Providing a safe work environment is always essential, but never more so than now. Meeting PSM/RMP compliance deadlines, providing ammonia refrigeration operator training, and maintaining critical safety systems are key components in a safe work environment for facility employees.
Safety systems, such as ammonia leak detection systems, must remain operational as required under the following regulatory criteria:
• OSHA 29 CFR 5189, Process Safety Management (PSM) Section (j)(2)(C) Mechanical Integrity
• EPA’s 40 CFR Part 68, Risk Management Program (RMP) Part 68.73
• EPA General Duty Clause
• RAGAGEP – IIAR Standard 6
These criteria require companies to comply with the manufacturer’s recommendations for maintenance and calibration of ammonia detection systems. Calibrating ammonia sensors on a frequency determined in these same recommendations keeps your business compliant. We all know that compliance is non-negotiable as the ammonia detection system is a life-safety device.
Mark Carlyle is a member of SCS’s ammonia detector calibration team.
Dedicating itself to providing a variety of online training and virtual meetings, the SCS Tracer Environmental team ensures your systems meet all regulatory obligations. When site visits are necessary; our teams and your facility members use a CDC-based safety protocol meeting state and local requirements, and facility requirements.
For assistance with ammonia sensor calibrations, please contact Mark Carlyle.
In this time of pandemics and stay-at-home orders across the country, much thought has been given to the concept of doing more work remotely. As employees have been required to work from home, the popularity of various business collaboration platforms, such as Zoom, has exploded. As businesses have come to rely on these platforms to continue their essential activities, the idea of utilizing these platforms to conduct remote PSM/RMP activities such as process hazard analyses (PHAs) for our ammonia refrigeration and other highly hazardous chemical processes has grown to a fever pitch.
There are many arguments in favor of a remote PHA. First, it allows us to safely maintain social distancing as required with the current state of emergency due to COVID-19. Second, it allows for more team members to participate while avoiding travel time and costs.
While the first argument supporting remote PHAs cannot be disputed, the reduction in travel costs is often offset by the added time that is required to conduct a thorough PHA over business collaboration video conferencing. There are often technical glitches with the computers or video conferencing platforms that need to be dealt with throughout the PHA. Correcting these issues consumes valuable time, time that is still needed for the discussion of the hazards of the process.
Another time factor that comes into play when conducting a PHA through video conferencing is “Zoom Fatigue.” “Zoom Fatigue” is real. It is challenging to remain focused and engaged in a video conference for more than about six hours at a time. This requires more days to complete the PHA properly. An argument against this six-hour limit is to simply “take more breaks.” While taking more breaks is certainly an option, meeting over a remote platform makes it difficult, if not impossible, to corral team members and get them back on task. In addition to trying to corral team members from breaks, an online platform makes the team members extremely susceptible to the desire to multi-task. More often than not, attendees are involved in checking and responding to emails, answering phone calls, or even addressing in-person issues when on a video/conference call, instead of giving full attention to the task at hand. This makes team engagement difficult and dramatically reduces the effectiveness, and hence the quality, of the PHA.
Team member engagement is driven by the facilitator. Most facilitators rely on eye contact, body movement, and voice inflection to help keep the team members engaged in the discussion. This is difficult at best over a video link. It is downright impossible if any of the team members do not have a video connection and only participate in an audio connection.
Sharing of documents and information is more time consuming using a remote platform. First, any documents that are not in an electronic format must be scanned in order for the team to look at them. Often a scanner is not available or cannot handle the physical size of the document. This leads to attempts to share the document using cell phone cameras. This method is time-consuming at best and often unreadable at worst. Second, it is often impossible due to screen size and resolution to look at multiple documents simultaneously over a video link. When the team is gathered around a conference room table, they can very quickly scan multiple large drawings and collaborate on interpreting them.
It is necessary for the team members to understand the basics of the methodology being used to conduct the PHA. This is why at least one team member must be knowledgeable in the methodology, so that they may guide the team. This guidance is more difficult for the facilitator to provide, given the reduced engagement experienced over a video link. It is often difficult for the facilitator to identify a look of confusion, frustration, or boredom over a video link. It is much easier to do so when sitting across from each other at a conference table.
Finally, perhaps the biggest pitfall associated with a remote PHA is the loss of the ability to take “field trips.” Often, when discussing a hazard or failure scenario, there is ambiguity in the documentation, and memories are vague. When conducting a PHA on site, the team can get up from the table and walk out and look at the area in question. With a remote PHA, this capability is lost. If someone from the site is participating via the remote video link, they could go out and take photos of the area in question and come back and share them with the team. This is not ideal since often pictures don’t tell the whole story, and things may be missed if people only see the picture.
PHAs conducted remotely over a video conferencing link are a viable option for certain types of PHAs. For instance, when conducting a limited scope PHA for a change being conducted under Management of Change, a remote PHA may be a good option. This would depend upon the quality of the available documents supporting the proposed change. When a PHA is being revalidated, and the previous PHA had not been cited for deficiencies in its conduct, a remote PHA may be a good option, providing that a portion of the team members who are knowledgeable of the process being analyzed took part in the previous PHA.
There are many instances where a facility should think long and hard about the potential pitfalls of conducting a process hazard analysis over a remote video conferencing link. If the facility has no existing PHA, if the previous PHA methodology and level of thoroughness were cited by regulators, or if the proposed PHA team consists of few members who took part in the previous PHA, then an on-site PHA should be strongly considered.
About the Author: Bill Lape is a Project Director for SCS’s Risk Management Group in our SCS Tracer Environmental Division. His expertise is in the development and deployment of standardized Risk Management and Process Safety Management (PSM) Programs, including process safety program implementation and PSM support to manufacturing facilities that utilize ammonia as a refrigerant. Prior to joining SCS, he served as Director of EHS Programs and Compliance for Dean Foods where he directed a team of professionals who provided PSM/RMP support, as well as support for stormwater, wastewater, and air permitting at the company’s facilities.
Congratulations to Jeanne Lemaster for recently earning her Masters and Ph.D. in NanoEngineering from the University of California, San Diego. While pursuing her doctorate, Jeanne worked part-time as a Project Professional on the Risk Management team with the specialty group SCS Tracer Environmental and has since returned to full time.
Jeanne has been a part of SCS’s team for over seven years. Dr. Lemaster is responsible for the documentation of Process Safety Management Programs (PSM) / Risk Management Programs (RMP) / California Accidental Release Prevention Programs (CalARP) projects for regulated facilities using hazardous materials. Her work includes preparing the program documentation for compliance with the PSM/RMP/CalARP regulations, leading Process Hazard Analyses (PHA) studies, completing Hazard Assessments, providing CalARP implementation training, developing Piping and Instrumentation Diagrams, conducting Seismic Assessments, and producing technical reports for clients.
Jeanne is affiliated with the American Institute of Chemical Engineers (AICHE), Refrigerating Engineers and Technicians Association (RETA), and the American Chemical Society (ACS).
CONGRATULATIONS, Dr. Lemaster!
Nanoengineers like Jeanne, provide scientific and technical expertise to scientists, engineers, technologists, technicians, or others, using their knowledge of chemical, analytical, and biological processes as applied to micro and nanoscale systems. Nanosystems Engineers also design nanosystems with components such as nanocatalysts or nanofiltration devices to clean specific pollutants from hazardous waste sites. They also design nano-enabled products with reduced toxicity, increased durability, or improved energy efficiency.
Matt Brokaw, P.E. joins the SCS Engineers new office at 3801 Lake Boone Trail, Suite 430, Raleigh, NC 27607, Tel: +1-919-662-3015
Senior Project Professional, Matt Brokaw
SCS Engineers, a top-tier ENR environmental consulting and construction firm, opened a larger office in Raleigh, North Carolina, in late May. The move centralizes the team closer to their clients’ sites to provide full-services. The new office accommodates new team members, including Matt Brokaw. Matt joins the SCS professionals who provide environmental services for solid waste management for the benefit of municipal and private landfills, public works, and recycling.
As a Senior Project Professional, Matt is responsible for the engineering and design of environmental solutions, with a primary focus in solid waste, stormwater management and planning, and erosion and sediment control critical to permitting compliant facilities and ultimately protecting natural resources. Extending the life of a landfill and adding airspace is often critical for the communities SCS clients serve.
The new SCS Raleigh location supports the growing demand for full-service environmental solutions supported by a mix of professionals. As specialized teams, they can help reduce greenhouse gas emissions, capture landfill gases, create renewable energy from by-products, and optimize utilities and businesses using environmental practices that are economically feasible. The firm specializes in permitting for and meeting comprehensive clean air, water, and soil goals. It provides a range of services such as PFAS treatment, solid waste master planning, landfill technology, risk management, groundwater monitoring, pre-closure and landfill closures, and Brownfields remediation.
About SCS Engineers
SCS Engineers’ environmental solutions and technology are a direct result of our experience and dedication to solid waste management and other industries responsible for safeguarding the environment. For more information about SCS, please visit our website at www.scsengineers.com/, contact , follow us on your preferred social media, or watch our 50th Anniversary video.
Circulated with permission from EREF – Press Release
For years, the public has considered recycling to be one of the best methods of preserving the environment and preventing valuable materials from going to the landfill. Coupled with this is the misconception that landfills are actually harmful to the environment.
As a result of this misunderstanding, consumers, driven to do their sustainable part by avoiding the trash can, discard their items in the recycling bin with little regard or understanding of what does and does not belong in that bin. Thanks to this wish-cycling and confusion, consumers unknowingly create more contamination, rendering some of the material un-recyclable, as well as dangerous conditions for solid waste and scrap recycling facilities.
With these stressors already weighing on facilities, fires at material recovery facilities are on the rise, with records set in July, August, and September of 2019 for reported fires.
Despite the recent increase in MRF fires, there is little data and evidence to explain how and why these fires spark. To fill in this data gap, the Environmental Research & Education Foundation (EREF), in collaboration with the Institute of Scrap Recycling Industries (ISRI), National Waste & Recycling Association (NWRA) and the Solid Waste Association of North America (SWANA) have partnered on a study to determine the causes and frequency of MRF fires in the U.S.
The primary objective of this effort is to compile information that summarizes the following information about fires at MRFs and scrap recycling facilities and in collection vehicles:
Frequency of MRF and scrap recycling fires annually (i.e. % of facilities)
Frequency of collection vehicles fires
Suspected cause(s) of these fires
Strategies/technologies used to fight the fire
Damage caused by the fire (e.g. property, personnel injury/death, lost operating revenue)
Preventative measures taken to minimize the potential for fires
Likelihood that lithium ion batteries disposed of at MRFs or scrap yards caused a fire
Key industry organizations have rallied around the issue, with the project stakeholders representing a significant portion of the scrap and recycling industry. “These fires present a major risk to worker safety. For years, NWRA has fought to improve worker safety in the waste industry,” said Darrell Smith, President and CEO of NWRA. “This study will better inform our efforts.”
“The recycling industry is taking a proactive approach to addressing the growing concern of fires at scrap facilities,” said Robin Wiener, President of ISRI. “While this includes the implementation of new technologies, workforce safety initiatives, and public outreach on proper recycling, identifying the causes of fires is the first step to finding a solution to prevent them. The survey will help identify the root causes which we can then use to better direct resources to prevent future fires.”
“The information gleaned from this study has the potential to save facility owners money, reduce material loss and, more importantly, increase worker safety,” said David Biderman, Executive Director and CEO of SWANA. “We’re excited about the impact this research can have on the industry.”
A critical component of the study is a survey of recycling and scrap facilities, which recently went live. “Such information is critical and benefits the entire industry, as fires serve to further financial pressure on an already strained industry,” noted Bryan Staley, President and CEO of EREF.
To participate in the survey, please visit the project website. Survey Closes May 29, 2020
Project sponsorships are available! To sponsor this project, please contact Bryan Staley at .
EREF is a 501(c)3 class charity that funds and directs scientific research and educational initiatives for waste management practices to benefit industry participants and the communities they serve. For more complete information on EREF funded research, its scholarship program and how to donate to this great cause, visit erefdn.org.
Landfills, especially large regional landfills, are huge enterprises with many different operations ongoing daily. A landfill’s tangible assets are equipment, buildings, machinery, construction materials in the ground, or stockpiled to support various operations. Of all these, the most significant asset is the permitted airspace. It’s undoubtedly a non-tangible asset when permitted, but gradually this asset gets consumed as it turns into revenue.
Creating landfill airspace during a design/permitting process involves the operator hiring a landfill engineer to develop the concept of the airspace, prepare an appropriate design with engineering methods, and obtain a permit for it through regulatory agencies. In a sense, a portion of your future revenue is in the hands of your landfill engineer. You depend on this engineer to create the maximum amount of airspace, generating the maximum amount of revenue for your operation over time. Your engineer is supposed to be your trusted partner, and you are investing an enormous amount of capital for the design, permit, and construction based on the work performed by the engineer.
In some instances, the operator leaves most of the technical decision making to the engineer. On other occasions, the operator is in the loop during the engineer’s design, but the operator is not heavily involved in the nuances of the disposal cell’s layout in consideration of the existing terrain. In either case, the engineer is significantly responsible for achieving the maximum amount of airspace. The multi-million dollar question is whether you could have had another 3 million or 5 million cubic yards of additional airspace in your permit. How do you check if your landfill engineer maximized airspace in the design?
Assuming proper training, most landfill engineers can design adequate landfills. Still, very few landfill engineers have the unique talent and experience that can maximize airspace within specific design parameters. You, as the operator want engineers with a proven track record of maximizing airspace in their landfill designs, and do not let relationships or political nuances affect your judgment during selection because tens of millions of dollars of additional revenue are at stake.
A trained landfill engineer may miss details that a highly qualified engineer would not. Incidentals here and there, if recognized and accounted for, can add significant airspace to the design. These details vary from site to site, and it’s up to the engineer to recognize the benefits of geometric and regulatory opportunities to add to the covered airspace. These details could be in the form of:
Special geometries for the landfill slopes,
The lateral extent of waste limits,
The landfill footprint placement within the terrain,
The extent of excavation for establishing bottom grades for disposal cells,
The relative position of base grades with respect to the groundwater elevations,
Combining leachate collection sumps among two or more disposal cells,
Steeper slopes to increase airspace while staying within the bounds of regulatory requirements,
Positioning peripheral systems in a different way to benefit from additional land to add to the landfill footprint,
Considering future expansion down the road and planning appropriately, and
Other nuances that an expert considers.
The operator chooses the project manager or the primary engineer for the design of a greenfield landfill or an expansion to an existing landfill, knowing that the work performed by the selected engineer could potentially add to or take away hundreds of millions of dollars from the bottom line of your enterprise. So, pick your engineer based on the engineer’s prior design track record and make sure the engineer is an expert in maximizing landfill airspace.
SCS is an expert, highly experienced landfill designer – relied on by many landfill operators as a trusted partner. Our culture is to serve our clients as if their project is our own, and we do not consider ourselves successful unless our clients are satisfied. These close relationships help us serve the majority of our clients on a long-term basis, with decades of continuous service and value.
SCS will gladly evaluate scenarios for your landfill expansions that you are planning to design and permit, and provide you with a preliminary estimate of airspace gain and revenue that an SCS design could bring, potentially increasing your primary asset by another tens of millions of dollars. Now that’s a value statement!
About the Author: Ali Khatami, Ph.D., PE, LEP, CGC, is a Project Director and a Vice President of SCS Engineers. He is also our National Expert for Landfill Design and Construction Quality Assurance. He has nearly 40 years of research and professional experience in mechanical, structural, and civil engineering.
Recently SCS Engineers achieved two Design-Build rankings in the 2019 Engineering News-Record – ENR, Top 500 Environmental Sourcebook, which publishes in May 2020.
“Our greatest reward is client satisfaction,” Mr. Jim Walsh, President, and CEO of SCS Engineers.
SCS ranks highly in both Design-Build for these environmental categories as most recently published:
2019 ENR Top 500 Sourcebook – Published in May 2020
Top 500 ranks SCS at No. 74 out of 500 firms.
ENR Top 20 ranks SCS No. 11 in Sewer and Waste
ENR updates other “Top” ENR publications in subsequent months throughout 2020. SCS’s current standings are as follows:
No. 2 Solid Waste
No. 11 Site Assessment Compliance
No. 13 All-Environmental Services
No. 20 Chemical & Soil Remediation
No. 25 Hazardous Waste Construction
No. 64 Overall Top 200 Environmental Firms
No. 13 Top 30 All-Environmental Firms
Top 400 Build – Published in 2018
No. 3 Solid Waste Construction
Thanks to you, SCS Engineers has received awards and industry recognition for research achievements and technology innovations. These honors have come to us from such organizations as SWANA, NWRA, Environmental Business Journal (EBJ), and many other engineering, building, technology, and environmental organizations.
We are grateful and continue striving to bring you the most value with every environmental solution. Thank you.
Los Angeles County Public Works – Environmental Programs Division is receiving a 2019 Food Recovery Challenge Award from the United States Environmental Protection Agency – USEPA this year. The national recognition is for the County’s substantial increase in food recovery and sustainable materials management. EPA’s data-driven awards are based on the information submitted in the Sustainable Materials Management – SMM, Data Management System, and reflect percent changes comparing an organization’s data to the previous year’s data.
LA County Public Works serves 88 cities and a population of more than 10 million people. The County is continually pursuing ways to make its communities more resilient by identifying new SMM actions to address greenhouse gases, waste generation, and pollution.
The ‘Scrape Your Plate’ program encouraged the County’s Public Works employees to divert food waste from area landfills through organics recycling. Collecting food in the headquarters cafeteria and dining area, the program quickly expanded to include 20 on-campus breakrooms and special events at field facilities across the County.
Public Works, in collaboration with the Sanitation Districts, made use of the existing anaerobic digestion infrastructure to convert 13,700 pounds of food waste to electricity. Worm composting bins divert an additional 1,200 pounds of food waste and another 340 pounds were source reduced by improved planning by kitchen staff. All of these diversion tactics reduce greenhouse gas emissions.
Getting employees and visitors to separate food waste properly is always a challenge. The project team, including SCS Engineers, significantly reduced cross-contamination by increasing on-site signage and peer-to-peer outreach. Signage, easily updated with user-friendly graphics makes a difference. The team further encourages new social behaviors with an educational video.
Despite the closing of recycling programs in other cities due to the pandemic, LA County Public Works is now expanding its program to recycle other types of organic waste, including food-soiled paper.
Well Done, LA!
Preventing and reducing food waste has a tremendous impact and positive benefits for our nation. Food is a valuable resource. Efforts to reduce food waste and ensure excess food doesn’t go to waste are needed now more than ever. Participants in EPA’s Food Recovery Challenge in 2019 prevented or diverted over 815,000 tons of food from entering landfills or incinerators, saving participants up to $42.3 million in avoided landfill tipping fees. The EPA provides many helpful tools on its website.
No airplanes, trains, buses, taxis, or Uber required.
SCS Engineers has been working diligently these past few weeks to bring online training to you. With our Tracer team’s dedication, we are excited to let you know, SCS is offering these online classes:
Ammonia Refrigeration Operator I & II,
Intro and Advanced PSM/RMP/GDC,
CARO Review,
CIRO Review, and
Custom classes
Use our online program to safeguard your operators’ continued compliance education for Process Safety Management and Risk Management Program regulations.
The industry is designing and building more substantive drainage features and larger collection systems from the bottom up, that maintain their integrity and increase performance over time, thus avoiding more costly problems in the future.
Waste360 spoke with three environmental engineers about what landfill operators should know about liquids’ behavior and what emerging design concepts help facilitate flow and circumvent problems such as elevated temperature landfills, seeps, and keep gas flowing.
The engineers cover adopting best practices and emerging design concepts to facilitate flow. They cover topics such as directing flow vertically to facilitate movement to the bottom of the landfill, drainage material, slope to the sump percentages, vertical stone columns, installing these systems at the bottom before cells are constructed, and increasing cell height to prevent the formation of perched zones.
Ali Khatami, one of the engineers interviewed, has developed standards for building tiered vertical gas wells that extend from the bottom all the way up. He frequently blogs about landfill design strategies that his clients are using with success. His blog is called SCS Advice from the Field. Dr. Khatami developed the concept of leachate toe drain systems to address problems tied to seeps below the final cover geomembrane. These seeps ultimately occur in one of two scenarios, each depending on how the cover is secured.
Landfill Gas Header: Location and BenefitsBy continuing to design gas header construction on landfill slopes, all of the components end up on the landfill slope as well. You can imagine what type of complications the landfill operator will face since all of these components are in areas vulnerable to erosion, settlement, future filling, or future construction. Additionally, any maintenance requiring digging and re-piping necessitates placing equipment on the landfill slope and disturbing the landfill slope surface for an extended period.
AIRSPACE, the Landfill Operators’ Golden EggAirspace is a golden egg, the equivalent to cash that a waste operating company will have overtime in its account. With each ton or cubic yard of waste received at the landfill, the non-monetary asset of airspace converts positively to the bottom line of the …
Gas Removal from Leachate Collection Pipe and Leachate SumpKeeping gas pressure low in and around the leachate collection pipe promotes the free flow of leachate through the geocomposite or granular medium drainage layer to the leachate collection pipe and improves leachate removal from the disposal cell. Using gas removal piping at leachate sumps is highly recommended for warm or elevated temperature landfills where efficient leachate removal from the leachate collection system is another means for controlling landfill temperatures.
Leachate Force Main Casing Pipe and Monitoring for LeaksLandfill operators may add a casing pipe to their leachate force main for additional environmental protection. Consequently, the leachate force main is entirely located inside a casing pipe where the leachate force main is below ground. In the event of a leak from the leachate force main, liquids stay inside the casing pipe preventing leakage …
Pressure Release System Near Bottom of LandfillsPressure Release System Near Bottom of Landfills – Essential Component for Proper Functioning of the Landfill Drainage Layer. Landfill designers are generally diligent in performing extensive leachate head analysis for the design of the geocomposite drainage layer above the bottom geomembrane barrier layer. They perform HELP model analyses considering numerous scenarios to satisfy all requirements …
Landfill Leachate Removal Pumps – Submersible vs. Self-Priming PumpsSelf-priming pumps can provide excellent performance in the design of a landfill leachate removal system. Landfill owners and operators prefer them to help control construction and maintenance costs too. A typical system for removing leachate from landfill disposal cells is to have a collection point (sump) inside …