Do you have NSPS or EG sites per the new definitions of “new” and “existing”?
Does your EG site have any upcoming planned or permitted expansions, or will it be commencing construction on an expansion permitted after July 17, 2014?
Will you need to submit/resubmit Design Capacity and NMOC reports to establish your sites status as subject to the new NSPS? Over, or under 34 Mg/year of NMOCs?
Are you a candidate for Tier 4? In the closed landfill subcategory?
For EG sites contact the SCS state representative by sending a request to
SCS Engineers will be publishing Pat Sullivan’s Technical Bulletin Summary of Final NSPS/EG Rules for Landfills as soon as it is published in the federal register. Meanwhile, please contact your SCS Project Manager or for answers to your questions or advice. Follow SCS Engineers on your favorite social media site or check our events for new presentations, publications, and webinars explaining the rules in more detail.
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 July 11, 2016, multiple organizations representing the full value chain of cellulosic waste feedstock conversion to transportation fuel sent a letter to Gina McCarthy, Administrator of the U.S. Environmental Protection Agency (EPA). The letter supporting the Renewable Fuel Standard Program: Standards for 2017 and Biomass-Based Diesel Volume for 2018 (Proposed Rule) noted that additional information and factors need to be considered.
Read or share a copy of the letter here, contact SCS Engineers, or one of the organizations below:
Sensitive natural resources include but are not limited to the following: Threatened and Endangered (T&E) species and their habitats, wildlife refuges, wetlands, and tribal burial grounds. These are areas where federal or states have identified protected resources. SCS Engineers has the expertise and credentials to perform surveys for clients with projects requiring the identification of these sensitive resources, along with the regulatory permitting with specialization in threatened and endangered species, wetlands, and critical habitats.
Development and construction often occur near or within areas identified as sensitive natural resources. Responsible developers identify sensitive resources near or within their proposed project area as part of their development plans because protecting our nation’s natural resources is important. The protection of sensitive natural resources is the basis of the Federal Endangered Species Act, Clean Water Act, and National Historical Preservation Act. Projects under consideration in sensitive areas require special permits; without which projects can be shut down causing costly contractor delays and schedule disruptions. Post-permitting and the associated fines can be severe, so even if you are not a conservationist, it makes good sense to complete the permitting process before breaking ground.
When considering a project in potentially sensitive ecological areas, SCS Engineers recommends a constraint analysis be performed. The analysis will determine if the proposed project location is within wetlands, critical habitat, threatened and endangered species range, and other potential constraints. If it is, SCS recommends that a site assessment is performed and initiate agency consultation to protect the sensitive resources.
Both the permitting process and the preliminary ecological assessments are not difficult but do require credentialed specialists. SCS has geologists, hydrologist, hydro-geologists, and environmental compliance professionals nationwide. SCS Engineers even has credentialed biologists for specialized threatened and endangered species monitoring and assessments for several species that include but not limited to the American Bury Beetle, Arkansas Shiner, Arkansas Darter, Topeka Shiner, Neosho Mucket Mussel, Rabbitfoot Mussel, Northern Longear Bat, and Indiana Bat in the Central U.S.
To determine if a project is within a sensitive natural resource area or to schedule an ecological consultation, contact .
About the Author: Vaughn Weaver
Vaughn Weaver has over 20 years of environmental services experience with a strong background in water quality and bio-monitoring and is currently a senior field technician at SCS in our Wichita office. He provides project assistance to a diverse team of environmental professionals made up of geologists, hydrogeologists, engineers, chemists, and biologists. His responsibilities include surveying project sites, mitigation monitoring, well sampling and monitoring, and report writing for clients.
In addition, he has 15 years of water quality experience with National Pollution Discharge and Emissions Systems (NPDES) for point source and non-point source permits. Vaughn is also a Certified Wetland Delineator – USACOE.
Tracie Onstad Bills, Northern California Director, Sustainable Materials Management at SCS Engineers
Thank you for the responses and questions about my blog Minimizing Contamination in Recycling. It seems appropriate to provide answers to the most frequently asked questions and send more advice. Any program should be tailored to your current collection system; what works and what doesn’t work for your locality; the demographics of your community; and how your community views recycling.
In light of those considerations, here are some recommendations for ways to minimize contamination in recyclables:
Learn more about recycling programs by reading Success In Selective Routing – Resource Recycling or the SCS project and case studies below:
As always, feel free to send me your questions and comments. Contact Tracie here.
SCS Engineers’ Tracie Onstad Bills and Leslie Lukacs were both selected to receive the California Resource Recovery Association’s (CRRA) prestigious Service Award this year. According to CRRA Executive Director, John H. Dane, the award recognizes “exceptional individual service to the organization and a contribution of time or resources beyond expectations.” That sounds like an SCSer alright.
Tracie Bills is SCS’s Sustainable Materials Management Director and is based in our Pleasanton, CA, location. She has been on the CRRA board for 10 years and has served in several leadership positions within the organization, including as its President for three years. Her expertise revolves around commercial recycling technical assistance, environmental purchasing, large venue and event zero waste programs, research and sustainability planning, garbage hauler franchise compliance and review, construction and demolition program / ordinance analysis and writing, climate inventory compilation, research and feasibility studies to help clients with comprehensive waste prevention and zero waste programs.
Leslie Lukacs serves as a Sustainable Materials Management Specialist in our Santa Rosa, CA, office. She has been on the CRRA board for 12 years and also served in a variety of leadership positions. She also founded CRRA’s Green Initiatives for Venues and Events technical council and was an instructor for CRRA’s Resource Management Certification Program for 5 years. Leslie specializes in the design and implementation of sustainable materials management and zero waste programs and is a pioneer in the greening of venues and events throughout the nation. Her extensive expertise in the logistics of zero waste, recycling, and composting programs, such as outreach management, business assistance, master planning, waste audits and characterization studies, extended producer responsibility ordinance preparation and implementation, compliance, grant writing, and administration are all key to successful long-term programs.
Both women were selected by the CRRA Board of Directors to be the 2016 recipients of the Service Award. The awards will be presented at the organization’s Annual Conference Awards Ceremony on August 9 in Sacramento.
CRRA is California’s statewide recycling association. It is the oldest and one of the largest non-profit recycling organizations in the U.S. CRRA is dedicated to achieving environmental sustainability in and beyond the state through Zero Waste strategies including product stewardship, waste prevention, reuse, recycling and composting. The organization provides its members with resources to advance local, regional and statewide waste reduction efforts which result in critical environmental and climate protection outcomes. Members represent all aspects of California’s reduce-reuse-recycle-compost economy and work for cities, counties, municipal districts, and businesses as well as hauling companies, material processors, non-profit organizations, state agencies, and allied professionals.
It’s not just that we like wine and happen to live and work in every wine producing region of the U.S.; SCS Engineers understands the need for clean water resources and how important they are to the wine industry and for agriculture in general. SCS helps wineries face an array of environmental and regulatory challenges including:
SCS is pleased to announce we are the newest member of WIN, the Wine Industry Network.
SCS Engineers offers sustainable environmental solutions to businesses with environmental challenges. SCS provides these services to private and public sector clients through a network of nationwide offices. For more information about SCS, please visit our website at www.scsengineers.com, or contact us at .
SCS Engineers has published two Technical Bulletins summarizing the O&G NSPS final rule and outlining the new LDAR requirements. The two Bulletins explain the modification of how oil and gas sources will be permitted under the Clean Air Act and the new requirements to reduce methane leaks from new oil and gas facilities consistent with the EPA’s New Source Performance Standards.
Reference the U.S. Environmental Protection Agency (EPA) new source performance standards for Crude Oil and Natural Gas Production, Transmission and Distribution (O&G NSPS), which includes amendments to 40 CFR Part 60, Subpart OOOO and a new Subpart OOOOa. Subpart OOOOa will apply to facilities constructed, modified or reconstructed after September 18, 2015.
Click to read or share the Technical Bulletins:
https://www.epa.gov/controlling-air-pollution-oil-and-natural-gas-industry
Pat Sullivan, REPA, CPP, BCES
(916) 361-1297
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 Environmental Protection Agency (EPA) has recently proposed increases in renewable fuel volume requirements across all types of biofuels under the Renewable Fuel Standard (RFS) program. The proposed increases would boost renewable fuel production and provide for ambitious yet achievable growth.
The Clean Air Act requires EPA to set annual RFS volume requirements for four categories of biofuels: cellulosic biofuel, biomass-based diesel, advanced biofuel, and total renewable fuel. EPA implements the program in consultation with the U.S. Department of Agriculture and the U.S. Department of Energy.
EPA will hold a public hearing on this proposal on June 9, 2016, in Kansas City, Missouri. The period for public input and comment will be open through July 11, 2016.
For more information on the proposal, see www.epa.gov/renewable-fuel-standard-program/proposed-renewable-fuel-standards-2017-and-biomass-based-diesel.
For more information on the public hearing, see www.gpo.gov/fdsys/pkg/FR-2016-05-25/pdf/2016-12358.pdf.