SCS Engineers is pleased to welcome John Tsun as its National Industrial Clean Air Act (CAA) Practice Leader. In his role, John will focus on increasing SCS’s services to both public and private sectors related to evolving regulatory policies stemming from the Clean Air Act (CAA). John will be based out of SCS’s Suffern, NY office, serving clients along the eastern seaboard and nationwide.
Mr. Tsun brings over three decades of extensive experience and qualifications in environmental engineering, air quality services, and regulatory compliance. His background includes managing air permitting and compliance projects for sectors including, but not limited to, petroleum, pharmaceutical, chemical, and power-generation facilities and governmental agencies. His specialization is in air-quality-related solutions that include regulatory compliance audits, emissions inventories, emissions control selections, permitting strategies, ambient air-quality monitoring, air dispersion and consequence modeling, soil vapor dispersion modeling, vapor intrusion barrier installation, vapor intrusion sampling, vibration monitoring, bi-axial tilt monitoring, and noise monitoring.
Mr. Tsun is knowledgeable in regulatory applicability, such as New Source Review and Prevention of Significant Deterioration, preparing air permit applications such as Title V computer simulation modeling, and compliance reporting. For our clients, Mr. Tsun’s experience translates into streamlined permits and compliance obligations that are practical while controlling emissions appropriately. These comprehensive attributes are particularly important to SCS Engineers with in-house resources to navigate the permitting process, secure the necessary approvals, and offer solutions that save time and money.
For many industries, CAA is critical because the evolution of regulations impacts capital expenditures, especially those with older facilities, which may be required to install pollution control technologies or upgrade equipment to meet current emission standards. Consequently, implementing and maintaining pollution controls increases operating costs if the environmental solutions are not identified and planned sustainably.
Air permitting is often the critical path element in a construction schedule for new facilities and must be completed before construction can commence. Guiding clients through properly identifying emission sources and inventories, selecting proper control technologies, and efficient modeling will minimize timelines that are important for construction timelines when “speed-to-market” is crucial.
“Our clients face ever-increasing challenges and scrutiny in complying with various State and Federal air and other environmental regulations. John has decades of proven experience helping clients successfully navigate these challenges. We are delighted to have him join our team and expand the CAA services we offer our clients,” SCS Engineers Senior Vice President Michael Miller says.
Clean Air Act Resources:
The proposed AERR rule would require nearly 130,000 facilities to report air toxics emissions directly to EPA. It would also give states the option to collect the air toxics data from industry (rather than states) and report it to EPA, provided the Agency approves their program. This proposed action would allow for EPA to annually collect (starting in 2027) hazardous air pollutant (HAP) emissions data for point sources in addition to continuing the criteria air pollutant and precursor (CAP) collection in place under the existing AERR.
Here are some key things to know about the proposed rule from the EPA website:
1. It would require air toxics (hazardous air pollutant) emissions reporting. While most states voluntarily report air toxics emissions data to EPA now, reporting is not consistent nationwide. The proposal would require many industrial facilities to report air toxics emissions data and offers states the option to report emissions on behalf of the industry sources in their states.
2. It would mean that more facilities must report emissions every year by using the same emissions thresholds every year to determine whether a facility’s detailed emissions information must be reported.
3. It would fill reporting gaps for some portions of Indian country and federal waters. The AERR proposal would require industry to report emissions for certain facilities that operate in those areas and that currently are not reported.
4. It includes provisions to limit the burden on small businesses. The proposal includes flexibilities such as allowing certain small businesses to report a facility’s total air toxics emissions instead of detailed data and exempting many collision repair shops from air toxics reporting requirements.
5. It would provide EPA information that would help the Agency improve its estimates of emissions from prescribed fires. EPA is committed to helping communities and our federal, state, local, and tribal partners manage the health impacts of smoke from wildland fires, including prescribed fires. Prescribed fire is a land management tool that can reduce the likelihood of catastrophic wildfires by reducing the buildup of unwanted fuels.
Additional Resources:
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