Air Permitting

Your air permit application can be the most complicated task in developing a facility. Air Pollution permitting requires experienced engineering and credibility with the delegated Clean Air Act (CAA) Administrators. SMG actively manages this process We assist in negotiating permit conditions with an understanding of the operational realities facing our clients. Once the permit is issued, SMG helps maintain compliance with required evaluations and inventories, comprehensive record keeping and reporting obligations. SMG has helped clients begin operations by obtaining authorizations ranging from small source air registrations to complex Title V major source permits. For sites with complex permitting requirements and related impact evaluation, SMG performs required air emissions dispersion modeling and provides recommendations for optimal permitting scenarios that provide operational flexibility.
SMG has experience in:

1. Preparing air permit applications for major (Title V), synthetic minor (FEDOOP/ FESOP), and minor/area sources of air pollution subject to local, state and federal regulations.

2. Prevention of Significant Deterioration (PSD) permitting for PSD major sources of air pollution including major source modifications, emissions netting analyses, air quality impact analyses, and nonattainment NSR permitting review.

3. Negotiating and developing source-specific State Implementation Plan (SIP) requirements including assessment of reasonably available control technology/ measures (RACT/RACM), review of ambient air monitoring data, submission of public comments, and technical examination of areawide SIP dispersion modeling.

4. Regulatory applicability determinations for affected facilities/affected sources subject to local, state, and/or federal air pollution regulations.

5. Reviewing permit terms and conditions to ensure clients have maximum operational flexibility, verify the permit language and standards provide clear and concise compliance demonstration methods, advocate for streamlining of permit standards (when applicable), and ensure permit requirements are not more stringent than those allowed by regulation.

6. Developing comprehensive emissions inventory surveys and major source emission statements for stationary sources across a variety of industries.

Air Dispersion Modeling

1. Air dispersion modeling evaluations using SCREEN3, AERSCREEN, and EPA’s regulatory “preferred” model AERMOD.
2. Assess National Ambient Air Quality Standards (NAAQS) modeled compliance for both single source and cumulative source modeling demonstrations.
3. Prepare Environmental Acceptability Demonstrations (EADs) for emissions of Toxic Air Contaminants (TACs) regulated by the Louisville Metro APCD. In addition to analyzing offsite impacts of facility TAC emissions, SMG can evaluate alternate control strategies and risk allocation for regulated processes at a stationary source.
4. Develop compliance strategies using parametric monitoring for stationary sources subject to risk-based emission standards under the Strategic Toxic Air Reduction (STAR) program administered by the Louisville Metro APCD.
5. Conduct screening analyses to estimate stationary source(s) impacts on both attainment and nonattainment areas.
6. Prepare significant impact level (SIL) determinations for stationary source(s) impacting nonattainment areas under review by a CAA Administrator.
7. Odor concentration modeling including estimates for probabilistic spatial distribution of odor plume(s) using AERMOD.

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