environmental consulting

September 13, 2017

ERA Level 1 Status

Your facility will need a Qualified Industrial Stormwater Practioner (QISP) to perform an ERA Level 1 Assessment, on or before October 1, 2017, and follow up with an ERA Level 1 Technical Report by January 1, 2018, or as soon as is practicable.  We recommend that this assessment and report be performed prior to the wet season of the 2017-18 permit cycle year, to assist dischargers in reviewing their minimum required BMPs and if needed, implement additional BMPs.

ERA Level 2 Status

Review your ERA Level 1 Action Plan now. Is it correct given the additional NAL exceedances?  You should review all items needed for a successful ERA Level 2 Action Plan and Technical Report to successfully reduce and/or eliminate pollutants of concern in stormwater discharge.

 

Requirements, Actions, Deadlines

Your facility is required to submit an ERA Level 2 Action Plan, prepared by a QISP, which addresses each Level 2 NAL exceedance via SMARTs. This Action Plan must identify which of the three options below (or a combination thereof) of demonstration(s) the Discharger has selected to perform:

  • Industrial Best Management Practice (BMP) Demonstration – Description/evaluation of relevant potential pollutant sources whereby additional Facility BMPs are implemented to comply with all applicable effluent limitations (BAT/BCT, ELGs and/or TMDLs) and to prevent future NAL exceedances (If this is not feasible to implement, you must provide estimated cost and rationale);

 

  • Non-industrial Pollutant Source Demonstration (run-on from adjacent facilities, aerial deposition). This option allows for a Discharger to demonstrate that the pollutants causing the NAL exceedances are not related to industrial activities conducted at the facility, and additional BMPs at the facility will not contribute to the reduction of pollutant concentrations.  The determination that the sources are not from industrial activity or natural background must be done by a QISP; and

 

  • Natural Background Pollutant Source Demonstration (e., iron in soils). This option takes its cue from the 2008 Multi-Sector General Permit (MSGP) whereby and if a Discharger can determine that the exceedance of a benchmark (NAL) is attributable to the presence of that pollutant in the natural background. A Site Plan(s) is very important in this regard which should include, but not limited be to facility locations, available land cover information, reference site and test site elevation, available geology, and soil information for reference and test sites, photographs showing site vegetation, site reconnaissance survey data, and records.

 

The State Water Board acknowledges that there may be cases where a combination of the demonstrations may be appropriate; therefore a Discharger may combine any of the three demonstration options in their Level 2 ERA Technical Report, when appropriate.

It is important to note that Level 2 is a serious situation under the IGP and you should start working immediately on your stormwater management goals for the ERA Level 2 Action Plan, which is due by January 1, 2018. For the BMP demonstration option, Dischargers may have to implement additional BMPs, which may include physical, structural, or mechanical devices that will reduce and/or eliminate pollutants in stormwater discharge.

The ERA Level 2 Technical Report, which summarizes the option(s) chosen and all relevant technical information, including design storm standards for treatment control BMPs, must be overseen and signed by a California Professional Engineer (PE) and submitted by January 1st, 2019.

 

Four important considerations in light of the ERA Level 2 exceedances:

    • Your facility Pollution Prevention Team (PPT) and/or consultant hopefully reviewed all the relevant 2016-17 storm water sampling analytical results during the annual report process. It is worth taking another look and reviewing each and every lab report, and look for j-flags, and potential issues during sampling to make sure it is truly an NAL exceedance. If this is an issue, training should also be done fairly soon to ensure proper sampling techniques during the 2017-18 stormwater season.

 

    • Budgetary: Capital expenditures can take time to get approved. The earlier the compliance-based BMP items are submitted for budgetary approval, the better. This will give the Discharger more flexibility and options for a tiered approach for implementation.

 

    • Non-government Organizations (NGOs) and Environmental Groups (EGs) are a “de facto” regulatory mechanism, and there has been a proliferation of citizen suits under the Clean Water Act recently. ERA Level 2 Dischargers could be on a short list for non-compliance and have greater exposure.

 

  • Remember, if you return to Baseline status under the IGP and breach the former ERA Level 2 NALs with a yearly average or instantaneous maximum exceedance(s), your facility returns directly to ERA Level 2. Make sure your BMPs are implemented for the long-term to prevent returning to Level 2 status.

 

 

Get help now by contacting an SCS Stormwater Professional near you.

 

 

 

 

Posted by Diane Samuels at 6:03 am

May 17, 2017

Oil and gas processing facilities, federal and local governments, landfills, land developers, contractors, industries with industrial hygiene plans can spend too much money for too little information if they don’t have an understanding of the limits and capabilities of their equipment and methods before the development of their Air Monitoring Plan (AMP) . That’s before considering the risk to their employees and to public health.

Even if you can’t afford a dedicated air monitoring group, you can eliminate the health risks, overwriting a plan, or overburdening your budget. A cost-benefit analysis and integrating stakeholders’ goals can help provide the guidance you need to develop a balanced air monitoring plan.

Start with this list of considerations when developing an Air Monitoring Plan (AMP). The list is followed by tips and suggestions which are helpful under specific circumstances.

The development of an AMP requires the following:

  • Understanding the monitoring objective(s).
    • Compliance Monitoring for Specific Compound(s)
    • Employee Health and Safety
    • Prevention of Significant Deterioration (PSD) Monitoring
    • Fence-line Job Site Monitoring
    • Active Dust Control
    • Source Related or Regional Monitoring
    • Determination of highest concentrations expected to occur
  • Identifying the spatial scale most appropriate for the monitoring objective(s).
    • Sampling Site Density
    • Upwind and Downwind Monitoring
    • Background Monitoring
  • Determination of the required temporal scale of the monitoring objectives:
    • Time-averaged Sampling and/or Real Time Monitoring
    • Desired Averaging Periods
    • Grab Samples
  • Determination of most appropriate monitoring equipment to be utilized.
    • Desired Detection Limits
    • Data Logging Required
    • Site Access Limitations
    • Power Availability
    • Real-Time Alarms if Needed
    • Meteorological Parameters

The information required for selecting the number of samples (5) and the sample locations include isopleth maps, population density maps, and source locations. The following are suggested guidelines:

  • The priority area is the zone of highest pollution concentration expected to occur in the area covered by the network; one or more stations should be located in this area;
  • Close attention should be given to densely populated areas within the region, especially when they are in the vicinity of heavy pollution;
  • The quality of air entering the region should be assessed by stations situated on the periphery of the region; meteorological factors (e.g., frequencies of wind directions) are of primary importance in locating these stations;
  • Sampling should be undertaken in areas of projected growth to determine the effects of future development on the environment;
  • A major objective of compliance monitoring is the evaluation of progress made in attaining the desired air quality; for this purpose, sampling stations should be strategically situated to facilitate evaluation of the implemented control strategies; and
  • Some information of air quality should be available to represent all portions of the region of concern.

 

The primary monitoring objectives should be determined before any data is collected.

 

Location of the monitoring site is initially dependent on the monitoring objective. For example, once it is known that there is a requirement to monitor for peak ambient H2S at a microscale site, it reduces the monitoring site location to specific areas. Hence, the first task when evaluating a possible site location is to determine the scale for which a candidate location can qualify by considering the following:

1. Location and emissions strengths of nearby sources, especially major source;
2. Prevailing wind direction in the area;
3. Nearby uniformity of land use;
4. Nearby population density.

To select locations according to these criteria, it is necessary to have detailed information on the location of emission sources, the geographical variability of ambient pollutant concentrations, meteorological conditions, and population density. Therefore, selection of the number, locations, and types of sampling stations is a complex process. The variability of sources and their intensities of emissions, terrains, meteorological conditions and demographic features require that each network is developed individually. Thus, selection of the network will be based on the best available evidence and on the experience of the decision team.

Developing an Air Monitoring Plan (AMP) can be a daunting task. There are many decisions to make that have downwind ramifications relative to budget, logistical constraints, and labor requirements. In addition, there may be competing goals in regards to the project stakeholders. SCS has the experience developing and implementing air monitoring plans and systems to meet these challenges; including developing site specific and network-wide AMPs for various monitoring objectives. SCS also understands the costs and demands of the implementation of AMPs on industry and government.

 

Performing a cost-benefit analysis is a crucial step in the AMP development in order to assure that the required data is attainable within the budget constraints.

 

If you need to perform Air Monitoring or are in the initial steps of developing an AMP please contact for expert advice and guidance specific to your region and industry. We have robust programs and experts nationwide. We can also incorporate the use of remote monitoring controls and monitoring by our FCC authorized drones.

Author: Paul Schafer, SCS’ National Expert Ambient Air Monitoring

 

 

 

 

 

Posted by Diane Samuels at 6:00 am

May 15, 2017

To Our ClientsThanks to you, our clients, SCS Engineers has received many awards and industry recognitions for research achievements and technology innovations. Engineering News-Record (ENR) recently released the Top 500 Design List, ranking SCS Engineers in the top 100 for the 9th year in a row. In the same publication, SCS is ranked in the Top 10 Sewerage/ Wastewater Firms.

Thank you for your friendship, your business, and the opportunity to serve you.

 

 

 

 

 

 

Posted by Diane Samuels at 6:00 am

May 3, 2017

When tackling a real estate development project, discovering contaminated historic fill is an unwelcome surprise, but with the proper due diligence, you can avoid project delays and cost increases.

fill on the property
Cudahy redevelopment project transforms closed landfill into safe, useful real estate. Click to learn more.

Historic fill is common on properties that were once rural and have become prime redevelopment sites as communities expanded. The fill may include contaminated materials like foundry sand, ash, demo and construction debris, and even municipal waste. In the past, these materials were used to fill wetlands or change the grade of the property before initial development. Today regulations have evolved, and state agencies require property owners to manage these materials appropriately during redevelopment. Also, particular types of historic fill are often not robust enough to structurally support your new building.

fill (compacted or otherwise) on the property
The “Defense Area” was demolished and replaced with new high-efficiency single-family homes shown here. The award winning community is now called The Emerald Ridge Development. Click to learn more.

There are many different kinds of fill materials – each with different physical properties and different potential contaminants. Knowing what is on your property before you start designing the site layout, and certainly, before you start digging, will help you plan your project to save time and money, and to receive state agency approval.

Before You Buy

The more you know about the property and the earlier you know it, the better prepared you will be to make decisions about how best to protect yourself from potential environmental liabilities and prepare for the environmental and geotechnical issues that historic fill can cause. Since every property is unique, the first thing you need to do is gain a thorough understanding of the property’s history and past use. Invest in a comprehensive Phase 1 Environmental Site Assessment (ESA). Consider it a starting point for clues about the possible types and amounts of historic fill which may be present on the property.

If the results of the Phase 1 ESA warrant it, conduct a Phase 2 ESA and geotechnical study to collect soil, fill, groundwater, and soil vapor samples. The Phase 2 ESA and geotechnical studies will help you understand if fill and contaminants are present and the best options for addressing them during the development planning stage.

Historic fill on a property is no longer the impediment to development that it once was. Take these steps to get ahead of potentially contaminated historic fill, and keep your project on time and budget.

You may be able to reduce or eliminate the need for costly landfill disposal by incorporating some of these concepts into your project:

  • Put surface parking lots or green spaces over areas with historic fill.
  • Move buildings with deep foundations or underground parking to areas of the property where the historic fill is not present.
  • Use dynamic compaction or Geopiers™ to stabilize the historic fill in place before constructing slab-on-grade buildings or parking lots above it.
  • Surgically remove minimal amounts of the historic fill and replace it with new compacted fill.
  • Use a deep foundation system such as piles or drilled piers to build over the historic fill without the need for excavation.
  • Install inexpensive sub-slab venting systems in the new buildings.

By testing early, performing a proper geotechnical evaluation, and incorporating design adaptations where needed, you can successfully develop projects with historic fill within your schedule and without breaking your budget.

SCS professionals are available to answer questions or concerns you may have pertaining to commercial, residential, or private development on brownfields – we provide remediation, brownfields, and  Environmental Due Diligence services nationwide. Contact  or one of our experts.

 

Ray TierneyAbout the author: Ray Tierney

Ray Tierney, PG, is a Vice President of SCS Engineers and one of our National Experts on Sustainability. He has 30 years of experience in environmental and sustainability engineering and has helped a wide range of organizations control and reduce their legacy environmental impacts and liabilities, lower their costs, obtain grants and permits to expand, and implement cost-saving practices. Ray serves the Midwest region and projects throughout the U.S.

JohnTabella, PG, LEED AP®, is SCS Engineers’ National Expert for Environmental Due Diligence and for Federal Services. In this capacity, he oversees all aspects of environmental services opportunities and projects primarily throughout the eastern seaboard and supports on opportunities and projects throughout the U.S.

Floyd Cotter specializes in solid waste management projects. His project work involves all areas of solid waste management including planning, permitting, transportation, landfill design, construction, and monitoring. Floyd is also experienced in general civil engineering, construction oversight, environmental site assessments, closure and post-closure plans, and permit and contract document preparation. Floyd is located in the Central region.

Randy Bauer has nearly 3 decades of experience conducting environmental site assessments, subsurface investigations, groundwater monitoring programs, soil and groundwater remediation, and geotechnical investigations at industrial hazardous waste and solid waste facilities. Randy is available to answer questions on the western seaboard.

 

 

 

Posted by Diane Samuels at 6:00 am

May 2, 2017

Increased separation and segregation correlate to additional space needs in transfer stations. Given the move to automation in solid waste collections, it is reasonable to assume that the processing of MSW is going to move toward automation as well.

In his most recent article, Mike Kalish discusses some of the key considerations for the development, or redevelopment of transfer stations today.

Read the article

Mike Kalish, P.E., LEED AP, is a Vice President of SCS Engineers and SCS’s National Expert on Transfer Stations. He has been the Project Manager for major transfer station renovations and expansions in several states.

 

 

Posted by Diane Samuels at 6:00 am

April 27, 2017

An ammonia system that has accurate valve tags, gives detail within facility documentation of SOPs, verifies the accuracy of facility P&IDs, and provides safety measures for operators and contractors for exercising the appropriate valves on the system. Standard operating procedures with proper valve tag placement also helps prevent human error.

Remember, you have the potential to improve safety and minimize risk. A strong training program and accurate operating procedures making a positive impact on worker safety and system operations.

Read the full article here.

 

 

 

Posted by Diane Samuels at 6:00 am

April 26, 2017

Imagine that one of your employees comes and tells you that a 100-gallon spill just took place at your facility and it is flowing swiftly toward a storm sewer on your property.

Suddenly all eyes are on you. What you do next will show your leadership and skill at addressing the issue and limiting the company’s liability. Are you ready to be the hero, or is spill preparedness the one item that just keeps slipping down your to-do list?

Use the techniques recommended in Chris Jimieson’s latest article to make your spill response training engaging and interactive for staff handling oil. Spill preparedness becomes part of your routine and you’re ready to be the hero if a spill occurs.

Improve Your Spill Preparedness

 

Posted by Diane Samuels at 6:00 am

April 19, 2017

The economic concepts discussed in the articles on our website are used by solid waste agencies to help determine the economic feasibility of a particular project, to determine service rates adjustments, and in general plan for the financial health and longevity of operations.

 

SCS Management Services™ helps many of our clients’  incorporate economic planning, financial analysis, and feasibility studies into their master planning and have requested copies of our articles. All can be found and filtered by topic area, and we are always ready to help you find the information you need.

Our articles may be printed or shared using the icons on the left navigation bar. Or, you may share or email this page to keep it handy. SCS respects your privacy; we do not monitor or collect your email address or information.

Contact Vita Quinn for more information. Ms. Quinn is SCS Engineers’ National Expert on Solid Waste Finance and Rate Studies. She has 12 years of experience as a financial analyst and management consultant. She has extensive experience working for local government and has developed financial sustainability solutions for various general governments, special revenue funds, and utility enterprise funds. Ms. Quinn has an MBA in Finance and a Bachelor’s Degree in International Economics.

 

 

Sound Fiscal PlanningAn Exercise in Sound Fiscal Planning: A Rural County’s Public Works Professionals Evaluate Future Solid Waste Service Scenarios, Costs, and Financing Options

https://www.scsengineers.com/scs-articles/an-exercise-in-sound-fiscal-planning-a-rural-countys-public-works-professionals-evaluate-future-solid-waste-service-scenarios-costs-and-financing-options-by-marc-rogoff-karl/

 

 

Residential Automated Collection Makes Sense for Idaho Falls

https://www.scsengineers.com/scs-articles/residential-automated-collection-makes-sense-for-idaho-falls-by-marc-j-rogoff-chris-canfield-and-tony-arehart-waste-advantage-magazine-february-2015/

 

 

The Nuts and Bolts of Implementing a Residential Automated Collection Program

https://www.scsengineers.com/scs-articles/the-nuts-and-bolts-of-implementing-a-residential-automated-collection-program-by-marc-rogoff-scs-richard-e-lilyquist-city-of-lakeland-fl-jeffrey-l-wood-city-of-lakeland-fl-and-donald/

 

 

Conducting a Rate Analysis as Part of a Master Plan Study in Killeen, Texas

https://www.scsengineers.com/scs-articles/conducting-a-rate-analysis-as-part-of-a-master-plan-study/

 

 

Financial ToolsFinancial Tools Assist in Completing Cost of Service Studies

https://www.scsengineers.com/scs-articles/financial-tools-assist-in-completing-cost-of-service-studies-wasteadvantage-may-2016/

 

 

Conducting Solid Waste Rate Studies and Business Plans

https://www.scsengineers.com/conducting-solid-waste-rate-studies-and-business-plans/

 

 

Get a Firm Handle on Solid Waste Costs to Optimize Performance

https://www.scsengineers.com/get-a-firm-handle-on-solid-waste-costs-to-optimize-performance/

 

 

Cash Flow Analysis Forestalls Long-Term Debt

https://www.scsengineers.com/scs-articles/cash-flow-analysis-forestalls-long-term-debt-waste-advantage-magazine-december-2015/

 

 

Is Privatization the Answer? You Need to Consider Several Factors Before Making the Decision for Solid Waste Services

https://www.scsengineers.com/publications/articles/page/11/

 

 

Developing a Strategic Business Plan for Your Agency

https://www.scsengineers.com/scs-articles/developing-a-strategic-business-plan-for-your-agency-bymarc-rogoff-apwa-reporter/

 

 

Economic Feasibility 101 – Understanding the Tools of the Trade

https://www.scsengineers.com/scs-articles/economic-feasibility-101-understanding-the-tools-of-the-trade-by-marc-rogoff-msw-management/

 

 

Assessing a Solid Waste Agency’s Financial Health

https://www.scsengineers.com/scs-articles/assessing-a-solid-waste-agencys-financial-health-by-marc-rogoff-and-richard-allen-msw-management/

 

 

Are Your Rates Correct? Collection and Disposal Rate Studies are a Valuable Tool

https://www.scsengineers.com/scs-articles/are-your-rates-correct-collection-and-disposal-rate-studies-are-a-valuable-tool-marc-rogoff-public-works-magazine/

 

 

Integrating Financial Analysis into Solid Waste Operations Planning

https://www.scsengineers.com/scs-articles/integrating-financial-analysis-into-solid-waste-operations-planning-by-marc-rogoff-msw-management/

 

 

Glass RecyclingHigh Costs and Limited Markets Put a Crack in Glass Recycling

https://www.scsengineers.com/scs-articles/high-costs-and-limited-markets-put-a-crack-in-glass-recycling-msw-june-2016/

 

 Recycling Trends in the United States

https://www.scsengineers.com/scs-articles/6555/

 

 

Waste ConversionCalculated Decisions: An Engineer’s Feasibility Report Can Help Communities and Financiers Assess the Risk of a Waste Conversion Project

https://www.scsengineers.com/scs-articles/calculated-decisions-an-engineers-feasibility-report-can-help-communities-and-financiers-assess-the-risk-of-a-waste-conversion-project-by-mark-rogoff-rew-magazine-renewable-energy-from-wast/

 

 

Anaerobic Digester Economics

 

Give SCS a call or send an email to if you have questions. Find your local office here: https://www.scsengineers.com/locations/.   Visit our Solid Waste Planning Services page for additional information, articles, whitepapers, and case studies.

 

 

 

Posted by Diane Samuels at 1:30 pm

March 15, 2017

recycling technology
New tools, new technologies can work well when integrated into a plan using feasibility studies first.

Increasingly, solid waste and recycling agencies are being asked by their political decision makers to improve efficiency, focus on customers, and reduce increased costs. Many agencies are managed with a combination of manual processes, desktop computer tools, limited vehicle and cart tracking and management tools, and custom databases. While effective, these methodologies often entail more effort, labor, and costs.

Smart technologies are expected to grow substantially over the next decade as agencies attempt to minimize their overall costs in solid waste collection and recycling and increase overall efficiency. As discussed briefly in this article, smart technologies have advantages and disadvantages. As agencies investigate technology to help support their service, ensure continued quality service delivery and meet demanding business requirements, it is important to conduct feasibility assessments to evaluate the economic costs to implement and update the use of new technologies in a sustainable manner.

Read the full article here.

Marc J. Rogoff and Laurel Urena of SCS Engineers.

 

 

Posted by Diane Samuels at 3:00 am

March 9, 2017

 

Solavann Sim, Project Director and OM&M Western Regional Manager at SCS Field Services is one of 40 young professionals recently announced by Waste360 as a 40 Under 40 next generation innovative leader, helping to shape the future of the waste and recycling industry.

 

What makes Sol shine so brightly?

For Solavann Sim it’s his positive qualities as an individual and his ability to work effectively using a multidisciplinary approach with his clients. Our industry’s  strongest and most respected leaders are those who are considered collaborative, not fixated on making all decisions themselves or working in a silo. On the contrary, innovation happens at the crossroads of different disciplines and that is where Sol shines brightest.

Sol’s landfill gas design-build and operations experience, along with his knowledge of hydrogen sulfide treatment programs, help prevent and mitigate potential problems quickly. His comprehensive technical and field competence, along with his clients, and his team comprised of staff in several disciplines approach solutions in various ways; each having unique perspectives but a common goal. Working collaboratively with clients the team solves complex challenges facing landfill owners and operators. Innovative solutions are often found where perspectives, ideas, and fields of expertise meet.

 

Read more about Solavann Sim and SCS Engineers LFG programs here.

 

See SCS’s 40+ years of innovative thinking at SCS Firsts an interactive list of client solutions, underneath News, Events, and Blogs.

 

 

Posted by Diane Samuels at 10:37 am
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