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.
By Bruce J. Clark, SCS Engineers
In 2015, the City of Miami Beach Public Works Department took the initiative to raise about 4,200 feet of asphalt streets. It’s also implementing a master plan developed in 2014 to protect the homes and livelihoods of 88,000 residents and $50 million in taxes.
Several U.S. cities are exploring how global climate trends could affect local infrastructure, but Miami Beach is the nation’s first city to face the reality of rising sea levels. Consequently, the city is providing others with unique insight. In the words of City Engineer Bruce Mowry, “There’s no playbook for these solutions.”
For years, Wisconsin landfills have relied on compliance with the storm water (stormwater) management requirements in the Chapter NR 500 code series to achieve compliance with the NR 216 storm water standards. Effective June 15, 2016, the Wisconsin Department of Natural Resources (WDNR) changed their policy, and now requires landfills and associated non-commercial borrow sites to obtain separate industrial storm water permit coverage.
Read the SCS Engineers Technical Bulletin to determine what action you may be required to take and by what date.
If you have questions or need help filing or developing a plan, please contact:
Betsy Powers, PE
(608) 216-7347
Sherren Clark, PE, PG
(608) 216-7323
…and as waste settles, it can have an effect on equipment,” according to Pat Sullivan of SCS Engineers in this ClimateWire article. As the U.S. EPA focuses on pushing landfill owners into cutting down on methane emissions some worry that a combination of tightening regulations and poor cost analysis might put some smaller landfills out of business.
LANDFILL EMISSIONS: Going to the dump? You might make electricity
Kavya Balaraman, E&E reporter
Reprinted from ClimateWire with permission from E&E Publishing, LLC. Copyright 2016.
Waste Management & Research, August 1, 2016,
Authors:
Ravi Kadambala, SCS Engineers, Boca Raton, FL
Jon Powell, Gainesville, FL, USA
Karamjit Singh, Jacksonville, FL, USA
Timothy G Townsend, Gainesville, FL
Vertical liquids addition systems have been used at municipal landfills as a leachate management method and to enhance biostabilization of waste. Drawbacks of these systems include a limitation on pressurized injection and the occurrence of seepage. A novel vertical well system that employed buried wells constructed below a lift of compacted waste was operated for 153 days at a landfill in Florida, USA. The system included 54 wells installed in six clusters of nine wells connected with a horizontally oriented manifold system. A cumulative volume of 8430 m3 of leachate was added intermittently into the well clusters over the duration of the project with no incidence of surface seeps. Achievable average flow rates ranged from 9.3 × 10−4 m3 s−1 to 14.2 ×
10−4 m3 s−1, which was similar to or greater than flow rates achieved in a previous study
using traditional vertical wells at the same landfill site.
Read the entire white paper here…
Recent direct communications with SWRCB and local Regional Boards’ have indicated that during the 2016-2017 permit cycle year, inspections will be more detailed for facilities considered to be at high risk, which were specifically named as those with a long history of water quality violations, as well as scrap metal recyclers, and End-of-Life Vehicle (ELV) recycling. There will also be increased focus on facilities that discharge to impaired waterbodies with adopted Total Maximum Daily Load (TMDL) requirements.
Industries should take action now if there is any uncertainty in regards to the meeting permit regulations. Contact your local SCS Engineers’ office or one of our industrial stormwater experts in California, Cory Jones or Jonathan Meronek. If you need questions answered, or if you are unsure of your business’s requirements, and believe that your facility may be in violation, SCS will help sort through the permitting red-tape. This includes SMARTs filing, NOI/NEC or NONA submittals, SWPPPs and Monitoring and Implementation Plans.
Recent News, Stats, and Resources
More Resources
An informative and complete discussion from Jeffrey L. Pierce of SCS Engineers, Energy Practice of siloxanes and landfill gas (LFG) utilization. Plus, presentations on the economics and performance of siloxane removal from biogas; advice on siloxane sampling, analysis and data reporting recommendations on standardization for the biogas utilization industry.
Read the NSPS – EG Technical Bulletin
While not a new concept, the authors examine the advantages and disadvantage of landfill mining as metropolitan areas grow larger and nearer to landfills, and as the landfills are filling up faster despite recycling programs.
Read or share the article by SCS Engineers’ Bruce Clark, Alyson Dagly, and Marc Rogoff here.
Landfill Services and Remediation Services at SCS Engineers
Article by Cheryl Moran, CHMM
Technological advances in traditional printing and the advent of digital printing can make it more challenging to know when you need an air permit and which permit is best for your operations.
There are two main activities that may trigger air permitting – construction and operation; each of these comes with its own permitting requirements. Always check to see if you are required to apply for a construction permit before bringing new equipment on site. Once a source is installed, an operating permit will be necessary, which is the focus of this article.
Federal Title V operating permits (also referred to as Part 70 permits) are required for any facility that is considered a “major source” of air pollution. For purposes of operating permits only[1], a major source is a facility that has the potential to emit (PTE) more than 100 tons per year (tpy) of any criteria pollutant; volatile organic compounds (VOC), carbon monoxide (CO), nitrogen oxides (NOx), sulfur dioxide (SO2), particulate matter less than 10 microns (PM10), or more than 10 tons of any individual hazardous air pollutant (HAP) or more than 25 tpy of combined HAPs . Permitting thresholds are lower for facilities located in non-attainment areas.
Some facilities take limits on material throughputs, hours of operation, or emissions in order to artificially lower their PTE to qualify for a Federally Enforceable State Operating Permit (FESOP). These permits are also called “synthetic minor” permits.
Facilities that do not exceed federal permitting thresholds may still need to acquire a state operating permit. State permitting programs have more options than ever before and several states are summarized below.
ILLINOIS:
All “emission units” are required to secure an air permit, or register with the Illinois EPA, even very small sources of air pollution. An “emission unit” is any piece of equipment located at an emission source that has a potential to emit air pollution. Registration of Smaller Sources (ROSS) is for operations that emit less than 5 tpy of combined criteria pollutants. Sources with a potential to emit more than 5 tpy, but whose emissions are less than the threshold for a FESOP, may qualify for a “life-time” operating permit.
Visit for more information on the Illinois EPA permitting program.
WISCONSIN:
ROP Type A Registration Permit is for facilities with actual emissions of less than 25 tpy for criteria pollutants and 6.25 tons per year for HAPs.
ROP Type B Registration Permit is for facilities with actual emissions of less than 50 tpy for criteria pollutants and 12.5 tpy for HAPs.
ROP C Registration Permit for Printers is only available to printers. To qualify for this permit, emissions of each criteria pollutant are limited to 25 tons per year, and HAPs are limited to 12.5 tons per year.
General Operation Permit (GOP) for Printers applies to digital, screen, lithographic web printing (both heatset and coldset), and lithographic sheetfed printing.
INDIANA:
Source Specific Operating Agreement for Surface Coating or Graphic Arts Operations is available to printers with total VOC and HAPs that do not exceed 15 lb/day (7 lb/day in select counties).
Permit by Rule may be used for facilities that qualify for an operating agreement with criteria pollutant and HAP emissions that do not exceed 20% of the major source limits.
Find more on the Indiana permit options at http://www.in.gov/idem/airquality.
Whether you are applying for a state operating permit, or a federal operating permit, all applications will go through your state environmental regulatory agency.
[1] For construction permitting purposes, the thresholds that define a “major source” are typically higher than the operating permit thresholds.
For more information contact Cheryl Moran at SCS Engineers, Wisconsin or Ann O’Brien at SCS Engineers, Illinois, or for an SCS professional in your state.
Cheryl Moran is a Project Manager with SCS Engineers with more than 20 years of experience in the printing industry. She is a Certified Hazardous Materials Manager (CHMM) and has worked with air, water, and waste issues including permitting, environmental recordkeeping, reporting and monitoring programs, hazardous waste management, environmental compliance audits, and sustainability programs.
Ann O’Brien is a Project Manager with SCS Engineers. During her 32-year career in the printing industry she was responsible for environmental compliance programs, including, but not limited to, air and water quality permitting, environmental recordkeeping, reporting and monitoring programs, hazardous waste management, environmental compliance audits, and environmental site assessments and due diligence associated with real estate transactions and corporate acquisitions.
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