SCS is working to get our landfill clients through NMOC and NSPS with timelines – they are prepared for what they need to do now and in the future. Listed here are the most popular and timely resources and information useful for your own planning.
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.
The EPA published NSPS – EG final rule in the federal register on August 29, 2016. This SCS Technical Bulletin compiles the 856 pages of NSPS and EG documents into 3 pages of the significant information you need to know. The rule takes effect 60 days after August 29, some requirements are linked to the publication date in the register.
Do you have NSPS or EG sites per the new definitions of “new” and “existing”?
Does your EG site have any upcoming planned or permitted expansions, or will it be commencing construction on an expansion permitted after July 17, 2014?
Will you need to submit/resubmit Design Capacity and NMOC reports to establish your sites status as subject to the new NSPS? Over, or under 34 Mg/year of NMOCs?
Are you a candidate for Tier 4? In the closed landfill subcategory?
For EG sites contact the SCS state representative by sending a request to
SCS Engineers will be publishing Pat Sullivan’s Technical Bulletin Summary of Final NSPS/EG Rules for Landfillsas soon as it is published in the federal register. Meanwhile, please contact your SCS Project Manager or for answers to your questions or advice. Follow SCS Engineers on your favorite social media site or check our events for new presentations, publications, and webinars explaining the rules in more detail.
Contamination causes major problems for recycling programs. Improving communication plays a pivotal role in solving the issue.
Tracie Onstad Bills, Northern California Director, Sustainable Materials Management at SCS Engineers
Thank you for the responses and questions about my blog Minimizing Contamination in Recycling. It seems appropriate to provide answers to the most frequently asked questions and send more advice. Any program should be tailored to your current collection system; what works and what doesn’t work for your locality; the demographics of your community; and how your community views recycling.
In light of those considerations, here are some recommendations for ways to minimize contamination in recyclables:
Mail outreach materials to business and residents on a regular basis. When your community is adding recycling or switching to a new recycling program, mail outreach starting 6 months before the new services begin to inform and prepare the community for the change. Then every other month send new information about the program so people get used to hearing about the upcoming program, what is expected of them, and the positive difference they are making in their community.
Use social media to get your message out, Including NextDoor, Facebook, Twitter, the local government/community website, newspapers, community TV stations, and radio. One of the people who responded to my previous blog, Cyril May, even uses magic as a part of his environmental outreach. He is the recycling coordinator for the City of Waterbury, CT, and uses magic to demonstrate the power of recycling when he goes door-to-door or speaks at schools. “Turning a ripped up newspaper into a new newspaper shows the magic of recycling that everyone has,” he says. “Causing dollar bills to vanish in smoke and flame showcases the taxpayer dollars lost when we send valuable recyclables to incinerators.”
After the service starts, follow up with additional outreach. Highlight what people should do as well as what they should not do. Yes – I am a firm believer in excellent outreach, education, and communication!
Some studies have suggested providing trash cans that are the same size as the recycling can, because when the recycling is free, people often will throw their trash into the recycling containers in order to keep a small trash container for a cheaper cost. I am not an advocate of this method, however, I am a realist and know that this is one cause of contamination, so keep an eye on it!
Make sure your hauler keeps track of any contamination issues and the causes. Knowing what the contamination is and why it is caused, will help you determine the next steps on how to address it. For example, if you have slight contamination because residents and businesses are throwing in items that they think are recyclable, you can continue to educate them about what can and cannot be recycled. However, if they are putting trash in the recycling containers in order to save costs, that is another matter that needs to be addressed appropriately, and may include citations or fines.
Many people throw more than they should into their recycling containers because they think “the hauler will sort it at the facility,” and so they don’t feel the need to be extra cautious about how they sort. As part of your outreach, I would recommend letting the community know that the cleaner the materials, the better the market and the more economical the service. They need to understand that there are consequences when they are not careful about how they recycle.
Make sure that the materials you accept in your recycling program can, in fact, be recycled. Cities often accept items in recycling containers because they can be recycled in theory (for example, milk cartons and polystyrene), when, in fact, they may not be. Depending on the local dynamics, recycling markets, recoverability at the recycling facility, or other barriers, certain materials may or may not be recycled. Be consistent with the materials you accept and don’t take items that may cause confusion.
In California, we have very diverse demographics and multiple languages. Providing outreach in those different languages, and even better, with pictures, will help your community fully understand the recycling program.
Go into the schools to get the kids engaged and excited about recycling. If you are starting a new recycling program, facilitate an assembly right before and/or after the service starts. Kids often influence their family’s behavior in such matters.
Multi-family dwellings should be treated differently than single-family residences. Because residents of multi-family dwellings do not typically pay for the service directly, their containers will almost always be contaminated because there is no ownership of the responsibility. There are other barriers as well, such as illegal dumping, fluctuation of tenants, move-in or move-out purging of material, etc. I have a different set of recommendations for multi-family dwellings which I consider one of the toughest nuts to crack.
Make sure the recycling haulers place non-collection tags on containers that are contaminated. After a few violation notices and the threat to suspend service, residents and businesses usually improve, especially when they realize that someone is watching them.
Be diligent when transitioning to your new recycling program and closely monitor how your residents and businesses are doing. I would recommend having a few interns go out for the first month or two and conduct random lid flips. Leave notes that say “good job – you’re an excellent recycler” to reinforce the good behavior. This will also provide a pulse on how the program is doing, where the problems are, and if there are certain districts of the city that are more contaminated than others. By isolating the areas that have high contamination, you can focus your outreach and education to the regions that need message reinforcement.
Be flexible. Remember that your program will be evolving, so go with the flow, and be sure to celebrate your successes!
SCS Engineers has published two Technical Bulletins summarizing the O&G NSPS final rule and outlining the new LDAR requirements. The two Bulletins explain the modification of how oil and gas sources will be permitted under the Clean Air Act and the new requirements to reduce methane leaks from new oil and gas facilities consistent with the EPA’s New Source Performance Standards.
Reference the U.S. Environmental Protection Agency (EPA) new source performance standards for Crude Oil and Natural Gas Production, Transmission and Distribution (O&G NSPS), which includes amendments to 40 CFR Part 60, Subpart OOOO and a new Subpart OOOOa. Subpart OOOOa will apply to facilities constructed, modified or reconstructed after September 18, 2015.
An SCS Engineers Technical Bulletin will be released early in the week.
The U.S. Environmental Protection Agency issued limits on methane emissions from oil and gas wells that are more stringent than those it proposed last year. The final regulations released on Thursday, May 12, 2016, will add hundreds of millions in additional costs per year; at least 25 percent higher than the preliminary version published in August 2015.
EPA Administrator Gina McCarthy told reporters on a conference call that the mandates, applying immediately to new and modified wells, are a “critical first step in tackling methane emissions from existing oil and gas sources.”
Under the rule, companies must upgrade pumps and compressors while expanding the use of “green completion” technology meant to capture the surge of gas that can spring out of newly fracked wells. Such green completion techniques have been required for new and modified natural gas wells since 2015, but Thursday’s rule would broaden the requirement to oil wells too.
Take me to the EPA summaries. Click on the information sheets listed below:
“Our clients enable SCS to build, grow, and sustain an engineering firm dedicated to solving environmental challenges,” said Jim Walsh, President and CEO of SCS. “We sincerely thank our friends, colleagues and, in particular, our clients for helping us achieve a highly regarded ranking each year.”
Firms are ranked in terms of revenue by Engineering News-Record magazine (ENR), as reported in the May 2, 2016, issue of the “ENR Top 500 Design Firms Sourcebook.” SCS has made the Top 500 list since its publication in 2002 and has ranked in the top 100 of that list since 2008.
When sorted by firm type, SCS Engineers is ranked the second largest environmental engineering firm (ENV) and is ranked in the “Top 20 Sewerage and Solid Waste” service firms in the nation. SCS has made this top 20 list since 2002.
Later in the year, ENR will publish additional resources and lists, including the “Top 200 Environmental Firms” issue, typically published in the month of August.
SCS Engineers along with Waste Management, Republic Services, Advanced Disposal, National Waste & Recycling Association, Solid Waste Association of North America, The Sanitation Districts of the County of Los Angeles, and other consultants have submitted additional comments to the U.S. Environmental Protection Agency (USEPA), Fuels & Incineration Group, Sector Policies and Programs Division regarding the Supplemental Proposal for the New Standards of Performance (NSPS) for Municipal Solid Waste (MSW) Landfills and the Proposed Emission Guidelines (EG).
The USEPA solicits comments from industry, state officials and other organizations to clarify key points in proposed policy prior to enacting the policy. Although the Agency is not required to consider additional comments after the closing period for such comments, these solid waste industry participants wanted to provide additional findings supporting portions of the policies and guidelines and asking for clarification in areas where there appears to be inconsistency with other federal rules or a lack of data.
The eighteen-page letter was submitted on January 22, 2016, to Ms. Hillary Ward. Since last Friday inclement weather has forced a closing of Federal Agencies in the Washington, D.C. region.
Two EPA landfill gas rules were published in the Federal Register in August 2015. The proposed EG Guideline rule affects “new” and “existing” landfill sites. Remember, these are guidelines only. Your local and state government agencies will use them to develop and implement the actual rules by which you do business.
Learn more in one place by reading the recent article in Waste Advantage Magazine, the SCS Engineers Technical Bulletin, and a slide set from a recent webinar about what you can expect for your business. All authored by Pat Sullivan, Senior Vice President at SCS and our National Expert on the Landfill Clean Air Act; NSPS.
Technical bulletins provide salient information in a condensed format. These summaries are useful to understand and start to plan for potential impacts to your business. Both bulletins posted today include deadlines and additional resources with contact information to help answer your questions. The two bulletins posted today are as follows:
Summary of the Clean Power Plan includes the final standards for new and existing Electric Utility Generating Units (EGUs). The Technical Bulletin reviews the U.S. EPA determination that the best system of emission reduction (BSER) consists of three building blocks; how the EPA determines the degree of emission limitation achievable through the application of the BSER for each type of unit; and how quickly and to what extent the measures encompassed by the building blocks could be used to reduce emissions. States will be required to submit a final plan, or an initial submittal with an extension request, by September 6, 2016. The types of plans and cost-effective strategies suggested for states to tailor their plans to meet their respective energy, environmental, and economic needs and goals, and those of their local communities is in the final sections.
Summary of Proposed Oil and Gas NSPSU.S. EPA promulgated an amended Standards of Performance for Crude Oil and Natural Gas Production, Transmission and Distribution (NSPS). Specifically, EPA proposed amendments to 40 Code of Federal Regulations (CFR) Part 60, Subpart OOOO and proposed an entirely new Subpart OOOOa. EPA also promulgated a draft control technique guidelines (CTGs) document for the oil and natural gas industry. The CTG is intended to provide state, local and tribal air agencies with information to assist them in determining reasonably available control technology (RACT) for reducing volatile organic compounds (VOC) emissions from select oil and natural gas industry emission sources in ozone nonattainment areas. Comments on the proposal are due November 17, 2015, and the final rules are slated to be promulgated in June 2016. Rule details are provided in the Technical Bulletin and table within the Technical Bulletin.
Clicking the title of each Technical Bulletin will take you to the full text. Each Bulletin may be shared, emailed, or printed.
About Pat Sullivan:
Pat Sullivan, Sr. VP, SCS Engineers
Pat Sullivan, BCES, CPP, REPA, is a Senior Vice President of SCS Engineers and our National Expert on the Landfill Clean Air Act and the New Source Performance Standard (NSPS). Mr. Sullivan has over 25 years of environmental engineering experience, specializing in solid and hazardous waste-related issues.
Click on Pat’s name to see his full qualifications and experience.
