SCS Engineers

May 28, 2024

The July 1, 2024, deadline for the Toxics Release Inventory – TRI Reporting is fast approaching.

Authorized under the Emergency Planning and Community Right-to-Know Act (EPCRA) and the Pollution Prevention Act (PPA), the Toxics Release Inventory (TRI) tracks the management of certain toxic chemicals that may pose a threat to human health and the environment.

Manufacturers, including food and beverage, electric utilities, and mining facilities, may need extra time this year to comply with recent rule changes related to per- and polyfluoroalkyl substances (PFAS).

TRI reporting is a two-step process, and covered facilities with at least ten full-time equivalent employees must complete the first step to evaluate whether a report is required each year. For each chemical that exceeds a reporting threshold, EPA requires the facility to calculate releases to the air, wastewater, and stormwater and the amount of the chemical recycled or treated on-site or sent off-site for treatment during the previous calendar year.

Watch New Rules and Tools for the 2023 Toxics Release Inventory now.

TRI Reporting Unscrambled and No-Strings Attached

SCS Engineers presents an on-demand educational video with complimentary articles and additional resources to get you started. Cheryl Moran, a senior project manager with decades of experience in regulatory compliance, sustainable practices, and chemical management, covers what you need to know to get started and what has changed that may require your facility or business to start reporting:

• Introduction to TRI
• Covered facilities
• Chemicals, activities, and thresholds
• Changes for the 2023 reporting year
• EPA guidance documents and tools
• Data quality control

June 6 – 27 – Please watch New Rules and Tools for the 2023 Toxics Release Inventory at your convenience.

Additional TRI Resources

• The compliance experts at SCS Engineers and Ms. Moran are available to answer client questions specific to facilities, chemicals, and PFAS. You may also request a copy of the video presentation with links to EPA resources. Contact SCS Engineers for any of these resources.
• Hazardous Waste Management
• Toxics Release Inventory The Community Right-to-Know Side of EPCRA

May 28, 2024

ABA Section of Environment, Energy, and Resources –  32nd Fall Conference in Seattle, WA.

The 32nd Fall Conference, October 23-25 is an opportunity to hear from leading practitioners and to learn about the challenges and opportunities shaping environment, energy, and resources law. During the conference, you will be able to leverage professional development opportunities, connect with industry experts such as SCS Engineers, and stay informed about the latest trends.

The conference features engaging discussions with leaders in environmental, energy, and resources law, including state and federal regulators, leading scholars, and in-house counsel. Each day will kick off with a plenary session, such as exploring the emergence of AI and its implications for environment, energy, and resources law, and the impact of recent Supreme Court decisions.

The conference agenda is diverse, providing updates on the Clean Water Act and Clean Air Act. A hypothetical industrial accident will focus on managing key roles in responding to the accident. Attendees will gain an understanding from energy practitioners as they delve into environmental justice considerations and the permitting process for energy and environmental projects and the strategic siting of renewable energy projects. Climate change remains a pressing concern, and panel discussions will explore recent climate litigation and the ramifications of climate change on water availability. Hear from panelists as they address Tribal considerations in the areas of treaty rights and co-management of state and federal lands and natural resources. Additional topics to be examined include dam removal developments, contaminated waterways cleanups, the impacts of regulatory requirements on supply chain logistics, the emergence of contaminants such as microplastics and 6PPD, and the evolving landscape of Environmental, Social, and Governance (ESG) and climate disclosure practices.

Experience firsthand this enriching event, where you’ll gain insights from top practitioners, build valuable connections, and be inspired by peers in the environmental, energy, and resources law community. We’ll see you in Seattle!

Register here for the ABA Section of Environment, Energy, and Resources Event in Seattle, WA

SCS Engineers’ professional staff, located according to their knowledge of regional and local geography, regulatory policies, and industrial or scientific specialty, are available nationwide. SCS professionals are technical experts and have been admitted as expert witnesses and supported legal counsel in a variety of environmental and regulatory litigation matters. We are always available to discuss:

1. Brownfields: https://www.scsengineers.com/services/brownfields-and-voluntary-remediation/
2. Solar Energy: https://www.scsengineers.com/services/landfill-services/landfill-renewable-energy/
3. Environmental Due Diligence: https://www.scsengineers.com/services/environmental-due-diligence-and-all-appropriate-inquiries/
4. Greenhouse Gas Monitoring, Inventories, Third-Party Verification: https://www.scsengineers.com/services/greenhouse-gas-services/
5. Wastewater & Liquid Treatment for PFAS: https://www.scsengineers.com/services/liquids-management/
6. Risk Management: https://www.scsengineers.com/services/risk-management-plans-and-process-safety-management/
7. Spill Prevention and SPCC Plans: https://www.scsengineers.com/services/storage-tanks-and-spill-prevention/
8. Stormwater Management: https://www.scsengineers.com/services/stormwater-management/
9. Sustainable Solutions Planning: https://www.scsengineers.com/services/sustainability-and-climate-change/
10. RNG and Anaerobic Digestion: https://www.scsengineers.com/services/biogas-anaerobic-digestion-renewable-energy-systems/
11. ABA SEER: https://www.americanbar.org/groups/environment_energy_resources/

May 22, 2024

WISCONSIN’S PRINTING INDUSTRY CHARTER MEMBERS Present

Changing Regulatory and Sustainability Landscape for the Printing Industry

Join us on June 26, 2024, from 9:30 am – 3:00 pm (Central Time) at the Waukesha County Technical College
Registration fee is $35

Program Agenda (Central Time)
9:30 a.m. – SGP and Green Tier Program introduction
10:00 a.m. – How to Identify Hazardous Waste in the Printing Industry
10:45 a.m. – How Sustainability Is Shaping the Printing Industry
11:30 a.m. – Update on Ozone Nonattainment Emission Reduction Credits and PM 2.5
12:15 p.m. – Lunch (provided)
1:00 p.m. – Overview of Environmental Compliance including Partial Tour of Printer Portal with Cheryl Moran
1:45 p.m. – Small Business Resources Available from the DNR
2:15 p.m. – Advances In Flexible Packaging Recycling (STRAP Process)
3:00 p.m. – Adjourn

Speaker Highlight: Cheryl Moran is a member and leader of the Wisconsin Printing Council and a member of the Great Lakes Graphics Association. She is presenting the 1 p.m. discussion on compliance issues and the printer portal; the regulatory portion of the changing regulatory and sustainability landscape for printers. Many changes to state and federal compliance can impact the printing industry. For example, the Emergency Planning and Community Right-to-Know Act (EPCRA) impacts industrial facilities and the public. Annual reporting is due from printing and production facilities meeting a growing number of criteria – in short – more industrial and government facilities will be required to file mandatory reports in 2024 and 2025.

The emergency planning includes annual notification of hazardous chemicals present at your site to your state and local emergency planning and response organizations, and with your fire department. That information is used to help them prepare for emergencies such as chemical releases or fires and is made available to the public.

This information is disclosed through the toxics release inventory (TRI). TRI covers a variety of industries based on their NAICS code, which employs 10 full-time equivalent employees or more and stores or uses specific chemicals, including 189 PFAS.

This report is often referred to by a variety of names, including Toxics Release Inventory, TRI, SARA 313 report, Form R, or Form A. Do not be fooled by the nomenclature; these all refer to the same reporting requirement.

May 20, 2024

Join SCS Engineers at the 34th Annual Professional Recyclers of Pennsylvania Recycling & Organics Conference at the Wind Creek Bethlehem in Bethlehem, Pennsylvania. The Professional Recyclers of Pennsylvania (PROP) is a leading association that unites community stakeholders, haulers, vendors, and recycling and organics professionals. They focus on sustaining successful recycling programs.

Conference attendees and exhibitors will enjoy networking, sessions, plenaries, and certification classes for grant writing, composting, program design, and more. Pre-conference certification classes will be on Tuesday, July 23rd. The agenda includes the annual PROP picnic, banquet and awards ceremony, and members meeting.

SCS is proud to exhibit at this event, which brings together leaders and organizations from the recycling and organics industries.

Register today!

May 20, 2024

Join SCS at the 2024 MRN/SWANA Mid-Atlantic Annual Conference, hosted by the Maryland Recycling Network (MRN) and the SWANA Mid-Atlantic Chapter at the Turf Valley Conference Center in Ellicott City, Maryland. This year’s conference features legislative updates from the Maryland Department of the Environment (MDE), live learning and networking opportunities for industry professionals, and engaging topics on innovative recycling methods, public outreach strategies, and food waste collection. Attendees will enjoy a crab feast and barbeque closing dinner.

SCS is proud to be a sponsor and exhibitor for the MRN/SWANA Mid-Atlantic Annual Conference, bringing together leaders and organizations across the solid waste and recycling industries.

SCS Experts are excited to present on the following topics this year.

Strategies for Measuring and Reducing Emissions to Comply with Current and Potential Future Regulations

Presenters: Josh Roth, PE, Vice President and Project Director, Landfill Gas (LFG) Group and Helen Steffens, EIT

SWANA members can earn CEUs by attending this event. Register today!

May 20, 2024

This blog summarizes USDA Natural Resources Conservation Service (NRCS) Code 336, which addresses Soil Carbon Amendments as a Conservation Practice Standard, part of the USDA Environmental Quality Incentives Program (EQIP), which provides monetary incentives to improve, among other things, soil quality. Soil carbon amendments include compost, biochar, and other carbon-based materials.

The program is potentially beneficial to compost and biochar facilities (public or private) as the USDA payments include an amount for purchasing finished compost or biochar, which would provide revenue to the facility owner. The payment schedules vary by state. For example, Delaware’s material purchase rates are $26.10 per CY for compost and $201.87 per CY for biochar.

Short History of the Amendments

Introduced in December 2019, Code 808 is an interim standard with the purposes of:

1. Maintain, increase, or improve soil organic matter quantity and quality
2. Maintain or improve soil aggregate stability
3. Maintain or improve habitat for soil organisms
4. Improve plant productivity and health
5. Improve the efficient use of irrigation water

It lists suitable criteria for applicable amendments and guidance for planning a carbon soil amendment. Twenty-nine states adopted code 808.

Code 336 was introduced in November 2022 as the final standard for soil carbon amendments, with minor changes from Code 808. Its purposes are to:

1. Improve or maintain soil organic matter.
2. Sequester carbon and enhance soil carbon (C) stocks.
3. Improve soil aggregate stability.
4. Improve habitat for soil organisms.

The main changes that Code 336 implements are quality standards for evaluating soil for amendment and the carbon amendments that need application to the soil.

Eligible Areas

Areas to which this practice applies, if organic carbon amendments will improve soil conditions:

1. Crop
2. Pasture
3. Range
4. Forest
5. Associated Agriculture Lands
6. Developed Land
7. Farmstead

Landowners or operators are responsible for planning, designing, and implementing carbon amendment applications, including acquiring all permits or approvals. The application and approval process varies by state and may be subject to local regulations.

Soil Criteria

Per Code 336, before carbon amendment application, evaluate all soil for:

1. Soil pH
2. Soil texture
3. Soil organic matter or soil organic carbon
4. Extractable phosphorous, potassium, calcium, sulfur, and magnesium
5. Cation exchange capacity

When conservation objectives are required, evaluate the soil for:

1. Aluminum, sodium, and soluble salts (electrical conductivity)
2. Bulk density
3. Aggregate stability
4. Available water capacity
5. Iron, manganese, copper, zinc

Soil Carbon Amendments Criteria

Code 808 Compost Requirements:

1. Carbon to Nitrogen ratio between 15:1 and 30:1 (target 20:1)
2. 40-60% moisture (60-40% solids)
3. Analysis of carbon and nitrogen content, phosphorus, potassium, pH, soluble salts (electroconductivity), organic matter, and bulk density

Code 336 Compost Requirements:

1. Document the origin of the compost
2. Report and meet conditions for All Carbon Amendments in Table 1
3. Report and meet conditions for Compost Amendments in Table 2

Code 336 Biochar Requirements:

1. Document the origin and production method
2. Report and meet conditions for All Carbon Amendments in Table 1
3. Report and meet conditions for Biochar Amendments in Table 3

Produced compost should be by controlled aerobic, biological decomposition of biodegradable feedstocks and should have the US Composting Council’s Seal of Testing Assurance Program (STA) or meet the Table 2 criteria.

Compost can be combined with other regionally appropriate soil carbon amendments, such as biochar, wood chips, sawdust, or pulverized paper, to meet the soil’s specific needs. Identify contaminants by testing any soil amendments. Remove contaminants such as glass, metal fragments, film plastic, hard plastic, and sharps before submitting the compost application.

Produce biochar by heating biomass to a temperature above 350 °C under controlled and limited oxygen concentrations to prevent combustion (i.e., pyrolysis or gasification). It should have the International Biochar Initiative (IBI) Certified biochar seal or meet the criteria in Table 3.

Payment Rate Tables (CT, DE, and FL Examples)

HU = “Historically Underserved” Farmers and Ranchers

Find additional state payment tables at https://www.nrcs.usda.gov/getting-assistance/payment-schedules.

Code 336 Implementation

Not all state offices have adopted NRCS Code 336, but the figure below by the US Biochar Initiative shows adoption at the close of 2023. (https://biochar-us.org/code336).

Discussion of the state-by-state adoption of NRCS Code 336 is in the BioCycle article States Should Adopt NRCS Soil Conservation Standard Code.

Code 336 pricing for compost appears to provide reasonable funding to offset material purchase, transport, application, and technical services. However, Code 336 pricing for biochar does not provide enough funds to subsidize the purchase of biochar in most markets fully. Further, additional costs remain for biochar transport, application, or technical services.

Table 1. Soil requirements under NRCS Code 336 (2022).

Table 2. Compost requirements under NRCS Code 336 (2022).

Table 3. Parameters for Biochar Amendments

Additional Resources:

• As always, contact the Organics Management team at SCS Engineers if you have questions pertaining to your specific facility.
• Meeting Evolving Air Quality Regulations and Permit Requirements for Composting Facilities
• Diversify Waste Management Revenue By Maximizing Carbon Credit Opportunities
• Organics Diversion – Find a Grant Program
• Organics Management

May 16, 2024

The Pennsylvania Department of Environmental Protection (PADEP) has launched a pilot program to speed up the issuance of National Pollutant Discharge Elimination System (NPDES) permits, focusing on construction stormwater discharges. Started on April 29, 2024, this pilot in 10 counties is designed to streamline the application process for land development projects over one acre that faces unique environmental challenges. Eligible counties include Allegheny, Beaver, Bucks, Chester, Lebanon, Lehigh, Luzerne, Monroe, Montgomery, and York.

From May 1, 2024, the pilot will process up to three NPDES applications per quarter per county, with a yearly maximum of twelve. Applications must involve a licensed professional to oversee the stormwater plan. A significant improvement over traditional methods, the pilot combines completeness and technical reviews within 47 business days. If deficiencies are found, applicants have 22 business days to resolve them, hastening the move to a draft permit stage and public notice.

Exclusions apply to permit renewals, amendments, and projects on brownfield sites or those with large land disturbances or previous enforcement actions. The pilot also mandates two pre-application meetings to ensure eligibility and a final submission within 22 business days after these meetings.

However, the pilot program excludes several types of applications, such as those for permit renewals, amendments, transfers, projects exempt from application fees, or those proposing unapproved stormwater control measures. It also excludes projects requiring special reviews, those disturbing large land areas, or those associated with past enforcement actions. Notably, projects on brownfield sites must complete all required environmental studies and obtain necessary approvals before applying.

The Bureau of Clean Water manages the statewide Erosion and Sediment Control (E&S) program, as specified under 25 Pa. Code Chapter 102, which mandates an E&S permit for certain activities causing significant earth disturbances:

• Construction activities disturbing more than one acre, excluding agricultural plowing or tilling, animal heavy-use areas, timber harvesting, or road maintenance, require an NPDES permit. Eligible entities may seek coverage under the PAG-01 or PAG-02 NPDES General Permits for stormwater discharges associated with small or general construction activities, respectively. Those ineligible for these permits must apply for an individual NPDES permit.
• Timber harvesting and road maintenance activities disturbing 25 acres or more must secure an E&S permit under the Pennsylvania Clean Streams Law instead of an NPDES permit.
• Oil and gas operations disturbing five acres or more also need an E&S permit under the same law. Eligible operators may apply for coverage under the E&S General Permit (ESCGP-3).
• Any other activities disturbing five acres or more not previously specified require an E&S permit.

Managed by the Bureau of Clean Water, the pilot seeks to cut application processing times significantly. Additional details and application procedures are available on PADEP’s website.

A draft of the PAG-02 General Permit that would become effective on December 8, 2024, has been posted to DEP’s eLibrary.

Additional Information:

• E&S program, contact DEP’s Bureau of Clean Water at .
• Stormwater Planning & Permitting
• Contact the Author

May 14, 2024

Sonya Betker is a zero waste and sustainability expert who brings decades of experience to SCS. Betker is a TRUE Advisor and a Sustainable Excellence Associate supporting her clients in sustainable resource management and waste reduction practices that minimize waste by reusing as many products as possible.

Betker’s expertise comes from leading regional, national, and global sustainability and circular economy programs for public and private clients by taking a holistic approach to lead and develop strategic programs. She is particularly proficient at maximizing partnerships for more efficient sustainability programs. Much of her experience has been in business management and brokering before her transition to environmental consulting.

Creating connections between stakeholders and excellent communication has been a constant throughout her career. These traits are especially valuable in zero waste and sustainability planning because they involve multiple stakeholders, including the public.

“Sonya brings field experience and a proven track record driving sustainability, building the business case highlighting potential revenue gains and cost savings with buy-in to sustainability,” states Betsy Powers, vice president and project director. “That provides more successful paths to circular systems, and our clients appreciate our sensitivity to costs.”

Betker’s background includes a B.S. in Business Management – Sustainability from the University of Wisconsin–Stout and over ten professional affiliations and certifications. She has a deep understanding of the most current sustainability issues, tools, and techniques and can communicate sustainability topics to diverse audiences. She can accurately assess sustainability risks and opportunities in an organization, community, or industry.

Betker is an author recognized in industry publications for her article “The future relationship of sustainability and traditional waste and recycling may be a key piece in solving our waste puzzle,” and featured in “Women in Waste” for her leadership skills.

“I’ve learned to look at the big picture of waste and recycling,” Betker said. “I like to look for commodities within markets and help with that circularity—reframing waste as a resource. Stopping or reusing food waste is a particularly rewarding area for many municipalities and businesses.”

Welcome to SCS Engineers where people like Sonya Betker are helping businesses and municipalities run cleaner and more efficiently! 

Additional Resources:

• Reach Sonya at
• Sustainability Planning
• Zero Waste, Sustainable Materials Management, Circular Economy

May 14, 2024

May 14, 2024

Join SCS Engineers at the 2024 WV Brownfields & Main Street Conference, taking place September 10th to 12th, 2024, at the Summersville Arena & Conference Center. This premier redevelopment event in West Virginia offers insightful sessions and workshops focused on brownfields redevelopment and downtown revitalization in rural communities.

Registration opens in June, so mark your calendars and join us for this all-day event where industry leaders converge to discuss strategies for sustainable development and community renewal. Don’t miss this opportunity to at the 2024 WV Brownfields & Main Street Conference connect, learn, and contribute to the future of West Virginia’s economic and environmental landscape.

Melissa Schick will be speaking at the conference!