compliance

May 2, 2016

 

No matter where the real property is located you may need a vapor intrusion pathway screening.

 

If you are buying or selling a property with a history of soil or groundwater contamination in Wisconsin, the state’s Department of Natural Resources requires vapor intrusion pathway screening. The screening is also necessary when buying or selling a property adjacent to a property with soil or groundwater contamination. Is this analysis necessary?

The screening is essential; vapors from contaminated soil or groundwater may transfer to indoor air, causing health risks. The vapors may or may not have an odor. Screen testing and analysis will determine their existence and the level of concentration. Most commonly levels are low, and no additional action is necessary. If beyond the threshold determined safe by your state, some mitigation may be required before purchase.

It is not a simple matter to apply an individual state’s current regulatory guidance to determine the need for vapor intrusion mitigation. The actual intrusion, or expected intrusion in the case of new buildings, is often overstated, and some regulatory agencies use screening values for indoor air chemical concentrations that are at or below levels commonly found in buildings. The slightest error in sampling technique can dramatically affect the resulting data.

SCS offers the full array of vapor intrusion services for residential, commercial, and industrial properties, and for developers, municipalities, lenders, attorneys, industrial facilities, tenants, landlords, and buyers and sellers of real property.

Contact SCS at 1-800-767-4727 or email us at .

Question about  this blog, please email one of the authors  Robert Langdon and Thomas Karwoski.

SCS has offices nationwide to serve our customers. To learn more about vapor mitigation, please visit the SCS website here: https://www.scsengineers.com/services/hazardous-waste-and-superfund/vapor-intrusion-mitigation-systems.

Posted by Diane Samuels at 6:00 am

April 28, 2016

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.

Food Recovery Hierarchy courtesy of www.epa.gov/sustainable-management-food page
Food Recovery Hierarchy courtesy of the EPA

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:

 

Posted by Diane Samuels at 6:00 pm

March 4, 2016

Who needs to comply with California’s Industrial General Permit for storm water?

 

This workshop was insightful, tightly constructed, and – most impressive – able to deliver high quality information that businesses can use immediately. I have been to hundreds of business workshops where companies feel drowned in the amount of expert information coming at them. Not so at this concise, one-hour workshop where businesses clearly understood the next steps they should take and where they can find resources to help them proceed.

Jo Marie Diamond, President and CEO, East County Economic Development Authority after attending the SCS seminar in San Diego, CA. on March 1, 2016.

 

SCS Engineers staff professionals are available to answer questions about compliance and the proposed fee schedule changes for attendees and any business unsure about the storm water permit. We can help clarify questions such as:

  • Who needs to comply, including the required list of Standard Industry Classification (SIC) codes, which includes many businesses you would not suspect! List of businesses affected here.
  • Compliance basics – How and what to file
  • Can I get out of the permit?
  • Are there value creation opportunities to minimize cost and still comply with the permit?
  • Liability issues – Can I be fined? How Much? Will Environmental Non-Government Organizations target my business for lawsuits? What is my recourse?
  • If I am a tenant, what is my liability to a property owner and what steps should I take to protect myself?
  • If I am a property owner, am I liable? What steps should I take during a purchase or lease to protect myself and inform my tenants of their legal obligations?

See the slide presentation here if you have not attended the seminars.

If you have questions about how the storm water permit could impact your business, or would like to know more about the permit fees, please contact Cory Jones, your nearest SCS office in California, or .

Cory Jones, P.E., ToR, QSIP, is a stormwater program manager at SCS Engineers. Jones manages complex projects for private and public clients that include site/civil, water/wastewater and stormwater engineering. He has completed a wide variety of special studies in storm water management and National Pollutant Discharge Elimination System (NPDES) compliance for federal, state and municipal public agencies.

Posted by Diane Samuels at 3:40 pm

February 24, 2016

Thirty-four senators and 171 representatives argue in a brief filed February 23, that the EPA overstepped its boundaries in creating the carbon-cutting Clean Power Plan. In short, the brief states that they feel that Congress never gave the EPA a clear statutory directive or authority to transform the nation’s electricity sector. The brief points out that the EPA seeks to make “decisions of vast economic and political significance” under a “long-extant statute,” and in doing so must point to a “clear statement from Congress.”

Yesterday’s brief comes just two weeks after the U.S. Supreme Court ruled the EPA cannot begin enforcing the rule until legal challenges filed by 25 states and four state agencies are resolved.

The D.C. Circuit Court of Appeals will hear oral arguments on the merits of the states’ case on June 2.

With the brief it is clear that the Clean Power Plan is not only facing legal challenges but also political ones. It may be left for the next Administration to pick up this pieces and decide the fate of the Plan.

Posted by Diane Samuels at 11:19 pm

January 13, 2016

Chuck_Pryatel_SCS_engineers
Chuck Pryatel, REHS at SCS Engineers

Meet Chuck Pryatel, the newly appointed Industrial Environmental Association (IEA) Secretary.

Chuck Pryatel is a Senior Project Advisor for SCS Engineers with over 30 years of experience in environmental regulatory compliance. He manages projects that include hazardous materials and waste compliance audits, preparation of spill prevention control and countermeasure plans, hazardous waste tank system assessments and certifications, and assists as a regulatory liaison resolving complex environmental issues. His experience includes completing environmental site assessments, subsurface investigations, preliminary endangerment assessments, health risk assessments, and environmental mitigation and clean-ups.

Prior to his private sector work Chuck served in positions of leadership at the County of San Diego Department of Environmental Health including Chief of the Hazardous Materials Division and Chief of the Site Assessment and Mitigation Division.

Chuck has a Masters of Business Administration from San Diego State University and a Bachelors of Arts in Biology from the University of California San Diego. He is a Registered Environmental Health Specialist in the State of California.

Congratulations Chuck!

 

The Industrial Environmental Association was formed in 1983 to promote responsible, cost-effective environmental laws and regulations, facilitate environmental compliance among member companies and provide related education activities for the community at large. The IEA’s evolution, however, has included an expanding role as the “voice” for manufacturing and associated companies in San Diego and Southern California, not only on legislative matters but on a variety of environmental issues that affect the quality of life of businesses in the region.

The Industrial Environmental Association actively insists on strong environmental compliance efforts among member companies as a matter of written policy. The IEA organizes a number of educational opportunities for member companies and the greater community including information exchanges, technical workshops, written papers, committees, and an annual conference.

IEA activism aims to prove with deeds as well as words that industrial companies care about the community, both environmentally and economically. IEA believes that industry must be involved in the process of environmental policy-making, and urges reliance on scientific, analytical data to evaluate regulations. The IEA willingly works closely with city and county government officials in an effort to realize environmental and community health protection.

Posted by Diane Samuels at 6:00 am

January 4, 2016

Two EPA landfill gas rules were published in the Federal Register in August 2015. The proposed EG Guideline rule affects “new” and “existing” landfill sites. Remember, these are guidelines only. Your local and state government agencies will use them to develop and implement the actual rules by which you do business.

Learn more in one place by reading the recent article in Waste Advantage Magazine, the SCS Engineers Technical Bulletin, and a slide set from a recent webinar about what you can expect for your business. All authored by Pat Sullivan, Senior Vice President at SCS and our National Expert on the Landfill Clean Air Act; NSPS.

Take me to this information.

 

Posted by Diane Samuels at 1:18 pm

November 10, 2015

Technical bulletins provide salient information in a condensed format. These summaries are useful to understand and start to plan for potential impacts to your business. Both bulletins posted today include deadlines and additional resources with contact information to help answer your questions. The two bulletins posted today are as follows:

  • Summary of the Clean Power Plan includes the final standards for new and existing Electric Utility Generating Units (EGUs). The Technical Bulletin reviews the U.S. EPA determination that  the best system of emission reduction (BSER) consists of three building blocks; how the EPA determines the degree of emission limitation achievable through the application of the BSER for each type of unit; and how quickly and to what extent the measures encompassed by the building blocks could be used to reduce emissions. States will be required to submit a final plan, or an initial submittal with an extension request, by September 6, 2016. The types of plans and cost-effective strategies suggested for states to tailor their plans to meet their respective energy, environmental, and economic needs and goals, and those of their local communities is in the final sections.
  • Summary of Proposed Oil and Gas NSPS U.S. EPA promulgated an amended Standards of Performance for Crude Oil and Natural Gas Production, Transmission and Distribution (NSPS). Specifically, EPA proposed amendments to 40 Code of Federal Regulations (CFR) Part 60, Subpart OOOO and proposed an entirely new Subpart OOOOa. EPA also promulgated a draft control technique guidelines (CTGs) document for the oil and natural gas industry. The CTG is intended to provide state, local and tribal air agencies with information to assist them in determining reasonably available control technology (RACT) for reducing volatile organic compounds (VOC) emissions from select oil and natural gas industry emission sources in ozone nonattainment areas. Comments on the proposal are due November 17, 2015, and the final rules are slated to be promulgated in June 2016. Rule details are provided in the Technical Bulletin and table within the Technical Bulletin.

Clicking the title of each Technical Bulletin will take you to the full text. Each Bulletin may be shared, emailed, or printed.

 

About Pat Sullivan:

Pat Sullivan, Sr. VP, SCS Engineers
Pat Sullivan, Sr. VP, SCS Engineers

Pat Sullivan, BCES, CPP, REPA, is a Senior Vice President of SCS Engineers and our National Expert on the Landfill Clean Air Act and the New Source Performance Standard (NSPS). Mr. Sullivan has over 25 years of environmental engineering experience, specializing in solid and hazardous waste-related issues.

Click on Pat’s name to see his full qualifications and experience.

 

Posted by Diane Samuels at 6:31 pm

November 9, 2015

DDC Journal recently published an interesting article by Pat Sullivan, “Developing power plants that reduce environmental impacts.” http://viewer.zmags.com/publication/097d62a6#/097d62a6/24

 

Pat Sullivan, BCES, CPP, REPA, is a Senior Vice President of SCS Engineers and our National Expert on the Landfill Clean Air Act and the New Source Performance Standard (NSPS). Mr. Sullivan has over 25 years of environmental engineering experience, specializing in solid and hazardous waste-related issues.

Posted by Diane Samuels at 7:22 pm

November 2, 2015

Transparency initiatives established by EPA as part of its Next Generation Compliance initiative mean increased reporting and recordkeeping for refineries.
Transparency initiatives established by EPA as part of its Next Generation Compliance initiative mean increased reporting and recordkeeping for refineries.

The U.S. Environmental Protection Agency (EPA) issued a final rule on September 29, 2015, seeking to further control emissions of hazardous air pollutants (HAPs) and volatile organic compounds (VOCs) from petroleum refineries.

This action finalizes the residual risk and technology review conducted for the petroleum refinery source category regulated under the National Emission Standards for Hazardous Air Pollutants (NESHAP; 40 CFR Part 63, Subpart UUU), including the refinery Maximum Achievable Control Technology Standard (MACT) 1 and Refinery MACT 2.

Click here to read the Technical Bulletin 

Posted by Diane Samuels at 2:10 pm

November 2, 2015

landfill-webinar-scs-engineersOn Monday, October 27, 2015, the Solid Waste Association of North America–SWANA and the National Waste & Recycling Association– NWRA submitted joint comments to the U.S. Environmental Protection Agency– EPA on the proposed revisions of the Emissions Guidelines– EG and Compliance Times for Municipal Solid Waste Landfills and to the supplemental proposal to the Standards of Performance for Municipal Solid Waste Landfills.

SCS Engineers has also submitted comments pertaining to the proposed EG and compliance revisions to the EPA. SCS leaders are involved in many outreach activities to help landfill owners and operators understand and prepare for the impact of the proposed modifications.

Contact SCS Engineers at for more information, or visit the SCS website for upcoming events and pertinent resources.

Posted by Diane Samuels at 6:00 am