environmental compliance

August 22, 2016

Author: Ann O’Brien

Alert: Toxic Release Inventory Form A and Form R Reports were due July 1, 2016

The Toxics Release Inventory (TRI) was created by EPA in response to several events that raised public concern about local preparedness for chemical emergencies and the availability of information on hazardous substances.

Printing is one of the industry sectors required to annually report releases of certain chemicals.  A printing facility with 10 or more full-time equivalent employees is required to report if the facility exceeds established chemical thresholds.  Note that TRI reporting is not based on the amount of emissions to atmosphere or how much waste is generated. Instead, a company that manufactures or processes more than 25,000 pounds or otherwise uses more than 10,000 pounds of a TRI-listed chemical were required to report releases of these chemicals by July 1, 2016.

There are currently over 650 chemicals covered by the TRI program including chemicals commonly used by printers, such as toluene, xylene, ethylbenzene, 1,2,4-trimethylbenzene,  glycol ethers, solvents, and metals. Of particular interest to lithographic printers is the wide use of glycol ethers in fountain solutions and more recently in cleaning solutions, to take the place of solvents with high vapor pressures.  It is important to mention that “glycol ethers” is a chemical category and within this category there are hundreds of individual chemicals that are reportable.  Safety Data Sheets (SDS) do not indicate the presence of “glycol ethers” as a constituent of a raw material so a printer must look up each listed constituent and compare it to the list of TRI chemicals to determine whether is it reportable.

For more information, contact Ann O’Brien () or Cheryl Moran () at SCS Engineers.

Ann O’Brien is a Project Manager with SCS Engineers.  During her 32-year career in the printing industry she was responsible for environmental compliance programs, including, but not limited to, air and water quality permitting, environmental recordkeeping, reporting and monitoring programs, hazardous waste management, environmental compliance audits, and environmental site assessments and due diligence associated with real estate transactions and corporate acquisitions.  

Cheryl Moran is a Project Manager with SCS Engineers with more than 20 years of experience in the printing industry. She is a Certified Hazardous Materials Manager (CHMM) and has worked with air, water, and waste issues including permitting, environmental recordkeeping, reporting and monitoring programs, hazardous waste management, environmental compliance audits, and sustainability programs.

August 17, 2016

SCS periodically prepares technical bulletins to highlight items of interest to our clients and friends. These are published on our website. This SCS Technical Bulletin addresses:

Inactive Surface Impoundments and EPA Direct Final Rules for Disposal of Coal Combustion Residuals from Electric Utilities.

Read and share the SCS Technical Bulletin here.

SCS Coal Combustion Residual Services

August 2, 2016

Survivability of leachate collection pipes depends upon the gravel placed on all sides of the pipe. Proper placement of gravel around the pipe and the granular soil material over the completed pipe/gravel/geotextile burrito is of significant importance in the protection of the leachate collection pipe.

Read the article by Dr. Ali Khatami here.

SCS Advice from the Field is a collection of blogs, articles, and white papers written by SCS professionals like Dr. Khatami. Search “advice from the field” to browse all of the topics.

Click here to search now.

August 1, 2016

Do you have NSPS or EG sites per the new definitions of “new” and “existing”?

Does your EG site have any upcoming planned or permitted expansions, or will it be commencing construction on an expansion permitted after July 17, 2014?

Will you need to submit/resubmit Design Capacity and NMOC reports to establish your sites status as subject to the new NSPS? Over, or under 34 Mg/year of NMOCs?

Are you a candidate for Tier 4? In the closed landfill subcategory?

For EG sites contact the SCS state representative by sending a request to

SCS Engineers will be publishing Pat Sullivan’s Technical Bulletin Summary of Final NSPS/EG Rules for Landfills as soon as it is published in the federal register. Meanwhile, please contact your SCS Project Manager or for answers to your questions or advice.  Follow SCS Engineers on your favorite social media site or check our events for new presentations, publications, and webinars explaining the rules in more detail.

July 13, 2016

On July 11, 2016, multiple organizations representing the full value chain of cellulosic waste feedstock conversion to transportation fuel sent a letter to Gina McCarthy, Administrator of the U.S. Environmental Protection Agency (EPA). The letter supporting the Renewable Fuel Standard Program: Standards for 2017 and Biomass-Based Diesel Volume for 2018 (Proposed Rule) noted that additional information and factors need to be considered.

Read or share a copy of the letter here, contact SCS Engineers, or one of the organizations below:

• The Coalition for Renewable Natural Gas (RNG Coalition)
• NGV America (NGVA)
• The Canadian Gas Association (CGA)
• Energy Vision (EV)
• The National Waste and Recycling Association (NWRA)
• The Solid Waste Association of North America (SWANA)
• Transportation Energy Partners (TEP)
• Virginia Clean Cities (VCC)
• Clean Fuels Ohio (CFO)
• Lone Star Clean Fuels Alliance (LSCFA)

July 13, 2016

By following the simple procedures governing selective routing in the commercial space, it is possible to turn a high disposal garbage collection system into a high diversion recycling system, without incurring additional costs or losing collection revenue. Read more…

Tracie Onstad Bills of SCS Engineers and Richard Gertman of For Sustainability Too explain the steps for commercial-stream routing and management of commercial recyclables with remarkable results in their Resource Recycling article published in June 2016.

Questions? Ask Tracie, she writes a blog series about recycling.

Contact Tracie directly. 

July 11, 2016

Sensitive natural resources include but are not limited to the following: Threatened and Endangered (T&E) species and their habitats, wildlife refuges, wetlands, and tribal burial grounds. These are areas where federal or states have identified protected resources. SCS Engineers has the expertise and credentials to perform surveys for clients with projects requiring the identification of these sensitive resources, along with the regulatory permitting with specialization in threatened and endangered species, wetlands, and critical habitats.

Development and construction often occur near or within areas identified as sensitive natural resources. Responsible developers identify sensitive resources near or within their proposed project area as part of their development plans because protecting our nation’s natural resources is important. The protection of sensitive natural resources is the basis of the Federal Endangered Species Act, Clean Water Act, and National Historical Preservation Act. Projects under consideration in sensitive areas require special permits; without which projects can be shut down causing costly contractor delays and schedule disruptions. Post-permitting and the associated fines can be severe, so even if you are not a conservationist, it makes good sense to complete the permitting process before breaking ground.

When considering a project in potentially sensitive ecological areas, SCS Engineers recommends a constraint analysis be performed. The analysis will determine if the proposed project location is within wetlands, critical habitat, threatened and endangered species range, and other potential constraints. If it is, SCS recommends that a site assessment is performed and initiate agency consultation to protect the sensitive resources.

Both the permitting process and the preliminary ecological assessments are not difficult but do require credentialed specialists. SCS has geologists, hydrologist, hydro-geologists, and environmental compliance professionals nationwide. SCS Engineers even has credentialed biologists for specialized threatened and endangered species monitoring and assessments for several species that include but not limited to the American Bury Beetle, Arkansas Shiner, Arkansas Darter, Topeka Shiner, Neosho Mucket Mussel, Rabbitfoot Mussel, Northern Longear Bat, and Indiana Bat in the Central U.S.

To determine if a project is within a sensitive natural resource area or to schedule an ecological consultation, contact .

About the Author: Vaughn Weaver

Vaughn Weaver has over 20 years of environmental services experience with a strong background in water quality and bio-monitoring and is currently a senior field technician at SCS in our Wichita office. He provides project assistance to a diverse team of environmental professionals made up of geologists, hydrogeologists, engineers, chemists, and biologists. His responsibilities include surveying project sites, mitigation monitoring, well sampling and monitoring, and report writing for clients.

In addition, he has 15 years of water quality experience with National Pollution Discharge and Emissions Systems (NPDES) for point source and non-point source permits. Vaughn is also a Certified Wetland Delineator – USACOE.

July 6, 2016

Contamination causes major problems for recycling programs. Improving communication plays a pivotal role in solving the issue.

Tracie Onstad Bills, Northern California Director, Sustainable Materials Management at SCS Engineers

Thank you for the responses and questions about my blog Minimizing Contamination in Recycling. It seems appropriate to provide answers to the most frequently asked questions and send more advice. Any program should be tailored to your current collection system; what works and what doesn’t work for your locality; the demographics of your community; and how your community views recycling.

In light of those considerations, here are some recommendations for ways to minimize contamination in recyclables:

• Mail outreach materials to business and residents on a regular basis. When your community is adding recycling or switching to a new recycling program, mail outreach starting 6 months before the new services begin to inform and prepare the community for the change. Then every other month send new information about the program so people get used to hearing about the upcoming program, what is expected of them, and the positive difference they are making in their community.
• Use social media to get your message out, Including NextDoor, Facebook, Twitter, the local government/community website, newspapers, community TV stations, and radio. One of the people who responded to my previous blog, Cyril May, even uses magic as a part of his environmental outreach. He is the recycling coordinator for the City of Waterbury, CT, and uses magic to demonstrate the power of recycling when he goes door-to-door or speaks at schools. “Turning a ripped up newspaper into a new newspaper shows the magic of recycling that everyone has,” he says. “Causing dollar bills to vanish in smoke and flame showcases the taxpayer dollars lost when we send valuable recyclables to incinerators.”
• After the service starts, follow up with additional outreach. Highlight what people should do as well as what they should not do. Yes – I am a firm believer in excellent outreach, education, and communication!
• Some studies have suggested providing trash cans that are the same size as the recycling can, because when the recycling is free, people often will throw their trash into the recycling containers in order to keep a small trash container for a cheaper cost. I am not an advocate of this method, however, I am a realist and know that this is one cause of contamination, so keep an eye on it!
• Make sure your hauler keeps track of any contamination issues and the causes. Knowing what the contamination is and why it is caused, will help you determine the next steps on how to address it. For example, if you have slight contamination because residents and businesses are throwing in items that they think are recyclable, you can continue to educate them about what can and cannot be recycled. However, if they are putting trash in the recycling containers in order to save costs, that is another matter that needs to be addressed appropriately, and may include citations or fines.
• Many people throw more than they should into their recycling containers because they think “the hauler will sort it at the facility,” and so they don’t feel the need to be extra cautious about how they sort. As part of your outreach, I would recommend letting the community know that the cleaner the materials, the better the market and the more economical the service. They need to understand that there are consequences when they are not careful about how they recycle.
• Make sure that the materials you accept in your recycling program can, in fact, be recycled. Cities often accept items in recycling containers because they can be recycled in theory (for example, milk cartons and polystyrene), when, in fact, they may not be. Depending on the local dynamics, recycling markets, recoverability at the recycling facility, or other barriers, certain materials may or may not be recycled. Be consistent with the materials you accept and don’t take items that may cause confusion.
• In California, we have very diverse demographics and multiple languages. Providing outreach in those different languages, and even better, with pictures, will help your community fully understand the recycling program.
• Go into the schools to get the kids engaged and excited about recycling. If you are starting a new recycling program, facilitate an assembly right before and/or after the service starts. Kids often influence their family’s behavior in such matters.
• Multi-family dwellings should be treated differently than single-family residences. Because residents of multi-family dwellings do not typically pay for the service directly, their containers will almost always be contaminated because there is no ownership of the responsibility. There are other barriers as well, such as illegal dumping, fluctuation of tenants, move-in or move-out purging of material, etc. I have a different set of recommendations for multi-family dwellings which I consider one of the toughest nuts to crack.
• Make sure the recycling haulers place non-collection tags on containers that are contaminated. After a few violation notices and the threat to suspend service, residents and businesses usually improve, especially when they realize that someone is watching them.
• Be diligent when transitioning to your new recycling program and closely monitor how your residents and businesses are doing. I would recommend having a few interns go out for the first month or two and conduct random lid flips. Leave notes that say “good job – you’re an excellent recycler” to reinforce the good behavior. This will also provide a pulse on how the program is doing, where the problems are, and if there are certain districts of the city that are more contaminated than others. By isolating the areas that have high contamination, you can focus your outreach and education to the regions that need message reinforcement.
• Be flexible. Remember that your program will be evolving, so go with the flow, and be sure to celebrate your successes!

Learn more about recycling programs by reading Success In Selective Routing – Resource Recycling or the SCS project and case studies below:

• Smart Business Recycling Programs – Los Angeles County, California
• Visual Characterization and Commercial Recycling / Organic Technical Assistance – Central Contra Costa Solid Waste Authority, California
• Waste Diversion – Mid-America Regional Council Solid Waste Management District, Missouri
• Solid Waste Master Planning – Escambia County, Florida
• Zero Waste Strategies Plan – Santa Monica, California
• Food Waste and Compostables Feasibility Study – Skagway, Alaska
• Recycling Feasibility Study with Landfill Cost Analysis – Lawton, Oklahoma

As always, feel free to send me your questions and comments. Contact Tracie here.

June 29, 2016

SCS Engineers’ Tracie Onstad Bills and Leslie Lukacs were both selected to receive the California Resource Recovery Association’s (CRRA) prestigious Service Award this year. According to CRRA Executive Director, John H. Dane, the award recognizes “exceptional individual service to the organization and a contribution of time or resources beyond expectations.” That sounds like an SCSer alright.

Tracie Bills is SCS’s Sustainable Materials Management Director and is based in our Pleasanton, CA, location. She has been on the CRRA board for 10 years and has served in several leadership positions within the organization, including as its President for three years. Her expertise revolves around commercial recycling technical assistance, environmental purchasing, large venue and event zero waste programs, research and sustainability planning, garbage hauler franchise compliance and review, construction and demolition program / ordinance analysis and writing, climate inventory compilation, research and feasibility studies to help clients with comprehensive waste prevention and zero waste programs.

Leslie Lukacs serves as a Sustainable Materials Management Specialist in our Santa Rosa, CA, office. She has been on the CRRA board for 12 years and also served in a variety of leadership positions. She also founded CRRA’s Green Initiatives for Venues and Events technical council and was an instructor for CRRA’s Resource Management Certification Program for 5 years. Leslie specializes in the design and implementation of sustainable materials management and zero waste programs and is a pioneer in the greening of venues and events throughout the nation. Her extensive expertise in the logistics of zero waste, recycling, and composting programs, such as outreach management, business assistance, master planning, waste audits and characterization studies, extended producer responsibility ordinance preparation and implementation, compliance, grant writing, and administration are all key to successful long-term programs.

Both women were selected by the CRRA Board of Directors to be the 2016 recipients of the Service Award. The awards will be presented at the organization’s Annual Conference Awards Ceremony on August 9 in Sacramento.

Congratulations, Ladies. We are so proud of our SCS Professionals!

CRRA is California’s statewide recycling association. It is the oldest and one of the largest non-profit recycling organizations in the U.S. CRRA is dedicated to achieving environmental sustainability in and beyond the state through Zero Waste strategies including product stewardship, waste prevention, reuse, recycling and composting. The organization provides its members with resources to advance local, regional and statewide waste reduction efforts which result in critical environmental and climate protection outcomes. Members represent all aspects of California’s reduce-reuse-recycle-compost economy and work for cities, counties, municipal districts, and businesses as well as hauling companies, material processors, non-profit organizations, state agencies, and allied professionals.

June 27, 2016

It’s not just that we like wine and happen to live and work in every wine producing region of the U.S.; SCS Engineers understands the need for clean water resources and how important they are to the wine industry and for agriculture in general. SCS helps wineries face an array of environmental and regulatory challenges including:

• Energy and natural resources conservation programs. These programs include protecting habitats and species.
• Water Quality – Stormwater, Wastewater, Groundwater, Well-water and Surface Water;
• Air Quality – Winery Fermentation and Aging Emissions, including VOCs, Stationary-Traditional Combustion Sources, and Greenhouse Gas Emissions;
• Environmental Due Diligence -All Appropriate Inquiries, Phase I’s/Phase II’s, Environmental Compliance Reviews and Audits, Vapor Encroachment and Vapor Intrusion Studies
• Hazardous Materials – For example in California, the California Unified Program Agency Requirements including Hazardous Materials Business Plans (HMBPs), Spill Control and Countermeasure Plans (SPCCs), and Hazardous Materials Inventories;
• Sustainable Materials -Recycling, Reuse, and Repurposing of Materials;
• Waste: Organic, Solid, Hazardous and other Wastes;
• Geographic Information Services (GIS) -Spatial Databases; GPS Inventories, plots, varietal blocks and soils maps, vineyard development; and
• Occupational Safety and Health – Facility Health and Safety Plans, Safety and OSHA Compliance Audits, Injury and Illness Prevention Programs.

SCS is pleased to announce we are the newest member of WIN, the Wine Industry Network.

SCS Engineers offers sustainable environmental solutions to businesses with environmental challenges. SCS provides these services to private and public sector clients through a network of nationwide offices. For more information about SCS, please visit our website at www.scsengineers.com, or contact us at .