Spectrum specializes in all areas of air quality permitting and compliance, and strives to offer each of our clients personalized solutions to meet their facility air quality needs. Spectrum’s air quality professionals dedicate themselves to providing a cost-effective and timely work product to our industrial, commercial, and government clients to assist them with their permitting, ongoing compliance, routine reporting, and other air quality issues. We work closely with our clients to prepare complete and technically defensible permit applications, plans, draft permits, emission inventories, and reports. Spectrum staff also have extensive knowledge of applicable local, state, and federal air quality regulatory requirements and wide-ranging experience in successful negotiations with regulatory agencies across the United States. Spectrum has expertise in a wide variety of industries, including Portland cement, steel, chemical, aluminum, paint, mining, ports, transportation, nuclear power production, and natural gas and coal power production. Detailed information about the specific air quality related services that we offer can be found below.
NSR Major Source Permitting
The New Source Review (NSR) permitting program was established to ensure that new or modified minor and major sources will not significantly degrade the existing air quality and will be equipped with the latest advances in pollution control equipment. Spectrum has extensive experience with NSR permitting and begins each project by performing an emissions quantification and regulatory review to determine the project’s NSR applicability and to identify the NSR permitting requirements under Nonattainment New Source Review (NNSR), Prevention of Significant Deterioration (PSD) regulations, and/or state construction air quality permitting requirements.
Spectrum provides our clients with complete permitting services from initial feasibility studies through the NSR permitting process, providing support during state and federal draft permit review, and attending public hearings. The NSR permitting process requires that new and modified major sources undergo rigorous air quality analyses to demonstrate that appropriate air pollution control technology is being proposed and that all air quality standards will be maintained. Spectrum has performed numerous air pollution control technology assessments, both assessing Best Available Control Technology (BACT) for attainment areas and also Lowest Achievable Emission Rates (LAER) for non-attainment areas. Spectrum provides a wide range of air quality dispersion modeling capabilities including both basic screening and refined modeling analyses for NAAQS, PSD Increments, and air toxics. Other NSR related services that Spectrum offers include secondary impact assessments and defining and facilitating the purchase of any required emission offsets.
Operating and Construction Permit Applications
Spectrum specializes in all types of air quality permitting, whether constructing a new facility, expanding an existing facility, or modifying current operations. We have experience with initial and renewal Part 70 operating permits (i.e., Title V), NSR major source construction permits, minor source operating and construction permits, synthetic minor permits, plant-wide applicability limit (PAL) permits, and source registrations.
Spectrum is capable of assisting our clients will all aspects of the air quality permit application process including: local, state, and federal regulatory applicability analyses, emissions quantification, flow diagram development or updates, draft permit language, development of required NSPS or NESHAP plans, compliance assurance monitoring (CAM) assessments, control technology assessments, compliance plans, NSR applicability analysis, and review of the issued draft permit.
Air Emission Inventories
Spectrum has extensive experience in developing accurate and defensible air quality emission inventories for industrial, commercial, and government facilities. These emission inventories assess emissions of all applicable criteria air pollutants, hazardous air pollutants, toxic air pollutants, and greenhouse gases.
Spectrum assists many of our clients with preparing annual actual emissions inventories to meet state emissions reporting and EPA GHG reporting requirements. We have also developed baseline actual inventories, future actual inventories, potential-to-emit emission inventories and contemporaneous air emission changes for use in NSR major source permitting. In addition, Spectrum can provide third-party audits of existing air quality emissions inventories to determine if appropriate emission factors are being utilized and correct emissions calculation methodologies employed.
We have experience with utilizing EPA’s TANKS 4.0.9d, WebFire, and AP-42 to calculate emissions from a variety of sources including: paved and unpaved roads, material transfer and handling, baghouses, blasting, flares, cooling towers, cement manufacturing, crushed stone processing, organic liquid storage tanks, gas turbines, gasoline and diesel combustion, and natural gas turbines and engines.
State operating permits, state regulations, and federal regulations can require a facility to complete and submit a variety of routine reports. Spectrum is adept at using many different state online reporting programs to submit annual emissions statements and also using EPA’s eGGRT program to submit annual greenhouse gas emissions reports.
Spectrum can assist our clients with completing annual Title V operating permit compliance certifications, where we work with our clients to document how they have complied with every condition of their Title V Operating permit during the previous year. We also have experience with NSPS and NESHAP semiannual compliance reporting, state routine monitoring and compliance reporting, and EPCRA reporting.
Spectrum also assists our clients in reviewing their NSPS and NESHAP performance test reports and notices of compliance to ensure that they meet all necessary regulatory requirements prior to their submittal.
NESHAP and NSPS Plans
Spectrum is extremely proficient and experienced in drafting an array of different plans required by NSPS and NESHAP regulations. These plans include:
Operation and Maintenance Plans
Startup, Shutdown, and Malfunction Plans
Site Specific Monitoring Plans
Opacity Monitoring Plans
CEM Quality Assurance/Quality Control Plans
Fugitive Dust Control Plans
In addition, Spectrum has experience with completing compliance assurance monitoring (CAM) Plans to meet 40 CFR 64 and any associated state requirements. Spectrum also has assisted clients with third-party audits of existing plans to ensure that they meet all necessary regulatory requirements.
Climate Change and Sustainability
Spectrum’s climate change services include assisting our clients to comply with regulatory requirements such as the GHG Tailoring Rule and GHG Mandatory Reporting Rule, and also evaluating future projects and operations to develop sustainability strategies that can be implemented. Spectrum is experienced with assessing carbon footprints and developing baseline and annual GHG emission inventories. We also are knowledgeable in the preparation of GHG Best Available Control Technology (BACT) assessments for attainment areas and also Lowest Achievable Emission Rates (LAER) assessments for non-attainment areas. Spectrum prepared one of the first GHG BACT analyses for a Portland cement Plant that was accepted by a state agency in the United States.