Each spring the Washington, Oregon and British Columbia chapters hold a joint Northwest Symposium. SCS Engineers never misses the opportunity to join other solid waste industry professionals from a wide variety of specialized fields. We look forward to seeing you at booth 16. The NW Regional Symposium is a great conference to exchange information and learn from technical experts, such as these speakers:
Michelle Leonard, Vice President & National Expert on Solid Waste Planning and Recycling
Food Recycling and Rescue – Los Angeles County’s Three-Pronged Approach
Ms. Leonard has over 30 years of experience in environmental consulting and project management, with an emphasis on Sustainable Materials Management, including solid waste management planning and facilities. She regularly shares her expertise with associations and communities interested in her work.
Shane Latimer, Ph.D., CSE, Project Director
Using Laser Technology to Control Birds at Landfills – Preliminary Results at a Southern Oregon Landfill
Dr. Shane Latimer, CSE, is an ecologist and an environmental planner with over 20 years’ experience in environmental assessment, planning and permitting. He specializes in projects that are often large, complex, or controversial, and involve a combination of land use, environmental permitting, and other constraints.
Tracie Onstad Bills, Senior Project Manager
Residential Food Waste Prevention Community-Based Social Marketing (CBSM) Pilot Study
Ms. Onstad-Bills has over 20 years of materials management experience, including working for a hauler, a county government, and a non-profit; she also has over 10 years with materials management consulting firms. She has provided commercial sector materials flow assessments, green events project management, construction and demolition (C&D) research, and recycling and waste management technical support to government agencies and businesses.
EPA has issued a revised NESHAP standard for municipal solid waste landfills. The new rule reflects EPA’s conclusions regarding the residual risk and technology rule, resolves confusion created when the previous rule was not updated at the same time as the landfill NSPS and updates landfill gas well head criteria for temperature. EPA is also clarifying that the standards are applicable during periods of startup, shutdown and malfunction, and requiring electronic reporting of performance test results.
This action finalizes the residual risk and technology review (RTR) conducted for the Municipal Solid Waste (MSW) Landfills source category regulated under National Emission Standards for Hazardous Air Pollutants (NESHAP) contained within 40 Code of Federal Regulations (CFR) Part 63, Subpart AAAA. Additionally, the U.S. Environmental Protection Agency (EPA) is taking final action to:
The EPA is also finalizing minor changes to the MSW Landfills NSPS and Emission Guidelines (EG) and Compliance Times for MSW Landfills contained within 40 CFR Part 60, Subparts XXX and Cf. Specifically, the EPA is finalizing provisions to the most recent MSW Landfills NSPS and EG that would allow affected sources to demonstrate compliance with landfill gas control, operating, monitoring, recordkeeping, and reporting requirements by following the corresponding requirements in the MSW Landfills NESHAP. According to EPA, these final amendments will result in improved compliance and implementation of the rule and eliminate some of the confusion created by the previous version of the EPA rule.
We’ve pulled this information from the Final Amendments to Air Toxics Standards for Municipal Solid Waste Landfills and SCS will publish an SCS Technical Bulletin on our blog and social media sites. Please contact your Project Manager for details specific to your operation.
Approximately 738 MSW landfills are subject to the NESHAP.
On February 25, 2020, EPA finalized amendments to the 2003 NESHAP for MSW Landfills. EPA issued air toxics standards for the MSW Landfills source category in 2003 that established emission limitations based on maximum achievable control technology (MACT) standards for hazardous air pollutants (HAP) from major and area sources.
The rule required MSW landfills greater than 2.5 million megagrams (Mg) and 2.5 million cubic meters with uncontrolled emissions greater than 50 Mg/year of non-methane organic compounds (NMOC) to install and operate a gas collection and control system (GCCS). Most emissions from MSW landfills come from the continuous biodegredation of the MSW. Landfill gas contains methane, carbon dioxide and more than 100 different NMOC, including, but not limited to, vinyl chloride, ethyl benzene, benzene and toluene.
Based on the RTR, EPA is finalizing no changes to the existing standards because the agency determined the risks to be acceptable with an ample margin of safety to protect public health and the environment. In addition, EPA did not identify any new cost-effective emission controls for MSW landfills. However, EPA is finalizing several minor amendments to reorganize and streamline requirements for MSW landfills that will improve the clarity, compliance and implementation of the rule. These include:
The Clean Air Act (CAA) requires EPA to regulate toxic air pollutants, also known as air toxics, from categories of industrial facilities in two phases. The first phase is “technology-based,” where EPA develops standards for controlling the emissions of air toxics from sources in an industry group or “source category.” EPA bases these MACT standards on emission levels that are already being achieved by the best-controlled and lower-emitting sources in an industry. Within 8 years of setting the MACT standards, the CAA directs EPA to assess the remaining health risks from each source category to determine whether the MACT standards protect public health with an ample margin of safety and protect against adverse environmental effects. This second phase is a “risk-based” approach called residual risk. Here, EPA must determine whether more health-protective standards are necessary.
Every 8 years after setting MACT standards, the CAA requires EPA to review and revise the standards, if necessary, to account for improvements in air pollution controls and/or prevention and to address any residual risks that still remain after the MACT is implemented.
The CAA requires EPA to assess the risk remaining after application of the final air toxics emission standards; known as a residual risk assessment. Based on the completed risk assessment, available health information, and associated uncertainties, EPA determined risks from the MSW Landfills source category are acceptable and provide an ample margin of safety to protect public health. EPA estimates the maximum individual lifetime cancer risk for inhalation for the source category to be less than 10-in-1 million.
The CAA requires EPA to assess, review and revise air toxics standards, as necessary, taking into account developments in practices, processes and control technologies. The technology review of the standards for MSW Landfills did not identify any developments that would further reduce HAP emissions beyond the original NESHAP.
Download a copy of the final rule notice from EPA’s website at the following address: https://www.epa.gov/stationary-sources-air-pollution/municipal-solid-waste-landfills-national-emission-standards.
SCS will publish an SCS Technical Bulletin on our blog and social media sites. Please contact your Project Manager for details specific to your operation.
SCS Customer Support: email@example.com
Over the past 50 years, SCS Engineers has earned a leadership role in solid waste management and environmental services, which would not have been possible without client and industry support. There were few engineering firms specializing in environmental consulting when SCS was founded in 1970.
Today, the firm’s work supports a wide range of environmental solutions in different industries and business sectors. Fifty years ago, no one could have imagined using drones and satellites to collect information to run landfills or businesses in an environmentally safe way. However, as Jim Walsh notes, no one could have imagined a Coronavirus pandemic either; he continues:
Even today, as we are in the midst of a crisis, the likes of which none of us has ever seen in our lifetimes, our clients need us every bit as much, if not even more. In many cases, we operate and maintain critical environmental infrastructure that must continue to operate. In recent days, many of our clients are asking us if we are prepared to continue to serve them now, and as conditions worsen. We’ve said yes, fortunately, because we can and we are ready. We follow health and safety rules and guidance, we have our contingency and communications plans in place, and our employee-owners know how to circle the wagons and move forward prudently as a team.
The firm’s business model has its 70 regional and satellite offices located near client sites with mobile offices co-located on project sites. “The model has always worked well for us,” states Senior Vice President Mike McLaughlin recently. “Our professionals and technicians live nearby; our distributed network means we can drive to project sites instead of flying, for example.”
Amid the recent COVID-19 outbreak, employees are still celebrating, albeit in a different way. Postponing parties and gatherings, employees with their families watched a documentary on April 1 demonstrating the firm’s 50 years of progress and accomplishments. The film features Founder Tom Conrad narrating the firm’s history, and several of the facilities, environmental practices, and technologies in use today, with a look toward tomorrow. “We’re proud of the care and contributions by our colleagues over the years, and now,” stated Bob Gardner, senior vice president. “That sense of responsibility and ownership, along with SCS’s camaraderie, will help see us through.”
The environmental consulting firm started as a partnership between Bob Stearns, Tom Conrad, and Curt Schmidt on April 1, 1970, in Long Beach, California. The three engineers knew and respected each other’s strengths and capabilities: Stearns was an expert in solid waste; Schmidt was a water and wastewater engineer; and Conrad was a jack-of-all-trades with experience in civil engineering, solid waste, water and wastewater.
The firm’s first project was to investigate a subsurface gas problem at a residential subdivision in Palos Verdes, California, and to design a solution. Eight months after SCS was founded, a new federal agency called the U.S. Environmental Protection Agency (EPA) was created, and SCS performed three of the first research contracts awarded by the new agency. One of those projects was a nationwide study of wastewater generation and treatment by the canned and preserved fruit and vegetable industry. Another was a national study to develop a methodology to compare and select equipment for sanitary landfills. The third was a study of the impact of federal agency regulations, policies, and practices on solid waste generation and recycling; this extensive study involved 12 agencies. To conduct these analyses, Tom Conrad moved from California to open the firm’s second office in Reston, Virginia. With these three contracts, and offices on both coasts, SCS was off and running.
In the mid-1970s, SCS engineered and began operation of two of the nation’s first gas recovery projects: Industry Hills and Ascon, both in Southern California. It was a big leap to get those systems working and commercially producing the gas for beneficial uses. Soon after, the federal government passed legislation to authorize tax credits for landfill gas recovery. Thus began the landfill gas utilization industry. From their experience on these two successful recovery projects and their other landfill gas work, SCS became one of the nation’s leading environmental firms.
Next, the firm designed a solid waste management plan, followed by a hazardous waste management plan, both for the state of Maine. In Seattle, Washington, SCS’s EPA water data management project spurred the use of computers to model water characteristics and stream flows throughout the country. Out of that grew a number of wastewater and water quality-related contracts for the EPA, including calculating the percentage of wastewater in water supplies. The amount of data collected was significant.
Tom Conrad explains:
For each public water supply drawing water from a river downstream from a wastewater treatment plant, the idea was to calculate the percentage of the wastewater in the water at each point. This was “big data” before the phrase was coined.
Current SCS President Jim Walsh describes SCS’s first computer to manage the data. “It had less power than an iPhone today, but it was a powerful computer in its time, and we had a massive amount of data that we would process through it,” he stated. The beginning of data collection performed by SCS for the EPA was an extension of the firm’s water quality and wastewater practice.
SCS’s work in the late 1970s and early 1980s was an outgrowth of a number of federal projects, for example, the Dredged Materials Project for the Corp of Engineers in Vicksburg, Mississippi. SCS professionals developed experience with contaminated sites, leachate, and groundwater pollution. The firm began applying these skills and disciplines to contaminated sites in southern California. SCS conducted a number of projects for public entities and developers where construction was planned for what were the first Brownfields before that term was coined. Basically, SCS was performing Phase I site investigations and Phase II investigations, including groundwater monitoring, soil sampling, and remediation when necessary.
Senior Vice President Mike McLaughlin, who leads the practice, states:
That really was the birth of our Environmental Services practice, which was heavily involved in site characterization, Brownfields development, and redevelopment of contaminated sites, that continues to flourish to this day.
Senior Vice President Bob Gardner further comments:
From our experience in landfill research, we were able to get in on the ground floor of many of the RCRA mandates for containment systems, leachate management, landfill liners, and cover systems. We did a lot of work through the ’80s and ’90s for municipal solid waste landfill permitting and design.
By the late 80’s SCS Engineers had created new practices, under the name SCS Field Services, to perform landfill and landfill gas system construction, operations, monitoring, and maintenance. The firm was proud to offer comprehensive services but knew from their experience that each landfill and solid waste operation is unique. SCS OM&M now operates 24,000 LFG extraction wells and supports over 650 landfills across the nation. SCS Construction is a Class A – General Engineering Contractor with Hazardous Materials Certification. The firm believes that by overlapping design, construction, and operational activities, it has led to the 44 innovations listed as SCS Firsts on their website and saved their clients money.
In 1986, the firm also made a significant and strategic decision to create an employee stock ownership plan.
Tom Conrad explains:
As an ESOP company, our employees own shares in SCS Engineers and all its practices. As founders, we felt that ownership inspires better performance and that our staff deserve control in the decision-making and direction of the company. It has proven to be a successful business model for the firm.
Combining SCS’s expertise in solid waste management, landfills, and regulatory compliance, SCS Energy was created in 2001 to focus on the design and design-build of landfill gas-to-energy (LFGE) systems. SCS now has one of the longest and most successful biogas practices in the United States, primarily in LFGE and digester gas-to-energy (DGE). SCS designs, constructs, and operates more LFGE and DGE facilities than any other engineering firm in the nation.
Growing and expanding its environmental expertise to serve other industries and sectors, the firm now has several specialized practices created along the way, which continue to support businesses and governments.
Tom Conrad feels that among his greatest achievements was the hiring and mentoring of many good people, including Jim Walsh, Mike McLaughlin, and Bob Gardner, in whose capable hands the company continues to grow and thrive. Jim Walsh calls Tom, “The best mentor anyone could ever have.” He went on to say, “Tom taught me a lot, but more, he let me figure things out on my own… I’ve often said that the best four years of education I ever got was not high school or college, it was learning from Tom Conrad 1974 to 1978.”
Over the years, SCS expanded and hired many talented people. They guide the firm, maintaining the founders’ focus on adopting their clients’ environmental challenges as their own and fostering a culture of success for employees by sharing equity ownership. The firm wins multiple awards for its work, helping clients minimize waste generation and effectively manage recycling, collection, and disposal operations, safely clean up contaminated properties or water for reuse, and otherwise find sustainable solutions to environmental challenges.
SCS’s culture attracts professionals with many types of expertise, helping the firm grow organically – it is on track to reach 1,000 employees this year, and has year over year record-breaking revenues. While SCS’s core capabilities are in solid and hazardous waste management, renewable energy, remediation, and environmental compliance, in the last decade, the demand for SCS services expanded into technology, more focus on wastewater and water reuse, composting, sustainable materials management, industrial health & safety, and risk management planning. The firm maintains a deep technical bench, a wide range of industry experts, and vast environmental regulatory systems knowledge that helps clients shorten project timelines and control costs.
Recognizing that industry associations benefit both employees and clients, SCS stays involved and active in hundreds of associations and local communities, serving in leadership roles, funding scholarships, and advancing research.
EREF’s President and CEO, Bryan Staley comments:
Investing in education and high-quality research was paramount to Bob Stearns, one of SCS’s founders, who chaired the Environmental Research and Educational Foundation before his retirement and established the Robert P. Stearns/SCS Engineers Master’s Scholarship. Those values continue, as does SCS Engineers’ partnership with EREF, with continued service on EREF’s Board of Directors via Jim Walsh, leadership on its Research Council through Bob Gardner (who chaired the Council in 2019) and ongoing support and participation by many SCS personnel in EREF research and educational initiatives.
David Biderman, SWANA Executive Director & CEO states, “SCS Engineers has been a leader in SWANA for decades, and we look forward to continuing to work closely with the company as we implement our vision to turn waste into a resource.”
SCS is producing technologies and programs that help clients lower operating costs and reduce their environmental impact. The technologies and applications used at landfills are finding footholds in agriculture, industry, and manufacturing as well as municipalities. These advances help achieve infrastructure that runs more efficiently and supports companies transitioning to renewable energy resources while limiting added expense to consumers.
SCS clients entrust the firm with the management of more than 35 million metric tons of anthropogenic CO2e greenhouse gases every year. The firm collects and beneficially uses or destroys enough methane to offset greenhouse gas emissions from 7.4 million passenger cars annually.
These figures do not include the emission reductions achieved by waste diversion, recycling, and repurposing wastes into useful products such as Renewable Natural Gas, compost, or supporting municipal programs that send perfectly edible food to those in need.
“We attribute our success to our loyal clients who entrust us to address the complexities of environmental challenges,” stated Jim Walsh, president, and CEO. “We are proud of our employee-owners who create the technologies, practices, and systems that make a sustainable, positive impact.”
Earth Day is also celebrating its 50th Anniversary this year – the first Earth Day took place just a few weeks after SCS started. Postponing parties and Earth Day events, some celebratory plans continue as the SCS employee-owners celebrate virtually for now with a documentary film, anniversary lapel buttons packaged with hand sanitizer, office plaques, and continued collaboration.
Despite the many impacts on our lives right now, our thanks go to the many public and private solid waste management employees, and organizations such as SWANA and the NWRA, for continuing to serve our communities to keep them clean and safe nationwide. Solid waste management is definitely an essential service on the frontline.
John Sullivan is the Permian Basin regional manager for SCS Engineers and a professional geologist from Texas Tech University in Lubbock, Texas. He started his career as a geologist
at the High Plains Underground Water Conservation District in Lubbock, working closely with the conservation and mapping of the Ogallala Aquifer.
For 25 years, he has worked in all manner of environmental consulting, including groundwater remediation, modeling and permitting of water systems. He was the national saltwater disposal asset manager for a leading energy service company, which entailed the management of SWDs in New Mexico, Oklahoma, Louisiana, North Dakota, and West, East and South Texas. He has permitted public water systems, pipelines, bulk fuel storage facilities, saltwater disposals, and chemical manufacturing plants.
Read John’s most recent article in the March issue of Shale Play Water Management, entitled Navigating Regulatory Hurdles for Induced Seismicity.
During this COVID-19 outbreak, many employers, property managers, and property owners are tirelessly working to maintain clean and safe environments for tenants and employees. Cleaning contractors and janitorial services are working overtime, expending considerable efforts trying to maintain clean and disinfected workspaces and buildings. While providing their services, they face continual challenges of not having enough information regarding COVID-19 behavior, and the dwindling supply of cleaning and disinfecting agents. Many have inquired about microbial sampling and analytical methodologies to evaluate the effectiveness of these cleaning measures.
Some of us have been here before. Twenty years ago, property managers and tenants faced similar challenges in the wake of anthrax contamination of mailrooms in several prominent buildings. The approach we took then—collecting wipe samples from areas of concern for analysis at a nationally-recognized specialty laboratory—can offer peace of mind and an empirical basis for the evaluation of cleaning/disinfection effectiveness.
While specific testing for viruses, including the novel coronavirus (SARS-CoV-2), is not generally available, it is possible to test environments and surfaces for the presence of surrogate clinical pathogens and bacteria—these should be absent if cleaning and disinfection are effective.
Every building, tenant space, and office work environment is unique, and therefore it is important to develop site-specific plans. Staff collecting the samples should be trained in hazardous incident response, including microbiological and chemical impacts on structures and the environment, and should have the proper personal protective equipment (somewhat scarce at present in many locations).
About SCS Engineers
SCS Engineers is a 50-year-old, employee-owned environmental consulting and contracting firm that designs and implements sustainable and innovative environmental solutions. With 70 offices nationwide and nearly 1,000 employees, we are a full-service provider in the solid waste, hazardous waste, and environmental engineering industries. We study challenges and design solutions; we remediate, build and operate environmental and energy projects and systems; and, we evaluate the public health risk of hazardous materials exposure scenarios. As technologies, industry, and public needs change and expand, SCS evolves to provide innovative solutions to our clients’ challenges.
Most states’ guidance considers SCS’s services as essential to protect public health.
Contact SCS today at 800-767-4727 or firstname.lastname@example.org for additional information and consultation regarding the effectiveness of cleaning/disinfection at your properties and workspaces in your state. Further information about SCS is on our website at https://www.scsengineers.com/.
To our valued clients, partners, and friends, we would like to pass on our wholehearted concern for you and your families’ well-being. We hope that those affected by the virus recover fully and quickly, and those healthy remain that way.
We look forward to the day we can meet again in a less socially-distant way, but in the meantime, know that we are here to serve and are available to help you carry the load in a challenging time.
The employee-owners of SCS Engineers
The coronavirus, COVID-19 outbreak has caused widespread disruptions as communities implement protective public health measures. Due to this situation, facilities may encounter difficulties that prevent them from submitting their Annual GHG reports for reporting year 2019 by the March 31, 2020 deadline.
EPA’s electronic Greenhouse Gas Reporting Tool supports facility and supplier reporting for the EPA Greenhouse Gas Reporting Program. The e-GGRT system will remain open past this deadline for all first-time submissions and resubmissions. Log-in here. The same URL has new user registration and help with retrieving lost passwords.
New to e-GGRT? Get help here.
The GHGRP requires reporting of greenhouse gas (GHG) data and other relevant information from large GHG emission sources, fuel and industrial gas suppliers, and CO2 injection sites in the United States. Approximately 8,000 facilities are required to report their emissions annually, and the reported data are available to the public in October of each year.
Both associations are providing guidance, as many waste management activities must continue. SCS is following association advice, state protocols, and our clients’ recommendations in our own procedures as we continue to perform essential work. We share the SWANA resources and recommendations here and thank them for their dedication. SCS employees should use SCS resources available on the SCS intranet and through our Health & Safety protocol, which reflect the safety precautions advised here.
Reprinted Letter to SWANA Members dated March 23, 2020
As communities and companies throughout the United States and Canada respond to the Coronavirus pandemic, SWANA will continue to provide assistance to its members and the waste industry.
A growing number of states and localities are issuing orders identifying certain industries as “essential” during the pandemic, and these orders typically include the solid waste industry and other categories of employees who may be SWANA members. In those locations, employees and contractors may need to demonstrate proof to law enforcement personnel or others that they work in an essential industry. See this template letter that employers can customize to their needs and provide to employees and contractors. The letter should be on agency/company letterhead and include a contact person and a telephone number to call. The contact person should be familiar with the applicable emergency declarations.
Employees and contractors should carry the customized letter with them at all times, and particularly when they are going to or from work. Several waste industry employees in California in their personal vehicles were stopped on their way to work by law enforcement personnel late last week, but fortunately, their employer had created a letter similar to the attached and the employees were able to show that letter and proceed to their places of employment.
This letter is intended to allow workers to demonstrate that they work in a job category identified as an essential service, including solid waste and recycling operations. It should not be used for any other purpose or by employees that are not actively supporting these operations.
In addition, attached is a notification document for solid waste employers and others to place in their work vehicles to demonstrate they are covered by recent emergency order guidance. It cites the Department of Homeland Security’s Cybersecurity & Infrastructure Security Agency, March 19, 2020 memo that identifies workers engaged in the removal, storage, and disposal of residential and commercial solid waste and hazardous waste as essential infrastructure workers.
Please do not hesitate to contact Jesse Maxwell at email@example.com or me at firstname.lastname@example.org if you have any questions about this letter, or need assistance responding to the Coronavirus pandemic. Please stay safe and healthy.
NWRA resources are plentiful and include these:
COVID-19 WORK PRACTICES At this time CDC and OSHA are not issuing waste and recycling specific guidelines for the handling of waste and recycling materials related to COVID 19. If this changes, NWRA will alert its members. Use this industry guidance.
COVID-19 RESOURCES Resources and information provided by agencies and organizations.
We know our valued clients, partners, and associations are busy assessing the impact and the disruptions caused by the COVID-19 coronavirus. Our thoughts are with your employees and their families during this health crisis.
SCS is committed and well prepared to continue the delivery of our services.
Our business model includes 70 regional and satellite offices located near client sites throughout the United States, with additional mobile offices co-located on project sites. The model has always worked well for us because our professionals and technicians live nearby; our distributed service network means we can drive to project sites instead of flying, for example. We do use national resources as well; if a lab closes in one region or state, we have access to other resources. We are monitoring local conditions (including regulatory guidance) for COVID-19 just as we do for other regulatory programs.
We put health and safety above any other consideration.
This includes the health and safety of our employees, the client representatives with whom we work, contacts we make during our work, and the public. Our employees can work remotely with full access to our infrastructure and technologies. Our field staff continues working with our clients to keep critical infrastructure running, and our SCS Remote Monitoring and Control and SCSeTools help. In most cases, government agencies understand that the services we provide to our clients are essential.
We are helping our clients prioritize critical functions to inform decisions that might have to be made in these rapidly-evolving circumstances. We have increased the frequency of our internal communications to assure that our back-up resources quickly mobilize when needed.
We continue to monitor the COVID-19 situation and have assembled a task force at the highest level of our firm to make sure our important work continues. As circumstances change, we will provide general updates on this website and via client updates from our project and regional managers. We continue adapting to meet our responsibilities safely and thank our clients, vendors, and colleagues for their diligent work and care.
Jim Walsh, President, and CEO
SCS Customer Support: