SCS Engineers

January 3, 2017

On Friday, Dec. 16, 2016, President Obama signed The Water Infrastructure Improvements for the Nation Act or the “WIIN Act.” Section 2301 of the WIIN Act allows states to establish permit programs to regulate the disposal of coal combustion residuals (CCR) units in lieu of the Environmental Protection Agency’s (EPA) CCR regulations and published at 40 CFR 257, Subpart D, also known as the federal CCR rule, that were effective as of October 19, 2015.

Under the federal CCR rule, enforcement has been through citizen suits brought under Section 7002 of the Resource Conservation and Recovery Act (RCRA). Following WIIN, for CCR disposal facilities operating under an approved permit program, citizen enforcement will be replaced by more traditional state and federal enforcement authorities. It will take time for states to apply for permit authority and to issue permits, and in the meantime the federal CCR rule will continue to be enforced by citizen suits, and utilities will be subject to potentially conflicting interpretations of what is required to comply at a given facility.

Other CCR-related highlights from the WIIN Act include:

  • EPA has not more than 180 days to approve in whole or in part a state’s permit program that complies with the WIIN Act’s requirements.
  • The proposed state programs will be subject to public notice and public comment within EPA’s 180-day approval timeframe.
  • State requirements may differ from those in 40 CFR 257, Subpart D, but only if EPA determines the state requirement are at least as protective as the federal CCR rule.
  • EPA must review previously approved state programs (1) at least every 12 years, (2) within 3 years of revising the federal CCR rule, (3) within 1 year of a “significant” unauthorized release from a CCR unit in the state, or (4) if a state requests that EPA review another state’s program with the claim that a CCR unit in another state is, or is likely to, impact their soil, groundwater, or surface water.
  • To the extent that Congress appropriates funds to do so, EPA must implement a permit program in states that elect not to pursue their own program or have lost their approved status. If funds are not provided by Congress, the federal CCR rule will be enforced through citizen lawsuits in the non-participating state.
  • EPA can now enforce the federal CCR rule under RCRA Sections 3007 and 3008 in states without an EPA-approved permit program. The EPA can also enforce the federal CCR rule under RCRA Section 3008 in states with approved permit programs with some additional considerations.

The WIIN Act that was passed by the U.S. Congress on Dec. 10, 2016, is based on CCR legislation that has been introduced in the House of Representatives and Senate in various forms over the past 6 years with the support of many in the utility industry. The WIIN Act has been lauded by the U.S. Senate Committee on Environment and Public Works and utility groups alike.

For example:

“This new permitting authority fixes the main problems with the recent coal ash regulation issued by the Environmental Protection Agency, by removing citizen suits as the sole means of enforcement and allowing states to tailor permit requirements on a case-by-case basis.”

Inhofe, Capito, Manchin, Hoeven Praise Inclusion of Coal Ash Provision in Bicameral, Bipartisan WIIN Deal

“The coal ash language will ensure that states have the authority and flexibility they need to regulate coal ash while protecting the environment as much as the current EPA coal combustion residuals rule,” said APPA Vice President of Government Relations and Counsel Desmarie Waterhouse.

Coal Ash Language Backed by APPA Is Headed to President’s Desk

“…these legislative provisions will enable states to be more involved in the permitting process for the closure of basins.”

EII Applauds Passage of the Water Infrastructure Improvements for the Nation Act

“The bill also injects greatly needed certainty into the regulation of coal ash by giving states clear permitting and enforcement authority and reducing litigation, while providing for its continued beneficial use.”

America’s Electric Co-ops Cheer House Passage of Water Resources Bill with Critical Coal Ash Provisions

SCS Engineers will continue to track the WIIN Act and provide you with updates as states consider and make known their approach to developing a CCR permit program, or not.

For questions about the Act or more information, please contact:

Mike McLaughlin, PE, Senior Vice President
Eric Nelson, PE, Vice President
Steve Lamb, PE, Vice President
Kevin Yard, PE, Vice President

Or contact your local SCS Engineers office.

Posted by Diane Samuels at 3:00 am

December 21, 2016

Rainy Days – SCS Engineers’ newsletter on everything Stormwater! We have shared some information below about stormwater compliance to help you understand and navigate the sometimes confusing regulatory process – a process that may leave you in a “daze”.

Cory Jones, PE, QSD, QISP ToR, ENV SP
SCS Engineers, Stormwater Management

Take me to the December 2016 Newsletter

SCS Engineers Stormwater Services

Posted by Diane Samuels at 3:00 am

December 20, 2016

As the weather cools it reminds us that Lee Pyle has compiled a series of great articles for the RETA Breeze this year. There’s still another coming soon, but here’s a review of what she’s published in 2016 to date. What else would you expect from the woman who brings ice sculptures to life in Nevada?

Click the links to take you to the article or to share it with others.

The Process Hazard Analysis Study and “Previous Incidents”, RETA Breeze, Jan-Feb 2016

Risk Management Planning – Get Involved!, RETA Breeze, Mar-Apr. 2016

Mechanical Integrity – 40 CFR 68.73 & OSHA 1910.119(j), RETA Breeze, May-Jun 2016

Incorporating RAGAGEP Into Your PSM – RMP, RETA Breeze, Jul-Aug 2016

PSM / RMP Compliance – DHS CSAT 2.0, RETA Breeze, Sep-Oct 2016 Issue

Thanks, Lee!

Posted by Diane Samuels at 3:00 am

December 15, 2016

Our latest SCS Technical Bulletin summarizes the EPA federal mandatory greenhouse gas (GHG) reporting program (GHGRP) into two pages of the most vital information. The new reporting requirements for Subparts HH and A discussed in our bulletin are effective January 1, 2017.

2016 GHG emissions reports due on March 31, 2017, must be completed in accordance with the updated Rule.

 

Remaining updates will be phased in from 2017 to 2019. These updates include, but are not limited to, revisions to the reporting regulation for all reporters including Subpart A Administrative Requirements, Subpart C Stationary Combustion Sources, and Subpart HH Municipal Solid Waste Landfills the three most common reporting sectors for MSW landfills. SCS Engineers will continue to post timely information, resources, and presentations to keep you well informed.

Use our resources for guidance or to answer questions.

Share, read, or print the Technical Bulletin

Greenhouse Gas Service Information

 

Posted by Diane Samuels at 4:56 pm

December 13, 2016

Is your manufacturing or industrial business ready for the 2017 environmental reporting season?

Don’t let the deadlines sneak up on you.

 

SCS Engineers provides a free guide to the most common environmental reports due at the federal and state levels. Each guide includes an overview of the reporting due along with the date each state requires submission.

When SCS says free, we mean it. No need to submit your company name, no endless email trail will follow; these are free guides to download and share with others from the compliance experts – SCS Engineers.

Click to download or share each state guide:

If your state is not listed, contact the nearest SCS office to speak with a compliance professional in your area and in your business sector; SCS is nationwide.

If you have questions or need help sorting out details such as which reports apply to your business or step-by-step support on how to prepare your reports in the states listed above, contact our regional professionals.

environmental reporting requirements

 

Learn more about Ann
Ann O’Brien  1-773-775-6362

 

 

environmental compliance reports

 

 Learn more about Cheryl
Cheryl Moran  1-608-216-7325

 

 

 

 

 

 

Posted by Diane Samuels at 3:00 am

December 12, 2016

Recycling markets are moving targets and create volatility that makes it difficult to anticipate market change. However, by controlling contracts you have a much better chance to implement a financially sustainable operation. Tracie and Michelle review managing costs and nine other important components in this engaging article.

Processors and municipalities have many considerations when establishing a recycling contract. Processors who seek legal assistance and are open about their concerns during the process can find ways to develop a contract that is sustainable for both processor and the community being serviced.

Read and share the full article here.

About Tracie Onstead Bills and Michelle Leonard

Posted by Diane Samuels at 3:00 am

December 5, 2016

Under section 211 of the Clean Air Act, the Environmental Protection Agency (EPA) is required to set renewable fuel percentage standards every year, including for cellulosic biofuel, biomass-based diesel, advanced biofuel, and total renewable fuel. In November the EPA established the 2017 standards, which will apply to all motor vehicle gasoline and diesel produced or imported in the year 2017. Most biogas produced qualifies as Advanced Cellulosic Biofuels, or the D3 category, which is the same as cellulosic (non-corn) ethanol. For the last several years, nearly 95% of the advanced cellulosic fuel generated has been from digester and landfill biogas, not cellulosic ethanol.

The final rule also establishes the four percentage standards applicable to producers and importers of gasoline and diesel, based on volume requirements. Renewable Fuel Volumetric Obligations (RVOs) are expected to continue driving the market to overcome constraints in the renewable fuel distribution infrastructure. This, in turn, could lead to substantial growth over time in the production and use of renewable fuels. If a renewable fuel-producing project uses a Renewable Fuel Standard (RFS)-approved pathway and is registered with EPA, the project can generate credits that can be sold to produce additional revenue. The value of these Renewable Identification Numbers (RINs) credits fluctuates based on market supply and demand.

The 2017 RVOs finalized in November for 2017 will help drive the market demand for these credits. Producers of biogas want the demand for RVO to be higher than the supply of biogas that will actually be produced and used as vehicle fuel during the year. This will protect the value of RINs, encouraging revenues for biogas-vehicle fuel projects and financing for new projects. Digester and landfill biogas normally have the highest value of all RINs.

Overall, EPA’s 2017 standards recognize the important role that biogas plays among all advanced biofuel producers, including cellulosic ethanol, and the role biogas will continue to play for generating renewable fuel for US vehicles.
SCS Engineers’ National Experts are available to answer your questions about the impact of the 2017 standards on your business and current and potential projects. Click here to contact SCS.

Posted by Diane Samuels at 3:00 am

December 1, 2016

Every state in the country has different permits to enforce the Environmental Protection Agency (EPA) Clean Water Act (CWA). Several states even have specific permits assigned to industry sectors. This article discusses with proper planning, most facilities can find a way to avoid fines and lawsuits. Implementing one of the alternatives could even reposition your operation as a safe, clean and respected industry leader that values the environment, the local economy, and community.

Read, share, and print the Recycling Today article here.

 

 

Posted by Diane Samuels at 12:05 pm

November 29, 2016

In the EPA’s Region 9 U.S.-Mexico Border Program Progress Report, April-September 2016

The Campo Band of Mission Indians (CBMI) staff members are working with the EPA and SCS Engineers to address their waste management needs. SCS Engineers, an environmental engineering firm, was contracted by the Border Environment Cooperation Commission to work with CBMI in response to their request for technical assistance.

SCS Engineers was contracted to prepare a waste characterization study to support the development of a zero waste plan. The study provides critical information for designing and developing the future programs, policies, and facilities to effectively achieve a zero waste program.

Based on the findings, CBMI will assess their infrastructure needs, including consideration of a transfer station. SCS Engineers conducted field sampling to assess the Golden Acorn Casino in September 2016, the same month that Jeff Scott, EPA’s Land Divison Director visited Campo.

The Border 2020 Program is the latest environmental program implemented under the 1983 La Paz Agreement. It builds on the Border 2012 Environmental Program, emphasizing regional, bottom-up approaches for decision making, priority setting, and project implementation to address the environmental and public health problems in the border region. As in Border 2012, the new Program encourages meaningful participation from communities and local stakeholders.

 

Posted by Diane Samuels at 3:00 am

November 28, 2016

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.

Posted by Diane Samuels at 3:00 am
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