SWANA’s new online testing platform gives members and industry professionals easy access to SWANA’s leading certification courses and exams.
The online testing platform has many benefits:
“The SWANA platform provides students the opportunity to read through the content and take their time preparing for exams; a valuable part of the learning process,” said Tracie Bills, SWANA/CRRA Zero Waste Course Instructor and Northern California Director at SCS Engineers.
On December 15, 2017, David Biderman, Executive Director and CEO of The Solid Waste Association of North America (SWANA) released comments in response to the Ministry of Environmental Protection (MEP) of the People’s Republic of China’s November 15, 2017, Notifications to the World Trade Organization (WTO) concerning restrictions on the import of solid waste.
We thank SWANA and Mr. Biderman for authorizing SCS Engineers to publish the comments for the benefit of all industry stakeholders and encourage you to share the letter.
Share this post using the icons at left, or download the SWANA letter using the button just under the letter window. SCS Engineers does not collect or share your contact information.
SWANA_Environmental_-Protection_Control_Standard_for_Imported_Solid_Wastes_as_Raw_Materials
SCS Engineers will continue to publish articles, white papers, and blogs pertaining to this and other relevant issues on our website. You are welcome to contact us if you are looking for specific information on technical and business issues that concern you.
SCS Engineers is a proud supporter of the SWANA Evergreen Chapter. the Chapter offers an annual scholarship to qualified undergraduate and graduate students in honor of Deborah Lambert. Ms Lambert was the SWANA Evergreen Chapter President 2002-2005, and we honor her for the many years she dedicated to the solid waste management field.
Please join us for our Winterfest Annual Holiday Party, which will be held today from 4:30 to 8:30 PM at the Bellevue Club, 11200 SE 6th Street, Bellevue, WA 98004. Enjoy fabulous food with friends and colleagues at the beautiful and festive Bellevue Club, the perfect way to start the holiday season! In addition to being a fun holiday event, Winterfest is our primary fundraising opportunity for our Educational Scholarship Fund.
Bellevue Club
11200 SE 6th Street
Olympic Suite A
Bellevue, WA 98004
These guys don’t want to miss Resource Management and Waste Diversion: Evaluating the Impact on Waste Management caused by the Changing Waste Stream Composition at WasteCon/ISWA 2017.
Solid waste management, and in particular sanitary landfilling, is being impacted by the waste composition evolution. One notable change is an overall decrease in tonnage. Reasons for the reduced quantity may be attributed to factors such as increased diversion of recyclables, increased diversion of vegetative organics, evolving diversion of food waste, changes to packaging, expansion of fresh organic foods lifestyle, expansion of fitness lifestyles, as well as other generational life choices.
Learn more about this topic and many others at the ISWA/WasteCon conference in Baltimore, MD.
Reprinted from SWANA Alert:
On Tuesday, August 1, the U.S. Environmental Protection Agency (EPA) will be holding a public hearing in Washington, DC on the proposed rule, ‘‘Renewable Fuel Standard Program: Standards for 2018 and Biomass-Based Diesel Volume for 2019.’’ In keeping with SWANA’s previous advocacy efforts in regards to the renewable fuel standard (RFS) program, we intend to submit a short written statement to be introduced into the hearing record.
The RFS program is a national policy that requires a certain volume of renewable fuel to replace or reduce the quantity of petroleum-based transportation fuel, heating oil or jet fuel. These amounts are set by EPA each year and the proposed rule will set those levels for 2018. One of the four fuel category amounts that will be set by the RFS is cellulosic biofuels, which includes compressed and liquefied renewable natural gas (RNG) produced from landfill biogas.
As a member of the SWANA Core Advocacy Group, we are notifying you that SWANA intends to submit comments to EPA on the RFS program as part of the August 1st hearing, and in post-hearing comments that EPA will be accepting through August 31st as necessary. These comments will support the testimony of other solid waste industry leaders and ask the EPA set the 2018 RVO standard for cellulosic biofuel at a level that takes into account increased generation of fuel from both existing registered projects and from new projects that will begin generating fuel in 2018. By setting the levels based upon actual current and future capacity instead of on historical data and trends, EPA will ensure that the levels set actually spur demand consistent with increased production. A failure to set the levels high enough would result in a lack of appropriate demand for these fuels, which would undercut the purpose of the RFS program
By setting the levels based upon actual current and future capacity instead of on historical data and trends, EPA will ensure that the levels set actually spur demand consistent with increased production. A failure to set the levels high enough would result in a lack of appropriate demand for these fuels, which would undercut the purpose of the RFS program.
If you or the Chapter or Technical Division members have any questions or concerns about these comments, or if you would like to discuss them further, please contact David Biderman at SWANA.
EPA is proposing a GHG SER of 75,000 tons per year (tpy) Carbon Dioxide equivalent (CO2e) and requesting comment on it as well as two lower levels, specifically 30,000 tpy and 45,000 tpy CO2e, respectively.
The Associations do not believe there is sufficient information to support lowering the GHG SER below the proposed 75,000 tpy CO2e level and provided a table utilizing equivalent criteria pollutants from combustion sources (i.e., NOx, CO) yields CO2 emissions as high as 780,000 tpy CO2.
EPA already concluded in USEPA, Proposed PSD Revisions Rule, 81 FR 68137 that the burdens of regulation at a GHG SER level between 30,000 and 75,000 tpy CO2e would yield a gain of trivial or no value from both a programmatic and individual project-level perspective. Therefore, NWRA and SWANA strongly recommend EPA retain proposed GHG SER of 75,000 CO2e (or higher), and resist pressure to lower the GHG SER.
On the Topic of Biogenic GHG Emissions, the EPA’s final rule requires clarification to remain consistent with previous documentation and research to prevent significant permitting delays and increased costs that will not result in meaningful emission reductions.
The Associations encourage the EPA to ensure that waste-derived biogenic CO2 (e.g., from municipal solid waste (MSW) landfills) is treated as carbon neutral under the final PSD Permitting Revisions Rule to be consistent with prior Agency determinations specified in this memorandum and documents as follows:S. EPA, Memorandum Addressing Biogenic Carbon Dioxide Emissions from Stationary Sources, McCabe, Janet, November 19, 2014.
S. EPA, Memorandum Addressing Biogenic Carbon Dioxide Emissions from Stationary Sources, McCabe, Janet, November 19, 2014. The documents highlight waste-derived, biogenic CO2 as a type of “carbon neutral” feedstock based on the conclusions supported by a variety of technical studies and conclusions of the Agency’s latest draft Framework for Assessing Biogenic Carbon Dioxide for Stationary Sources, which was released with the memo. The Agency memo stated that “the Agency expects to recognize the biogenic CO2 emissions and climate policy benefits of such feedstocks in [the] implementation of the CPP.”
US EPA, Emission Guidelines for EGUs, 80 FR 64855. Both the revised Framework, and the EPA’s Scientific Advisory Board (SAB) peer review of the 2011 Draft Framework, found “that the use of biomass feedstocks derived from the decomposition of biogenic waste in landfills, compost facilities, or anaerobic digesters did not constitute a net contribution of biogenic CO2 emissions to the atmosphere.”
S. EPA, Appendix N. of Revised Framework for Assessing biogenic Carbon Dioxide for Stationary Sources, November 2014, pg. N-25. In Appendix N. of the Framework, entitled Emissions from Waste-Derived Biogenic Feedstocks, EPA calculated negative Biogenic Accounting Factors (BAF) for various examples of treatment of landfill gas via collection and combustion. EPA explains, “Negative BAF values indicate that combustion of collected landfill gas feedstock by a stationary source results in a net CO2e emissions reduction relative to releasing collected gas without treatment.”
US EPA, Carbon Pollution Emission Guidelines for Existing Stationary Sources: Electric Generating Units; Final Rule [Emission Guidelines for EGUs], 80 FR 64885. “[T]he use of some biomass-derived fuels can play a role in controlling increases of [in] CO2 levels in the atmosph The use of some kinds of biomass has the potential to offer a wide range of environmental benefits, including carbon benefits.”
US EPA, Emission Guidelines for EGUs, 80 FR 94855. Types of waste-derived biogenic feedstocks may include: landfill gas generated through decomposition of MSW [municipal solid waste] in a landfill; biogas generated from the decomposition of livestock waste, biogenic MSW, and/or other food waste in an anaerobic digester; biogas generated through the treatment of waste water, due to the anaerobic decomposition of biological materials; livestock waste; and the biogenic fraction of MSW at waste-to-energy facilities.
NWRA and SWANA believe the final PSD Revisions document should follow the approach to waste-derived feedstocks enshrined in the Final Clean Power Plan, and as recommended by the SAB, and ensure that waste-derived biogenic CO2 is treated as carbon neutral. Based on EPA’s own lifecycle assessments for the Renewable Fuels Standard program, its U.S. GHG Inventory, and confirmed by the SAB, EPA has sufficient analysis to support exclusion of selected categories of biogenic emissions from PSD permitting, including those from managing landfill gas and organic components of MSW.
The EPA does not seem to consider the regulatory treatment of biogenic CO2 from stationary sources to be a key issue in the context of the PSD revisions rule, based on a comment found in a Summary of Interagency Working Comments on Draft Language. Instead, the EPA continues to believe this rulemaking to establish a GHG SER under the PSD program is not the appropriate venue to address the broader concern of the regulatory treatment of biogenic CO2 from stationary sources.
The Associations strongly disagree and are concerned that because EPA remains silent on this important issue, some permitting authorities might improperly require landfills to incorporate biogenic CO2 emissions in the PSD permitting process. Historically, few landfills triggered PSD because non-methane organics emissions rarely reached the threshold. However, if biogenic CO2 emissions become subject to PSD, many landfill projects, which are “anyway sources” due to renewable energy projects, would also be forced to do BACT analysis for GHG. Biogenic CO2 is emitted from:
From the perspective of developing new renewable transportation fuel or energy projects, subjecting biogenic emissions from landfills to PSD could be an enormous barrier. The Associations would like the EPA to clarify in its final rule that the emissions of biogenic CO2 from treating or controlling landfill gas does not increase the CO2 levels in the atmosphere, but instead, has positive emission reduction and climate benefits. Failing to clarify this important point could subject landfills to significant permitting delays and increased costs that will result in no meaningful emission reductions.
Questions? Contact SWANA, NWRA, Patrick Sullivan, or your local SCS office.
Construction and Demolition Recycling Inc. is a California state certified C&D recycling facility which handles debris from the renovation, construction, and demolition of commercial interior spaces. CDR is the only facility in California that accepts only commercial interior debris, and the only facility in the country that can show a better than 80% diversion rate of these materials traditionally buried in landfills.
CDR’s staff also salvages usable items such as furniture, desks, chairs, file cabinets, and more, for reuse, donating more than 50 tons of these materials every month to not-for-profit agencies and other organizations. All of this allows CDR to divert over 80% of all inbound debris from landfills, a diversion rate that has been third party-verified by the Recycling Certification Institute.
The CDR facility in South Gate, California is a fully permitted C&D/inert debris processing and transfer facility. The facility is owned and operated by Interior Removal Specialist, Inc. (IRS), a demolition company that conducts demolition activities primarily of the interior of offices and other commercial buildings. Construction and Demolition Recycling Incorporated’s goal is to lead by example; showing that the diversion of tenant improvement demolition debris can be accomplished as efficiently and cost effectively as the debris from more traditionally recognized demolition debris. CDR has become the first and so far only recycling facility in Southern California that has earned Third Party Diversion Certification from The Recycling Certification Institute, making CDR the only facility in Southern California that is eligible to provide the US Green Building Council LEED Pilot Point for facilities with 3rd party verification.
Read the full article to learn some of the innovative strategies of this successful recycling company in “Construction and Demolition Debris Recycling Program; How CDR was Conceived and How CDR Remains Sustainable.”
Solid Waste Management, Sustainability, and Recycling Programs
On June 1, 2016, the National Waste & Recycling Association (NWRA), the Solid Waste Association of North America (SWANA), and the Coalition for Renewable Natural Gas (RNG Coalition) provide comments on Pipeline Safety: Safety of Gas Transmission and Gathering Pipelines (FR20722) proposed rules to Mr. Mike Israni, Deputy Associate Administrator for Pipeline Safety – Field Operations at U.S. Department of Transportation. Comments by the three not-for-profits were made on behalf of the solid waste industry including companies, municipalities, and professionals.
The letter reflected the solid waste industry support for the efforts made by the Pipeline and Hazardous Materials Safety Administration (PHMSA) to ensure pipeline safety and included comments on the Advance Notice of Proposed Rulemaking, (ANPRM) as follows:
The revised definition for gathering line (onshore) as the basis for determining the beginning and endpoints of each gathering line requires further clarification. The definition remains too broad for applications that do not have the same level of risks since they are not accessible to the public.
PHMSA has elected not to propose rulemaking for landfill gas systems. However, it notes that pipelines that transport landfill gas away from the landfill to another facility are transporting gas and that PHMSA may consider this in the future.
The associations pointed out that the same rulemaking for landfill gas systems should apply to all forms of biogas that are collected and managed in a similar manner to landfill gas. Also noted was that low-pressure gas lines delivering biogas off-site to a dedicated end user need not be considered for further regulation as they do not present the same level of risk that natural gas or other high-pressure gas lines do. Landfill gas/biogas systems fall under federal, state and local regulators. Because landfill gas/biogas systems are regularly inspected for safety, generally use plastic piping, and do not present a substantial risk to the public the Associations feel that it is not necessary to consider additional regulation.
Contact NWRA, SWANA, RNG Coalition or SCS Engineers for more information.
The Solid Waste Association of North America (SWANA) Applied Research Foundation released a report concluding that: a significant amount of additional food waste processing capacity will be required to achieve national, state, provincial, and local food waste diversion goals. The report also emphasizes the need for local decision-making in selecting and implementing those food waste diversion programs.
…a significant amount of additional food waste processing capacity will be required to achieve national, state, provincial, and local food waste diversion goals. The report also emphasizes the need for local decision-making in selecting and implementing those food waste diversion programs.
The report goes on to say that interest in recovering food waste from municipal solid waste is growing to meet goals established by the U.S. Environmental Protection Agency and U.S. Department of Agriculture, but many major metropolitan areas lack the infrastructure to manage the ability to meet the established goals. Two examples were cited:
Several states, including Massachusetts and Connecticut, condition their food waste diversion requirements on the ability of generators to access adequate capacity within a certain distance.
Speaking as SWANA’s Executive Director and CEO David Biderman stated:
We believe that Americans need to rethink how food is handled before it is considered waste, to divert it into programs to feed people, and to find other productive uses for food as food. Once it becomes waste, however, municipal decision-makers, working with their processing partners, need to determine how to best manage the material.
The SWANA report focuses on the effects of food recovery at the two lowest tiers of the hierarchy – composting and landfilling/incineration. The report concludes that food waste diverted from landfill operations has the potential to be processed at composting facilities. Then, going on to say that anaerobic digestion (AD) and co-digestion at wastewater treatment facilities are also likely destinations for diverted food waste.
Jeremy O’Brien, Director of the Applied Research Foundation, noted:
The food recovery hierarchy does not apply universally; an analysis of greenhouse gas impacts based on local data and conditions is needed to identify the best food scraps management options for a specific community.
The report encourages solid waste managers to perform a life cycle analysis of economic and environmental costs and benefits based on local needs, system capabilities, and data to identify the most effective ways to manage food waste at the local level.
SCS Engineers and SWANA are both long-time advocates for local decision-making in establishing programs to collect and manage municipal solid waste.
Related articles:
The National Waste & Recycling Association (NWRA) and the Solid Waste Association of North America (SWANA) returned comments and recommendations on the Environmental Protection Agency’s (EPA) draft Part 71 Operating Permit for Ocean County Landfill and MRPC Holdings LFGTE Operations, Permit Number: P71-0CMH-001 (Draft Permit) to EPA Region 2 Permitting Section, Air Programs Branch. The letter was sent on January 28, 2016, to Mr. Steven C. Riva of the EPA.
NWRA and SWANA expressed concerned that the EPA’s issuance of the Draft Permit, and the circumstances under which it has been prepared, represent a significant departure from practical permitting policies and will constitute a disincentive to expand existing and develop future landfill gas-to-energy (LFGTE) projects around the country.
The jointly submitted comments from both not-for-profit Associations on the Draft Permit were intended to convey their members’ strong interest in these projects, which represent an economic investment in alternative renewable energy sources and the reduction in greenhouse gas (GHG) emissions. Both Groups have expressed concern that the EPA’s actions should not undermine those investments and the benefits derived from these LFGTE projects.
The main points of the letter cover the Associations’ disagreement with the EPA’s approach to common control. NWRA and SWANA support the position that the OCL and MRPC are two separate sources that are not under common control, and they oppose the position proposed by EPA Region 2 in the Draft Permit. Both Groups are urging EPA to re-evaluate this decision and utilize an environmentally beneficial approach when making common control determinations for landfills and third-party LFGTE plants both now and in the future. Other portions of the letter address the uncertainty that EPA’s position would create for affected facilities and how it could re-open already settled compliance expectations.
Members of NWRA and SWANA have access to the letter and may continue directing comments and questions through either Association.
Questions directed to SCS Engineers should be addressed to Pat Sullivan, Senior Vice President and the SCS National Expert on the Clean Air Act.
Learn more about SCS Clean Air Act Services, or Greenhouse Gas Services, or
Landfill Gas to Energy Services
