SCS periodically prepares Technical Bulletins to highlight items of interest to our clients and friends who have signed up to receive them. We also publish these on our website at https://www.scsengineers.com/publications/technical-bulletins/.
Our most recent Bulletin entitled EPA Seeks Feedback On Inactive Surface Impoundments at Inactive Electric Utilities summarizes the EPA’s request for comments and information pertaining to inactive impoundments at inactive facilities.
Operators and owners who may be affected by forthcoming decisions around inactive CCR surface impoundments include electric utilities and independent power producers who generate CCR within the North American Industry Classification System (NAICS) code 221112. Though the EPA states “other types of entities … could also be regulated” and advises those wanting to confirm if the regulation applies to them to read the applicability criteria and comment. Landowners with a legacy surface impoundment on their property purchased from a utility will want to review the proposed definitions closely.
SCS Engineers will continue to post timely information, resources, and presentations to keep you well informed. These include additional guidance, industry reaction, and webinars for our clients.
Visit our website for more information.
SCS Engineers announces Brittney Odom’s promotion to the Southeast region’s Environmental Services Director. Odom will continue expanding and integrating SCS’s environmental engineering and consulting operations to provide more streamlined and efficient services in her new role. She will lead environmental operations in Alabama, Florida, Mississippi, Georgia, and the Caribbean. As with all SCS leaders, she continues serving her clients in Boca Raton in her expanded role.
Odom supports real estate developers, municipalities, banks, and insurance firms to identify properties’ environmental conditions. Next, depending on soil, water, and geotechnical testing determines the appropriate environmental due diligence and the engineering activities necessary to redevelop them and be in 100% compliance with local and federal rules.
There is an active push to develop more affordable residential housing in the U.S. Real estate developers and residents want to be close to business and transportation hubs, but potential development sites could require remediation. Once agricultural sites, golf courses, or at one-time housing industrial operations, these properties need environmental testing, due diligence, possibly remediation, or vapor intrusion barriers to ensure the safe redevelopment. No matter the condition, properties with a past can return to pristine condition and make desirable residential and mixed housing locations, supporting economic development.
“It’s important to know and understand all of the options ahead of time to keep costs down and environmental quality up for sustainable communities,” stated Odem. “You need to reassure all parties that there is no leaking storage tank or anything that could compromise health.”
Her focus recently is on the redevelopment of large-size properties contaminated with arsenic and other legally applied pesticides. These property types include golf courses and agricultural land that have become inactive but are in high demand for residential use. These projects may need soil management, including remediation, soil blending, and placement restrictions.
Odom has years of experience conducting environmental site assessments, overseeing remediation activities, and submitting regulatory reports, including Phase I & II assessments in Florida, Tennessee, Louisiana, Texas, and the Caribbean. These focus on gas station properties and bulk storage terminals for large oil companies, often located on prime waterfront sites.
Additional highlights in Odom’s professional career include expertise in the applicable Florida Regulatory Chapters and Standard Operating Procedures. She also has experience in state and international cleanup efforts and their associated regulatory procedures. She participated in successful environmental closure efforts, with imposed engineering controls and property restrictions.
Odom has ten years of experience managing subsurface investigation and conducting oversight during remedial activities, including source removal and remediation system installation. She holds certifications in 40-Hour HAZWOPER/OSHA training, Loss Prevention System, CPR, RCRA Hazardous Waste, DOT Hazardous Waste, and American Petroleum Institute certification.
“Brittney’s breadth of experience solving the complexities of large scale redevelopment while meeting all environmental regulatory compliance enables her to innovative better solutions,” said Carlo Lebron, SCS vice president and director of SCS’s Southeast operations. “She’s an expert, with access to our deep bench of engineers, scientists, technology, and even economists within SCS.”
SCS Engineers now provides the Augusta Environmental Services Department with engineering, environmental and testing, and Construction Management & Quality Assurance Services at the Deans Bridge Road Landfill, in Blythe, Georgia. The facility operates under the State of Georgia Environmental Protection Division as a Subtitle D Landfill, accepting up to 1,500 tons per day of waste. Active and closed sections of the landfill comprise approximately 1,177 acres of property. Some additional acreage contains ancillary facilities such as office and maintenance buildings, customer drop off area, sediment ponds, roads, and leachate holding facilities. The Augusta Department of Environmental Services is responsible for the landfill facilities, solid waste management planning for Augusta, and all residential solid waste collections. Additionally, the Department is responsible for the Augusta Brownfield program and other environmental compliance issues.
Landfills are carefully engineered facilities closely regulated and monitored to ensure they have the protections necessary to prevent contamination of groundwater, air, and adjoining land. Best landfill management practices include collecting and treating leachate – the water that passes through a landfill. The methane gas naturally produced from decomposing landfill waste is collected and converted into various forms of energy – including compressed natural gas. This alternative fuel powers Augusta Solid Waste trucks or is a substitute for pipeline natural gas.
The Department consolidated all landfill services assigning them to SCS Engineers, a professional environmental consulting firm with over 50 years of experience in performing landfill site acceptability studies, landfill design services, landfill environmental compliance activities. The firm was already engaged in the Landfill’s Gas Collection and Control System (GCCS) expansion. The consolidation of services provides a more cost-effective approach for permitting, design, operations, monitoring, and maintenance. The comprehensive SCS team is a uniquely qualified and experienced full-service consulting and engineering team with demonstrated relevant field experience in Georgia. Leading the team is Sowmya Bulusu, a Georgia Professional Engineer, with over 12 years of landfill engineering performed in accordance with the Environmental Protection Division (EPD) of the Georgia Department of Natural Resources, the Georgia Solid waste management Act, and other applicable federal, state, and local rules and regulations. As the Project Director, Carlo Lebron is a registered Georgia Professional Engineer for 15 years bringing over 21 years of experience on over one hundred solid waste projects.
“The SCS team brought the five-year permit review submittal package in early, giving Georgia’s Environmental Protection Division plenty of time to deem it administratively complete,” stated Sowmya Bulusu. “Working with our field technicians, we quickly identified and brought at-risk gas wells into compliance, used our drones to provide an aerial survey of the entire landfill, saving Department funds.”
SCS Engineers’ environmental solutions directly result from our experience and dedication to solid waste management and other industries responsible for safeguarding the environment. Click for more information about comprehensive landfill services.
From SWANA’s Executive Summary
A new report developed by the SWANA Applied Research Foundation (ARF) addresses two important questions associated with municipal solid waste (MSW) at landfills.
What tasks will be required to manage closed landfills following the post-closure care period to ensure continued protection of public health and the environment?
How will those associated costs be paid for?
Subtitle D regulations require that the post-closure care period is maintained and the environmental protection systems are managed and monitored—it should be 30 years in length, but the period is determined by the state regulatory agency that issued the landfill permit. Once the post-closure period ends, the closed landfill enters into a new status, which SWANA defines as the “Long-Term Management,” or LTM period. EPA’s Subtitle D regulations don’t address monitoring and maintenance activities required during this period.
Based on the ARF’s research, the new report offers conclusions regarding the long-term management of MSW landfills during the LTM period. Some include best practices, but ARF also had some interesting conclusions related to final cover geomembranes and looking to landfills as longer-term assets.
The full report, The Long-Term Management of Closed MSW Landfills Following the Post-Closure Care Period, is currently available only to SWANA ARF subscribers. SWANA members receive free access to ARF industry reports one year after publication.
Contact your SCS Engineers Project Manager or local office for information on best practices.
SCS Engineers is a leading environmental consulting and contracting firm with over 50 years of expertise in designing, permitting, constructing, and operating landfills. The firm is a pioneering force in developing landfill design technologies in use today by most landfill designers in the United States and internationally. Dr. Khatami describes several of the more prominent of these technologies below.
Landfills without Terraces
SCS is one of the first landfill designers to develop the concept of straight-up 3:1 slopes for landfills with no terraces. The modern version of tack-on swales (also known as tack-on berms) for control of surface water runoff came about along with this concept. This technology simplified waste filling operations for landfill operators and added significant additional airspace to landfill facilities. This concept’s financial benefits for SCS’s clients over the past three decades exceed one billion dollars.
Pipe Downchutes
SCS developed the single-barrel downchute and double-barrel downchute systems combined with the tack-on swales for landfill slopes during final cover installation. SCS has been designing and constructing these systems since the early 1990s, and none of the constructed systems have experienced failure. System performance for such a long time is a clear indication of the design’s suitability in combination with the tack-on swales. These concepts eliminate numerous problems that arise with open surface downchutes and other downchute systems combined with terraces on landfill slopes. The construction simplicity and rapid system installation make them the most useful systems for our clients.
Leachate Toe Drain System
SCS was the first landfill designer that developed the concept of a toe drain to collect and properly dispose of leachate seeps below the final cover geomembrane. SCS coined the term leachate toe drain system or LTDS for standardizing the design over 20 years ago. The LTDS is currently an essential component of all landfill designs that experience leachate seeps on exterior slopes, and landfill designers are catching up with the concept.
Rainwater Toe Drain System
SCS was a pioneering landfill designer in developing the proper means for collecting and removing water from the final cover drainage layer located above the final cover geomembrane. SCS coined the term rainwater toe drain system, or RTDS, to standardize the design over 20 years ago. The RTDS concept is currently an integrated component of all closure projects designed and constructed by SCS and many other landfill designers.
Sustainable Landfill Design Concepts
SCS revolutionized the landfill base grades design by developing the Landfill Green Design concept over two decades ago. Many regional landfill owners welcomed the concept and its numerous benefits, including savings in construction material and increasing airspace, to name a few. Introducing the second generation of the landfill green design within a few years, SCS addressed solid waste rules in several states. The improvements apply to very long disposal cells, minimum slope values for the leachate collection pipes, and minimum slope for a disposal cell’s base area. Coining the second generation design a Landfill Green-H Design, with “H” for hybrid, SCS reflects the combination of the landfill green design concept and the traditional herringbone concept. Readers of the SCS Advice from the Field blog can look forward to an upcoming blog on the term herringbone soon!
Over the past two decades, SCS has increased the airspace of many large regional landfills by modifying their solid waste permits incorporating the first and second generations of these concepts. The savings in construction material for these facilities exceeds $130,000,000, and the added financial benefit related to extra airspace is nearly $300,000,000. These SCS design concepts not only reduce construction costs and increase landfill airspace; they also have other sustainable benefits that landfill owners and operators value to help meet their sustainability goals.
The third generation of SCS’s Landfill Green Design is now available. Landfill Green+ Design provides its predecessors’ benefits with a higher degree of sustainability to our clients.
Tiered Vertical Gas Wells
SCS developed the concept and coined Tiered Vertical Gas Well, or TVGW, for the largest waste operator in the world as part of the developing standards for preventing elevated temperature conditions forming in deep and wet landfills. TVGWs collect landfill gas from the entire vertical column of waste from the bottom lining system to the final cover system. SCS developed additional concepts for horizontal blankets and fingers around the TVGWs to improve gas collection and rapid vertical movement of leachate through the vertical column of waste, allowing leachate to migrate vertically down to the leachate collection system rapidly. TVGWs have been a necessary component of new disposal cell construction at deep and wet landfills since their introduction to the industry.
Recently, SCS developed the second generation of TVGWs, known at SCS as TVGW+. TVGW+ simplifies the construction of intermediary pads and improves the connection of the pads to the vertical wells. Horizontal blanks and fingers can integrate easily into the TVGW+.
Gas Release System at Lining System
SCS developed the concept and coined the term Gas Release System (GRS) for the largest waste operator in the world as a part of the developing standards for preventing the formation of elevated temperature conditions in deep and wet landfills. The GRS releases high-pressure landfill gas near the bottom of the landfill. Excessive pressure can adversely impact leachate flow within the geocomposite drainage layer above the lining system geomembrane. Landfill owners and operators can apply the GRS concept to non-wet or shallow landfills as long as gas pressure near the bottom lining system is an issue.
Clog-Free Leachate Collection Pipe System
Over five years ago, SCS developed a design for leachate collection pipes without geotextile, which is a primary source of clogging in the vicinity of leachate collection pipes. SCS coined the term Clog-Free LCS Pipe or CFPIPE to standardize the design. Leachate from the geosynthetic drainage layer flows directly into the gravel around the LCS pipe and then into the pipe without passing through a geotextile. Since its introduction to the industry, SCS incorporates the CFPIPE into the design of landfills requested by clients looking for sustainable and clog-free systems.
Superior Ranking
The development of these technologies and many other SCS Firsts illustrates the value that the combination of our engineers, consultants, field staff, and scientists brings to each client. Our landfill designers work in combination with other highly sophisticated landfill related technologies developed by SCS, such as landfill gas systems, renewable energy systems, SCS RMC® remote monitoring and control, SCS eTools® for data management and decision making, and stellar operation and maintenance services.
As environmental industry pioneers, we never stop striving to be the most valuable landfill full-service provider. We highlight industry Firsts on our website just beneath the photo headlines.
FREE ON-DEMAND WEBINAR & Q/A – RECORDED JAN.21, 2021
Landfills, compost facilities, transfer stations, and renewable energy plants are cognizant of odor issues and strive to minimize odors. Proactive odor management is critical to the continued success and operation of these facilities.
More so than ever before, the solid waste industry faces complex and challenging odor issues based upon public, regulatory, and legal actions. Since odors are generally enforced through nuisance regulations, compliance can be difficult to achieve, not to mention almost impossible to define. Enforcement of odor nuisances is subjective, usually at the discretion of an environmental inspector or Air Pollution Control Officer, and often based upon citizen complaints. When citizen complaints mount, and enforcement action is leveraged, lawsuits often surface as an added ongoing challenge to waste facility operations. Now politicians are demanding action and using alleged odor violations as part of their environmental platforms. Facing odor issues can be costly and threaten the intended land-use designs that waste facilities require to serve their local communities.
SCS Engineers’ January webinar was for those who want 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.
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.
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 .
As large tracts of geographically desirable vacant land become scarcer, residential and commercial property developers are increasingly turning to old landfills or former dumps. However, such redevelopment is complex and rife with uncertainties. When compared to greenfield development, the land acquisition costs are lower. Still, any savings are typically offset by greater environmental and infrastructure costs associated with the foundation, landfill gas management, stormwater management, groundwater impacts, meeting closure requirements, and multiple regulatory agency coordination. Therefore, it is important to maximize the developable area while providing engineering solutions to make the project economically feasible. In this blog, we identify some options to reuse challenging sites and lessons learned to contribute to successful redevelopment projects.
Deep Dynamic Compaction
Old landfills or dumps present some unique soil stability challenges. Deep dynamic compaction (DDC) is a ground stabilization technique that has gained popularity in recent years to improve subsurface soil conditions. DDC involves dropping 6 to 30-ton weights from a height between 30 and 75 feet to achieve the desired soil compaction. DDC can effectively apply to a range of subsurface materials, including former C&D debris or municipal solid waste dumps.
DDC provides a stable foundation for future development, minimizes differential settlement while leaving the landfill waste in place, and eliminates the costs associated with removing, transporting, and disposing of buried waste, costing millions of dollars. For simplicity’s sake, let’s consider a 1-acre old landfill or a dumpsite with an average of 15 feet of waste. If excavating the waste and replacing it with clean fill, the disposal fee costs for the excavated waste alone could exceed $400,000. Alternatively, DDC costs range from $1.50 to $2.00 per square foot or $65,000 to $87,120 per acre, excluding mobilization, which costs around $30,000.
Gas Mitigation Systems
Constructing buildings on top of dynamically compacted areas generally requires a combustible gas barrier layer below the building foundation to manage subsurface combustible gases (typically methane). The barrier is required because the waste remains in place. In its simplified form, gas mitigation systems include:
These gas mitigation systems can be either a passive or an active system with a blower. The cost of such systems varies depending on the size of the building, location, and type of liner system used. Typical capital costs for passive systems are in the range of $7 to $9 per square foot for the spray-applied liner and $3 to $4 per square foot for the HDPE liner. For an active system using blowers, add $3 to $4 per square foot. The designer configures a system from these options to address the client’s risk preference and considering future tenant preferences.
Using innovative approaches, impaired lands are increasingly attractive to developers. Beyond the cost-saving benefits to developers realized through DDC and an appropriate gas mitigation system, such projects also create local jobs, increase the tax base, and protect public health and the environment.
About the Authors:
Somshekhar Kundral – Mr. Kundralis, PE, is a Senior Project Manager with over 12 years of broad and diverse environmental engineering experience that includes projects in landfill redevelopment, landfill gas management system design, site assessment, groundwater remediation system design, stormwater management, and injection well system construction. Som is experienced with site permitting, compliance reporting and construction administration services, and remediation systems’ operation and management.
