ZMassociates is an expert in Federal and California Environmental Impact Analysis, including performing CEQA/NEPA required analysis, studies, and technical report preparation.

ZMassociates has 15 years of experience in writing EIR and EIS reports and performing detailed technical studies. Staff provide the utmost diligence in following guidelines and making sure all data, information, figures, and tables are accurate. We are experts in human health risk assessment for large-scale construction projects and in performing complex detailed research and analysis of air quality criteria pollutant levels, toxic air pollutants, and conformity analysis for fine particulate and carbon monoxide.

ZMassociates staff put much thought and care into writing of CEQA/NEPA documents.  Delivering a quality product every time.

Project: Sunrise Powerlink Project –CEQA/NEPA EIR/EIS Review and Analysis Regarding Construction Air Emissions and GHG Mitigation Implementation 

ZMassociates staff reviewed this complex and demanding EIR/EIS and recalculated a detailed air study for this massive project. ZMassociates performed complex detailed research for emission factors for a long list of onroad and offroad vehicles to update GHG and criteria pollutant emissions estimates for a large utility project in Southern California.  This included large, medium, and small helicopters, non-conventional construction vehicles, and updated emission factors for offroad engines being upgraded or retrofitted for the project.  ZMassociates easily modeled the update to better reflect specifics of the project as planned, allowing for significant reduction in EIR/EIS calculated emissions.  This detailed work provided documented, defensible, and accurate estimates of the project emissions, putting the client in a position to better negotiate project emission offsets and mitigation measures.

Project:  CEQA/NEPA Documents
Mitigation Measures Ranked by Cost-Effectiveness and Emission Reductions
(subcontractor to Camp, Dresser and McKee and URS Corporation) 

ZMassociates completed an extensive prioritization of emission reduction strategies while preparing air quality and environmental justice portions of the Environmental Impact Report and EIS for the Modernization of Los Angeles International Airport.

ZMassociates completed all construction-related air quality analyses for the EIR and EIS and Supplemental EIR prepared for Los Angeles World Airport’s LAX project.  The project included hundreds of pages of spreadsheet calculations broken out by each day of a 15-year construction buildout.  Off-road engine factors along with SCAQMD CEQA Handbook data was used to complete the analyses.   These calculations include numerous combinations of on-road (i.e. truck and bus) calculations and emissions from off-road engines (ie. generators and construction equipment).

The project also included extensive evaluation of proposed emission reduction technologies including, but not limited to:  new engines, emulsified fuels, low-sulfur diesel fuel and after combustion technologies such as diesel oxidation catalysts and PM filter traps.    ZMassociates reviewed and ranked over 100 mitigation measures as part of this task.  Measures were evaluated on a cost-effectiveness basis; with cost-effectiveness expressed on a cost per ton of diesel PM10 and NOx reduced. 

As part of these reports, ZMassociates prepared draft deliverables consisting of, 1)  a written summary of each suggested measure and the assumptions used to derive each cost estimate;  2)  an Excel spreadsheet outlining the range of potential costs and emission reductions associated with each measure; and 3)  back-up documentation including all references used (i.e. websites, telephone logs, emails from vendors, site visit notes, etc.).   Deliverables were presented in both electronic and hard-copy formats. 

Project:  San Diego International Airport Site Mitigation – CEQA/NEPA document
ZMassociates assisted CDM by providing cost estimates for various air quality mitigation measures.  Measures include diesel reduction technologies such as:  switching to LNG and CNG fueled trucks and vehicles; use of alternative fueled generators and off-peak delivery trips.  ZMassociates reviewed and ranked over 40 mitigation measures as part of this task.  Measures were researched and ranked based on costs. 

Provide Air Quality and GHG Technical Report 

ZMassociates prepared and Air Quality and GHG technical report that presented a screening-level evaluation of anticipated emissions for criteria pollutants as well as GHGs; possible mitigation options; and evaluation of significance under CEQA with and without mitigation incorporated. The report focused on construction-period emissions but included a brief assessment of the potential for operational impacts related to criteria pollutants and GHG. Evaluation methods were consistent with the City of San Diego’s adopted emission factors and modeling protocols. 

Expert legal services

ZMassociates provides expert legal services to help you try to settle your case before it goes to trial. 

In most cases, we do just that – keep you out of a long and arduous court battle.

CEO Thomas Miller has over 15 years of experience serving as an expert witness on environmental legal cases. Mr. Miller provides support in environmental justice, wrongful death, and hazardous waste cases. The ZMassociates team provides expert legal services support in  the form of background research, technical data gathering and analysis, and report writing.  With the backing and research of his expert staff, Mr. Miller works to keep your legal battle as short and sweet as possible.

Examples of Expert Legal Services Provided

Martha Custer, et al., vs. Cerro Flow Products, Inc., 2017 – 2018

Mr. Miller was retained as an expert witness, produced a detailed Expert Report, and was deposed by defendants.  The case is scheduled for trial in February 2018, where Mr. Miller will be an expert witness. Mr. Miller and ZMassociates provided air dispersion modeling demonstrating the air emission dispersion pattern from historic process air emissions from Cerro Copper secondary copper smelter operations, over a 50-year time span.  Mr. Miller used the U.S. EPA AERMOD air dispersion model to show that Cerro Copper process emissions created an unacceptable dioxin and furan exposure for at least 19 plaintiffs living down-wind of the Cerro operations.

Tom Johansen, et al. vs. Noranda Mining, Inc., et al, in the District Court of the Sixth Judicial District of the State of Idaho, In and for the County of Bannock, Case No. CV-10-2173-PI., 2012-2013

Mr. Miller was retained as an expert witness, produced a detailed Expert Report. and was deposed by defendant’s attorneys and experts. The case was settled out of court, in part due to Mr. Miller’s expert report and analysis results forcing the mining companies to settle the case rather than go to trial. Mr. Miller and ZMassociates provided expert forensic chemical research, analysis, dispersion modeling and human health risk analysis supporting plaintiff exposure and medical injury claims of injury due to exposures of toxic metals emitted, transported, and leached from the Blackbird Cobalt mine operations, in Salmon, Idaho.  Mr. Miller’s work was backed with good science, good data, and utilization of state of the art forensic analysis and contaminant modeling protocols.

Rosanne Borsch, et al. vs. Chevron Corporation, et al./ Lead Case No. YC 056077 and Julie Murray, et al. v. Chevron Corporation, et al. Case No. YC 056221, Los Angeles County Superior Court., July 2009

Mr. Miller was retained as an expert witness, produced a detailed Expert Report, and was deposed by defendant’s legal team.  The case was settled out of court, due to Mr. Miller’s in-depth technical report showing that Greka Energy was not culpable for the alleged plaintiff exposures.  In fact, Mr. Miller demonstrated that plaintiff exposures to workplace toxins were more likely to have caused the fatal illness that the plaintiffs experienced.

Mr. Miller and ZMassociates provided in-depth research on plaintiff claims, potential chemical exposures, routes of exposure, risk analysis, modeling, and a summary expert opinion report.  Due the extensive work by ZMassociates in concert with great legal representation, the case was settled before going to trial.

Orchard View Farms, Inc. vs. Martin Marietta Aluminum, Inc., No. 73-3080 (9th Cir. June 23, 1975)

Mr. Miller was retained as an expert witness.  Mr. Miller prepared a detailed Expert Report and was deposed by defendant’s legal team.  The case was temporarily referred to mediation by the court.

Mr. Miller provided background research and technical data for legal arguments during the lengthy jury trial. This work included compiling more than 10 years of complex ambient air monitoring data, plant air discharge data, and meteorological data, and literature search, statistical analysis, modeling support, and strategy and opinion papers.

Air & Hazardous Waste Permitting

Getting a permit is a long and arduous process.

We at ZMassociates work to simplify and expedite this process, saving you time and money!

Our Air Quality & Hazardous Waste Permitting Experience and Services:

ZMassociates is a leader in air and hazardous waste permitting. Mr.Thomas Miller’s extensive background in industrial process chemistry, working within industry and government regulatory agencies, developing and managing environmental programs.  ZMassociates has developed a large working knowledge of air and hazardous waste permitting, compliance assistance, auditing, and training.

We work alongside businesses to provide detailed guidance through application or application renewal for a variety of permits including:

        • Air Quality Permit to Construct
        • Air Quality Discharge Permit
        • Title V Air Quality Permit
        • Part B Hazardous Waste Permit
        • Hazardous Waste Unit Closure and Post-Closure Permit
        • Waste Pile, Surface Impoundment, Tanks, and various specialty treatment units
        • Permit Modifications

Staying up-to-date on the current regulations, we help businesses make strategic changes to their policies and procedures. In turn, this reduces the regulatory burden and complexity of the permit application.

We also provide auditing services, utilizing government permitting checklists. This helps ensure that your business is complying with all laws and regulations which may affect you.

Past air and hazardous waste permitting work

Honeywell Torrance Title V and RECLAIM Permit Management and Updates

Baldwin Park Operable Unit Air Quality Permit Updates and Air Emission Testing from Six Air Stripper and Activated Carbon Treatment Units

Lawrence Livermore National Laboratory – Leading Preparation of the Hazardous Waste Part B TSDF Permit Application.  ZMassociates staff led preparation of the Renewal Application for the RCRA TSDF Part B Hazardous Waste Permit.  Due to our substantial regulatory experience, ZMassociates was able to effectively guide the client through the massive regulatory requirements to prepare this 11-volume renewal application.  Our staff experts were instrumental in making strategic changes that reduced the regulatory burden and the complexity of the permit application.  Reducing the unnecessary content and detail in the permit application resulted in less-stringent conditions in the final approved operating permit. The permitting agency is the California Department of Toxic Substance Control (DTSC), with oversight review by the U.S. EPA.  In addition to leading preparation, ZMassociates acted as auditor by reviewing the permit application using DTSC’s RCRA Permit checklist.

Lawrence Berkeley National Laboratory Library Permit Renewal Application – Performing Phase 1 preparation of the Part A and B Permit renewal application for the Lawrence Berkeley National Laboratory Library Hazardous Waste Handling Facility. During Phase 1 preparation, ZMassociates staff developed a detailed list of options for Lawrence Berkeley National Library (LBNL) to evaluate that addressed Parts A and B Hazardous Waste Permit Renewal Application due to Department of Toxic Substances Control application in April 2016. Options were based on analysis of technical documents provided by LBNL, an on-site visit and communications with LBNL staff.

air and hazardous waste permitting at Lawrence Livermore National Laboratory

Air dispersion modeling

One of our favorite areas of work here at ZMassociates is air dispersion modeling.

ZMassociates tackles the industry’s toughest air dispersion modeling projects primarily utilizing Lakes AERMOD software.

We research meteorological and historic emissions data to produce the most accurate and reliable air dispersion models.

Working with engineers and government officials, we make sure that our models are accurate and comply with regulations.

Examples of our Air Dispersion Modeling work

ZMassociates set precedence when performing the nation’s first federal EPA conformity analysis modeling. Modeling was determined for a 65-mile long proposed highway project spanning from Palmdale to Victorville, California.  Though the PM10 & PM2.5 EPA conformity analysis rule was not scheduled to be implemented at the beginning of the project, EPA and Caltrans required conformity analysis for this project due to its relevance and precedence-setting character.

ZMassociates performed the emissions inventory for mobile and stationary sources, obtained relevant MET data suitable for AERMOD analysis, evaluated terrain and downwash characteristics of the project, and set up and ran AERMOD in modular sections representative of the project route.  We ran and modeled several alternative routings using EMFAC2007 and EMFAC2011 for traffic data sets covering all of the segments and intersections of the project.  High-speed rail analysis was included into the project analysis.  AERMOD was set up using line-volume for the mobile sources and point and area sources for stationary sources within a two mile distance of the project route.  Due to the length of the proposed highway, the project was split into four sections and analyzed accordingly.

The EIR/EIS technical reports will include a summary of environmental impacts and mitigation measures, methodology, affected environment, environmental consequences (operational and construction), cumulative impacts analysis, and appendices, as necessary. Some outlines for the technical studies may vary due to specific requirements of a particular environmental topic. The methodology will include a discussion of the methods used to conduct the analysis, measures used to define the study area, regulatory requirements, and any NEPA or CEQA significance criteria specific to the environmental topic. Both the potential operational and construction impacts will be discussed as part of the environmental consequences. Potential mitigation measures will also be identified. All technical reports will be based on the Environmental Methodology Guidelines Version 5. 

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