Air Quality

• Identification of regulated Emission Sources to be included in the Modeling Analysis.
• Determination of facility-wide emission rates based on individual Emission Sources.
• Evaluation of whether air dispersion modeling is required using Level I & II de minimis analysis.
• Preparation of relevant site and vicinity physical characteristics to be used in the air dispersion modeling analysis, such as property boundaries, fence lines, building footprints and heights, topographical features, and meteorological data.
• Determination of Emission Point release characteristics such as location, release height, release type (point, area, or volume), hour/day/month/season adjustments, temperature, flowrate, etc.
• Completion of initial screening air dispersion modeling analysis using EPA-approved model AERSCREEN.
• Completion of refined air dispersion modeling analysis using EPA-approved model AERMOD.
• Preparation of summary report containing details of Modeling Analysis input parameters and results, and comparison to applicable ambient air quality and/or toxic air pollutant standards.

Air Quality permitting is an ever-evolving field. Myriad regulations and standards lay between your facility and full air quality compliance. Rogers & Callcott is committed to navigating your facility through the maze of government regulations. Whether the result of corporate acquisition, employee departure, or other reason, questions regarding a facility’s air quality requirements need to be answered and addressed. To help our clients, we start with a thorough, 4-step air quality regulatory compliance assessment:

• Emissions Inventory – We determine the types and quantities of regulated air pollutants emitted by our facility based on physical and operational characteristics.
• Confidential Compliance Assessment – We compare existing conditions to the current permit(s) and discuss any identified shortcomings. If requested by Counsel, we can complete the assessment in accordance with South Carolina’s Environmental Audit Privilege and Voluntary Disclosure Act.
• Regulatory Negotiation – If non-compliance is discovered, we will work with facility management to develop a solution that will create minimal financial and corporate liability on the road to total compliance.
• Permit Application, Renewal, and Modification – As necessary, we will prepare the appropriate permit applications, air dispersion modeling, and renewal requests. In cases where the assessment reveals the removal of previously permitted equipment or emissions below threshold values, we will prepare the necessary documentation to modify the facility’s permit. Typically, the result of such modifications will be to reduce a facility’s regulatory burden.

When planning an addition to your facility, an Air Quality construction permit may or may not be required. The typical approach we follow to determine air construction permitting requirements includes:

• Identification of whether planned processes and/or equipment proposed for installation may have the potential to emit regulated air pollutants.
• Calculation of estimated potential air pollutant emissions from individual pieces of equipment. Evaluation of whether any process bottlenecks affect maximum potential to emit values.
• Estimation of facility-wide emissions and comparison to regulatory thresholds.
• Identification of any applicable Federal (NSPS, NESHAP, etc.) and/or State regulations based on physical, material, and/or operational characteristics.
• Assessment of ambient air quality and toxic air pollutant standards compliance via air dispersion modeling.
• Preparation of appropriate permit application documentation for submission to South Carolina Department of Health and Environmental Control’s Bureau of Air Quality (SCDHEC-BAQ) or equivalent regulatory/permitting agency.

Once construction or a new addition is complete, a facility’s potential to emit may require operation as a Major Source under a Title V Air Operating Permit.  If a facility has agreed to federally enforceable conditions to limit emissions below Major Source thresholds, then a facility may operate under a Conditional Major Air Operating Permit. Permit applications for both permits require facilities to submit a substantial amount of information to regulatory agencies related to physical characteristics, operational details, raw materials, and final products in a particular format using specific forms.

In addition, SCDHEC requires facilities to determine applicability of hundreds of federal and state air quality regulations on an individual, line-by-line basis.  Having prepared over 50 such major source and conditional major operating permit applications for other facilities, we can leverage our prior experience to expertly prepare your application in the manner and format desired by regulatory agencies.