M.S. Hatch Consulting

MSHC’s staff has New Source Review (NSR) and Title V permitting experience at several California Air Districts (see Agency Relationships). 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.

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 National Emission Standards for Hazardous Air Pollutants (NESHAP and New Source Performance Standards (NSPS) assessments, including:

• Aerospace Manufacturing and Rework Facilities NESHAP (40CFR Part 63 subpart GG)
• Compression-ignition engine NSPS (40 CFR Part 60 Subpart IIII)
• Industrial, Commercial, and Institutional Boilers and Process Heaters NESHAP for Major Sources (40 CFR Part 63 Subpart DDDDD)
• Industrial, Commercial, and Institutional Area Source Boilers NESHAP (40 CFR Part 63 Subpart JJJJJJ)
• Municipal Solid Waste Landfill NESHAP (40 CFR Part 63 Subpart AAAA)
• Municipal Solid Waste Landfills NSPS (40 CFR Part 60 Subpart WWW)
• Reciprocal Internal Combustion Engine (RICE) NESHAP (40 CFR Part 63 Subpart ZZZZ)
• Shipbuilding and Ship Repair (Surface Coating) NESHAP (40 CFR Part 63 Subpart II)
• Spark-ignition engine NSPS (40 CFR Part 60 Subpart JJJJ)
• Other regulations for industrial activities.

Our staff is also experienced in determining applicability and planning for compliance with rules and regulations promulgated by the California Air Resources Board (CARB) and local California Districts (see Agency Relationships). 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.

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
• Risk Reduction Plan preparation

MSHC has provided a detailed analysis of prioritization scores to eliminate the requirement to complete a full HRA and save the client both time and money. MSHC staff have also managed HRA projects that drastically reduced public notification requirements by negotiating representative emission factors with the regulatory agency.

CARB 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, CARB developed diesel PM targeted 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 the following regulations:

• ATCM for Stationary Compression Ignition Engines (aka Stationary ATCM) [Title 17, CCR, § 93115]
• ATCM for Diesel Particulate Matter from Portable Engines Rated at 50 Horsepower and Greater (aka Portable ATCM) [Title 17, CCR, § 93116]
• Regulation to Establish a Statewide Portable Equipment Registration Program (PERP) [Title 13, CCR, § 2450 to 2465]
• Large Spark-Ignition Engine Fleet Requirements Regulation (LSI Regulation) [Title 13, CCR, § 2775]
• Regulation for In-Use Off-Road Diesel-Fueled Fleets (ORD Regulation) [Title 13, CCR, § 2449]
• Regulation to Reduce Emissions of Diesel Particulate Matter, Oxides of Nitrogen and Other Criteria Pollutants from In-Use Heavy-Duty Diesel-Fueled Vehicles (Truck and Bus Regulation) [Title 13, CCR, § 2025]

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, 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.

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.

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 extensive 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.

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 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.

MSHC staff has experience and familiarity with the NPDES General Permits for Stormwater Discharge from Industrial Activity (IGP), Construction Activity (CGP), and the Municipal Separate Storm Sewer System (MS4). Our staff has experience with permitting from Notice of Intent (NOI) through Notice of Termination (NOT). This includes SWPPP preparation, amendment, and implementation. Our staff includes QSDs/QSPs, QISP, and a trainer of record. We provide inspectors and samplers to meet the permit requirements. We have prepared exceedance response action (ERA) documents, rain event action plans (REAPs), and have trained and worked with clients to maintain SMARTS, including uploading annual reports, NOI, and NOT. We help our clients with no exposure certification (NEC), notice of non-applicability (NONA), reduced sampling frequency, and pride ourselves on providing cost-effective solutions for compliance. Our trainer of record provides training for all general NPDES permits and has acted as compliance group leader for over twenty industrial transportation facilities. Due to the recent stormwater discharge standards, some facilities are required to implement advanced BMPs including treatment systems that meet numeric effluent standards. MSHC works with vendors to warranty treatment systems that meet the stringent discharge standards or assist with alternative compliance options. When needed, we assist with NOV response and work with clients to avoid fines. Our clients include construction contractors and developers, industrial facilities, utilities, municipalities, Caltrans, and other transportation agencies.

Stormwater Services Offered:

• SWPPP Development
• BMP and Treatment Design
• SMARTS, AdHoc/Annual Reporting
• Exceedance Response Action
• Training
• Inspections

Our stormwater practice is led by John Gleason, who brings more than 30 years of experience to MSHC. Mr. Gleason is a professional engineer certified as a Stormwater Pollution Prevention Plan (SWPPP) developer and trainer of record. He has trained over 200 Qualified SWPPP Developers-Practitioners (QSDs-QSPs), over forty Qualified Industrial Stormwater Practitioners (QISPs), and myriad field staff. He has managed compliance projects for National Pollutant Discharge Elimination System (NPDES), General Permits for Construction, Industrial, and Municipal activities, as well as dewatering and individual permits. Mr. Gleason has supported utility agencies, developers, municipalities, industrial facilities, and construction companies. His clients include Southern California Edison (SCE), Irvine Community Development Company, Gerdau, Riverside Transportation District, Los Angeles (LA) Metropolitan Water District, LA County Metropolitan Transportation Authority (LA Metro), Marine Corps Installations West (MCIWEST), Turner Construction, Ametek, and Caltrans. Previously, Mr. Gleason worked for LA County Public Works as an Environmental Compliance Manager.

Check out our Training link for upcoming Stormwater related training!

• Antelope Valley Air Quality Management District (AVAQMD)
• Eastern Kern Air Pollution Control District (EKAPCD)
• Imperial County Air Pollution Control District (ICAPCD)
• Mojave Desert Air Quality Management District (MDAQMD)
• San Diego Air Pollution Control District (SDAPCD)
• San Joaquin Valley Air Pollution Control District (SJVAPCD)
• South Coast Air Quality Management District (SCAQMD)
• Ventura County Air Pollution Control District (VCAPCD)

• Arizona Department of Environmental Quality (ADEQ) Air Quality Division
• California Air Resources Board (CARB)
• Nevada Department of Environmental Protection (NDEP) Bureau of Air Pollution Control (BAPC)

• U.S. Environmental Protection Agency Region IX (EPA Region 9)