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February 24, 2016

Thirty-four senators and 171 representatives argue in a brief filed February 23, that the EPA overstepped its boundaries in creating the carbon-cutting Clean Power Plan. In short, the brief states that they feel that Congress never gave the EPA a clear statutory directive or authority to transform the nation’s electricity sector. The brief points out that the EPA seeks to make “decisions of vast economic and political significance” under a “long-extant statute,” and in doing so must point to a “clear statement from Congress.”

Yesterday’s brief comes just two weeks after the U.S. Supreme Court ruled the EPA cannot begin enforcing the rule until legal challenges filed by 25 states and four state agencies are resolved.

The D.C. Circuit Court of Appeals will hear oral arguments on the merits of the states’ case on June 2.

With the brief it is clear that the Clean Power Plan is not only facing legal challenges but also political ones. It may be left for the next Administration to pick up this pieces and decide the fate of the Plan.

Posted by Diane Samuels at 11:19 pm

January 13, 2016

Chuck_Pryatel_SCS_engineers
Chuck Pryatel, REHS at SCS Engineers

Meet Chuck Pryatel, the newly appointed Industrial Environmental Association (IEA) Secretary.

Chuck Pryatel is a Senior Project Advisor for SCS Engineers with over 30 years of experience in environmental regulatory compliance. He manages projects that include hazardous materials and waste compliance audits, preparation of spill prevention control and countermeasure plans, hazardous waste tank system assessments and certifications, and assists as a regulatory liaison resolving complex environmental issues. His experience includes completing environmental site assessments, subsurface investigations, preliminary endangerment assessments, health risk assessments, and environmental mitigation and clean-ups.

Prior to his private sector work Chuck served in positions of leadership at the County of San Diego Department of Environmental Health including Chief of the Hazardous Materials Division and Chief of the Site Assessment and Mitigation Division.

Chuck has a Masters of Business Administration from San Diego State University and a Bachelors of Arts in Biology from the University of California San Diego. He is a Registered Environmental Health Specialist in the State of California.

Congratulations Chuck!

 

The Industrial Environmental Association was formed in 1983 to promote responsible, cost-effective environmental laws and regulations, facilitate environmental compliance among member companies and provide related education activities for the community at large. The IEA’s evolution, however, has included an expanding role as the “voice” for manufacturing and associated companies in San Diego and Southern California, not only on legislative matters but on a variety of environmental issues that affect the quality of life of businesses in the region.

The Industrial Environmental Association actively insists on strong environmental compliance efforts among member companies as a matter of written policy. The IEA organizes a number of educational opportunities for member companies and the greater community including information exchanges, technical workshops, written papers, committees, and an annual conference.

IEA activism aims to prove with deeds as well as words that industrial companies care about the community, both environmentally and economically. IEA believes that industry must be involved in the process of environmental policy-making, and urges reliance on scientific, analytical data to evaluate regulations. The IEA willingly works closely with city and county government officials in an effort to realize environmental and community health protection.

Posted by Diane Samuels at 6:00 am

November 10, 2015

Technical bulletins provide salient information in a condensed format. These summaries are useful to understand and start to plan for potential impacts to your business. Both bulletins posted today include deadlines and additional resources with contact information to help answer your questions. The two bulletins posted today are as follows:

  • Summary of the Clean Power Plan includes the final standards for new and existing Electric Utility Generating Units (EGUs). The Technical Bulletin reviews the U.S. EPA determination that  the best system of emission reduction (BSER) consists of three building blocks; how the EPA determines the degree of emission limitation achievable through the application of the BSER for each type of unit; and how quickly and to what extent the measures encompassed by the building blocks could be used to reduce emissions. States will be required to submit a final plan, or an initial submittal with an extension request, by September 6, 2016. The types of plans and cost-effective strategies suggested for states to tailor their plans to meet their respective energy, environmental, and economic needs and goals, and those of their local communities is in the final sections.
  • Summary of Proposed Oil and Gas NSPS U.S. EPA promulgated an amended Standards of Performance for Crude Oil and Natural Gas Production, Transmission and Distribution (NSPS). Specifically, EPA proposed amendments to 40 Code of Federal Regulations (CFR) Part 60, Subpart OOOO and proposed an entirely new Subpart OOOOa. EPA also promulgated a draft control technique guidelines (CTGs) document for the oil and natural gas industry. The CTG is intended to provide state, local and tribal air agencies with information to assist them in determining reasonably available control technology (RACT) for reducing volatile organic compounds (VOC) emissions from select oil and natural gas industry emission sources in ozone nonattainment areas. Comments on the proposal are due November 17, 2015, and the final rules are slated to be promulgated in June 2016. Rule details are provided in the Technical Bulletin and table within the Technical Bulletin.

Clicking the title of each Technical Bulletin will take you to the full text. Each Bulletin may be shared, emailed, or printed.

 

About Pat Sullivan:

Pat Sullivan, Sr. VP, SCS Engineers
Pat Sullivan, Sr. VP, SCS Engineers

Pat Sullivan, BCES, CPP, REPA, is a Senior Vice President of SCS Engineers and our National Expert on the Landfill Clean Air Act and the New Source Performance Standard (NSPS). Mr. Sullivan has over 25 years of environmental engineering experience, specializing in solid and hazardous waste-related issues.

Click on Pat’s name to see his full qualifications and experience.

 

Posted by Diane Samuels at 6:31 pm

November 2, 2015

Transparency initiatives established by EPA as part of its Next Generation Compliance initiative mean increased reporting and recordkeeping for refineries.
Transparency initiatives established by EPA as part of its Next Generation Compliance initiative mean increased reporting and recordkeeping for refineries.

The U.S. Environmental Protection Agency (EPA) issued a final rule on September 29, 2015, seeking to further control emissions of hazardous air pollutants (HAPs) and volatile organic compounds (VOCs) from petroleum refineries.

This action finalizes the residual risk and technology review conducted for the petroleum refinery source category regulated under the National Emission Standards for Hazardous Air Pollutants (NESHAP; 40 CFR Part 63, Subpart UUU), including the refinery Maximum Achievable Control Technology Standard (MACT) 1 and Refinery MACT 2.

Click here to read the Technical Bulletin 

Posted by Diane Samuels at 2:10 pm

October 14, 2015

NWRA-logoToday, the National Waste & Recycling Association hosted a webinar concerning the revised NSPS (New Source Performance Standards for Landfills) Rule. EPA is revising the NSPS rules which will be tentatively published in the Fall, 2015. These rule changes may impact the way air emissions from landfills are being managed and is a significant change from 1996 published standards. During this informative session, attendees learned:

  • The specific changes the EPA is revising on NSPS and the impact on air emissions;
  • Tactics for landfill owners/operators to minimize the impact;
  • A better understanding of what the EPA constitutes as landfill gas.

If you missed this presentation, NWRA has granted SCS permission to post the slide show on our website. We welcome everyone to view the slide show and thank the NWRA for sponsoring the webinar. Webinar presenters include:

  • Pat Sullivan, Senior Vice President, and SCS National Expert – Landfill Clean Air Act; NSPS.
  • Niki Wuestenberg, Corporate Air Compliance Manager, Republic Services
  • Amy Banister, Senior Director of Air Quality, Waste Management

For more information and answers to your questions please contact Pat Sullivan, SCS Engineers or the webinar presenters.

Click for information about NSPS/NESHAP Compliance Services.

 

Posted by Diane Samuels at 4:19 pm

October 1, 2015

SCS Engineers’ Vice Presidents Tom Rappolt and Dan Johnson have collectively been named the 2015 IEA Associate of the Year by the Industrial Environmental Association (IEA) of San Diego. An award will be presented at the 31st Environmental Awards Luncheon on October 29, 2015, at the San Diego Convention Center.

IEA promotes responsible, cost-effective environmental laws and regulations, facilitates environmental compliance among member companies and provides educational activities for the San Diego community and Southern California.

“This award recognizes SCS Engineers’ many years of support for IEA and our mission,” said Meridith Marquis, President of IEA. “Several SCS staff members have provided critical technical expertise, helped IEA members and staff in evaluating the impacts of regulatory and legislative proposals, and actively participated in several IEA committees and conferences.”

Learn more about SCS Services by clicking here.

Posted by Diane Samuels at 6:01 am
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