term exposure can result in reproductive effects such as reduced sperm count and developmental effects such as slowed fetal growth.
Benzenamine is used in the manufacturing and processing of dyes and pigments, petrochemicals, plastics, resins, and other chemicals. Benzenamine is a probable human carcinogen and can cause bladder tumors and pancreatic cancer in workers. Long-term exposure to benzenamine can result in a range of adverse health effects such as difficulty in breathing, tumor growth in the spleen, and possible reductions in fetal viability.
MBOCA is used in the manufacturing and processing of rubbers, plastics, resins, and other chemicals. MBOCA is a probable human carcinogen. Specifically, animal studies have shown that exposure to MBOCA can cause liver and urinary bladder cancer. Short-term exposure to MBOCA can result in eye and skin irritation. Data further demonstrates that MBOCA exposure can damage genetic material in cells, potentially leading to numerous adverse health effects.
EPA Prioritization Process
Prioritization is the first step under EPA’s authority to regulate existing chemicals currently on the market and in use. EPA’s proposed designations are not themselves a finding of risk. If EPA finalizes these designations, the agency will initiate risk evaluations for these chemicals to determine whether they present an unreasonable risk to human health or the environment under the TSCA conditions of use (the way the chemical is made and used), which the agency is required to complete within 3-3.5 years. If at the end of the risk evaluation process EPA determines that a chemical presents an unreasonable risk to health or the environment, the agency must begin the risk management process to take action to eliminate these unreasonable risks.
EPA began the process of prioritizing these five chemicals in December 2023 and also announced that it expects to initiate prioritization on five chemicals every year, which will create a sustainable and effective pace for risk evaluations. According to EPA, the agency has continued to improve the prioritization process by investing in cutting-edge software to review more information earlier in prioritization. EPA has also implemented improvements to its systematic review approaches as recommended by the Scientific Advisory Committee on Chemicals (SACC) by incorporating additional data sources such as assessments published by other government agencies to identify potential hazards and exposures, clarifying terminology to increase transparency in the systematic review process, and presenting interactive literature inventory trees and evidence maps to better depict data sources containing potentially relevant information.
EPA has conducted a preliminary screening and technical review of large data sets to more efficiently identify relevant information for prioritization and risk evaluation and can easily flag information that may be useful to retrieve later in the risk evaluation process. As a result, EPA now has a head start on risk evaluations. At this proposed designation stage, EPA has a much fuller understanding of how these chemicals behave in the environment and their potential hazards and exposures than it had at this point in the process in the previous prioritization cycle conducted in 2019. That has also enabled EPA to make considerably more information available to the public a year earlier than occurred for the first 30 chemicals designated for risk evaluation under TSCA. The public will be able to see which studies and what information EPA considered in its screening review for proposed designation and submit any additional information they would like EPA to consider via public comment.
Additional Resources:
On May 17, 2024, the U.S. Environmental Protection Agency (EPA) expanded its Toxic Release Inventory (TRI) program to include seven additional per- and polyfluoroalkyl substances (PFAS), raising the total number of PFAS tracked under the TRI to 196 to report in 2025 for the year 2024—the PFAS to report on for 2023 on July 1, 2024 numbers 186.
This decision, mandated by the 2020 National Defense Authorization Act (NDAA), which requires annual updates to the PFAS list in the TRI, reflects ongoing efforts to monitor and manage environmental exposure to these persistent chemicals.
The EPA removed the de minimis exemption for PFAS under the “chemicals of special concern” category as of October 2023. This elimination underscores the increased regulatory focus on these substances due to their environmental and health risks, thereby intensifying the demands on facilities to track and report PFAS handling accurately. This ongoing regulatory evolution highlights the increasing scrutiny and accountability for environmental stewardship concerning PFAS.
SCS’s educational video Toxics Release Inventory Reporting explains how to identify and quantify facilities subject to TRI reporting, including:
Facilities must start compiling historical and new information to meet compliance requirements. The educational video covers the reporting thresholds and tips for collecting the data, calculating usage, and determining which form to report to the EPA. Some facilities accidentally overreport, so our expert tells you how to avoid this mistake.
Including additional PFAS in the TRI places a greater compliance burden on many industries. Companies must adapt by implementing more rigorous tracking systems and investing in technologies to reduce PFAS emissions or discharges.
Tracking specific product formulations is more important than ever. Safety Data Sheets (SDS) and historical reporting are a good place to start. Still, our expert explains how to minimize your facility’s risk of non-compliance, fines, or legal actions by not relying on SDS. She provides many tips for increasing the accuracy and accountability of this public information.
Request Tools and Resources Slides or ask a Hazardous Waste Expert a question here.
On October 16, 2023, US EPA’s Integrated Risk Information System (IRIS) Program released an updated toxicological review for inorganic arsenic, which includes proposed changes to the toxicity factors. Many federal, state, and local agencies use IRIS toxicity factors to assess environmental risk and establish risk-based environmental standards.
For example, the State of Florida and Miami-Dade County derived their direct exposure Soil Cleanup Target Levels (SCTLs) using these toxicity values, per Chapter 62-777, Florida Administrative Code and Chapter 24-44(2), Code of Miami-Dade County. If adopted, the updated toxicity values will lead to lower arsenic cleanup standards and, as a result, will significantly impact the assessment and remediation of contaminated sites throughout Florida.
Toxicity Factors Under Review and Potential Impact
The specific toxicity factors under review are the oral cancer slope factor (CSFo) and the oral reference dose (RfDo). In the current draft of the updated assessment, the IRIS Program has proposed a CSFo of 53 mg/kg/day for combined cancer risk and an overall RfDo of 0.031 µg/kg/day to protect against all noncancer adverse health effects associated with inorganic arsenic across all life stages.
To illustrate the significance of these updates, we used the proposed CSFo to re-calculate the State of Florida SCTLs. The resulting SCTLs would decrease from the current Residential SCTL of 2.1 mg/kg to 0.1 mg/kg and from the current Commercial/Industrial SCTL of 12 mg/kg to 0.4 mg/kg (assuming all other exposure factors remain the same). If the proposed changes to the toxicity factors are approved, remediation in Florida could feel the impact. An environmental engineer/consultant knowledgeable in due diligence, background assessments, and risk assessment/management can help you navigate these changing regulatory requirements.
Rulemaking Process At Midpoint
The following links will direct you to the proposed toxicological review, a summary of the comments received during the public comment/peer review process, and information on the general assessment review process:
Given the potential impact on the cleanup standards, it is important to remain current with this updated assessment’s development and keep our clients informed of the potential changes. EPA is reviewing over a hundred comments received on the October 2023 draft IRIS Toxicological Review of Inorganic Arsenic. We understand that the final document’s projected release date will be announced once the Science Advisory Board delivers its peer-reviewed report. We’ll keep you informed.
Additional Resources:
About Arsenic
Arsenic is a naturally occurring trace element in the environment. It is in geological formations, and levels in soil can range from 1–40 milligrams per kilogram (mg/kg). Erosion, leaching, and some human activities can increase arsenic levels in soil. Arsenical pesticides were once commonly used in agriculture to maintain turf (e.g., golf courses, parks, etc.) and treat wood. While their use has been significantly restricted, residual concentrations can still be detected during an environmental site audit/assessment.
Land Remediation and Brownfields: Information, case studies, grants, and educational materials.
Meet our Authors: Environmental Scientist Anabel Rodriguez Garcia and Lisa Smith, a principal technical advisor and expert in risk-based corrective action.
