Your Trusted Partner in Environmental Solutions

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) 

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.