Agency interaction / research concerning rule implementation, permitting and enforcement policies. Agency meeting support including meeting strategy, agendas and logistics, and advocating on behalf of client. Negotiation of draft and final permit conditions. Stakeholder group representation.
All aspects of state and federal new source review air permit applications for new and modified facilities including emissions calculations, control technology evaluations, regulatory applicability analyses, dispersion modeling, PSD / NNSR netting calculations, agency interaction, application preparation, pre-application meetings, post-application support.
Expert witness support for contested air permit hearings. Areas of expertise include emissions calculations, air pollution control technology, air dispersion modeling, ambient air monitoring, regulatory requirements and compliance, permit conditions, agency air pollution control policy.
Air Dispersion Modeling
All aspects of refined modeling demonstrations for state and federal air permit applications including modeling protocols, agency pre-modeling meetings, model emissions inventory preparation, model execution, analysis of alternate plant design on predicted off-site impacts, modeling reports, analyses demonstrating compliance with NAAQS, PSD increments, and state air quality standards and effects screening levels (ESLs).
Compliance/Due Diligence Audits
Regulatory support to evaluate compliance with air quality requirements for current and potential future assets. Support includes review of equipment, permitting, emissions, and monitoring, record keeping and reporting records; rule applicability determinations; rule compliance determinations; audit reports; economic analyses / cost estimation for remedial equipment upgrades and permitting.
Support for ongoing compliance with permit conditions and state / federal air quality regulations. Services include initial notifications, compliance plans, startup, shutdown, malfunction (SSM) plans, and periodic reports pursuant to federal NSPS / MACT requirements and state VOC / NOx control requirements; Title V deviation reporting and compliance certifications; emissions tracking support; air permit compliance tracking and reporting; cap and trade annual compliance reports.
Comprehensive emissions source identification and emission rate quantification support. Services include site surveys / initial emission inventory preparation; annual emission inventory updates; inventory audits; Potential to Emit (PTE) inventories for establishing the applicability of MACT, Title V and other regulatory programs; inventories in support of NOx SIP, HRVOC and other compound-specific programs.
Non-testifying technical support to attorneys in response to and in anticipation of permit hearings, enforcement actions, toxic tort cases and rule development matters. Support includes technical assistance for identifying strengths and weaknesses in opponent’s case; independent technical review of client permit documents prior to hearing; review of historical permitting, operational and capital authorization records pursuant to CAA Section 114 information requests and enforcement matters.
Title V Permitting
Potential to emit (PTE) inventories for determination of Major Source status. Regulatory analyses to determine applicable air quality requirements and associated monitoring, record keeping and reporting. Preparation of initial Title V applications, permit revisions and permit renewals. Agency interaction including negotiation of draft and final permit conditions. Periodic compliance certifications and deviation reporting. Synthetic Minor certifications to render Title V not applicable to qualifying sites.
Forward-looking analyses for meeting corporate permitting goals for new / increased production and timely cost-effective compliance with future regulatory requirements. Services include regulatory applicability analyses; identification of preferred compliance options; rule compliance action plan / timelines; rule tracking / technical comment support; agency interactions and stakeholder representation; benchmarking analyses; cap and trade strategies; air permitting / rule compliance strategy documents for presentation to corporate management.
Control Technology Analyses
Air pollution control equipment evaluations pursuant to state and federal air quality requirements. Services include Best Available Control Technology (BACT) and Lowest Achievable Control Rate (LAER) analyses for state and federal air permits; comparative technical and economic analyses of alternate emission control options; benchmarking analyses to establish industry-specific best management practice (BMP) emission controls; evaluation / negotiation of appropriate control measures pursuant to agency enforcement actions; fugitive dust control plans; evaluation of future MACT / RACT / NSPS emission control requirements on existing operations.
Ambient Air Monitoring Studies
PSD pre-construction monitoring plans; emissions data / monitoring data correlation studies; background monitor data evaluations in support of air dispersion modeling demonstrations; fence line monitoring studies in support of permit / agreed order requirements.