risk management

March 13, 2020

In light of public concerns related to COVID-19, SCS Engineers has proactive measures and contingency plans in place to protect our employees and our clients, while continuing our work. SCS’s Health & Safety practice, in consultation with our executives, the Centers for Disease Control, and industry associations, endeavors to make the most responsible decisions as circumstances demand.

SCS will post updates here as needed, and is in regular and consistent communication with all employees and with our clients.

 

 

 

 

Posted by Diane Samuels at 9:49 am

February 12, 2020

The environmental reporting season is just around the corner.  Every year Ann O’Brien publishes a table to help you determine your reporting obligations. The table summarizes the most common types of environmental reports due to environmental regulatory agencies in Illinois, Indiana, and Wisconsin, along with respective due dates.

Table: environmental regulatory agencies in Illinois, Indiana, and Wisconsin

The professional engineers and consultants at SCS Engineers can help you navigate the local, state, and federal reporting obligations and permitting for your business, in your region, and in your industry.  Contact us at or find a professional like Ann, nearest you.

Ann O’Brien is a Project Manager with SCS Engineers with more than 30 years of experience in the printing industry. Ann’s experience includes air and water quality permitting, environmental recordkeeping, reporting and monitoring programs, hazardous waste management, employee EHS training, environmental compliance audits, and environmental site assessments and due diligence associated with real estate transactions and corporate acquisitions.

Thanks, Ann!

 

 

 

 

Posted by Diane Samuels at 6:01 am

January 20, 2020

Do Tracer Environmental professionals ever slow down? The SCS Tracer professionals at SCS Engineers were busy publishing new articles last month in addition to Operator Training. We’ve compiled several of them along with the most popular in our SCS library for your convenience. Select a title and start reading. Enjoy!

How to Properly Complete an IIAR 6 System Safety Inspection Checklist Form?  When filling out the ANSI/IIAR 6-2019 Ammonia Refrigeration Safety Inspection Checklists, located in appendix B, some of the information required may not always be readily accessible. This comprehensive article takes readers step-by-step through the process.

Epic Fails, Part Deux    Failures that come together, form a picture. The author discusses how we can begin to learn from these Epic Fails and start to take steps to prevent them in our plants.

Ammonia Pipe and Equipment Labeling – Part I   Recognized and Generally Accepted Good Engineering Practices (RAGEGEP), an overview of many of the standards and guidelines that are relevant to the ammonia refrigeration system labeling, and guidance on how to apply them.

Ammonia Pipe and Equipment Labeling – Part II    Options facilities have when choosing their RAGAGEP for pipe and equipment labeling.

It’s All in Your Past, RETA Breeze    Investing in the knowledge and development of your personnel is the first step towards making your management system world-class in the safe operation and maintenance of your ammonia refrigeration system.

Employee Training Under PSM/RMP   FAQs 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.

Mechanical Integrity, Documentation Discrepancies    Checks, and verification prevent big problems.

Managing Organizational Change: How it Impacts Your Ammonia Refrigeration System During periods of organizational change, we must keep in mind the potential impacts on our facility’s PSM/RMP or ARM programs, and on the operation of the ammonia refrigeration system itself.

PSM/RMP Compliance Audits: Who Should Perform Them?   What to look for in an auditor for hire? For starters, more than a consultant familiar with PSM/RMP regulations.

Management of Change: Have We Captured All of the Impacts of a Change?   It is vital to ask as many questions as possible regarding equipment changes under consideration. With more information, you may find that the proposed changes could impact safety.

 

 

 

 

 

 

 

 

 

Posted by Diane Samuels at 6:01 am

August 31, 2018

We are all trying to wrap our heads around how to implement and document Recognized and Generally Accepted Good Engineering Practices (RAGAGEP). There are so many elements to review when codes and standards are released it is difficult to know where to start.

One place to start is with the industry improvements associated with life safety. International Institute of Ammonia Refrigeration (IIAR) ANSI Standard 2, Safe Design of Closed-Circuit Ammonia Refrigeration Systems, includes specifications for new construction and can be a tool to ensure your engine room is keeping up with industry standards especially when it concerns life safety.

One change from previous versions of the IIAR Standard 2 is the number and location of eyewash/safety showers. IIAR 2 (2014) is now more in line with OSHA expectations. Keep readingmore from Lee Pyle.

Posted by Diane Samuels at 6:03 am

August 27, 2018

A few years ago, an engineer working for a“friend’s plant” chose to replace their  evaporative condenser with an adiabatic condenser. On the surface, the choice seemed like a good idea since  adiabatic condensers often provide higher heat rejection with lower water and electricity usage. The condenser was purchased and installed, but all was not well. When not carefully considered, replacing equipment or control programs can have unforeseen consequences such as negative impacts on operational safety.

In this real life example the author examines what information would have made a big difference and significant savings had the right questions been asked.

Click to read this article and others written for those in industries using ammonia refrigeration.

 

 

 

Posted by Diane Samuels at 6:03 am

August 22, 2018

Regulatory policies governing the food industry are in flux giving corporate compliance headaches, but it doesn’t need to keep you up at night with a massive workload. Consultants are an option if you lack the workforce or expertise to conduct PSM/RMP compliance audits.

William Lape, CIRO, reviews the questions to ask of your consultant before hiring. Starting with the amount of experience that the auditor has evaluating programs against the PSM/RMP regulations; review the resumes and auditor’s support structure; training related to the PSM/RMP regulations and how to properly audit; and ask questions, is the auditor familiar with your covered process, or just PSM/RMP in general? Imagine hiring a consultant with the lowest price and discovering s/he has little experience with ammonia refrigeration.

Read this article and others by clicking here.

 

 

 

Posted by Diane Samuels at 6:03 am

June 25, 2018

A fire at your transfer station or MRF can cause significant downtime, lost revenue, and added cost to restore the damaged equipment and building components. The fire department can tear a metal building apart just fighting the fire. Fires can also trigger negative publicity and could result in injury or even loss of life. Even with automatic sprinkler systems in place, fires can spread quickly. Traditional fire sprinklers are designed to protect the building from completely burning down. However, in most solid waste processing facilities, they are mounted relatively high in the building. Placement can result in significantly delayed response times to react to a fire which has time to grow and propagate. The delay can result in significant damage to structural elements, insulation, lighting, electrical, roof, and wall panels.

International Fire Protection recently published an article by Ryan Fogelman suggesting an investment in more effective fire technology safety systems to prevent fire incidents rather than mitigating the damage. The author’s solution is using automated detection of excessive heat using military grade thermal detection to pinpoint the exact location, with automated emergency alerts, remote human verification, and remotely controlled coolants to contain the threat of fire. These are all innovative solutions and certainly seem logical to help MRFs, transfer stations, and composting operations minimize the chance of an expensive emergency that could shut down operations.

Now we face the dilemma of how public agencies and businesses can afford the new or improved technology.

SCS Engineers believes that preventative strategies and designs are superior and in the long term are safer and less costly. For example, system costs typically include the monthly 24/7 monitoring and operation and set up for multi-year periods (e.g., ten years). At one MRF that experienced a fire, SCS Engineers estimated the cost to install, monitor, and maintain a 24/7 fire suppression system for the 10-year period was less than the cost of the single fire incident. Operators and owners are challenged with a business problem that requires integrating specialized engineering and technology expertise with financial expertise to create operational efficiencies.

When estimating the cost of new technologies to mitigate emergencies and increase safety, the financial considerations are paramount. Elected officials, public works directors, private sector waste management decision-makers and public utilities must operate efficiently while providing critical community services, and maintain existing service levels. They must do so while keeping rates, fees, taxes, and assessments as low as possible for the residents of a community.

Environmentally sustainable solutions must be economically feasible to achieve consensus by constituents and shareholders.

SCS Management Services™ supports a comprehensive approach to environmental solutions as described in International Fire Protection, by providing financial experts who work in combination with our engineering and technology consultants to design solutions that support MRFs, transfer stations, and composting operations planning for long-term economic and financial sustainability.

Posted by Diane Samuels at 6:00 am

April 10, 2018

Modeling for a Worst Case Release and the Alternative Release Scenario – not so mysterious after all. Lee Pyle explains it to you in her recent article in the RETA Breeze. Lee is SCS Engineers National Expert on Industrial Risk Management Plans and Process Safety Management.

All of us with over 10,000 pounds of ammonia in our plant system are well aware of the EPA Risk Management Program Hazard Assessment requirements (40 CFR Part 68.20). When the EPA inspector shows up, we hand them the manual and cross our fingers that they understand what they are reading and pray they do not ask a question.

Do not fret; chances are that the inspector at your plant is probably not much more fluent in dispersion modeling than you are. Much debate occurs over how long it would take to stop a release, but you do not want to get into a debate with an EPA inspector.

Read, share, or print Unmasking the Mystery of the Worst Case Release and the Alternative Release Scenario here. Happy Modeling!

 

 

 

Posted by Diane Samuels at 6:01 am

September 19, 2017

Jeopardy question: What is the best way to thaw frozen chocolate?

Chocolate enthusiasts know this and will learn much more at the RETA 2017 National Conference in, where else, Hershey, PA.

The 2017 conference is offering attendees a truly robust program full of a variety of topics, including Technical Sessions in the areas of Compliance, Engineering, Manufacturing & Operations. Hands-On sessions will also be available, as well as Manufacturer Specific Sessions.

SCS Tracer will be welcoming attendees at booth 610, sponsoring Refrigeration Jeopardy, while providing advice and help as they always have. Play Crack the Code and win prizes during the conference. Visit the booth and SCS  sessions for hints.

  • Monday & Tuesday – Gene Dumas is teaching the CARO Review Course 
  • Tuesday – Juan Parra is teaching two Spanish Sessions: Que es un Balance de Energia y por que Me Debe Importar? + Reto de Operador!
  • Wednesday – Mark Carlyle is presenting Do I have Enough of the Right Training
    • Hot Point Session: SCS Tracer Environmental
    • Andrew Fiala is presenting What is an Energy Balance and Why Should I Care?
  • Fun and Games on Friday, September 29 at 10:30 am SCS is hosting Operator & Management Jeopardy + Engineering & Compliance Jeopardy hosted by Amber Dittrick and Daniel Cuevas with Final Jeopardy happening at 11:30.

 

Details here

SCS Tracer Services here

 

 

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