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air quality Support Services

Air Management Program Compliance Support

Turn to DSG Solutions in Shoreline, WA and Gardner, MA for the professional assistance you require to stay in compliance with various state and federal air quality regulations. Take advantage of our tailored air management support services so you know that your facility is in compliance. Whether you need air compliance reporting, monitoring plan, or QA/QC Plan development, training or auditing assistance, our team can help.

Our Air Management Support Services

Let DSG Solutions be your air management program’s regulatory expert to help you with whatever air quality programs you may be dealing with, such as:

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Acid Rain Program
Cross State Air Pollution Rule
Title V Air Operating Permit Compliance
State Air Permit Compliance
Regional Greenhouse Gas Initiative
Mandatory Greenhouse Gas Reporting Rule

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New Source Performance Standards
National Emission Standards for Hazardous Air Pollutants
State Air Emissions Monitoring Regulations
Compliance Assurance Monitoring
Parametric Emissions Monitoring

Ask About Our Air Management Support Services

Should you have any questions about the air management support services we offer, please let us know. We are here to gladly discuss the details of our business with you. Give us a call or send us an email to schedule an appointment with our air management support experts.

DSG combines regulatory expertise, an acute attention to detail, day-to-day experience with various DAHS software packages, and the technical background to provide services in the following general categories:

COVID-19 STAFFING RISK MANAGEMENT

We are available to support air management and air compliance reporting activities due to potential staffing shortages related to COVID-19. We can help develop a site-specific air compliance reporting risk mitigation plan, provide routine CEMS/COMS data review and/or provide last minute air compliance reporting support. To minimize risk during these challenging times, our staff is providing continued and uninterrupted support to our clients from home. We know that working remotely is not an option for everyone, so having DSG Solutions provide remote support either in a backup/reserve capacity or as an active part of your air management project team can help minimize risk with meeting your company's numerous on-going air compliance regulatory deadlines.

Please remember that we work nationwide and are here to help "So You Can Breathe Easy."

AIR MANAGEMENT PROGRAM AND DAHS AUDITS

DSG Solutions can work with a facility to develop an audit scope of work that can address immediate concerns within a facility’s air management program. We have experience in performing general air compliance regulatory audits, air permit compliance audits, as well as DAHS configuration compliance audits that can focus on Part 75, Part 60, Part 63, and state reporting concerns. Typically, after developing a defined and applicable audit scope of work, our company will prepare an informational request to prepare for the audit. Although a site visit may not be needed depending upon the scope of work, we recommend that we spend some time on site to interview appropriate personnel and to observe the internal group dynamics governing a facility’s air management program. Following an audit, we will provide an audit-findings report that may include sections such as compliance findings, general audit recommendations, DAHS configuration update recommendations, or CEMS configuration update recommendations. If you are considering an air management compliance audit, please contact us and we will work with you to develop an audit scope of work to meet your facility’s needs.

Paper Download:

Data Acquisition and Handling System (DAHS) Emissions Compliance and Regulatory Audit Recipe for Large Combustion Units Equipped with Continuous Emission Monitoring Systems (CEMS) and Continuous Opacity Monitoring Systems (COMS)

TRAINING

DSG Solutions has experience providing site-specific training sessions in the following CEMS/air management areas:

New, Revised, and Refresher Air Permit Compliance Training

We can distil complicated facility air permits, including operating permits, into a training session focused on specific facility needs that may include reviewing air compliance emission limits, monitoring, recordkeeping, and/or reporting requirements. This training session duration depends on the complexity of a facility but typically varies between 2 to 4 hours.

DAHS Functionality Training

We can develop a site-specific training session focusing on topics, such as general DAHS overview, compliance channels and configuration, DAHS data entry procedures, and reporting configuration review. This training session can be developed for different site personnel that interacts with the DAHS software. Depending upon the training session scope, this training typically varies between 2 to 8 hours.

Operator Regulatory Training

We can prepare a site-specific air compliance training session geared towards the facility’s operational staff focusing on air permit emission limits, facility emissions monitoring configuration, and other operator CEMS/air management specific recordkeeping and reporting responsibilities. This training session is typically designed to be between 2 to 3 hours in duration and can be presented more than once to allow the entire operational staff the chance to participate.

I&C Technician Regulatory Training

We can prepare a site-specific CEMS training session focused on the needs of a facility’s I&C technicians that may include detailed discussions on CEMS quality assurance testing requirements and procedures, CEMS preventive maintenance activities and post-maintenance QA testing requirements, CEMS quality control activities, as well as other I&C CEMS/air management specific recordkeeping and reporting responsibilities. This training session can be developed to be between 3 to 8 hours in duration depending on the training scope.

Environmental Manager Regulatory Training

We can develop a site-specific training session for managers that oversee a facility’s CEMS/air management program that can focus on each or any of the major portions of the program. The training can focus on reviewing and defining operational staff responsibilities, I&C technicians responsibilities, environmental manager responsibilities, reviewing a facility’s air permit and CEMS compliance obligations, as well as developing requested procedures to help improve a facility’s CEMS/air management program. This training can be developed to be between 4 to 8 hours in duration depending upon the training scope.

If you are considering a site-specific CEMS/air management training session, please contact us so that we can work together to develop a training session that focuses on your immediate needs and concerns.

DATA ANALYTICS

DSG Solutions can help improve an air emissions management program using data-driven assessments and comprehensive feedback. We have extensive experience with:

Verifying historical air compliance submittals and DAHS configuration accuracy
Modeling mass emissions during unsteady operations using historical CEMS data
Performing thorough reviews of CEMS and DAHS data flow and calculations
Estimating emissions due to recently discovered CEMS/DAHS configuration problems
Forecasting emissions and fuel use for alternative operating and fuel use scenarios
Evaluating anomalies in CEMS data due to analyzer/sensor malfunction or performance degradation
Conducting historical CEMS data assessments to characterize and/or identify trends in emissions and operation
Evaluating and quantifying compliance risk and impacts from newer regulations

Considering our expertise with CEMS and DAHS data, we are available to help with any challenging data analysis project.

Development of Startup/Shutdown DURATION AND Emission Limits Based Upon CEMS Data

There is a continued trend by state agencies to implement startup and shutdown duration and emission limits and we can assist with the preparation of proposed limits. We have developed a method based upon a statistical method, the upper prediction bound, to objectively determine limits from historical site-specific CEMS data. We originally presented this method at the 2009 Annual AWMA Conference & Exhibition during an extended abstract presentation entitled, “Development of Startup and Shutdown Permit Limits Based Upon Historical Data From Combustion Sources Monitored by Continuous Emission Monitoring Systems.” Most recently, we presented updates to this method at the 2020 Annual Conference and Exhibition (ACE) that was held virtually on June 29 - July 2, 2020 in a paper and presentation entitled, "Startup and Shutdown Air Permit Limit Development Framework for Combustion Sources Monitored by Continuous Emission Monitoring Systems." Aditya Shivkumar won the award for 2020 Best Your Professional Paper in the Industrial, Power and Government Sectors group.

2020 Paper Download: Startup and Shutdown Air Permit Limit Development Framework for Combustion Sources Monitored by Continuous Emission Monitoring Systems

2009 Paper Download: Development of Startup and Shutdown Permit Limits Based Upon Historical Data From Combustion Sources Monitored By Continuous Emission Monitoring Systems

MONITORING PLANS

Part 75

DSG Solutions has extensive experience reviewing, updating, and developing Part 75 CEMS electronic and hardcopy monitoring plans. Electronic monitoring plans are submitted as a section within the Part 75 Electronic Data Reports (EDRs) and describe the Part 75 monitoring methodology at a facility. Information within the electronic monitoring plan includes combustion source identification information, analyzer identification information, and applicable equations to calculate required mass emissions that may include NO_x, SO₂, and CO₂. Also included are analyzer configuration information, such as span and range values as well as default values, including the diluent cap, maximum potential concentration (MPC), maximum emission rate (MER), maximum potential stack flow rate (MPF), or maximum potential fuel flow rate(s). An annual general review of Part 75 electronic monitoring plans is recommended to verify the plan reflects recent historical data and current monitoring information. Annual Part 75 analyzer span/range evaluations are required and can be completed along with a general review of the electronic monitoring plan.

A hardcopy Part 75 monitoring plan is required to describe the electronic monitoring plan information. For example, a discussion of the monitoring methodology including a monitoring configuration schematic and a data flow summary diagram are required. In addition, the hardcopy monitoring plan is required to include supporting calculations to justify current span/range analyzer settings, as well as any relevant site-specific current electronic monitoring plan default values such as the MPC, MER, MPF, and fuel factor(s). If you are working towards reviewing and updating your Part 75 electronic and/or hardcopy monitoring plan(s), please contact us.

Part 98

The 40 CFR 98 Mandatory Greenhouse Gas Reporting Rule requires the development of a Monitoring Plan. Part 98 requires the monitoring of CO₂, CH₄, and N₂O for general stationary combustion sources, including Part 75 combustion units. The Part 98 Monitoring Plan requirements include a description of the responsible site personnel, an explanation of the methods used to collect necessary data for the emissions calculations, applicable monitoring and calculation methodologies, as well as a description of the CEMS QA/QC procedures. If you need assistance developing a Part 98 Monitoring Plan, please do not hesitate to contact us.

Part 63

The 40 CFR 63 National Emission Standards for Hazardous Air Pollutants (NESHAP) rules require the development of a CEMS or a Continuous Parameter Monitoring System (CPMS) Monitoring Plan. The Part 63 Monitoring Plans may need to include a description of the monitoring system design, sampling location(s), monitoring equipment accuracy/performance specification(s), data collection, ongoing quality assurance and quality control elements, as well as acceptable passing criteria and recordkeeping/reporting requirements. If you need assistance developing a Part 63 Monitoring Plan, please contact us.

Part 60

Although not required by 40 CFR 60 New Source Performance Standards (NSPS) Rules, maintaining a Part 60 monitoring plan is recommended as part of a robust CEMS/air management program and can be an important document to have available during an inspection by an air regulatory agency. If you would like assistance developing a Part 60 Monitoring Plan, please contact us.

QUALITY ASSURANCE / QUALITY CONTROL (QA/QC) PLANS

DSG Solutions can also help review and update Part 60, Part 63, and Part 75 CEMS Quality Assurance / Quality Control (QA/QC) Plans as these are living documents that are required to be maintained to reflect a facility’s currently installed emissions monitoring equipment. CEMS QA/QC Plans are required by certain states to be reviewed annually and, in general, CEMS QA/QC Plans are required to be reviewed and updated for many reasons, including recertification projects requiring analyzer replacements. A general annual review of a facility’s CEMS QA/QC Plan is recommended.

DSG Solutions can review and update a CEMS QA/QC Plan to satisfy current Part 60 and Part 75 regulatory requirements. If your CEMS QA/QC Plan has not been updated recently, let us know and we can update your Plan to satisfy the regulatory requirements that apply to your facility.

DSG Solutions can also help improve a facility’s QA/QC Plan by transforming the document, from a Plan that satisfies regulatory requirements to a Plan that can be referred to regularly by personnel responsible for maintaining and overseeing a CEMS program. We can work with you to help strengthen your CEMS QA/QC program by identifying any weaknesses that may be strengthened through improving specific sections of your CEMS QA/QC Plan. Examples include:

Developing a CEMS Responsibilities Section
Improving QA Testing Procedures
Improving QC Procedures
Developing an In-Depth Post-Maintenance QA Testing Section Required by EPA and Certain State Agencies
Reviewing and Updating a Facility’s Spare Parts Inventory
For Facilities With Add-On Controls, Developing a Section Documenting the Parameters Monitored to Justify the Use of Standard Part 75 Missing Data Procedures
Developing a Detailed Reporting Section That Can Include Specific DAHS Procedures

If you are working towards improving your CEMS QA/QC program, revisiting your facility’s CEMS QA/QC Plan, along with re-/training appropriate personnel, please contact us.

40 CFR 75 ELECTRONIC DATA REPORTS (EDR)

DSG Solutions provides expert 40 CFR 75 Electronic Data Reports (EDRs) support to our clients. We have extensive Part 75 EDR experience with many types of facilities, including coal/gas/oil fired boilers, gas/oil fired combustion turbines with and without supplemental duct firing, common stack configurations, common pipe configurations, Low Mass Emission (LME) units, and Appendix E units. Throughout the years, we have supported our clients with many challenging EDR projects, including CEMS re-/certifications, stack flow to fuel metering monitoring conversions, EDR configuration updates such as implementing add-on emission control parametric monitoring for proper missing data procedures, analyzer span/scale range updates, and electronic monitoring plan reviews and updates.

We have over 40 years of combined EDR experience, so if you are looking for help with your EDRs, you have come to the right place. We pride ourselves in supporting each of our clients with any level of assistance needed, from preparing a facility’s quarterly EDRs on a regular basis to simply reviewing EDRs prior to submittal. We can also help a facility better improve their EDR preparation and review process. We can prepare Part 75 quality assurance (QA) test occurrence summaries to help assure CEMS QA tests are completed on time, from typical to complicated monitoring systems that may include rotating fuel meters or like-kind analyzers. We can help review DAHS data entry procedures for parameters, such as monthly natural gas GCV, fuel oil GCV, sulfur, or density, as well as quality assurance test data. Throughout the years, we have had extensive correspondence with EPA’s Clean Air Markets Division on challenging EDR projects, and we find this experience invaluable when working on projects that require agency interaction. We also actively participate in the EPA Emissions Collection and Monitoring Plan System (ECMPS) software shared database users group to aid with the continued ECMPS software development.

If you need help of any kind with your quarterly Part 75 EDRs, including assistance with the ECMPS software, please contact us so that we can help restore confidence in your EDR preparation process and submittals.

40 CFR 60 NSPS REPORTS

DSG Solutions provides expert 40 CFR 60 New Source Performance Standards (NSPS) Excess Emissions and Monitoring System Performance Reports (EEMPRs) support to many of our clients. For this reason, we have extensive Part 60 NSPS reporting experience that includes Subpart D, Da, Db and Dc, Subpart J, Subpart GG, and Subpart KKKK. The EEMPRs summarize time periods of both CEMS excess emissions events and periods when the applicable CEMS is non-operational and follow the prescribed template within 40 CFR 60.7. Throughout the years, we have helped implement NSPS reporting requirements for new facilities or for facilities that may have overlooked certain aspects of their NSPS reporting requirements.

The United States Environmental Protection Agency’s 40 CFR 60 air emissions regulations have undergone revisions which may necessitate updates to your EEMPRs. For example, the Part 60 data validation criteria were revised in 2007 to mimic the Part 75 quadrant rule. In response to these updates, facilities should review and perhaps revise their EEMPR DAHS reporting configurations.

We can prepare a facility’s quarterly and/or semiannual Part 60 EEMPRs, help configure required EEMPRs for newly installed combustion units, work with a facility to review EEMPRs prior to submittal, help with a general DAHS EEMPR review, or help in any way to support a facility’s current NSPS reporting concerns.

If you need help preparing or configuring your quarterly or semiannual EEMPRs, please contact us for assistance.

40 CFR 63 NESHAP RULES

DSG Solutions provides expert support for 40 CFR 63 National Emission Standards for Hazardous Air Pollutants (NESHAP) Rules including Subpart ZZZZ (RICE NESHAP), Subpart DDDDD (Major Source Boiler MACT), Subpart UUUUU (MATS), and Subpart JJJJJJ (Area Source Boiler MACT). We have followed the development of each of these rules, including providing comments to EPA on the proposed regulations as well as attending meetings, workshops, and webinars focusing on the compliance timelines and requirements. We can help facilities review the NESHAP regulations for applicable emission standards and provide guidance on monitoring, testing, recordkeeping, and reporting requirements including assistance with the EPA's Compliance and Emissions Data Reporting Interface (CEDRI). Importantly, we can help determine if your facility is a Major or Area Source of HAPs; the first step in determining which regulations apply. If you are working to bring a facility into compliance with one of the newer NESHAP regulations or are trying to determine whether a Subpart applies to any of your combustion units, please contact us.

STATE QUARTERLY REPORTING

States typically have CEMS monitoring and reporting requirements in addition to federal requirements which may require separate CEMS quarterly reports to document a facility’s compliance status with short-term and long-term emission limits. However, state short-term emission limits CEMS reports can have many different required formats, from reports that mimic the typical Part 60 NSPS reports to very detailed hourly emissions reports. In addition, 12-month rolling or 365-day rolling emissions reports are required at many facilities and recordkeeping, and reporting requirements are typically overseen by state agencies. DSG Solutions has extensive experience supporting both short-term and long-term emissions CEMS reporting requirements. We have helped to review DAHS configurations regarding a facility’s current state reporting requirements, implement new reports for existing facilities that have worked through air permit modifications that either require new (e.g. startup or shutdown) or modified emission limits, and implement DAHS reports for regulatory updates. We can help review your current DAHS reports configuration, review your quarterly reports prior to submittal, or prepare your quarterly reports on an ongoing basis.

DSG Solutions has extensive experience with individual state CEMS monitoring and reporting requirements within numerous states, including California, Hawaii, Massachusetts, New York, New Jersey, Pennsylvania, Rhode Island, and Texas. However, if you are in another state and need assistance, please contact us and we can work with you regarding your state reporting concerns.

TITLE V OPERATING PERMIT SEMIANNUAL AND ANNUAL REPORTS

DSG Solutions has extensive experience assisting facilities with their operating permit reporting requirements. We assist many of our clients with their ongoing semiannual and annual operating permit reports. We have assisted numerous clients that received their initial Title V Operating Permit develop and implement a semiannual and annual operating reporting template and process. For complicated facilities that are overseen by numerous personnel, we have prepared documents to assign operating permit provisions to specific personnel in efforts to help simplify the semiannual and annual reporting submittals and to clarify an individual’s operating permit responsibilities. If you oversee a facility limited by a Title V Operating Permit and need assistance with your submittals that may include developing, improving, or reviewing your reporting requirements, please contact us.

ANNUAL EMISSION STATEMENTS

DSG Solutions has extensive experience and assists many of our clients with preparing their annual emission statements. These reports, which are required by state agencies, typically follow a state-specific reporting format and summarize the annual emissions from stationary combustion sources at a facility. These reports can include emissions from larger Part 60 and Part 75 sources to very small combustion sources such as small natural gas fired boilers or heaters that do not require air permits. We currently prepare a wide variety of annual emission statements, from reports that include a single stationary combustion source to a report that includes well over a hundred stationary combustion sources. We have helped facilities improve their annual emission statement reporting process by reviewing documentation supporting prior submittals and developing recommendations. Because we have a detailed understanding of various Data Acquisition and Handling System (DAHS) software packages we can review, update, and configure DAHS reports that improve the annual emission statement reporting process. Since we have extensive experience preparing annual emission statements, as well as other CEMS reports, we can prepare a submittal and help streamline the preparation process by requesting minimal information from the facility. If you need assistance with reviewing or preparing your upcoming annual emissions statement, please contact us.

GREENHOUSE GAS RULES

DSG Solutions can help support monitoring, recordkeeping, and reporting requirements associated with the federal 40 CFR 98 Mandatory Greenhouse Gas Reporting Rule, the Regional Greenhouse Gas Initiative (RGGI), as well as state-specific greenhouse gas reporting rules. Part 98 requires the monitoring of CO₂, CH₄, and N₂O for general stationary combustion sources including Part 75 combustion units. Part 98 affects facilities that emit more than 25,000 metric tons of CO₂equivalence (CO_2e). RGGI affects electric generating units serving generators ≥ 25MW in ten eastern states. The Massachusetts greenhouse gas reporting rule affects facilities that emit more than 5,000 tons of CO_2e and California’s greenhouse gas cap-and-trade program covers major sources of GHG emissions such as refineries, power plants, and industrial facilities.

State, regional, and federal greenhouse gas rules are developing and being implemented at a fast pace including EPA’s phase-in approach of the Tailoring Rule that was promulgated as a result of actions to regulate GHGs under the Clean Air Act. DSG Solutions can help facilities review and implement a greenhouse gas reporting program based upon applicable regulatory requirements. Considering each rule affects different combustion units and has different monitoring and reporting requirements, DSG Solutions can help untangle the rapidly developing greenhouse gas regulations as they apply to your facility. If you are working towards implementing or improving your facility’s greenhouse gas reporting process, please contact us.

AS-NEEDED SUPPORT

DSG Solutions can also assist with numerous other CEMS/air management activities that include:

12-Month or 365-Day Rolling Emissions

We can help manage long-term emission limits and operating hour restrictions recordkeeping and reporting requirements. We can review current methodologies and/or develop new recordkeeping methods for new facilities or new limits. We also have experience assisting facilities automate their long-term emission limit recordkeeping and reporting requirements within DAHS software.

Out-of-the-Office Emissions Review

Considering operating permits typically require permit deviation notifications to state agencies within a short timeframe, such as within two business days, DSG Solutions can help review emissions when a facility’s environmental manager is out of the office. We can also prepare deviation reports for submittal in the case of an emissions permit deviation. If you are going on vacation or will be unable to review your facility’s emissions please contact us so that we can help.

Parametric Emission Monitoring System (PEMS) Reports

We also support PEMS and can help review DAHS configurations and prepare regulatory submittals. If you are looking for assistance with your PEMS please contact us.

If you have any other CEMS/air management program concerns, please contact us and we can discuss whether we can be of assistance. We always do our best to help clients with their immediate CEMS/air management needs..