When Melissa Russo’s boss Phil Carrillo told her he thought she should get her drone pilot license, she thought he was kidding. At the time, she worked on SCS’s Remote Control (RMC) team; selling drone services was a part of her job, but she had not thought of flying these unmanned vehicles herself.
Her thirst for competition kicked in when he turned the proposition into a bet. He was going after his pilot license himself; she bet she’d beat his score. They finished in a dead heat, but what started as friendly rivalry ended up bringing a new dimension to Russo’s job— a job that continues to expand in breadth as new opportunities turn up.
Today she not only flies, sells drone services, and teaches others how to sell and fly, but she’s helped bring geographical information systems (GIS) into RMC’s portfolio. How these technologies fit together is RMC remotely collects data from drones and different landfill systems. Then the GIS translates that data into maps, capturing a visual picture of how clients’ facilities’ systems are performing. The GIS piece is one of the latest chapters in the story of Russo’s evolving role (more to come on that).
Piloting is what especially gets her juices going.
“I love working with my team, supporting them in what they do. But when it comes to drones, I like the hands-on experience of flying myself more than telling other people how to do it.”
She controls these small aircraft from a device on the ground, sharply focused on her surroundings while keeping the drone in her sight at all times.
“You have to make sure there are no manned vehicles around; they have the right of way. And there’s a lot of continuous movement on landfills. You’re constantly aware of your surroundings. Is a truck coming? Am I in line with where dumping is going on?”
Flying drones takes muscle and mechanical aptitude.
The drone and case can weigh 45 pounds. And there are a lot of moving parts to assemble and calibrate.
Sometimes it’s manual work, pointing and rotating a remote controller to send a radio signal to tell the drone what to do. But more often, she pilots automated flights that she maps in advance and uploads the flight path specs into software that interfaces with the drone.
“When I’m flying drones, I can access areas where if I had boots on the ground, I couldn’t. I can go and explore just about anywhere, similar to when I dream— only it’s real,” she says.
With any task, she’s laser-focused, concentrating on one part of the picture at a time to grasp the details. She steps back and uses critical thinking, accumulated knowledge, and imagination to take on what’s before her.
The innovation process
“We’re pretty lucky with our timing; new and proven technologies are emerging quickly. I’m one of many SCSers with a deep knowledge of technology and practical experience in the solid waste industry. Together, we can make a difference because we understand the business and operational challenges very well. When I need an expert in another industry, I just reach out to a colleague. The learning process never ends, and each project helps me and my team constantly find better answers.
“My boss is more of a big-picture person; his ideas are huge and amazing. He comes to me with new ideas, and I figure out how to make them work and implement them,” Russo says.
She points to his idea to use proven GIS technology within RMC. She was already using GIS to map methane data, process topographic maps, and stockpile calculations. For instance, she integrates methane values into the GIS and overlaps them with imagery so her clients can zoom in on one well or get a large-scale view of the overall health of the gas collection system. But integrating GIS in new ways to incorporate multiple landfill systems would solve some expensive problems and, better yet, prevent even more expensive mitigation and repairs.
Expanding GIS applications to illustrate multiple landfill systems
“I know drones and how to process drone data. But now that we are expanding applications, I add more layers of landfill data, such as liquids, soil, the gas collection and control system (GCCS), SCADA, and surface emissions, to bring them into the RMC GIS platform. My colleagues are demonstrating these technologies at the SCS June Client Webinar.”
“I created a team of hand-picked SCS staff with both GIS and waste management backgrounds (and a whole lot of drive) to make the vision come to life,” she says. “That’s how we innovate, tight teams with access to nationwide expertise.”
Within six months of the project’s genesis, Russo and her team had integrated gas and liquid collection systems, other landfill systems, and asset management into the RMC GIS platform. She and her team now sell these applications nationwide.
Russo’s come a long way since joining SCS at age 21
In her mind, she grew up at the company. Before coming on board, she managed a shop in Manhattan Beach, California, while she began thinking about what to do next.
“I learned a lot about business and people. It was a stepping-stone – I discovered how to earn trust, build rapport, and sell. But in time, I decided I wanted a more professional job,” she recalls.
She went to work for a real estate company managing the SCS Engineers Long Beach office, where she would soon take an entry-level Accounts Payable position in SCS Field Services.
In time, she transitioned to the Health and Safety group, assisting in creating training material and managing truck fleets. Soon she was managing assets, among other firsts for her. By this point, she had developed enough software, accounting, and other administrative skills to step up fast.
Part of the job was keeping up with vehicle maintenance, so she often spoke with field staff. Many of them she already knew from her days working in the accounting department.
Growing with her SCS colleagues
“When I was in my first administrative roles, I supported many colleagues who were field techs or supervisors; they are project managers now. It feels as though we’ve grown up together, and we know and trust each other. We collaborate well and know that when we bring projects to each other that we will take care of each other,” Russo says.
She especially likes the RMC concept because remote control and automation enable her, her clients, and her team to work smarter, not harder because they leverage the technology to work for them.
“That means we can usually work from anywhere, giving all of us more time for family, friends, or allocating the time saved towards other needed to-dos. I’m up at five a.m. and, at times, may not finish work until nine at night. Somehow, us working women find the balance in between meetings, writing proposals, and answering emails; I have lunch with my two boys or take them to a park,” she says.
Bambi Lance, a veteran SCSer and her mother, works in the same business unit as Melissa does. “Mom’s been here for 16 years, and it’s interesting to have her perspective not only as my mom but as someone who knows SCS. She knows my department, and she knows me. She sees what I am doing and she along with management encourage me to do more and believe in myself.”
Russo reflects again on the concept of stepping-stones on the way to knowledge and maturity. I’m competitive and take on challenges, which has been a driving force in all I do today. It’s helped me take a personal inventory of how I am now versus the young Melissa,” she says.
She uses it to gauge her direction. And she uses it to connect to her staff. “I try to help them see you can turn almost any experience, into a positive. I want my team to see we are all learning and growing. They can, as I can, comfortably bring new ideas to the group and company, which often turn into new ways to help clients.”
She circles back to her decision to fly drones, explaining how it aligns with her career path from her first steps to today. “Becoming a pilot was a natural fit because it’s a new challenge. The craving to take on new tasks is how I grew from an accounting administrator to a project coordinator up to a business manager. It’s wanting to expand my knowledge, tackle new feats, and accomplish what I was not sure I could do. I like the challenge.”
The SCS Culture is Driven by Client Success
Join SCS on June 10 for another client webinar. Using case studies, we show you how our clients tackle common challenges using proven GIS technology to reduce expenses and run more productively.
Property Development: Time is money on development projects. Environmental engineers use GIS to more accurately pinpoint potential contamination sources, conduct site assessments, strategize remediation solutions, and see sampling results weeks faster. Infographics and dashboards show if and exactly where to continue sampling without waiting weeks or months for reports.
Landfills: Operators make diagnostic and forensic use of GIS to address maintenance tasks faster. We’ll cover modeling 3D wells and liquid level data, showing how GIS embedded dashboards and infographics pinpoint exactly where to assign staff. At the same time, supervisors monitor completed assignments seeing real-time results and what still needs attention.
Siting Solid Waste Facilities: Decision-makers use multi-criteria decision analysis incorporated into a geographic information system to account for relevant technical data, environmental, social, and economic factors during the site selection of a waste transfer station. The resulting maps and infographics are useful at public meetings too.
SCS Engineers periodically prepares SCS Technical Bulletins – short, clear summaries of U.S. Environmental Protection Agency (EPA) rules and plans. On May 21, 2021, the EPA published a Federal Plan to implement the new Emission Guideline (EG) rule for municipal solid waste (MSW) landfills. The Federal Plan is published under Title 40 of the Code of Federal Regulations (CFR) Part 62, Subpart OOO.
Read, share, download the Federal Plan for Landfill EG Rule Tech Bulletin here.
It goes without saying: landfill operators are forever working to stay on top of odors, especially when the community smells something and points to the landfill or when regulators come calling. This blog shares two odor stories: one around landfill gas and another around trash. Then it looks at what happened when an operator got a permit restriction over alleged hydrogen sulfide emissions; odor was not the problem here. It was a perceived health risk; learn how SCS proved a predictive model was off the mark.
Is Landfill Gas a Source of Community Odors? And Ensuring Compliance
Living up to landfill odor nuisance standards is tough. The underlying premise is that odors must limit peoples’ ability to enjoy life or property to create a public nuisance, but it’s a subjective call. How strong an odor is and sometimes even if it exists depends on perception, so the question becomes: when they aren’t sure what they are being measured against, how do operators comply and prove compliance?
SCS recently helped a client figure out how to accomplish this after receiving odor complaints from the community, ultimately leading to a state agency-issued violation.
“We needed to thoroughly investigate to identify and mitigate odors, then prove compliance to the state regulator. Making a strong, valid case without having a numeric standard to go by takes both creativity and a scientific approach,” says Pat Sullivan, SCS senior vice president.
Sullivan, a biologist and his team of meteorologists, air dispersion modelers, and engineers, had a good starting point. They knew landfill gas was the source of the problem. But they needed more data to get to the root of that problem, and the operator’s required surface monitoring did not tell enough of the story.
The team launched a series of studies relying on multiple investigative tools.
“When we may have to put in more gas collection components, as we did here, we want to be sure we install them exactly where they are needed. This entails going above and beyond the standard modeling with a more rigorous methodology to get a comprehensive landfill gas emissions footprint,” Sullivan says.
SCS began by bringing out a drone to reach more landfill areas than technicians on foot for better coverage. The drone can fly over slopes, areas too dangerous to walk due to constant movement of heavy equipment, and areas inaccessible because of snow and ice. As it flies, it shoots a laser, which identifies methane based on the light refraction by methane molecules—then incorporates the data into a map for a comprehensive, visual picture.
Knowing methane concentrations at specific locations is important, but determining where to be more vigilant in controlling landfill gas also requires knowing hydrogen sulfide (H2S) concentrations. Sometimes overall methane levels are within acceptable limits, but the hydrogen sulfide in it is elevated, which could be a problem, Sullivan explains.
Getting a good grasp on H2S’s potential impact is tricky, as levels can vary radically from one area of the landfill to another. Pat Sullivan, SCS senior vice president, has seen them range from 100 parts per million to as high as 100,000 at different locations.
SCS used a Jerome meter, a highly sensitive tool that precisely quantifies H2S down to low-level part per million levels. SCS took it across the landfill and then into the community in search of H2S hot spots.
At the same time that the team investigated surface emissions of H2S, they went deeper down, sampling each landfill gas extraction well for levels of this volatile sulfur compound to identify potentially problematic spots within the landfill gas system.
“For this, we used Dräger sampling tubes, a resourceful tool in that rather than sending 100 samples to the lab, we analyze them ourselves and get immediate results,” Sullivan says.
Technicians get accurate quantitative results within plus or minus about 20% and can view concentration readings out in the field. Results are recorded on field logs and entered into a database for future analysis.
SCS overlaid the methane data from the drone study with the H2S data on both surface emissions and wells to develop a roadmap to design a landfill gas system upgrade. It includes new wells and piping in focused areas and more blowers for increasing the vacuum to pull more gas.
“We saw immediate results,” Sullivan says.
“Total gas collected went up 15 to 20 percent. Complaints went down significantly, and our client has not received another violation since.”
Of course, as the landfill takes in more trash, it will generate more gas, so due diligence is ongoing.
“Problem-solving is a phased approach. You do what you determine to be most effective; evaluate; then do additional work to improve. We will continue to follow this site and fine-tune where needed to keep the system running efficiently and keep the community and regulators happy,” Sullivan says.
Taking Down Landfill Odors from Trash
New garbage on a landfill’s active face can be a source of offsite odors, but determining if the waste facility is responsible, and determining when, where, and how odors travel, takes forensic work. Landfill odor experts rely on multiple data sets and tools to understand what can be complex issues and ultimately devise the most effective odor mitigation program when necessary.
In a couple of recent scenarios in Southern California, SCS combined complaint data, meteorological data, and smoke studies to get a full picture that verified the decomposing waste was the odor source. Then staff helped nail down specific times the problem occurred and under what conditions; providing a concise window can save operators labor and other resources because they can execute proactive measures only when needed.
“We look at complaint data to learn the location, day, and time of the complaint, but these accounts are not reliable by themselves. So, we overlay this information with meteorological data to determine the wind conditions during those days and times. Weather-related data is important in vetting offsite odors because if the landfill is not upwind of the location when the complaints happen, there likely is another source,” says Pat Sullivan, SCS senior vice president.
Sullivan and his team begin their investigations in two possible ways – setting up meteorological stations at strategic areas on the landfill to capture wind-related data or capturing data from already situated stations. Then they produce wind roses from their findings, which graphically represent wind speed; how often the wind blows from certain directions; and how these two correlate. In these two scenarios, graphing wind data times during each day helped determine exactly when specific wind conditions are prevalent.
In one of the two cases, odors occurred in the summer and almost always in the morning. The data not only showed where the winds were coming from at those times, but also showed they were traveling at low to moderate speeds.
“We matched that information to complaints and confirmed that the wind conditions were indeed driving the odors,” Sullivan says, explaining the speeds were just enough to carry the odor molecules into the community but not high enough to disperse and dilute them.
“Now we have painted a picture of wind conditions that we can focus on to get more information. We are getting closer to designing a multi-tiered odor mitigation program,” he says.
The next step was a smoke study, which reveals how odors move offsite, identifying the exact pathways and movement trajectory. These details are important because to treat or disrupt odor molecules; operators need to intersect the odor plume before it leaves the site.
SCS odor experts release colored smoke at the time and location they believe odors are, based on the meteorological data. They film from a drone to get a bird’s eye view of the smoke plume as well as get a camera filming from a different angle, following the plume movement to identify its path out of the landfill. This method enables them to determine where to intersect the odors as they move through the air before leaving the site.
From this research came three recommended measures to take during unfavorable wind conditions:
One of the landfill operators now has the problem under control and has received no further violations.
The other site made many of the same changes and plans to open a second disposal area for smelly loads. This client has seen a significant reduction in complaints and violations, but it’s a work in progress. The next true test will come when Sullivan and his team reevaluate in the summer.
“We will see then if any improvements are needed and tweak the solution if needed.”
And as with our other clients, we are training operators on how to be proactive. We teach them how to identify and grade odors and how to follow set procedures. And we help them with strategy implementation,” he says.
Odor mitigation is an ongoing undertaking. The team continually assesses and quantifies emissions and potential impacts.
“We look for changes that will control odors or prevent them in the first place. And we provide clients with the know-how and support to stay ahead today and into the future. Landfills and waste volumes are growing and changing. It’s a dynamic scenario. And we continue to build on what we have proven and adjust to keep up to make more progress,” Sullivan says.
Showing That a Model Can Over Predict H2S Emissions
Hydrogen sulfide (H2S) can be problematic even at very low concentrations, so this volatile sulfur compound is on federal, state, and local regulators’ radar. Some jurisdictions require the evaluation of air toxic emissions to determine potential health impacts to nearby communities.
They are also calling for these evaluations during permitting or to decide when controls are needed. To make these impact determinations, regulators typically rely on standard H2S risk assessments leveraging air dispersion modeling that predicts concentrations at locations away from the source.
However, this methodology, which includes estimates of emissions and predicts offsite concentrations based on algorithms that mimic how air moves, is not always accurate. Inaccuracy proved to be the case at one SCS client’s site. The model overpredicted offsite measurements of H2S that the state and local agency classifies as toxic.
Ultimately, the client entered into an enforcement agreement with the state because the operator had a permit limit, based on results of the risk assessment that it could not meet.
“Respectfully, the agency came in maintaining that the levels were out of compliance; it came as a surprise and seemed questionable to our team given our experience. We felt that the air modeling and risk assessment results derived from this modeling were not accurate,” says Sullivan.
First, his team tried to adjust model inputs and variables that would yield what they believed would be more accurate data. Even though they could show improvements, the model adjustments could not obtain readings that showed compliance with the risk-based limits.
Next, they began going out monthly and measuring real concentrations at receptor locations. The team used a Jerome sensor, a highly sensitive handheld device that detects H2S down to single-digit parts per billion levels with good accuracy.
When they compared the predictions from the standard model to their readings on the same days of each month and same times of day, they confirmed the concentrations were well below the acceptable risk threshold.
“Because we did this over an extended period, we have continuous readings and a large data set from many locations that give a history and statistical validity,” Sullivan says. Every monitored value was substantially lower than the values predicted by the model.
“What that means is we could show that while there were onsite emissions, they were not escaping the landfill at levels that would exceed risk-based thresholds. That was useful in proving to the regulators that the landfill was actually in compliance with the standard, even when the model suggested it was not,” Sullivan says.
Now SCS is asking for revising its client’s permit and that the limitations are made more flexible based on real-time, longer-term findings. While the team is still waiting on the final permit decision, they’re confident they have proof that the site complies with the risk-based limit.
The outcome of this project has potential beyond possibly changing one permit for one operator, Sullivan surmises.
“We think the data developed from this study showing how the models can overestimate real-world conditions can ideally help other operators build a sound case in circumstances where they truly are in compliance.”
Related Resources
Staying Ahead of Odor Management at Solid Waste Facilities – This video recording is from a live session about the challenges of odors, including measuring them and the science behind them. Throughout the recording, the speakers’ field questions as they make recommendations for assessing and avoiding odors, regulatory issues, litigation, and responding to complaints.
The presentation and Q&A run for 1 hour 41 min. It’s well worth your time, with plenty of questions posed by solid waste facility operators, landfill managers, and composting operators answered.
SCS Engineers encourages you to share this video or any from our Learning Center. You can embed them at events and use them for in-house training. Look for our
SCS Engineers is expanding its environmental expertise with Nathan Williams, PE, as an Environmental Engineer in the firm’s Portland, Oregon office. Williams will support SCS’s growing client base in the region to meet and remain compliant with local, state, and federal regulations that impact their business or municipality, with particular emphasis on stormwater compliance and management.
Washington, Oregon, and Idaho clients have regulatory requirements that include Compliance Audits, Spill Prevention and Countermeasure Plans (SPCC), Stormwater Pollution Control Plans (SWPCP), Air Pollution Control Discharge Permits, Risk Management Plans, Form R reports and Resource Conservation and Recovery Act (RCRA) Part B. These plans and permits address regulatory requirements and help protect watersheds and wetlands that provide drinking water to downstream communities, habitat for fish and wildlife, and countless other public and economic benefits.
Williams brings expertise and credentials to provide comprehensive stormwater management services to support businesses in the region ranging from vineyards to landfills. His experience includes working on permitting and remediating contaminated sites for industrial, residential, and power generation reuse across Oregon and Washington.
As a Certified Erosion and Sediment Control Lead, Williams has extensive experience in erosion and sediment control projects, from design, permitting, implementation, and project closeout with final stabilization. Combining these skillsets helps businesses continue to deliver products and services on schedule as they encounter increasingly rigid compliance regulations.
As with all SCS Engineers employee-owners, Nathan Williams engages in industry associations and his community. Learn about Nathan and how his work on the SCS team helps municipalities, all citizens, and businesses thrive.
About SCS Engineers
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, watch a short video, visit our website, or follow us on your favorite social media.
$2 million in cooperative agreements is available for local governments to host Community Compost and Food Waste Reduction (CCFWR) pilot projects. The cooperative agreements support projects that develop and test strategies for planning and implementing municipal compost plans and food waste reduction plans. They are part of USDA’s broader efforts to support urban agriculture.
USDA’s Office of Urban Agriculture and Innovative Production will accept applications on Grants.gov until 11:59 p.m. Eastern Time on July 16, 2021. Projects should span two years, with a start date of September 25, 2021, and a completion date of September 25, 2023.
Local governments may submit projects that:
NRCS will assist in conservation-related activities.
Priority will be given to projects that include economic benefits; provide compost to farmers; integrate other food waste strategies, including food recovery; and collaborate with multiple partners.
The deadline for applications is July 16, 2021.
Project Example: The Department of Sanitation of New York and nonprofit Big Reuse establishes food scrap drop-off locations while New York City Parks Department is diverting wood chips and leaves from landfill disposal to create compost. GreenThumb, Brooklyn Grange, Hellgate Farms, Gowanus Canal Conservancy, and other urban farms distribute the compost for food production in the boroughs of Queens and Brooklyn, diverting approximately 600,000 pounds of food scraps and green waste from landfills and providing 350 cubic yards of compost to food producers.
Get Started with SCS’s ASP Composting Pilot Program
• Low-cost opportunity to test ASP composting feasibility
• Ability to test different feedstock mixes
• Assess the quality of the finished compost
• Assess odor control and process control
• Test footprint is 5000 sqft or less on your site
Webinar
A pre-recorded webinar will provide an overview of the cooperative agreements’ purpose, project types, eligibility, and basic requirements for submitting an application. The webinar will be posted at farmers.gov/urban.
More Information
Questions about this cooperative agreement opportunity can be sent to .
The Office was established through the 2018 Farm Bill and is designed to be a USDA-wide effort. Representatives from agencies throughout USDA play a critical role in successfully servicing urban customers. Other grant and engagement opportunities are available in addition to the CCFWR agreements. More information is available at farmers.gov/urban.
Additional resources that may be of interest to urban agriculture entities include NIFA grants, FSA loans, and AMS grants to improve domestic and international opportunities for U.S. growers and producers.
Partial Reprint from EPA Announcement
The U.S. Environmental Protection Agency (EPA) is announcing the selection of 151 communities to receive 154 grant awards totaling $66.5 million in Brownfields funding through its Multipurpose, Assessment, and Cleanup (MAC) Grants.
This funding will support underserved and economically disadvantaged communities across the country in assessing and cleaning up contaminated and abandoned industrial and commercial properties. Approximately 50 percent of selected recipients will be receiving EPA Brownfields Grant funding for the first time and more than 85 percent are located in or serving small communities.
The grant announcement includes:
The list of the fiscal year 2021 applicants selected for funding is available here: https://www.epa.gov/brownfields/applicants-selected-fy-2021-brownfields-multipurpose-assessment-and-cleanup-grants
Please spend some time with our experts as they help you negotiate funding, regulatory compliance, and helpful tools that will help your community prepare to remediate brownfields and other properties with a past into affordable housing, mixed communities bolstering economic development, stadiums, recreation facilities and parks, logistics centers…
SCS Engineers is expanding its environmental expertise hiring Richard Southorn, PE and PG, as Project Director in the firm’s St. Charles, Illinois office. Richard is a Professional Engineer in 13 states and a Professional Geologist in Illinois and Delaware. He will support SCS clients with their coal combustion residual (CCR) and municipal solid waste projects, including facilities for composting and the safe management of hazardous wastes.
As a Project Director, he runs teams providing comprehensive services ranging from construction plan development to full-scale design services. His client responsibilities include the coordination and supervision of the project teams made up of professional engineers, geologists, technicians, planners, and support staff.
Richard has expertise in developing site layouts and analyzing designs for multiple landfill facilities. These designs fit within the comprehensive environmental services landfill operators need to manage these complex, integrated systems. Richard’s design approach for landfill infrastructure integrates the elements that all play a role in environmental due diligence, including the landfill base and final cover liner systems, leachate extraction and cleanout systems, landfill gas control systems, and stormwater management controls.
As a licensed Professional Geologist, Southorn also oversees geotechnical stability evaluations, stormwater modeling, and the design and evaluation of landfill gas systems that minimize greenhouse gases. He has overseen many hydrogeological investigations that characterize subsurface stratigraphy, hydrology and hydrogeology, protecting groundwater for safer and more efficient facilities.
As with all SCS Engineers employee-owners, Richard engages in industry associations and his community. Learn about Richard Southorn and how SCSs’ work protects all citizens.
About SCS Engineers
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, watch a documentary, or follow us on your favorite social media. You can reach us at .
Fast-growing small to medium-sized businesses that use common chemicals and generate waste may be at risk for fines because they’ve grown into unfamiliar regulatory territory. Recently while helping a small business experiencing rapid growth, it occurred to me that many small and mid-size businesses generate waste that meets the EPA’s definition of “hazardous waste,” and the EPA is uncompromising when it comes to managing and disposing of hazardous waste.
While there are somewhat complicated requirements for storing hazardous waste at businesses and facilities, understanding them to maintain reasonable insurance rates and a safe work environment is worth every minute of your time. You’ll not only avoid fines, but your workers can easily avoid creating unsafe work conditions. My blog intends to help simplify the regulations to begin looking at your business as it is growing.
First, let’s define the terminology.
There are exceptions to these terms, but these are the basics to help the average business manager understand a complex and complicated set of regulations.
The basics of understanding hazardous waste storage and management
There are many requirements for storing and labeling waste and issues related to safety, like not storing acids in metal containers or storing two incompatible wastes close together that could react and cause a fire or explosion.
For our purposes, remember that you must have a single dedicated hazardous waste storage area, and the storage area is subject to many design, construction and operating requirements.
Each type of Generator has a storage time limit and must dispose of hazardous waste from a facility or business before the deadline. Large Quantity Generators have 90 days from placing the first waste in the storage container (accumulation start date), and Small Quantity Generators have 180 days. It is mandatory to write the accumulation start date on the container label when the first waste goes inside.
Realistic Safety Protocols
For small to medium-sized businesses Generators, it isn’t practical to have employees carrying small containers of waste to a storage area each day or at the end of each shift. It’s inefficient and could lead to the accidental mixing of incompatible wastes. It is better to have one or two trained staff responsible for placing wastes in storage containers and keeping the labels current. To help, the EPA allows for “Satellite Accumulation” of hazardous waste at the point of generation (the shop, workstation, etc.). A facility can have multiple Satellite Accumulation areas, but each area must meet these requirements:
A Growing Small Business Case Study
As mentioned earlier, let’s discuss the real-world example that got this blog started. A company started a metal container painting operation and was not familiar with hazardous waste regulations. Like many, starting as a very small operation, they were lucky, and the business grew larger over a short period.
Along with growing business comes a growing facility to accommodate it, but managing all the change creates an opportunity for some things to slip between the cracks. Employees didn’t know they could not toss partially filled paint and solvent containers in the facility’s dumpster.
During an EPA inspection, the company was subject to an enforcement action for failing to characterize their waste and improper disposal of hazardous waste, among other violations. The inspection results spurred business fines, and although the EPA has the option of pursuing criminal charges, they did not in this case.
Simple, Practical Steps to Compliance
Upon review of the records, tour of the facility, and understanding the workflow, the company took the recommended actions creating satellite accumulation areas and a hazardous waste storage area. Starting with establishing the storage area first, we also obtained an EPA ID number for the facility.
The next important step is training employees on the hazardous waste requirements pertaining to their jobs. Because some of the paint is water-based (typically non-hazardous), the facility now trains its employees to separate water and solvent-based paints and waste products, saving on disposal costs.
The company knows it is growing at a rate that will generate more than 1,000 kg/month of paint and solvent waste; therefore, it makes sense to register as a LQG. One employee is now in charge of hazardous waste management.
There are five bulk paint stations and a touch-up operation for small parts, so six satellite accumulation areas are now functioning. Each area has a 30-gallon waste container to prevent accidental accumulation of more than 55 gallons. Busy painters tend to put waste in buckets if the drum fills before their shift ends. At the end of each shift, the hazardous waste manager checks each satellite accumulation area and transports full or nearly full containers to the hazardous waste storage area.
For less than the cost of the final negotiated fine and legal fees, the facility has a compliant program and is receiving very favorable regulatory inspections.
If you want to dive into the details of this topic, this link to an EPA Frequently Asked Questions webpage may be of interest: https://www.epa.gov/hwgenerators/frequent-questions-about-hazardous-waste-generation.
About the Author: Jim Oliveros, P.G is a Project Director in SCS Engineers Environmental Services practice. He has over 35 years of experience in the environmental consulting field, including hazardous waste permitting, compliance, and corrective action. Jim is experienced in conducting assessment and remediation of contaminated properties, completing multimedia compliance audits, assisting with waste stream identification, characterization and management; and, federal and state regulatory policy. He embodies SCS’s culture of delivering great results to his clients, on time and within budget.
A large renewable energy company had ambitious plans when it bought a decommissioned plant in Missouri: to mass-produce corn oil-based biodiesel with an eye to ramp up fast. But after investing millions to purchase and retrofit the facility, the company got a surprise. The municipal wastewater treatment plant underestimated the discharge limits; now, the operator could only run at 10 to 15% capacity to send its high-strength wastewater to the City.
There was an urgency to move forward to begin to get a return on a major investment, but as important was to have a viable, long-term solution. Vetting, building, and mobilizing what turned out to be a complex, sustainable system takes time.
The project entails a lot of research and understanding of what’s in the wastewater, production processes to reduce contaminants, and technologies and vendors to support the project from start to finish. SCS Engineers came in to assist.
Nathan Hamm, program lead for wastewater and liquids management practice, said:
It was clear that we would have to find an immediate, short-term solution while looking for a long-term answer to the wastewater problem. We quickly identified and helped our client connect with another treatment plant for the interim where it could transport wastewater. This enabled the ramp-up while we searched for an economically viable strategy to take them into the future and give them the option for growth even beyond their current expansion plans should they choose.
The initial goal was to find a way to partner with the City to enhance their treatment system so the client could stay local.
SCS worked with the City’s wastewater treatment consultant on a two-part answer: restoring an anaerobic digester owned by the City located at its wastewater treatment plant to increase capacity; building a dedicated wastewater force main/pipeline from the operation to the municipal treatment plant. It was an economical plan that would perform the intended function. But the City would only commit to this arrangement for five years.
“We needed more security and certainty so our client’s investment would return value over the long run. We began evaluating various systems for on-site wastewater treatment, looking at both anaerobic and aerobic options to treat the contaminated water,” Hamm says.
There are plenty of challenges to take on, such as high BOD strength, high sulfates, high temperatures, and in this case, limited spare plant space for a robust wastewater treatment system.
Following a wastewater characterization study to analyze what the plant was generating and identify process changes to reduce wastewater generation and contaminant concentrations, SCS whittled the alternatives down to anaerobic treatments. Compared to aerobic options, they are less energy-intensive and generate less sludge. As a bonus, they create methane to power the client’s boiler.
Ultimately, the selection was an anaerobic membrane bioreactor (AnMBR) system, which leverages bacteria to break down organics in untreated water and filters out solids. The operator now treats 100% of the wastewater on-site and discharges directly to the municipal treatment plant well below permit limits.
“What’s most important to our client is that with this investment they have complete control and for the long term. They own and run the system, are well-positioned to comply with discharge limits, even if they were to get tighter. And they are ready to increase production,” Hamm says.
Progressing from identifying a fitting technology to launching the whole system is a multi-leg journey. Early on, SCS vetted installations in several states from New York to Georgia and took the client to the top performers.
Hamm states,
We vet first to ensure the system’s integrity and that it will serve our client’s needs. But it is important that once we do our due diligence, they see the system in operation and talk to operators about what they like and did not like.
Next, we helped evaluate proposals and assessed capital and operating costs to determine if they are reasonable and comprehensive to avoid costs later. There is a lot to digest, and we want to make sure our client has every bit of information to support their decision.
The SCS team negotiated a design-build contract then oversaw the construction process.
“We served as the liaison between the plant and contractor, which is important to safeguard that our client gets what they need and what they paid to get. Taking on this role helps us stay on top of scheduling moving faster while maintaining efficiency and safety,” Hamm says.
The foundation work was a project in and of itself. The structure needed to support numerous tanks and treatment vessels, including a 2-million gallon digester tank.
The design-builder originally hired another contractor for the foundation, but SCS could do the job for about half the cost.
“We brought in our geotechnical engineers and a vendor we knew working in the area to perform a thorough assessment and pile load test. Following the load testing, we were confident we could build a structure to support the system, limit the differential settlement to acceptable levels, and perform well,” Hamm says.
The new wastewater treatment system is up and running smoothly.
“We are on weekly calls even four months in to review performance tests confirming the system is operating effectively. And we have determined it is,” says Hamm.
“Our client is running at full capacity. They no longer haul wastewater offsite. They eliminated their hefty monthly wastewater treatment surcharges because they are discharging clean water. And they will likely pay off their investment in less than three years,” Hamm says.
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