(40 CFR Part 60, Subpart OOO)
On May 21, 2021, EPA published the final MSW Landfills Federal Plan, which implements the 2016 Emission Guidelines (EG Subpart Cf) under 40 CFR Part 62 Subpart OOO. The Federal Plan becomes effective June 21, 2021, and impacts landfills that have not triggered NSPS Subpart XXX requirements and landfills located in states and Indian country without EPA-approved EG Cf rules.
Affected are MSW landfills that commenced construction on or before July 17, 2014, and have not been modified or reconstructed since July 17, 2014.
The Federal Plan requires existing landfills that reach an annual emissions threshold of 34 metric tons of nonmethane organic compounds (NMOC) or more to install a system to collect and control landfill gas (GCCS). It also implements various emission limits, compliance schedules, testing, monitoring, reporting and recordkeeping requirements for GCCSs established in the 2016 Emission Guidelines for MSW Landfills.
The Federal Plan also establishes a definition for “legacy controlled landfills.” These are landfills that have previously satisfied the requirement to submit an initial design capacity report, initial (or annual) NMOC emission rate reports, and collection and control system design plan under 40 CFR part 60, subpart WWW; 40 CFR part 62, subpart GGG; or a state/tribal plan implementing 40 CFR part 60, subpart Cc.
If you are subject to the Federal Plan and are not a “legacy controlled landfill,” you must submit a design capacity report by September 20, 2021. And if the design capacity report indicates a capacity equal to or greater than 2.5 million Mg and 2.5 million m3 of solid waste, you must also submit an initial NMOC emission rate report within 90 days after the effective date of the Federal Plan (September 20, 2021).
SCS is working to develop a Technical Bulletin for distribution to our mailing list and on social media. The Bulletin will consolidate the Final Rule into several pages highlighting significant dates and key impacts for you.
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.
Related Information
Preparing for restrictive discharge limits, and treatment options… Read More »
Lately, landfill operators are putting stock in onsite landfill leachate treatment systems as a strategy to stay on top of increasing requirements in their already demanding regulatory world. Leachate treatment systems help meet tightening restrictions on liquids that landfills send to municipal wastewater treatment plants or discharge directly. And onsite leachate treatment gives operators … Read More »
Not long ago, a Utah food manufacturer turned to SCS with a persistent problem: high concentrations of fats, oils, and grease (FOG) in its wastewater— high enough to clog the city’s sewer line, knock it out of compliance, and cost it a steep surcharge year after year. As the plant worked toward a solution, … Read More »
In November 2020, this EPA Memo provides recommendations for an interim strategy to address PFAS monitoring in NPDES permits – both for wastewater and stormwater discharges. Jeff Marshall recommends reading it and highlights excerpts. Jeff notes it will be interesting to see how soon state permit writers begin adding PFAS monitoring requirements to landfill NPDES … Read More »
Local governments feed tens of thousands to millions of dollars into their landfills long after closure to continue protecting the environment and people, compelling some of them to find creative ways to offset post-closure maintenance costs and to potentially profit. In some cases, these localities convert closed landfills to active, useful community assets.
Two Maryland counties are among recent SCS Engineers’ clients who are converting their idle properties into revenue-generators that serve their communities—they are installing solar farms, a growing trend on closed landfills. This is consistent with the U.S. EPA’s Re-Powering America’s Land Initiative that encourages renewable energy development on landfills.
Siting solar energy installations
These sites are fairly flat, open spaces conducive to solar installation, and most are near power lines and in regions where real estate is limited and high-priced. While properties like these Maryland landfills provide ideal locations and are inexpensive, the projects command a robust multidisciplinary redevelopment approach. It takes proficiency in environmental and civil engineering designs that protect natural resources while maintaining landfill integrity. Look for consultants with both landfill and brownfields experience who know permitting processes, are up on local regulators’ hot spots, and have established relationships with energy service companies.
One of these projects on a closed county landfill will be a 6-megawatt system, sprawling over 170 acres, the largest solar project on county property. It will provide inexpensive, green electricity to low- and mid-income families, enough to power 930 homes, as well as power county buildings.
SCS Engineers was selected by Ameresco, the solar developer for both projects, to develop the required state and local permits. As the solar developer, Ameresco is performing turnkey services for the projects, including solar design, interconnection with the utility for sale of the electrical power, and operation of the solar systems consistent with a long-term agreement with both of these counties.
“This project will provide financial relief to people of the county and also help fulfill our client’s goal to advance green infrastructure and operations in county buildings,” says Mike Kalish, SCS Engineers Project Manager.
A full understanding of local regulations and proven engineering designs are key to success.
Pulling together the detailed engineering components to secure the state permit and local approvals are involved processes. Knowing the regulatory programs and potential impacts of the design and construction are key to quick and efficient navigation of the approval processes. “The faster you can get through permitting, the better for communities who want access to power. The county officials have made this decision while Ameresco is investing significant capital, and we want to assist in project implementation to enable a return on that investment as soon as possible,” Kalish says.
He and his team key in on what regulators look for and their anticipated trigger points and work to stay a step ahead.
“Because of our familiarity from prior work at these sites, we were able to avoid costly site investigations, thereby saving time in the permitting processes,” Kalish says.
SCS supports clients not just in developing designs that meet regulators’ requirements but verifying, documenting, and demonstrating compliance with all aspects and considering the long-term needs. For instance, meeting the fire marshal’s codes showing the proposed roadway design meets stipulations around access into the site and around solar panel arrays.
“We also take great care to maintain the cap’s integrity and ultimately its closure certification,” Kalish says. “But we have a holistic plan that accounts for more than the cap to be sure that the landfill is in its existing condition once we complete the project. For example, the solar panels mount on a series of ballast blocks that sit on the ground surface; there is no digging involved.”
“We are attentive to mitigating impacts to natural resources and ecosystems, just as we are diligent in protecting the landfill.”
“There’s also adjacent forest we need to go through to connect to the electric grid. So, in our evaluations, we take into account design considerations and impacts to forest conservation regulations as well,” Kalish says. “Maximizing development while protecting sensitive resources, as well as valuable capital assets, is a priority.”
“That’s a quick turnaround considering the diligence and attention to detail that large solar projects require, but it’s important to our client, so it’s our priority too. This is when knowing local regulations well is most valuable. As important is that we have a long-standing relationship with the client where we know the site’s history – all key to being able to move quickly and safely.”
The SCS Engineers and Ameresco Team
SCS is working with Ameresco, one of the largest renewable energy project developers in North America. SCS and Ameresco have very complementary skills. Whereas SCS has decades of experience in landfill engineering and permitting, including varied post-closure uses for landfills such as solar, Ameresco has extensive experience with renewable energy to provide comprehensive turnkey services from electrical design to managing the interconnect to the grid to negotiating the purchase agreements for the sale of power to utilities. The teaming relationship is vital to executing successful projects from feasibility study to design, all the way to completion.
“Ameresco is a very big player in energy, and we are large in the landfill engineering space. Both companies have offices nationwide. We work on over one-third of the landfills in the United States. Together, we have an expansive reach and breadth of experience in every essential competency to offer successful solar projects on closed landfills,” Kalish says.
Solar Energy on Brownfields and Closed Landfills
When excess food at any stage of the food system can’t be diverted to people in need, the next best option is to feed it to animals. Even with the best systems in place to develop an efficient food system, there will always be some fraction that is not fit for consumption. This material should be recycled and reused to minimize the environmental burden and allow for recovery of part of the resources initially used in its production, processing and transport, creating a more circular food system.
In a circular system, food waste is recycled by treatment to stabilize it, anaerobic digestion and composting are common food waste treatment technologies used to stabilize waste and produce residual materials that can replenish the soil, thus contributing to a circular food system. While a circular system uses resources more efficiently, the approach is not without risk. The authors of this paper investigated heavy metals, halogenated organic compounds, foodborne pathogens and antibiotic resistance genes (ARGs) in the food system and their fates during digestion and composting.
While not impossible to mitigate, design, planning, and waste characterization play tremendous roles in sustainable systems.
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SCS Engineers announces its iOS and Android application SCS WDT™ for wireless data transfer of landfill flare readings to mobile devices. The app expands the power of SCS MobileTools® to observe system and environmental activity securely and in real-time.
Today’s landfill gas flares collect data using a Supervisory Control and Data Acquisition (SCADA) system. The flare’s SCADA system records data at preset intervals generating hundreds of thousands of readings to process and analyze. Often data is stored on a data card at the flare site. A technician collects the data by transcribing it into a log or digitally reading it, then transferring the reading to a computer. The data is then uploaded into the landfill’s database for analysis and reporting.
The process, with its multiple steps, is slow and open to human error. SCS WDT™ digitally collects flare readings directly into a mobile device and into SCS DataServices® in seconds, reducing human error and multiple steps. The app’s interface provides secure access to information that drives critical operating decisions and collects historical data for trends, corporate directives, and landfill gas OM&M programs.
Landfill managers and environmental engineers can monitor their flares in real-time, seeing exceedances immediately. SCS WDT™ uses GPS to capture the exact physical location of flares and place the data into the appropriate landfill’s site location too. Flare readings are available, literally in seconds, for review, analysis, and corrective action if needed. Pilot testing at 30 landfills nationwide demonstrates that SCS WDT™ saves time and errors by removing extra steps and people in the progression; there is no need to wait until the end of a technician’s shift to transfer readings or have extra hands in the process.
SCS DataServices®, a secure web-based landfill gas management application, is part of the SCSeTools® platform in use on hundreds of landfills backed by over 50 years of landfill design, operation, and maintenance experience. SCS Engineers understands how unique landfill operations are today, so SCS WDT™ works as a standalone app with other platforms and is free to SCSeTools® users. Download on the Apple App Store for iPhones and iPads, Google Play for Android.
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. For additional information and demonstrations of these productivity-enhancing tools, please click here.
