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Primary Areas of Expertise:
Air Quality Modeling and Impact Assessment
Permits for Source Construction and Operation
Title V Permitting
NEPA Environmental Impact Assessments
In general, a facility subject to Title V is defined as a facility emitting more than 100 tons per year of any regulated air pollutant. In keeping with the stringent requirements of Title V, subject facilities must submit a comprehensive operation permit application. When relevant, air permit applications adress Reasonably Available Control Technology (RACT), Best Available Control Technology (BACT), Lowest Achievable Emission Rate (LAER), Maximum Achievable Control Technology (MACT), or BART (Best Available Retrofit Technology). If a facility is subject to New Source Performance Standards (NSPS) or National Emission Standards for Hazardous Air Pollutants (NESHAPs), Prevention of Significant Deterioration (PSD) or New Source Review (NSR), Regional Haze Rule or Acid Rain Program, these rule requirements are addressed in the permit application. This permitting extends to EPA's initial list of 188 Hazardous Air Pollutants and over 160 other air pollutants regulated under accident al release and stratospheric ozone protection provisions. K&A has, in certain applicable cases, recommended modifications to existing permits in order to reclassify a facility as a "synthetic" non-Title V source, thereby avoiding stringent Title V regulations and fees.
K&A has evaluated the applicability of Title V rules and related regulations for facilities in a variety of industries, including Power, Cement, Asphalt, Fertilizer, Fiberglass manufacturing, Heavy Mineral Mining and Processing, Phosphate Mining, Aircraft Component Manufacturing, Citrus, Medical Waste Incineration and Animal Feed Manufacturing.
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