We are deeply saddened by the passing of our founder Tom Conrad, but we celebrate his spirit by continuing the culture he established at SCS Engineers. Tom was energetic, creative, hard-working, and fun-loving! His accomplishments in preventing and mitigating environmental damage are just one of the reasons we respect him so much.
Another reason is that Tom believed in providing opportunities for everyone. He founded and ran SCS based on giving individuals the tools they need to thrive while providing for their families, the environment, and their communities. These tools are trust, mentorship, and open dialog. By building these philosophies into our culture, Tom sparked multiple innovations and environmental solutions by some of the finest people you’ll ever want to meet.
These SCSers continue our culture of caring and listening. Anyone at SCS can contribute their ideas for improving a process or technology. Our executives promote forums to keep the conversations and idea exchanges going and open to all. And just as Tom would insist, innovations are proven before they are implemented.
We’re proud of all SCSers, especially our young professionals, who consistently bring in fresh ideas and perspectives by asking “why and how” questions. Designing sustainable environmental solutions requires a deep understanding of systems, processes, and industry knowledge. Asking the right questions and seeking answers indicates a curious mind; Tom called these people “thinkers,” one of the best compliments we could get. Asking these questions indicates a self-actualized mind. And answering the questions takes a team. At SCS, we encourage both.
SCS’s mentorship and young professionals programs are thriving. They were established more formally in the last decade but have always been a part of SCS. President and CEO Jim Walsh called Tom “The best mentor anyone could ever have,” going on to say that Tom “taught me a lot, but more, he let me figure things out on my own… I’ve often said that my best four years of education were not high school or college; it was learning from Tom Conrad.”
SCS’s culture survives because of trust. So as Tom did, we continue to place trust and confidence in SCS’s employee-owners. Tom understood long ago that trust creates a culture of teamwork and respect, enabling effective problem-solving. In fact, Tom was so proud and confident in the firm’s environmental accomplishments in 1987 that he modified the company’s Employee Stock Ownership Plan to expand ownership of SCS to all employees. Today SCS remains 100% employee-owned and is a driving force for SCSers to deliver high-quality and ethical solutions to our clients.
Tom’s other major and no less important philosophy was to “have fun!” We take the time to engage and laugh with our colleagues, clients, and associates.
Our nationwide offices are busy year-round helping their communities, especially during the holidays. A special thanks to our young professionals, who think BIG, for organizing our annual Feed America campaign, always with a healthy, fun competition between our offices!
You can learn more about how SCS continues in Tom Conrad’s spirit today by watching this short video made by SCSers coast to coast.
EPA intends to update and expand its November 2021 oil and gas regulation proposal by reducing methane emissions and other harmful air pollution from new and existing oil and natural gas operations. The Agency has issued a supplemental proposal adding proposed requirements for sources not previously covered.
Registration is open for EPA’s virtual public hearing impacting hundreds of thousands of existing oil and gas sources nationwide. The Agency states it will promote innovative methane detection technologies and other cutting-edge solutions which are being developed.
Hearing information:
To register to speak or to watch a live stream of the hearing on both days, please visit EPA’s website for the supplemental proposal.
The registration deadline is January 5, 2023. See instructions for submitting a written comment.
On December 5, 2022, the EPA released a memo providing direction under the NPDES permitting program to empower states to address known or suspected discharges of per- and polyfluoroalkyl substances (PFAS). The memo cites state programs in Michigan and North Carolina that other states may want to replicate. These approaches and others could help reduce PFAS discharges by working with industries, and the monitoring information they collect, to develop facility-specific, technology-based effluent limits.
As stated in its memo, the EPA’s goal is to align wastewater and stormwater NPDES permits and pretreatment program implementation activities with the goals in EPA’s PFAS Strategic Roadmap. The memo recommends that states use the most current sampling and analysis methods in their NPDES programs to identify known or suspected sources of PFAS and to take actions using their pretreatment and permitting authorities, such as imposing technology-based limits on sources of PFAS discharges.
The Agency hopes to obtain comprehensive information by monitoring the sources and quantities of PFAS discharges, informing other EPA efforts to address PFAS. The EPA will need this information since new technologies and treatments are in development but remain unproven to work successfully in specific industries.
Other proposed actions by the Agency include designating two PFAS as Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) hazardous substances and an order under EPA’s National PFAS Testing Strategy requiring companies to conduct PFAS testing and nationwide sampling for 29 PFAS in drinking water starting in 2023.
In a letter to Congress, SWANA and NWRA associations request that regulation under CERCLA for addressing PFAS contamination assign environmental cleanup liability to the industries that created the pollution in the first place. Both associations note that landfills and solid waste management, an essential public service, do not manufacture nor use PFAS. Therefore, the general public should not be burdened with CERCLA liability and costs associated with mitigating PFAS from groundwater, stormwater, and wastewater.
Resources:
Illinois EPA Environmental Justice Procedures
The Illinois EPA Bureau of Air recently implemented more stringent procedures for securing an air permit for a new emissions source or emissions unit when the operations are located in, or within a mile of, an Environmental Justice area. How long the new procedures will remain in effect is not known, but any increase in air emissions will subject the project to more extensive review by the Illinois EPA and possibly the United States Environmental Protection Agency (USEPA) Region V, which could extend the permit application review by a substantial amount of time. Depending on the location of the source, the type and amount of the pollutant(s) being emitted, and the amount of interest or objection by interested parties, there is also a chance that the permit may not be approved. Interested parties include, but are not limited to, local activists, local government agencies, neighboring citizens, and other entities with an interest in Environmental Justice (EJ).
Assuming a permit with a net increase in emissions is approved, it will likely include the following elements.
Illinois EPA is recommending that a company seeking to construct and operate a new or modified source, or add a new emissions unit to an existing source, identify ways within the plant to lower air emissions of the applicable air contaminant(s) such that the project will not result in a net emissions increase. Illinois EPA is not expecting a source to conduct a formal netting exercise, but instead suggests considering product substitutions such as alternative cleaning solutions with low or no volatile organic material (VOM) or hazardous air pollutants (HAPs); for instance, a mixture of acetone and water, or detergents. Other approaches may include the installation of add-on pollution control equipment, use of cleaning solutions with low vapor pressures which evaporate more slowly, capturing some of the VOM in shop towels and cleaning rags rather than emitting them to the atmosphere, installation of recovery equipment (e.g., distillation equipment), and considering other raw material substitutions or equipment replacements.
When an air permit application is submitted to the Illinois EPA for a proposed project that does not result in a net emissions increase, the application will be processed by the permitting department, and then a draft permit will be forwarded to the EJ group at Illinois EPA. The EJ group will forward a copy of the draft permit to interested parties specific to that EJ area. If no comments are received within two weeks, the permitting group will issue a draft permit to the permittee for review and comments. Any substantive comments received from interested parties will be addressed by the Illinois EPA, and this process could cause delays, particularly if a public hearing is requested and granted.
Environmental Justice Background
The USEPA defines environmental justice as “the fair treatment and meaningful involvement of all people regardless of race, color, national origin, or income, with respect to the development, implementation, and enforcement of environmental laws, regulations, and policies.” Environmental justice was originally established by Title VI of the Civil Rights Act of 1964, which prohibits recipients of federal financial assistance (states, grantees, etc.) from discriminating against these populations in any program or activity. The scope of Title VI was expanded by Executive Order 12898 by President Clinton on February 11, 1994. Executive Order 12898 was issued to direct federal agencies to incorporate achieving EJ into their mission, and to identify and address, as appropriate, disproportionally high adverse human health and environmental effects of their programs, policies, and activities on minority and low-income populations. More recently, President Biden issued Executive Order 14008 Tackling the Climate Crisis at Home and Abroad on January 27, 2021.
Illinois EPA has adopted policies and procedures to conform to Title VI of the Act and Executive Orders 12898 and 14008. According to Illinois EPA, “environmental justice is the protection of the health of the people of Illinois and its environment, equity in the administration of the State’s environmental programs, and the provision of adequate opportunities for meaningful involvement of all people with respect to the development, implementation, and enforcement of environmental laws, regulations, and policies.”
EJ areas in Illinois are derived from US Census Block Groups where the population consists of a substantial amount of minorities and/or the area is heavily populated by persons and families living below the poverty line. Further information on how EJ areas are established can be found at Illinois EPA EJ Start (arcgis.com), which also includes a map identifying all EJ areas in the state.
About the Author: Ann O’Brien is a Project Manager at SCS Engineers with 33 years of experience in the printing industry. She assists companies with air, water, and waste management; EPCRA; environmental compliance audits; and Phase I Environmental Site Assessments.
For more information or assistance with identifying ways to lower air emissions or help with maneuvering through the air permitting process at Illinois EPA, contact Ann O’Brien () in Chicago, IL, or Cheryl Moran () in Milwaukee, WI. For assitance in other states please contact .
The USWAG Utility Decommissioning Workshop in Crystal City, VA, begins on December 12th. This valuable workshop provides utilities the chance to focus on topics that can save time and money while working toward new goals. We’ll be covering these topics:
SCS Engineers Vice President and Deep Well Injection Expert, Monte Markley, will present a session on how deep well injection is facilitating site development and minimizing post closure costs for utilities nationwide. The challange for sustainably managing CCR leachate and other liquid residuals as a facility is decommissioned is met in phases by facilitating site redevelopment allowing leachate lagoon or evaporation basins to be decommissioned in the short term and utilizing the DIW for long term leachate disposal. The small foot print of a deep injection well and the ability to safely, continuously operate with minimal staffing allows conventional leachate management infrastructure real estate to be re-purposed. Having the ability to decommission leachate lagoons and other water treatment infrastructure (e.g. groundwater pump and treat systems) within 18-24 months after closure allows owners to avoid significant post closure care costs. Avoided costs include long term operrations and maintenance, regulatory reporting, and financial assurance. Mr. Markley’s presentation based on case studies outlines the requirements to get a well permitted and operational at a facility, and includes examples of capital and opex costs avoided.
Agricultural growing and harvesting operations are typically exempt from air planning, permitting and odor nuisance regulations. However, cannabis operations may require approval from the local Planning Commission. They may also require air permits from the local air regulatory agency for manufacturing operations (e.g., for solvents and associated combustion equipment such as boilers). Air permit applications for cannabis manufacturing operations may include the following based on project-specific conditions:
In addition to these permitting services, and to avoid costly nuisance complaints, cannabis growers may also need odor-related services such as:
While these may seem like imposing lists for air planning they are not for engineers who work in the industry.
Developing effective plans to mitigate odors is vital in gaining Planning Commission approvals which often depend upon resolving concerns raised by the public. Comprehensive OAPs and OMPs include odor control Best Management Practices (BMPs) and adaptive management strategies for responding to odor complaints when cannabis operations are near residences and schools.
Odor Control – Odor Nuisance Mitigation Case Study
Cannabis greenhouses in the Carpinteria, California region were causing off-site odor nuisances at nearby residences. The inherent smell needed addressing, as odor-neutralizing vapors along cannabis greenhouse perimeters and ridgelines were not providing adequate odor control.
Working with Cannabis Association for Responsible Producers (CARP) Growers, Pacific Stone, Groundswell, and Envinity Group, SCS Engineers utilized its air quality and odor expertise to collect continuous measurements using our SCSent-i-PED (Pollutant and Environmental Data). SCSent-i-PED is a state-of-the-art method for measuring TRS compounds to the parts per billion (ppb) level. The system can assess concentrations in real time, and a single machine can assess multiple locations and sources within a facility. This method successfully assessed relative odor levels and spatial/temporal fluctuations in odor-causing emissions.
Data collection is vital and useful to:
SCS, through its years of experience in air quality and odors, provides cost-effective, sustainable solutions that enable greenhouses and facilities to coexist in urban and suburban environments. Our clients not only get solutions, but they also have the data and science to understand better how odors behave and vary within a cannabis greenhouse.
To learn more, watch a video about air planning and managing greenhouse odors at https://www.scsengineers.com/services/clean-air-act-services/odor-monitoring-and-control/
About the Author: Paul Schafer is a Vice President and Project Director at SCS Engineers and the firm’s National Expert on Ambient Air Monitoring. During his technical career, Paul has assumed key roles in several nationally significant monitoring efforts. He has in-depth experience interfacing with regulatory agencies regarding the performance of monitoring systems, source emission tests, and continuous process monitors, which SCS operates for our clientele. He has had direct working experience with multiple local, state, and federal agencies regarding monitoring programs and air quality impact assessments. As with all solutions at SCS, cost control management and defensible technical performance are primary goals integral to all sustainable monitoring programs.
The Maryland Department of the Environment (MDE) is working to develop a new regulation aimed at reducing methane emissions from municipal solid waste (MSW) landfills in the state. Methane is a potent greenhouse gas (GHG) with a global warming potential over 25 times greater than carbon dioxide. The new requirements MDE is considering are modeled after similar rules in California and Oregon and would become among the most stringent in the US. MDE anticipates publication of the draft rule in December 2022, followed by public participation and finalization of the rule in the spring of 2023.
This proposed rulemaking has been several years in development and is consistent with Maryland’s GHG Reduction Act of 2009 and the recent Climate Solutions Now Act of 2022 that requires Maryland to become “net zero” for GHG emissions by 2045, with an interim goal of achieving 60% GHG reductions by 2031 (over 2006 levels). MDE estimates that once implemented; this rule could result in up to a 50% reduction in GHG emissions from affected landfills.
MDE presented initial details about the draft regulation (aka, the state plan) at the October 24, 2022, Air Quality Control Advisory Council and stakeholder meeting. The proposed rule would apply to smaller and mid-sized landfills. It would likely impact many facilities not currently subject to the EPA’s federal landfill air regulations under NSPS & EG 40 CFR 60 Subparts Cf and XXX and NESHAP CFR 63 Subpart AAAA. MDE estimates that 32 active and closed MSW landfills in the state will be subject to the proposed regulation.
SCS Engineers is tracking the proposed rule closely, so stay tuned for additional details once the draft rule is published.
For additional information on MSW regulations and GHG emission reductions, please visit scsengineers.com or one of SCS’s nationwide offices.
About the Author: Joshua Roth, PE, is a Vice President and Project Director with the Landfill Gas (LFG) Group in the SCS Reston, VA office. He has served on a number of LFG engineering projects involving LFG remediation system design, emissions inventories and air permitting, migration and odor control, ambient air sampling and reporting, LFG and CER due diligence projects, GHG emission mitigation and reporting, field sampling and assessments, and general emissions control projects.
Welcome to the SCS Engineers Environmental Learning Center. Every month we record a live session on an environmental hot topic! We invite everyone to these open forums where participants can ask questions throughout. The video recordings are available in our Learning Center to watch at your convenience. Best of all, we respect your privacy; these are educational videos not sales pitches followed by a mountain of spam email. Our videos are intended to share our experience in environmental fields with individuals to enhance problem-solving and innovation. Click below to visit.
Whether reducing methane emissions at landfills, repurposing contaminated properties, producing alternative energy, or sequestering carbon, we have focused on finding smart climate solutions and improving the natural environment since our inception in 1970.
SCS Engineers supports many businesses and municipalities taking steps to address climate change, which many consider the most important challenge facing our planet. Every business is resource-intensive with most environmental issues occurring during the operational phase of business or production. The sustainable environmental solutions and testing we discuss in our videos we offer to the agricultural, construction, extraction, manufacturing sectors, and municipalities to help them attain their cleaner operating goals and often improve operating efficiency.
You’ll also find articles, papers, blogs and more videos on environmental topics from A-Z using our search and filter feature. Can’t find something – let us know at our professionals are ready to help.
Other Playlists Include:
The FY 2023 Brownfields Multipurpose, Assessment, Revolving Loan Fund, and Cleanup Grant Guidelines are now available (go to Open Solicitations). The application submission deadline is November 22, 2022.
Please see the link below for Multipurpose, Assessment, RLF, and Cleanup (MARC) Grant Application Resources: https://www.epa.gov/brownfields/multipurpose-assessment-rlf-and-cleanup-marc-grant-application-resources#Open%20Solicitations
From the official guidance:
SCS Engineers has a successful track record supporting communities interested in land recycling and obtaining EPA Brownfields grants. Please visit our website for more information.
Welcome to the SCS Engineers Environmental Learning Center. Every month we record a live session on an environmental hot topic! We invite everyone to these open forums, where participants can ask questions throughout. The video recordings are available in our Learning Center to watch at your convenience. Best of all, we respect your privacy; these are educational videos, not sales pitches followed by a mountain of spam emails. Our videos are intended to share our experience in environmental fields with individuals to enhance problem-solving and innovation. Click below to visit.
Whether reducing methane emissions at landfills, repurposing contaminated properties, producing alternative energy, or sequestering carbon, we have focused on finding smart climate solutions and improving the natural environment since our inception in 1970.
SCS Engineers supports many businesses and municipalities taking steps to address climate change, which many consider the most important challenge facing our planet. Every business is resource-intensive, with most environmental issues occurring during the operational phase of business or production. The sustainable environmental solutions and testing we discuss in our videos we offer to the agricultural, construction, extraction, manufacturing sectors, and municipalities to help them attain their cleaner operating goals and often improve operating efficiency.
You’ll also find articles, papers, blogs and more videos on environmental topics from A-Z using our search and filter feature. Can’t find something – let us know at . Our professionals are ready to help.
Other Playlists Include:
Please send a request here if you’d like an invitation to our live sessions.
