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.”
Community Resource Center’s Holiday Baskets program is the largest holiday distribution of its kind in San Diego County. For 34 years, the Center has held its collection drive, spreading cheer to more than 1,000 families in need during the holidays. Families in need can come in to “shop” for gifts and food for their family members.
This year, SCS Engineers continued its support of the Community Resource Center. SCS’s San Diego and Tracer Carlsbad offices combined efforts in donating non-perishable foods, outerwear, toys, baby items and more.
“Last year, the donation drive brought in more than 5,000 toys, around 500 bikes and 35 tons of food for those in need,” said Chuck Pryatel, Senior Project Advisor with SCS. “SCS has contributed to this effort for three years, and it’s heartwarming to work with such a generous group of people.”
About CRC
After seeing so many in need in the community, a group of community and business leaders came together to form an organization addressing the homelessness and food issues in the community, forming Community Resource Center (CRC). Established in 1979, CRC has grown from providing basic needs for families in crisis to offering extensive programs that facilitate the safety, stability, and self-sufficiency of low-income and episodically homeless households – including domestic violence (DV) victims.
EPA is proposing a GHG SER of 75,000 tons per year (tpy) Carbon Dioxide equivalent (CO2e) and requesting comment on it as well as two lower levels, specifically 30,000 tpy and 45,000 tpy CO2e, respectively.
The Associations do not believe there is sufficient information to support lowering the GHG SER below the proposed 75,000 tpy CO2e level and provided a table utilizing equivalent criteria pollutants from combustion sources (i.e., NOx, CO) yields CO2 emissions as high as 780,000 tpy CO2.
EPA already concluded in USEPA, Proposed PSD Revisions Rule, 81 FR 68137 that the burdens of regulation at a GHG SER level between 30,000 and 75,000 tpy CO2e would yield a gain of trivial or no value from both a programmatic and individual project-level perspective. Therefore, NWRA and SWANA strongly recommend EPA retain proposed GHG SER of 75,000 CO2e (or higher), and resist pressure to lower the GHG SER.
On the Topic of Biogenic GHG Emissions, the EPA’s final rule requires clarification to remain consistent with previous documentation and research to prevent significant permitting delays and increased costs that will not result in meaningful emission reductions.
The Associations encourage the EPA to ensure that waste-derived biogenic CO2 (e.g., from municipal solid waste (MSW) landfills) is treated as carbon neutral under the final PSD Permitting Revisions Rule to be consistent with prior Agency determinations specified in this memorandum and documents as follows:S. EPA, Memorandum Addressing Biogenic Carbon Dioxide Emissions from Stationary Sources, McCabe, Janet, November 19, 2014.
S. EPA, Memorandum Addressing Biogenic Carbon Dioxide Emissions from Stationary Sources, McCabe, Janet, November 19, 2014. The documents highlight waste-derived, biogenic CO2 as a type of “carbon neutral” feedstock based on the conclusions supported by a variety of technical studies and conclusions of the Agency’s latest draft Framework for Assessing Biogenic Carbon Dioxide for Stationary Sources, which was released with the memo. The Agency memo stated that “the Agency expects to recognize the biogenic CO2 emissions and climate policy benefits of such feedstocks in [the] implementation of the CPP.”
US EPA, Emission Guidelines for EGUs, 80 FR 64855. Both the revised Framework, and the EPA’s Scientific Advisory Board (SAB) peer review of the 2011 Draft Framework, found “that the use of biomass feedstocks derived from the decomposition of biogenic waste in landfills, compost facilities, or anaerobic digesters did not constitute a net contribution of biogenic CO2 emissions to the atmosphere.”
S. EPA, Appendix N. of Revised Framework for Assessing biogenic Carbon Dioxide for Stationary Sources, November 2014, pg. N-25. In Appendix N. of the Framework, entitled Emissions from Waste-Derived Biogenic Feedstocks, EPA calculated negative Biogenic Accounting Factors (BAF) for various examples of treatment of landfill gas via collection and combustion. EPA explains, “Negative BAF values indicate that combustion of collected landfill gas feedstock by a stationary source results in a net CO2e emissions reduction relative to releasing collected gas without treatment.”
US EPA, Carbon Pollution Emission Guidelines for Existing Stationary Sources: Electric Generating Units; Final Rule [Emission Guidelines for EGUs], 80 FR 64885. “[T]he use of some biomass-derived fuels can play a role in controlling increases of [in] CO2 levels in the atmosph The use of some kinds of biomass has the potential to offer a wide range of environmental benefits, including carbon benefits.”
US EPA, Emission Guidelines for EGUs, 80 FR 94855. Types of waste-derived biogenic feedstocks may include: landfill gas generated through decomposition of MSW [municipal solid waste] in a landfill; biogas generated from the decomposition of livestock waste, biogenic MSW, and/or other food waste in an anaerobic digester; biogas generated through the treatment of waste water, due to the anaerobic decomposition of biological materials; livestock waste; and the biogenic fraction of MSW at waste-to-energy facilities.
NWRA and SWANA believe the final PSD Revisions document should follow the approach to waste-derived feedstocks enshrined in the Final Clean Power Plan, and as recommended by the SAB, and ensure that waste-derived biogenic CO2 is treated as carbon neutral. Based on EPA’s own lifecycle assessments for the Renewable Fuels Standard program, its U.S. GHG Inventory, and confirmed by the SAB, EPA has sufficient analysis to support exclusion of selected categories of biogenic emissions from PSD permitting, including those from managing landfill gas and organic components of MSW.
The EPA does not seem to consider the regulatory treatment of biogenic CO2 from stationary sources to be a key issue in the context of the PSD revisions rule, based on a comment found in a Summary of Interagency Working Comments on Draft Language. Instead, the EPA continues to believe this rulemaking to establish a GHG SER under the PSD program is not the appropriate venue to address the broader concern of the regulatory treatment of biogenic CO2 from stationary sources.
The Associations strongly disagree and are concerned that because EPA remains silent on this important issue, some permitting authorities might improperly require landfills to incorporate biogenic CO2 emissions in the PSD permitting process. Historically, few landfills triggered PSD because non-methane organics emissions rarely reached the threshold. However, if biogenic CO2 emissions become subject to PSD, many landfill projects, which are “anyway sources” due to renewable energy projects, would also be forced to do BACT analysis for GHG. Biogenic CO2 is emitted from:
From the perspective of developing new renewable transportation fuel or energy projects, subjecting biogenic emissions from landfills to PSD could be an enormous barrier. The Associations would like the EPA to clarify in its final rule that the emissions of biogenic CO2 from treating or controlling landfill gas does not increase the CO2 levels in the atmosphere, but instead, has positive emission reduction and climate benefits. Failing to clarify this important point could subject landfills to significant permitting delays and increased costs that will result in no meaningful emission reductions.
Questions? Contact SWANA, NWRA, Patrick Sullivan, or your local SCS office.
Using non-ad valorem assessments in solid waste management are based on the improvement or service cost allocated to a property and are levied on a benefit unit basis, rather than on value. Under the special assessment system, there is less incentive to drop out of program participation even if solid waste costs increase.
The best source of data for compiling the assessment roll is the records of the county or city official responsible for property appraisal and valuation. Limitations may exist with the data because these records are maintained for the purpose of determining property valuations, not for performing solid waste or other non-ad valorem assessments. However, additional information such as benefits rendered, occupancy, and frequency of benefits could be developed in order to convert the initial records into a complete and accurate assessment role.
Click here to read this insightful article by Marc Rogoff and Laurel Urena of SCS Engineers.
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:
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.”
“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.”
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.
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
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!
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.
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
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.
Learn more about Ann
Ann O’Brien 1-773-775-6362
Learn more about Cheryl
Cheryl Moran 1-608-216-7325
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
Corporate Headquarters
3900 Kilroy Airport Way Suite 300
Long Beach, CA 90806
Telephone
1 (800) 767-4727
1 (562) 427-0805 | FAX
Contact Us
