NSPS/NESHAP/NSR and ERC Air Emission Compliance

NSPS, NESHAP, NSR, and ERC are key U.S. Clean Air Act (CAA) components for industrial emissions: NSPS (New Source Performance Standards) set tech-based limits for new/modified sources; NESHAPs (National Emission Standards for Hazardous Air Pollutants) control specific toxic pollutants (HAPs); NSR (New Source Review) is the permitting process for criteria pollutants in areas with bad air quality, requiring permits for new/modified major sources; and ERC (Emission Reduction Credits) are tradable credits generated by over-controlling pollution, used for compliance in NSR programs, though ERCs are distinct from the Employee Retention Credit (ERC) in tax law, focusing here on air regulation. Compliance involves monitoring, testing, reporting, and, at times, complex permit applications or offsets. SCS Engineers offers comprehensive air emission compliance services that meet these standards and emerging state and local standards.

New Source Performance Standards (NSPS) and National Emission Standards for Hazardous Air Pollutants (NESHAP) Compliance
SCS Engineers has a strong relationship with the EPA. SCS has actively worked with the EPA on NSPS/NESHAP rules since 1989. SCS provides technical comments, supporting documentation, and assists in negotiations on the rule as part of our regulatory advocacy services.

SCS air quality experts have continued to make technical presentations on NSPS and NESHAP rules and new monitoring technologies at national conferences and workshops since 1991. These same experts provide clients with NSPS/NESHAP compliance training and educational webinars on a range of topics.

SCS applies our extensive experience with NSPS and NESHAP to a wide range of industrial clients and sources, including but not limited to:
Reciprocating internal combustion engines (RICE)

  • Aerospace facilities
  • Painting and coating operations
  • Gas turbines
  • Chemical plants
  • Asphalt shingle manufacturing
  • Solid waste incinerators
  • Industrial and commercial boilers
  • Fiberglass boat manufacturing
  • Chromium plating
  • Oil and gas operations
  • Petroleum refining
  • Steel industry
  • Municipal solid waste landfills
  • General manufacturing

Emissions Source Testing Management
SCS provides project management oversight for stack emissions testing. These services include tracking compliance deadlines, bid procurement, developing protocols, overseeing source test contractors, reviewing field and lab data, preparing/reviewing source test reports, working with the regulatory agencies, and comparing source test results to permit limits.

Gas and Air Sampling/Analysis 
SCS provides gas and air sampling for airborne contaminants, including volatile organic compounds (VOCs) and air toxics; airborne asbestos fibers; lead
and other metals; particulates; and other pollutants. This includes sampling directly at the source, at the fenceline, in ambient air, and for indoor air quality
(IAQ) surveys.

Air and Meteorological Monitoring
SCS specializes in the design and construction of ambient air and meteorological monitoring stations. Our experts possess nearly 100 years of experience in
all aspects of air monitoring, including program design, custom equipment design and fabrication, installation, O&M, calibration, quality assurance/quality control
(QA/QC), and auditing.

Emission Inventories
SCS prepares air emissions inventories for facilities that must document and report their actual or potential emissions of regulated pollutants, including VOCs, oxides of nitrogen (NOx), oxides of sulfur (SOx), carbon monoxide (CO), particulate matter (PM), GHGs, and air toxics. Inventories may include process descriptions and process flow diagrams to illustrate how the various emitting devices and processes emit into the atmosphere.

Our engineers and scientists use various emission quantification techniques, including continuous emission monitors, source testing results, mass balance, emission factors, regulatory guidance or models, and empirical equations, to produce the most accurate inventory possible within budgetary constraints.

Emission Reduction Credit (ERC) Assessment
SCS has extensive experience with emission reduction credit (ERC) projects for industrial facilities. Our experience includes traditional ERC projects that meet the criteria for air pollutant offsets required for New Source Review (NSR) compliance, including offset determinations, assistance in securing ERCs, preparing applications, assisting our clients in creating bankable ERCs, and marketing ERCs for our clients.

Air Monitoring Site Construction and Equipment Integration
In addition, SCS provides construction monitoring (air, noise, and vibration) in compliance with air permit requirements. SCS has in-house experts who can assist with permit requirements that involve monitoring and documenting environmental conditions—such as air quality, noise levels, and vibration impacts — during construction activities or facility operations to ensure compliance with regulatory limits and permit conditions.

–Air Monitoring: Monitors dust, particulate matter (PM10 or PM2.5), and emissions from construction equipment or site activities. The monitor data is
utilized for:

  • Dust control measures (e.g., water spray, covering piles).
  • Real-time monitoring at site boundaries.
  • Compliance with ambient air quality standards or project-specific limits.

–Vibration Monitoring: Detects and records ground vibrations caused by heavy equipment, pile driving, or blasting. The purpose of this is to conduct:

  • Pre-construction baseline surveys of nearby structures.
  • Continuous or event-based monitoring during high-impact activities.
  • Notification procedures if vibration exceeds thresholds.

–Noise Monitoring: Measures sound levels to ensure the project stays within legal or permit-mandated limits. The purpose:

  • To determine if there is a need to use noise barriers or mufflers on equipment.
  • Monitoring noise levels during specific hours (e.g., daytime only).
  • Comparing measured noise levels to local ordinances or project thresholds.
  • Construction equipment noise certification.

 

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SCS Engineers
3900 Kilroy Airport Way Suite 300
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FAX: 1 (562) 427-0805

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