In a Motion filed on November 7, the U.S. Environmental Protection Agency (USEPA) requested remand of five provisions of the Coal Combustion Residuals (CCR) Rule (40 CFR Parts 257 and 261), which would allow the agency to reconsider the provisions. This SCS Engineers Technical Bulletin covers the five provisions and the basis for their reconsideration. Read the full text here.
Oral arguments on EPA’s motion took place on November 20, 2017. EPA had asked that oral arguments be postponed, and all other aspects of the litigation are suspended until it could rule, but the court did not agree. The current provisions in this Technical Bulletin remain in place unless and until USEPA revises or rescinds them in a future rulemaking.
SCS Engineers will continue to track these issues and keep you informed. Join our Technical Bulletin email list by clicking here, or follow SCS on LinkedIn, Facebook, or Twitter .
Using a simple example the authors make apparent the importance of understanding a refrigeration system’s actual performance. An energy balance is a very useful tool to do so.
Not only do PSM regulations require that facilities have this in your PSM program, there is real value in understanding a system’s capacities. Operation and efficiency translates to substantial dollar savings every year. Savings that can be reinvested in your facility.
Calculating the total consequences of an unbalance system is more complex, but there are considerable savings running a properly energy balanced refrigeration system. Savings that can fund maintenance needs and avoid postponing timely repairs.
This white paper, presented at the RETA 2017 Conference in Pennsylvania is available in English and Spanish by clicking here.
Learn more about environmental and engineering services for Process Safety Management (PSM), Risk Management Plans (RMP), and ammonia refrigeration safety at SCS Engineers.
Ann O’Brien of SCS Engineers has pulled together a list of questions that printers should be asking themselves before the environmental reporting season is upon us.
Use Ann’s questions as a guide to find out how ready your company is, and decrease your risk of non-compliance by being more organized.
If you don’t know the answers, ask Ann. She’s one of our air and water permitting, monitoring, and reporting experts at SCS. Ann specializes in printing industry compliance.
Contact and we’ll direct you to an air, storm water, wastewater, or groundwater expert near you and in your industry.
Temporary Landfill Caps
Temporarily capping landfill slopes is becoming a common measure for landfill operators. There are many benefits to closing landfill slopes with geomembrane on a temporary basis. One of the benefits is delaying construction of the final cover. Following is a discussion of the steps that should be taken to determine whether temporarily capping the slope with geomembrane and postponing the final cover construction is a better financial/operational decision.
Cost Burden
Constructing the final cover is costly, and it is considered an unavoidable expense that has no return on the money spent. Therefore, some operators perform a financial evaluation to determine whether the final cover construction costs can be delayed (provided, of course, that such delays are acceptable to the regulating agency). When evaluating whether to delay the final cover, the cost of maintaining the slopes during the postponement period should be considered. The operator must look at the financial aspects of either closing the slopes with a temporary geomembrane or of leaving the slopes open during the postponement period.
Temporary Landfill Capping Option
The benefits of temporarily capping the slopes during the postponement period may include:
The other side of the coin is the expense associated with the temporary cap. There may be repair costs associated with the geomembrane every few years in order to ensure that the temporary cap remains intact.
Leaving Slopes Open Option
The option of leaving the slopes open during the postponement period involves maintenance expenses such as:
The benefits of leaving the slopes open are twofold: first, the operator will save the costs of constructing the temporary cap; and second, the operator will gain additional airspace as waste settles during the postponement period.
Experience with the Temporary Capping Option
As discussed above, both options provide the benefit of gaining additional airspace during the postponement period. Constructing a temporary cap involves the costs of materials and installation, including the geomembrane and the ballasting system that keeps the geomembrane in place. Generally, the financial and non-tangible benefits of a temporary cap that remains in place five years or longer are more attractive than leaving the slopes open; therefore, most operators choose to install a temporary cap. The next step in the financial evaluation should be comparing the costs of the temporary cap to permanently closing the slopes without postponement.
Final Step in the Financial Evaluation
The next question is whether it makes financial sense to postpone the construction of the final cover.
Waste settlement during the postponement period and the resulting airspace are considered the determining financial factor in choosing the right option. If the present worth value of the airspace generated from waste settlement during the postponement period is greater than the cost to construct the temporary cap at the present time, then the temporary cap option would make financial sense; otherwise, the final cover should be constructed without postponement.
It should be noted that the length of the postponement period plays a very important role in this financial equation. Longer postponement periods have the potential for a greater gain in airspace. Another incentive that should be factored into the financial evaluation is the potential return on the money set aside for the final cover construction during the postponement period.
To assist with this financial evaluation, landfill operators are encouraged to discuss these options with their landfill engineers. Settlement models can be performed to calculate the amount of airspace that may be generated during the postponement period as well as the present worth value of the generated airspace. The returns on the final cover construction costs during the postponement will just be “icing on the cake.”
Read the related Advice From the Field blogs from the landfill and LFG experts at SCS Engineers:
Contact the author: Ali Khatami or your local SCS Engineers’ office.
Discovering unexpected pockets of soft soils at the time of construction can delay your project and drive up costs for landfills, support features, and many other types of construction. If you don’t find them, building over them can result in unexpected settlement affecting a structure or building, or cause a slope stability problem for a berm or stockpile. You can avoid both of these scenarios with early investigation and appropriate construction planning.
While landfill development investigations typically require numerous soil borings within the proposed waste limits of the landfill, it’s common to overlook perimeter areas. Pockets of soft soil deposits can be associated with nearby existing wetlands, lakes, or rivers; with wind-blown silt or ancient lake deposits from periods of glaciation; or with fill placed during previous site uses.
The landfill perimeter areas may contain tanks for leachate or fuel, buildings, perimeter berms for screening or landscaping, stockpiles, and other features. A tank or building constructed over soft soils could experience unexpected settlement affecting the performance and value of the structure. The potential for a slope stability problem can increase for a large berm or stockpile built on soft soils.
The first step to avoid these problems and identify problem soils is to include perimeter areas in your subsurface investigation. Perform soil borings or test pit excavations at the locations of the proposed perimeter features such as tanks or berms. If you encounter soft soils, address them like this:
Contact SCS’s geotechnical engineers for more information on how to find and test soft soil areas early in a landfill’s project schedule, so you can effectively address associated construction issues in a way that considers cost and minimizes unexpected project delays.
Pat Sullivan discusses two case studies that provide examples of two different approaches to odor management. The proactive approach resulted in a more positive outcome than the reactive approach. Although the odor issues never go away completely, the proactive facility has avoided lawsuits and regulatory enforcement and continues to have a positive working relationship with the community.
SCS Engineers freely shares our articles and white papers without imposing on your privacy.
Click to read Part I of this two part series. We’ll let you know when Part II is published soon.
Tuesday, October 10, 1:00 pm – 2:30 pm ET
This Air & Waste Management Association webinar covers the effective, sustainable operation of municipal solid waste (MSW) landfills in today’s changing environment.
The latest updates to EPA regulations in over two decades limiting air emissions from landfills will be reviewed in detail.
Participants will learn the available models for quantifying landfill gas generation emissions and which model to use in different situations as well as energy recovery from landfill gas, its emissions, and how control requirements can affect feasibility.
Christine H. Stokes, a New Jersey Licensed Site Remediation Professional (LSRP) and chemical engineer with 20 years of experience, is now supporting clients out of the SCS Engineers’ New York regional office. Ms. Stokes’ knowledge and experience will ensure a high-level of quality solutions for SCS clients in the New York and New Jersey area.
Ms. Stokes is highly respected by clients, attorneys, and regulatory agencies involved in the environmental industry. For SCS clientele, she will continue her track record of successful project management for environmental sites, including planning and executing remedial investigations for soil and groundwater in addition to vapor intrusion assessments.
She will be responsible for planning, permitting, and conducting remedial actions, including underground storage tank closures and media treatment utilizing in-situ chemical oxidation and bioremediation. In addition, she has expertise with conventional methods such as pump and treat, and soil excavation.
SCS Engineers is known for providing all-inclusive services for contaminated sites undergoing redevelopment. Coupled with Ms. Stokes’ environmental project expertise, she will provide the key strengths respected by clients who appreciate a firm who will meet their performance and technical objectives.
“I am excited to join the SCS team,” said Ms. Stokes. “I see opportunities to support many different clients in both the private and public sectors, including those who require environmental expertise to develop new infrastructure and remediate valuable properties.”
Welcome to SCS, Christine!
Your facility will need a Qualified Industrial Stormwater Practioner (QISP) to perform an ERA Level 1 Assessment, on or before October 1, 2017, and follow up with an ERA Level 1 Technical Report by January 1, 2018, or as soon as is practicable. We recommend that this assessment and report be performed prior to the wet season of the 2017-18 permit cycle year, to assist dischargers in reviewing their minimum required BMPs and if needed, implement additional BMPs.
Review your ERA Level 1 Action Plan now. Is it correct given the additional NAL exceedances? You should review all items needed for a successful ERA Level 2 Action Plan and Technical Report to successfully reduce and/or eliminate pollutants of concern in stormwater discharge.
Your facility is required to submit an ERA Level 2 Action Plan, prepared by a QISP, which addresses each Level 2 NAL exceedance via SMARTs. This Action Plan must identify which of the three options below (or a combination thereof) of demonstration(s) the Discharger has selected to perform:
The State Water Board acknowledges that there may be cases where a combination of the demonstrations may be appropriate; therefore a Discharger may combine any of the three demonstration options in their Level 2 ERA Technical Report, when appropriate.
It is important to note that Level 2 is a serious situation under the IGP and you should start working immediately on your stormwater management goals for the ERA Level 2 Action Plan, which is due by January 1, 2018. For the BMP demonstration option, Dischargers may have to implement additional BMPs, which may include physical, structural, or mechanical devices that will reduce and/or eliminate pollutants in stormwater discharge.
The ERA Level 2 Technical Report, which summarizes the option(s) chosen and all relevant technical information, including design storm standards for treatment control BMPs, must be overseen and signed by a California Professional Engineer (PE) and submitted by January 1st, 2019.
Get help now by contacting an SCS Stormwater Professional near you.
Circumstances sometimes dictate that a licensed landfill is your only option, but Wisconsin’s solid waste laws allow you to dispose of some types of contaminated soil at other locations if the soil qualifies as low risk. Alternative options are available through an exemption process outlined in Wisconsin Administrative Code Chapter NR 718.
Who Can Apply for an NR 718 Exemption?
Except for required actions when contamination is first discovered, the Wisconsin Department of Natural Resources (WDNR) must pre-approve exemptions.
Know the Rules Before You Apply
Additional information and answers to your compliance questions are available by contacting an SCS professional. In Wisconsin, contact Ray Tierney or Betty Socha. Are you ready to take control of your environmental compliance costs? Contact me or Betty Socha to learn more about how you can save money on soil disposal at your next project.
To learn more about compliance options for contaminated dirt disposal, remediation, and construction options in other states contact or visit the SCS website services page.
Related Services and Compliance:
Brownfields and Voluntary Remediation
Environmental Due Diligence and All Appropriate Inquiries
