We are deeply saddened by the passing of our founder Tom Conrad, but we celebrate his spirit by continuing the culture he established at SCS Engineers. Tom was energetic, creative, hard-working, and fun-loving! His accomplishments in preventing and mitigating environmental damage are just one of the reasons we respect him so much.
Another reason is that Tom believed in providing opportunities for everyone. He founded and ran SCS based on giving individuals the tools they need to thrive while providing for their families, the environment, and their communities. These tools are trust, mentorship, and open dialog. By building these philosophies into our culture, Tom sparked multiple innovations and environmental solutions by some of the finest people you’ll ever want to meet.
These SCSers continue our culture of caring and listening. Anyone at SCS can contribute their ideas for improving a process or technology. Our executives promote forums to keep the conversations and idea exchanges going and open to all. And just as Tom would insist, innovations are proven before they are implemented.
We’re proud of all SCSers, especially our young professionals, who consistently bring in fresh ideas and perspectives by asking “why and how” questions. Designing sustainable environmental solutions requires a deep understanding of systems, processes, and industry knowledge. Asking the right questions and seeking answers indicates a curious mind; Tom called these people “thinkers,” one of the best compliments we could get. Asking these questions indicates a self-actualized mind. And answering the questions takes a team. At SCS, we encourage both.
SCS’s mentorship and young professionals programs are thriving. They were established more formally in the last decade but have always been a part of SCS. President and CEO Jim Walsh called Tom “The best mentor anyone could ever have,” going on to say that Tom “taught me a lot, but more, he let me figure things out on my own… I’ve often said that my best four years of education were not high school or college; it was learning from Tom Conrad.”
SCS’s culture survives because of trust. So as Tom did, we continue to place trust and confidence in SCS’s employee-owners. Tom understood long ago that trust creates a culture of teamwork and respect, enabling effective problem-solving. In fact, Tom was so proud and confident in the firm’s environmental accomplishments in 1987 that he modified the company’s Employee Stock Ownership Plan to expand ownership of SCS to all employees. Today SCS remains 100% employee-owned and is a driving force for SCSers to deliver high-quality and ethical solutions to our clients.
Tom’s other major and no less important philosophy was to “have fun!” We take the time to engage and laugh with our colleagues, clients, and associates.
Our nationwide offices are busy year-round helping their communities, especially during the holidays. A special thanks to our young professionals, who think BIG, for organizing our annual Feed America campaign, always with a healthy, fun competition between our offices!
You can learn more about how SCS continues in Tom Conrad’s spirit today by watching this short video made by SCSers coast to coast.
The announcement of new developments, especially new housing, is always welcome, given nationwide shortages. Wood Partners recently spoke of its Alta Cuvee project in Rancho Cucamonga, CA., an area experiencing high growth rates. With the construction currently underway, the community plans to open in late 2024.
Careful development companies follow all environmental guidelines set forth by local, state, and federal agencies to ensure sustainability. At the Alta Cuvee project, SCS Engineers performed a Phase I Environmental Site Assessment, ensuring due diligence on the part of Wood Partners.
Today’s commercial real estate transactions take environmental issues into consideration. Complex laws can impose significant environmental liabilities on purchasers, sellers, and lenders, whether or not they caused the problem and whether or not they still own the property.
When looking for a new home, look for reputable companies that perform due diligence. When looking for environmental due diligence services, look for engineers and consultants providing comprehensive services for the welfare of future tenants, owners, and your firm’s reputation.
All Appropriate Inquiries (AAI) is a process of evaluating the environmental condition of a property and assessing the likelihood of contamination. Parties must comply with the requirements of the AAI Rule or follow the standards set forth in the ASTM E1527-13 or E1527-21 Standard Practice for Phase I Environmental Site Assessments to satisfy the statutory requirements for conducting all appropriate inquiries.
Learn more:
EPA intends to update and expand its November 2021 oil and gas regulation proposal by reducing methane emissions and other harmful air pollution from new and existing oil and natural gas operations. The Agency has issued a supplemental proposal adding proposed requirements for sources not previously covered.
Registration is open for EPA’s virtual public hearing impacting hundreds of thousands of existing oil and gas sources nationwide. The Agency states it will promote innovative methane detection technologies and other cutting-edge solutions which are being developed.
Hearing information:
To register to speak or to watch a live stream of the hearing on both days, please visit EPA’s website for the supplemental proposal.
The registration deadline is January 5, 2023. See instructions for submitting a written comment.
In December, the SCS Madison office hosted the Great Lakes Graphics Association’s “Women in Print” luncheon and program. The purpose of this group is to bring together “women working in a man’s world” and give them a space to share experiences, offer coaching and advice, and share examples with women of all ages. The group motivates and encourages each other to push past old gender norms and share experiences with women of all ages. It was wonderful that SCS hosted 17 women from their early 20s to women in their late 60s who were among the first to call print shops their employers.
Environmental sustainability is part of many printers’ business models. The network and GLGA provide opportunities to discuss best practices for moving in a green direction, addressing critical regulatory issues, and environmental reporting — while having many minds contributing great ideas and proven solutions.
This was the 5th meeting of the group, and we’re proud to host them, as it is challenging to find safe places to meet during COVID, RSV, and flu season. Cheryl Moran spoke about how she grew up in print, from her coursework in college to her first job as a secretary in a print house to her evolution as an environmental, health, and safety trainer, manager, and director. She continues to offer her expertise to printers across the US while she trains and develops her team here at SCS.
It was wonderful to see everyone, especially after being virtual for so long. We look forward to hosting more Great Lakes Graphics Association events and opening our doors even wider in 2023. If you are interested in joining us, you can contact Cheryl Moran.
Resources:
On December 5, 2022, the EPA released a memo providing direction under the NPDES permitting program to empower states to address known or suspected discharges of per- and polyfluoroalkyl substances (PFAS). The memo cites state programs in Michigan and North Carolina that other states may want to replicate. These approaches and others could help reduce PFAS discharges by working with industries, and the monitoring information they collect, to develop facility-specific, technology-based effluent limits.
As stated in its memo, the EPA’s goal is to align wastewater and stormwater NPDES permits and pretreatment program implementation activities with the goals in EPA’s PFAS Strategic Roadmap. The memo recommends that states use the most current sampling and analysis methods in their NPDES programs to identify known or suspected sources of PFAS and to take actions using their pretreatment and permitting authorities, such as imposing technology-based limits on sources of PFAS discharges.
The Agency hopes to obtain comprehensive information by monitoring the sources and quantities of PFAS discharges, informing other EPA efforts to address PFAS. The EPA will need this information since new technologies and treatments are in development but remain unproven to work successfully in specific industries.
Other proposed actions by the Agency include designating two PFAS as Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) hazardous substances and an order under EPA’s National PFAS Testing Strategy requiring companies to conduct PFAS testing and nationwide sampling for 29 PFAS in drinking water starting in 2023.
In a letter to Congress, SWANA and NWRA associations request that regulation under CERCLA for addressing PFAS contamination assign environmental cleanup liability to the industries that created the pollution in the first place. Both associations note that landfills and solid waste management, an essential public service, do not manufacture nor use PFAS. Therefore, the general public should not be burdened with CERCLA liability and costs associated with mitigating PFAS from groundwater, stormwater, and wastewater.
Resources:
Illinois EPA Environmental Justice Procedures
The Illinois EPA Bureau of Air recently implemented more stringent procedures for securing an air permit for a new emissions source or emissions unit when the operations are located in, or within a mile of, an Environmental Justice area. How long the new procedures will remain in effect is not known, but any increase in air emissions will subject the project to more extensive review by the Illinois EPA and possibly the United States Environmental Protection Agency (USEPA) Region V, which could extend the permit application review by a substantial amount of time. Depending on the location of the source, the type and amount of the pollutant(s) being emitted, and the amount of interest or objection by interested parties, there is also a chance that the permit may not be approved. Interested parties include, but are not limited to, local activists, local government agencies, neighboring citizens, and other entities with an interest in Environmental Justice (EJ).
Assuming a permit with a net increase in emissions is approved, it will likely include the following elements.
Illinois EPA is recommending that a company seeking to construct and operate a new or modified source, or add a new emissions unit to an existing source, identify ways within the plant to lower air emissions of the applicable air contaminant(s) such that the project will not result in a net emissions increase. Illinois EPA is not expecting a source to conduct a formal netting exercise, but instead suggests considering product substitutions such as alternative cleaning solutions with low or no volatile organic material (VOM) or hazardous air pollutants (HAPs); for instance, a mixture of acetone and water, or detergents. Other approaches may include the installation of add-on pollution control equipment, use of cleaning solutions with low vapor pressures which evaporate more slowly, capturing some of the VOM in shop towels and cleaning rags rather than emitting them to the atmosphere, installation of recovery equipment (e.g., distillation equipment), and considering other raw material substitutions or equipment replacements.
When an air permit application is submitted to the Illinois EPA for a proposed project that does not result in a net emissions increase, the application will be processed by the permitting department, and then a draft permit will be forwarded to the EJ group at Illinois EPA. The EJ group will forward a copy of the draft permit to interested parties specific to that EJ area. If no comments are received within two weeks, the permitting group will issue a draft permit to the permittee for review and comments. Any substantive comments received from interested parties will be addressed by the Illinois EPA, and this process could cause delays, particularly if a public hearing is requested and granted.
Environmental Justice Background
The USEPA defines environmental justice as “the fair treatment and meaningful involvement of all people regardless of race, color, national origin, or income, with respect to the development, implementation, and enforcement of environmental laws, regulations, and policies.” Environmental justice was originally established by Title VI of the Civil Rights Act of 1964, which prohibits recipients of federal financial assistance (states, grantees, etc.) from discriminating against these populations in any program or activity. The scope of Title VI was expanded by Executive Order 12898 by President Clinton on February 11, 1994. Executive Order 12898 was issued to direct federal agencies to incorporate achieving EJ into their mission, and to identify and address, as appropriate, disproportionally high adverse human health and environmental effects of their programs, policies, and activities on minority and low-income populations. More recently, President Biden issued Executive Order 14008 Tackling the Climate Crisis at Home and Abroad on January 27, 2021.
Illinois EPA has adopted policies and procedures to conform to Title VI of the Act and Executive Orders 12898 and 14008. According to Illinois EPA, “environmental justice is the protection of the health of the people of Illinois and its environment, equity in the administration of the State’s environmental programs, and the provision of adequate opportunities for meaningful involvement of all people with respect to the development, implementation, and enforcement of environmental laws, regulations, and policies.”
EJ areas in Illinois are derived from US Census Block Groups where the population consists of a substantial amount of minorities and/or the area is heavily populated by persons and families living below the poverty line. Further information on how EJ areas are established can be found at Illinois EPA EJ Start (arcgis.com), which also includes a map identifying all EJ areas in the state.
About the Author: Ann O’Brien is a Project Manager at SCS Engineers with 33 years of experience in the printing industry. She assists companies with air, water, and waste management; EPCRA; environmental compliance audits; and Phase I Environmental Site Assessments.
For more information or assistance with identifying ways to lower air emissions or help with maneuvering through the air permitting process at Illinois EPA, contact Ann O’Brien () in Chicago, IL, or Cheryl Moran () in Milwaukee, WI. For assitance in other states please contact .
Agricultural growing and harvesting operations are typically exempt from air planning, permitting and odor nuisance regulations. However, cannabis operations may require approval from the local Planning Commission. They may also require air permits from the local air regulatory agency for manufacturing operations (e.g., for solvents and associated combustion equipment such as boilers). Air permit applications for cannabis manufacturing operations may include the following based on project-specific conditions:
In addition to these permitting services, and to avoid costly nuisance complaints, cannabis growers may also need odor-related services such as:
While these may seem like imposing lists for air planning they are not for engineers who work in the industry.
Developing effective plans to mitigate odors is vital in gaining Planning Commission approvals which often depend upon resolving concerns raised by the public. Comprehensive OAPs and OMPs include odor control Best Management Practices (BMPs) and adaptive management strategies for responding to odor complaints when cannabis operations are near residences and schools.
Odor Control – Odor Nuisance Mitigation Case Study
Cannabis greenhouses in the Carpinteria, California region were causing off-site odor nuisances at nearby residences. The inherent smell needed addressing, as odor-neutralizing vapors along cannabis greenhouse perimeters and ridgelines were not providing adequate odor control.
Working with Cannabis Association for Responsible Producers (CARP) Growers, Pacific Stone, Groundswell, and Envinity Group, SCS Engineers utilized its air quality and odor expertise to collect continuous measurements using our SCSent-i-PED (Pollutant and Environmental Data). SCSent-i-PED is a state-of-the-art method for measuring TRS compounds to the parts per billion (ppb) level. The system can assess concentrations in real time, and a single machine can assess multiple locations and sources within a facility. This method successfully assessed relative odor levels and spatial/temporal fluctuations in odor-causing emissions.
Data collection is vital and useful to:
SCS, through its years of experience in air quality and odors, provides cost-effective, sustainable solutions that enable greenhouses and facilities to coexist in urban and suburban environments. Our clients not only get solutions, but they also have the data and science to understand better how odors behave and vary within a cannabis greenhouse.
To learn more, watch a video about air planning and managing greenhouse odors at https://www.scsengineers.com/services/clean-air-act-services/odor-monitoring-and-control/
About the Author: Paul Schafer is a Vice President and Project Director at SCS Engineers and the firm’s National Expert on Ambient Air Monitoring. During his technical career, Paul has assumed key roles in several nationally significant monitoring efforts. He has in-depth experience interfacing with regulatory agencies regarding the performance of monitoring systems, source emission tests, and continuous process monitors, which SCS operates for our clientele. He has had direct working experience with multiple local, state, and federal agencies regarding monitoring programs and air quality impact assessments. As with all solutions at SCS, cost control management and defensible technical performance are primary goals integral to all sustainable monitoring programs.
UPDATE 4-29-25: the Governor’s office put a hold on Amendment 9, and the Waste Management Board has announced its intention to formally withdraw Amendment 9 (see Agenda Item 4 and Tab C).
The Virginia Waste Management Board (Board) approved the final action, Amendment 9, to the Virginia Solid Waste Management Regulations (VSWMR) at its Board meeting on October 28, 2022. Since that approval, the final regulation has been under executive review. The Secretary of Natural and Historic Resources review resulted in a request to withdraw the final regulation, as the discretionary changes are unnecessary and do not further protect public health nor the environment (see attached memo).
Amendment 9 included provisions related to 1) landfill siting and setbacks, 2) landfill operations, 3) landfill gas monitoring, 4) landfill groundwater monitoring, 5) open burning exemptions, and 6) clarified other requirements. Landfill siting and setbacks as well as open burning exemptions can both be addressed by local governments exercising their authority, such as zoning and land use controls and the solid waste management planning process. Landfill operations and landfill gas monitoring can both be addressed by the Department of Environmental Quality (DEQ) through the existing solid waste management permitting process. The VSWMR provisions in 9VAC20-81-430 already authorize DEQ to include conditions that are necessary to protect public health or the environment, or to ensure compliance with the VSWMR. For example, DEQ has already included the topographic survey requirements contemplated by Amendment 9 into existing landfill permits where necessary on a case-by-case basis. Amendment 9 also included landfill groundwater monitoring requirements, including a placeholder for emerging contaminants with pending Maximum Containment Levels (MCLs). As placeholders, further amendments would have been required to fully operationalize these provisions. In addition, since Amendment 9 was contemplated, legislation has been enacted in Virginia to address PFAS, including legislation that provides for monitoring at landfills in watersheds that provide source water for drinking water facilities that have measured MCL exceedances for PFAS in finished drinking water.
In its October 28, 2022, meeting, the Virginia Waste Management Board voted to adopt changes to the Virginia Solid Waste Management Regulations known as Amendment 9. Amendment 9 was initiated several years ago, and the amendments address issues that have arisen since the previous amendment. The changes involve updated standards for siting, operation, and monitoring of landfills as well as revising exemptions for open burning of waste. Following adoption by the Board, the amendment is now undergoing Executive Branch Review.
Some of the key changes that are part of this amendment include the following:
Follow SCS Engineers on your preferred social media channel for additional details, or contact us at .
About the Authors:
Josh Roth, PE, is a Vice President and Project Director with the Landfill Gas (LFG) Group in the SCS Reston, VA office. He supports LFG engineering projects involving remediation system design, emissions inventories and air permitting, migration and odor control, ambient air sampling and reporting, LFG and CER due diligence projects, GHG emission mitigation and reporting, field sampling and assessments, and general emissions control projects.
Mike Mclaughlin, PE, JD, is SCS Engineers’ Senior Vice President of Environmental Services. He is a licensed engineer and attorney with over 40 years of professional experience providing advice on environmental matters. He is an expert on environmental compliance, remediation, and allocation of response costs. He is a member of the Board of Governors of the Virginia State Bar Environmental Law Section, and Budget Officer of the American Bar Association’s Section of Environment, Energy and Resources (ABA SEER).
Hydrogen is commonly produced using steam methane reforming (SMR), which requires heat, a catalyst, and feedstock such as natural gas. SMR operations generate atmospheric emissions from combustion and process vents which may require air permitting. Air permitting can be a complicated process that delays facility construction and project start-up.
Comprehensive feasibility studies include phases to facilitate pre-application meetings and submission of a complete air permit application in a timely, cost-effective manner. Based on our case studies, SCS suggests a four-phase approach.
Phase 1: Preparation and Due Diligence
To begin the evaluation, your engineer compiles all available project information, such as plot plans, process flow diagrams, equipment lists with specifications, zoning, grading, and utilities. Since project specifications are subject to change, your engineer must remain flexible and iterative in their analysis approach as new data becomes available.
Phase 2: Emissions Analysis
The next phase is to calculate the project’s potential to emit criteria pollutants and greenhouse gases (GHGs). The calculation assesses potential requirements for Best Available Control Technology (BACT), emission offsets, Title V, and climate change mitigation. Always use an engineering firm with expertise in GHG emissions inventories and third-party verification of GHG emission inventories and reduction credits. Here’s why, based on the analysis, your engineer will be looking for these factors to smooth the application process:
Project emissions complied with BACT limits based upon a comparison to other permitted SMR facilities.
Project emissions that require the purchase of carbon credits on an ongoing basis to comply with Cap and Trade regulations.
Project emissions that do not trigger the need for emission offsets or Title V.
Phase 3: Regulatory Review
Conducting a regulatory review will identify potential requirements from local regulations such as California’s South Coast Air Quality Management District (SCAQMD). Using SCAQMD as an example, the project must comply with the additional rules.
Phase 4: Results and Conclusions
The comprehensive feasibility study summarizes the potential air quality permitting thresholds, requirements, costs, and schedule for your project. It includes all conclusions and supporting data for decision-making. With a comprehensive study in hand, your project is more sustainable, and you have valuable answers during discussions leading to obtaining a complete air permit.
SCS has over 50 years of environmental experience and trusted working relations with regulatory agencies. Many local, state, and federal agencies attend our free webinars, and industry associations request our input and insight when agencies are planning new rules. We serve as expert witnesses. If you’d like to learn more about developing air permitting strategies and applications, visit our website or contact us at .
About the Author: Greg Hauser is a Project Director responsible for environmental compliance projects. Greg brings over 30 years of experience with compliance topics such as air quality permitting, emission inventories, dispersion modeling, health risk assessments, and odor impact assessments. He surveys facilities to identify sources of interest, collects field samples of odorous emissions, develops odor emission profiles based on odor concentrations and flow rates, and conducts dispersion modeling to predict odor concentrations at or beyond the facility’s property boundary. He also provides health risk assessments for aerospace, manufacturing, wastewater treatment, and oil and gas facilities.
Glenn Haave has had a close relationship with protecting our environment for years, ever since his days working on the ocean towing ships in and out of ports. He figured his deep appreciation of his natural surroundings and desire to protect them might carry into his chosen career path, especially after earning a Bachelor of Science in Geology. But when he came to SCS Engineers as a high-spirited, new graduate, he had no idea of the opportunities that would come his way— both at SCS and serving in the U.S. Coast Guard Reserves.
“Both SCS and the Coast Guard hold you accountable to rise to the occasion and get the job done. With that trust and delegation of responsibilities, I am challenged to become a leader, which gives me a sense of duty and confidence,” Haave says.
Combining Geology, Hands-On Experience, and Teamwork
Starting at SCS doing groundwater and soil sampling and helping remediate landfills for redevelopment, Haave proved to be a fast learner. Quickly building on his skills, he was presented with a unique proposition– to join one of only a few multidisciplinary teams in the country that design and install deep well injection infrastructure. EPA-approved injection wells are safe for placing fluids underground into porous geologic formations. These underground formations may range from deep sandstone or limestone to a shallow soil layer. Injected fluids may include water, wastewater, brine (salt water), or water mixed with chemicals.
Planning, permitting, and executing these projects is a multifaceted undertaking encompassing geologic consulting, reservoir engineering, and deep drilling, with environmental protections and sustainability as core goals.
“Few geologists ever get to work on this type of job. These projects require a lot of capital, time, and very specialized expertise. I was fortunate to be working at SCS’s Miami office at the right time, able, and willing,” says Haave, drawn to complex tasks calling for a razor-sharp eye for detail, focus, and discipline.
Drawing on his experience supporting the Miami-Dade Water and Sewer Department Ocean Outfall Legislation Injection Well Program, where he saw 11 wells constructed in a demanding, high-profile project, he is now on a multidisciplinary team of SCS professionals.
Innovations in Carbon Sequestration – Protecting Our Environment
Now, he takes on a new charge: working on a type of deep injection well called a Class VI well. This sophisticated infrastructure directs carbon dioxide (CO2) liquids and gases into the ground for long-term storage. A fairly new, EPA-approved carbon sequestration technique, it is proven effective at substantially reducing CO2 emissions to the atmosphere.
“Class VI wells are an exciting evolution as the world looks to decarbonize the economy. I feel like I am part of an extraordinarily innovative solution where I am using my background to support a global effort to impact our climate positively,” Haave says.
“I feel a sense of purpose in that we are helping mitigate exponential global warming. At least as important, I am comforted that what we do brings hope that my son, daughter, and their generation will grow up on a healthy, safe planet.”
Another Dimension – U.S. Coast Guard A School
As he embraces this unique opportunity to help the environment, he celebrates another milestone: graduating from U.S. Coast Guard A School and advancing in rank to Marine Science Technician Petty Officer Third Class. His calling will be responding to pollution incidents to protect U.S. waters and inspecting facilities and container vessels that transfer hazardous materials to and from land.
Getting into the Reserves is not easy, nor are the next steps. Making it into A school after boot camp is typically a two-year journey: the waiting list of accomplished graduates is long.
Haave finished three intensive months of classroom work; mock training in the field, morale-building exercises to keep spirits high while away from family and friends, and a battery of testing.
Through these rigorous trials, he took on the honorary role of Master at Arms, leading and mentoring his shipmates and serving as a liaison between the crew and captain.
“Becoming a Coast Guardsman was like a dream come true. It was something I had wanted to do since I was 19. But I needed time to mature. I did a lot of soul searching before I could fully realize what was entailed in living up to Coast Guard expectations; to truly embrace that it’s about a sense of duty to country and family, and to deliver on that conviction,” says Haave, now 37, and nominated as a most inspirational person by his shipmates and instructors.
When he shared his long-envisioned, materialized aspiration with his SCS supervisors, he was unsure what they would think; he was taking on another big commitment.
“They were not only accommodating, but they are proud. SCS Engineers is a military-friendly organization. They are always supportive, flexible, and believe in me.”
In the Coast Guard, he had a choice from a far-encompassing list of specialty areas, given his high military school entrance score. He chose marine science technology because it tied in with his civilian work – navigating and ensuring adherence to federal regulations and being a steward of the environment.
Looking Forward
Gazing back at how far he’s advanced in just the last few years, then looking forward, Haave says, “You know, I’m just 37 years old. I feel like I have a lot more in my gas tank –the amazing experiences I have been fortunate to have are just the beginning. I see more opportunities to advance as a leader and to become an even more rounded geologist, able to approach every project comprehensively and deeply.”
We thank all of our veterans and appreciate Glenn Haave for his service to the U.S. Coast Guard and his commitment to protecting our environment with SCS Engineers by advancing sustainable environmental practices and solutions.
Find out more about carbon sequestration and greenhouse gases:
Video: Building a Well
Information: Deep Well Injection and Sequestration Wells
Video: Carbon Sequestration for Landfills and GHG Tutorial
Safe engineering takes discipline and teamwork –qualities that have always served SCS and our clients with innovative, proven solutions for running operations more efficiently and greener. For a rewarding career, consider SCS Engineers, where all employee-owners have a vested interest in every solution.
Corporate Headquarters
