environmental compliance

June 12, 2024

Toxics Release Inventory Compliance
Including additional PFAS data in TRI reporting places a greater compliance burden on many industries; this video and free educational resources step you through the process this year and next.

 

On May 17, 2024, the U.S. Environmental Protection Agency (EPA) expanded its Toxic Release Inventory (TRI) program to include seven additional per- and polyfluoroalkyl substances (PFAS), raising the total number of PFAS tracked under the TRI to 196 to report in 2025 for the year 2024—the PFAS to report on for 2023 on July 1, 2024 numbers 186.

This decision, mandated by the 2020 National Defense Authorization Act (NDAA), which requires annual updates to the PFAS list in the TRI, reflects ongoing efforts to monitor and manage environmental exposure to these persistent chemicals.

The EPA removed the de minimis exemption for PFAS under the “chemicals of special concern” category as of October 2023. This elimination underscores the increased regulatory focus on these substances due to their environmental and health risks, thereby intensifying the demands on facilities to track and report PFAS handling accurately. This ongoing regulatory evolution highlights the increasing scrutiny and accountability for environmental stewardship concerning PFAS.

SCS’s educational  video Toxics Release Inventory Reporting explains how to identify and quantify facilities subject to TRI reporting, including:

  • Those having ten or more full-time employee equivalents (calculated using a specific method).
  • Manufacture or process listed PFAS or PBTs during the calendar year.
    • Per- and polyfluoroalkyl substances (PFAS) will no longer have a de minimis concentration as of January 1, 2024, for the report due July 1, 2025.
    • Thresholds are established for TRI reports due July 1, 2024.
    • Persistent bioaccumulative toxins (PBTs) do not have a de minimis concentration.

Facilities must start compiling historical and new information to meet compliance requirements. The educational video covers the reporting thresholds and tips for collecting the data, calculating usage, and determining which form to report to the EPA. Some facilities accidentally overreport, so our expert tells you how to avoid this mistake.

Including additional PFAS in the TRI places a greater compliance burden on many industries. Companies must adapt by implementing more rigorous tracking systems and investing in technologies to reduce PFAS emissions or discharges.

Tracking specific product formulations is more important than ever. Safety Data Sheets (SDS) and historical reporting are a good place to start. Still, our expert explains how to minimize your facility’s risk of non-compliance, fines, or legal actions by not relying on SDS. She provides many tips for increasing the accuracy and accountability of this public information.

 

In addition to the TRI educational video, SCS Engineers offers a slide set with links to many helpful tools and great advice. All resources are educational.

Request Tools and Resources Slides or ask a Hazardous Waste Expert a question here.

 

 

 

 

Posted by Diane Samuels at 6:00 am

June 11, 2024

Potential impact on the cleanup standards for arsenic, EPA IRIS.On October 16, 2023, US EPA’s Integrated Risk Information System (IRIS) Program released an updated toxicological review for inorganic arsenic, which includes proposed changes to the toxicity factors. Many federal, state, and local agencies use IRIS toxicity factors to assess environmental risk and establish risk-based environmental standards.

For example, the State of Florida and Miami-Dade County derived their direct exposure Soil Cleanup Target Levels (SCTLs) using these toxicity values, per Chapter 62-777, Florida Administrative Code and Chapter 24-44(2), Code of Miami-Dade County. If adopted, the updated toxicity values will lead to lower arsenic cleanup standards and, as a result, will significantly impact the assessment and remediation of contaminated sites throughout Florida.

Toxicity Factors Under Review and Potential Impact

The specific toxicity factors under review are the oral cancer slope factor (CSFo) and the oral reference dose (RfDo). In the current draft of the updated assessment, the IRIS Program has proposed a CSFo of 53 mg/kg/day for combined cancer risk and an overall RfDo of 0.031 µg/kg/day to protect against all noncancer adverse health effects associated with inorganic arsenic across all life stages.

To illustrate the significance of these updates, we used the proposed CSFo to re-calculate the State of Florida SCTLs. The resulting SCTLs would decrease from the current Residential SCTL of 2.1 mg/kg to 0.1 mg/kg and from the current Commercial/Industrial SCTL of 12 mg/kg to 0.4 mg/kg (assuming all other exposure factors remain the same). If the proposed changes to the toxicity factors are approved, remediation in Florida could feel the impact. An environmental engineer/consultant knowledgeable in due diligence, background assessments, and risk assessment/management can help you navigate these changing regulatory requirements.

toxicological review for inorganic arsenic

Rulemaking Process At Midpoint

The following links will direct you to the proposed toxicological review, a summary of the comments received during the public comment/peer review process, and information on the general assessment review process:

 

Given the potential impact on the cleanup standards, it is important to remain current with this updated assessment’s development and keep our clients informed of the potential changes. EPA is reviewing over a hundred comments received on the October 2023 draft IRIS Toxicological Review of Inorganic Arsenic. We understand that the final document’s projected release date will be announced once the Science Advisory Board delivers its peer-reviewed report. We’ll keep you informed.

 

Additional Resources:

 About Arsenic

Arsenic is a naturally occurring trace element in the environment. It is in geological formations, and levels in soil can range from 1–40 milligrams per kilogram (mg/kg). Erosion, leaching, and some human activities can increase arsenic levels in soil. Arsenical pesticides were once commonly used in agriculture to maintain turf (e.g., golf courses, parks, etc.) and treat wood. While their use has been significantly restricted, residual concentrations can still be detected during an environmental site audit/assessment.

Land Remediation and Brownfields: Information, case studies, grants, and educational materials.

 

Anabel Rodriguez Garcia
Garcia
Smith
Smith

Meet our Authors: Environmental Scientist Anabel Rodriguez Garcia and Lisa Smith, a principal technical advisor and expert in risk-based corrective action.

 

 

 

 

Posted by Diane Samuels at 6:00 am

May 30, 2024

Printing industry environmental risks and compliance

WISCONSIN’S PRINTING INDUSTRY CHARTER MEMBERS Present

Changing Regulatory and Sustainability Landscape for the Printing Industry

Join us on June 26, 2024, from 9:30 am – 3:00 pm (Central Time) at the Waukesha County Technical College
Registration fee is $35

Program Agenda (Central Time)
9:30 a.m. – SGP and Green Tier Program introduction
10:00 a.m. – How to Identify Hazardous Waste in the Printing Industry
10:45 a.m. – How Sustainability Is Shaping the Printing Industry
11:30 a.m. – Update on Ozone Nonattainment Emission Reduction Credits and PM 2.5
12:15 p.m. – Lunch (provided)
1:00 p.m. – Overview of Environmental Compliance including Partial Tour of Printer Portal with Cheryl Moran
1:45 p.m. – Small Business Resources Available from the DNR
2:15 p.m. – Advances In Flexible Packaging Recycling (STRAP Process)
3:00 p.m. – Adjourn

 

Speaker Highlight: Cheryl Moran is a member and leader of the Wisconsin Printing Council and a member of the Great Lakes Graphics Association. She is presenting the 1 p.m. discussion on compliance issues and the printer portal; the regulatory portion of the changing regulatory and sustainability landscape for printers. Many changes to state and federal compliance can impact the printing industry. For example, the Emergency Planning and Community Right-to-Know Act (EPCRA) impacts industrial facilities and the public. Annual reporting is due from printing and production facilities meeting a growing number of criteria – in short – more industrial and government facilities will be required to file mandatory reports in 2024 and 2025.

The emergency planning includes annual notification of hazardous chemicals present at your site to your state and local emergency planning and response organizations, and with your fire department. That information is used to help them prepare for emergencies such as chemical releases or fires and is made available to the public.

This information is disclosed through the toxics release inventory (TRI). TRI covers a variety of industries based on their NAICS code, which employs 10 full-time equivalent employees or more and stores or uses specific chemicals, including 189 PFAS.

This report is often referred to by a variety of names, including Toxics Release Inventory, TRI, SARA 313 report, Form R, or Form A. Do not be fooled by the nomenclature; these all refer to the same reporting requirement.

Posted by Diane Samuels at 6:00 am

May 22, 2024

WISCONSIN’S PRINTING INDUSTRY CHARTER MEMBERS Present

Changing Regulatory and Sustainability Landscape for the Printing Industry

Join us on June 26, 2024, from 9:30 am – 3:00 pm (Central Time) at the Waukesha County Technical College
Registration fee is $35

Program Agenda (Central Time)
9:30 a.m. – SGP and Green Tier Program introduction
10:00 a.m. – How to Identify Hazardous Waste in the Printing Industry
10:45 a.m. – How Sustainability Is Shaping the Printing Industry
11:30 a.m. – Update on Ozone Nonattainment Emission Reduction Credits and PM 2.5
12:15 p.m. – Lunch (provided)
1:00 p.m. – Overview of Environmental Compliance including Partial Tour of Printer Portal with Cheryl Moran
1:45 p.m. – Small Business Resources Available from the DNR
2:15 p.m. – Advances In Flexible Packaging Recycling (STRAP Process)
3:00 p.m. – Adjourn

 

Speaker Highlight: Cheryl Moran is a member and leader of the Wisconsin Printing Council and a member of the Great Lakes Graphics Association. She is presenting the 1 p.m. discussion on compliance issues and the printer portal; the regulatory portion of the changing regulatory and sustainability landscape for printers. Many changes to state and federal compliance can impact the printing industry. For example, the Emergency Planning and Community Right-to-Know Act (EPCRA) impacts industrial facilities and the public. Annual reporting is due from printing and production facilities meeting a growing number of criteria – in short – more industrial and government facilities will be required to file mandatory reports in 2024 and 2025.

The emergency planning includes annual notification of hazardous chemicals present at your site to your state and local emergency planning and response organizations, and with your fire department. That information is used to help them prepare for emergencies such as chemical releases or fires and is made available to the public.

This information is disclosed through the toxics release inventory (TRI). TRI covers a variety of industries based on their NAICS code, which employs 10 full-time equivalent employees or more and stores or uses specific chemicals, including 189 PFAS.

This report is often referred to by a variety of names, including Toxics Release Inventory, TRI, SARA 313 report, Form R, or Form A. Do not be fooled by the nomenclature; these all refer to the same reporting requirement.

Posted by Diane Samuels at 1:03 pm

May 16, 2024

SCS Engineers
The Pennsylvania Department of Environmental Protection – NPDES Regulatory Updates with Deadlines

 

The Pennsylvania Department of Environmental Protection (PADEP) has launched a pilot program to speed up the issuance of National Pollutant Discharge Elimination System (NPDES) permits, focusing on construction stormwater discharges. Started on April 29, 2024, this pilot in 10 counties is designed to streamline the application process for land development projects over one acre that faces unique environmental challenges. Eligible counties include Allegheny, Beaver, Bucks, Chester, Lebanon, Lehigh, Luzerne, Monroe, Montgomery, and York.

From May 1, 2024, the pilot will process up to three NPDES applications per quarter per county, with a yearly maximum of twelve. Applications must involve a licensed professional to oversee the stormwater plan. A significant improvement over traditional methods, the pilot combines completeness and technical reviews within 47 business days. If deficiencies are found, applicants have 22 business days to resolve them, hastening the move to a draft permit stage and public notice.

Exclusions apply to permit renewals, amendments, and projects on brownfield sites or those with large land disturbances or previous enforcement actions. The pilot also mandates two pre-application meetings to ensure eligibility and a final submission within 22 business days after these meetings.

However, the pilot program excludes several types of applications, such as those for permit renewals, amendments, transfers, projects exempt from application fees, or those proposing unapproved stormwater control measures. It also excludes projects requiring special reviews, those disturbing large land areas, or those associated with past enforcement actions. Notably, projects on brownfield sites must complete all required environmental studies and obtain necessary approvals before applying.

The Bureau of Clean Water manages the statewide Erosion and Sediment Control (E&S) program, as specified under 25 Pa. Code Chapter 102, which mandates an E&S permit for certain activities causing significant earth disturbances:

  • Construction activities disturbing more than one acre, excluding agricultural plowing or tilling, animal heavy-use areas, timber harvesting, or road maintenance, require an NPDES permit. Eligible entities may seek coverage under the PAG-01 or PAG-02 NPDES General Permits for stormwater discharges associated with small or general construction activities, respectively. Those ineligible for these permits must apply for an individual NPDES permit.
  • Timber harvesting and road maintenance activities disturbing 25 acres or more must secure an E&S permit under the Pennsylvania Clean Streams Law instead of an NPDES permit.
  • Oil and gas operations disturbing five acres or more also need an E&S permit under the same law. Eligible operators may apply for coverage under the E&S General Permit (ESCGP-3).
  • Any other activities disturbing five acres or more not previously specified require an E&S permit.

Managed by the Bureau of Clean Water, the pilot seeks to cut application processing times significantly. Additional details and application procedures are available on PADEP’s website.

A draft of the PAG-02 General Permit that would become effective on December 8, 2024, has been posted to DEP’s eLibrary.

 

Additional Information:

 

 

Posted by Diane Samuels at 6:00 am

May 6, 2024

H&H Modeling Improvements and Best Practices
Hydrologic and Hydraulic (H&H) Modeling is used in engineering analyses to evaluate waterbodies, pipes, culverts, channels, and rainfall. H&H Models enable the evaluation of drainage and/or flooding impacts of various development or restoration scenarios and support the development of design and policy solutions.

 

Hydrologic and hydraulic modeling software are critical for managing our nation’s surface waters. Quantitative models help local communities and environmental engineers better understand how surface waters change in response to development and pollution, and how to protect them. Surface water modeling software has been useful for solving large-scale watershed and local stormwater studies for over 50 years. Over time, these tools have evolved dramatically.

Early versions of Hydrology & Hydraulics (“H&H”) software were developed by the US Army Corps of Engineers Hydraulic Design Center (HDC). Examples are the early hydrologic modeling tool HEC-1 and the early open channel hydraulics tool, HEC-2. When a model was executed, results were in a simple tabular format, generally without notes about unusual results or troubleshooting tips.

These pieces of software were slow and cumbersome to use – generally, one needed a pad of paper and a pencil to make notes on printouts of the input code. Using these tools was a hassle, but – you knew every inch of the information entered. Back in the early days of these tools, specialty modeling firms flourished. Generally, “modelers” had master’s degrees supporting hydrologic or hydraulic study, which helped inform modeling.

Fast Forward to 2024

The picture of H&H modeling has changed dramatically. Understandably, the light-speed growth of software and computing power has enabled us to enter information and get results out of almost any model many times faster than the equivalent effort 40 years ago. Software user interfaces have become Windows-based, with 3D charts and output tools that give the whole story of a simulation with very easy access.

Moreover, an increasing number of public agencies are publishing their own HSPF-based long-term statistical hydrology simulation software. HSPF stands for “Hydrologic Simulation Program -FORTRAN,” originally developed by the EPA as a flow/duration model. It gives statistical returns of rainfall/runoff events over a period of years. A sophisticated but cumbersome to use platform, many agencies have incorporated the HSPF engine into a locally focused “Black Box Model,” which reduces user input down to the general characteristics of tributary areas and then directly produces a necessary BMP (pond, swale, etc.) footprint.

Legacy to HydroCAD

The legacy USACE tools mentioned previously evolved from HEC-1 and HEC-2 to HEC-HMS and HEC-RAS in their current versions. Both current models feature advanced data input, computation, and output modes. HEC-RAS, in particular, has evolved to perform dynamic flow simulations, GIS-based mapping, and 2-D flow calculation (not just straight down the channel, but also coming in/out of the channel from all directions).

Some newer, practicality-based tools, such as HydroCAD, enable the general civil engineer to perform H&H calculations to a significant level of detail for single-event storms. Additionally, today’s younger engineers have developed an ability to use new software that exceeds any previous generation.

Field Experience and Expertise Matters

Challenges can arise when adeptness at locating and entering data exceeds the user’s experience in hydrologic or hydraulic studies. Balancing this knowledge is crucial since both are essential for accurate water resources study (environmental, stormwater, and work related to climate change).

The aspect of current progress that gives one pause is how easy it has become to get results. Today’s users are adept at running simulations and getting results. However, sometimes these results are wrong or at least should raise questions.

Unfortunately, a novice user can get results that may look “fine” to them but odd to an experienced water resource engineer. If not carefully reviewed for engineering judgment, the less experienced user could inadvertently issue plans or study results with costly errors—This is a critical reason for a seasoned modeling professional’s review for quality assurance.

H&H software is more accessible and rapid than ever before but offers new challenges in ensuring those using, interpreting, and reviewing output have sufficient background in the subject matter. Moving forward, modelers who receive assistance with the “buttons and levers,” as well as a review of results by an experienced water resources professional, will learn to start thinking critically about their analysis results more quickly.

More formally, a project-specific QC process geared toward the review of applied hydraulics in H&H modeling helps maintain a firm’s quality of modeling performance and documentation

 

Hydrologic and Hydraulic Modeling Resources:

 

Jonathan ArchibaldAbout the Author: Jon Archibald, PE, has over two and a half decades of experience. He has strong expertise in leading multidisciplinary design teams, stormwater facility design, site civil engineering, and capital project execution. Jon has served clients in the solid waste, municipal, aviation, military, high-tech, hydroelectric, and flood risk sectors.

He successfully delivered several capital programs as a public works project manager for the City of Oregon City, OR. He has also assisted public agencies as an owner’s engineer. His combination of public and private experience helps foster collaboration on challenging design and permitting efforts.

Jon has delivered dozens of successful civil and water resource projects in the Pacific Northwest, California, and Alaska. Projects include site civil infrastructure, private and public utility design, hydrologic and hydraulic modeling studies, and design and accreditation of flood control systems. You can reach Jonathan or any of our Stormwater experts at or on LinkedIn.

 

 

 

Posted by Diane Samuels at 6:00 am

April 24, 2024

sp001 standard

 

A Summary of the Latest Updates for AST Inspections Using STI SP001 7th Edition

The Steel Tank Institute (STI) released the 7th Edition of the SP001 Standard for the Inspection of Aboveground Storage Tanks (ASTs) in late February 2024. This release comes six years after updating the previous Edition in January 2018.

The first update is the change to STI’s website, which is now www.stispfa.org. This new website includes much of the same information as the previous website, but the site map of that information is very different, with some data behind a membership wall, including the list of certified inspectors.

Revisions and Definitions

As for the SP001 7th Ed. text, it now includes a few revised and new definitions. The definition of Double-walled AST and Spill Control now specifies that “A tank insulation system or insulating jacket placed on a tank does not constitute a double wall tank.” This clarification distinguishes between insulation and the actual structure of the tank.

The Initial Service Date is specific to the tank “regardless of the AST’s current location or ownership. If the initial service date is unknown (e.g., rented or repurposed AST),” refer to the Inspection Schedule section of SP001.

In addition, the Standard now includes a definition for a Permit-Required Confined Space, providing clear guidelines on the safety requirements for confined spaces in line with the applicable OSHA requirements.

The Ultrasonic Testing Scan (UTS) is further clarified to mean “An ultrasonic scan which scans 100% of a designated surface area.” This scan detects thinning from material loss, not just corrosion.

Relevance to AST Inspections

Several items during formal tank inspections are now specifically mentioned. Manways are now on the list of tank components for inspection. The Basic Tank Anatomy Figure (Figure A.1.2) is revised to include the Manway, Fill Pipe, Tank Gauge, and Tank Support. This enhancement provides a more comprehensive overview of common tank components.

In addition to these updates, tank inspections now specifically include verifying the accuracy of the owner’s STI SP001 AST Record data, inspecting for vegetation growing alongside or against the AST or the foundation, and Ultrasonic Thickness Testing (UTT) readings of the corroded areas if corrosion is evident on the outside surface of the secondary tank shell.

The 7th Edition also broadens the range of potential inspectors, designating the responsibility of conducting Periodic AST inspections and the Leak test to “a qualified party designated by the owner” or “a qualified party designated by the owner or owner’s designee.” A detailed description of the grid pattern for Formal Internal Inspections (FII) is in the 7th  Edition.

If Microbiologically Influenced Corrosion (MIC) is suspected, the standard now suggests testing a sample of liquid from the tank bottom for bacteria that could cause MIC going forward.

A written report is required for each Formal External Inspection (FEI) & Formal Internal Inspection (FII) performed.

Should the integrity of spill control be compromised during an inspection, SP001 7th Ed. includes a reevaluation of the tank category and inspection timetable. This new standard introduces more flexibility and responsiveness to potential issues that may arise during inspections.

In conclusion, the 7th Edition of STI’s SP001 Standard for the Inspection of Aboveground Storage Tanks presents significant updates and clarifications that aim to enhance the inspection process, ensuring the safety and longevity of ASTs.

 

Benjamin ReynoldsAbout the Author: Benjamin Reynolds is a Senior Project Professional in our Little Rock, Arkansas, office. His experience includes Spill Prevention, Control, and Countermeasures (SPCC), Tank Assessments, Storm Water Pollution Prevention Plans (SWPPPs), and Phase I and II Environmental Site Assessments. He is a Professional Engineer licensed in Arkansas, Oklahoma, Tennessee, and Florida. Reach out to Ben at or on LinkedIn.

 

Additional AST and SPCC Resources and Tips:

 

 

 

 

Posted by Diane Samuels at 6:00 am

April 22, 2024

Environmental Justice - SCS Engineers

 

Developers looking to build in or near wetlands in Florida must navigate a complex permitting process, particularly considering the recent court order affecting the State 404 Program. With the pause in the State 404 Program, developers must revert to the federal permitting process under the Clean Water Act (CWA) Section 404, administered by the U.S. Army Corps of Engineers and overseen by the Environmental Protection Agency (EPA).

As of February 15, 2024, the Florida Department of Environmental Protection (DEP) has temporarily lost its authority to issue State 404 Program permits.

The State 404 Program, effective December 22, 2020, was designed to streamline the permitting process by allowing the state to evaluate and issue permits for a broad range of water resources within the state to protect Florida’s waters, residents, and economy more efficiently. The EPA had approved Florida’s assumption of the CWA Section 404 program, making it one of the only three states with Michigan and New Jersey to have such authority.

A recent court ruling shifts the administration of the 404-permitting process in Florida back to the U.S. Army Corps of Engineers and EPA, affecting developers, government projects, and any activities requiring dredge or fill permits in state-assumed waters. Specifically, the decision was part of a larger judicial examination of how agency deference is applied and its impacts on individual rights versus governmental interests.

Before starting any project, it is essential to determine if the land in question falls under the authority of the CWA Section 404. This involves identifying if the project area includes waters of the United States, including wetlands. The U.S. Army Corps of Engineers conducts jurisdictional determinations to make this assessment.

It is advisable to schedule a pre-application meeting with the U.S. Army Corps of Engineers. During this meeting, developers can present their project plans and receive guidance on the permitting process,

Depending on the project’s impact on the wetlands, developers may need to apply for either a Nationwide Permit (for minimal impacts) or an Individual Permit (for significant impacts). The application process requires detailed project descriptions, impact assessments, and mitigation plans.

A general Nationwide Permit may be suitable for activities with minimal adverse effects, streamlining the review process. An individual permit is required for potentially significant impacts, involving a more detailed review process, including public notice and opportunity for hearing.

General permits, like Nationwide Permits, are designed for activities with minimal environmental impacts and offer a streamlined review process. They apply broadly to numerous similar projects, reducing the need for detailed scrutiny of each case.

Individual permits, on the other hand, are required for projects that might have significant environmental impacts. This process is more rigorous, involving a detailed review, public notices, and opportunities for hearings to assess the potential environmental consequences more closely.

Developers must demonstrate efforts to avoid impacts on wetlands, minimize unavoidable impacts, and provide compensation for any remaining unavoidable impacts through restoration, establishment, enhancement, or preservation of aquatic resources.

Certain projects may require consultation with other federal agencies, such as the U.S. Fish and Wildlife Service or the National Marine Fisheries Service. Additionally, the public and interested stakeholders can comment on Individual Permit applications.

Developers must ensure compliance with other relevant environmental regulations, such as the Endangered Species Act and the National Historic Preservation Act, as part of the permitting process.

Given the current uncertainty and potential for further legal developments regarding Florida’s State 404 Program, developers should closely monitor any updates from the Florida Department of Environmental Protection and the U.S. Army Corps of Engineers. Consulting with legal and environmental professionals familiar with Florida’s federal and state wetland regulations is highly recommended to navigate this complex regulatory landscape effectively.

Developers in Florida working with their consultants on wetlands issues need to navigate a complex regulatory landscape. Determining if a project requires a Nationwide Permit for minimal impacts or an Individual Permit for significant impacts is crucial. Developers and their consultants should engage in pre-application meetings with the U.S. Army Corps of Engineers, understand the necessity of demonstrating efforts to avoid, minimize, and compensate for wetland impacts, and ensure compliance with other relevant regulations like the Endangered Species Act. Consulting with environmental legal professionals is highly recommended to navigate these regulations effectively.

 

Additional Environmental Permitting Resources & Protections in the U.S.

 

 

 

 

 

Posted by Diane Samuels at 6:00 am

April 3, 2024

L to R: Stacey Dolden, Eddy Smith, Steve Liggins, Doug Doerr, Nathan Hamm, Curtis Jang, and Jay Hatho of SCS Engineers.

 

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.

 

 

Posted by Diane Samuels at 6:00 am

March 25, 2024

EPA alert

 

EPA is issuing a new Clean Water Act (CWA) rule that requires certain facilities to prepare and implement facility response plans (FRP) that address the storage and worst-case discharge of hazardous substances (HSs).

According to the EPA, the facility response plan requirements apply to facilities that could reasonably be expected to cause substantial environmental harm based on their location. These include facilities with a maximum onsite quantity of a CWA hazardous substance that meets or exceeds threshold quantities, located within a 0.5-mile radius of navigable water or conveyance to navigable water, and meets one or more substantial harm criteria.

From EPA’s site: See CWA Hazardous Substance Facility Response Plan Applicability.

Facilities may be identified as posing substantial harm either through a self-identification process or a process whereby EPA Regional Administrators may assess facilities on a case-by-case basis and, if appropriate, require a facility to develop a response plan based on, among other things, concerns related to potential impacts of a worst-case discharge on communities with environmental justice concerns.

The CWA hazardous substance FRP requirements apply to facilities that:

  • Have a maximum onsite quantity of any CWA hazardous substance that meets or exceeds 1,000 times the Reportable Quantity (see 40 CFR 117.3); and
  • Are within 0.5-mile of navigable water or a conveyance to navigable water; and 
  • Meet one or more of the following substantial harm criteria: 
    • Ability to cause injury to fish, wildlife and sensitive environments.
    • Ability to adversely impact a public water system.
    • Ability to cause injury to public receptors.
    • Has had a reportable discharge of a CWA hazardous substance above the Reportable Quantity within the last five years that reached navigable water. 

EPA estimates that the rule will impact 12,618 facilities, including 7,264 estimated for rule familiarization and the Substantial Harm Certification Form, and 5,354 facilities further developing and maintaining FRPs under the final rule.

Facilities will be required to submit FRPs to the EPA within three years of the new rule’s effective date.

Here is the link for the EPA webpage: https://www.epa.gov/hazardous-substance-spills-planning-regulations/final-rulemaking-clean-water-act-hazardous

And here is the link for the pre-publication of the Federal Register notice for the new rule:  https://www.epa.gov/system/files/documents/2024-03/cwa-hs-frp-final-rule-pre-publication_.pdf

If you’d like more information pertaining to your facility’s CWA compliance, please contact for a compliance expert.

 

 

 

Posted by Diane Samuels at 6:00 am