The Clean Air Act (CAA or Act) provides a comprehensive set of regulations to monitor criteria and toxic air pollutants, and it requires major sources of air pollution to obtain detailed operating permits and to conduct various compliance activities. SCS Engineers helps industrial, commercial, and institutional clients comply with the CAA. We determine how the Act affects your operations, and we develop practical strategies to meet the requirements. Our extensive experience provides us with proven, industry-specific approaches to measuring emissions and maintaining compliance; and our strong relationships with agencies provides the expertise required to obtain and maintain the appropriate permits.
Our air emissions and permitting services include:
Air Quality Assessments
SCS Engineers has a staff of highly trained professionals who use state-of-the-art proprietary and regulatory-developed methodologies to measure and monitor air quality and solve issues that may arise. We offer advanced air quality field testing services, including air quality and general environmental compliance auditing, emissions inventories, air toxic risk assessments, emission reduction credit/greenhouse gas credit services, tracer sciences, ambient air monitoring, permitting and compliance, air pollution control equipment evaluation and design, air dispersion modeling and risk assessment for air toxins, indoor air quality surveys, quality assurance/quality control on emissions source testing and sampling, analytical services and more.
Emissions Inventories
SCS Engineers prepares air emissions inventories for facilities that must document their actual or potential emissions of regulated pollutants such as volatile organic compounds (VOCs), oxides of nitrogen (NOx), oxides of sulfur (SOx), carbon monoxide (CO), particulate matter (PM), GHG, and air toxins. Our experienced engineers utilize a variety of emission quantification techniques such as continuous emission monitors, source testing results, mass balance, emission factors, and empirical equations to arrive at the most accurate inventory possible within budgetary constraints.
Air Toxin Risk Assessments
SCS prepares Risk Assessments according to the requirements of applicable regulations. Risk Assessments are based on emission inventories corresponding to actual or proposed operations and typically consist of four steps: hazard identification, hazard assessment, exposure assessment, and risk characterization. Dispersion models are used in conjunction with risk-based algorithms to estimate cancer impacts, acute health effects, and chronic health effects associated with each emission profile. Impacts are evaluated for residential and worker populations, as well as for sensitive receptors such as schools, hospitals, and day care centers. Based upon our professional analysis, a systematic mitigation plan can be implemented to reduce toxic air sources in compliance with mandated risk reduction requirements. In addition, once risk sources have been identified, SCS Engineers can recommend cost-effective ways to reduce overall risk by implementing strategic changes to facility operations (e.g., changing coating materials, adding emission control devices, etc.).
Emission Reduction Credit/Greenhouse Gas Credit Services
SCS has been involved with many Emission Reduction Credit (ERC) projects for landfills and industrial facilities, including traditional ERC projects associated with criteria air pollutant offsets required for NSR compliance, as well as GHG credits earned by landfills through methane control or other processes that create GHG reductions at industrial plants.
We have conducted numerous GHG reduction credit assessments, provided third-party due diligence for assessments for GHG credits, and filed applications on behalf of our clients with various registries and agencies for mandatory reporting and voluntary registration of GHG credits. SCS Engineers is currently providing GHG consulting support services to the two largest waste collection companies in the U.S. – Waste Management, Inc. and Republic Services, Inc. – for all of their landfills nationally.
Emissions Source Testing and Sampling/Analytical Services
SCS Engineers provides quality assurance/quality control (QA/QC) oversight for stack (point source) emissions testing. Actual stack testing is performed by a specialty subcontractor, and we work with subcontractors who meet rigorous standards, including proximity to the source, knowledge of the source, cost consciousness, proper certification, and impeccable references.
We can complete other forms of air sampling and analysis in-house, such as ambient air monitoring, sampling for VOCs and air toxics, sampling for airborne asbestos fibers, lead and other metals and dust, and IAQ surveys for various other pollutants.
Air Permitting
SCS Engineers is highly experienced with the intricacies of air permitting. Planning new facilities or modifying existing facilities and operations can sometimes become quite complex. SCS’s team is comprised of air quality experts who understand the intent of regulatory requirements. We prepare complete, accurate permit applications that are essential to obtaining successful air permits, saving you time, money, and aggravation.
Air permitting encompasses PSD/NSR permits and Title V operating permits as well as state and local permits. Requirements associated with those permitting programs may involve control technology evaluations, ambient air dispersion modeling analysis, offsets, and emissions trading. A thorough understanding of air regulations at both the Federal and state levels and interpretation of rules established through precedent are keys to a successful permitting experience. Our up-to-date knowledge allows us to help clients avoid unnecessary permitting activity for projects with limited environmental impact.
SCS Engineers can help expedite the approval process and avoid construction delays through obtainment of pre-construction waivers where appropriate. Our staff is forward-thinking in helping you make decisions that will determine whether your operation will be required to undergo PSD review or non-attainment NSR permitting, or if the application of netting, offsets, or additional control technology could result in a minor source permit. The location of a facility and the pollutants it emits are deciding factors in terms of air pollution control technology requirements. SCS stays well-informed about developments in air pollution control technology requirements in order to serve you better. Our expertise extends through the following technologies:
Landfill Air Emissions and Permitting
Air quality at landfills is a specialized area of expertise for SCS Engineers. We have performed NSPS and EG projects at hundreds of landfills, and we have excellent working relationships with the regulatory community, including the EPA and state/local air districts, as well as with site owners in the solid waste industry. We have a thorough understanding of air regulations that apply to landfills, and with our reputation in the industry, we are able to work with state and local agencies in their interpretation.
We take a practical approach to finding air quality solutions. Our engineers recommend technology that is appropriate to your project, from simple, passive approaches to complex, automated systems.
SCS Engineers can help you minimize the costs of regulatory permitting, reporting, and compliance tasks required by air, soil, water, chemical, and risk management regulations. Title V of the 1990 Clean Air Act Amendments requires facilities to certify compliance with applicable monitoring, record keeping, and reporting (MRR) requirements. Continuously showing compliance with numerous Federal, state, and local regulations can be time consuming. SCS’s engineers are experts at developing streamlined, cost-effective MRR strategies tailored to our clients’ specific needs. We can develop customized database management systems to process data and prepare regulatory reports efficiently. Databases can be used to maintain permit information, provide automated reminders regarding compliance responsibilities, generate periodic reports, graphically display information, and provide comprehensive audit trails, master lists, and summary logs. SCS Engineers has developed a secure, user-friendly system of hardware, software, and wireless technology, called SCSeToolsTM, to identify, collect, track, and report in real-time the air quality data at landfills to aid in compliance with environmental regulations.
Title V Permitting Services
The Title V operating permit is the single most important air quality permit for an industrial plant or landfill. Title V permits are umbrella permits that combine all air quality requirements, permits, and compliance elements into one permit. It essentially increases the visibility and liability of the facility in the eyes of the regulator and the public.
SCS Engineers is among the nation’s leading practitioners of Title V compliance services. Because of our expertise in understanding, interpreting, and complying with Title V requirements at the state and local levels, SCS has been awarded Title V permitting projects for hundreds of industrial facilities and landfills throughout the U.S.
SCS’s first step for compliance with the Title V Operating Permit Program is to determine if a Title V Permit is even required. In many instances, a “Synthetic Minor” Permit is a viable option (for small to mid-size industrial operations). If a Synthetic Minor Permit is determined to be appropriate, SCS can perform all of the services related to the preparation of this permit application. If a Title V Permit is necessary, SCS provides turnkey pre- and post-permit application services, including:
Our involvement in the Solid Waste Association of North America (SWANA), the National Waste & Recycling Association (NWRA), and the Waste Industry Air Coalition (WIAC) allows us to be at the cutting edge of changes in landfill regulation. It also enables us to provide regulatory advocacy on behalf of our clients so that new regulations and interpretations are more fair and reasonable.
State and Local Permitting Services
Our state and local permitting services include permitting applicability reviews for facility expansions and new construction, and preparation and submittal of permit applications. These projects typically involve emissions calculations, source testing, air modeling, application preparation, fee calculation, and permit negotiations.
SCS has extensive experience completing applications for authority-to-construct/permits-to-construct/permits-to-operate for submittal to local air pollution control agencies in California and other states across the country. We have worked in all 50 states and various U.S. territories, and we have particular strength supporting clients on the east and west coasts. For example, SCS has an excellent working relationship with all of the local Air Pollution Control Districts (APQDs) and Air Quality Management Districts (AQMDs) in California.
Permit Appeals/Variances
Air quality permits-to-construct and permits-to-operate include conditions that must be satisfied for a facility to remain in compliance. However, situations can arise where a facility disagrees with a permit condition and must file a formal appeal. Sometimes a facility simply cannot comply with a permit condition or a regulatory requirement. In these cases, a facility must apply for a formal variance. SCS’s engineers can prepare appeals and variances to address each compliance situation. It is important to note that, under Title V, non-compliance can lead to civil lawsuits and Federal enforcement actions. Therefore, facilities need to utilize every protection mechanism available in order to minimize/prevent future liabilities. Our engineers can implement non-compliance response strategies based on any situation.
