Emission Inventories
A comprehensive emission inventory is the basis for correct and effective permitting. SEC works hard to understand the manufacturing processes at your facility and their emissions in order to create inventories that correctly reflect emissions. We also use information already collected by the facility as inputs to the emission inventory when possible, to minimize recordkeeping burden.
Construction and Operating Permits
We have over 25 years of extensive experience obtaining permits for our clients to install and then operate equipment. SEC understands both the flexibility required by manufacturing and the environmental regulations that apply. With this knowledge, SEC seeks to develop advantageous strategies for compliance and permit conditions that allow those strategies.
Title V Operating Permits
SEC has helped clients retain or renew over 100 Title V operating permits. We understand the additional requirements and liabilities associated with these federal permits and seek to help our clients manage these issues effectively.
Prevention of Significant Deterioration (PSD) Permitting
PSD permitting is the most complex type of permitting required for new sources and modifications to sources at facilities that meet PSD thresholds in areas that attain National Ambient Air Quality Standards (NAAQS). It is a full scientific study of the effect of emissions on the ambient air quality in the vicinity of the source, including BACT requirements for control, air dispersion modeling to predict impacts, and possibly ambient air monitoring to establish baseline or post project concentrations. SEC has over 20 years’ experience in obtaining PSD permits for clients.
Non-Attainment New Source Review Permitting
With lower and lower NAAQS, more and more facilities find themselves in non-attainment areas. Installations or modifications that result in significant emissions in a non-attainment area can add substantial burdens to the permit requirements, including emission controls that meet Lowest Achievable Emission Rate (LAER) and the purchase of emission offsets. In actual practice, SEC has helped clients reduce emissions to avoid significant emissions increases under these circumstances. However, we have a circumspect understanding of these regulations and can help clients devise the best strategy for a non-attainment new source review permit, if emissions cannot be reduced.
New Source Performance and MACT Standards
These families of federal rules apply to source categories. However, the definition of the source categories is often broad and potentially confusing. SEC has helped numerous clients identify how these rules affect them or do not affect them. We have helped clients with numerous NSPS and more than 20 MACT standards. We have directly defended clients’ decisions on these rules with EPA. This broad experience gives us an understanding of the underlying basis for these rules and how EPA interprets their language. Our experience in this area can avoid costly penalties and unwanted scrutiny.
Reporting
Many state and federal rules or permits contain reporting requirements on an ongoing basis. For example, a Title V operating permit requires semi-annual reports and annual certification of compliance. SEC has helped clients prepare these reports since the inception of the Title V program and understands what information is required from regulators. We believe in providing required information and nothing more. In our experience, this approach results in the least amount of regulatory attention to the facility.
Stack Testing
When a facility performs a stack test to obtain important data or to satisfy a regulatory requirement, it is essentially conducting an expensive, detailed laboratory experiment in the field. Preparation for a stack test and proper conduct of that test is vital to produce useful and repeatable information. SEC staff have performed stack tests and understand the equations used to obtain results. We know which inputs are most important. SEC can help make sure a facility gets the correct information the first time, without repeated efforts. In many cases, a regulator will be on-site to observe the testing. We can help escort the regulator and answer his questions, making sure he understands and agrees with the facility’s choice of testing methods.