Specs+Spaces Article - Citadel Environmental Services: Greening the Workplace

An article was published from Dunn-Edwards Specs + Spaces, recognizing Citadel not only for its work in helping companies Go Green, but also for setting a great example as to how beneficial being Green can be!

Specs+Spaces Citadel Environmental Services: Greening the Workplace

EHS&S Consultant by Day - Financial Prognosticator by Night

While I practice Environmental, Health, Safety and Sustainability (EHS&S) consulting by day, I’ve been forced to become a financial prognosticator by night. As the Principal of Citadel, a mid-sized, employee-owned EHS&S firm, I’ve always had to make forecasts about the economy, identify industry trends, and formulate corporate strategies. The basis for my decision making could be as sound as making conclusions relying on established business and trade journals or as weak as consulting with the swelling in my trick knee. Either way, it was hard for me to go wrong. 

Before the last major recession, “all boats were rising” - I could always dial in growth into the planning process, as we had grown steadily for 15 years. Conversely, for 2008-2010ish, I could forecast reductions or no growth as the entire economy was either in a tail-spin or treading water – “all boats were sinking”.

But a couple of weeks ago, I was given a challenge by a valued Citadel business consultant, Dr. Kim Huynh, to conduct a webinar to a university audience. My responsibility was to share my insights into the EHS&S industry as to its stability, potential for growth, trends, and industry drivers. My challenge was that I was presenting to a mature, international audience that likely wouldn’t merely accept “because my trick knee is never wrong” predictions, and were looking for fact-based assessments. And we all know, anyone making predictions the last couple of years were, either, fools or someone who was going to soon made a fool. But, here I was, being forced to make predictions in the transparency of fog.

I turned to three trusted sources to measure the state of the economy for the EHS&S industry: (1) our existing pipeline, (2) IBISWorld’s August 2011 Report, and (3) our insurance broker.

Unrecognized by most, the environmental industry is a good leading indicator about the strength of the economy or at least investor confidence. We represent several hundred clients in numerous industries including real estate, retail, entertainment, education, energy, manufacturing/aerospace, defense, health care, government, etc. Often, environmental firms, especially those similar to Citadel that service the entire life-cycle of real estate, are the first in on deals, working with the “smart money” before architects and engineers, and well before contractors. Therefore, my first indicator was looking at work in progress, backlog, opportunities, and the telltale billable hours metric. Having reviewed those measures, the first indicator for an economic upturn was a “go.” 

The second source was IBISWorld’s August 2011 Report for our industry. After reading about 50 pages of the report and all of the entertaining charts (zzzz), the conclusion was that we could expect 9.4 % annual growth for the next several years. The second indicator was a “go.” So far, so good. 

The third source, while ostensibly an odd source, was our insurance broker. For the past 20 years, I’ve turned to our broker as a bellwether as to the state of the economy. Similar to Citadel, his firm represents clients from a cross-section of different industries and are intimately familiar with their clients’ business operations. In the case of our broker, it doesn’t hurt that he is the West Coast President of an insurance brokerage owned by one of the nation’s top-ten largest banks. Having his insight into his customer base and access to his parent company’s economists, he reported back that almost all of his clients were adjusting their strategic plans upward or currently hiring new staff to service existing business or expected business. Our experience is similar to many of our broker’s - we’ve been hiring additional staff (announcements will be forthcoming), investing in real estate and equipment, conducting extensive staff development, and re-tooling our practices of how we work.

The conclusion for my preparation for the webinar was that the EHS&S industry was on solid footing and that a recovery was underway. Now, I recognize that there are some destabilizing factors and some looming threats to the economy such as the presidential election, national debt/spending cuts, Europe’s sovereign debt crisis, and a series of bad options for dealing with Iran, however, it’s time for the bear (at least a timid bear) to come out of hibernation. In won’t be a quick, gangbuster recovery, but it will steadily improve over time.

Now, I just have to hope that I’m not tomorrow’s fool.

Loren Witkin

Principal

BIOGRAPHY

Citadel Owner & Founder Gives 30 Minute Webinar For American City University!

Citadel Owner & Founder Mr. Loren Witkin speaks with American City University about the Environmental Consulting Services Industries. Follow the link to the 30 minute Webinar: 

https://sas.elluminate.com/p.jnlp?psid=2012-03-15.1045.M.EE8ED0C9EE74913536550A20D8664A.vcr&sid=voffice

Hazardous Waste Operations and Emergency Response ON-LINE Training

Citadel was contracted by a major motion picture studio to provide computer-based Hazardous Waste Operations and Emergency Response (HAZWOPER) training. Citadel created a unique E-Learning account for every employee, which allowed users to access the training course modules via the internet from any location at any time. All courses were self-paced with optional audio narration, and all users were granted access to an internal messaging system. The client’s account included access to the seven (7) part HAZWOPER training course that included; • Scope, Application, and Training Requirements of the HAZWOPER Standard • Toxicology, Monitoring, and Medical Surveillance • Hazard, Risk Assessment, and Identification • Respiratory Protection and Personal Protective Equipment • Confined Spaces, Handling Drums and Containers • Site Control and Decontamination • Emergency Response and Spill Prevention All E-Learning modules consisted of interactive flash media presentations, module specific exams with randomized questions, and printable completion certificates. The HAZWOPER course ended with a final exam in addition to individual exams for each of the seven (7) component modules. All courses complied with and met applicable Federal and State training requirements.

Review of California Certified Unified Program Agencies, Hazardous Materials Inventories and Emergency Response Program

Citadel Environmental Services, Inc. was contracted by a major retail company to review the requirements of the California Certified Unified Program Agencies (CUPAs) in anticipation of updating the company's Hazardous Materials Business Plan for multiple retail store locations. The California Certified Unified Program Agency (CUPA) is a local agency that has been certified by the California Environmental Protection Agency to implement six state environmental programs within the local agency's jurisdiction. The Unified Program includes the Hazardous Materials and Hazardous Wastes Inventory and Business Emergency Response Plan.

Citadel conducted hazardous materials site surveys, as well as prepared Hazardous Materials Business Plans that included compiling Hazardous Material Inventory forms, Emergency Response Plans, Hazardous Waste Generator forms, and other agency-specific reporting forms for the local CUPAs within the jurisdiction of each retail store location.

The Hazardous Materials Inventory and Business Emergency Response Plan Program regulate the use and storage of hazardous materials by business and industry. Chemical Inventory Title 42, Section 11022 of the United States Code and Chapter 6.95 of the California Health and Safety code require the reporting of hazardous materials when used or stored in certain quantities (greater than 55 gallons of liquid, 500 pounds of solids, or 200 cubic feet of compressed gases). A Chemical Inventory was generated for all retail stores that disclosed all hazardous materials and wastes stored, used, or handled above the reporting threshold on site. This disclosure information assists emergency responders in planning for and handling emergencies which involve hazardous materials. The program objective is to safeguard lives and minimize property loss.

Citadel Wins EXXONMOBIL GOLD SAFETY Award!

Citadel is proud to announce the receipt of the GOLD SAFETY AWARD, given by our client ExxonMobil for more than 10,000 man hours worked without injury in 2011.  We'd like to recognize our team: 

• Jeff Klein (Team Leader)
• Barry Smith
• Russel Ragsdale
• Oscar Jimenez
• Shawn Robbins
• Alex Bernal
• Deanna Iacono
• Gabby Sandoval

Citadel hopes to approach the 50,000 man hours mark in 2012, and wish our team the best for this year!

Thank-You, from the Citadel Family

For the past twenty minutes, I’ve sat at my keyboard looking for inspiration… Looking for that feeling, idea, thought, or topic that would inspire me to write something meaningful for our final 2011 newsletter.  I was really having a hard time connecting to what I was writing.  Would it start with the economy, the state of the industry, politics, or something esoteric and then flow into something really powerful or would I tell an anecdotal story woven with a great moral.
I just couldn’t find it until I looked at the obvious – what did I really want to say and do?  Ta dah! The whole time, I was just trying to find a way to say a sincere, “Thank You”  and recognize those important to us.  Not a half-hearted “thanks” or a barely audible “thank you” said in passing, but a genuine, looking-someone-in-the-eyes, annunciating clearly “Thank You.”  Regardless of our insecurities with the economy, the rancor of politics, or changes within the industry, the commonality is our appreciation for our clients, employee-owners, vendors, community, and the environment in which we thrive.
You all make it possible.  Every day and with every project, you give us opportunities to challenge ourselves, our technical skills, our values, and our sense of commitment.  You provide us opportunities to be successful and purposeful.  For all of those things we are truly thankful.  Have a wonderful holiday season and new year and  “Thank You,”

Loren and the entire Citadel family.      

EPA Fines California Portland Company (CPC)

California Portland Company (CPC) is the largest producer of sand, gravel and quarry rock in the Pacific Northwest. CPC owns and operates three Portland cement plants in the United States and is headquartered in Glendora, Calif.
The facility covered by the settlement is located in Kern County, Calif. The Facility includes a dry process Portland cement manufacturing facility with an annual capacity of 1.44 million tons of cement clinker, along with a nearby quarry to mine raw products such as limestone and clay for use in cement production. 
Emissions from the Mojave plant are approximately 3,200 tons of nitrogen oxides (NO_x) and 1,200 tons of sulfur dioxides (SO₂) per year.
The consent decree requires CPC to install and continuously operate BACT-level emissions controls to reduce emissions of NO_x and SO₂.

• NO Emission Limitations and Controls_x

The settlement requires the installation and continuous operation of a selective non-catalytic reduction (SNCR) unit to control NO_x emissions.  While the plant is required to conduct testing in order to set a final NO_x limit after the CD is entered, CPC is required to meet a final 30-day rolling average emissions rate of no greater than 2.5 lb of NO_x per ton of clinker produced.

• (SO) Emission Limitations and Controls₂

The settlement will require the installation and continuous operation of a lime injection system (LIS).  While the plant is required to conduct testing in order to set a final (SO₂) limit after the Decree is entered, CPC is required to meet a 30-day rolling average emission rate of no greater than 1.7 lb (SO₂) per ton of clinker produced.

• NO emissions are expected to be reduced by more than 1,200 tons per year_x
• (SO₂) emissions are expected to be reduced by more than 360 tons per year

 NO_x and (SO₂) have adverse effects on human health and the environment as discussed below:

• Nitrogen Oxides-- NO can cause or contribute to a variety of health problems and adverse environmental impacts, such as ground-level ozone, acid rain, global warming, water quality deterioration, and visual impairment.  Affected populations include children, people with lung diseases such as asthma, and exposure to these conditions can cause damage to lung tissue for people who work or exercise outside._x
• Sulfur Dioxide -- High concentrations of (SO₂) can affect breathing and may aggravate existing respiratory and cardiovascular disease.  Sensitive populations include asthmatics, individuals with bronchitis or emphysema, children, and the elderly.  (SO₂) is also a primary contributor to acid deposition, or acid rain.

CPC will pay a total penalty of $1.4 million to the United States for violations resolved in the Decree.

Toy Donation To NorthEast Mental Health Center - Citadel In Service

As part of Citadel's commitment to give back to our community, employees each donated one Toy at our Annual Holiday party on December 18th, which were then gifted to the children at Northeast Mental Health Center in South Pasadena, Californa!  They were so very excited to receive the gifts, which will be given to the families in their center on Christmas day. 

Contaminated Debris under RCRA

As with contaminated soil, debris is very different in physical form from the process wastes that EPA evaluated when establishing LDR treatment standards. The definition of debris in §268.2(g) is:

"Debris means solid material exceeding a 60 mm particle size that is intended for disposal and that is: a manufactured object; or plant or animal matter; or natural geologic material. However, the following materials are not debris: any material for which a specific treatment standard is provided in Subpart D, Part 268, namely lead-acid batteries, cadmium batteries, and radioactive lead solids; process residuals such as smelter slag and residues from the treatment of waste, wastewater, sludges, or air emission residues; and intact containers of hazardous waste that are not ruptured and that retain at least 75% of their original volume. A mixture of debris that has not been treated to the standards provided by §268.45 and other material is subject to regulation as debris if the mixture is comprised primarily of debris, by volume, based on visual inspection."
Several aspects of the debris definition warrant discussion:

1. Debris is material that is bigger in one dimension than 2.5 inches (60 mm).
2. Debris is material that is intended for disposal. When manufacturing operations are shut down, a very common material that is encountered is metallic equipment and components that might be contaminated with hazardous constituents. If this material is recycled instead of disposed, it is not "debris" subject to the LDR debris standards. In other words, recycling rather than disposing material may eliminate the need to comply with the debris standards.
3. Examples of manufactured objects that are "debris" are gloves and other personal protective equipment, solder paste wipes, pipes, pumps, valves, etc. that will be disposed (perhaps due to radioactive contamination that makes them nonrecyclable). [RO 14660]
4. An example of plant material that would be "debris" is a tree stump.
5. An example of geologic material that would be "debris" is a rock.
6. The language about intact containers addresses drums that might be dug up as part of a remediation project. If the drums contain hazardous waste and are intact, the contents of the drums must be treated to meet §268.40 standards for whatever waste codes are associated with the contained wastes. In other words, intact drums of hazardous waste are not eligible for the more lenient alternative treatment standards for debris. On the other hand, if a ruptured drum is excavated, it may be managed under the debris standards.
7. The language about material being primarily debris based on visual inspection implies that it is not necessary to run a sieve analysis to determine if a waste is mostly debris, as opposed to something else (e.g., soil). A visual assessment is all that is required.

 

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