SES personnel have assisted many clients in attaining Title V, Federally Enforceable State Operating Permits (FESOP), Permit-by-Rule, and State air operating permits in both attainment and non-attainment areas. Industries served include the automotive industry, foundries, bulk petroleum terminal and distribution facilities, metal finishing, electronics manufacturers, hazardous materials remediation facilities, and various other manufacturing facilities.
In addition, SES personnel have continued to support clients with air compliance by maintaining company compliance, bringing non-compliant sources into compliance, reviewing current air permits to determine operation capacity, evaluating potential and current air pollution control equipment, completing required annual air compliance reports, and answering questions about everyday operations.
Highlighted below are examples of specific air permitting and compliance accomplishments.
Integrated Pulp & Paper Mill, Boiler Rebuild - PSD Avoidance
SES personnel evaluated the potential impacts of a recovery boiler rebuild project with respect to EPA’s Prevention of Significant Deterioration (PSD) rule. Emissions netting calculations initially revealed that the planned redesign would have triggered stringent PSD permitting requirements and costly New Source Performance Standards due to a net increase in NOx emissions. Plant management was interested in boosting boiler capacity, while avoiding PSD requirements. This was accomplished by identifying the maximum allowable NOx emissions for the project and coordinating with boiler design engineers to add low-NOx burners to the specifications.
Integrated Pulp & Paper Mill, MACT baseline monitoring & standards development
While USEPA was in the process of developing MACT standards for kraft paper mills, SES personnel coordinated the air & water emissions monitoring of 20+ manufacturing sources at an older mill. The test results were submitted for inclusion in the MACT baseline for similar operations. As a result of this project, the final promulgated rule provided more operating flexibility for existing sources.
National Manufacturer, Title V Permitting
SES personnel coordinated the initial 2-year permitting effort including; stack inventory & mapping, emissions inventory, MRR (monitoring, recordkeeping, and reporting) plans, and compliance certifications for a national manufacturer. An MS Access database was developed to manage the emissions inventory each year or more frequency as required. This tool significantly improved the efficiency of calculating annual emissions & associated permit fees for approximately 300 sources at the manufacturing facility.