Air Quality
Air Quality practice requires that we address issues on behalf of our clients that include:
- Providing advice to client regarding what is and is not a regulated air emission and compliance with the air quality regulations
- Air quality compliance activities and documents required by state and federal administrative laws and regulations
- Notifications and permitting related to emission sources
- Unauthorized releases or emissions to the atmosphere
- Defense of administrative or civil enforcement actions related to air quality issued or instituted by state or federal administrative agencies
- Defense of civil actions by state and US departments of justice related to air quality after referral of administrative enforcement actions by state or federal environmental agencies
Air Quality matters in which the firm has or attorneys with the firm have been involved include the following:
- Defense attorney in several class actions and numerous toxic tort suits on behalf of chemical manufacturers air releases of various inorganic and organic chemicals that allegedly caused exposure and personal injuries to nearby residents. Investigated root causes, assimilated technical-legal facts, air modeling, located and coordinated experts, developing defense strategies and preparing the case for trial.
- Resolved issues with state agency regarding emission banking, toxic air pollutant fence line concentrations, issuance of emission reduction certificates, netting out of new source review and non-attainment netting for an SBR rubber manufacturing facility
- Prepared air permit application for a barge cleaning and maintenance facility
- Prepared opinions detailing the actions necessary to bring a commercial solid waste disposal facility into compliance with the state air quality regulations
- Resolved issues with state agency for a major oil refinery regarding a PSD netting analysis for the start up of existing equipment that would indirectly increase boiler emissions but not exceed permitted emission levels
- Drafted an entire set of revised asbestos regulations for submission to the responsible state agency on behalf of a commercial solid waste disposal facility
- Responsible for ensuring Air Quality compliance at a commercial hazardous waste treatment, storage and disposal facility and a large ethylene and styrene manufacturing facility
- Developed fugitive emissions monitoring programs for multiple industrial clients, including a large refinery
- Implemented Method 22 testing on industrial flares at a large refinery
- Prepared and submitted various modifications to large refinery client’s air permits for process unit modifications
- Implemented Benzene NESHAP Compliance (40 CFR 61 Subpart FF) at a large refinery
- Implemented Hazardous Organic NESHAP (HON) Loading Racks (40 CFR 63 Subpart G) at a large refinery
- Implemented HON Waste Water (40 CFR 63 Subpart G) at a large refinery
- Implemented HON Cooling Towers (40 CFR 63 Subpart F) at a large refinery
- Implemented Cooling Tower Leak Detection and Repair at a large refinery
- Implemented Benzene Transfer Operations (40 CFR 61 Subpart BB) at a large refinery
- Implemented Marine Loading MACT/RACT (40 CFR 63 Subpart Y) at a large refinery
- Implemented Wastewater Systems (40 CFR 60 Subpart QQQ) at a large refinery