SCS Engineers announces that Lauren Romanazzi is leading the firm’s Bay Area Sustainable Materials Management operations. She reports to Senior Vice President Michelle Leonard, who leads the firm’s Sustainable Materials Management program for North America.
Romanazzi, an environmental services specialist, brings a wealth of experience and expertise to her role. She holds a Master of Public Administration in Sustainable Management from the Presidio Graduate School in San Francisco.
With over a decade of experience in government and integrated waste management, her areas of expertise include sustainable program development, contract management, policy implementation, stakeholder engagement, and customer service. She has also managed tasks involving organic waste disposal, reducing greenhouse gas (GHG) emissions, regulatory compliance, and policy/program development.
Her eleven years with the City of San José have given her the tools to excel as the lead on Bay Area Sustainable Materials Management operations. Her responsibilities at the City included collaborating with stakeholders, managing Council District Neighborhood Clean-up projects, analyzing illegal dumping program data, overseeing the creation of the Zero Waste Element, which contributes to community carbon neutrality by 2030, as well as overseeing the implementation of a statewide policy on reduction of organic waste disposal and GHG emissions.
Senior Vice President Michelle Leonard states, “Hiring Lauren is another step in environmental excellence for our clients. She brings a unique blend of expertise and experience in waste management and policy implementation. Her journey from Assistant Environmental Services Specialist to Supervisor at the City of San José showcases a commitment to sustainability that makes her an asset to our firm and our clients.”
Additional Resources:
In recent years, the growing concern over the environmental and health impacts of nanoplastics has highlighted their pervasive presence and potential harmful effects on living organisms. The early 1970s saw the first reports of plastics polluting the marine environment. However, scientists only began to focus significantly on nanoplastics in the early 2000s, making it a significant area of study in scientific literature since then.
Both microplastics and nanoplastics, small plastic particles differing mainly in size, pose environmental and health risks. Sources of microplastics, defined as pieces smaller than five millimeters, include the breakdown of larger plastics, microbeads in cosmetics, and synthetic fibers from textiles. Nanoplastics, measuring less than 100 nanometers, challenge detection and removal efforts due to their minuscule size. Their potential for deep penetration and accumulation in organisms, including crossing cellular barriers, raises concerns about their impact on toxicology. These smaller plastics may result from further microplastic breakdown or specific engineering for specific uses.
Synthetic or semi-synthetic materials, plastics consist of long polymer chains and pose risks due to their environmental persistence and potential for bioaccumulation. The large surface area and hydrophobic nature of nanoplastics enable them to carry organic pollutants, including persistent organic pollutants (POPs) such as PCBs, dioxins, DDT, PAHs, BPA, and phthalates, many of which disrupt endocrine functions. The process of pollutants associated with plastics varies, influencing environmental degradation processes.
Qian et al. found that bottled water from various brands contains approximately 2.4 ± 1.3 × 10^5 plastic particles per liter on average.[1] They individually analyzed these particles to identify the chemical diversity among different polymer types. Among the identified polymers, Polyamide 66 (PA), Polypropylene (PP), Polyethylene Terephthalate (PET), Polyvinyl Chloride (PVC), and Polystyrene (PS) likely contribute significantly to micro-nano plastics exposure through bottled water. Although the specific chemical composition of these micro-nano plastics varies across brands, PA consistently emerged as a predominant component in quantity among the brands studied.
Furthermore, Qian et al. found comparing the exposure of micro-nano plastics from bottled water challenging when using blank samples of reverse osmosis (RO) water from the Milli-Q system, as the Milli-Q water showed the same level of plastic contamination as bottled water. Since plastics are a major component in many parts of the entire water purification system and polyamides serve as the most common material for RO membranes, the presence of nanoplastics in the water disqualifies it from being used as the lab blank for nanoplastic studies.
Overall, RO is an effective approach in control of plastics, however, the age of the membrane and its integrity and the operation conditions might affect the effectiveness of the filtration process according to SCS research and experts.
The widespread detection of microplastics in items consumed daily by humans, including food, beverages, and packaging materials—with bottled water being a significant source—highlights the pervasive nature of microplastic ingestion. Field documentation has shown that microplastics affect a broad spectrum of aquatic organisms across the marine food web, including turtles, seabirds, fish, crustaceans, and worms.[2]
The toxic effects of nanoplastics on organisms depend on their surface properties and size. Positively charged nanoplastics, for instance, disrupt cellular functions more significantly than their negatively charged counterparts, and their small size facilitates easier penetration of cellular membranes, leading to accumulation in tissues and cells.[3]
Cai et al. examined 33 studies on advanced methods for pretreating, separating, identifying, and measuring nanoplastics. While most studies effectively identified nanoplastics added to environmental samples as standards, they struggled to isolate and measure nanoplastics in actual environmental samples. A significant issue is that these studies often quantified nanoplastics without chemically verifying the types of polymers involved, casting doubt on the accuracy of their findings.
The current techniques for detecting and quantifying nanoplastics in the environment are limited, with Fourier Transform Infrared Spectroscopy (FTIR) being the predominant method for identifying polymers.[4] Emerging technologies, such as Hyperspectral Stimulated Raman Scattering (SRS) microscopy, promise to enhance the detection of nanoplastics by providing detailed, label-free chemical imaging through unique Raman signatures.[5] Nonetheless, the effective deployment of these technologies faces challenges, including the need for precise sample preparation and the ability to distinguish plastics from other environmental materials. Achieving accuracy in identifying plastics amongst other substances and distinguishing among various plastic polymers is crucial.
Ongoing advancements in technology and methodology are essential for detecting, quantifying, and monitoring nanoplastics across different settings. Such efforts are vital for gaining a clearer understanding of their distribution and concentration levels.
Understanding the entire lifecycle of nanoplastic pollution—from production to degradation—and the collective measures required to address this widespread issue is imperative. The minute size and substantial surface area of nanoplastics, relative to their volume, contribute to their resistance to natural degradation processes. The inherent chemical stability of polymers, which is beneficial for numerous applications, means that plastics do not readily decompose or chemically interact with other substances in the environment.
The hydrophobic nature of many nanoplastics limits their engagement with waterborne microbes and enzymes that potentially could help break them down. Polymers with high chemical and thermal stability, such as Polyethylene Terephthalate (PET), Polypropylene (PP), and Polystyrene (PS), are particularly resistant to environmental degradation processes. This resistance makes nanoplastics especially challenging to degrade, leading to their accumulation and persistence in the environment over time.
One of the most direct ways to combat nanoplastic pollution is to reduce the overall production and use of plastics, especially single-use plastics that are more likely to degrade into micro and nanoplastics. However, the likelihood of substantially reducing plastic production and use depends on various factors, including technological advancements, policy decisions, consumer behavior, and global cooperation.
Developing and using biodegradable or sustainable plastics instead of traditional ones is key. These alternatives are becoming more available and affordable, but more innovation and investment are needed to use them widely.
Better recycling technology that can efficiently turn used plastics into new products could reduce the need for new plastic. However, improving these technologies and making them available everywhere is a challenge.
The issue of nanoplastic pollution is global, with particles found even in remote areas, necessitating international cooperation and solutions.
Ongoing research into nanoplastics, including their interactions with biological systems and their potential roles in diseases such as Parkinson’s,[6] underscores the critical need for developing effective detection, quantification, and mitigation strategies to address the environmental risks they pose.
The extent to which nanoplastics are present in the environment remains uncertain because of the inefficiencies and inaccuracies in current detection methods. These methods’ outlined strengths and weaknesses underscore the unreliability of existing data.
The widespread concern over microplastics and nanoplastics has spurred scientific, policy, and public efforts to better understand their sources, movement, and impacts and find ways to reduce their environmental footprint. Nevertheless, challenges persist in detecting and quantifying nanoplastics, understanding their degradation and contaminant release mechanisms, and tracking their movement through food webs.
Resources:
[1] Qian N, Gao X, Lang X, Deng H, Bratu TM, Chen Q, et al. Rapid single-particle chemical imaging of nanoplastics by SRS microscopy. Proc Natl Acad Sci. 2024;121(3):e2300582121
[2] Wright, S. L., Thompson, R. C., & Galloway, T. S. (2013). The physical impacts of microplastics on marine organisms: A review. Environmental Pollution, 178, 483–492.
[3] Karapanagioti, H. K., & Klontza, I. (2008). Testing phenanthrene distribution properties of virgin plastic pellets and plastic eroded pellets found on Lesvos Island beaches (Greece). Marine Environmental Research, 65, 283–290.
[4] Vanavermaete, D., Lusher, A., Strand, J. et al. Plastics in biota: technological readiness level of current methodologies. Micropl.&Nanopl. 4, 6 (2024). https://doi.org/10.1186/s43591-024-00083-9
[5] Qian N, Gao X, Lang X, Deng H, Bratu TM, Chen Q, et al. Rapid single-particle chemical imaging of nanoplastics by SRS microscopy. Proc Natl Acad Sci. 2024;121(3):e2300582121.
[6] Anionic nanoplastic contaminants promote Parkinson’s disease-associated α-synuclein aggregation. Liu Z, Sokratian A, Duda AM, Xu E, Stanhope C, Fu A, Strader S, Li H, Yuan Y, Bobay BG, Sipe J, Bai K, Lundgaard I, Liu N, Hernandez B, Bowes Rickman C, Miller SE, West AB. Sci Adv. 2023 Nov 15;9(46):eadi8716. doi: 10.1126/sciadv.adi8716. Epub 2023 Nov 17. PMID: 37976362.
About the Author: David Palmerton, Jr., PG, is a Project Director for the Environmental Services Practice. Mr. Palmerton has managed strategic and technical environmental consulting issues for Fortune 100 companies throughout the United States. He has typically provided senior technical oversight, strategic support, and cost control for large multi-component environmental sites. His consulting assignments have included environmental science-based investigations, including soil, sediment, groundwater, and dense non-aqueous phase (DNAPL) investigations and remediation at some of the nation’s most high-profile sites. Mr. Palmerton has over 35 years of experience in environmental consulting in the areas of environmental liability assessment, investigation and remediation. Reach Dave on LinkedIn, or our consultants and engineers nearby at
SCS Engineers, a leading environmental engineering firm, proudly announces the appointment of its new executive leadership team subsequent to its semiannual Board of Directors meeting, under the guidance of Chairman Jim Walsh and CEO Doug Doerr.
Curtis Jang assumes the role of President, leveraging his extensive 30-year tenure in financial management and organizational improvement. Mr. Jang, will spearhead strategies aligning with the overarching goals set forth by the CEO and Board.
CEO Doug Doerr affirms the significance of this leadership transition, stating, “To ensure our continued success and to position ourselves for future growth, I’ve entrusted several key individuals to assume new executive roles. As one of the country’s foremost environmental engineering firms experiencing remarkable growth, it is imperative that we equip ourselves for the challenges and opportunities ahead.”
In his capacity as President, Mr. Jang will collaborate closely with Doug Doerr and the newly appointed executive leadership team to steer SCS Engineers towards its envisioned future – prioritizing the welfare of its employee-owners, fostering a cohesive ‘One SCS’ ethos, and delivering unparalleled service to our valued clients.
Eddy Smith, assuming the role of Chief Operating Officer, will lead business strategies across various units and practices to foster enhanced collaboration company-wide, thereby enhancing value delivery to clients. With over three decades of experience in environmental and civil engineering design and consulting, Mr. Smith brings a wealth of expertise to his new role.
Chief Financial Officer Steve Liggins, leveraging his financial acumen and a notable career spanning over 17 years, will oversee finance and accounting functions, ensuring fiscal stewardship within the organization.
Stacey Dolden, entrusted with the role of Chief People Officer, will spearhead the company’s intensified focus on enhancing the employee experience. As a certified Senior Professional in Human Resources with 24 years of experience, Ms. Dolden is committed to nurturing a best-in-class workplace, with a particular emphasis on fostering effective career pathways for all employees.
Jay Hatho, SCS’ Chief Information and Chief Technology Officer, will lead the development and implementation of innovative technological solutions within SCS, as well as for our clients. With over 25 years of experience, Mr. Hatho is dedicated to ensuring SCS remains at the forefront of technological advancement, thereby enhancing client service delivery and fostering employee-owner collaboration.
Nathan Hamm, in his capacity as Senior Vice President, will focus on driving strategic initiatives aimed at expanding the company’s service platform and offering creative solutions to clients’ environmental and business challenges. With over 26 years of industry experience, Mr. Hamm brings a wealth of knowledge and expertise across various service sectors within the engineering consulting arena.
The appointment of this new executive leadership team underscores SCS Engineers’ unwavering commitment to excellence, innovation, and client satisfaction. With their collective expertise and vision, SCS Engineers is poised to embark on an exciting new chapter of growth and success.
About SCS Engineers: SCS Engineers is a renowned environmental engineering firm dedicated to providing innovative and sustainable solutions to complex environmental challenges. With a steadfast commitment to excellence and client satisfaction, SCS Engineers has emerged as a trusted industry leader, serving clients across various sectors with integrity, expertise, and unparalleled professionalism.
Organics diversion is a hot topic, highlighting the need for more recycling to help communities benefit from methane emission reductions and decarbonization. Methane emissions from organic waste, such as food and plants, are largely preventable and comprise a significant portion of the U.S. waste stream. That makes actions to reduce these emissions popular, such as diverting waste from landfills, establishing recycling and composting programs, and energy recovery from organic materials – they create social and economic opportunities. At the same time, the programs make significant progress toward climate action goals.
Federal Grant Funding
The U.S. government has grant funding available to assist state and local government and non-profit organizations in increasing organic diversion. Currently, several agencies and departments have grants available. These are the U.S. Environmental Protection Agency (EPA), the U.S. Department of Agriculture (USDA), and the U.S. Department of Energy (DOE).
Finding the Right Grant
ReFED has partnered with the Natural Resources Defense Council to develop a Federal Grants Database to provide a centralized place to identify funding. The Resources and Guides | ReFED database provides the grant name, the agency, a description, the deadlines, the eligibility, a link to the grant, and other useful information.
EPA’s current grant programs are:
At least eight of the SWIFR grants are organics-related, and the communities that are taking advantage of them are as follows:
More details on each of these projects are here.
EPA also has the Climate Pollution Reduction Grants that the states and other regional authorities will administer. The states and regional authorities are developing their implementation plans for these grants. SCS Engineers expects food scrap and composting projects to be some of the many projects eligible for these grants.
DOE has two grant programs:
USDA has several grant opportunities related to food waste, including:
In January, the USDA announced an investment of approximately $11.5 million in 38 cooperative agreements that support innovative, scalable waste management plans to reduce and divert food waste from landfills. The Composting and Food Waste Reduction cooperative agreements, which the American Rescue Plan Act funds, are part of USDA’s broad support for urban agriculture.
Among the projects, the Southeastern Connecticut Regional Resources Recovery Authority proposes to construct and operate southeastern Connecticut’s first and only commercial-scale food waste composting facility, creating the necessary infrastructure to divert the region’s organic material from the municipal solid waste stream, generate a local source of high-quality compost, and increase awareness of the importance of food waste reduction and recycling. SCS assisted with the design and permitting of this project.
The USDA’s Fertilizer Production Expansion Program (FPEP) provides grants to help eligible applicants increase or expand the manufacturing and processing of fertilizer and nutrient alternatives in the United States. The Compost Crew in Maryland has received tentative notice of funding for a new compost facility. SCS assisted with the design of this project.
For States and Communities Getting Started
Historically, feasibility studies and pilot programs make excellent first steps toward decarbonization, recycling, composting, and zero waste programs. Many states and communities start with waste composition and feasibility studies or pilot programs.
Truly sustainable programs balance economic, environmental, and social factors to ensure they work long-term and comply with grant terms. These services are available from reputable sustainable materials management engineers and consultants who understand all aspects of solid waste management and federal and local air, water, and soil regulations.
Additional Resources:
About the Author: Dana Murray Blumberg, PE, is SCS Engineers’ Vice President for International Services and our National Expert on Federal Services. She has three decades of professional experience in civil/environmental engineering, including landfill gas emissions modeling and collection system design; landfill gas energy technology evaluation, feasibility analysis, energy user outreach and analysis; landfill closures; transfer station design and construction; and stormwater hydrology and hydraulics.
SCS Engineers Receives Four Environmental Business Achievement Awards
The Environmental Business Journal (EBJ) is an independent business research publication that provides strategic market intelligence to the environmental industry. EBJ is honoring SCS Engineers with four 2023 Business Achievement Awards.
“In a year of strong growth and financial performance for the environmental industry in 2023, a number of companies set themselves apart with performance, transactions, or projects that merit special recognition,” said Grant Ferrier, editor of Environmental Business Journal and chair of the EBJ Business Achievement Award selection committee.
SCS Engineers and our client will accept awards at the awards banquet at Environmental Industry Summit XXII on April 02-04, 2024, in San Diego, along with Business Achievement and Lifetime Achievement awardees.
Lifetime Achievement Award to James Walsh, SCS Board of Directors Chair
During his 40-year career, Jim worked at the forefront of sustainable solid waste management, sanitary landfills, and landfill gas (LFG), building an international reputation in these specialty fields. Among its many environmental services, SCS Engineers offers one of the longest and most successful biogas practices in the United States, primarily in landfill gas to energy. Jim has been engaged on over 100 landfill design and permitting projects and was chief design engineer, principal investigator, or project manager on over 300 landfill gas projects, in addition to serving as principal investigator on multiple landfill gas R&D projects for U.S. EPA, U.S. DOE, and Gas Research Institute. He continues his work at SCS as a highly sought after expert witness and ETLF specialist in North America, Jim is held in high esteem by his colleagues, clients, and industry.
San Gabriel Valley Food Recovery
The San Gabriel Valley Council of Governments (SGVCOG) retained the services of SCS Engineers to assist their member cities in compliance with state mandates regarding edible food recovery and food waste prevention. Implementing commercial food recovery programs is important to ensure members meet state compliance, avoid penalty fees, and reap the environmental and humanitarian benefits, such as addressing food insecurity.
SCS collaborated with the SGVCOG team and local stakeholders to analyze commercial edible food generation, calculate edible food recovery capacity in the region, develop safe food recovery/donation strategies, and create and implement education and outreach to establish one of the largest SB 1383 edible food recovery programs in California.
The combined effort has helped the SGVCOG better understand how and where food waste is generated within its communities and identify the capacities of food recovery organizations to recover excess edible food from businesses. The program has conducted inspections at over 500 businesses and recovery organizations to educate them on food waste reduction and edible food recovery. The program’s results are impressive.
EBJ Sustainable Solution Planning
Sustainability is the new imperative for public and private sectors to diligently establish sustainability initiatives and plans to meet their goals. Planning is the logical starting point, but planners often lack experience in designing and implementing environmental solutions. This oversight leads to less-than-desirable results against goals.
While others focus on identifying overarching goals related to NetZero or Climate Change, SCS partners with clients, preparing detailed plans and project execution to advance sustainability initiatives that scale. SCS Engineers has produced built projects and programs for over five decades that lower industrial operating costs and reduce greenhouse gases.
Integrating sustainability into the core business strategy ensures long-term viability. Selecting a company that’s engineered, constructed, operated, and monitored sustainable solutions helps ensure individual and holistic sustainable plans that scale based on funding and accommodate evolving technologies, market conditions, and regulatory requirements.
SCS’s sustainable solutions planners’ team with our diverse environmental engineers, scientists, and technicians, including our greenhouse gas monitoring and carbon sequestration practices. Our professional staff are located according to their knowledge of regional and local geography, regulatory policies, and industrial or scientific specialties. Full service by these experts provides added value and quality for our clients so that every project successfully achieves NetZero or Climate Change plan goals.
EBJ Large Company Business Achievement
Winners are awarded based on growth, achievements in profitability, major new project wins, staff hires, and new clients. SCS Engineers has grown steadily for decades and celebrated its 53rd anniversary in 2023. SCS Engineers’ core capabilities are solid and hazardous waste management, renewable energy, land remediation, and environmental compliance. With over 1,200 employee-owners, the firm’s scientists, engineers, and consultants produce technologies and create sustainable programs that help run industrial operations and essential public services more efficiently while reducing and verifying greenhouse gases and environmental impacts. In addition, the firm’s technology and sustainability programs for solid waste management support sustainable environmental solutions in the agricultural, industrial, and manufacturing sectors.
SCS employee-owners have a reputation for philanthropy in the communities they serve and generous donations during the holidays or when tragedy strikes.
SCS wins accolades by functioning across practices and geographical regions — with communications between those in the field, offices, and practices. It takes every SCSer to make this happen.
Many companies are scrambling in anticipation of new and pending climate change disclosure requirements. There is much activity, but it doesn’t mean it’s the best or right activity to provide real investment returns on efforts to meet sustainability goals.
In March 2022, the U.S. Securities and Exchange Commission (SEC) announced a proposed rule requiring certain climate-related disclosures in initial filings and annual financial reports. Following several months of silence, the SEC has revealed that the final vote on the Climate Change Disclosure rule has been delayed again until Spring 2024. The final adoption delays result from several groups challenging aspects of the proposed rule. The good news is that this will provide a little more runway for companies to gauge their sustainability programs, allowing time to monitor progress and ensure achieving the desired results.
The SEC’s proposal is similar to the International Financial Reporting Standards Foundation corporate reporting standards for sustainability and climate risk established by the International Sustainability Standards Board (ISSB). Similar to the SEC, similar regulations in Europe affect global companies, like the European Sustainability Reporting Standards (ESRS), which require ESG reporting for companies in the EU starting January 2024.
In addition, California recently passed SB253, Climate Corporate Data Accountability Act or CCDAA, which affects large companies doing business in California and requires them to disclose emissions publicly. Other states are considering climate accountability regulations in their respective committees as well.
Many leaders are looking at how to get the “biggest bang for their buck” from sustainability plans while adhering to the reporting and monitoring required for for climate change disclosure from regulatory agencies. One of the less complicated areas to explore is the utilization of water.
Many companies don’t have full insight into how they measure and monitor their water use within individual process areas, reporting rough estimates and preliminary data. Using a sustainability consultant with experience mitigating environmental impacts can help supplement your efforts with salient data.
In one case study, SCS Engineers partnered with a steel manufacturer to help them prepare a water stewardship program. The steel facility did not have ample clarity on baseline utilization regarding sustainability metrics. Instead of starting from scratch to research the appropriate benchmarking, the SCS team accessed a breadth of data prepared by others in the industry, demonstrating where the steel manufacturer ranked accordingly.
The steel industry’s approach to sustainability benchmarking is a great example of companies proactively addressing their carbon footprints. The ResponsibleSteelTM standard stems from the large target painted on the industry’s back—the process of creating steel is CO2-heavy and energy-intensive.
Steel companies have come together to develop a holistic green standard to improve their image and reduce environmental impacts. Several other industries have collectively participated in blind studies to capture information on sustainability-related metrics from production, buildings, and campus-level processes. SCS accessed publicly available benchmarking data to demonstrate that its steel client was best in class compared to other facilities and helped planners target the higher return on investment activities.
Many large manufacturers keep operational data close to the vest because they don’t want to share confidential or potentially proprietary information with their competitors, which makes perfect sense.
SCS Engineers has faced these hurdles before, like with a recent energy audit for a large aerospace company. The team found many factors other similar companies had published and used this to establish its benchmarks. Steve Stewart, SCS’s Director of Sustainability, says, “Our approach includes taking a handful of sustainability aspects and investigating how the client compares with similar facilities. Then we can start to develop a strategy to see what moves the needle.”
The main question is: where do you invest your sustainability dollars now for the biggest impact? Most focus on greenhouse gasses, so looking at a company’s direct emissions activities is a natural place to start. “We look at how the company uses electricity and natural gas, then move on to other utilities such as waste and water. These are typically your significant opportunities for improvement,” says Steve.
Accounting firms and consulting companies are on the upstream side of establishing sustainability programs; most lack environmental engineers and scientists’ insight on the most innovative approaches and processes used in designing and implementing cost-effective solutions. In other words—they lack the technical knowledge to solve these issues in the field.
“Management consultants can help program and provide reporting structures, but they don’t always understand the execution and requirements from a ‘boots on the ground’ perspective. That’s where the real results happen and what truly moves the needle in reducing GHGs,” says Stewart.
Knowing what’s coming down the line, companies should now select their environmental partners and ask questions about carbon footprint calculations and climate change disclosures. A major misstep is to view disclosures as a mere compliance requirement since many studies correlate stock price with a company’s commitment to ESG principles.
Additional Climate Change Disclosure Resources:
About the Author: Steven Stewart, PE, is SCS’s National Expert and Director for Sustainability. He is responsible for project development and serving as the client account manager for firms with a sustainability focus. Steven has with more two decades of experience within the environmental consulting and manufacturing industries providing strategic thinking related to project planning, regulatory strategy, and developing sustainability initiatives that deliver as planned. His experience includes energy efficiency measures, GHG reduction, carbon sequestration, water reuse and stewardship, and solid waste minimization and recycling programs. He has additional experience managing and performing permitting, compliance audits, developing environmental management systems, long-term environmental planning, environmental and sustainability capital projects. Steven has served as Environmental Manager and Capital Projects Portfolio manager at a large steel manufacturing facility which provides valuable experience to clients during project development and planning. Mr. Stewart is a licensed Professional Engineer in Alabama and Florida. You can reach him at or on LinkedIn.
Wastewater treatment is crucial to safeguard our water resources and the environment. Additionally, recycling wastewater is an excellent way to conserve this valuable resource, especially important for citizens and industry in the near future. At SCS Engineers, we specialize in the sustainable collection, treatment, and reuse of wastewater for municipalities and industries—our Landfill Leachate and Industrial Wastewater Treatment practice designs and implements these solutions.
SCS is excited to announce that Kerim Temel, PE, has joined the practice as a project director and wastewater treatment services leader. Based in Virginia Beach, Virginia, Kerim will provide technical project support and guidance for municipal and industrial wastewater treatment, landfill leachate treatment, groundwater remediation, and treatment systems operations and maintenance (O&M) across SCS. He has extensive experience treating complex wastewater from various industries, including landfills, pharmaceuticals, food and beverages, and chemical manufacturers. He has expertise in treating conventional and emerging contaminants such as Perfluoroalkyl Substances—PFAS. Temel’s skills include alternative evaluations, characterization, treatability testing, process design, confirmation testing, system evaluations, startup and training, and system optimization and troubleshooting.
Josh Strickland has recently joined SCS Engineers as a project professional based in Mobile, Alabama. He holds an academic background in chemical engineering and has gained experience in the oil and gas, manufacturing, and solid waste industries. Strickland primarily focuses on process engineering and supports project execution through process and mechanical design improvements. These improvements significantly enhance safety, design, production, processing, sizing, and equipment procurements while positively impacting collaboration.
SCS has a proven history of helping clients overcome their wastewater management issues. Treating and reusing wastewater is complex, but it is essential for many of our clients’ operations, sustainability objectives, and financial performance. With the addition of Kerim and Josh to SCS’s team, we have strengthened our technical expertise and capacity to tackle these challenges. ~ Nathan, Hamm, senior vice president and SCS’s national expert on Liquids Management.
Conducting Phase I Environmental Site Assessments (ESAs) is important to avoid significant financial risks for buyers and lenders. Inexperienced or unqualified consultants might overlook critical issues, making it vital to choose qualified environmental consultants. We recommend interviewing consultants to discuss project needs and assess their expertise to understand how they handle potential challenges.
It is essential to ensure the consultant’s qualifications. This process includes checking their educational background and professional certifications, such as Professional Geologist (PG), Professional Engineer (PE), and Certified Environmental Professional (CEP).
The ASTM International E1527-21 standard, effective in early 2023, is the current industry benchmark for Phase I ESAs. These assessments serve two primary purposes: due diligence — identifying potential contamination in real estate transactions, and liability relief — aiding purchasers in qualifying as bona fide prospective purchasers (BFPPs) to avoid liability for existing contamination.
To gain recognition as a BFPP, compliance with the All-Appropriate Inquiry (AAI) Rule is necessary. A Phase I ESA conforming to the current EPA-approved ASTM standard demonstrates this compliance.
Under Federal Law, the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) holds current property owners liable for environmental contamination in all but limited circumstances, even if the contamination occurred before their ownership. In some states, like New Jersey, claiming the Innocent Purchaser Defense requires additional assessment work.
Risks of Inadequate Phase I ESAs
The case of a financial institution versus an environmental consulting company underscores the risks associated with an inadequate environmental site assessment. The financial institution suffered considerable monetary loss due to an incomplete historical review, which failed to detect signs of contamination. Additionally, the property owner lost both the functional value of their property and the right to legal action against the assessment contractor, as they were not designated as “users” in the environmental report, facing potentially millions in cleanup costs.
A report from the USEPA released three months after the property transaction confirmed radioactive contamination on the site, previously utilized for hazardous material processing. Despite historical cleanup efforts, extensive radioactive contamination remained, with records dating back decades. This contamination significantly devalued the property and increased liabilities for the property owner and the financial institution.
For several months, the property owner delayed informing the financial institution about the contamination and related legal action. A new environmental consultant hired by the property owner estimated remediation costs to be between $4 million and $30 million. The property owner defaulted on their loan from the financial institution 33 months after its initiation, with a remaining balance of $3 million. Subsequently, the financial institution obtained a new appraisal for the property, which indicated an “as is” value of zero dollars.
Key Recommendations:
Risks of Using an Inexperienced Consultant
In the T&K Realty case, the environmental consultant performed a Phase I ESA for T&K Realty but failed to identify an underground storage tank despite evidence of a potential tank location. The consultant installed monitoring wells on the property as part of a Phase II ESA. During sewer line construction, workers found and uncovered a tank. They discovered a monitoring well drilled through the tank, releasing its contents. The tank, located next to a garage that serviced motor homes and other vehicles, contained volatile organic compounds like dichlorobenzene, 1,2-dichloroethene, methylene chloride, trichloroethene, benzene, ethylbenzene, naphthalene, toluene, trimethylbenzene, xylenes, solvents, and petroleum constituents. Complicating matters, the consultant used the sewer contractor to try to remove the tank, resulting in the contractor spilling most of the remaining contents on the ground. The release and subsequent spill resulted in groundwater contamination.
T&K Realty had to pay the costs incurred by NYSDEC, the costs to investigate the contamination and remediate the site, and legal costs. These costs amounted to hundreds of thousands of dollars.
Key Recommendations:
Conducting a Phase I ESA has become customary, but one should never underestimate its value. Collaborating with a qualified and competent Environmental Professional (EP) to ensure compliance with ASTM standards and the AAI Rule is essential. Failure to meet these requirements in a Phase I ESA could jeopardize the purchaser’s liability defenses.
Recognized Environmental Conditions – Best Practices
In the case of TC Rich vs. Shah Chemical Corporation (Shah)[1], an interesting situation arose regarding the recognition of a Recognized Environmental Condition (REC) during two separate Phase I ESAs conducted at separate times.
In the initial Phase I ESA TC Rich performed in 2005, they identified only one REC before purchasing the property and concluded that there was no contamination after soil sampling.
However, in 2015, TC Rich conducted another Phase I ESA to secure a loan. This time, the Phase I ESA identified the prior operations of Shah as a REC and initiated a Phase II ESA. The Phase II ESA revealed Tetrachloroethylene (PCE) contamination in soil, soil gas, groundwater, and even indoor air within the property building, consistent with discharges from Shah’s historical operations.
As a result, TC Rich initiated legal action against Shaw to recover toxic cleanup costs for the property, future cleanup costs, past damages, and attorney fees.
Importantly, TC Rich asserted that they neither caused nor contributed to the hazardous substance discharge on the property and had no prior knowledge or reason to believe that the property was contaminated. TC Rich took civil action against Shah for future cleanup costs and neither caused nor contributed to the contamination, leading to a settlement. If necessary, TC Rich could have used the “innocent landowner” defense under CERCLA.
Key Recommendations:
Conducting thorough Phase I Environmental Site Assessments (ESAs) is essential for uncovering and addressing potential environmental contamination and conditions linked to properties. Inadequate ESAs, often resulting from inexperienced consultants, can have significant financial and legal consequences for the owner, borrower, and/or lender. This is exemplified in various cases, including those detailed herein, which involved a major financial institution, an environmental consulting firm, and situations like T&K Realty and TC Rich.
Compliance with the AAI Rule is an important first step to qualify for the Bona Fide Prospective Purchaser defense under CERCLA, thus helping parties avoid financial liability for contamination caused prior to their ownership.
In summary, compliance with ASTM E1527-21 and the AAI Rule is essential for due diligence efforts to ensure legal protections and the performance of a thorough risk assessment to maintain confidence in real estate transactions, especially in urban and industrial areas with an environmental history.
References:
About the Author: David Palmerton, Jr., PG, is a Project Director for the Environmental Services Practice. Mr. Palmerton has managed strategic and technical environmental consulting issues for Fortune 100 companies throughout the United States. He has typically provided senior technical oversight, strategic support, and cost control for large multi-component environmental sites. His consulting assignments have included environmental science-based investigations, including soil, sediment, groundwater, and dense non-aqueous phase (DNAPL) investigations and remediation at some of the nation’s most high-profile sites. Mr. Palmerton has over 35 years of experience in environmental consulting in the areas of environmental liability assessment, investigation and remediation. Reach Dave on LinkedIn, or our consultants and engineers nearby at
SCS has a group of national experts working with all offices in North America to provide in-depth knowledge based on decades of experience supporting clients’ environmental needs. These resourceful people provide a wealth of information and guidance to support sustainable solutions in the industries SCS works in and with other professionals. Clients depend on the combination of SCS professional expertise, SCS leadership, and our roster of National Experts who consistently bring value to each solution. With the expanded leadership, SCS’s third generation can create even more sustainable solutions to environmental challenges. The firm announces its newest national experts as follows:
Anaerobic Digestion – Erik Anderson, PhD, is a Senior Project Manager. He has 14 years of engineering and process design experience in the renewable fuels sector, including anaerobic digestion, pyrolysis to syn-gas generation, and zero-liquid discharge technologies. He has worked on projects from initial concept development through front-end engineering design and construction management. His work includes modeling renewable energy technologies for economic comparison or life-cycle analysis. He is the inventor of several U.S. patents related to bioenergy and served as commissioner on the National Biodiesel Accreditation Committee from 2014-2021.
Brownfields Grants – Melissa Schick’s expertise includes preparing successful brownfields grant applications, helping public and private-sector clients navigate state and federal brownfields redevelopment and voluntary cleanup programs and closeout requirements, implementing and completing brownfields redevelopment projects, coordinating and communicating with all stakeholders.
Clean Air Act & NSPS – Josh Roth, PE, is a Project Director with the Landfill Gas (LFG) practice, serving on many 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. Roth regularly publishes and presents at industry and regulatory events, often appearing in client webinars, and leads one of SCS’s internal “University” training sessions monthly.
Elevated Temperature Landfills – Bob Dick, PE, works on civil and environmental engineering projects related to solid waste management. He has worked on over 25 major landfill multi-task assignments and performed over 150 landfill gas projects – some of the toughest in the US. His work involves landfill gas migration control, odor control, emissions control, Clean Air Act compliance, energy recovery and utilization, and carbon credit monetization. Dick is part of the SCS team that developed technical standards for the largest waste operator in the U.S. to implement in active and future disposal cells to prevent the formation of ETLF conditions in landfills. He incorporates these standards into the best management practices of landfill management teams globally.
Environmental Justice – Candy Elliott, PG, brings her scientific perspective and experience as an Environmental Justice expert to support disadvantaged communities marginalized by underinvestment and overburdened by pollution. She helps make impactful changes through her work experience with site characterization, site assessment and remediation, brownfields, groundwater monitoring and reporting, groundwater corrective action, mining, and other industrial facility or site development projects. These sites often provide excellent locations with existing infrastructure and transportation but with the need to clean the soil or, in some cases, mitigate other potential health risks to emerge as excellent opportunities for economic revitalization efforts and for creating green spaces.
Odor Management – Paul Schafer. Many of today’s waste management strategies and facilities lower GHGs. They, along with agricultural production, can emit odors. SCS has two National Experts to address industrial needs. Schafer leads Ambient Air Monitoring Services and plays key roles in significant national monitoring efforts. He has in-depth experience in interfacing with regulatory agencies regarding the performance of monitoring systems, source emission tests, and odor assessments, as well as with federal and state agencies regarding monitoring programs and air quality impact assessments, particularly for agriculture.
Odor Management – Patrick Sullivan, BCES, CPP, REPA. Sullivan is SCS’s National Expert for Clean Air Act (CAA) programs and leads the firm’s GHG, Sustainability, and CAA services. With over three decades of experience, he is often sought after to mitigate odors and analyze potential exposure for solid waste and industrial facilities. Sullivan is also a Senior Vice President and Principal-in-Charge for air quality permitting and compliance projects, GHG emissions, and climate change. Pat is a Harvard-degreed scientist, a Registered Environmental Property Assessor, Board Certified Environmental Scientist, a Certified Permitting Professional in the South Coast Air Quality Management District, and an accredited Lead Verifier under the California Air Resources Board (CARB) AB 32 Greenhouse Gas (GHG) programs.
Sustainable Planning – Steven Stewart, PE, PMP. Stewart is responsible for project development and client account manager for those with a sustainability focus. He has more than two decades of experience within the Environmental Consulting and Manufacturing Industry, providing strategic thinking related to project planning, regulatory strategy, and developing sustainability initiatives. Stewart leads projects related to energy efficiency measures, GHG reduction, carbon sequestration, water reuse and stewardship, and solid waste minimization and recycling programs. He has managed and performed permitting and compliance audits, developed environmental management systems, long-term environmental planning, and environmental sustainability capital projects. His background includes serving as Environmental Manager and Capital Projects Portfolio manager at a large steel manufacturing facility.
Over the years, SCS expanded and hired many talented people. They guide the firm, maintaining the founders’ focus and culture of adopting their clients’ environmental challenges as their own and fostering a culture of success for employees and communities.
The firm has won multiple awards for helping clients minimize waste generation, effectively managing recycling, collection, and disposal operations, renewable energy, safely cleaning up contaminated properties, protecting wastewater and groundwater, and cutting GHG emissions.
These employee-owners are most proud of the difference they make for their clients and communities as trusted partners. SCS clients entrust the firm with managing more than 35 million metric tons of anthropogenic CO2e greenhouse gases yearly. SCS collects and beneficially uses or destroys enough to offset greenhouse gas emissions from 7.4 million passenger cars annually. That’s more than any other environmental firm in North America.
Carbon credits can be a reliable and lucrative source of revenue for organic waste management facilities in addition to more traditional revenue sources. Voluntary carbon credits provide compost and anaerobic digestion facilities with an additional source of income, complementing tipping fees and sales of final products. Carbon credits are issued, bought, and sold in carbon markets in a broader effort to lower greenhouse gas emissions. The Climate Action Reserve (CAR) establishes carbon credit standards, guidelines, and values (Climate Reserve Tonnes or CRTs).
Participation in voluntary carbon markets, mines, landfills, compost facilities, and anaerobic digestion facilities can generate additional revenue while reducing greenhouse gas emissions.
Is your project eligible for carbon credits?
There are two main types of carbon markets: regulatory and voluntary. Regulatory carbon markets require mandatory participation. Voluntary carbon markets provide carbon offset credits for qualifying products that effectively reduce greenhouse gas emissions from a baseline level. Each voluntary market defines its baseline and qualifications for offset projects. Offset credits can then be sold. Within voluntary carbon markets, eligible organic waste management and landfill projects can participate in generating carbon credits.
Project developers can enter into purchase/sale agreements and single-year or multi-year partnerships with buyers to secure evaluated carbon prices. The project developer does not need to guarantee credit quantities, as the brokerage assumes responsibility for managing the credits over a specific period and guarantees a price per credit. The brokerage markets any amount exceeding the agreed-upon price per credit to potential buyers. This option provides more long-term pricing stability.
Climate Action Reserve (CAR)
CAR is a nonprofit organization that promotes the reduction of greenhouse gas emissions through market-based policies and solutions. CAR serves as an approved Offset Project Registry (OPR) for the State of California’s Cap-and-Trade Program and is integral in supporting the issuance and administration of compliance offsets.
CAR also establishes standards for voluntary offset projects in the North American voluntary carbon market. It operates as a publicly accessible registry for carbon credits generated under its standards. CAR has eight voluntary offset protocols for waste handling and methane destruction projects in the United States, Mexico, and Canada. They assist, advise, and register clients with voluntary offset projects.
SCS has partnered with clients to pursue voluntary offset projects in Organic Waste Composting and Organic Waste Digestion protocols. Contact SCS Engineers at or Greg McCarron on LinkedIn to learn how your project may qualify.
