Are you approaching the required five-year review/plan re-certification for your facility’s Spill Prevention, Control, and Countermeasure (SPCC) Plan? Even if you’ve been through several cycles of performing five-year tune-ups on your SPCC Plan, you can make your next review easier and prepare yourself for future SPCC Plan re-certifications if you follow these five tips.
Start Early
Late renewals are a consistent pain point for many companies. To avoid being late with your next re-certification, start your review six months before your SPCC Plan is due for its 5-year review. If you are conducting the review internally, start by identifying the person who will be doing the review. If you are using a third party, this approach will help you go through the proposal/contracting process, so you are ready to conduct the actual review and complete the re-certification before the Plan expires.
Simplify Data Collection
One of the keys to a compliant SPCC Plan is to collect accurate data in the field about your facility’s oil sources. Streamlined data collection is of particular importance if you have a large facility or your oil storage changes regularly. The key to simplifying data collection is to make sure your reviewer has organized information to evaluate the compliance aspects of each source. Accurate data collection can limit the follow-up required from plan preparers to verify information, as well as minimize the potential for discrepancies. Moreover, particularly useful if a third party is auditing your Plan or if it is in review during an EPA inspection.
Reduce Redundancy with a Summary Table
One way to simplify your Plan is to use an oil source summary table to cover as much information as possible. A table can include each oil source and the aspects of how the oil source is compliant with the SPCC Rule. There may be areas in the Plan where you need to provide additional text discussion regarding oil sources to explain a compliance matter. In general, try to avoid duplicating information within the Plan.
Watch Out for Commonly Overlooked Areas
While secondary containment and overfill protection are key elements to review at each oil source, some reviewers forget to measure the size of containment structures. Dimensions need to be carefully measured in the field to verify and show sufficient secondary containment capacity in your facility’s SPCC Plan.
Another commonly overlooked area is facility drainage; specifically the overland flow in the proximity of each oil source, which is key to determining the potential receptors where spilled product can travel. These receptors could be storm sewers, ditches, wetlands, or waterways. You can discuss the protection of these receptors during your facility’s annual SPCC training. Swift action and concise communication during a spill can help limit your liability.
Use Targeted Annual Training
Many companies struggle to comply with the annual training requirement. One of the tripping points is trying to train all employees who handle oil for example. To avoid this pitfall, implement a tiered training program so you can focus the training content based on an employee’s responsibility level.
Spill recognition and notification through proper internal channels to get a spill cleaned up is an essential message for employees that occasionally handle oil. These employees could also be trained to aid with the initial control and response to a spill. A second tier may include team members who manage the SPCC Plan; they have additional responsibilities such as inspections of oil sources and spill reporting.
By Chris Jimieson, SCS Engineers
Chris Jimieson has over 17 years of experience supporting industrial, commercial, military, federal, state, municipal, and solid waste companies with environmental compliance. He has extensive experience building and reviewing SPCC and Storm Water Pollution Prevention Plans (SWPPP) and manages compliance assignments, providing computer-based training modules to meet employer training needs. Contact Chris at or 608-216-7367.
At the upcoming USWAG CCR Workshop Feb 22-23 in Arlington, VA, Steve Lamb and Floyd Cotter of SCS Engineers will present a session about the advantages and disadvantages of emerging alternative capping options, and how different regulatory agencies are viewing these options.
About this Session: Traditional final cover and capping design for coal combustion residual (CCR) surface impoundments and landfills have included compacted soil liner, geomembrane liner, drainage layer, and a vegetative soil cover. But coal-fired plants oftentimes don’t have the large volumes of soil that it takes to implement these options.
Alternative capping options have recently emerged in the industry such as exposed geomembrane liners or synthetic turf/geomembrane liner systems. Some of these alternative capping options have many advantages over their traditional counterparts. These advantages include faster installation times, minimal need for soil, improved storm water quality, and reduced maintenance and post-closure costs. For surface impoundments, alternative capping designs can also greatly reduce the amount of disturbance of the existing CCR material within the impoundment.
About Steve Lamb: Steve Lamb, PE provides SCS with over 27 years of experience in solid and hazardous waste management, environmental engineering, civil engineering, hydrology and hydraulics, landfill engineering, remedial design, and regulatory compliance. Mr. Lamb is a Vice President and director of SCS’s Charlotte, NC office.
About Floyd Cotter: 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. Mr. Cotter is also experienced in general civil engineering, construction oversight, environmental site assessments, closure and post-closure plans, and permit and contract document preparation.
“Dave Hostetter sets the example of how an honorable, dynamic, and experienced engineer acts at SCS,” said Paul Mandeville, Senior Vice President and Director of SCS’s offices on the east coast. “Dave serves as a model of what young professionals and students should strive to become in their professional careers; we are very proud of him.”
Dave Hostetter, a recent graduate of the SAME DC Post’s 2015 Leadership Lab was honored to receive the Society of American Military Engineers Honorable Mention for Outstanding Contributions by Young Civilian Member. Dave is a registered professional engineer, a LEED Accredited Professional (LEED AP) through the U.S. Green Building Council, and a Certified Energy Manager (CEM) at SCS Engineers.
Throughout his career he has focused on three things: using his engineering skills to make a difference in the world, serving his clients wholeheartedly, and mentoring others. These guiding principles have led him through many fields of engineering from HVAC and plumbing engineering to energy engineering to landfill gas engineering to controls system engineering.
From 2012 to 2013 Dave was the site project manager for a large retro-commissioning project of two hospitals in the Veterans Integrated Service Network (VISN) 3. More than 1,500,000 square feet of building space were retro-commissioned. Throughout this project, he worked diligently to identify hundreds of issues with the building HVAC systems and create recommendations for each one. His recommendations were projected to save the VA approximately $200,000 / year and have an average payback period of approximately 0.2 years.
In 2016 Dave engineered and installed a unique environmental monitoring system for a client at a port in New Jersey. The client had an air monitoring program which required them to monitor the air quality at six different points around the port on a daily basis. Their original process was time-consuming and was, therefore expensive. Dave engineered and installed a system of wireless sensors which communicate air monitoring data back to an online database. This online database allows the client to view current and historical data, it automatically generates a daily summary report, and it sends out alarms when one of the measured parameters exceeds its alarm setpoint. This new system has reduced the client’s expenditure on labor, saved costs and resources, and increased their ability to understand and respond to the results from their environmental monitoring system.
Dave mentors other young professionals at SCS by involving them in real life hands-on engineering projects. These projects include some sort of equipment installation or troubleshooting work which allows the young engineers to actually see how things are installed, ask good questions on how things work, get face-to-face time with a senior level engineer, and learn valuable lessons on risk and safety management in specific situations.
Dave’s expertise was developed as the result of SCS professionals taking the time to mentor him in the same manner, and his goal is to pass the learning technique and knowledge on to others.
Dave lives the SCS Engineers mission statement to:
Clients trust him for his honest and comprehensive approach to their challenges. Dave takes ownership of his work and puts in the time and effort to deliver excellent results and maintain a great relationship with his clients.
Congratulations, Dave!
Ms. Sharon Bison proudly accepts the Sustaining Member Award presented to SCS Engineers from Col. Kirk Gibbs, Commander, US Army Corps of Engineers, Los Angeles District. Sharon is the outgoing President of the SAME Orange County Post.
We asked Sharon to recount the campaigns that mattered most during her tenure. She responded, “It has been an honor and a pleasure to serve SAME as President of the Orange County Post for the past two years, where I have been able to put my leadership skills to work with a dynamic group of colleagues. Together, we’ve helped to make a positive difference in the lives of nearly a dozen college students who received more than $24,000 in scholarships, and for veterans and their families who benefitted from donations of nearly $60,000 made to Wounded Warriors. The Post has also been of benefit to charities including the American Cancer Society, Project Healing Waters, Armed Forces YMCA, and the Challenged Athlete’s Foundation: Operation Rebound, during my service term.”
Jim Walsh, President, and CEO of SCS Engineers said, “SCS is proud of our staff who share their industry knowledge with associations and share their own time supporting their local communities and non-profit organizations throughout our nation. We thank you for your service and your contributions working toward the betterment of society and the environment.”
A typical SCS landfill expansion project contains an engineering evaluation and analyses addressing important technical considerations which include the existing hydrogeologic conditions, global slope stability, Landfill base settlement, geomembrane compression and strain, leachate pipe strength, useful life of the existing infrastructure and utility lines, stormwater management, leachate and landfill gas system expansion.
This case study site, it shows that the vertical or piggyback expansion of a landfill is a unique way of solving landfill airspace shortage problem. Its feasibility is always site specific and depending on the existing waste types, slopes, liners, design capacity of leachate and gas collection, and stormwater management systems. In addition, the landfill design needs to be thoroughly investigated, engineered, and operated.
From the results of the global final slope stability and the landfill base settlement analyses, it concluded that a vertical expansion at the case study landfill will not increase the risk to human health or the environment over the existing regulatory approved conditions. A vertical expansion provides the landfill owner with an opportunity to increase the landfill volume and provide the residents with the maximum service life within the existing footprint of the permitted Landfill. This maximization of available resources does not expand the environmental footprint of the site and provides better environmental protection and at the same time creates a sustainable landfill site.
A vertical expansion provides the landfill owner with an opportunity to increase the landfill volume and provide the residents with the maximum service life within the existing footprint of the permitted Landfill. This maximization of available resources does not expand the environmental footprint of the site and provides better environmental protection and at the same time creates a sustainable landfill site.
This case study was presented at ISWA 2016.
Read and share the complete case study here.
SCS Engineers was selected to provide on-call services for capital improvement projects at the Riverside Regional Water Quality Control Plant (RWQCP) and the Tequesquite Landfill for the City of Riverside Public Works Department.
SCS Engineers provides wastewater planning, compliance, and engineering services for capital improvement projects at the Riverside Regional Water Quality Control Plant and the Tequesquite Landfill for the City of Riverside Public Works Department.
Over the next three years, SCS will provide wastewater planning and engineering services; geotechnical and materials testing; specialty inspection, including concrete, structural steel, electrical, welding, instrumentation, high voltage inspection services, and other optional construction inspections; PLC programming services; landfill studies, remediation and monitoring; air quality testing and compliance services; as well as regulatory and environmental compliance services.
“SCS Engineers is excited to be a part of the RWQCP plant expansion that will ensure the City of Riverside complies with current state and federal regulations,” said Pat Sullivan, Sr. Vice President with SCS Engineers. “We look forward to assisting RWQCP and the Tequesquite Landfill meet the growing needs of their community.”
Getting a firm handle on a solid waste operation and expenses is a challenge for any solid waste agency manager or landfill operator. It is particularly imperative in this era of “lean and mean” budgets and looming regulatory policy. Doing more with less is the watchword for most operations across the country still reeling from the financial impacts of the Great Recession.
SCS Engineers has created a package of articles to help you identify if your landfill, landfill gas, or solid waste operation is ready for 2017. We hope this useful guidance will help you plan for the upcoming year. SCS professionals are always available to answer questions and provide advice. Find the office or SCS professional nearest to you by clicking on one the links here: Offices and Professionals.
Download, print or share this package by using the download button under the articles or by using the navigation at left. The package includes the following information written by SCS National Experts:
Article in Waste360: explains who’s impacted and how to begin managing the costs.
SCS Technical Bulletin: a digest of hundreds of EPA regulatory policy into the information and timelines to act on now.
Article: strategic financial planning to support infrastructure costs.
Call our compliance specialists – find the office nearest you or email us at
Last year Tom Barham, SCS Engineers’ General Counsel and Field Services Construction Director made headlines at SCS with his admission to the United States Supreme Court Bar. We are extremely proud of Tom!
This month Tom had the opportunity to have lunch with Supreme Court Justice Ruth Bader Ginsburg as part of a fireside chat sponsored by the Association of Corporate Counsel. The discussion was led by Ted Olsen, a former Solicitor General of the United States who has argued 62 cases before the Supreme Court.
Justice Ginsburg was remarkably open and candid about her career and generous with her advice, including sharing advice from her mother in law on how to have a successful marriage, which she noted as “the best advice she ever received.”
As a pioneer in women’s rights and civil rights in America, Justice Ginsburg was involved in many important cases as an advocate and a judge. Asked about which cases stood out, she recalled a case challenging Virginia Military Institute’s (VMI) male only cadet policy. She noted that this was one case Mr. Olsen lost 7-1 and the one vote he got was from Justice Scalia who was already was on VMI’s side and needed no more advocacy to secure his opinion. (According to Mr. Olsen, RBG is known for her “wicked sense of humor”.) The case was memorable not for its legal precedent, but because of correspondence from the family of a female cadet. The female cadet’s father, a Marine and VMI graduate, wrote Justice Ginsburg to thank her for helping to create the opportunity for his daughter to attend VMI.
Subsequently, another letter from the daughter arrived with a Keydet pin which the daughter received upon graduation. The pin traditionally is given to the mother of the graduate, but since the cadet’s mother passed away before her graduation, the cadet sent it to Justice Ginsburg explaining that the Justice was like the grandmother to her and all future generations of female cadets. Justice Ginsburg keeps the letter and pin on her desk at the Supreme Court.
On how to have a successful marriage, Justice Ginsberg’s mother in law advised that it is best sometimes to be deaf to things you don’t want to hear, and handed her a pack of earplugs. Justice Ginsburg explained she has found that advice very helpful, choosing to be deaf to unpleasant things sometimes said.
“When you think about it, it was remarkable to have an opportunity to have lunch with a sitting Supreme Court Justice,” said Tom. “I even had an opportunity to ask for her advice on teaching fundamentals of the Constitution and our legal system to the international students in the class I teach in the University of Maryland Graduate School of Civil Engineering. Maybe I can get The Notorious RBG to guest lecture next semester?”
About Tom Barham
Mr. Barham is SCS Engineers General Counsel and Senior Vice President of Construction Services. He is a member of the Virginia and District of Columbia bars, and holds a degree in building construction. He has over 30 years of experience in construction and construction law.
Mr. Barham provides SCS Field Services with expertise in construction management, including procurement, scheduling, budgeting, and estimating, as well as other contract formation and administration activities.
Mr. Barham has directed several full service (design/build) projects and has been involved in numerous projects such as Landfill Gas (LFG) collection systems (blower/flare stations, extraction wells, horizontal collection trenches, header lines, and condensate collecting/containment systems); groundwater pump and treat systems (stripping towers, recharge galleries, groundwater wells, deep recharge wells, collection/distribution piping, and pump stations); bio-treatment facilities (containment areas, moisture/nutrient application, and soil mixing); underground storage tanks (excavation, testing, triple rinse, and restoration); soil vapor extraction systems (cat/ox treatment facilities, vapor extraction wells, collection header lines, and air make-up wells).
Any facility that manufactures, uses, stores, or distributes certain chemicals above a specified quantity listed on Appendix A must complete and submit a Chemical Security Assessment Tool (CSAT) Top-Screen within 60 days of coming into possession
of the Chemicals of Interest (COI) .
In developing the list, the Department looked to existing expert sources of information including other federal regulations related to chemicals. With the publication of a final Appendix A, all provisions of 6 CFR Part 27, including § 27.210(a)(1)(i), are operative and in effect. The other sources that the Department referenced in part are:
Many manufacturers, food storage facilties, cold storage facilities, and industries have chemicals that fall into one or more of the listed categories. Please contact our professional staff to find out if your business is at risk of non-compliance of CFR Part 27.
What to do? Who to contact? Jake Tilley or Lee Pyle of SCS Engineers.
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