Environmental Risk Management
simplifying Risk Management
 Airborne Particulates |
|---|
 Air Pollution |
 EMS System Compliance |
AIR EMISSIONS RECORDKEEPING & REPORTING
Emissions inventories are integral to determining regulatory applicability, obtaining air permits, performing air quality impact analyses, and conducting compliance assessments. In addition, regulatory agencies require that all Title V sources and most other emission sources report actual emissions for purposes of fee assessments. Riebdon has conducted emissions inventories for numerous of facilities, some with more than 100's of individual emission points, including fugitive, mobile, point, area, and line sources. We utilize many resources to determine the most appropriate emission factor for each unit, including information developed by EPA, industry organizations, and equipment manufacturers. We also develop custom emissions tracking and reporting tools that are consistent with the complexity of the site and the budget of the client.
Section 313 of the Emergency Planning and Community Right-to-Know Act (EPCRA, or Title III of the Superfund Amendments and Reauthorization Act of 1986) requires submission of EPA Form R, the Toxic Chemical Release Inventory (TRI) reporting form. Riebdon assists with TRI reporting by assembling the required information and gathering the appropriate historical data. In addition to the TRI reports, Riebdon also assists clients with Tier 2 reporting and emergency release notifications required under EPCRA.
ENVIRONMENTAL RISK MANAGEMENT
Riebdon helps organizations/ facilities comply with applicable regulations and minimize the risks to the community and the environment associated with industrial operations. We are particularly adept at employing various models to predict the impact of accidental release scenarios as is required under EPA’s Section 112(r) Risk Management Program and to assess the residual risk that remains following compliance with the Section 112 National Emissions Standards for Hazardous Air Pollutants (NESHAPs).
Risk Management Planning
The Risk Management Program (RMP) developed under Section 112(r) of the 1990 Clean Air Act Amendments regulates the storage and/or processing of toxic and flammable substances. It requires affected facilities to develop and submit risk management plans that include a hazard assessment, prevention program, and emergency response program. The RMP is based on a three-tiered (program) approach that is designed to link the degree of risk associated with the facility to the required analysis and planning.
The first step of the RMP planning process is to determine if any of the listed chemicals are used at a facility in quantities that exceed the regulatory threshold. If so, Riebdon Group can help you evaluate options for modifying your processes in order to opt out of the program or step down to a less rigorous level. Once the appropriate program level is determined for each affected process, we can you develop a comprehensive Risk Management Plan and communicate about potential hazards with stakeholder groups.
In June 2004, or five years after their original submittal date, approximately 6,000 facilities that have submitted RMP plans will be required to update their original plans with information about significant process changes, updated impact analyses taking into account the 2000 census, and other data. Riebdon Group can assist in preparing these plan updates regardless of whether we developed your initial plan.
Hazard Identification and Modeling
Riebdon has performed numerous health effects impact studies for actual and potential releases of hazardous air pollutants. These studies have included emissions estimations, acute toxicity evaluations for comparison to threshold limit value-based concentration limits, cancer risk assessment modeling using the GEMS ® database, and ambient monitoring studies. Our company has considerable experience in modeling emissions from accidental releases of liquid spills and spills of liquefied gases using dense gas and EPA-approved puff models. Riebdon also has senior staff as well a partnerships which are skilled at preparing analyses for use by industry in class-action litigation and providing expert testimony on the results.
Services to Streamline Air Permitting.......Regulatory applicability analyses.......Permit strategy development.......Emissions quantification.......Air dispersion analyses........Permit application development.......Compliance certification assistance..........Control technology evaluations...........Emissions trading assistance
AIR QUALITY PERMITTING
Whether constructing a new industrial facility, expanding an existing facility, or modifying operations, owners and operators may be subject to air quality permitting requirements. Industrial sources must be designed, constructed, and operated to comply with all applicable air quality regulations. Air quality regulations exist within a range of permitting programs, including state and local codes, and federal programs such as New Source Review and the Title V operating permit program. Each permitting program has associated technical requirements such as emissions quantification, control technology evaluations, air quality analyses (including regulatory dispersion modeling), ambient air quality and meteorological monitoring, and compliance assurance.
Riebdon can assist with all phases of the air permitting process. Our experience translates into accurate, timely, permit applications that are developed for maximum flexibility, and expert negotiations with regulatory agencies that streamline the process.
New Source Review
The federal New Source Review (NSR) program requires that new and modified major sources undergo rigorous air quality analyses and receive a permit prior to beginning construction on any physical changes or changes in the method of operation. The analyses must demonstrate the application of appropriate pollution control technology and maintenance of air quality standards. NSR is a constantly evolving program, at both the state and federal levels. To determine NSR applicability, Riebdon identifies and characterizes emissions from the equipment that comprise the regulated source. Using this information, along with U.S. EPA attainment designations, Riebdon performs a thorough regulatory review to determine applicability and requirements of Nonattainment New Source Review (NNSR), Prevention of Significant Deterioration (PSD) regulations, and state construction permitting requirements. Riebdon then works with our clients to develop a permitting strategy that will enable the project to proceed in a timely manner, while optimizing operational flexibility and minimizing costs.
Nonattainment NSR (NNSR) Requirements
New or modified major sources in areas designated as nonattainment with National Ambient Air Quality Standards (NAAQS) may be subject to NNSR. If potential emissions from a modification exceed threshold quantities and the facility is a major source of emissions, QEHS3s will conduct an emissions netting analysis. Emissions netting considers previous emissions changes (within a defined period) at an existing major source to determine if the proposed modification can avoid classification as a major modification. If NNSR is triggered, then the facility will be required to install Lowest Achievable Emission Rate (LAER) technology. LAER is defined as the most stringent emission limitation contained in any State Implementation Plan (SIP) or the most stringent limitation achieved in practice, whichever is lower. Under certain limited circumstances, however, the Best Available Control Technology (BACT), which is less stringent, may meet the requirements for LAER.
Other NNSR requirements include locating and purchasing emissions offsets from other permitted sources that have certified emissions reduction credits, as well as demonstrating that the project cannot reasonably be completed in another area of the country. In addition to assisting with permitting requirements, Riebdon Group can also assists clients with identifying and negotiating the purchase of offsets.
Prevention of Significant Deterioration (PSD)
New or modified major sources located in areas designated as attainment for NAAQS are subject to PSD review if net emissions exceed certain threshold quantities. Like NNSR, PSD regulations allow major sources to net out of PSD review. PSD review involves extensive air dispersion modeling that addresses issues such as complex terrain, direction-specific building downwash, and visibility impairment and regional haze impacts in Class I areas.
Obtaining a PSD permit in a timely, cost-efficient manner requires a thorough understanding of the entire PSD program. Riebdon Group reviews each project for PSD applicability and consults with our clients to develop viable options for avoiding PSD review. If PSD review cannot be avoided, our extensive experience with the PSD program helps save our clients thousands of dollars in permitting costs and opportunity costs due to delays in the start of construction for new or modified facilities.
Operating Permits
Title V of the 1990 Clean Air Act Amendments required states to develop a federally enforceable operating permit program for significant sources of air emissions, as defined by certain annual threshold levels. Subject sources are required to submit permit renewal applications once every five years to update regulatory applicability and incorporate changes at the facility. In addition to renewal applications, facilities may be required to submit Title V permit modification applications if they undertake new construction, make changes in source operations, or become subject to new or existing regulations (e.g., NESHAP).
The Title V program shifted the burden of demonstrating compliance from the regulatory agency to the facility. Compliance demonstration and certification may be a significant undertaking depending on company processes, regulatory requirements, and the efficiency of recordkeeping and reporting methodologies. Riebdon assist's clients in developing Title V permit applications that increase operational flexibility while reducing monitoring, recordkeeping, and reporting requirements. Our experience in preparing permit modification applications across the country allows Riebdon Group to bring unique state specific insight to each project and develop the most beneficial strategies based on client needs.
Call us today to learn how Riebdon can assist with your air permitting requirements.
Let US Help
If there's any way we can help, please let us know.
407.494.5191
> Submit an Inquiry Form