Air Quality

Ashworth Leininger Group routinely assists major source facilities, including refineries, oil and gas operations, electrical power generating facilities, manufacturing facilities, and legal counsel on local air district, and Federal EPA Title V operating permitting and compliance requirements.

ALG is recognized as a leader in Title V permitting matters: our staff has authored papers with EPA senior staff on Title V implementation issues, provided expert testimony on Title V requirements, and prepared scores of Title V permit applications for complex source operations around the United States. Staff also serves on agency sponsored task-forces and peer review panels, and has been admitted as expert witnesses in federal and state litigation. Specific technical services are listed below:

Local Air Quality Permitting

ALG staff collaborates with our clients and equipment manufacturers to secure pre-construction approvals for new and modified equipment. Technical services include:

  • Preparation and negotiation of complex air permits under New Source Review (NSR) and Prevention of Significant Deterioration (PSD) regulations
  • Control technology studies to support the determination of appropriate control technology under NSR, regional haze, SIP, and MACT programs
  • Design and implementation of meteorological and ambient air quality monitoring programs
  • Ambient air quality impact analyses, including baseline, project, increment, visibility studies
  • Emission offset trading and certification
  • Air toxics health risk assessment studies
  • Continuous Emissions Monitoring System (CEMS) design, certification, and performance/source testing
  • NESHAP permitting (40 CFR Parts 61 and 63)

For more information, please contact Ev Ashworth at (805) 764-6017 or email Ev at eashworth@algcorp.com.

Federal Title V Permitting and Compliance

In addition to securing pre-construction approvals, ALG has extensive experience with permitting Federal Title V facilities. ALG staff helped our clients and trade associations comment on the design of the EPA and state/local operating permit programs, and have secured scores of Title V permits for major sources throughout the United States. Technical services include:

Preparation of initial and renewal Title V applications, including

  • Calculation of emission inventories for criteria, air toxic, and GHG emissions
  • Definition of applicable federal, state and local requirements
  • Definition and negotiation of monitoring, recordkeeping and reporting protocols
  • Air dispersion modeling and health risk analyses (where applicable)
  • Strategic design to optimize operating flexibility, leverage application and permit shields and alternate operating scenarios, where necessary, and negotiation of streamlined permit terms and conditions;
  • Title V implementation programs and data management software;

For a more detailed summary of Title V air permitting services, please see the following SOQ:

For more information, please contact Bart Leininger at (805) 764-6012 or email Bart at bleininger@algcorp.com

Greenhouse Gas Emission Compliance

ALG is a verified body under the AB32 Mandatory GHG Emissions Reporting Regulation, with five accredited lead auditors, supplemented by senior air quality engineers and air quality specialists. This demonstrated technical expertise also our submission of GHG reports under EPA’s Greenhouse Gas Reporting Program (40 CFR Part 98 and specific reporting subparts). By partnering with our clients, we are able to provide the technical guidance necessary to streamline reporting and assure the adequacy of all data under the respective programs. We also collaborate with our clients to prepare and update internal GHG monitoring and voluntary reduction programs. We encourage you to visit our testimonials page to gauge our clients’ satisfaction with our GHG reporting services.

GHG Emission Reduction Programs

ALG collaborates with our clients and agency staffs to design, quantify, and implement GHG mitigation programs required to secure pre-construction approvals or CEQA certification. Here our staff leverages technical expertise and direct prior experience in identifying cost-effective and practical GHG reduction options for industrial operations. We also assist our clients and equipment engineers in the integration of GHG reduction technologies into project design, which realizes economic and thermal efficiencies and decreases overall project costs.

For a more detailed summary of the Greenhouse Gas Emission Compliance services, please see the following SOQs:

For more information please contact Mark Gruber at (805) 764-6015 or mgruber@algcorp.com.

Emission Reduction Credit Acquisition

ALG staff have secured approvals for innovative emission offset projects for mobile (off-road, railroad, and marine sources), industrial (point sources), and area emission sources.

Our technical services include the following:

  • Engineering and emissions analysis to assure proper quantification of actual emissions, including;
    • - Calculation and reporting of monthly/quarterly/annual emission reductions;
    • - Analysis and quantification of missing data;
    • - Auditing of Continuous Emission Monitoring Systems (CEMS);
  • Ongoing support to our larger industrial clients subject to local and regional cap-and-trade programs

For more information please contact Jayme Dryden at (805) 764-6005 or jdryden@algcorp.com.

Health Risk Assessments

Ashworth Leininger Group’s health risk assessment (HRA) practice leverages our expertise in air toxics emissions inventory development, best available control technology for toxics (T-BACT) determination, and air dispersion modeling on behalf of industrial and regulatory clients. As illustrated below, ALG has the capabilities to:

  • Develop defensible toxic air contaminant (TAC) emission inventories under the California Air Toxics Hot Spots Program (AB 2588);
  • Use Geographic Information System (GIS) to develop key input data for HRAs;
  • Perform air dispersion modeling consistent with EPA, ARB, and local air district modeling guidelines;
  • Execute health risk assessment models that use the source emission rates developed in the emission inventory task and the output of the air dispersion modeling to quantify potential health effects;
  • Prepare comprehensive HRA reports; and
  • If necessary, provide assistance in making T-BACT determinations and developing Risk Reduction Plans.

ALG has conducted health risk assessments and public warning analyses to support a wide range of air permitting requirements; examples include:

  • Performed preliminary air dispersion modeling for the potential expansion of an electric generating station. Designed a meteorological monitoring network to support refined complex terrain modeling and assisted in developing permitting strategies;
  • Prepared refined health risk assessments to comply with AB 2588, the California air toxic "hot spots" program, for a variety of facilities in Los Angeles, Santa Barbara, Ventura, and Kern Counties, including a glass manufacturing plant, large fuel storage and distribution facilities, chemical plants, petroleum production facilities, a semiconductor manufacturing facility, and a major university;
  • Managed air quality impact analysis task for an expansion project at a glass container manufacturer. Calculated operational emissions for the proposed expansion. Performed air dispersion modeling and health risk assessment for the project to demonstrate that impacts are below significance thresholds established by the South Coast Air Quality Management District. Results of these analyses were incorporated into the EIR prepared by the city;
  • Performed accidental release modeling of a variety of regulated toxic and flammable substances at a refinery. The offsite consequence analysis included worst-case releases and alternative release scenarios. Results were incorporated into the Risk Management Plans for the facility.

For more information on ALG's HRA services please refer to our HRA brochure.

 

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