compliance

December 20, 2017

By keeping open lines of communication between industry stakeholders and the U.S. EPA at a federal level, both parties have been able to improve the quality of GHG emissions data reported under the GHGRP while reducing the monitoring burden.

Read this SCS Engineer’s abstract that discusses the cooperation between the U.S. Environmental Protection Agency (EPA) and solid waste industry stakeholders in developing, revising, and implementing the landfill reporting requirements as part of the federal GHG Reporting Program (GHGRP) (40 CFR Part 98). The paper covers:

  • Outreach in early stages of the GHGRP development through recent decisions to utilize GHG emissions data from the GHGRP in the EPA’s current draft Inventory of U.S. Greenhouse Gas Emissions and Sinks: 1990-2015 (GHG Inventory).
  • The initial implicit assumptions made by both the EPA and Stakeholders, using the reporting of “back-up devices” and the calculation of the fraction of time a destruction device was operating as an example of the assumptions made and an illustration of how those assumptions were implemented implicitly in the GHGRP.
  • How stakeholders have reached out to the EPA to address incorrect or misleading assumptions.
  • A summary of how stakeholders work to provide the EPA with additional data necessary to justify changes to the regulation, including revisiting oxidation factors that were rejected in the initial GHGRP and reducing methane measurement frequency at landfills.
  • How changes have improved landfill reporting under the GHGRP to make it more representative of actual emissions and more reflective of the sites that are reporting.
  • The unintended consequences of stakeholder outreach and revisions to the GHGRP for landfills.

 

Click here to read the paper.

 

Posted by Diane Samuels at 6:03 am

November 28, 2017

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

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

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

Read the full article.

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

 

 

 

 

Posted by Diane Samuels at 6:00 am

October 23, 2017

They all use permitted grain elevators. According to Reuters, in 2017, the United States had 25 billion US bushels of storage capacity, a growth of 25% in the previous decade. Reuters Business News, April 11, 2017. There are a myriad of safety and permitting requirements for grain elevators; this article lists a few in Wisconsin.

Securing the proper air permits helps safeguard these facilities against the legal, financial, and reputational risks of non-compliance. The air permitting process can be complicated, but there are tools and people that can help.

Environmental engineering firms help guide companies through the process and offer direct support. States provide tools and support such as the self-serve tools on the WDNR website, for example, to help determine what level of permitting is applicable too. These State environmental sites provide the necessary permitting forms and backup calculations specific to the type of permit your facility may need to apply for. You may be able to submit an application online, and a certified engineer can do that for you as part of a permitting plan.

If you find the sites and requirements perplexing, ask a qualified environmental engineer to help. SCS Engineers professionals are recognized for their environmental permitting knowledge and are available to answer questions.

Learn more about air-permitting in Wisconsin or contact one of SCS Engineers’ local offices in a region near your facility.

 

 

 

 

Posted by Diane Samuels at 6:00 am

September 27, 2017

Tuesday, October 10, 1:00 pm – 2:30 pm ET

This Air & Waste Management Association webinar covers the effective, sustainable operation of municipal solid waste (MSW) landfills in today’s changing environment.

The latest updates to EPA regulations in over two decades limiting air emissions from landfills will be reviewed in detail.

Participants will learn the available models for quantifying landfill gas generation emissions and which model to use in different situations as well as energy recovery from landfill gas, its emissions, and how control requirements can affect feasibility.

Posted by Diane Samuels at 6:01 am

August 8, 2017

MasterMold, LLC makes component parts for manufacturers of recreational vehicles, utility equipment, and agricultural equipment who use the components in their end products. Because of the wide variety of industries and customers it serves, MasterMold must be poised to respond to its customers’ growth by increasing production levels on demand.

There is a solution.

Executive Vice President Jon Butts manages environmental compliance at three production facilities. “Environmental management is just one of the many hats I wear,” says Butts. MasterMold has multiple environmental needs. Permitting is high on Butts’ list, and so is passing routine inspections.

To help MasterMold meet its environmental compliance needs, the SCS Engineers team assessed the company’s air permitting needs with an eye toward future increases in customer demand. The team helped turn around a permit application quickly so MasterMold could continue to meet its customers’ production expectations without interruption and remain compliant with environmental rules and regulations. Butts stated:

Then SCS Engineers helped me collect and organize data for emission calculations in one place. They created an easy-to-use tool that my staff updates monthly so we’re prepared for an on-site inspection anytime. I can demonstrate compliance, pass inspections quickly, and get back to focusing on my customers.

Butts got the opportunity to test the new tool during the company’s latest inspections. MasterMold has undergone routine inspections by the Wisconsin Department of Natural Resources (WDNR) and the U.S. Environmental Protection Agency (USEPA). Both agencies checked the company’s compliance status with its air permit at its largest plants. “I had everything organized right at my fingertips,” Butts says. “I was ready for the inspections. I now know exactly where all of our emissions come from and exactly how they change over time.”

The excellent results of MasterMold’s latest inspections say it all and SCS is grateful for the chance to help businesses with complex environmental challenges.

Thanks to the tool SCS Engineers helped me build, MasterMold passed its latest inspections in just a few hours with no citations. I’m confident I will pass on-site inspections and gain and grow inspectors’ trust in MasterMold’s business practices. Now I’m in a position to influence the process, take proactive steps, and partner with my inspector instead of responding reactively.

—Jon Butts, Executive Vice President, MasterMold, LLC | Johnson Creek, WI

 

 

Posted by Diane Samuels at 6:03 am

June 20, 2017

Jared Omernik suggests following five steps to prevent environmental contamination at mixing and loading pads, or mix/load pad for short. Follow Jared’s tips to achieve compliance, limit your environmental liability, and keep your operations running smoothly.

Read the article in the summer 2017 edition of the Wisconsin Agribusiness News Quarterly

 

Posted by Diane Samuels at 6:04 am

May 17, 2017

Oil and gas processing facilities, federal and local governments, landfills, land developers, contractors, industries with industrial hygiene plans can spend too much money for too little information if they don’t have an understanding of the limits and capabilities of their equipment and methods before the development of their Air Monitoring Plan (AMP) . That’s before considering the risk to their employees and to public health.

Even if you can’t afford a dedicated air monitoring group, you can eliminate the health risks, overwriting a plan, or overburdening your budget. A cost-benefit analysis and integrating stakeholders’ goals can help provide the guidance you need to develop a balanced air monitoring plan.

Start with this list of considerations when developing an Air Monitoring Plan (AMP). The list is followed by tips and suggestions which are helpful under specific circumstances.

The development of an AMP requires the following:

  • Understanding the monitoring objective(s).
    • Compliance Monitoring for Specific Compound(s)
    • Employee Health and Safety
    • Prevention of Significant Deterioration (PSD) Monitoring
    • Fence-line Job Site Monitoring
    • Active Dust Control
    • Source Related or Regional Monitoring
    • Determination of highest concentrations expected to occur
  • Identifying the spatial scale most appropriate for the monitoring objective(s).
    • Sampling Site Density
    • Upwind and Downwind Monitoring
    • Background Monitoring
  • Determination of the required temporal scale of the monitoring objectives:
    • Time-averaged Sampling and/or Real Time Monitoring
    • Desired Averaging Periods
    • Grab Samples
  • Determination of most appropriate monitoring equipment to be utilized.
    • Desired Detection Limits
    • Data Logging Required
    • Site Access Limitations
    • Power Availability
    • Real-Time Alarms if Needed
    • Meteorological Parameters

The information required for selecting the number of samples (5) and the sample locations include isopleth maps, population density maps, and source locations. The following are suggested guidelines:

  • The priority area is the zone of highest pollution concentration expected to occur in the area covered by the network; one or more stations should be located in this area;
  • Close attention should be given to densely populated areas within the region, especially when they are in the vicinity of heavy pollution;
  • The quality of air entering the region should be assessed by stations situated on the periphery of the region; meteorological factors (e.g., frequencies of wind directions) are of primary importance in locating these stations;
  • Sampling should be undertaken in areas of projected growth to determine the effects of future development on the environment;
  • A major objective of compliance monitoring is the evaluation of progress made in attaining the desired air quality; for this purpose, sampling stations should be strategically situated to facilitate evaluation of the implemented control strategies; and
  • Some information of air quality should be available to represent all portions of the region of concern.

 

The primary monitoring objectives should be determined before any data is collected.

 

Location of the monitoring site is initially dependent on the monitoring objective. For example, once it is known that there is a requirement to monitor for peak ambient H2S at a microscale site, it reduces the monitoring site location to specific areas. Hence, the first task when evaluating a possible site location is to determine the scale for which a candidate location can qualify by considering the following:

1. Location and emissions strengths of nearby sources, especially major source;
2. Prevailing wind direction in the area;
3. Nearby uniformity of land use;
4. Nearby population density.

To select locations according to these criteria, it is necessary to have detailed information on the location of emission sources, the geographical variability of ambient pollutant concentrations, meteorological conditions, and population density. Therefore, selection of the number, locations, and types of sampling stations is a complex process. The variability of sources and their intensities of emissions, terrains, meteorological conditions and demographic features require that each network is developed individually. Thus, selection of the network will be based on the best available evidence and on the experience of the decision team.

Developing an Air Monitoring Plan (AMP) can be a daunting task. There are many decisions to make that have downwind ramifications relative to budget, logistical constraints, and labor requirements. In addition, there may be competing goals in regards to the project stakeholders. SCS has the experience developing and implementing air monitoring plans and systems to meet these challenges; including developing site specific and network-wide AMPs for various monitoring objectives. SCS also understands the costs and demands of the implementation of AMPs on industry and government.

 

Performing a cost-benefit analysis is a crucial step in the AMP development in order to assure that the required data is attainable within the budget constraints.

 

If you need to perform Air Monitoring or are in the initial steps of developing an AMP please contact for expert advice and guidance specific to your region and industry. We have robust programs and experts nationwide. We can also incorporate the use of remote monitoring controls and monitoring by our FCC authorized drones.

Author: Paul Schafer, SCS’ National Expert Ambient Air Monitoring

 

 

 

 

 

Posted by Diane Samuels at 6:00 am

May 15, 2017

To Our ClientsThanks to you, our clients, SCS Engineers has received many awards and industry recognitions for research achievements and technology innovations. Engineering News-Record (ENR) recently released the Top 500 Design List, ranking SCS Engineers in the top 100 for the 9th year in a row. In the same publication, SCS is ranked in the Top 10 Sewerage/ Wastewater Firms.

Thank you for your friendship, your business, and the opportunity to serve you.

 

 

 

 

 

 

Posted by Diane Samuels at 6:00 am

April 26, 2017

Imagine that one of your employees comes and tells you that a 100-gallon spill just took place at your facility and it is flowing swiftly toward a storm sewer on your property.

Suddenly all eyes are on you. What you do next will show your leadership and skill at addressing the issue and limiting the company’s liability. Are you ready to be the hero, or is spill preparedness the one item that just keeps slipping down your to-do list?

Use the techniques recommended in Chris Jimieson’s latest article to make your spill response training engaging and interactive for staff handling oil. Spill preparedness becomes part of your routine and you’re ready to be the hero if a spill occurs.

Improve Your Spill Preparedness

 

Posted by Diane Samuels at 6:00 am

February 27, 2017

 

Follow these tips to save time and money on the next five-year update of your facility’s SPCC Plan.

 

Are you approaching the required five-year review/plan re-certification for your facility’s Spill Prevention, Control, and Countermeasure (SPCC) Plan? Even if you’ve been through several cycles of performing five-year tune-ups on your SPCC Plan, you can make your next review easier and prepare yourself for future SPCC Plan re-certifications if you follow these five tips.

Start Early
Late renewals are a consistent pain point for many companies. To avoid being late with your next re-certification, start your review six months before your SPCC Plan is due for its 5-year review. If you are conducting the review internally, start by identifying the person who will be doing the review. If you are using a third party, this approach will help you go through the proposal/contracting process, so you are ready to conduct the actual review and complete the re-certification before the Plan expires.

Simplify Data Collection
One of the keys to a compliant SPCC Plan is to collect accurate data in the field about your facility’s oil sources. Streamlined data collection is of particular importance if you have a large facility or your oil storage changes regularly. The key to simplifying data collection is to make sure your reviewer has organized information to evaluate the compliance aspects of each source. Accurate data collection can limit the follow-up required from plan preparers to verify information, as well as minimize the potential for discrepancies. Moreover, particularly useful if a third party is auditing your Plan or if it is in review during an EPA inspection.

Reduce Redundancy with a Summary Table
One way to simplify your Plan is to use an oil source summary table to cover as much information as possible. A table can include each oil source and the aspects of how the oil source is compliant with the SPCC Rule. There may be areas in the Plan where you need to provide additional text discussion regarding oil sources to explain a compliance matter. In general, try to avoid duplicating information within the Plan.

Watch Out for Commonly Overlooked Areas
While secondary containment and overfill protection are key elements to review at each oil source, some reviewers forget to measure the size of containment structures. Dimensions need to be carefully measured in the field to verify and show sufficient secondary containment capacity in your facility’s SPCC Plan.
Another commonly overlooked area is facility drainage; specifically the overland flow in the proximity of each oil source, which is key to determining the potential receptors where spilled product can travel. These receptors could be storm sewers, ditches, wetlands, or waterways. You can discuss the protection of these receptors during your facility’s annual SPCC training. Swift action and concise communication during a spill can help limit your liability.

Use Targeted Annual Training
Many companies struggle to comply with the annual training requirement. One of the tripping points is trying to train all employees who handle oil for example. To avoid this pitfall, implement a tiered training program so you can focus the training content based on an employee’s responsibility level.

Spill recognition and notification through proper internal channels to get a spill cleaned up is an essential message for employees that occasionally handle oil. These employees could also be trained to aid with the initial control and response to a spill. A second tier may include team members who manage the SPCC Plan; they have additional responsibilities such as inspections of oil sources and spill reporting.

By Chris Jimieson, SCS Engineers

Chris Jimieson has over 17 years of experience supporting industrial, commercial, military, federal, state, municipal, and solid waste companies with environmental compliance.  He has extensive experience building and reviewing SPCC and Storm Water Pollution Prevention Plans (SWPPP) and manages compliance assignments, providing computer-based training modules to meet employer training needs. Contact Chris at or 608-216-7367.

SCS Compliance Services

Posted by Diane Samuels at 3:00 am
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