Breweries under SIC code 2082 (malt beverages) are required to sign up for the new California stormwater permit, under the State Water Resources Control Board. That permit went into effect a year ago. To this point, enforcement has been slow but there are indications that enforcement will increase in 2017.
The mandatory minimum penalty for non-filing starts at $5,000 and can increase substantially under the Clean Water Act for discharges that do not meet state water quality standards. In addition, based on recent experience, there is considerable risk of lawsuits brought by environmental groups or others. More than 120 suits have been filed this year. In either case, this is not an issue you should ignore.rewpubs are likely exempt (based on SIC code), our analysis of available public data indicates that 129 of the 600 or so breweries that should sign up for the permit have done so or around 20%. Hat’s off to our brethren who have complied!
Based on SIC code brewpubs are likely exempt; our analysis of available public data indicates that 129 of the 600 breweries that should sign up for the permit have done so. Hat’s off to our brethren who have complied!
And 117 of the 129 have submitted No Exposure Certifications. This certification process is quite straight forward and includes a checklist that, in a nutshell, states that no operations or storage of spent grain or yeast are outdoors and uncovered (i.e. all raw and intermediate products must be covered and sealed when moved into and out of the facility).
That leaves over 400 breweries at risk.
If you aren’t sure whether you’re required to comply with the stormwater permit or aren’t sure what to do, stop by the SCS Engineers booth (#10) at the CCBA Fall Conference in California for advice.
CONTACT YOUR LOCAL SCS ENGINEERS’ OFFICE IN YOUR STATE
We can also help you with other water issues including flood control site drainage, water treatment options, water recycling, and using groundwater to reduce your reliance on City or water district supplies.
CCBA Fall 2016 Conference
November 13, 2016 – November 15, 2016
Oakland Scottish Rite Center
1547 Lakeside Dr.
Oakland, CA 94612
Cory Jones, QISP
Stormwater Manager
858-571-5500
SCS Engineers was selected to provide on-call services for capital improvement projects at the Riverside Regional Water Quality Control Plant (RWQCP) and the Tequesquite Landfill for the City of Riverside Public Works Department.
SCS Engineers provides wastewater planning, compliance, and engineering services for capital improvement projects at the Riverside Regional Water Quality Control Plant and the Tequesquite Landfill for the City of Riverside Public Works Department.
Over the next three years, SCS will provide wastewater planning and engineering services; geotechnical and materials testing; specialty inspection, including concrete, structural steel, electrical, welding, instrumentation, high voltage inspection services, and other optional construction inspections; PLC programming services; landfill studies, remediation and monitoring; air quality testing and compliance services; as well as regulatory and environmental compliance services.
“SCS Engineers is excited to be a part of the RWQCP plant expansion that will ensure the City of Riverside complies with current state and federal regulations,” said Pat Sullivan, Sr. Vice President with SCS Engineers. “We look forward to assisting RWQCP and the Tequesquite Landfill meet the growing needs of their community.”
Caroline Larose was awarded the Robert P. Stearns – SCS Engineers Master’s Scholar this year. Her project, “Material Flows: Strategies to Reduce Ann Arbor’s Municipal Solid Waste and Improve Diversion,” consists of a comprehensive benchmarking analysis of urban waste programs and a review of city stakeholders to distill a set of MSW management, education, and awareness best practices. Following her research, Caroline plans to draft recommendations for the City, which will include updated MSW goals and an action plan to improve diversion and reduce waste creation.
About Caroline Larose
Caroline chose to go back to school to further her pursuit of making cities more sustainable. She identified solid waste as her primary research focus and has worked towards her idea of eliminating waste as a concept. Caroline is now in her third year as a dual MBA/MS student at the Erb Institute for Global Sustainable Enterprise at the University of Michigan.
Caroline works to promote waste reduction and diversion on campus and throughout the Ann Arbor community by advising the implementation of campus-wide composting and uniform bin signage, as well as by organizing events such as the first Ross School of Business Waste Audit & Education Day and annual clothing swaps. Caroline, a member of the University-wide Student Sustainability Initiative board, has served as the VP of Sustainability for the Ross Net Impact chapter for 2-years. As a result of her leadership on campus, Caroline was selected to join the Ann Arbor Resource Management Team, advising the City of Ann Arbor on how to reduce its solid waste and improve diversion.
Getting a firm handle on a solid waste operation and expenses is a challenge for any solid waste agency manager or landfill operator. It is particularly imperative in this era of “lean and mean” budgets and looming regulatory policy. Doing more with less is the watchword for most operations across the country still reeling from the financial impacts of the Great Recession.
SCS Engineers has created a package of articles to help you identify if your landfill, landfill gas, or solid waste operation is ready for 2017. We hope this useful guidance will help you plan for the upcoming year. SCS professionals are always available to answer questions and provide advice. Find the office or SCS professional nearest to you by clicking on one the links here: Offices and Professionals.
Download, print or share this package by using the download button under the articles or by using the navigation at left. The package includes the following information written by SCS National Experts:
Read the full article by Marc Rogoff, SCS Engineers.
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.
Call our compliance specialists – find the office nearest you or email us at
A solid waste rate analysis will provide your agency with a deeper understanding of how to establish rates and appropriately allocate costs to the various functions of your operation. This financial analysis can also be used to estimate and plan for various contingencies year-by-year.
For example, if your agency would like to buy new collection vehicles or expand your landfill or recycling center, a rate study will allow you to assess how the purchase would impact your current budget. You can then determine if you will have adequate surpluses during the fiscal year to procure these items or if a rate adjustment might be necessary at some point.
Importantly, if the final recommendation of the rate study is a rate increase, you will be armed with information that will strengthen your case when requesting a fee increase.
Read and share this newly published article by Marc J. Rogoff, Ph.D., and Laurel Urena, M.S., E.I.T., of SCS Engineers. Learn more about this valuable service at SCS Engineers and see how others are using rate analysis.
Read and share the full article
Learn more about Rate Analysis
Read how one organization used rate analysis as part of their solid waste master plan
SCSeTools® gives you the ability to instantly map air leaks, vacuum distribution, wells that are “over pulling” and wells that are underutilized – valuable tools for every wellfield technician to maximize system performance beyond simple compliance tracking and reactive wellhead tuning.
As a field technician, you walk a fine line – tuning to a threshold, pulling as hard as you can, as safe as you can. When important data factors start to wander you need to troubleshoot quickly to keep collecting as much as gas as possible without over compensating and adjusting wellheads multiple times. SCSeTools® makes troubleshooting faster and more efficient by turning your data into maps identifying important conditions in the field and the wellheads that need tuning. Field technicians know how to balance the wellfield without killing bacteria and without diluting the gas.
A map of your field with your specific tuning range quickly shows data that are typically missed in reams of data. SCSeTools alerts you to these indicators using a map of each wellhead in the wellfield. Where you formerly needed months for these changes to become apparent, SCSeTools tells you at the touch of a button when a change began occurring and which wellheads are impacted. As a technician you know what you need to tune and which wellheads need your attention.
Using SCSeTools pick any parameter that the GEM collects and create custom ranges or use specified guidelines to quickly identify trends throughout the landfill. Tuning ranges can be adjusted to specific conditions found at individual landfills. Smooth a saw tooth collection pattern and learn from your data for maximum vacuum and maximum collection without risk.
Last year Tom Barham, SCS Engineers’ General Counsel and Field Services Construction Director made headlines at SCS with his admission to the United States Supreme Court Bar. We are extremely proud of Tom!
This month Tom had the opportunity to have lunch with Supreme Court Justice Ruth Bader Ginsburg as part of a fireside chat sponsored by the Association of Corporate Counsel. The discussion was led by Ted Olsen, a former Solicitor General of the United States who has argued 62 cases before the Supreme Court.
Justice Ginsburg was remarkably open and candid about her career and generous with her advice, including sharing advice from her mother in law on how to have a successful marriage, which she noted as “the best advice she ever received.”
As a pioneer in women’s rights and civil rights in America, Justice Ginsburg was involved in many important cases as an advocate and a judge. Asked about which cases stood out, she recalled a case challenging Virginia Military Institute’s (VMI) male only cadet policy. She noted that this was one case Mr. Olsen lost 7-1 and the one vote he got was from Justice Scalia who was already was on VMI’s side and needed no more advocacy to secure his opinion. (According to Mr. Olsen, RBG is known for her “wicked sense of humor”.) The case was memorable not for its legal precedent, but because of correspondence from the family of a female cadet. The female cadet’s father, a Marine and VMI graduate, wrote Justice Ginsburg to thank her for helping to create the opportunity for his daughter to attend VMI.
Subsequently, another letter from the daughter arrived with a Keydet pin which the daughter received upon graduation. The pin traditionally is given to the mother of the graduate, but since the cadet’s mother passed away before her graduation, the cadet sent it to Justice Ginsburg explaining that the Justice was like the grandmother to her and all future generations of female cadets. Justice Ginsburg keeps the letter and pin on her desk at the Supreme Court.
On how to have a successful marriage, Justice Ginsberg’s mother in law advised that it is best sometimes to be deaf to things you don’t want to hear, and handed her a pack of earplugs. Justice Ginsburg explained she has found that advice very helpful, choosing to be deaf to unpleasant things sometimes said.
“When you think about it, it was remarkable to have an opportunity to have lunch with a sitting Supreme Court Justice,” said Tom. “I even had an opportunity to ask for her advice on teaching fundamentals of the Constitution and our legal system to the international students in the class I teach in the University of Maryland Graduate School of Civil Engineering. Maybe I can get The Notorious RBG to guest lecture next semester?”
About Tom Barham
Mr. Barham is SCS Engineers General Counsel and Senior Vice President of Construction Services. He is a member of the Virginia and District of Columbia bars, and holds a degree in building construction. He has over 30 years of experience in construction and construction law.
Mr. Barham provides SCS Field Services with expertise in construction management, including procurement, scheduling, budgeting, and estimating, as well as other contract formation and administration activities.
Mr. Barham has directed several full service (design/build) projects and has been involved in numerous projects such as Landfill Gas (LFG) collection systems (blower/flare stations, extraction wells, horizontal collection trenches, header lines, and condensate collecting/containment systems); groundwater pump and treat systems (stripping towers, recharge galleries, groundwater wells, deep recharge wells, collection/distribution piping, and pump stations); bio-treatment facilities (containment areas, moisture/nutrient application, and soil mixing); underground storage tanks (excavation, testing, triple rinse, and restoration); soil vapor extraction systems (cat/ox treatment facilities, vapor extraction wells, collection header lines, and air make-up wells).
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.
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