environmental consulting

May 6, 2020

CERLCA Jurisdiction and PRP Definition

A recent Meyers | Nave publication discusses the Supreme Court’s April 20, 2020 decision in Atlantic Richfield Co. v. Christian. The firm suggests the decision adds another layer of complexity to the Comprehensive Environmental Response, Compensation, and Liability Act – CERCLA, liability issue. The decision opens the door for state courts to hear claims that challenge EPA-defined approved clean-ups and has the potential to expand the “potentially responsible party” – PRP class for current “owners” of a “facility.”

The Court’s decision introduces new considerations into CERCLA liability analysis and settlement strategy. The Court’s holding will have many immediate ramifications, including the following:

• It may be argued that the decision broadens the definition of PRP. CERCLA’s already-expansive definition of PRPs now includes landowners whose soil is contaminated by another PRP’s facility because a release has “come to be located” on their land.

• The decision has the potential to unravel comprehensive and time-consuming CERCLA requirements in a federally-approved clean-up scheme. For example, if EPA waives the requirement to adopt state applicable or relevant and appropriate requirements (“ARARs”) at a federal CERCLA site, it seems entirely plausible that some litigants could use a nuisance or similar lawsuit to seek to impose ARARs that EPA specifically considered and waived.

• The decision might have created an additional layer of CERCLA requirements that apply to PRPs that desire to bring state law claims in state court. Though they were found to be PRPs, the plaintiff landowners were allowed to present their own plan to restore their own private property as long as they obtained EPA approval, but it is unclear what process the landowners would use.

• The decision might reduce the incentive to enter into CERCLA settlements with EPA if parties are not shielded from contribution claims − which now could arise by exposing settling parties to potential litigation at the state level. While the Court noted that CERCLA: (1) encourages covenants not to sue which cap liability to the Government and (2) protects settling parties from contribution claims by other PRPs, the decision seems to contradict both of those positions and undermines finality of settlements.

Clean Water Act Developments

In April, the courts and federal agencies announced major developments significantly affecting regulation under the Clean Water Act – CWA and how the CWA may be applied in the future.

• First, a U.S. District Court in Montana issued a sweeping decision under Section 404 of the CWA that purports to invalidate and enjoin the use of Nationwide Permit 12 (NWP 12), the widely-used general CWA § 404 permit for construction of pipelines and other utility lines across regulated water bodies, for all projects anywhere in the country.

• Second, the Trump Administration published its long-anticipated “Navigable Waters Protection Rule” in the Federal Register, defining what constitutes Waters of the United States (WOTUS) that are regulated under the CWA, which is narrower in scope than both the 2015 rule promulgated by the Obama Administration and the pre-2015 rule now in effect.

• Third, the Supreme Court issued a decision in County of Maui, Hawaii v. Hawaii Wildlife Fund, et al. (No. 18-260) in which the majority held that a CWA discharge permit is required where “the addition of the pollutants through groundwater is the functional equivalent of direct discharge from [a] point source into navigable waters [i.e., WOTUS].”

Each of these developments could have far-reaching implications for regulations under the CWA. Assuming the 2020 Rule withstands legal challenges, it is seen as favorable for industry and other regulated entities, while the two judicial decisions are perceived as problematic for such entities. Davis Graham & Stubbs describes each development in more detail in the firm’s recently published article.

MATS Supplemental Cost Finding and Clean Air Act RTR 

On April 16, 2020, the U.S. Environmental Protection Agency (EPA) finalized the 2016 Supplemental Cost Finding for the Mercury and Air Toxics Standards – MATS, for coal- and oil-fired power plants, consistent with a 2015 U.S. Supreme Court decision. The agency also completed the Clean Air Act-required residual risk and technology review – RTR, for MATS. According to the EPA power plants are already complying with the standards that limit emissions of mercury and other hazardous air pollutants (HAPs), and this final action leaves those emission limits in place and unchanged.

However, with this final action, EPA is not removing coal- and oil-fired power plants from the list of affected source categories for regulation under section 112 of the Clean Air Act, consistent with existing case law. Those power plants remain subject to and must comply with the mercury emissions standards of the MATS rule, which remains fully in effect notwithstanding the revised cost-benefit analysis.

In addition, EPA has completed the required RTR for MATS and determined no changes to the rule are needed to further reduce residual risk. The RTR satisfies the statutory requirements set out by Congress in the Clean Air Act. More information is available on EPA’s Mercury and Air Toxics Standards website.

Proposal to Retain NAAQS for Particulate Matter

On April 14, 2020, the U.S. Environmental Protection Agency – EPA announced its proposal to retain, without changes, the National Ambient Air Quality Standards – NAAQS for particulate matter (PM) including both fine particles (PM2.5) and coarse particles (PM10).

According to the EPA because of Clean Air Act programs and efforts by state, local and tribal governments, as well as technological improvements, average PM2.5 concentrations in the U.S. fell by 39 percent between 2000 and 2018 while average PM10 concentrations fell by 31 percent during the same period.

EPA states it is following the principles established to streamline the NAAQS review process and to fulfill the statutory responsibility to complete the NAAQS review within a 5-year timeframe. More information about the rule can be found at EPA’s: National Ambient Air Quality Standards (NAAQS) for Particulate Matter (PM) Pollution website.

EPA will accept public comment for 60 days after the proposed standards are published in the Federal Register. EPA plans to issue the final standards by the end of 2020.

U.S. Greenhouse Gas Emissions and Sinks Inventory Announcement

The Environmental Protection Agency’s annual report, “Inventory of U.S. Greenhouse Gas Emissions and Sinks: 1990-2018,” provides a comprehensive look at U.S. emissions and removals by source, economic sector, and greenhouse gas – GHG. The gases covered by this inventory include carbon dioxide, methane, nitrous oxide, hydrofluorocarbons, perfluorocarbons, sulfur hexafluoride, and nitrogen trifluoride. The inventory also calculates carbon dioxide emissions that are removed from the atmosphere by “sinks,” e.g., through the uptake of carbon and storage in forests, vegetation, and soils.

On April 13, 2020, the EPA’s comprehensive annual report on nationwide GHG emissions released to the public. It shows that since 2005, national GHG emissions have fallen by 10%, and power sector emissions have fallen by 27%.

“While there was a small rise in emissions due to weather and increased energy demand from the prior year in this report, based on preliminary data, we expect next year’s report to show that the long-term downward trend will continue,” said EPA Administrator Andrew Wheeler.

According to the announcement, annual trends are responsive to weather variability and economic conditions. Year-over-year, national GHG emissions were 3% higher in 2018 than the prior year, due to multiple factors, including increased energy consumption from greater heating and cooling needs due to a colder winter and hotter summer in 2018 compared to 2017.

According to environmental and research groups, driving the drop’s long-term downward trend is chiefly due to a shift away from coal power generation. The 2019 drop was driven by a nearly 10 percent fall in emissions from the power sector, the biggest decline in decades [Rhodium Climate Service]. Utilities are closing coal plants in favor of cheaper natural gas and renewable energy.

Emissions from industry rose slightly last year, and are now greater than those from coal-fired power plants, most driven by a strong economy. Emissions from buildings were up, and emissions from other sectors of the economy collectively grew by more. The shift to lower-carbon energy is largely restricted to the electricity sector, and in order to meet international and state goals, state policies continue to target other sectors that collectively make up a majority of U.S. emissions.

More information is available at EPA’s website Inventory of U.S. Greenhouse Gas Emissions and Sinks.

For more information about potential impacts to waste, energy, or manufacturing please contact your nearest SCS Engineer’s office or your Project Manager. 

May 4, 2020

In this Waste Today article, Sam Cooke discusses the factors, treatment options,  analytical methods,  and identifying PFAS sources to most effectively reduce the concentrations of ammonia and PFAS in landfill leachate.

Reducing these concentrations help meet discharge permit requirements for direct discharge of treated leachate to surface waters and to meet publicly owned treatment works (POTW) discharge permit standards.

Sam points out that accomplishing ammonia and PFAS reduction with established wastewater treatment technologies works, but the right treatment depends on each site’s specific parameters. He suggests conducting bench-scale and pilot-scale testing for any feasible nitrogen removal or treatment system.  Testing the wastewater helps to identify any changes in the concentration of nitrogen compounds. Thus, necessary changes to the treatment processes, such as additional aeration or chemical additions are easier to identify and less costly to implement.

Best practices for treating ammonia in landfill leachate, Waste Today

About the Author: Mr. Cooke, PE, CEM, MBA, is a Vice President and our expert on Industrial Waste Pretreatment. He has nearly three decades of professional and project management experience in engineering with a concentration in environmental and energy engineering. Mr. Cooke works within SCS’s Liquids Management initiative to provide services to our clients nationwide.

Learn more about liquids management at landfills.

May 1, 2020

SWANA’s Badger Chapter Board of Directors recognized Lindsey Carlson with the YP of the Year Award. 

Lindsey is an employee-owner at SCS Engineers on the solid waste management team performing Construction Quality Assurance – CQA and reporting for field projects, as well as OM&M on landfills and assisting with landfill reporting and compliance.

Lindsey earned her BS in Soil and Waste Resources—Waste Management from the University of Wisconsin—Stevens Point in the Summer of 2018. She currently serves on the SWANA Badger Chapter Board and is co-YP Liaison, plus participates in SCS’s Young Professionals program.

Lindsey recently published an article Finding Solutions for an Open Dumpsite: Solid Waste in The Gambia in the April edition of the Badger Chapter YP Newsletter.

The Gambia, is a tiny sliver of a country in West Africa, has a population of just under 2.5 million. About a fourth of the country’s population is under the jurisdiction of the Kanifing Municipal Council (KMC) – the most densely populated area of The Gambia. The people and leadership of the Kanifing municipality are united in their desire to have positive changes in solid waste management in the community and at the Bakoteh dumpsite. Ideally, solving the problem will implement a means of positive change for many aspects of the KMC citizens’ lives.

Outside of work, Lindsey is a self-described “bird nerd” who has two parrots: A Green Cheek Conure (7 years old) and a Yellow-Naped Amazon (34 years old). She often volunteers at Feathered Friends Sanctuary and Rescue where they provide care for around 65 surrendered parrots.

Congratulations Lindsey! We’re very proud of you.

April 30, 2020

Scientists and experts agree that climate change is a present-day threat to communities across the U.S., manifesting in both predictable and unpredictable ways. As detailed in the National Climate Assessment Vol. 4 (NCA4), coastal storms are increasing in strength and frequency, forest fires are becoming much larger and more destructive, annual precipitation is changing and increasing in variability, and widespread flooding is becoming more common both in the interior of the nation and along the coasts.

These changes present complex challenges to the waste management industry that must be addressed and planned for. For example, one challenge is an increasing frequency of large-scale weather events and natural disasters, which are creating more debris that must be managed and which affects the characteristics of landfilled waste. Landfill design needs to incorporate precipitation changes and increased threats due to weather variability, flooding,  and sea-level rise. Precipitation changes affect gas generation rates and require a diligent reaction to maintain effective gas collection. Because of weather pattern changes, risks of cover material erosion and swales have increased for landfills in both wet and dry climates, which may require stronger natural caps or the use of emerging technologies for alternate cover. Additionally, landfills are affected by an increase in the variability of precipitation and rapid changes between weather extremes.

It is clear that waste management facilities must adapt to these changes in addition to scenario building for pandemics to maintain effective operations. Adaptations available include making changes to landfill design and planning, such as incorporating precipitation changes into the modeling of leachate and gas generation or increasing the distance between the bottom liner and groundwater.

Systems should be regularly evaluated and areas needing repairs should be corrected quickly and diligently. Gas generation models should be updated regularly and collection systems need to be expanded or adjusted to account for precipitation increases or decreases.

More frequent and intense storms are creating challenges for cover material management, liquids management, and maintaining slope stability. Facilities should implement innovative uses of both existing technology and new or emerging technologies.

Communities with waste management facilities should include waste management infrastructure in emergency management plans, including maintaining landfills and collections operations and using landfills as both temporary debris storage and as an option for final disposal.

Since climate change effects vary by region and locale, many facilities are developing a specific plan for adaptation and management. To reduce the inevitable costs of adaptation and maintain responsiveness to weather changes, a reactive approach is being abandoned in favor of a proactive approach.

About the Author: Jacob Shepherd is a Senior Project Professional specializing in air compliance and reporting within EPA Region III. He is experienced in environmental engineering, air compliance, renewable energy, landfill and landfill gas engineering, and environmental services throughout the mid-Atlantic region, and is a licensed P.E. in Virginia.

Resources and Recovery
Get started with these resources and recovery success studies; click to read, download, or share each:

• County Removes 573,866 Cubic Yards of Debris in 99 Days
  Manatee County, Florida solid waste division’s removal plan serves as a model for natural disaster response. Covered by Public Works Magazine.
• Is Your Solid Waste Infrastructure at Risk from Hurricanes and Flood Events? The article discusses how operators can help prevent damage to their critical solid waste facilities that need to function during and after a major storm. Covered by Waste Advantage Magazine.
• Expansion of An Active Landfill  – Vertical expansion increases the landfill volume within the existing footprint of the permitted Landfill. A landfill can run out of its storage capacity prematurely for many reasons including a response to a huge amount of debris waste from a natural disaster like a tropical storm or hurricane. Covered by ISWA.

Contact for assistance starting or refining your plan ahead of natural disasters and pandemics. We offer these services:

Planning for Natural Disaster Debris – help for communities to develop or revise a disaster debris management plan. Many aspects of disaster debris planning can be relevant to communities demolishing abandoned residential buildings and remediating properties.

Guidance about Planning for Natural Disaster Debris – much of the construction or demolition waste can be recovered and recycled. SCS Engineers designs and builds these facilities so we can help locate the nearest C&D debris recyclers as part of your plan.

Planning Financial Response and Recovery – the SCS Management Services™ team offers services to support financial planning and to quickly access budget and operational financial impacts. Eliminate concerns about the upcoming fiscal year expectations and anticipated medium-term impacts of pandemics and natural hazards on local government operations and revenue streams. Address issues such as:

April 13, 2020

Do you know how much oil you store in aboveground containers at your facilities? If you have more than 1,320 gallons at a facility, you may need an SPCC Plan. SPCC stands for Spill Prevention, Control and Countermeasure, and it is a federal rule (40 CFR 112 in the Federal Register) designed to prevent oil-based products from entering navigable waterways of the United States. But it’s about more than just compliance. It’s an important tool to help you limit your liability.

As a utility leader, your focus is to deliver electricity to your customers; however, facilities covered under the SPCC Rule are subject to inspections and potential enforcement actions if your practices are out of compliance.

Does the SPCC rule apply to me?

The 1,320-gallon threshold isn’t the only requirement for an SPCC Plan. The SPCC Rule only counts oil storage containers with a capacity of 55 gallons or more. Many electric utility facilities will meet the oil storage threshold, including substations, storage yards, power plants, and operations and maintenance facilities.

Another criterion is that a facility must reasonably be expected to discharge oil into navigable waters or adjoining shorelines of the U.S. The Environmental Protection Agency (USEPA) does not define what “reasonably be expected” means. Instead, the responsibility is on the facility owner or operator to determine the potential for discharge. In reality, it’s usually easy to think of a scenario where spilled oil could reach a waterway. Even if you think a spill would never reach the stream, what if there was a significant rain event that washed away spilled oil on the ground through a storm sewer? Often “reasonably be expected” is not challenged, and it’s best to err on the side of caution.

The SPCC rule applies to my facilities, now what?

It’s time to prepare an SPCC Plan. The Plan summarizes your facility’s oil sources, identifies spill response coordinators, and outlines your spill prevention measures and spill response procedures. There are three options:  1) Prepare the Plan yourself; 2) Use a third-party provider to prepare your Plan; or 3) Have a licensed professional engineer (PE) prepare your Plan. The option you choose depends on how much oil you store at your facility and your working knowledge of the SPCC Rule.

If your facility has less than 10,000 gallons of oil and no single aboveground oil storage container with a capacity greater than 5,000 U.S. gallons, you may prepare your own SPCC Plan, following the USEPA’s Tier I qualified facility template.

You can download the USEPA’s Tier I qualified facility template here: https://www.epa.gov/sites/production/files/2014-05/documents/tier1template.pdf. It is the cheapest way to comply with the SPCC Rule. You need to be familiar with the SPCC Rule’s requirements to complete a self-certified plan. You must also follow all of the requirements without deviation.

If your facility has less than 10,000 gallons of oil and a single aboveground oil storage container with a capacity greater than 5,000 U.S. gallons, you qualify under the USEPA’s Tier II qualified facility category. The USEPA does not provide a plan template for a Tier II qualified facility. You can still prepare the Plan yourself, or you may hire a third party or PE to prepare the Plan for you. If you prepare the Plan yourself, you must still follow all of the requirements precisely without deviating from them.

If your facility has greater than 10,000 gallons of oil storage, you must have a licensed PE prepare and certify your facility’s SPCC Plan. The Rule allows PEs the flexibility to deviate from certain requirements, so you may decide you want a PE to prepare and certify your plan for your Tier I or Tier II qualified facility.

The Value of an SPCC Plan

An SPCC Plan is about more than just compliance. An SPCC Plan contains important information that will be critical if you have an oil spill. The Plan contains inspection forms and protocols that help you maintain your oil sources and prevent a spill from happening in the first place. It identifies the single point of contact, an “SPCC Coordinator” for the facility. If there is a spill, the Plan contains steps to contain and control the spill initially, and the proper contacts to notify internally and externally.

The SPCC Rule requires oil-handling personnel to receive annual training to respond to spills in their work areas properly, and the SPCC Plan contains the material that must be covered in training. The SPCC Plan also contains forms for you to document training, plan reviews and updates, and spill notifications.

Work with your staff to determine if the SPCC Rule applies to you. An SPCC Plan is a required document for certain facilities to help you comply with the SPCC Rule and gain the benefits of having a plan in place. But more than that, it’s a practical document designed to assist with training and inspections while serving the function to help prevent spills from occurring. And if spills do occur, an SPCC Plan provides the guidance to help control the spill and limit your liability.

Read Part II – Are You Ready to Respond to an Industrial Spill?

About the Author: Jared Omernik has 12 years of experience helping electric utilities comply with environmental regulations, including helping utility owners and operators build and review SPCC Plans and Storm Water Pollution Prevention Plans (SWPPPs).

For questions about the SPCC Rule or SPCC Plans, contact Jared at .

March 30, 2020

During this COVID-19 outbreak, many employers, property managers, and property owners are tirelessly working to maintain clean and safe environments for tenants and employees. Cleaning contractors and janitorial services are working overtime, expending considerable efforts trying to maintain clean and disinfected workspaces and buildings. While providing their services, they face continual challenges of not having enough information regarding COVID-19 behavior, and the dwindling supply of cleaning and disinfecting agents.  Many have inquired about microbial sampling and analytical methodologies to evaluate the effectiveness of these cleaning measures.

Some of us have been here before. Twenty years ago, property managers and tenants faced similar challenges in the wake of anthrax contamination of mailrooms in several prominent buildings. The approach we took then—collecting wipe samples from areas of concern for analysis at a nationally-recognized specialty laboratory—can offer peace of mind and an empirical basis for the evaluation of cleaning/disinfection effectiveness.

While specific testing for viruses, including the novel coronavirus (SARS-CoV-2), is not generally available, it is possible to test environments and surfaces for the presence of surrogate clinical pathogens and bacteria—these should be absent if cleaning and disinfection are effective.

Every building, tenant space, and office work environment is unique, and therefore it is important to develop site-specific plans. Staff collecting the samples should be trained in hazardous incident response, including microbiological and chemical impacts on structures and the environment, and should have the proper personal protective equipment (somewhat scarce at present in many locations).

About SCS Engineers

SCS Engineers is a 50-year-old, employee-owned environmental consulting and contracting firm that designs and implements sustainable and innovative environmental solutions. With 70 offices nationwide and nearly 1,000 employees, we are a full-service provider in the solid waste, hazardous waste, and environmental engineering industries. We study challenges and design solutions; we remediate, build and operate environmental and energy projects and systems; and, we evaluate the public health risk of hazardous materials exposure scenarios. As technologies, industry, and public needs change and expand, SCS evolves to provide innovative solutions to our clients’ challenges.

Most states’ guidance considers SCS’s services as essential to protect public health.

Contact SCS today at 800-767-4727 or for additional information and consultation regarding the effectiveness of cleaning/disinfection at your properties and workspaces in your state. Further information about SCS is on our website at https://www.scsengineers.com/.

March 8, 2020

For International Women’s Day, SCS decided to interview one of our own, Nicole Kron, who is a Hydrogeologist in Madison, Wisconsin. Nicole joined SCS Engineers in December 2017, as a project professional in the Environmental Services practice. Nicole graduated with her Bachelors of Science in Geology from the University of Illinois and earned her Masters of Science in Hydrogeology from Illinois State University.

Early in her career, prior to working at SCS, she did a lot of fieldwork – characterizing sites, determining where there might be issues of contamination that would need to be cleaned up, drilling and installing wells, collecting groundwater and soil sampling and just getting an understanding of the geology of the site.

Nicole now focuses more on the evaluation and preparation for the fieldwork. Once the fieldwork is completed, Nicole conducts the evaluation of the lab data that comes back and a groundwater analysis if needed. Based on the data they receive, whether it’s groundwater data or soil data or any other medium, she performs evaluations for what that means for that site. She then develops reports that explain the geology and hydrogeology of the site, the extent of contamination, and what are the next steps, whether that be to close the site or needing to do more work to better define the issue. She assists in a lot of those different areas and helps with managing the reporting and analysis of the findings. 

• What attracted you to SCS Engineers?

Prior to coming to SCS Engineers, I had worked with two other firms. They were good firms but did not always have the warmest culture. I had a friend who worked in the SCS Engineers’ Madison office and mentioned that he enjoyed working for SCS and encouraged me to apply. There’s always going to be challenges and difficult times wherever you work. What I appreciate about working at SCS Engineers is that when there are those challenges, or if I’m having a tough day, there is still an environment of support at SCS and a desire for everyone to achieve their goals. SCS Engineers has the best work culture I’ve ever worked in!

• What is your favorite part of working at SCS?

Working with my team! I also love that I have the opportunity to develop my own career path and can contribute to finding solutions to issues we encounter while working on projects. I always feel respected and not just a “cog in the wheel,” but a part of the team. I appreciate that my work is valued here.

• What do you feel is your greatest achievement or contribution at work?

This is hard to answer! I’m a part of such a great team and am able to do a lot of work for some of our bigger clients in the Midwest. I’ve also taken over as the local SCS Young Professionals Leader for the Upper Midwest, where I help arrange meetings and lead discussions. I work on ways to help the YP’s feel like a connected group, supported while learning new skills, and improving work environments.

• What was your greatest challenge at SCS, and how have you overcome that?

We all have different personalities and strengths to our personalities. There are no personality types that are designed for one type of career. For example, I’m an extrovert and like to collaborate with other people. But, not everyone is an extrovert and may take on challenges differently than I do. On the DiSC chart of personalities, I am a solid “iD,” which means I like to be high-spirited and enthusiastic and am also strong-willed. It’s good to recognize everyone has different strengths and weaknesses, and learning what works and doesn’t work for your team.

• In your college career, were there as many women as men at school in Illinois?

Surprisingly, there were! It was fairly balanced. Many of the women that I attended school with have gone into a variety of fields since graduating – Oil and Gas, government and state agencies, and a few went into environmental consulting. I do see an increase in women joining the environmental field, which is exciting! Most are just starting off in their careers, but I think it’s great that hopefully there will continue to be more women in STEM fields!

• Tell us about “Skype with a Scientist” and how you got involved with this program.

The non-profit organization was started by a graduate student who wanted to ensure that science would continue beyond just the classroom and that students could see scientists as well-rounded people. Scientists are paired up with a classroom over a Skype video conference, and the students can ask questions about the scientist’s work and why they chose their career path. It’s a great opportunity for students to see what scientists are like and what they do. The founder of the program wanted to make sure students would see more of a scientist than the stereotype of a person with a lab coat and goggles on, mixing chemicals all day.

I’ve participated in two sessions – a 4^th-grade class and a 10^th-grade class. The 4^th graders were from Canada, wanted to talk about volcanoes, and where they could find diamonds! The 10^th-grade class happened to be an all-female class. They were excited to learn that I was a dancer and used to perform in plays and on the speech team in college. We also talked about how it is okay to fail sometimes and to recognize failure as part of the journey in your career and in life. Failure is part of being a scientist. If your experiment fails, you can’t just give up. You have to try something new! It was great to be able to remind your students that it’s okay to fail sometimes as long as you learn how to work through it.

• What advice do you have for scientists just entering the field of Hydrogeology?

Don’t discount opportunities to learn something that would be applicable to your field. When I was finishing my Masters, I had an opportunity to take a class that would give me the foundational understanding in this field, but I elected not to take it because I did not believe I would go into environmental consulting. Now I’m working in this field! Yes, it was one class and didn’t hinder my abilities to get a job or do my job today, but you never know what may be in store for you in the future. If you have an opportunity to learn something new, try it anyway! This should go beyond STEM as well. If you have a chance to learn, do it!

• Have you had to overcome any obstacles as a woman in the field of Environmental Services?

As a woman in the environmental field, sometimes you are the minority, but that’s not a bad thing. You are there to contribute and to be a part of a team. It shouldn’t matter the color of your skin, how old you are, or what gender you associate with.

• What advice do you have for women getting into the STEM field?

Remember that your voice is just as important as everyone else’s! Be ready to listen and learn. Your voice has just as much power and meaning as any other person in the room.

• What are your favorite hobbies outside of SCS?

I love to knit, go camping, and kayaking! I also really love to go dancing! I used to take ballroom dance classes when I was younger, so I take any opportunity I have to go dance!

Interview by Lindsay Evans, SCS Engineers Human Resources

March 5, 2020

SCS Engineers welcomes Ben Reynolds, to our Little Rock, Arkansas office. Mr. Reynolds joins the SCS environmental services team providing support to real estate developers, construction firms, and industrial clients in the region. These businesses need to manage air, water, and soil safely within federal and state policies as they operate.

Ben is a Professional Engineer in Arkansas, Oklahoma, and Tennessee. He comes to SCS Engineers from the Arkansas Division of Environmental Quality (DEQ), where he served as the technical branch manager for Assessment and Remediation and in the Hazardous Waste Division as a permit engineer. His expertise and working knowledge from the DEQ is valuable to clients who need support to obtain multiple permits and to complete successfully Brownfield and other voluntary remediation projects.

Working as an environmental engineer, Ben gained experience helping clients with Phase I and Phase II environmental site assessments, Spill Prevention, Control, and Countermeasures (SPCC) Plan, and Storm Water Pollution Prevention Planning (SWPPP). These assessments and plans keep businesses compliant with environmental federal and state regulatory policies. Ben approaches each project analytically, mitigating the financial risk and future liability through careful evaluation, analysis, and planning that protects clients and the environment during all phases of redevelopment or production.

Ben also has experience with real-time telemetry for directional drilling, assisting with well completions, and the production of oil and natural gas. Telemetry is useful in many industries for collecting measurements and other data at remote or inaccessible points. These systems complement SCS’s technologies, SCSeTools® and SCS RMC®, to help streamline monitoring, auditing, and record-keeping, which reduce the cost of operations and of maintaining environmental records. His experience complements and enhances SCS’s Oil & Gas and SCS’s Energy practices too.

Ben earned his Bachelor of Science in Mechanical Engineering at the University of Arkansas. His supplemental professional education includes Establishing Energy Metrics, Closure Cost and Financial Assurance, Resource Conservation and Recovery Act (RCRA), RCRA Sampling Techniques, and Stack Sampling. He is certified as an STI/SPFA SP001 Aboveground Tank Inspector; with OSHA Hazardous Waste Operations and Emergency Response (HAZWOPER) 40-Hour Certified.

“Ben’s a valuable resource for our clients,” stated Dan McCullough. “We’re happy to welcome another SCS member with strong analytical skills and the expertise to resolve complex environmental challenges.” The SCS Engineers Little Rock office supports the growing demand for environmental scientists, engineers, and consultants. SCS professional staff specializes in meeting federal, state, and local clean air, water, and soil goals, and the restoration of property once thought impractical to revitalize.

February 24, 2020

SCS has completed numerous mold surveys for a variety of facilities, such as schools, offices, warehouses, industrial, and commercial buildings. We do not recommend a mold survey if you observe mold — if you can see it, you have a mold issue. Mold is ubiquitous and requires water and food to grow, so if you observe mold growth, the first step is to stop the source of water.

Exposure

There are no promulgated governmental exposure limits for mold, as every individual responds differently to the presence of mold. Mold surveys are typically performed after the water leak has been repaired, and the water damaged building materials have been replaced. This post-remediation survey lets you know if the cleanup has been successful and the area is safe to occupy.

If tenants are complaining of moldy or musty odors, a survey can tell you if you have a mold problem even if there is no visible growth. Mold can be present inside walls, air ducts, and false ceilings, behind cabinets, beneath flooring, for example. Successful survey results will show lower levels of mold spores inside the building compared to the outside sample results, with low to absent levels of concern.

Survey Process
SCS performs indoor air quality or IAQ, mold surveys using the newest battery-powered Zefon Bio-Pump® Plus, which collects an air sample for mold analysis in as little as 5 to 10 minutes, with an auto-shutoff feature once the sample is collected. Typically, a minimum of six samples are recommended, three inside and three outside, with the total number of samples dependent on the size and complexity of the affected area.

We transport the sample cassettes to a certified laboratory under the chain-of-custody protocol for mold spore analysis, with results typically available within 2 to 5 days. Rush analysis is available for an additional cost (same day service is dependent on the time of sample delivery to laboratory). Laboratory analytical reports may include spore counts for approximately 20 types of mold, total count comparisons; background count comparisons; explanation of results with descriptions of the individual spore types; references, and informational links.

Costs
Typical costs for a mold survey range from $2,500 to $10,000, depending on the location, size, and complexity of the survey area. As soon as the review of the laboratory report is complete, SCS provides verbal results, with a technical report typically issued within 10 business days of receipt of laboratory data. Most mold inspection firms utilize technician level workers. Having oversight by a certified industrial hygienist, SCS ensures the most complete and comprehensive survey appropriate to the needs of landlords and owners of commercial buildings and multi-residential dwellings.

If you’d like more information or have questions, please contact Jed Douglas, CIH, CSP, PG, Senior Project Advisor at SCS Engineers, or contact SCS at for an Occupational Health and Safety professional nearest you.

Mr. Douglas is a Senior Project Advisor specializing in Occupational Health and Safety Programs. He is a Certified Industrial Hygienist (CIH), a Certified Safety Professional (CSP), a licensed Professional Geologist in California, Oregon, Washington, and Arizona, and a U.S. Green Building Council LEED Accredited Professional. He has over 25 years of experience as a health and safety specialist and senior project manager, and has managed numerous environmental projects involving safety; soil and groundwater investigations and remediation of hazardous constituents; and, indoor air quality (IAQ) assessments for physical, chemical, and biological contaminants.

February 21, 2020

SCS Engineers has expanded into Green Bay to increase our municipal solid waste and electric utility customer support in the Green Bay/Fox Cities area.

Jared Omernik, SCS senior project manager, and civil engineer is now in Green Bay and available to provide support for local projects. Jared has worked with many of SCS Engineers’ clients from the Madison office over the past five years. Mr. Omernik has experience as an engineer on a wide variety of civil and environmental engineering projects. He has worked on development, permitting, design, construction, documentation, and compliance for a number of projects in several states.

Contact Jared via email at or call 608-216-7348. Thank you for your continued trust in SCS Engineers. We look forward to meeting your engineering and environmental compliance needs.