Areas of Expertise
Compliance services are divided into the following basic activities that are integrated to meet client requirements:
- Compliance Management
- New Source Review (NSR)/Title V/Minor Source Air Permitting & Emission Inventories
- Detailed NSPS/MACT/NESHAP/Permit Compliance Assessments/Audits
- Resource Conservation and Recovery Act (RCRA) auditing, permitting, and modification
- Continuous Emissions Monitoring Systems (CEMS)
- Greenhouse Gas (GHG) Permitting/Reporting
- Air Dispersion Modeling
- Ambient Air Quality Monitoring
- Development and Delivery of Operator Certification Training
- Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) or Superfund
- Trial Burns, Compliance Tests, and Other Emissions Testing.
Focus assists clients in developing regulatory compliance programs that integrate the requirements of applicable environmental regulations with facility standard operating procedures into a single comprehensive compliance system. This approach minimizes duplication of effort in meeting each law’s requirements and provides a framework for collecting, organizing, storing, and reporting all required data. To keep pace with changing regulatory requirements, we have developed a unique approach to regulatory compliance programs that is tailored to each client’s specific requirements.
New Source Review (NSR)/Title V/Minor Source Air Permitting & Emission Inventories
Focus provides a full range of air permitting services, including air emissions inventories, regulatory and compliance assessments, preparing permit applications, negotiating with regulatory agencies, participating in public hearings, and conducting performance compliance tests. Focus personnel successfully prepare PSD, NSR, Construction, Operating, Title V, and Minor Source permit applications addressing federal, state, and local regulations and requirements.
Detailed NSPS/MACT/NESHAP/Permit Compliance Assessments/Audits
New Source Performance Standards (NSPS), National Emission Standards for Hazardous Air Pollutants (NESHAP) and Maximum Achievable Control Technologies (MACT) standards are hard enough to read, interpret, and understand. Complying with these standards can, in reality, be very complicated and burdensome. Focus is specialized in NSPS, NESHAP, and MACT compliance and can help facilities anticipate and plan for compliance issues. To ensure compliance with applicable regulations, Focus assesses a facility’s existing program to identify gaps with NSPS, NESHAP, and MACT requirements and helps the facility develop an implementation program and compliance management system.
Resource Conservation and Recovery Act (RCRA)
Facilities which generate, treat, store, or dispose of hazardous waste are regulated under RCRA. Focus personnel have been actively involved in RCRA compliance since its early implementation. Focus engineers assist with applications, modifications, renewals, audits, and closures. This involves supporting clients from small quantity generators with their recordkeeping and reporting through to developing the Part A and Part B permit applications / modifications for large commercial treatment, storage, and disposal facilities (TSDF).
Continuous Emissions Monitoring Systems
EPA has placed the burden on sources to continually prove compliance with emissions standards and limitations. Through the use of continuous emissions monitoring systems (CEMS), affected sources can provide assurance to the agency that they are meeting their emissions limitations. In addition, sources subject to the Acid Rain Program and/or the NOx Budget Program must use CEMS to calculate their allowances. Focus has experience with CEMS performance specifications, associated certification tests, and quality assurance/quality control plans. Focus works with our clients to ensure that CEMS are installed correctly, meet the required levels of accuracy and precision, and demonstrate compliance with performance and reporting requirements.
Greenhouse Gas (GHG) Permitting and Reporting
With an emphasis on climate change and the environment, EPA is pursuing the collection and reporting of greenhouse gas emissions data which will lead to regulatory policy. Focus engineers understand plant process operations and will assist clients with their emissions reporting and recordkeeping. Further, Focus performs energy audits and evaluates energy recovery options to assist clients with their sustainability goals.
Air Dispersion Modeling
When air dispersion modeling is required, Focus can assist in selecting the model that best matches the level of sophistication required to provide reliable results without unnecessary expense. We also have experience in conducting research into the accuracy and precision of model predictions. This gives us insight into applying air dispersion models and interpreting model results. Model results are presented graphically and visually to enhance interpretation of the information.
Ambient Air Quality Monitoring
Focus offers extensive experience with sampling procedures of the EPA, OSHA, and National Institute of Occupational Safety and Health (NIOSH). This experience includes conducting ambient air monitoring near industrial plants, remediation sites under CERCLA and RCRA, and emergency response sites from accidental spills of hazardous chemicals. Focus can also conduct urban-wide monitoring and background monitoring.
Keeping up with regulatory change is a major business challenge. Regulations can impact company operations through unnecessary enforcement actions and unplanned capital costs. Focus helps clients with this complex and ever-changing regulatory environment by reporting on existing legislation and new regulatory developments and by providing community relations technical support and Expert Witness testimony.
Focus developed and delivered a qualified operator training program for operators of hazardous waste combustors in accordance with HWC MACT under an ASME QHO program. Although the program is no longer offered under ASME, Focus retains the knowledge, experience, and expertise to develop and deliver site specific training for operators, supervisors, and managers to meet regulatory compliance requirements for control system operators.
Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) or Superfund
See our discussion under Environmental Remediation Management or Thermal Desorption Remediation.
Trial Burns, Compliance Tests, and Other Emissions Testing.
See our discussion under Air Emission Testing & Test Management.