According to Sean Bothwell, the executive director of the California Coastkeeper Alliance, “There are … thousands of facilities that have failed to enroll in the industrial stormwater permit, creating an economic disadvantage for those facilities that are doing their job to be compliant with their permit. SB-205 will level the playing field for the regulated community and help California achieve their mission of attaining swimmable, fishable, and drinkable California waters.”
California’s Stormwater Multiple Application and Report Tracking System (SMARTs) currently shows approximately 13,000+ active industrial stormwater sites/dischargers (Notice of Intent and No Exposure Sites). For these current General Stormwater Permit (IGP) enrollee’s vs. non-filers, the playing field has not been level across industrial sectors. There is a cost, sometimes substantial, for being in, and maintaining compliance under the IGP. The Permit is fee-based; water quality regulatory programs and the programs and resources supporting those programs are funded directly with the fees collected by these regulated entities under those programs.
The additional late-permittees and associated fees will help with the challenge of staffing at the State and Regional Boards, for processing and enforcement. As of today, there is not a direct additional fee/fine for the potential late filers; the message being that potential dischargers (or SIC code-based Facilities with a condition of No Exposure) not covered under the IGP should enroll as soon as possible, to avoid potential initial fines and future costly penalties.
Future penalties could also include “de facto” regulatory compliance penalties through non-government organizations (NGOs) and environmental group citizen lawsuits and 60-day notice-of-intents under Section 505 of the Clean Water Act. SCS Engineers advises businesses to check the Regional Board to see if they need coverage.
If unsure or unfamiliar with stormwater compliance, seek help from a Qualified Industrial Stormwater Practioner (QISP) or begin by using the resources linked to helpful sites from our blog. Although not a comprehensive list, these types of facilities do need stormwater compliance, as follows:
About the Author: Jonathan Meronek is a State of California Industrial General Permit (IGP) Qualified Industrial Storm Water Practitioner (QISP), QISP Trainer-of-Record (QISP-ToR) and an Envision Sustainability Professional (ENV-SP). With an eye to clients’ operational needs combined with long-term sustainable solutions, Jonathan has performed Site BMP and Pollutant Source Assessments, written Stormwater Pollution Prevention Plans (SWPPPs), and implemented Monitoring Implementation Plans (MIPs); for over one-hundred facilities throughout California.
He continues to provide National Pollutant Discharge Elimination System (NPDES) stormwater services for state, municipal, and private clients across a vast cross-section of industrial sectors. Jonathan works with LRPs, facility managers, and attorneys to re-evaluate facilities comprehensively for NPDES compliance using technology-based BPT/BCT/BAT/NSPS levels of control to reduce and eliminate pollutants of concern in stormwater discharge.
Enviro-Check, a new program at the Wisconsin Department of Natural Resources (WDNR), limits environmental liability for organizations that are making a good-faith effort to investigate and correct violations. Enviro-Check empowers businesses and facilities to verify proactively that they are meeting environmental requirements with a third-party assessment. Many states have similar programs; for our blog, we use Enviro-Check as an example.
There are four steps to participate in the Enviro-Check program:
Step 1 – Notify WDNR 30 days before an audit
Step 2 – Conduct Audit within 365 days of application submittal
Step 3 – Submit Report within 45 days of completing the audit
Step 4 – Take Corrective Action within 90 days of a report
Enviro-Check and guidance in other states are beneficial anytime but are especially useful when there are changes at a facility, such as staff or management turnover, replacing equipment or expanding the operations, buying or selling a business, or when new federal or state rules or regulations are announced.
Benefits to your business can include:
SCS Engineers’ environmental compliance teams have experience in air, stormwater, wastewater, solid waste, hazardous waste, spill prevention programs, and emergency response plans. Our auditors and engineers participate in a range of auditing scenarios from single program gap analyses to full environmental compliance audits. Our staff of environmental professionals can help you:
To learn more about how you can have SCS as your third party assessor for WDNR’s Enviro-Check or a program in your state, contact
This week, 271 chrome plating facilities in California received an order from the California State Water Resources Control Board (SWRCB) mandating the investigation of Per- and poly-fluoroalkyl substances (PFAS) at their facilities. Up until 2016, fume suppressants used by these facilities often contained perfluorooctanesulfonate (PFOS), a variety of PFAS.
PFAS consists of thousands of entirely man-made chemicals characterized by a strong bond between fluorine and carbon that have many manufacturing and industrial applications. They are also found in consumer products such as carpeting, apparel, personal care items, and fast food paper wrappings. PFAS is used in firefighting foam, wire and cable coatings, and in the manufacturing of semiconductors. Health studies have linked small doses of PFAS, including PFOS, to reduced immune response, raised cholesterol, and cancer.
PFAS has been widely used within the chrome plating industry as a chemical fume suppressant. According to the National Association for Surface Finishing, it’s estimated that 30 – 40% of surface finishing facilities have chromium electroplating processes. The beginning of its use in the industry goes back to the 1950s and most recently has been required by many states to reduce harmful hexavalent chrome air emissions. Because the chrome plating industry is so highly regulated and monitored, the required use of PFAS in the plating process is well known and therefore has been “on the radar” of state and federal enforcement agencies as potential sources for PFAS pollution.
For more information or assistance with PFAS in the chrome plating industry in California, contact Senior Geologist Lyn Love at 562-426-9544 or .
For help assessing and managing PFAS nationwide please contact for assistance.
About Wendell Minshew: Wendell is a Senior Project Manager in our Sacramento office. He has over 30 years of engineering experience. He specializes in civil engineering services in the planning, design, permitting, and construction management of solid and hazardous waste facilities. He is a licensed Professional Engineer in California and Nevada.
And an amazing photographer!
Per- and poly-fluoroalkyl substances (PFAS) are receiving increasing attention from regulators and the media. Within this large group of compounds, much of the focus has been on two long-chain compounds that are non-biodegradable in the environment: PFOS (perfluorooctane sulfonate) and PFOA (perfluorooctanoic acid). Long detected in most people’s bodies, research now shows how “forever chemicals” like PFAS accumulate and can take years to leave. They persist even when excreted through urine. Scientists have even tracked them in biosolids and leafy greens like kale. Recent studies have linked widely used PFAS, including the varieties called PFOA and PFOS, to reduced immune response and cancer. PFAS have been used in coatings for textiles, paper products, cookware, to create some firefighting foams and in many other applications.
Testing of large public water systems across the country in 2013 through 2015 found PFAS detected in approximately 4 percent of the water systems, with concentrations above the USEPA drinking water health advisory level (70 parts per trillion) in approximately 1 percent (from ITRC Fact Sheet.) Sources of higher concentrations have included industrial sites and locations were aqueous film-forming foam (AFFF) containing PFAS has been repeatedly used for fire fighting or training.
Source identification is more difficult for more widespread low-level PFAS levels. For example, in Madison, Wisconsin, PFAS have been detected in 14 of 23 municipal water supply wells, but the detected concentrations were below the USEPA’s health advisory levels for PFOA and PFOS. A study of potential PFAS sources near two of the Madison wells identified factories, fire stations, landfills, and sludge from sewage treatment plants as possible sources, but did not identify a specific source.
With the EPA positioned to take serious action on PFAS in late 2019 and 2020, regulators in many states have already started to implement their own measures, while state and federal courts are beginning to address legal issues surrounding this emerging contaminant. State actions have resulted in a variety of state groundwater standards for specific PFAS compounds, including some that are significantly lower than the USEPA advisory levels. These changes mean new potential liabilities and consequences for organizations that manufacture, use, or sell PFAS or PFAS-containing products, and also for the current owners of properties affected by historic PFAS use.
Questions for manufacturers, property owners, and property purchasers include:
If remediation is required, a number of established options to remove PFAS from contaminated soil and groundwater are available, including activated carbon, ion exchange or high-pressure membrane systems. On-site treatment options, including the management of reject streams where applicable, are also available.
Do You Need Help?
Need assistance with PFAS or have an idea that you would like to discuss? Contact for more information.
Use these resources to explore more about PFAS each is linked to helpful articles and information.
SCS Engineers welcomes Mark Pearson, P.E, to the firm’s environmental engineering practice. As a Project Director, he and his team will provide water and wastewater engineering and consulting to public and private entities in the region and the U.S. from SCS’s Overland Park office.
Mark brings decades of expertise in environmental engineering, with an emphasis on wastewater design for water treatment plants, wells, pumping stations, and including sewers and waterlines. His experience includes project management through facility planning, design, and construction phases; a good fit for SCS’s comprehensive solutions.
A Professional Engineer licensed in three states, he supports clients with the design, construction, and implementation of environmental treatment systems for water and wastewater plants and post-industrial use, reuse, and the disposal of liquids. Mark helps support industries and landfills facing increasing regulatory policies, higher standards required by water treatment plants, and the rising costs associated with protecting water supplies.
Mark has worked on a wide range of projects around the world and in the United States. He is a certified Envision Sustainability Professional (ENV SP) and a member of the National Council of Examiners for Engineering and Surveying (NCEES). He earned his bachelor’s degree in civil engineering from the Missouri University of Science and Technology, and his master’s degree in environmental engineering from California State University-Long Beach.
“Mark’s expertise and knowledge enhance SCS’s ability to provide sustainable process treatment design and wastewater solutions to industrial and landfill clients who are responsible for leachate and liquids management, which is a significant operational expense for them,” stated Nathan Hamm, a Vice President of SCS Engineers and Central region lead in the Liquids Management program.
Bill Lape discusses the most frequently asked questions about designing a training program that is part of your facility’s PSM and RMP programs and provides a defensible position during inspections while ensuring that your facility operators and maintainers perform their jobs safely.
Bill tackles all your questions in this article. Set-PSM-RMP-Hut-Hut
SCS Engineer’s Long Beach Headquarters sponsored and participated in the U.S. Vets Storm the Beach 5K/10K Run, Walk & Roll for Veterans event in Long Beach, CA.
U.S. Vets is an impressive organization supporting our Veterans in Long Beach, many of whom are homeless. These men and women who have served our country receive housing, employment opportunities, and counseling services from this private non-profit organization.
Participating this year, left to right: Sonia Aguirre, Wendy Mendoza, Sara Garcia and husband, Brendan McGarrity, Jennifer McCafferty, Stacey Dolden, Deidra McGrew and Hanna Suh and friend.
Visit our website and look for careers with our award-winning team of professionals.
SCS Engineers’ Arizona office is continuing to grow with the addition of Dana Justice, a marketing specialist, who previously worked at the award-winning firm’s office in San Diego.
“Dana brings fresh ideas, strong problem-solving skills, and creative business development tactics to the Arizona office,” said Dan Sola, Arizona project director of SCS Engineers.
Justice is responsible for supporting marketing and business development in Arizona, Nevada, and California for environmental services. Her job responsibilities include engaging in business development outreach and continuing to strengthening the firm’s client success culture. As an employee-owned environmental consultant and contractor, SCS excels at accomplishing specific technical needs and high quality but also strives to provide a superior working relationship with their clients.
“SCS has great company culture with a sense of family among the staff,” Justice said. “I’m thrilled to take on a larger role in the Southwestern region and new responsibilities at SCS.”
Justice earned a bachelor’s and master’s in business administration from California State University San Marcos. She lives in Mesa.
The Arizona office has completed 3,500 projects during the last 30 years for the solid waste industry, government, and other industries responsible for safeguarding the environment as part of doing business.
Wendell, a Senior Project Professional in the SCS Engineers Sacramento office became interested in photography 35 years ago. He had broken his ankle and needed something to do because he felt grumpy not being able to play tennis. His tennis partner loaned him a camera, some film, and his dark room.
Wendell was hooked.
Wendell’s beautiful photos capture the reason we work with our clients to protect our environment. See a few pieces of his organic work, and look for more soon.
Mr. Minshew has over 30 years of engineering experience. He specializes in civil engineering services in the planning, design, permitting, and construction management of solid and hazardous waste facilities. He is a licensed Professional Engineer in California and Nevada.
Thank you for sharing, Wendell.
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