News & Updates

CK Associates is pleased to welcome Todd Higginbotham. Todd brings more than 25 years of experience in air quality permitting and compliance, supporting complex industrial facilities across the United States.

Throughout his career, Todd has provided regulatory strategy, permitting, and compliance support for a wide range of industries, including petroleum refining, chemical and petrochemical manufacturing, natural gas processing, steel production, fertilizer manufacturing, and wood products facilities. His expertise includes New Source Review (NSR) permitting, Title V permitting, emissions inventories, regulatory applicability assessments, and air quality compliance audits.

Todd has extensive experience supporting capital projects at major industrial facilities, coordinating with engineering and operation steams, preparing environmental documentation, and managing regulatory reviews with state agencies such as the Louisiana Department of Environmental Quality(LDEQ). He has also supported clients in complex regulatory matters involving NSPS, NESHAP, and Clean Air Act investigations, including technical analyses related to enforcement actions, mediation, and settlement negotiations.

Todd earned a Bachelor of Science in Chemical Engineering from Louisiana State University and has held senior consulting roles with several national environmental consulting firms. His depth of regulatory expertise and industry knowledge strengthens CK Associates’ ability to help clients navigate challenging air quality permitting and compliance requirements.

We are excited to have Todd on board and look forward to the value he brings to our clients and our team.

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The Safe Drinking Water Act (SDWA) was passed by Congress in 1974 to protect public health by regulating the nation’s public drinking water supply. The SDWA was amended in 1986 and 1996 and requires many actions to protect drinking water and its sources. The SDWA authorizes the United States Environmental Protection Agency (US EPA) to set national health-based standards for drinking water to protect against both naturally occurring and man-made contaminants that may be found in drinking water. US EPA, states, and water system operators have responsibilities to make sure that these standards are met. In Louisiana, the Louisiana Department of Health (LDH) administers drinking water rules as codified in Louisiana Administrative Code (LAC) 51, Part XII - Water Supplies. 

Water Systems

LAC 51, Part XII defines a public water system as: a system for the provision to the public of water for potable water purposes through pipes or other constructed conveyances, if such system has at least 15 service connections or regularly serves an average of at least 25 individuals daily at least 60 days out of the year. LDH considers systems which do not meet these requirements as private water systems. LAC 51 Part XII also applies to private water systems. 

LAC 51 Part XII §309 requires that all public water systems be under the supervision and control of a duly certified operator. Certified operators must earn 8 hours of continuing education credits every two years. 

Public water systems may not construct, operate or modify the capacity, hydraulic conditions, treatment processes or the quality of finished water without a permit from the state health officer. Detailed plans and specifications for the installation for which a permit is requested shall be submitted by the Engineer of Record or the person responsible for the charge of a municipally owned public water supply or by the owner of a privately owned public water supply.

Cross-connection Control

In 2016, LDH adopted the International Plumbing Code (IPC) as amended in LAC 17, Part I, §111. LAC 17, Part I, §111 amends a requirement to color code potable and non-potable water pipes when non-potable water is present for certain industrial facilities listed in R.S. 40:4.12. The exemption requires certain industrial facilities to have a cross-connection control survey performed by a certified person meeting the requirements of American Society of Inspectors of Plumbing and Sanitary Engineers (ASSE) 5120 every five years. The exemption also requires the development of a potable water distribution identification plan (PWDIP) satisfying the statute requirements. The exemption to the color-coding requirement is only applicable to facilities with the following 1997 National America Industrial Classification System (NAICS) Standard Industrial Classification (SIC) codes:

• 22111 electric power generation.
• 3221 pulp, paper, and paperboard mills.
• 324 petroleum and coal products manufacturing.
• 325 chemical manufacturing.
• 326 plastics and rubber products manufacturing.
• 331 primary metal manufacturing.
• 211 oil and gas extraction.
• 486 pipeline transportation.
• 213111 drilling oil and gas wells.
• 213112 support activities for oil and gas operations.
  

How CK Associates Can Help 

CK Associates (CK) can provide support in evaluating, maintaining, and documenting compliance with drinking water systems. This support includes:

• Conducting cross-connection control surveys and backflow preventer inspections
• Developing/updating potable water distribution identification plans
• Evaluating drinking water quality for compliance with disinfectants/disinfection byproduct, lead and copper, and total coliform requirements
• Sampling water supply sources for per- and polyfluoroalkyl substances (PFAS) 

The United States Postal Service (USPS) has implemented updates to its postmark date system that may affect how regulatory agencies determine the official receipt date of mailed documents. While the intent of this change is to modernize mail processing, it does introduce important timing considerations for regulatory filings and compliance submittals.

At CK, we’re staying ahead of this shift so our clients can stay focused on their operations with peace of mind that their compliance needs remain in good hands.

What’s Changing

Under the updated USPS system, postmark dates may no longer consistently reflect the exact day a document is physically mailed. In some cases, postmarks may be applied later in the mail-processing cycle, which could impact deadlines where agencies rely strictly on postmark date rather than delivery confirmation.

For time-sensitive regulatory submittals, this change increases the risk that mailed documents could appear late even when they were sent on time.

How This May Affect Clients

Certain environmental and regulatory programs require documentation to be postmarked by a specific deadline. With this USPS change:

• Relying solely on traditional mail postmarks may carry added risk
• Agencies may question compliance timing if postmarks are delayed
• Proof of timely submission becomes more important than ever

How CK Is Navigating the Change

CK is proactively adjusting our internal processes to protect our clients and maintain compliance certainty. Our approach includes:

• Earlier submission planning to build in additional buffer time
• Expanded use of electronic submittals where allowed or encouraged by agencies
• Alternative delivery methods (such as tracked or certified services) when mailing is required
• Clear documentation and records to support proof of timely submission
• Client communication and coordination for deadlines that may be affected

We are also closely monitoring regulatory agency guidance as they adapt to the USPS changes and will adjust our practices as expectations evolve.

What Clients Can Expect from CK

As always, CK’s priority is compliance confidence. You can expect:

• Thoughtful planning around deadlines
• Transparent communication when mailing timelines matter
• Practical, forward-thinking solutions that reduce risk
• A steady partner who keeps up with changes so you don’t have to

If you have questions about how this change may affect a specific submittal or program, your CK project team is ready to help. We’ll walk alongside you and make sure deadlines are met no surprises, no scrambling.

Additional details regarding this change can be found in the Federal Register notice USPS Postmark Date System Updates (FR Doc. 2025-20740)

Charles Roccaforte joins CK Associates’ Woodlands office as a Senior Scientist on the Air Team. Charles brings 30 years of experience supporting complex industrial operations, achieving and maintaining compliance excellence. Charles has extensive knowledge and experience in regulatory compliance, including developing compliance programs, federal and state air permitting, and auditing, and has strong relationships with federal and state regulatory agencies. His career includes nearly two decades at the ExxonMobil Beaumont Complex, where he supported one of the largest refineries in North America.

Throughout his career, Charles has built a strong reputation for his collaborative leadership style, his ability to translate complex rules into clear, actionable guidance, and his skill in fostering positive relationships with regulatory agencies and internal stakeholders. He has developed compliance assurance systems, led major permitting initiatives and conducted audits to ensure continuous improvement.

Lisa Rosensteel joins CK Associates as a Senior Engineer in our Woodlands, TX office, expanding our Air Team expertise. Lisa brings over a decade of experience in managing and supporting environmental compliance programs for chemical manufacturing facilities across Texas and Louisiana. She has a strong background in federal and state regulatory compliance, reporting, and permitting and holds a Bachelor of Science in Chemical Engineering from Louisiana State University.

Lisa has built a career focused on building, improving, and sustaining various chemical plants’ environmental compliance programs as well as navigation and implementation of new regulations while driving sustainable operational practices. Her expertise and leadership will be instrumental in supporting our clients and expanding CK’s commitment to environmental excellence in the region.

This year’s Clean Gulf Conference in New Orleans (November 18-20) features CK Associates’ Keith Nichols. Nichols chairs a session on All Hazards/Disaster Restoration and Remediation: Transitioning from PFAS Containing Fire Fighting Foam. He also is speaking on Combining Remediation and Restoration Tasks to Enhance Ecological Functions.

Keith Nichols is a Senior Project Manager/Scientist with thirty-five years of experience conducting ecological studies for inland and coastal waters. Based on his wide range of expertise from an ecological perspective he provides habitat and wildlife assessments for clients in over 20 states. Mr. Nichols is also responsible for providing Natural Resource Damage Assessment (NRDA) technical direction for obtaining baseline and incident data and facilitating cooperative efforts between clients and State and Federal Natural Resource Trustee Agencies to reach settlement.

October’s Louisiana Section of the Air & Waste Management Association’s 2025 Annual Conference features seven speakers from CK Associates across six presentations. Their session titles include:

• HON Rule & POTUS Action – Navigating CAA Sec 112
• Tips & Tactics for HON Flare Management Plans
• IT Responses in 2025- Do’s and Don’ts
• Louisiana Air Permitting 101
• WOTUS Permitting in a Post-Sackett World
• Overview of Potable Water for Industrial Users

Our team values sharing its expertise.  Speakers include David Hawley, Claire Odenweller, Robert Berg, Karen Blakemore, Reagan Berry, Anna Bearden and Phil Kerr.

In September, CK Associates led a National Resource Damage Assessment (NRDA) team in our Baton Rouge office as part of an overall Spill Response Drill for one of our clients. This exercise brought together corporate partners with state and federal agencies dedicated to protecting our vital resources in the Gulf.

Natural Resource Damage Assessment (NRDA) is the process of evaluating how hazardous substance releases or oil discharges may have impacted natural resources. It involves collecting and analyzing data to understand the extent of the damage and then identifying the best ways to restore those resources and ensure appropriate compensation for the injuries. See What is a Natural Resource Damage Assessment? CK Associates welcomes the opportunity to partner with our clients to mitigate their risk through effective preparation.

CK Associates is proud to recognize the generosity of our colleague, Jeffery Schweitzer, and his wife Tommie, who recently donated $20,000 to the McNeese State University Foundation in support of the Schweitzer Environmental Engineering Scholarship. This contribution builds on a previous donation to the scholarship fund, which was established to assist students pursuing the newly introduced environmental engineering minor at McNeese, launching this fall.

Jeffery Schweitzer, a Senior Environmental Scientist at CK Associates, is a proud McNeese alumnus. He earned his Bachelor of Science degree in Environmental Science in 1975, followed by a Master’s degree in the same program. Prior to CK, Jeff enjoyed a long career at Citgo’s Lake Charles refinery, gaining valuable industry knowledge.  When donating this money, he requested that it be directed toward deserving local students attending McNeese from Southwest Louisiana or East Texas in an effort to keep local students local.  His commitment to supporting future environmental professionals reflects both his personal dedication to the field and CK Associates’ values.

Pictured are Dr. Srinivasan Ambatipati, Department Head of Engineering and Computer Science at McNeese, and Jeffery Schweitzer.

https://mcneesefoundation.org/schweitzers-donate-to-mcneese-foundation/

At CK, we understand that shifting business priorities and economic cycles can lead to temporary shutdowns or long-term mothballing of industrial facilities. These transitions often involve workforce reductions, leaving few—if any—environmental staff on-site. However, environmental permits and regulatory obligations typically remain active. Maintaining compliance and reducing environmental liability is essential to preserve value, enable future sales, or support repurposing efforts.

That’s where CK comes in.

Our experienced multimedia environmental team seamlessly steps in to support—or fully manage—your ongoing compliance needs. From keeping permits current, to handling routine monthly, quarterly, and annual reporting for air, water, and waste permits, CK partners with you to ensure your site remains in good standing.

For example, we’ve served as the environmental compliance arm for a shuttered Louisiana refinery, managing all reporting requirements for several years post-closure. As companies move to repurpose equipment or transition to new processes, our same team often leads the preparation of new permits—ensuring continuity, efficiency, and deep site knowledge.

With CK, you gain a flexible, scalable partner. We adjust our support as your needs evolve—another reason CK is a trusted “One Stop Shop” for environmental compliance and permitting.

As many in the industry are aware, the EPA announced last year that they were initiating focused enforcement on their Benzene NESHAP found in 40 CFR Part 61 S Subpart FF, and the companion regulation found in 40 CFR Part 60 Subpart QQQ, with a particular emphasis on ethylene production facilities, and petroleum refineries.  They have since visited a number of sites in Louisiana and Texas for multiday audits with team members from various EPA Regions and the NEIC. CK has a deep and broad bench for providing BWON assistance to our clients.

‍Our expertise ranges from the longtime BWON rule owner and corporate auditor at a large Baton Rouge Petrochemical Complex to other very experienced former site environmental professionals that set up and managed the BWON programs at their sites from New Orleans to Lake Charles.  We team these experienced Subject Matter Experts (SME’s) with younger staff who have participated in BWON projects and audits for a number of clients under their mentorship and are comfortable managing and analyzing large amounts of data, reviewing and marking up P&ID’s, and mining information out of plant data acquisition systems.

No matter what the need, CK is ready to assist at any point, whether before EPA visits, as we’ve done for virtually 100% of the ethylene crackers in Louisiana (and many in Texas), or working with counsel to develop rebuttals and defenses to EPA findings if the visit has already occurred.  CK has had a long relationship with most of these sites over the past 40+ years, in fact, we are in the process of preparing the TAB and other compliance reports for many of these sites, while training less experienced company rule owners.  We are ready to assist in any way that we can and are very comfortable working under Attorney-Client Privilege and can provide references from both site personnel and third party counsel that will attest to our capabilities and knowledge of this rule.