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The following is a summary of Waid Environmental's Air Quality Services. Click on the links in the table of contents to take you to the details section for that service.

Table of Contents

  1. Permit and compliance strategy development and support
  2. Environmental Audits
  3. State and federal New Source Review and Title V operating permits
  4. Agency negotiations and liaison
  5. Regulatory analysis, recordkeeping, and reporting
  6. Air dispersion modeling and air quality analysis
  7. Evaluation of emission controls, Best Available Control Technology (BACT), Lowest Achievable Emission Rates (LAER), and Maximum Achievable Control Technology (MACT)
  8. Emissions Inventory preparation (traditional and Greenhouse Gases)
  9. Expert testimony and litigation support
  10. Training


Service Details


 1. Permit and compliance strategy development and support:

  • Ambient impact considerations
  • Compliance audits
  • Compliance issue resolution
  • Economic analysis
  • Emission banking
  • Grassroots and expanded plants
  • Review of competitor regulatory files
  • Siting analysis
  • Strategic planning
  • Third party reviews

Development of a permitting and compliance strategy is affected by many factors, such as the possibility that both state and federal permits may be required, the feasibility of using compensating emission reductions as offsets for planned emission increases, the area attainment status with respect to National Ambient Air Quality Standards (NAAQS), and the types of emission controls to be proposed and their suitability as BACT or Lowest Achievable Emission Rate (LAER) (as required by permitting regulations). Waid Environmental's engineers evaluate these factors early in the permitting process to optimize scheduling and balance both short-term and long-term permitting needs.


 2. Environmental Audits:

  • Compliance audits
  • Compliance issue resolution
  • Third party reviews
  • Due diligence


 3. State and federal New Source Review and Title V operating permits:

  • Ambient impact analysis
  • Ambient monitoring plan
  • Compliance Assurance Monitoring (CAM)
  • Emission estimation
  • Exemptions, alterations, and Texas SB1126 notifications
  • Flexible permits
  • Interface with engineering design and construction firms
  • Prevention of Significant Deterioration (PSD)/NSR
  • Public notices, meetings, hearings
  • Standard permits and exemptions

Preparation of air permit applications and exemptions is done by staff members who are knowledgeable of the requirements of both state and federal agencies. Waid Environmental offers complete support in all areas of the permitting process.


 4. Agency negotiations and liaison:

  • Compliance
  • Inspections [e.g., State Implementation Plans (SIP)]
  • Permits
  • Resolution of Notices of Violation

Liaison and negotiation with regulatory agencies are often necessary during a project, requiring frequent interaction with regulatory personnel. Major permitting issues are identified and discussed early in the preparation process to ensure that they are resolved promptly. Issues that arise during the agency's permit application review are expeditiously settled due to our continual contact with the agency staff. In the latter stages of the permitting process, we negotiate with the agency staff to obtain permit provisions as reasonable as possible.


 5. Regulatory analysis, recordkeeping, and reporting:

  • Compliance Assurance Monitoring (CAM)
  • Chemical emission tracking systems
  • Compliance certification reports
  • Compliance manuals
  • Customized reporting systems [e.g., Superfund Amend-ments and Reauthorization Act (SARA), fugitive]
  • Emission, inspection, and permit fees
  • Historical/current research and review
  • New Source Performance Standards (NSPS)
  • National Emission Standards for Hazard-ous Air Pollut-ants (NESHAPS), MACT, and SIP rules
  • On-site support as client staff members
  • Pollution control property tax determinations
  • Processing/handling/reporting CEM data
  • Proposed regulation analysis and comment
  • Upset/maintenance reporting
Interpretation of regulations is critical. Our engineering staff reviews new and amended environmental regulations at both state and federal levels as they are proposed and adopted. Interpreting regulations is essential in defining technical requirements (such as the requirements for specific emission control equipment, performance testing, and monitoring) and in negotiating permit limitations.


 6. Air dispersion modeling and air quality analysis:

  • Meteorological data processing/handling
  • Monitor siting
  • Non-reactive and reactive pollutants
  • Odors/health effects
  • Permits [Air, Resource Conservation and Recovery Act (RCRA)]
  • Plant siting analysis
  • Risk management plans
  • Stack parameter specifications
  • Toxics/disaster analysis

Atmospheric dispersion modeling is required during permitting to show that no NAAQS, federal Prevention of Significant Deterioration (PSD) increment standards, or state property line standards are violated by the proposed sources or by the cumulative effect of proposed sources and existing sources. Atmospheric dispersion modeling is also required to show that the proposed sources will not cause adverse health or general welfare impacts, or cause nuisance odors or dusts. The staff at Waid Environmental has years of experience in selecting and running approved atmospheric dispersion models for projects ranging from simple single-stack studies to complex multi-source impact analyses. In addition, our staff members have maintained a close working relationship with the modeling staffs of the TCEQ and EPA Region VI. Several of our staff members have provided expert testimony related to modeling efforts in TCEQ permit hearings.

More about modeling...


 7. Evaluation of emission controls,
 Best Available Control Technology (BACT),
 Lowest Achievable Emission Rates (LAER),
 and Maximum Achievable Control Technology (MACT):

  • Best Available Control Technology (BACT)
  • Lowest Achievable Emission Rate (LAER)
  • Maximum Achievable Control Technology (MACT)
  • Reasonably Available Control Technology (RACT)
  • Bid specifications and vendor/bid evaluation
  • Economic analysis
  • Pilot system design
  • Process/material changes
  • Technical/on-site

Technical evaluation of emission controls and analysis of BACT is a fundamental requirement of the permitting process. In nonattainment areas, new source review may require the installation of LAER, regardless of cost considerations. Specific control technologies may also be required by federal New Source Performance Standards (NSPS), National Emission Standards for Hazardous Air Pollutants (NESHAPS), or by TCEQ regulations. Our engineering staff is experienced in determining the technical, practical, and economic feasibility of emission controls and specifying the preliminary design features of emission control equipment.


 8. Emissions Inventory preparation:

Actual emissions are calculated with proven and reliable approaches using cost effective tools. Annual emissions are currently reported for traditional pollutants. Ongoing emission calculations may be set up for various purposes. Greenhouse gases (GHG), such as carbon dioxide, hydrofluorocarbons, methane, and nitrous oxide, are expected to be required by EPA for sites which exceed 25,000 metric tons/yr of GHG. Waid Environmental has experience in both traditional and GHG inventories.


 9. Expert testimony and litigation support:

Expert testimony at public hearings has been provided by Waid and Associates staff members in support of both industrial clients and citizen's groups. Waid Environmental has developed a reputation for fairness and professionalism, especially in providing expert testimony.


 10. Training:

  • Computer-based
  • Courses and materials