In implementing the EPA’s federal requirements for Coal Ash Residual – CCR sites, the Texas Commission on Environmental Quality’s CCR program needs to be at least as protective as the requirements of the self-implementing federal CCR rules. The TCEQ also is charged with making the Texas CCR program consistent with other TCEQ regulatory programs. As such, the TCEQ incorporated various provisions of state permitting programs and procedures into Chapter 352.
Whereas many of the EPA’s federal requirements are adopted directly by reference to the federal CCR rules (40 Code of Federal Regulations, as amended through April 17, 2015, issue of the Federal Register (80 FR 21301)), other requirements were tailored and, or expanded to be consistent with TCEQ programs. Following are select examples correlating the EPA and TCEQ requirements:
There were also five provisions of the federal CCR regulations that the TCEQ did not include in its permit program. These are addressed in EPA’S announcement regarding the TCEQ’s application requesting partial approval of their CCR state permit program. See https://www.epa.gov/coalash/us-state-texas-coal-combustion-residuals-ccr-permit-program
SCS Engineers and Florida East Coast Industries (FECI) are to be honored at the annual conference in Florida planned for August 2021. The firms will receive a 2021 Engineering Excellence Award by the American Council of Engineering Companies of Florida. The honor acknowledges SCS for the environmental engineering firm’s innovative design that integrates groundwater remediation with the stormwater management system on a 500-acre former landfill site. The design enabled the developer to remediate the former landfill into the Countyline Corporate Park in Southeast Florida.
Industrial real estate is in high demand, but former landfills and brownfields present environmental challenges that can become cost-prohibitive to redevelop without sound environmental expertise. FECI retained the professional services of SCS Engineers to provide consulting and design services addressing the environmental concerns preventing the transformation of a former landfill into a state of the art business park.
Environmental guidelines require 28% (or about 140 acres) of the site to be set aside for stormwater retention. The set aside would require the relocation of several thousand cubic yards of waste and prevent the 140 acres’ redevelopment. The estimated loss of $300 million in potential real estate sales, coupled with the groundwater remediation expense, made the site redevelopment cost-prohibitive. Unless resolved, the problem also impeded FECI’s corporate sustainability goals.
SCS’s experts in landfill design, closure, and remediation, developed a solution tying together the groundwater remediation and stormwater management systems. The integrated system allows for shallow aquifer recharge with stormwater and captures impacted groundwater at the site’s boundary. “We were able to provide an alternative design acceptable to all the permitting agencies, eliminating the need to set aside large areas for stormwater retention,” said Mr. Som Kundral, P.E., SCS’s senior project manager.
SCS’s remedial actions protect public health while opening the site for reuse. The project will be completed in phases. Phase I, consisting of 160 acres, is complete, with two million square feet of occupied businesses and a 30-acre community park. Development of the other three phases, which include another six million square feet, is underway.
The development will create hundreds of new jobs, deliver several hundred million dollars to the city and county tax base, and provide a 30-acre public park. “The engineering solution protects the environment while meeting FECI’s strategic, social, economic, and sustainability goals,” said Mr. Eduardo Smith, P.E., SCS’s senior vice president of client success.
Learn more about these related topics, events, and case studies at SCS Engineers:
EPA is hosting a free workshop in January on landfill monitoring and emissions. The workshops are scheduled twice, over half-day sessions. These sessions will include presentations highlighting the latest technological developments for monitoring and measuring landfill gas emissions.
Dates and Times: Register once for both sessions.
If you have any questions, please contact Shannon Banner at or John Evans at .
Maura Dougherty is joining SCS’s Southwest Business Unit as a Senior Project Manager in the solid waste engineering practice. Dougherty will execute engineering design, operations support, and construction quality assurance projects. She is responsible for project management, client service, business development, technical leadership, and overseeing professional staff teams. Dougherty reports to Vice President and Southwest Business Unit Director of Engineering, Vidhya Viswanathan, P.E., from SCS’s Pleasanton office.
“Maura is a senior professional with proven extensive success in solid waste engineering, construction, and construction quality assurance solutions,” said Viswanathan. “Her experience managing landfill and landfill gas collection and control system engineering and construction projects strengthen our efforts to support our solid waste and recycling clients.”
Dougherty is a registered Professional Engineer in California, Oregon, Washington, and Hawaii. She brings over 20 years of experience overseeing landfill engineering and construction projects, coordinating with regulatory staff, conducting design and technical reviews, and supporting construction work. Dougherty earned her B.S.E. in civil engineering at the University of Princeton and her M.S. in environmental engineering from U.C. Berkeley.
Register for SCS Engineers’ January webinar to learn more about the proactive strategies and practices you can implement at your critical solid waste facilities. This free webinar will help you develop capabilities to assess the potential for odor issues and, by doing so, set realistic benchmarks toward cost-effective and meaningful mitigation measures.
DATE: Thursday, January 21, 2021 TIME: 2 p.m. ET
Our panelists bring comprehensive expertise to the table, including facility design and planning, technical experience in air quality compliance and pollutant dispersion and air measurement programs, atmospheric dispersion and transport of airborne pollutants, particularly in the area of complex terrain. They will provide decades of strategies, resources, and best practices and technologies based on successful solutions that help support your facility as you prepare for, and likely will, experience odor complaints.
The team answers questions throughout the presentation, and the second portion of the program is devoted to Q&A and idea exchange.
SCS Engineers’ newest environmental technology application is for use at solid waste facilities and landfills. These sites require specific monitoring and analyses of groundwater and liquids, landfill gas – LFG, and surface emissions critical to facility infrastructure and the environment.
“We work side-by-side with our clients at hundreds of facilities nationwide. SCS MobileTools® supports operating decisions, whether our client is managing one site or hundreds,” states Pete Carrico, senior vice president and assistant director of SCS Field Services.” The App’s interface gives clients quick access to information that drives critical operating decisions and provides data for corporate directives and landfill gas OM&M programs for regional or national operations.
SCS MobileTools® is the iOS and Android mobile interface for the SCSeTools® platform. Access to data to make informed decisions is especially valuable when technicians are in the field, or operators are working remotely. Landfill and solid waste facility owners, operators, and technicians use the new application to observe system and environmental activity securely and in real-time on a mobile phone or device.
Featuring state-of-the-art technology, SCS MobileTools® provides users the ability to interact with a site or facility data, including site-specific monitoring and exceedance metrics for landfill gas, liquid levels, and surface emissions. Responsive, touch-enabled flow data charting is accessible, illustrating flow targets, reading dates, flow rates, and historical flow data analysis.
When compared year-over-year, generation and disposal trends produce information critical to assessing optimal options and solutions that represent significant savings for landfill gas Operations, Maintenance & Monitoring – OM&M programs. For this reason, the savings compound for regional or national operators.
For instance, monitoring and analyzing landfill gas generation and collection data against modeled estimates are valuable information. SCS MobileTools® handles the input, analysis, review, and export of landfill gas flow and related information, specifically flow rates, impacts on gas collection (e.g., extraction well liquid levels), and analytical data for data collection points.
In SCS’s release pipeline, SCS MobileTools® will include mapping and visualization functions in early 2021. SCS MobileTools® is available for download on the Apple App Store for iPhones and iPads, Google Play for Android.
SCS Engineers’ SCSeTools® platform and applications help facilities and companies operate more efficiently by continually gauging operational health and identify trends critical to operations and the environment.
SCS Technology Services®, the technology development practice within SCS Engineers, announces a new application for tracking and analyzing environmental data. The application expands the firm’s SCSeTools® platform, demonstrating its commitment to developing the most advanced data-driven technology in the environmental services industry.
Groundwater monitoring and compliance services are long-term and expensive responsibilities that generate enormous amounts of monitoring and laboratory data. SCS Groundwater™ is a tool to monitor and manage the data associated with operations and reporting requirements for various sites. Sites include active or closed landfills, plants, and impact sites such as former dry cleaners or industrial facilities.
The application also monitors and manages data effectively for clean groundwater applications such as groundwater basin management projects consistent with standard protocol under state and federal environmental compliance rules. SCS Groundwater™ collects and efficiently organizes groundwater monitoring and maintenance data providing those responsible for environmental compliance with a reliable, consistent, and cost-effective way to manage the large volume of information.
The application’s primary value is enabling users to set up a detailed monitoring plan for any number of events, including the sampling points to include and what analyses to perform at each point. Once the information upload is finished, the application checks incoming data against the plan to confirm all work is complete.
SCS Groundwater™ generates reporting components such as data tables, charts, graphs, and maps for compliance, reporting, and finding trends. For example, on a brownfield site, the compliance manager could upload historical monitoring data results, view the data trends over time, and then produce report tables and figures. Operators can also use the data in other applications for additional analysis or visualization.
SCS Engineers’ environmental solutions and technology directly result from our experience and dedication to industries responsible for safeguarding the environment as they deliver services and products. For information about SCS, visit the SCS eTools pages or enjoy our 50th Anniversary video to see the technology in action.
The SCSeTools® platform and applications help facilities operate more efficiently by continually gauging operational health and spot trends that help determine when and how to invest in infrastructure. Field staff, environmental compliance experts, brownfields, developers, and clients in the waste industry guide the technology designs. For additional information and demonstrations of these productivity-enhancing tools, please contact .
The events of 2020 have affected the economy, the way we conduct business, and even our social interactions. Now, more than ever, streamlining costs is key for public and private sector clients across the country. Enter groundwater monitoring projects.
Often overlooked as an opportunity to reduce costs, it’s an excellent place to start when examining the costly operational processes of a solid waste facility. Groundwater monitoring is often thought of as necessary for compliance requirements and overlooked when considering ways to reduce spending. However, the proactive review of all monitoring projects may offer monitoring reduction or even cessation opportunities.
SCS Engineers has successfully employed these strategies at several Florida landfills. For instance, in Marion County, the SCS team worked to get a cessation in landfill gas and groundwater monitoring at the Martel Closed Landfill. Hired to conduct routine post-closure monitoring, the team observed obvious trends in the data that were favorable to the County. If you consider that monitoring costs average $10,000 to $50,000 per year, the potential cost savings over ten years is $100,000 to 500,000.
Bottom line: you should take the initiative to ask a few simple questions to see if further examination is warranted. What if contaminants are naturally occurring? Is the data in the technical reports supporting conclusions that include reduction or cessation when appropriate? Are you simply meeting the minimum requirements of the permit without an eye on the future?
About the Author: SCS Project Director David Atteberry puts his 20+ years of environmental consulting and management experience to work for his clients. His technical experience includes geologic and hydrogeologic investigations involving hazardous waste, solid waste, environmental, and water supply. Dave’s technical areas of expertise include contamination assessments, remediation, site characterization, aquifer characterization, RCRA compliance, waste characterization, environmental due diligence, reserve budgeting, and field sampling techniques.
SCS Groundwater™ collects and efficiently organizes groundwater monitoring and maintenance data providing those responsible for environmental compliance with a reliable, consistent, and cost-effective way to manage, view, and assess large volumes of information.
The application’s primary value is enabling users to set up a detailed monitoring plan for any number of events, including the sampling points to include and what analyses to perform at each point. Once the information upload is complete, the application checks incoming data against the plan to determine if all work is completed.
Efficient and consistent data collection means better quality control, fewer violations, and less costly operations. The application is a relational data management system specifically designed for groundwater management. Learn about more benefits here.
Across the industry, stakeholders agree the next few years will be critical in shaping how landfills deal with PFAS and how the public perceives it. Waste trade associations, scientists, and a host of organizations are in the midst of conducting a number of studies looking closely at the issue, PFAS treatment options, the positive impact of recycling, and regulatory policies.
While there are sites noted in the article, there’s no practical way for most companies and landfills to respond at this time responsibly. Additionally, landfills are unique; no two are alike. Most human exposure to PFAS occurs through contaminated food. The majority of landfill leachate is pre-treated at the landfill before going to a wastewater treatment plant, where additional treatment occurs before discharge.
According to EREF President Dr. Bryan Staley, in the article, “The relative impact of leachate as a human exposure pathway needs further evaluation to understand its relative degree of importance as it relates to health implications.”
Dr. Gomathy Radhakrishna Iyer, landfill leachate and design expert for SCS Engineers, said some operators are waiting to see what regulations may come even as they work on accounting for potential compliance issues and seeking solutions. “When the clients are thinking of upgrading their treatment plans, some are definitely taking into consideration PFAS treatment,” Radhakrishna Iyer said.
“You’re spending millions of dollars, you need to do your due diligence, right? At this point, consideration should be given to PFAS treatment during the feasibility stages,” she said.
SCS Engineers welcomes Project Manager Jeff Phillips to the Clive, Iowa office. Jeff works with a growing number of solid waste management clients interested in integrating sustainable materials management into their solid waste master plans. The practice is widely known as Integrated Solid Waste Management, ISWM.
Jeff Phillips comes to SCS with over two decades of designing and implementing ISWM programs. His expertise includes a comprehensive list of individual tasks and services, including facilitating strategic planning and consensus-building sessions, performing waste and recycling industry market analyses, developing and presenting comprehensive financial plans to solid waste agencies, identifying, authoring, and managing federal and state grants. He also designs, performs, manages waste characterization analyses, authors and produces videos for training and education purposes, and is involved in community outreach events for solid waste agencies, city councils, and the public.
“Jeff provides innovative approaches to develop and strengthen programs and operations in Iowa,” said Christine Collier, senior project manager. “He fits right into our SCS philosophy of ensuring client success.”
Jeff is an active member of the Solid Waste Association of North America and the Iowa Society of Solid Waste Operations, where he previously served on the Board of Directors and Conference Planning Committee. He earned a Bachelor of Arts, Geography, and Environmental Studies from the University of Iowa.
