environmental compliance

August 4, 2025

Congratulations to Gabrielle Stephens for her promotion to lead SCS’s Southwestern U.S. Air Compliance Group. She brings over two decades of client success to the role.

Greenhouse gas (GHG) reporting or verification, regulatory air compliance, and air permitting services fall within Ms. Stephens’ purview. She leads teams that support clients in the solid waste and manufacturing industries, who find value in having a regulatory liaison to navigate ever-changing federal, state, and local regulations. These teams help maintain efficient operations and enhance business communication with stakeholders.

Regulatory agencies often operate independently, and knowledgeable environmental consultants know how best to meet multiple agency data requirements, resulting in positive relationships between agencies and clients. SCS clients find that improved communication helps minimize or prevent permitting and compliance delays. Agencies, especially air district staff, can depend on the accuracy of Clean Air Act experts who are experienced with newer technologies proven to work, but potentially new in a district.

Ms. Stephens’ experience spans multiple states, numerous air districts and local enforcement agencies.

Beyond her work in air permitting and compliance, Ms. Stephens works on emissions estimates and inventories and has extensive experience preparing permit-to-construct/operate and Title V permit applications. She has also undertaken projects evaluating and reporting to meet the federal Greenhouse Gas (GHG) Rule and the AB 32 Landfill Methane Rule. Her collaborative efforts with the solid waste industry contribute to multiple facilities obtaining landfill gas-to-energy and RNG permits that positively impact air quality.

Ms. Stephens’ air compliance audits, permitting, and compliance reporting for manufacturing facilities, including fiberglass boats, product removers, ceramics, paper products, and cement/aggregates, help ensure regulatory compliance and improve operational efficiency.

We thank Gabrielle for her legacy of shared client successes and look forward to many more years of collaborative achievement!

 

Additional Clean Air Act Resources:

 

 

Posted by Diane Samuels at 6:00 am

July 28, 2025

Alert for industry to changes in regulations it must comply with.

 

Recently, Donald Trump issued four executive orders extending Clean Air Act – NESHAP compliance deadlines for a number of specific facilities that provide medical equipment sterilization, burn coal to make electricity, manufacture certain synthetic chemicals, or mine taconite. The big headline is the EPA announcing plans to rescind the ‘endangerment finding’ that allows climate regulation. However, at the same time coal combustion residuals rules are being changed. This Regulatory Alert contains language from the four executive orders, which includes a list of the specific facilities that have been granted extensions to comply. In each order, the President finds that the technology required is not available and that it is in the interest of national security to provide the extensions.

Normally there is a notice-and-comment rulemaking under the Administrative Procedures Act to extend deadlines. If the courts allow the President to continue invoking national security we may see more such executive orders modifying regulations. Follow SCS Engineers on social media to read our SCS Technical Bulletins, which summarize regulatory proposals and changes for public and private entities.

As the regulatory landscape continues to evolve, proactive planning is critical to preserving flexibility, value, and mitigating risk. We encourage businesses to consult with environmental engineers and consultants and their legal counsel to navigate these changes for continued sustainable success.

 

NESHAP – EtO Rule

On April 5, 2024, the Environmental Protection Agency published a final rule, pursuant to section 112 of the Clean Air Act, 42 U.S.C. 7412, titled National Emission Standards for Hazardous Air Pollutants:  Ethylene Oxide Emissions Standards for Sterilization Facilities Residual Risk and Technology Review, 89 FR 24090 (EtO Rule).  The EtO Rule imposes new emissions-control requirements on commercial sterilization facilities.

Certain stationary sources subject to the EtO Rule, as identified in Annex I of this proclamation, are exempt from compliance with the EtO Rule for a period of 2 years beyond the EtO Rule’s relevant compliance dates (Exemption).  This Exemption applies to all compliance deadlines established under the EtO Rule applicable to the stationary sources listed in Annex I, with each such deadline extended by 2 years from the date originally required for such deadline.  The effect of this Exemption is that, during each such 2-year period, these stationary sources will remain subject to the emissions and compliance obligations in effect prior to the issuance of the EtO Rule.  In support of this Exemption, I (Trump) hereby make the following determinations:

The technology to implement the EtO Rule is not available.  Such technology does not exist in a commercially viable form sufficient to allow implementation of and compliance with the EtO Rule by the compliance dates set forth in the EtO Rule. It is in the national security interests of the United States to issue this Exemption for the reasons stated in paragraphs 1 and 3 of this proclamation. Link

ANNEX I

International Sterilization Laboratory
Affected Facility/Source: Groveland Facility, Florida

Becton Dickinson and Company

Affected Facility/Source:

      1. BD Covington, Georgia
      2. BD Madison, Georgia
      3. BD Medical, Utah
      4. BD Medical Pharmaceutical Systems, Nebraska
      5. Edwards Lifesciences Technology Sàrl, Puerto Rico

KPR US, LLC d/b/a Kendall Patient Recovery
Affected Facility/Source: Augusta Facility, Georgia

MedXL, LLC

Affected Facility/Source: Ardmore Facility, Oklahoma

Aligned Medical Solutions

Affected Facility/Source:

      1. 1602 4th Ave. Facility, Billings, Montana
      2. 1400 Montana Ave. Facility, Billings, Montana

Professional Contract Sterilization, Inc.

Affected Facility/Source: Taunton Facility, Massachusetts

Sterigenics U.S., LLC

Affected Facility/Source:

      1. Atlanta Facility, Georgia
      2. Charlotte Facility, North Carolina
      3. Grand Prairie Facility, Texas
      4. 4900 S Gifford Ave. Facility, Los Angeles, California
      5. 4801-63 E 50th St. Facility, Los Angeles, California
      6. Ontario Facility, California
      7. Queensbury Facility, New York
      8. Salt Lake City Facility, Utah
      9. Santa Teresa Facility, New Mexico

Cosmed Group, Inc.

Affected Facility/Source:

      1. Erie Facility, Pennsylvania
      2. Franklin Facility, New Jersey
      3. Linden Facility, New Jersey

Arthrex

Affected Facility/Source: Ave Maria Facilities (2), Florida

Cook Incorporated

Affected Facility/Source: Ellettsville North Facility, Indiana

ALCON Research Ltd.

Affected Facility/Source: ALCON Advance Optic Device Center, North Facility, West Virginia

  1. Braun U.S. Device Manufacturing LLC

Affected Facility/Source: Allentown Manufacturing Facility, Pennsylvania

DeRoyal Industries, Inc.

Affected Facility/Source:

      1. 1135 Highway 33 South, New Tazewell, Tennessee
      2. 1211 Highway 33 South, New Tazewell, Tennessee

Sterilization Services of Georgia, Inc.

Affected Facility/Source: Atlanta Facility, Georgia

Sterilization Services of Virginia, Inc.

Affected Facility/Source: Richmond Facility, Virginia

Trinity Sterile, Inc.

Affected Facility/Source: Trinity Sterile, Inc., Maryland

LivaNova USA, Inc.

Affected Facility/Source: LivaNova Arvada Facility, Colorado

Covidien LP

Affected Facility/Source: Covidien North Haven Facility, Connecticut

Medtronic Xomed LLC

Affected Facility/Source: Jacksonville Facility, Florida

Medtronic Puerto Rico Operations Company, Inc.

Affected Facility/Source:

      1. Villalba Facility, Puerto Rico
      2. Juncos Facility, Puerto Rico

Advanced Product Solutions

Affected Facility/Source: Columbia Facility, Alabama

Affected Facility/Source: Salinas, Puerto Rico

Steri-Tech, Inc.

 

NESHAP – MATS Rule

On May 7, 2024, the Environmental Protection Agency published a final rule, pursuant to section 112 of the Clean Air Act, 42 U.S.C. 7412, titled National Emissions Standards for Hazardous Air Pollutants:  Coal- and Oil-Fired Electric Utility Steam Generating Units Review of the Residual Risk and Technology Review, 89 FR 38508 (Rule), which amended the preexisting Mercury and Air Toxics Standards (MATS) rule to make it more stringent.  The Rule’s effective date was July 8, 2024.  Id.  Its compliance date is July 8, 2027, 3 years after its effective date.  See 89 FR 38519.

Certain stationary sources subject to the Rule, as identified in Annex I of this proclamation, are exempt from compliance with the Rule for a period of 2 years beyond the Rule’s compliance date — i.e., for the period beginning July 8, 2027, and concluding July 8, 2029 (Exemption). The effect of this Exemption is that, during this 2-year period, these stationary sources are subject to the compliance obligations that they are currently subject to under the MATS as the MATS existed prior to the Rule.  In support of this Exemption, I (Trump) hereby make the following determinations:

a.  The technology to implement the Rule is not available.  Such technology does not exist in a commercially viable form sufficient to allow implementation of and compliance with the Rule by its compliance date of July 8, 2027.

b.  It is in the national security interests of the United States to issue this Exemption for the reasons stated in paragraphs 1 and 3 of this proclamation. Link

ANNEX I

Affected Facility/Source: Cardinal Unit 1, Unit 2, and Unit 3, Ohio

Tri-State Generation and Transmission Association

Affected Facility/Source: Craig Generating Station Unit 2 and Unit 3, Colorado

City Water, Light and Power

Affected Facility/Source: Dallman Unit 4, Illinois

Cardinal Operating Company

 

NESHAP – HON Rule

On May 16, 2024, the Environmental Protection Agency published a final rule titled New Source Performance Standards for the Synthetic Organic Chemical Manufacturing Industry and National Emission Standards for Hazardous Air Pollutants for the Synthetic Organic Chemical Manufacturing Industry and Group I & II Polymers and Resins Industry, 89 FR 42932 (HON Rule). The HON Rule imposes new emissions-control requirements on certain chemical manufacturing facilities, some of which were promulgated pursuant to section 112 of the Clean Air Act, 42 U.S.C. 7412.

Certain stationary sources subject to the HON Rule, as identified in Annex I of this proclamation, are exempt from compliance with those aspects of the HON Rule that were promulgated under section 112 of the Clean Air Act, 42 U.S.C. 7412 for a period of 2 years beyond the HON Rule’s relevant compliance dates (Exemption). This Exemption applies to all compliance deadlines established under the HON Rule applicable to the stationary sources listed in Annex I, with each such deadline extended by 2 years from the date originally required for such deadline. The effect of this Exemption is that, during each such 2-year period, these stationary sources will be subject to the emissions and compliance obligations that they are currently subject to under the applicable standard as that standard existed prior to the HON Rule. In support of this Exemption, I (Trump) hereby make the following determinations:

a.  The technology to implement the HON Rule is not available. Such technology does not exist in a commercially viable form sufficient to allow implementation of and compliance with the HON Rule by the compliance dates in the HON Rule.

b.  It is in the national security interests of the United States to issue this Exemption for the reasons stated in paragraphs 1 and 3 of this proclamation. Link

ANNEX I

  1. Shell Chemical LP
    i. Affected Facility/Source: Geismar Plant, Louisiana
  2. SABIC Innovative Plastics Mt. Vernon, LLC
    i. Affected Facility/Source: Manufacturing Plant, Indiana
  3. Bakelite Synthetics
    i. Affected Facility/Source:
    a. Riegelwood, North Carolina;
    b. Conway, North Carolina;
    c. Crossett, Arkansas;
    d. Louisville, Kentucky;
    e. Lufkin, Texas;
    f. Taylorsville, Mississippi
  4. The Dow Chemical Company
    i. Affected Facility/Source: Glycol II Plant, Louisiana
  5. Trinseo LLC
    i. Affected Facility/Source:
    a. Trinseo Facility, Georgia
    b. Trinseo Facility, Michigan
  6. Formosa Plastics Corporation, U.S.A.
    i. Affected Facility/Source:
    a. Formosa Plastics Corporation, Louisiana
    b. Formosa Plastics Corporation, Texas
  7. Union Carbide Corporation/The Dow Chemical Company
    i. Affected Facility/Source:
    a. Seadrift Operations, Texas
    b. Hahnville, St. Charles Parish Facility, Louisiana
  8. Westlake Vinyl’s LLC/Westlake Corporation
    i. Affected Facility/Source:
    a. Petrochemical Complex, Louisiana
    b. Styrene Monomer Production Facility, Louisiana
    c. Styrene Marine Terminal, Louisiana
    d. Lake Charles South Facility, Louisiana
    e. Lake Charles North Facility, Louisiana
  9. BASF TotalEnergies Petrochemicals LLC
    i. Affected Facility/Source: Port Arthur Facility, Texas
  10. BASF Corporation
    i. Affected Facility/Source:
    a. Geismar Facility, Louisiana;
    b. North Geismar Facility, Louisiana;
    c. Freeport Facility, Texas
  11. Rubicon LLC
    i. Affected Facility/Source: Geismar Facility, Louisiana
  12. CITGO Petroleum Corporation
    i. Affected Facility/Source:
    a. Lake Charles Refinery, Louisiana
    b. Corpus Christi Refinery, Texas
    c. Lemont Refinery, Illinois
  13. INEOS Americas LLC
    i. Affected Facility/Source: Bayport EO Plant, Texas
  14. Celanese Corporation
    i. Affected Facility/Source:
    a. Narrows Facility, Virginia
    b. Clear Lake Facility, Texas
    c. Bishop Facility, Texas
    d. Bay City Facility, Texas
  15. Huntsman Petrochemical LLC
    i. Affected Facility/Source:
    a. Huntsman Pensacola, Florida
    b. Huntsman Conroe, Texas
  16. TotalEnergies Petrochemicals & Refining USA, Inc.
    i. Affected Facility/Source:
    a. TotalEnergies Petrochemicals & Refining USA, Inc., Alabama
    b. Cos-Mar StyreneMonomer Plant, Alabama
    c. TotalEnergies Polystrene Plant, Louisiana
    d. Port Arthur Refinery, Texas
  17. Indorama Ventures Xylenes and PTA
    i. Affected Facility/Source: Decatur Facility, Alabama
  18. Denka Performance Elastomer LLC
    i. Affected Facility/Source: LaPlace Neoprene Production Facility, Louisiana
  19. Sasol Chemicals (USA) LLC
    i. Affected Facility/Source: Lake Charles Chemical Complex, Louisiana
  20. Philips 66 Company
    i. Affected Facility/Source:
    a. Sweeny Refinery, Texas
    b. WRB Refining LP Calvert Refinery, Illinois
    c. WRB Refining LP Borger Refinery, Texas
  21. Indorama Ventures Oxides, LLC
    i. Affected Facility/Source: Port Neches Facility, Texas
  22. Eastman Chemical Company
    i. Affected Facility/Source: Longview Facility, Texas
  23. DuPont Specialty Products USA, LLC
    i. Affected Facility/Source: Pontchartrain Site, Louisiana
  24. Stepan Company
    i. Affected Facility/Source: Millsdale Facility, Illinois
  25. Ascend Performance Materials Operations LLC
    i. Affected Facility/Source:
    a. Ascend Decatur, Alabama;
    b. Ascend Alvin, Texas;
    c. Ascend Pensacola, Florida

 

NESHAP – Taconite Rule

On March 6, 2024, the Environmental Protection Agency published a final rule, pursuant to section 112 of the Clean Air Act, 42 U.S.C. 7412, titled National Emission Standards for Hazardous Air Pollutants: Taconite Iron Ore Processing, 89 FR 16408 (Taconite Rule).  The Taconite Rule imposes new emissions-control requirements on taconite iron ore processing facilities.

Certain stationary sources subject to the Taconite Rule, as identified in Annex I of this proclamation, are exempt from compliance with the Taconite Rule for a period of 2 years beyond the Taconite Rule’s relevant compliance dates (Exemption).The technology to implement the Taconite Rule is not currently available, and it is necessary to issue this Exemption now because long design, permitting, and construction lead times mean that regulated entities will not be able to meet the relevant compliance deadlines absent compliance relief. This Exemption applies to all compliance deadlines established under the Taconite Rule, with each such deadline extended by 2 years from the date originally required for such deadline. The effect of this Exemption is that, during each such 2-year period, these stationary sources are subject to the emissions and compliance obligations that they are currently subject to under the applicable standard as that standard existed prior to the Taconite Rule. In support of this Exemption, I (Trump) hereby make the following determinations:

a.  The technology to implement the Taconite Rule is not available.  Such technology does not exist in a commercially viable form sufficient to allow implementation of and compliance with the Taconite Rule by the compliance dates in the Taconite Rule.

b.  It is in the national security interests of the United States to issue this Exemption for the reasons stated in paragraphs 1 and 3 of this proclamation. Link

ANNEX I

  1.  United States Steel Corporation
    i.    Affected Facility/Source:
    i.    Keetac Plant, Keewatin, Minnesota
    ii.   Minntac Plant, Mountain Iron, Minnesota2.    Cleveland-Cliffs Inc.
    i.    Affected Facility/Source:
    i.    United Taconite, Minnesota
    ii.   Northshore Mining, Minnesota
    iii.  Hibbing Taconite, Minnesota
    iv.   Minorca Mine, Minnesota
    v.    Tilden Mine, Michigan
    vi.   Empire Mine, Michigan

 

 

Posted by Diane Samuels at 6:00 am

July 21, 2025

capturing and sequestering CO2

On April 17, 2025, the U.S. Environmental Protection Agency (EPA) announced it will extend the compliance deadlines for coal combustion residual (CCR) management unit (CCRMU) requirements. This action will allow facilities to submit both sections of the Facility Evaluation Report simultaneously, provided that both reports are turned in no later than February 8, 2027. 

EPA is also extending the groundwater monitoring requirements for owners or operators of coal combustion residual management units until August 8, 2029. Because the Facility Evaluation Report and groundwater monitoring requirements are necessary for compliance with other CCRMU requirements, EPA is aligning these remaining CCRMU compliance deadlines.

EPA has proposed to approve North Dakota’s CCR program application, which would allow the state to manage coal ash disposal in surface impoundments and landfills. EPA is also working with Wyoming and other states as they seek to manage their CCR programs without federal oversight.

EPA is accepting comments for 30 days after publication in the Federal Register. Unless EPA receives adverse comments, this final rule will be effective six months after publication in the Federal Register.

Additional Resources: 

 

 

 

Posted by Diane Samuels at 6:00 am

July 18, 2025

The U.S. meat and poultry industry generates slaughterhouse waste (SHW) as a by-product, which is converted into additional products through the rendering process to minimize waste. Although rendering generates sellable commodities, Anaerobic Digestion (AD) is a proven, scalable technology for offsetting energy-intensive processes and minimizing FOG and contaminants in wastewater. AD can provide new opportunities for onsite waste management paired with renewable energy production and biogas potential for thermal energy, electricity generation, and renewable natural gas (RNG) to offset operating costs.

The EPA’s proposed Effluent Limitations Guidelines (ELGs) will require that facilities add biological treatment, creating a new waste stream (waste biosolids) that could be managed along with other slaughterhouse wastes via anaerobic digestion.

SCS Engineers presents a free educational forum explaining the opportunities for the meat and poultry industry and how to determine if AD is feasible to help your operation reduce energy costs with biogas production and enable nutrient recovery while reducing wastewater contamination. We’ll cover:

  • New opportunities for onsite waste management paired with renewable energy production.
  • Biogas potential for thermal energy, electricity generation, and renewable natural gas (RNG).
  • How processing/slaughterhouse wastes can be ideal feed substrates for anaerobic digestion.
  • Conditions and considerations that impact performance.
  • The next logical steps to determine feasibility and economic benefits.

Live Virtual Event Thursday, August 21, 2025
1:00 PM ET | Noon CT | 11:00 AM MT | 10:00 AM PT

REGISTER HERE FOR Anaerobic Digestion Feasibility for the Meat and Poultry Industry

 

Erik AndersonMeet Dr. Erik Anderson, a senior SCS Liquid Management team member and a National Expert in AD. He has 15 years of experience in process design related to biomass engineering, specifically anaerobic digestion and other waste-to-energy systems. His work includes modeling biomass technologies for performance, cost, and economic evaluation or life-cycle analysis, combining material testing and/or pilot-scale testing for more value.

CAN’T MAKE THE LIVE SESSION? RSVP AND WE’LL SEND YOU THE RECORDING.

Additional ELG Resources: 

 

 

 

Posted by Diane Samuels at 4:04 pm

July 16, 2025

Amendment to existing Virginia regulations regarding the use of emergency power generators (EPGs) at certain military installations; 9VAC5-80-1111 of 9VAC5-80; 9VAC5-540-40 of 9VAC5-54

The Virginia Department of Environmental Quality (DEQ) recently approved amendments to the Emergency Power Generator (EPG) regulations that apply to certain military installations. The amendments will provide greater flexibility with respect to the operation of mission-critical EPGs at Department of Defense (DoD) facilities for non-emergency purposes, including up to 50 hours per year for planned outages, switch gear, and related electrical system testing.

The amendment should not have an impact on EPG permitting. Nonetheless, we suspect the amendment may interest EPG operators at DoD facilities in Virginia.

Implementation of the amendments is consistent with the U.S. Environmental Protection Agency’s National Emissions Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines pursuant to 40 CFR Part 63 Subpart ZZZZ and New Source Performance Standards pursuant to 40 CFR Part 60 Subparts IIII and JJJJ.

As noted in 9 VAC 5-80-1111, DoD facilities that desire to take advantage of the increased operational flexibility must first certify their EPGs per 9VAC5-20-230.

The amended regulation published in the Virginia Register on July 14, 2025. Additional details, including the revised regulation (track changes employed to highlight amendments), are available at: https://townhall.virginia.gov/l/ViewStage.cfm?StageID=10796

If you have a question pertaining to the amendments, please contact SCS Engineers.

 

 

 

Posted by Diane Samuels at 6:00 am

July 14, 2025

RMC
SCSers Dana Sedillo, Melissa Russo, and Evelyn Martinez demonstrating industrial remote control technology.

 

Remote Monitoring and Control Return on Investment Based on Case Studies in the U.S.

Environmental and industrial operators face mounting pressures from complex issues like tightening regulations, rising compliance costs, persistent labor shortages, and aging infrastructure. In this environment, traditional monitoring and maintenance methods, such as manual readings, paper logs, and in-person inspections, often fail to meet the demands of modern operations.

Facilities increasingly adopt Remote Monitoring and Control (RMC) systems to bridge the gap. RMC systems, originally developed to support gas and liquid management in the waste sector, now play a critical role in automating environmental compliance, optimizing equipment performance, and delivering real-time data insights across various facility types. These technologies deliver continuous data, enable remote access, and support faster, more informed decision-making. From pump stations and blowers to temperature and emissions monitoring, the shift to RMC offers not just better oversight but substantial cost savings.

Here, we highlight three real-world case studies where RMC deployments led to measurable financial return on investment and operational gains.

Cutting Air Monitoring Costs at an Industrial Facility

Air monitoring is critical to environmental compliance for landfills, renewable natural gas (RNG) operations, and solid waste facilities. These sites can emit volatile organic compounds (VOCs) and hazardous air pollutants (HAPs) through various processes, including waste decomposition, gas destruction, and material handling. Regulatory agencies require continuous or periodic monitoring to assess pollutant levels, ensure public health protection, and enforce site-specific permit conditions. Failure to comply can result in substantial fines, heightened regulatory scrutiny, and reputational harm.

Regulators required continuous air quality monitoring for a volatile organic compound and a hazardous air pollutant at one industrial site. Manual sampling, performed daily, was costing the facility roughly $1,000 per day. Compliance was non-negotiable, but the cost was becoming unsustainable.

SCS Engineers installed a $90,000 RMC air monitoring system with seven wireless air sensors and a meteorological station. The system automates alarms, regulatory reporting, and historical data logging, all now accessible in real-time.

Within three months, the system paid for itself and saves the client an estimated ~$365,000 annually. Beyond that, it provides peace of mind. Since the system was implemented, the site has avoided regulatory fines, thanks partly to the transparent, consistent data reporting regulators now receive automatically.

Preventing Leachate Tank Overflows and Overbilling

Leachate is the liquid that drains from or through a landfill and contains a complex mix of organic and inorganic compounds, including heavy metals, ammonia, and pathogens. If not properly managed, leachate can contaminate groundwater, damage infrastructure, and trigger costly environmental violations. Closed, unstaffed landfills continue to generate leachate that must be regularly monitored, stored, and hauled away for treatment. Regulatory requirements typically mandate accurate volume tracking, overflow prevention, and timely reporting to demonstrate compliance and mitigate risk.

One SCS client operated a closed landfill with an above-ground leachate tank. With no staff on-site, they faced two persistent problems: haulers had no visibility into daily volumes, leading to inefficiencies and billing confusion, and during winter, the risk of frozen pipes or tank overflow posed serious compliance and environmental hazards.

 

An example schematic of a leachate tank and pump system. The primary components include a wet well (manhole) and submersible pump, an above-ground storage tank, a discharge pump, and two flow meters. Liquids from the landfill are pumped and drained into the manhole; from there, they are pumped into the above-ground storage tank. The leachate is pumped out of the above-ground storage tank and into trucks that haul the leachate off-site for disposal.

 

For $30,000, SCS implemented an RMC system that provided haulers with mobile access to real-time tank levels and flow data, saving the client an estimated $10,000+ annually. Adding new alarms to flag leaks, freezing temperatures, and meter fouling, problems that had previously gone undetected until damage occurred, led to an increase in the efficiency of hauler dispatching, the elimination of billing disputes, and the prevention of at least one major overflow event by the early warning system. “Without a doubt, the system paid for itself through reduced O&M costs and prevented environmental issues,” said one SCS project manager, who quoted an ROI of roughly 1.5 to 3 years, depending on site-specific variables for a system like this.

Automating Flare Restarts at a Closed Landfill

Gas collection and control systems are essential at landfills to manage the decomposition of organic waste, which generates methane, a potent greenhouse gas. Flares are a critical component of these systems, used to combust excess landfill gas and maintain regulatory compliance with air quality and greenhouse gas standards. Reliable flare operation is not only required by permits but also essential to prevent the accumulation of subsurface pressure and potential emissions. Frequent flare-outages can result in safety concerns, odor complaints, noncompliance penalties, and costly emergency callouts. At unstaffed or remote landfills, delays in flare restarts can be especially expensive and disruptive.

Flare Remote Monitoring Screen

 

At a separate closed landfill, the client spent as much as $35,000 monthly on callouts to manually restart a flare system that frequently shut down due to power fluctuations. Each visit required a time-consuming and costly process in which an employee was required to drive to the site, reset the system, and monitor the restart.

SCS installed an RMC solution costing approximately $85,000, enabling remote flare monitoring, alarm, and restart. With the new system in place, staff could respond immediately from any connected device, eliminating the need for site visits.

The anticipated monthly savings? Roughly $30,000. The investment was a clear financial win with a projected payback period of less than three months.

Efficiency That Pays for Itself

As environmental compliance becomes tighter, labor markets shift, and equipment costs rise, operational efficiency is no longer a luxury; it’s a necessity. Whether you’re operating a landfill, a manufacturing facility, or an industrial site, the pressures are the same: reduce costs, maintain compliance, protect your workforce, preserve your infrastructure, and get a return on your investment.

RMC systems address all these pressures simultaneously. From automated gas monitoring at a landfill to VOC and HAP air monitoring at a facility to liquid hauling validation at an industrial facility, RMC systems are helping operators transform data into action and costs into savings.

In industries where budgets are scrutinized and return on investment must be proven, RMC makes a compelling case. It’s a solution that pays for itself, sometimes within months, while laying the foundation for long-term performance and resilience. The opportunity to modernize and save is right at your fingertips.

 

Facility Technology Resources:

 

 

Posted by Diane Samuels at 6:00 am

June 12, 2025

Alert of regulatory changes or proposed changes for municipalities and industry.

Power Plants: 40 CFR Part 60, [EPA-HQ-OAR-2025-0124; FRL-12674-01-OAR], RIN 2060-AW55

On Wednesday, June 11, 2025, the U.S. Environmental Protection Agency (EPA) proposes repealing all greenhouse gas (GHG) emissions standards for fossil fuel-fired power plants. The EPA proposes that the Clean Air Act (CAA) section 111 requires it to find that GHG emissions from fossil fuel-fired power plants contribute significantly to dangerous air pollution as a predicate to regulating GHG emissions from those plants, which the current administration does not agree with.

The EPA is further proposing to make a finding that GHG emissions from fossil fuel-fired power plants do not contribute significantly to dangerous air pollution.

The EPA is also proposing, as an alternative, to repeal a set of requirements that includes the emission guidelines for existing fossil fuel-fired steam generating units, the carbon capture and sequestration/storage (CCS)-based standards for coal-fired steam generating units undertaking a large modification, and the CCS-based standards for new base load stationary combustion turbines.

EPA is proposing to repeal certain amendments issued in 2024 to the National Emission Standards for Hazardous Air Pollutants for Coal- and Oil-Fired Electric Utility Steam Generating Units – a rule commonly known as the Mercury and Air Toxics Standards for power plants, or simply MATS. This proposal would revert to 2012 standards for air toxic pollutants from coal- and oil-fired power plants.

This action proposes to relieve all facilities of the more stringent filterable particulate matter (PM) emission standard for coal-fired EGUs, the tighter mercury standard for lignite-fired EGUs, and the requirement to use PM Continuous Emissions Monitoring Systems (CEMS).

Comment Period

Public and industry comments must be received on or before 45 days following publication in the Federal Register. This document is a prepublication version, signed by EPA Administrator Lee Zeldin on 06/11/2025. While the EPA has taken steps to ensure the accuracy of this version, it is not the official version.

The EPA will hold a virtual public hearing in the future. You may send comments identified by Docket ID No. EPA-HQ-OAR-2025-0124, using these channels as follows:

All submissions received must include the Docket ID No. for this rulemaking. Comments received may be posted without change to https://www.regulations.gov, including any personal information provided.

 

Please get in touch with SCS Engineers with questions pertaining to your power plant operations or facilities. Thank you. We will post regulatory updates in more detail as they unfold.

Posted by Diane Samuels at 6:00 am

June 2, 2025

Join SCS Engineers as Sponsors and Exhibitors at the IEA’s Annual Environmental Training Symposium & Conference on June 5th at the San Diego Mission Valley DoubleTree by Hilton in San Diego. For over 40 years, this event has excelled in providing a balance of valuable information, including environmental compliance guidance, and regulatory and legislative updates.

The conference attendees consist of environmental, health, and safety professionals, NGO representatives, environmental engineers, environmental consultants and attorneys, and government affairs representatives. These participants represent manufacturing, biotech, and high-tech companies, as well as the Department of Defense, and federal and state regulators.

The 20+ conference sessions vary from year to year depending on current legislation and regulations.

Posted by Brianna Morgan at 3:05 pm

May 28, 2025

John Tsun joins SCS Engineers
John Tsun joins SCS Engineers.

 

SCS Engineers is pleased to welcome John Tsun as its National Industrial Clean Air Act (CAA) Practice Leader. In his role, John will focus on increasing SCS’s services to both public and private sectors related to evolving regulatory policies stemming from the Clean Air Act (CAA). John will be based out of SCS’s Suffern, NY office, serving clients along the eastern seaboard and nationwide.

Mr. Tsun brings over three decades of extensive experience and qualifications in environmental engineering, air quality services, and regulatory compliance. His background includes managing air permitting and compliance projects for sectors including, but not limited to, petroleum, pharmaceutical, chemical, and power-generation facilities and governmental agencies. His specialization is in air-quality-related solutions that include regulatory compliance audits, emissions inventories, emissions control selections, permitting strategies, ambient air-quality monitoring, air dispersion and consequence modeling, soil vapor dispersion modeling, vapor intrusion barrier installation, vapor intrusion sampling, vibration monitoring, bi-axial tilt monitoring, and noise monitoring.

Mr. Tsun is knowledgeable in regulatory applicability, such as New Source Review and Prevention of Significant Deterioration, preparing air permit applications such as Title V computer simulation modeling, and compliance reporting. For our clients, Mr. Tsun’s experience translates into streamlined permits and compliance obligations that are practical while controlling emissions appropriately. These comprehensive attributes are particularly important to SCS Engineers with in-house resources to navigate the permitting process, secure the necessary approvals, and offer solutions that save time and money.

For many industries, CAA is critical because the evolution of regulations impacts capital expenditures, especially those with older facilities, which may be required to install pollution control technologies or upgrade equipment to meet current emission standards. Consequently, implementing and maintaining pollution controls increases operating costs if the environmental solutions are not identified and planned sustainably.

Air permitting is often the critical path element in a construction schedule for new facilities and must be completed before construction can commence. Guiding clients through properly identifying emission sources and inventories, selecting proper control technologies, and efficient modeling will minimize timelines that are important for construction timelines when “speed-to-market” is crucial.

“Our clients face ever-increasing challenges and scrutiny in complying with various State and Federal air and other environmental regulations. John has decades of proven experience helping clients successfully navigate these challenges. We are delighted to have him join our team and expand the CAA services we offer our clients,” SCS Engineers Senior Vice President Michael Miller says.

 

Clean Air Act Resources:

 

 

 

Posted by Diane Samuels at 11:10 am

April 1, 2025

Join SCS Engineers at the Environment, Labor & Safety+ Conference (ELS+) on April 21-23 at the Omni Charlotte Hotel in Charlotte, NC. The ELS+ Conference is a vital platform for safety, environmental compliance, and HR professionals in the meat and poultry industry.

The conference tackles emerging trends and real-world challenges by delivering practical, actionable insights that help you keep your workforce safe, facilities compliant, and teams engaged. Attendees will benefit from a collaborative, confidential environment where they can exchange strategies, discuss challenges, and learn from industry peers.

ELS+ equips you with tools, knowledge, and talking points to bring back to your plant, helping you drive real, positive change. Whether you’re managing safety programs, navigating complex environmental regulations, or leading HR initiatives, this event offers the expertise and connections you need to succeed.

Click here to register and connect with SCS Engineers at ELS+ to move your team and your company forward.

Posted by Brianna Morgan at 11:24 am
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