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Air Quality CARB Mobile Source Program GHG Inventories & Management Hazardous Materials/Waste Remediation Sustainability Water Quality

Air Quality

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Air Quality Permitting - NSR and Title V

MSHC's staff has New Source Review (NSR) and Title V permitting experience at all large California Air Districts (see Agency Relationships), including SDAPCD, SCAQMD, MDAQMD, SJVAPCD, VCAPCD and EKAPCD. We have an outstanding reputation with the regulatory agency staff, which directly benefits our clients in negotiating favorable permit conditions. We have performed comprehensive 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. Our Title V experience includes preparing complete and timely initial and renewal Title V applications, including detailed Compliance Assurance Monitoring (CAM) Plan applicability analysis, permit streamlining, and permit shield development. We routinely negotiate flexible permit conditions with the regulatory agencies on behalf of our clients.

AB 2588 Inventory, Risk Assessment, and Risk Reduction

MSHC provides Assembly Bill (AB) 2588 Air Toxics "Hot Spots" Program support to government and private facilities in California. Our services include:

MSHC prepares annual air emission inventories for the Department of Defense installations in the southwest, including NWS Seal Beach, NALF San Clemente Island, Naval Air Station (NAS) North Island, NAS Lemoore, NAWS (Naval Air Weapons Station) China Lake, MCAS Miramar, Marine Corps Air Ground Combat Center Twentynine Palms and Fort Irwin. Our inventories for San Diego Navy installations cover 300+ permitted pieces of equipment and an extensive inventory of 2,500+ SDSs and TDSs. We routinely meet multiple concurrent regulatory deadlines.

We focus on saving our clients time and resources by calculating accurate and representative prioritization scores (PS), which in many cases, have eliminated the requirement to complete a full HRA. For example, We helped NAS North Island, Naval Base San Diego, and Continental Maritime of San Diego (CMSD) avoid preparing a HRA and extensive public notification by demonstrating that the San Diego APCD PS calculations were overly conservative and overestimated the potential health risks. MSHC researched and proposed representative emission factors and adjusted distances to receptors to revise the calculations. For MCAS Miramar, MSHC developed an HRA comparison between 2013 and current base operations and negotiated with SDAPCD to rescind a new HRA, saving $60K to increase efficiency and eliminate unnecessary use of resources.

MSHC has managed HRA projects that drastically reduced or eliminated public notification by negotiating representative emission factors with the regulatory agency. The HRA projects completed by our team range from <10 sources at a small facility, to >100 sources and 1,000's of receptors at facilities measured in square miles.

MSHC prepared the 2022 and 2023 NASSCO Public Notification Plan based on Calendar Year 2013/2017 emissions. We coordinated with the SDAPCD and NASSCO to complete mailing of the notification packets to 1,059 homes in the Barrio Logan neighborhood. MSHC supported NASSCO in preparing for and holding a Public Meeting to discuss the notification.

CMSD's HRA based on the 2014 emissions showed that potential public health risks exceeded the public notification and risk reduction levels specified in Rule 1210, triggering a risk reduction audit and plan. MSHC prepared the Risk Reduction Plan for the acute noncancer health risk. The SDAPCD approved the plan with minimal comments. The plan implementation also eliminated the public notification requirement.

Compliance Audits and Plans

MSHC provides regulatory applicability assessment and compliance plan preparation and implementation assistance to our government and private industry clients. We routinely perform facility audits to help our clients maintain ongoing compliance with federal, state, and local air quality regulations. Our staff is experienced with air quality requirements in all large California air districts, including SDAPCD, SCAQMD, MDAQMD, and SJVAPCD. Since 2008, our staff has provided applicability determinations and compliance planning for California Air Resources Board (CARB) Diesel and Mobile Source regulations, including Advanced Clean Fleet, Clean Truck Check, Truck and Bus, In-use Offroad Diesel, Large Spark Ignition, and the recently promulgated Zero Emission Forklift regulations. 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. For nearly three 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 the Aerospace NESHAP, Shipbuilding and Ship Repair NESHAP, Boiler NESHAP, the Reciprocal Internal Combustion Engine (RICE) NESHAP, and the compression-ignition engine and Spark-ignition engine NSPSs.

CARB Mobile Source Program

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CARB Mobile Source Program Compliance

The California Air Resources Board (CARB) has developed an integrated planning approach to transition to cleaner mobile source technologies throughout the state. Mobile sources and the fossil fuels that power them continue to contribute a majority of emissions of diesel particulate matter and smog-forming pollutants, and the largest portion of greenhouse gas emission in California. To reduce these emissions and transition to zero-emission technology, CARB developed the 2020 Mobile Source Strategy and vehicle fleet regulations, including the following:

MSHC is supporting Marine Corps Installations West (MCIWEST) and Navy Region Southwest (NRSW) fleets in ensuring compliance with ORD, LSI, Truck & Bus, Airborne Toxic Control Measure for Portable Engines, Clean Truck Check, ACF, and other regulations. We update the fleet inventories via DOORS and TRUCRS reporting platforms by registering and decommissioning fleet vehicles as needed. MSHC manages multiple concurrent regulatory reporting deadlines. We maintain an open lines of communication with fleet managers, responding to inquiries, and fulfilling information requests promptly. We have developed compliance memoranda for ORD fleets for all NRSW installations subject to the regulation; reviewed upcoming regulations such as the ZEF, ACF, and Clean Truck Check to assess the potential impact on each fleet and collaborated with fleet managers to compile a comprehensive inventory of vehicles subject to new regulations and prepared for reporting.

GHG Inventories & Management

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MSHC has considerable experience in performing greenhouse gas (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 also prepared applicability assessments and compliance plans with the numerous AB 32 GHG regulations, such as those regarding landfill methane, refrigerants, SF6, commercial recycling, and other early action measures.

MSHC supports the Navy and Marine Corps installations in California that are subject to mandatory reporting rule regulations. These include Navy Medical Center San Diego (NMCSD), Naval Base Coronado, Naval Air Station Lemoore, Naval Air Weapons Station China Lake, Marine Corps Air Ground Combat Center (MCAGCC) Twentynine Palms, and Marine Corps Base (MCB) Camp Pendleton. Previously MSHC supported NMCSD with CARB third-party verification of the GHG report submitted which was free of material misstatement and conformed to the state and federal regulatory requirements.

MSHC also assists Navy and Marine Corps facilities in complying with requirements for SF6 gas insulated equipment (GIE) used in electricity transmission and distribution equipment at NBC, NBPL, NBSD, NPS Monterey, NAWS China Lake, NBVC, NWS Seal Beach, NAS Lemoore, MCAGCC Twentynine Palms, MCB Camp Pendleton, Marine Corps Air Station (MCAS) Miramar, and Marine Corps Logistics Base (MCLB) Barstow. We prepare and submit the annual reports via CARB's e-GGRT for all installations.

MSHC supported the U.S. Department of Veterans Affairs (VA) complete their first comprehensive GHG inventory in support of an overall electrification study for their Long Beach VA Medical Center. The inventory included evaluating Scope 1, 2, and 3 GHG emissions. The inventory was used to identify opportunities to eliminate Scope 1 GHG emissions and recommend systems or modifications to be installed or completed.

MSHC prepared the 2022 and 2023 GHG inventory for the Hollywood Burbank Airport in support of their Airport Carbon Accreditation (ACA) Level 2 application. The 2022 submittal was the initial reporting for Burbank Airport and required obtaining historical information to complete the three-year average. The inventory was used to develop emission reduction targets for future years at the airport to steadily decrease its emissions over time. MSHC also led the GHG inventory in support of the submittal of the ACA Level 2 applications for the Long Beach Airport for 2022 and 2023.

Previously, MSHC staff completed a comprehensive fence line-to-fence line GHG assessment for eight MCIWEST installations and Edwards AFB. The projects included the preparation of a GHG assessment report that comprised:

Hazardous Materials/Waste

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EPCRA (Emergency Planning and Community Right-to-Know Act): Tier II and Toxic Release Inventory Reporting

MSHC provides Emergency Planning and Community Right-to-Know Act (EPCRA) annual reporting support for Tier II (also known as SARA 312) and Toxic Release Inventory (also known as SARA 313). The EPCRA regulation acknowledges the public's right to information concerning toxic chemical storage and usage/releases to the environment. EPCRA establishes a framework for reporting the storage and use of listed toxic chemicals from facilities that meet reporting criteria and providing the U.S. Environmental Protection Agency (EPA) with release information to assist the agency in determining the need for future regulations. Facilities required to submit under EPCRA Section 312 must complete Tier II forms (for California facilities, this is covered under the Hazardous Material Business Plan requirements) for each hazardous material that meets reporting criteria. Facilities required to submit a Toxics Release Inventory (TRI) Report under EPCRA Section 313 must complete a Form R for each listed toxic chemical that meets the reporting criteria.

Biennial Hazardous Waste Report

MSHC staff has experience with RCRA Large Quantity Generators (LQG) and filing biennial reports using the RCRAInfo Systems Module. Our staff collaborates with clients to obtain all necessary information, such as hazardous waste manifests, facility information, and waste stream information.

Asbestos and Lead Based Paint

MSHC provides extension of staff to a local utility's Environmental Division, providing project request intake and oversight for asbestos and lead paint safety surveys. Certified Asbestos Consultants are assigned to conduct surveys prior to renovation and demolition. MSCH follows strict safety procedures for electrical exposure and protection since much of the work is near or part of energized high voltage systems and requires lockout/tagout electrical shutdowns. MSHC staff reviews the submitted survey reports for quality using the South Coast Air Quality Management (SCAQMD) checklist for asbestos surveys and comments from the air district staff on submitted surveys. MSHC staff also checks for completeness and accuracy of chain of custody forms, laboratory results, data tables, photos, and diagrams. We have prepared standard operating procedures for submitting survey requests, intake or requests, assignment of CACs, review of survey reports and forwarding results to requestors.

ARARs/CERCLA

Provide regulatory expert for evaluation of applicable or relevant and appropriate requirements (ARARs) for remediation projects. Developed and maintained the Navy Standard Text for ARARs, a client privileged document with consistent Navy positions on RCRA, CERCLA, CWA, CAA ESA, and similar state requirements.

Remediation

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MSHC supports remediation projects, including feasibility studies, air and water permitting and studies, work plans, health and safety plans, regulatory evaluations, and storm water pollution prevention plans. Our staff has expertise permitting emissions from treatment systems and discharges to sanitary/industrial sewer and storm sewer systems and designed and certified water treatment systems. Our regulatory expert staff identify and evaluate federal, state, and local regulations for remediation projects from siting to waste handling, treatment, storage, and disposal, to clean-up levels. MSHC staff has experience preparing SWPPPs (Stormwater Pollution Prevention Plans) for remediation projects and incorporating remediation activities into the BMPs (Best Management Practices), such as using excavations as stormwater BMPs.

Sustainability

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MSHC staff has experience in federal sustainability requirements, most notably Executive Order (EO) 13514. MSHC staff supported developing regional sustainability programs and strategic sustainability performance plans, including:

MSHC staff managed and executed a project to understand and evaluate Marine Corps Installations West's (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, Department of Defense Strategic Sustainability Performance Plan (SSPP), and US Marine Corps SSPP with a 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 meet those mandates. The SMT collects sustainability metrics across each Marine Corps facility in the region and provides real-time analysis on the facility's progress towards meeting the mandates. The SMT rolls up facility sustainability metrics to be viewed at the regional level and has reporting functionality to access specific sustainability metrics. The SMT gives managers and key decision-makers the information needed to prioritize resources 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 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.

Most recently, MSHC supported Paramount Pictures Corporation with waste diversion tracking in an effort to reduce landfill waste.

Water Quality

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MSHC staff has experience with the National Pollutant Discharge Elimination System (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 qualified SWPPP practitioners and developers (QSDs/QSPs), Qualified Industrial Stormwater Practitioners (QISPs), 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 collaborated 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), No Discharge Reports, and reduced sampling frequency. Our trainer of record provides training for all general NPDES permits and has functioned 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 collaborates with vendors to warranty treatment systems that meet 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:

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 680 QSDs-QSPs, over 40 QISPs, over 320 Caltrans Water Pollution Control Managers, and myriad field staff. He has managed NPDES compliance projects, 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, Security Paving, North County Transit Authority, Los Angeles (LA) Metropolitan Water District, LA County Metropolitan Transportation Authority (LA Metro), Marine Corps Installations West (MCIWEST), Turner Construction, and Caltrans. Previously, Mr. Gleason worked for LA County Public Works as an Environmental Compliance Manager.

Check out our Training section for upcoming Stormwater related training!