There is no single best approach to financing fleet replacement costs. With the financial challenges facing local governments today in providing cost-effective and timely solid waste management services, evaluation of these various approaches should be made focusing on ways to minimize costs while providing value-added services to the public.
Marc Rogoff discusses a number of alternative vehicle/equipment purchasing programs, which are being used by solid waste agencies to preserve cash. Each of the financing methods described has its own particular advantages and disadvantages, which can be influenced by local municipal circumstances.
Read the complete article here.
By Chris Jimieson, PE and Jared Omernik, PE
Do you know how much oil and fuel you store in aboveground containers at your facility? If you have more than 1,320 gallons, you may need an SPCC Plan. What is an SPCC Plan? SPCC stands for Spill Prevention, Control, and Countermeasure, and it is a federal rule (40 CFR 112 in the Federal Register) designed to prevent oil-based products from entering navigable waterways of the U.S. But it’s about more than just compliance. It’s an important tool to help you limit your liability.
Facilities covered under the SPCC rule are subject to agency inspections and potential enforcement actions if the facility’s practices are found to be out of compliance.
Does the SPCC rule apply to me?
The 1,320-gallon threshold isn’t the only trigger for an SPCC Plan. One of the keys to take away from the SPCC rule is that it does not count oil/fuel storage in containers less than 55-gallons in size. Another trigger is that a facility must reasonably be expected to discharge oil into navigable waters or adjoining shorelines of the U.S.
The Environmental Protection Agency (EPA) does not define what “reasonably be expected” means. Rather, the responsibility is on the facility owner or operator to determine the potential for discharge. In reality, it’s usually easy to think of a scenario where spilled oil could reach a waterway. Even if you think a spill would never reach the stream, what if there was a significant rain event that washed away spilled oil on the ground through a storm sewer? Often the “reasonably to be expected” is not challenged, so it is best to err on the side of caution.
The SPCC rule applies to my facility, now what?
There are three options: 1) Prepare the plan yourself. 2) Use a third party provider to prepare your plan, or 3) Have a licensed professional engineer develop your plan. The option you choose depends on how much oil you store at your facility and your working knowledge of the SPCC rule.
If you have less than 10,000 gallons of oil and no single aboveground oil storage container with a capacity greater than 5,000 U.S. gallons, you may be able to prepare your own SPCC Plan, following the EPA’s Tier I qualified facility template.
You can download the EPA’s Tier I qualified facility template here: https://www.epa.gov/sites/production/files/2014-05/documents/tier1template.pdf. The template is the least expensive way to comply with the SPCC rule. However, some users feel it is a little confusing.
If you have less than 10,000 gallons of oil and have a single aboveground oil storage container with a capacity greater than 5,000 U.S. gallons, you could qualify under the EPA’s Tier 2 qualified facility category. The EPA does not provide a plan template for a Tier II qualified facility. You can still prepare the plan yourself, or you may hire a third party or professional engineer to develop the plan for you.
If your facility has greater than 10,000 gallons of oil storage, you must have a licensed professional engineer prepare your facility’s SPCC Plan.
Working on an SPCC Plan with a Third Party Provider
If you decide to work with a third party provider, here are some things you can expect as part of the process. The provider will conduct a facility site visit to review the oil storage. Prepare to have a staff member familiar with the oil storage escort the provider to each of the sources. The provider will ask questions about spill prevention features at each source location, including secondary containment, overfill protection, and interstitial monitoring, if applicable.
After visiting the oil sources, the provider may ask to see any available tank data such as specifications, current inspection protocol, and tank repair or integrity testing documentation. You can eliminate follow-ups and help keep costs down by having this data available for review.
Following the site visit, the provider will prepare an SPCC Plan that you should review for accuracy before implementation.
The Value of an SPCC Plan for Your Facility
An SPCC Plan is about more than just compliance. An SPCC Plan contains inspection forms and protocols that can help to prevent a spill at your facility. It identifies the single point of contact, an “SPCC Coordinator” for the facility. If there is a spill, the Plan contains steps necessary to contain the spill initially and control the discharge, and the proper contacts to notify internally and externally.
The SPCC rule requires all oil-handling personnel receive annual training to respond appropriately to spills in their work areas. The annual training requirement is another key element to spill prevention, but also covers aspects on how to properly take control and countermeasure actions in the event of an oil spill.
Work with your staff to determine if the SPCC rule applies to you. An SPCC Plan is a required document for certain facilities to help you comply with the SPCC rule and gain the benefits of having a plan in place. However, more than that, it is a practical document that’s designed to assist with training and inspections and to help prevent spills from occurring. Moreover, if spills do occur, an SPCC Plan provides the guidance to help control the spill and limit your liability.
Chris Jimieson and Jared Omernik have more than 26 years’ combined experience helping various types of clients with environmental compliance. Chris and Jared have extensive experience helping customers build and review SPCC and Storm Water Pollution Prevention Plan (SWPPP) projects. For questions about the SPCC rule or how to comply, Contact Chris at
For questions about the SPCC rule or how to comply, Contact Chris at or 608-216-7367, or contact Jared at or 608-216-7348 in the Upper Midwest.
To find an office near you click here.
When Virtual Care Providers, Inc. (VCPI) set out to sell their company, David Bartlett, VCPI Chief Financial Officer, thought they had their environmental due diligence squared away. “We did our due diligence in 2006 when we purchased the property,” said Bartlett. “Unfortunately we discovered that the original Phase 1 Environmental Site Assessment (ESA) missed some potential issues.”
To complete the sale, VCPI needed to conduct a new Phase 1 assessment. That’s when David hired SCS Engineers to help VCPI through the environmental due diligence process. “When Ray Tierney and his team went through the Phase 1 process, they discovered there was something there. The original Phase 1 from our prior consultant missed some things.”
Long before it was a data center, the property owner used hazardous chemicals in their manufacturing process. As part of that process, they stored some of the chemicals on the exterior of the property. Although the chemicals had been removed long ago, some of them had spilled onto unpaved areas. While VCPI had no knowledge of the property’s prior use when they bought it, SCS Engineers uncovered detailed records and photos of the chemical storage in state agency files.
“Of course the parties involved in the sale were concerned about these past issues and the impact they could have on the sale and ongoing use of the property,” Bartlett confirmed. “We initiated a Phase 2 to gain clarification. Then we worked with the Wisconsin Department of Natural Resources (WDNR) to get the property closed.” In the end, no active remediation was required. However, these steps were necessary to get the WDNR to grant site closure.
“Being in this situation was painful,” Bartlett admitted. “But SCS Engineers’ integrity shone through in every step and was absolutely critical. Everyone that I worked with at SCS Engineers gave us peace of mind that the steps we took weren’t just to pad pocketbooks. Ray’s team showed us how each step in the process was necessary to get us past the problems, on to resolution, and on to the successful sale of our company. I completely trusted the information SCS Engineers gave us.”
“Without Ray and his team, we never would have been able to expedite the process. We simply didn’t have the connections or the relationships with the WDNR to move it along. SCS Engineers’ familiarity with the process and relationships with the WDNR really helped speed us to resolution, which allowed us to move forward with the sale of our business.”
“I don’t know what would have happened or how long it would have taken without SCS Engineers’ expertise. The depth and breadth of their knowledge shed light on issues I wasn’t aware of. Not only did Ray’s team help us uncover the issues, they gave us a plan to determine the extent of those issues and helped show us how to move past them. Their expertise, knowledge, and guidance were critical.”
VCPI kept the sale of their business on track and closed on December 22, 2016.
Thank you for your kind letter, Mr. Bartlett. We were happy to help resolve the issues leading to the sale and the safe ongoing use of the property by its new owner.
Read and share the WasteAdvantage article describing the solution process here. Written by:
According to the U.S. EPA, approximately 561,000 underground storage tanks (USTs) nationwide store petroleum or hazardous substances. The greatest potential threat from a leaking UST (LUST) is contamination of groundwater, the source of drinking water for nearly half of all Americans. EPA, states, and tribes work in partnership with industry to protect the environment and human health from potential releases.
Randy Bauer, a project director with SCS Engineers in Arizona stated, “We have seen a significant increase in the number of storage tank failures nationwide, primarily from single-walled fiberglass tanks installed in the 1990s.” He went on to say, “Some fuel additives, such as ethanol, are known to eventually dissolve the epoxy used in the fiberglass tanks, leading to cracks and failures.”
SCS currently has seven soil and groundwater remediation systems in operation in Arizona because the Arizona Department of Environmental Quality (ADEQ) has a proactive program. As the state’s environmental regulatory agency under the Environmental Quality Act of 1986, ADEQ is a separate, cabinet-level agency that directs all of Arizona’s environmental protection programs. Their mission is to protect and enhance public health and the environment in Arizona. The department does this by overseeing the state’s environmental laws and authorized federal programs to prevent pollution of the air, water, and land, and to ensure clean up of pollution, such as LUSTs when it occurs.
About Randy Bauer:
Mr. Bauer has nearly 30 years of experience conducting environmental site assessments, subsurface investigations, groundwater monitoring programs, soil and groundwater remediation, and geotechnical investigations at industrial hazardous waste and solid waste facilities. His responsibilities include supervision, planning, and conducting of numerous Phase I and Phase II environmental site assessments (ESAs) and underground storage tank (UST) removals. Mr. Bauer has planned and directed the characterization and remediation of several large projects involving soil and groundwater contamination. He also directed several hydrogeologic characterizations, including the collection of soil and groundwater samples and interpretation of aquifer tests. He has prepared several Remedial Investigation/Feasibility Study (RI/FS) reports, and prepared, designed, and implemented treatability studies, Remedial Action Plans (RAPs), and groundwater monitoring programs. He has been directly responsible for the preparation of several Aquifer Protection Permits (APPs) for wastewater treatment plants and solid waste disposal facilities. Mr. Bauers duties included
Mr. Bauer has planned and directed the characterization and remediation of several large projects involving soil and groundwater contamination. He also directed several hydrogeologic characterizations, including the collection of soil and groundwater samples and interpretation of aquifer tests. He has prepared several Remedial Investigation/Feasibility Study (RI/FS) reports, and prepared, designed, and implemented treatability studies, Remedial Action Plans (RAPs), and groundwater monitoring programs. He has been directly responsible for the preparation of several Aquifer Protection Permits (APPs) for wastewater treatment plants and solid waste disposal facilities. Mr. Bauers duties included
He has been directly responsible for the preparation of several Aquifer Protection Permits (APPs) for wastewater treatment plants and solid waste disposal facilities. Mr. Bauer’s duties include the senior technical review of documents, as well as negotiation and coordination with the Arizona Department of Environmental Quality (ADEQ).
Increasingly, solid waste and recycling agencies are being asked by their political decision makers to improve efficiency, focus on customers, and reduce increased costs. Many agencies are managed with a combination of manual processes, desktop computer tools, limited vehicle and cart tracking and management tools, and custom databases. While effective, these methodologies often entail more effort, labor, and costs.
Smart technologies are expected to grow substantially over the next decade as agencies attempt to minimize their overall costs in solid waste collection and recycling and increase overall efficiency. As discussed briefly in this article, smart technologies have advantages and disadvantages. As agencies investigate technology to help support their service, ensure continued quality service delivery and meet demanding business requirements, it is important to conduct feasibility assessments to evaluate the economic costs to implement and update the use of new technologies in a sustainable manner.
Marc J. Rogoff and Laurel Urena of SCS Engineers.
SCS Engineers’ Phillip E. Gearing, PE is a winner of the SWANA 2017 Young Professional Award from the Wisconsin Badger Chapter. The Solid Waste Association of North America honors individuals like Phil who make a significant difference in the solid waste industry.
Phil represents the best of the young professionals working within Wisconsin’s solid waste industry. Clients, contractors, and team members appreciate Phil’s leadership and passion for doing the job right.
He is a dedicated father of three children and an avid fan of all things Wisconsin, namely Badger sports, Green Bay Packer football, and Brewer baseball. Wisconsin from head to toe! Phil was raised on a dairy farm in Jackson County near Merrillan and attended the University of Wisconsin – Madison where he earned his B.S. in Geological Engineering, Geology, and Geophysics.
Phil serves clients out of the SCS Engineers office in Madison, WI.
Read about Phil’s work and SWANA award here.
Despite the fact that you have taken every precaution, hitting utility lines or other hidden infrastructure is still relatively common. Even after all the records are consulted and metal detector tests completed, you can dig up an entire storage tank that wasn’t accounted for or find a random pipe with no apparent usefulness.
Having a tool that can get you down there without damage is a significant benefit to those in the field. SCS recommends using the Hydrovac or Air Knife technologies, tools that can save money and time when working on sites with sensitivities or a longer historical background when the risks are highest.
SCS uses these tools when drilling at a transfer station near older or deeper power lines. We find utilities can be buried deeply below ground or are not encased in metal pipes, making metal detectors useless.
When remediating a historic property for developers with nearby utility lines and there’s a question about the accuracy of the records, it is far safer and cost efficient to use these newer technologies to dig a hole as small as for setting a mailbox, or as large as digging an entire site for construction.
The Hydrovac and Air Knife will both remove soil cover and allow you to see any underground utilities or infrastructure before excavation or drilling. The Hydrovac uses pressurized water and a vacuum system to remove soil. The Air Knife accomplishes the same thing using compressed air instead of water.
SCS Engineers can provide a range of equipment sizes and capabilities including:
By Thomas Karwoski and Sherren Clark
About the Authors:
Mr. Karwoski has 30 years of experience as a hydrogeologist and project manager. He has designed and managed investigations and remediations at existing and proposed landfills; and industrial, Superfund, military, and petroleum sites.
Ms. Clark has more than 25 years of experience in civil engineering and environmental science, with a technical background in both engineering and hydrogeology. She manages multidisciplinary projects including landfill design and monitoring, brownfield site investigation and remediation, and environmental management and permitting for private and public sector clients.
Links to SCS Services: CCR, Landfill, and Remediation pages.
What makes Sol shine so brightly?
For Solavann Sim it’s his positive qualities as an individual and his ability to work effectively using a multidisciplinary approach with his clients. Our industry’s strongest and most respected leaders are those who are considered collaborative, not fixated on making all decisions themselves or working in a silo. On the contrary, innovation happens at the crossroads of different disciplines and that is where Sol shines brightest.
Sol’s landfill gas design-build and operations experience, along with his knowledge of hydrogen sulfide treatment programs, help prevent and mitigate potential problems quickly. His comprehensive technical and field competence, along with his clients, and his team comprised of staff in several disciplines approach solutions in various ways; each having unique perspectives but a common goal. Working collaboratively with clients the team solves complex challenges facing landfill owners and operators. Innovative solutions are often found where perspectives, ideas, and fields of expertise meet.
Read more about Solavann Sim and SCS Engineers LFG programs here.
See SCS’s 40+ years of innovative thinking at SCS Firsts an interactive list of client solutions, underneath News, Events, and Blogs.
Read and share the full article by David Greene, PE, here.
EPA recently established expansive new air rules affecting MSW Landfills. Implementation of the new rules places new responsibilities on both the regulated community and regulators alike. However, some of these responsibilities are unclear and have created unresolved issues that should be addressed in close consultation now with your state/local regulatory authority.
For example, if a landfill is “new,” the facility is now subject to NSPS Subpart XXX, which is fully effective. A design capacity and NMOC emissions rate report should already have been submitted.
If NMOC emissions from a facility exceed 34 Mg/yr, then the landfill will need to submit a GCCS design plan within 12 months of the date of exceedance and install and operate within 30 months (no later than May 2019 for those triggering with the promulgation of the rule). If a landfill is an “existing emissions source,” it will be subject to the new EG rule (Subpart Cf).
Landfill owners should maintain close contact with their state/local regulatory authority regarding the status of the regulator’s state implementation plan, due by November 2017. That state implementation plan will prescribe the required compliance dates for an existing landfill, likely to be no later than the 2018/2020 time period. In either case, owners should become familiar with the rule and stayed tuned as compliance guidance evolves to address the unresolved issues.
Contact SCS Engineers to discuss the regulatory status in your state at , or call your local representative.
