ACS consistently provides you with the information you need to help you make sound compliance decisions.
Emissions Inventory
How do I know whether I have to prepare an emissions inventory?
Requirements for the submission of emissions inventories vary depending upon the state in which the emission units are located. Most states require submission an annual basis to report emissions that have been generated during the prior calendar year. Some states require an emissions inventory only when specifically requested. An emissions inventory is generally required for any site that has potential emissions equal to or greater than 100 tons per year of any criteria pollutant. Smaller amounts of hazardous air pollutants may trigger reporting requirements. Sites located in non-attainment areas are also generally subject to reporting requirements at lower emission rates.
Why should I use ACS to prepare my emissions inventory?
The emissions inventory is a critical piece of your compliance history and will be used to determine applicability of specific regulations. State requirements change frequently concerning reporting requirements and calculation methodology. ACS ensures that the latest requirements are reflected in the emissions inventories we prepare and we provide documentation of the methodology used, assumptions incorporated, significant year-to-year changes in reported emissions and permit limits that appear to have been exceeded.
Permits
What is the process for obtaining a permit?
While all states have similarities in permitting requirements, they all have specific forms and procedures for submitting a permit application. Each state-specific requirement must be satisfied before a permit is deemed “administratively complete”. The time frame for obtaining a permit can be as short as three months to well over a year from the time an administratively complete application is submitted to the agency. The time frame for obtaining authorization is generally shortened significantly for proposed construction projects with resulting emissions below the levels that require a permit.
Why should I use ACS to help me obtain a permit?
ACS has prepared hundreds of permit applications and possesses a comprehensive understanding of overall regulatory compliance. ACS environmental consultants ensure that the owner/operator will not be burdened with any unnecessary requirements while also ensuring that no applicable requirements are overlooked. Applications are prepared accurately and completely to eliminate delays that inevitably result when regulators are forced to request additional data or clarification. Our meticulous attention to detail in the permit application and review of the draft permit has resulted in reduced costs and excellent compliance for our clients. ACS has reduced or eliminated regulatory compliance burdens for numerous clients, often resulting in construction and compliance cost savings that are many times greater than the cost for preparing the permit application.
Risk Management Plan
Who requires a RMP (Risk Management Plan)?
The risk management program requirements apply to owners and operators of stationary sources that have more than a threshold quantity of a regulated substance contained in a process (40 CFR 68.115). A stationary source is subject to the Risk Management Program requirements only if it has more than a threshold quantity of a regulated substance in a process. The definition of process is very broad, and includes any use, storage, manufacturing, handling, on-site movement, or any combination of these activities. A stationary source is covered by the RMP rule if it has a process containing greater than the defined threshold quantity of a regulated substance at any time.
How does the RMP relate to the Process Safety Management program?
A program level 3 RMP is required for processes subject to the OSHA PSM regulation as well as for any process classified under one of ten NAICS codes. Many elements of the PSM can be incorporated into the RMP.
How can ACS help me prepare the RMP?
ACS has prepared Risk Management Programs for various industries and evaluated several of the available models. We can prepare an RMP that is clear and concise and assist with implementation and training to ensure ongoing compliance. Our environmental consulting team can prepare an RMP that is clear and concise and assist with implementation and training to ensure ongoing compliance.
Title V
What is the purpose of the Title V permit program?
The federal operating permit program codifies all of the requirements of the Clean Air Act into one enforceable document. It is through the Title V permit that provisions of the CAA will be enforced, e.g. compliance assurance monitoring, air toxins, etc. The Title V permit serves as the single source that contains all emission limitations, operating restrictions, operating requirements, and testing, record keeping and reporting requirements.
Who requires a Title V permit?
All major sources of air pollution must obtain an operating permit. Permits are also required for sources subject to new source performance standards, sources subject to national emissions standards for hazardous air pollutants and any other source in EPA-designated categories.
What is required after I get the Title V permit?
The Title V permit program was not intended to create new regulations but instead to codify existing regulations. The Title V permit program requires detailed record keeping and periodic reporting to verify continuous compliance. In addition to penalties that can be assessed for noncompliance, under Title V additional penalties can be assessed for not self-reporting any noncompliance.
How can ACS help me with the Title V program?
ACS has been directly involved with the Title V program since its inception and we have prepared hundreds of Title V permit applications. We are committed to making regulatory compliance as painless as possible for our clients and we have consistently achieved this goal.
Non-attainment permit
Who needs a Non-attainment New Source Review permit?
Proposed construction of a site or modifications to an existing major site in non-attainment areas are subject to Non-attainment New Source Review (NNSR) permitting if potential emissions of the pollutant(s) for which the site is not in attainment are above the “major” threshold definition for the non-attainment area.
Why should I use ACS to help me obtain a NNSR permit?
ACS is recognized by several state agencies and numerous clients as a leader in air compliance issues. We prepare permit applications that are technically complete and thorough, follow up with the regulators to ensure there are no delays and thoroughly review the proposed and final permit to ensure that it accurately reflects the permit application. Our environmental consulting team also maintains regular communications with agency personnel and stays abreast of regulatory developments. This results in expedited approval of permits and ensures there are no surprises in the resulting compliance requirements for our clients.
Hazardous Air Pollutants (HAP)
Are HAPs regulated differently than other air pollutants?
Section 112 of the Act defines a major source as “any stationary source or group of stationary sources located within a contiguous area and under common control that emits or has the potential to emit considering controls, in the aggregate, 10 tons per year or more of any hazardous air pollutant (HAP) or 25 tons per year or more of any combination of hazardous air pollutants…” The term “potential to emit” is defined in the section 112general provisions (40 CFR Part 63.2) as “the maximum capacity of a stationary source to emit a pollutant under its physical or operational design,” considering controls and limitations that are federally enforceable. This definition is consistent with definitions in regulations for the new source review and Title V permit programs.
Can I avoid being subject to the MACT requirements?
Section 112 of the Clean Air Act distinguishes between major sources and area sources of hazardous air pollutants. Although maximum achievable control technology (MACT) is required for all major sources of hazardous air pollutants, lesser controls or no controls may be required of area sources in a particular industry. In addition, whether a facility is a major or area source of hazardous air pollutants may affect the applicability of other CAA requirements — such as when or whether the facility is required to obtain a Title V operating permit. To avoid MACT requirements, major sources must agree to enforceable restrictions that will keep actual emissions of HAPs below 10 tons per year of any listed pollutant and 25 tons per year of any combination of listed pollutants. This may be done by restricting hours of operation, installing control equipment, or implementing process modifications that eliminate or reduce the quantity of HAPs present. An analysis of each source should be conducted to determine the consequences of compliance with the applicable NESHAP against actions that would be necessary to avoid being subject to the standard. In many cases, actions required to comply with the MACT standards will result in emissions of HAPs falling below the major source definition.
Can ACS help me with my HAPs problem?
ACS has coordinated implementation and compliance actions for MACT standards at chemical plants and other facilities and assisted other sources with compliance through reporting, permit preparation, and thorough documentation of compliance requirements to assist plant personnel. Our personnel understand regulatory requirements and the reality of field operations. This combination has resulted in ACS environmental consultants consistently satisfying our clients and reducing compliance costs.
Dispersion Modeling
What is “Dispersion Modeling”?
Air dispersion modeling is used to predict off-property concentrations resulting from emissions of air pollution. Equations and algorithms representing atmospheric processes are incorporated into various computer models, which enable the modeler to enter pertinent data, such as emission rates and distance parameters. The model calculates atmospheric concentrations of a pollutant at specific points, or receptors, near the source(s) being evaluated.
When do I need to conduct dispersion modeling?
Most state environmental agencies require some degree of modeling analysis as part of the air permit application process. It is important to determine the level of air pollution concentrations from an emissions source in order to evaluate the effect those emissions will have on the air quality in the vicinity of the source. Agency staff use modeling results to determine whether a facility is operating or will operate in compliance with state and federal standards, and whether its operations may result in negative health effects on persons living or working in the area.
Why should I have ACS assist me with air dispersion modeling?
ACS uses EPA’s most current version of Air Dispersion Models and a graphical software package to perform refined air dispersion modeling. Our approach to modeling consists of (1) collecting all needed information about the facility, such as point parameters, exact location, and emission rates, to produce the most accurate results; (2) performing preliminary modeling to determine whether refined modeling is required; (3) if necessary, performing a refined modeling analysis according to the guidelines of the state in which the facility is located; and (4) producing a finished report for the environmental agency or agencies and for the client. ACS environmental consultants have performed refined modeling in several states for various types of facilities.
If you have any questions about compliance or a regulatory question in general, call us and we can help.