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Liberty’s air quality management team has experience preparing Title V, PSD, and NSR air permits in more than 30 states. Our air quality management services include air permitting, air pollution control assessments, air quality modeling and monitoring, and air emissions testing. Our staff has ex-regulators with intimate air pollution control and regulatory and compliance experience. Our staff has extensive industrial experience installing, operating, and maintaining air pollution sources and pollution control devices.
Overview
Much of our work involves teaming with clients to develop plans for new products, new plants, assess opportunities to minimize risk, and build community and consumer participation. Liberty has been engaged in a wide range of business–growth projects. Our experience includes air quality permitting, regulatory applicability and major new source permitting (e.g., preparation of PSD and non-attainment area NSR permit applications). A brief overview of our air quality and strategic services are provided below:
- Strategic environmental planning (e.g., plant siting and fatal flaw analyses)
- Pollution control device feasibility, troubleshooting, and cost evaluations
- Innovative solutions and flexible permitting (e.g., PALs)
- Regulatory tracking and rulemaking negotiation on behalf of corporations and trade associations including New Source Review (NSR) Reform, Maximum Available Control Technology (MACT) standard development
- Title V permit negotiation, enforcement assistance, economic benefit analyses, supplemental environmental projects (SEPs)
- Enforcement assistance, economic evaluations, expert testimony
- Environmental Management System (EMS) development
- Air permitting such as Prevention of Significant Deterioration (PSD), New Source Review (NSR), Title V, and state construction permits
- Air quality modeling including Industrial Source Complex (ISC); AERMOD; CALPUFF for visibility/haze; air toxics
- Air quality monitoring such as meteorological towers, SODAR, ambient monitoring
- Pollution control system control and data collection enhancements
- MACT compliance assistance such as Startup, Shutdown & Malfunction (SSM) Plans, Standard Operating Procedure (SOP) Plans for fugitive emissions and control device O&M procedures
- NOx Budget Plans & NOx Averaging Plan
- Risk Management Plans
- Emission release inventories (Toxic Release Inventories, Global Warming and Green House Gas Inventories)
- Leak Detection and Repair
Innovative Air Permitting
 Liberty air quality staff have assisted clients in increasing operating flexibility through Title V permitting and development of innovative air permitting approaches (e.g., plant-wide applicability limits [PAL].) For some companies PALs offer the ability to respond more quickly to short-notice opportunities and change, offering a competitive advantage where typical permitting schedules would add cost, uncertainty, and limited control over planning. The recently promulgated federal New Source Review reform provides an opportunity for clients as states adopt these NSR revisions which allow the issuance of PAL permits.
Operating Permits
Liberty staff members have extensive Title V permitting expertise. Our staff routinely reviews and negotiates operating permit conditions for our clients. These negotiations often result in additional operating flexibility for our clients, thereby maximizing their competitiveness and minimizing costly regulatory requirements.
Liberty has prepared Title V permit applications and renewals for large and complex facilities. The renewal of the initial Title V permits represents an opportunity to incorporate additional operating flexibility, to address potential applicability of newly issued federal and state regulations, and to address the federal CAM Plan requirements. Liberty offers a unique experience base of regulatory and engineering professionals to prepare CAM Plans for large pollution control systems. CAM Plans must both meet the regulatory intent of the federal CAM Rule and provide clients with compliance assurance at a reasonable cost and minimal additional plant operational and maintenance requirements.
Risk Management Plans
Liberty develops Risk Management Plans (RMPs) including applicability assessments, worst case and alternative release scenario development, modeling, RMP data management systems, process safety management (PSM) development and implementation, corporate training, and guidance document development.
Compliance Assistance
 Through Title V compliance certification requirements, the U.S. EPA’s promulgation of the Credible Evidence Rule, periodic monitoring requirements of Title V, and the Compliance Assurance Monitoring (CAM) rule, compliance demonstration has been profoundly redefined. The significance of these changes is of paramount importance to companies and their Responsible Officials. Liberty is developing programs for clients to document “reasonable inquiry” enabling Responsible Officials to certify the accuracy and completeness of initial applications and establish ongoing “systems” for annual certifications. Liberty works with in-house expertise in instrumentation and controls to develop periodic monitoring systems that incorporate process information monitoring as a surrogate to direct continuous emissions monitoring.
Liberty provides engineering support, agency negotiation, and expert testimony to support client’s resolution of enforcement issues, and in support of real estate and manufacturing plant ownership transfer. Liberty also provides support for annual compliance reporting, including Toxic Release Inventory (TRI), SARA Title III Reports, annual emission statements, and ISO 14000 support.
Emissions Testing
 Liberty’s Project Managers have extensive emissions testing experience and expertise covering nearly all the U.S. EPA Reference Methods. Our intimate knowledge of testing, and the inter-related connection between testing and other aspects of air quality management provide extreme value to our clients. The testing knowledge is integral to solutions in the following areas:
- Pollution control technology assessment,
- emission inventory development,
- capture efficiency,
- control equipment performance and equipment specifications and warrantees,
- compliance assessment,
- non-compliance resolution,
- negotiation of commercial terms for air pollution and control equipment and control systems, and
- development of parametric monitoring, periodic monitoring, and compliance assurance monitoring.
Continuous Emissions Monitoring Systems
Liberty has experts in Continuous Emission Monitoring (CEM) systems. Some of the related services we provide include:
- Selection, design, and installation of CEM equipment
- QA/QC Plan Development, including Source Test Plan and Test Protocol development
- Relative Accuracy Test Audits (RATA)
- Elimination of bias
- Annual audits and re-calibration
Environmental Management and Auditing
Liberty personnel have extensive experience in preparing environmental management systems (EMS) to ensure clients’ environmental monitoring, recordkeeping, and reporting obligations are met. Liberty has developed EMS and environmental “permit manuals” in support of clients’ corporate governance obligations. We have developed environmental calendars and environmental recordkeeping systems for clients, often in spreadsheet or “checklist” format.
Three key aspects of Liberty’s audit services are: (1) independence of auditors, (2) confidentiality of the audit activity and (3) sensitivity to corporate culture. Our primary auditors are highly experienced in designing and conducting environmental audits for a range of diverse facilities and also have practical operating and maintenance experience and thus understand how environmental laws and regulations affect day-to-day operations. Liberty personnel have conducted compliance audits as part of:
- ISO 14001 certifications
- PSD “look-back assessments”
- Clean Air Act compliance audits
- Management system audits
- Due Diligence for Mergers and Acquisitions
- General Permit Reviews
- Policy, Procedure, and Compliance Guide Development
- Supplier Evaluations and Approval Process
Corporate-Level Consulting
Liberty provides corporate-level consulting with multi-site clients. Liberty’s partnerships with corporate-level staff provide a specific expertise, additional resources for fast turnaround needs, and routine support for clients’ environmental management requirements. Examples of Liberty’s corporate level consulting include:
- Preparing Title V air permit applications and performing draft Title V permit reviews in a programmatic fashion across several multiple facility businesses
- Performing environmental audits across multiple facilities
- Participating on an “environmental platform team”
- Providing strategic planning assistance for a major automobile parts manufacturer’s expansion plans
- Tracking regulatory development, commenting on proposed rules, participating in stakeholders negotiations, developing position papers on issues of concern
- Developing and implementing corporate-wide environmental management programs
- Developing common environmental data management systems for quality assured and cost-effective operations, and also to enable rapid informed decision making
Plant-Level Consulting
 Environmental awareness, compliance, and effectiveness are increasingly becoming "internalized" in plant operations. Liberty assists facilities through training, and developing systems for plants to manage the day-to-day environmental requirements. Liberty also provides periodic assistance and specific project assistance where specific expertise and experience is required.
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