The Industrial General Permit is an NPDES permit that regulates discharges of stormwater associated with industrial activity. Based on the projected revenue and the predicted surplus, SWRCB is working to refine program funding and plans to adjust the current IGP permit fee structure.
Glen Osterhage, Fee Branch Manager for the California State Water Resources Control Board (SWRCB), Division of Administrative Services, met with industry leaders on November 3, 2015, to discuss potential changes to the stormwater Industrial General Permit (IGP) fee structure. Meeting attendees included: SCS Engineers, the Industrial Environmental Association (IEA), California Stormwater Quality Association (CASQA), the California Taxpayers Association (CTA), California Chamber of Commerce, the Independent Energy Producers Association (IEPA), and the host – California Manufacturing and Technology Association (CMTA).
The SWRCB funds eight core permit programs through the Waste Discharge Permit Fund, which pays for over 800 staff. California has cut allocations for agency staff funding by approximately $30 million dollars, forcing SWRBC to distribute its cost burden across the permit fee base. Currently, IGP permit fee revenue is $14.4 million (a single permit fee of $1,791 multiplied by approximately 8,035 permittees). However, SWRCB projects higher revenues due to increased enrollment when all newly required permittees file. Core programs are also subsidized with excess funds coming from the Construction Permit fees (excess of $2M over required $2M last year). Based on the current projected revenue and the predicted surplus the SWRCB is working to refine the IGP program funding and plans to adjust the structure of the permit fee from a flat rate to a rate adjusted for facility size, project complexity, and the threat to water quality.
Following the 2017 to 2018 year permit periods, the SWRCB will have better estimates with which they can accurately adjust fees. The SWRCB is exploring the potential for providing fee discounts for benefits or subsidizing other permit compliance cost burdens. For now, the No Exposure Certification (NEC) IGP Permits are likely to remain a flat fee, but their value may change following additional baseline permit data results.
The SWRCB’s revenue goal is, as always, to break-even; any proposed change to the fee structure is not intended to boost agency revenue over expenses. Another goal is to have data readily available for selecting a permit fee tier from the information submitted on the IGP’s online database application (Storm Water Multiple Application & Report Tracking System, SMARTS, smarts.waterboards.ca.gov).
The SWRCB will have additional meetings to collect comments on the proposed change in hopes of creating a consensus with permittees on these impending changes.
SCS Engineers will provide information as it becomes available. Our professionals are available to assist newly required permittees with filing and compliance requirements.
Contact SCS’s Stormwater Manager, Cory Jones at 1-858-571-5500 or .
Stormwater Management Services
Technical bulletins provide salient information in a condensed format. These summaries are useful to understand and start to plan for potential impacts to your business. Both bulletins posted today include deadlines and additional resources with contact information to help answer your questions. The two bulletins posted today are as follows:
Clicking the title of each Technical Bulletin will take you to the full text. Each Bulletin may be shared, emailed, or printed.
About Pat Sullivan:
Pat Sullivan, BCES, CPP, REPA, is a Senior Vice President of SCS Engineers and our National Expert on the Landfill Clean Air Act and the New Source Performance Standard (NSPS). Mr. Sullivan has over 25 years of environmental engineering experience, specializing in solid and hazardous waste-related issues.
Click on Pat’s name to see his full qualifications and experience.
DDC Journal recently published an interesting article by Pat Sullivan, “Developing power plants that reduce environmental impacts.” http://viewer.zmags.com/publication/097d62a6#/097d62a6/24
Pat Sullivan, BCES, CPP, REPA, is a Senior Vice President of SCS Engineers and our National Expert on the Landfill Clean Air Act and the New Source Performance Standard (NSPS). Mr. Sullivan has over 25 years of environmental engineering experience, specializing in solid and hazardous waste-related issues.
The Solid Waste Association of North America – SWANA, is the largest member-based solid waste management association in the world.
SCS Engineers proudly announces Nathan Hamm, P.E., is the recently elected President of the Kansas Sunflower SWANA chapter. Members of the chapter voted to elect Hamm to continue the leadership of John Hawk, the former chapter President and the General Manager of the McPherson Area Solid Waste Utility. Hamm’s term began on October 22, 2015, and will run for two years.
Nathan Hamm is a registered professional engineer in Kansas and five surrounding states with nearly two decades of experience in the field of environmental engineering. He is a Vice President at SCS and currently serves as the Overland Park –Kansas City Office Manager. As Office Manager, he is responsible for managing the technical and support personnel and the office’s financial performance and business development efforts. He also manages complex projects, maintains client relationships, and provides technical guidance.
“An environmental solution mandates innovative thinking and broad resources, “stated Hamm. “ Our Kansas SWANA chapter provides these and stays true to our principles; that’s how we remain effective and helpful to our members.”
Hamm’s career has concentrated on environmental solutions in solid waste management, alternative energy, power generation, and in agricultural production industries. He is a skilled leader developing and managing multi-disciplinary teams to achieve critical objectives.
Congratulations Nathan!
The U.S. Environmental Protection Agency (EPA) issued a final rule on September 29, 2015, seeking to further control emissions of hazardous air pollutants (HAPs) and volatile organic compounds (VOCs) from petroleum refineries.
This action finalizes the residual risk and technology review conducted for the petroleum refinery source category regulated under the National Emission Standards for Hazardous Air Pollutants (NESHAP; 40 CFR Part 63, Subpart UUU), including the refinery Maximum Achievable Control Technology Standard (MACT) 1 and Refinery MACT 2.
Click here to read the Technical Bulletin
On Monday, October 27, 2015, the Solid Waste Association of North America–SWANA and the National Waste & Recycling Association– NWRA submitted joint comments to the U.S. Environmental Protection Agency– EPA on the proposed revisions of the Emissions Guidelines– EG and Compliance Times for Municipal Solid Waste Landfills and to the supplemental proposal to the Standards of Performance for Municipal Solid Waste Landfills.
SCS Engineers has also submitted comments pertaining to the proposed EG and compliance revisions to the EPA. SCS leaders are involved in many outreach activities to help landfill owners and operators understand and prepare for the impact of the proposed modifications.
Contact SCS Engineers at for more information, or visit the SCS website for upcoming events and pertinent resources.
Denver, PA. – SCS Engineers is opening a new office in Denver, Pennsylvania. The professional engineering staff currently serving clients in Reading will be joined by additional environmental consulting staff moving to the larger office space on November 1, 2015. The new office is located at:
SCS Engineers
22 Denver Road, Suite E
Denver, PA 17517
Tel: +1-610-382-3050
Denise Wessels, P.E., and SCS Project Manager stated, “We are strengthening our commitment to the Commonwealth, and the new location enables us to broaden our environmental services in the region, including SCSeTools®.”
SCS provides quality environmental consulting and construction services to municipal and private sector clients, and has recently expanded SCSeTools®, a platform for organizing big data collected at landfills. The tools collect data, and then organize the data into analyses, graphs, and maps that allow landfill owners and operators to predict, assess, and plan the operation and maintenance of their facilities. This insight helps with decision-making for operational excellence and helps to improve the bottom line.
This is the third and final article in a series of our interview with representatives from the U.S. Environmental Protection Agency (EPA), Mary Wesling and Robert Lucas, both of whom have extensive experience with Risk Management Plan – RMP implementation and enforcement. The interview continues the discussion of recognized and generally accepted good engineering practices – RAGAGEPs, Process Safety Management – PSM, and EPA resources for help.
Jake Tilley is part of the SCS Tracer Environmental team of RETA certified professionals who work with clients in food service and industrial food and beverage processing.
Click here to read the article.
Reprint
The SWANA Landfill Gas and Biogas Division is very busy right now with several important efforts. On the Rules and Regulations front, the U.S. EPA has promulgated two draft landfill gas (LFG) rules that were published in the Federal Register on August 27, 2015. These include a draft Emission Guideline (EG) rule and a supplemental draft New Source Performance Standards (NSPS) rule.
The proposed EG rule affects “existing” landfill sites (i.e., landfills that have not been expanded and were not newly constructed after July 17, 2014). The NSPS rule is a supplemental proposal that affects “new” landfill sites (landfills that are new or were expanded in capacity after July 17, 2014). Comments on both are due by October 26, 2015. Final issuance of both rules is expected in the first quarter of 2016. The Division Rules and Regulation and Advocacy committees are working together to develop SWANA’s industry comments on the rules.
The major focus of both rules is the current 50 Mg/year of non-methane organic compounds (NMOCs) emission threshold, which triggers the installation of a LFG collection and control system (GCCS). In the proposed rules, that threshold will be lowered to 34 Mg/year for all landfills except existing, closed sites. This appears to be the centerpiece of the U.S. EPA’s plan to create additional NMOC and methane reductions from landfills. With a lowered NMOC threshold, some landfills, particularly those that have been too small to trigger the installation of a GCCS, will be required to install them.
Other key components of the draft EG rule, which are likely to be similar in the NSPS rule, include the following:
The draft EG rule also provides clarifications on several existing rule topics, as well as topics where U.S. EPA decided not to include such items in the rule:
During the comment period, the EPA also is looking for public comment on:
The EPA will have the ability to add more provisions to the final version of the rule based on the information submitted as a part of these information requests. This means the industry must make a strong case to the EPA to get them to consider our opinions on these issues.
Comments on this article should be addressed to Patrick S. Sullivan, Senior Vice President, SCS Engineers, at 916-361-1297 or
Today, the National Waste & Recycling Association hosted a webinar concerning the revised NSPS (New Source Performance Standards for Landfills) Rule. EPA is revising the NSPS rules which will be tentatively published in the Fall, 2015. These rule changes may impact the way air emissions from landfills are being managed and is a significant change from 1996 published standards. During this informative session, attendees learned:
If you missed this presentation, NWRA has granted SCS permission to post the slide show on our website. We welcome everyone to view the slide show and thank the NWRA for sponsoring the webinar. Webinar presenters include:
For more information and answers to your questions please contact Pat Sullivan, SCS Engineers or the webinar presenters.
Click for information about NSPS/NESHAP Compliance Services.
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