epa compliance

July 18, 2018

In an increasingly complex regulatory world, Remote Monitoring and Control (RMC) systems provide the tools necessary to improve safety, increase efficiency and make the right decisions quickly. Beyond capturing and storing data, these systems can sort through mountains of data, identify what’s important and deliver meaningful information to operators in real time or as needed.

Some of the added benefits of using RMC systems include:

  • early problem detection;
  • minimal downtime;
  • efficient and predictive scheduling of technicians;
  • real-time analysis of data;
  • automated reporting; and
  • secure data storage.

Read the Waste Today article – click here. Learn more about Remote Monitoring and Control here.

 

 

 

Posted by Diane Samuels at 6:00 am

July 10, 2018

This paper, presented at A&WMA’s 111th Annual Conference details the Tier 4 process and the potential issues that have arisen from conducting a Tier 4. This paper also assesses potential Tier 4 sites, exceedance reporting, wind monitoring, additional SEM equipment requirements, penetration monitoring, notification and reporting requirements, and impacts on solid waste landfills that will use the Tier 4 SEM procedure for delaying GCCS requirements. This paper reviews the changes between the draft NSPS and the final version of the new NSPS that was promulgated.

Click to read or share the paper, and learn about the authors.

 

 

 

 

Posted by Diane Samuels at 12:05 pm

April 25, 2018

 

The industry standard SP001 is incorporated into many Spill Prevention, Control, and Countermeasure (SPCC) Plans is now updated.  How does it affect your facility’s SPCC Plan?

The Steel Tank Institute (STI) recently released an updated version of SP001 – Standard for the Inspection of Aboveground Storage Tanks. This document is the industry standard used in most SPCC Plans for inspection guidelines and integrity testing for shop-fabricated aboveground storage tanks. In a typical SPCC Plan prepared by SCS Engineers, your monthly and annual inspection forms, and tank integrity testing frequency requirements are based on the criteria provided in SP001.

Summary of Key SPCC-related Items in the Revised SP001 Standard:

  • Monthly and annual inspection forms have been updated.
  • The inspection forms include revised questions that should help facility staff with improved clarity on inspection criteria.
  • The inspection forms have been reformatted, and the length of the forms has been reduced.
  • The integrity testing inspection schedule and evaluation criteria remain consistent with the previous SP001 edition.
  • There is a new appendix with guidance aimed at inspection of hot-mix asphalt tanks.

Do you need to amend your SPCC Plan because of this revised industry standard?

No.  We recommend incorporating the updated inspection forms during your next SPCC Plan Amendment or 5-year renewal.

How do the changes affect the implementation of your SPCC Plan?

The inspection criteria have been simplified, and more flexibility is allowed with the revised inspection forms. This will help make your inspection process easier and of higher quality.

Need help sorting out the details of the revised standard, or have an SPCC Plan that needs amending or is due for a 5-year review?  Contact , and we will help you stay on top of your SPCC needs with offices nationwide.

Brief SPCC-related document history:

 

Coauthors: Denise Wessels and Amber Fidler.
SCS Engineers SPCC specialists in Pennsylvania.

 

Posted by Diane Samuels at 6:03 am

April 18, 2018

It might feel like the July 1 deadline is far away, but it is time to start preparing to report your releases of toxic materials. The U.S. Environmental Protection Agency (USEPA) indicates that printing and related industries are subject to this report. It is an important part of your environmental compliance strategy if you have a facility with at least 10 full-time equivalent employees in a covered NAICS code that exceeded a reporting threshold in the previous calendar year. Reporting releases of toxic materials on an annual basis is one aspect of the Emergency Planning and Community Right-to-Know Act (EPCRA).

Read the article with steps to your report for printing and related industries.

Consolidated List of Chemicals Subject to the Emergency Planning and Community Right To Know Act (EPCRA), Comprehensive Environmental Response, Compensation and
Liability Act (CERCLA) and Section 112(r) of the Clean Air Act

 

 

 

Posted by Diane Samuels at 6:03 am

April 10, 2018

Modeling for a Worst Case Release and the Alternative Release Scenario – not so mysterious after all. Lee Pyle explains it to you in her recent article in the RETA Breeze. Lee is SCS Engineers National Expert on Industrial Risk Management Plans and Process Safety Management.

All of us with over 10,000 pounds of ammonia in our plant system are well aware of the EPA Risk Management Program Hazard Assessment requirements (40 CFR Part 68.20). When the EPA inspector shows up, we hand them the manual and cross our fingers that they understand what they are reading and pray they do not ask a question.

Do not fret; chances are that the inspector at your plant is probably not much more fluent in dispersion modeling than you are. Much debate occurs over how long it would take to stop a release, but you do not want to get into a debate with an EPA inspector.

Read, share, or print Unmasking the Mystery of the Worst Case Release and the Alternative Release Scenario here. Happy Modeling!

 

 

 

Posted by Diane Samuels at 6:01 am

April 9, 2018

Secondary containment is a basic engineering control to prevent a chemical or oil spill. There are misconceptions, though, regarding secondary containment requirements. In terms of oil-based storage, these misconceptions can lead to not enough containment capacity, significantly more containment capacity than necessary, or simply not providing the right level of containment when containers are grouped.

Chris Jimieson of SCS Engineers explains the five most common misperceptions and advises you how to keep your facility in compliance.

Read the article by clicking here.

 

 

 

Posted by Diane Samuels at 6:00 am

March 19, 2018

A look at the confusion stemming from regulatory uncertainty of new rules limiting air emissions from municipal solid waste landfills by David Greene, P.E., SCS Engineers – Asheville, NC.

The landfill industry continues to work with EPA Administration to get a longer-term stay to work out needed NSPS/EG rule changes. At this time, industry representatives are hopeful both these related goals can be achieved.

While the new NSPS/EG rules became effective back in 2016, the concerns with the rules raised at the time still remain unresolved. Despite this, we can expect resolution though it may take some time to fix. The fog should be lifting, yielding changes that are expected to be more workable for both the landfill industry and state/local regulators. In the meantime, stay tuned and stay informed.

Read the full article with links to the NSPS/EG update in a recently published SCS Technical Bulletin.

 

 

Posted by Diane Samuels at 6:00 am

March 6, 2018

SCS Engineers periodically prepares Technical Bulletins to highlight items of interest to our clients and friends who have signed up to receive them.  Our most recent SCS Bulletin summarizes the new rules which took effect on October 28, 2016, with compliance obligations under the NSPS Subpart XXX rule beginning November 28, 2016. Originally, states and local air jurisdictions were to submit their proposed EG rules by May 30, 2017; however, there have been some delays in this process, which we condense and detail in this Bulletin. SCS will continually update coverage of this Rule on our website.

 

 

 

 

 

Posted by Diane Samuels at 9:24 am

February 26, 2018

In a Motion filed on November 7, the U.S. Environmental Protection Agency (USEPA) requested remand of five provisions of the Coal Combustion Residuals (CCR) Rule (40 CFR Parts 257 and 261), which would allow the agency to reconsider the provisions. This SCS Engineers Technical Bulletin covers the five provisions and the basis for their reconsideration. Read the full text here.

Oral arguments on EPA’s motion took place on November 20, 2017.  EPA had asked that oral arguments be postponed, and all other aspects of the litigation are suspended until it could rule, but the court did not agree. The current provisions in this Technical Bulletin remain in place unless and until USEPA revises or rescinds them in a future rulemaking.

SCS Engineers will continue to track these issues and keep you informed. Join our Technical Bulletin email list by clicking here, or follow SCS on LinkedIn, Facebook, or Twitter .

 

 

Posted by Diane Samuels at 6:01 am

November 28, 2017

Ann O’Brien of SCS Engineers has pulled together a list of questions that printers should be asking themselves before the environmental reporting season is upon us.

Use Ann’s questions as a guide to find out how ready your company is, and decrease your risk of non-compliance by being more organized.

If you don’t know the answers, ask Ann. She’s one of our air and water permitting, monitoring, and reporting experts at SCS. Ann specializes in printing industry compliance.

Read the full article.

Contact and we’ll direct you to an air, storm water, wastewater, or groundwater expert near you and in your industry.

 

 

 

 

Posted by Diane Samuels at 6:00 am