M.S. Hatch Consulting, LLC

 
M.S. Hatch Consulting, LLC


services 


    
Air Quality Permitting – NSR and Title V
 

MSHC’s staff has NSR and Title V permitting experience at South Coast Air Quality Management District (SCAQMD), San Diego Air Pollution Control District (SDAPCD), Mojave Desert Air Quality Management District (MDAQMD), Eastern Kern Air Pollution Control District (EKAPCD), San Joaquin Valley Air Pollution Control District (SJVAPCD), and Ventura County Air Pollution Control District. We have an outstanding reputation with the regulatory agency staff, which directly benefits our clients in negotiating favorable permit conditions. We have performed numerous Best Available Control Technology (BACT) evaluations and cost effectiveness calculations for industrial equipment and processes, including internal combustion engines, gas turbines, engine test cells, and spray booths.

 Compliance Audits and Plans  

MSHC provides compliance audits, as well as applicability assessments, compliance plans, and implementation assistance for compliance with federal, state, and local air quality regulations. For nearly two decades, MSHC staff has supported the military and private industry with detailed NESHAP assessments, including the Aerospace, Shipbuilding, and Reciprocal Internal Combustion Engine NESHAPs and New Source Performance Standards (NSPS) for Diesel and Gas-Fired Engine assessments, Municipal Landfill NESHAP and NSPS, and other regulations for industrial activities. We are currently performing a comprehensive NESHAP/NSPS and federal and state GHG regulations applicability assessment for Edwards AFB in California. Our staff is also experienced in determining applicability and planning for compliance with rules and regulations promulgated by local California Districts, including SCAQMD, SDAPCD, MDAQMD, EKAPCD, Imperial County Air Pollution Control District, and SJVAPCD. We proactively participate in the rule development process, often on behalf of our clients, to provide input during the process and prepare our clients for compliance.

    AB 2588 Inventory, Risk Assessment, and Risk Reduction 

MSHC provides Assembly Bill (AB) 2588 Air Toxics "Hot Spots" Program support to facilities in California. Our services include Air Toxics Emission Inventories, including plan and report preparation; screening and detailed Health Risk Assessments (HRAs); public notification support; and Risk Reduction Plan preparation. MSHC is currently providing similar services to the Navy and City of San Diego. Previously, MSHC staff managed HRA projects that drastically reduced public notification requirements by negotiating representative emission factors with the regulatory agency.

  ARB Diesel Program Compliance 

ARB has identified particulate emissions from diesel engines as toxic air contaminants based on their potential to cause cancer and other adverse health effects.  To reduce these emissions, ARB has developed Airborne Toxics Control Measures (ATCMs) and vehicle fleet regulations to regulate emissions from diesel engines and large spark ignition (LSI) off-road engines.  These include regulations controlling stationary, portable, heavy duty on-road, and mobile off-road diesel engines. MSHC provides inventory, emission calculations, compliance plan development, and reporting services for compliance with these regulations. MSHC is currently providing ARB Diesel Program support to the City of San Diego, Edwards Air Force Base (AFB), and Navy Region Southwest (NRSW). Previously, MSHC staff managed region-wide ATCM, ARB Diesel Program, and LSI compliance projects for Marine Corps Installations West (MCIWEST) and NRSW installations.

   GHG Management, Inventories, and Verification 

MSHC staff has considerable experience in performing GHG emissions inventories for various protocols and programs, including both California AB 32 and U.S. Environmental Protection Agency (EPA) Mandatory Reporting for various reporting categories/industries. Since the inception of the state and federal GHG regulations, MSHC staff has actively participated in the regulation development process and supported clients with applicability analyses. For example, MSHC supports the Region 9 DoD Air Quality Task Force in tracking and preparing for compliance with California AB 32 and federal GHG regulations.

Additionally, MSHC has ARB accredited Lead Verifiers that can support 3rd party verifications of AB 32 Mandatory Reporting. MSHC staff has assisted many clients in their initial GHG emissions reporting, including creating a GHG emissions management program and training sessions, GHG Monitoring Plans, and Cap-and-Trade strategies; preparing e-GGRT submissions; and providing support during 3rd party verification. MSHC staff also has extensively knowledge and experience in completing applicability assessments and compliance plans with the numerous AB 32 GHG regulations, such as those regarding landfill methane, refrigerants, SF6, commercial recycling, and other developing early action measures.

Previously, MSHC staff completed a comprehensive fenceline-to-fenceline GHG assessment for eight MCIWEST installations and Edwards AFB.  The projects included the preparation of a GHG assessment report that comprised a complete GHG inventory, a review of potential carbon credits from Base projects, analysis of AB 32 compliance requirements, EPA GHG Mandatory Reporting Rule assessment and reporting, GHG Tailoring Rule for Title V and PSD Permitting assessment, and GHG inventories based on the Federal GHG Accounting and Reporting Guidance for EO 13514. MSHC staff calculated GHG emissions from Scope 3 and mobile sources and an inventory of water/energy conservation projects and vehicle fleet management requirements throughout MCIWEST.

Sustainability Management and Plans 

MSHC staff has extensive experience in federal sustainability requirements, most notably Executive Order (EO) 13514. MSHC staff has worked on developing regional sustainability programs and strategic sustainability performance plans, including sustainability metric tracking for GHG management, energy and water usage and conservation, LEED certification, fleet management, sustainable acquisition (green procurement), pollution prevention, electronics stewardship, sustainable planning, and waste diversion.

Previously, MSHC staff managed and executed a project to understand and evaluate MCIWEST’s business processes to help develop the MCIWEST Sustainability Management Program and Draft MCIWEST Order 5090.3. MSHC staff also mapped the Environmental Management System (EMS) business process (e.g., Goals, Objectives, Targets, and Actions) to meet the EMS implementation requirements for EOs 13423 and 13514, DoD SSPP, and USMC SSPP with a SQL-based web application called the Sustainability Management Tool (SMT). The SMT is an enterprise-wide tool to centralize and standardize sustainability mandates, and projects planned to in order to meet those mandates. The SMT collects sustainability metrics across each facility in the region and provides real time analysis on the facility's progress towards meeting the mandates. The SMT includes features that roll-up facility sustainability metrics to be viewed at the regional level, as well as reporting functionality to access specific sustainability metrics. The SMT gives managers and key decision makers the information needed to prioritize resources in order to achieve the maximum sustainability benefits. 

MSHC staff supported NAVFAC SW and MCIWEST in presenting the SMT to the Assistant Secretary of the Navy for Energy and Environment and Commanding Officers and Leadership staff at Marine Corps Air Station Yuma and Marine Corps Base Camp Pendleton. MSHC continues to provide user support to the SMT, as well as conducts training for MCIWEST users, both in-person and via webinar.

MSHC staff also prepared Installation Sustainability Performance Plans for several MCIWEST installations to track compliance and recommend projects to meet the sustainability metrics outlined in the MCIWEST Order 5090.3. The Installation Sustainability Performance Plans provide the sustainability metrics and projects that is to be loaded on the SMT.

MSHC staff also compiled global Department of Navy sustainability requirements in order to assess their status with meeting the metrics laid out in various sustainability mandates for NAVFAC  Headquarters.