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Permitting and ComplianceEES routinely assists clients with preparation and implementation of air quality permitting strategies for new capital projects and plant expansions. We also provide continuing support after permit approval, including design and execution of compliance programs, such as monitoring and recordkeeping, that are required to demonstrate compliance with permit conditions. Specific services that are provided in the context of permitting and compliance projects vary, but generally include some or all of the activities discussed throughout this section. In addition, EES provides:
Permitting and compliance projects typically require
a broad understanding of diverse technical issues, as well as detailed
knowledge of applicable federal, state and local air quality
regulations and knowledge of the policies, procedures and staff of
administering agencies. This
is particularly important as new rules and regulations continue to be
promulgated to implement the 1990 Clean Air Act Amendments.
EES staff has a long history successfully helping clients
address the issues that are the principal focus of new regulatory
requirements, i.e., regulatory analysis and applicability
determinations; Clean Air Act training; development of emissions
inventories; preparation of permit applications; compliance planning,
impact assessment modeling, including accidental release scenarios;
and conformity analyses for federally-funded projects.
We have held more than 25 public and client-specific workshops
nationwide on the requirements of the Clean Air Act for private and
government facilities. Summaries of representative air quality permitting
and compliance projects completed by EES staff are presented below. Regulatory Analysis and Applicability
Determinations Title V Applicability
Determination Continental Coatings EES
engineers estimated a facility-wide emissions inventory for
Continental Coatings and potential to emit scenario to determine the
applicability of Title V permitting.
EES staff revised the facility emission calculations using more
appropriate industry-related engineering calculations and better
representative emission factors that lowered facility-wide emissions
and helped the facility avoid Title V requirements. PSD Applicability
Review and Compliance Plan Development UCAR
Carbon EES
staff developed a Compliance Plan and evaluated PSD applicability for
several air emission sources at UCAR Carbon’s Factory.
The project involved the development of a Best Available
Control Technology (BACT) analysis for NOX
emissions and providing guidance on the development of a proposed
compliance plan for the facility. HAPs Evaluation and
Emissions Inventory Submittal Chevron EES
engineers performed HAPs evaluation for the Chevron blend plant and
distribution center. This
location produces over one million gallons of various oil improvers,
boiler fuels, and oil additives.
Actual and potential-to-emit (PTE) calculation routines were
developed for the HAPs that are generated from blending operations,
storage tanks, and transfer lines.
EES engineers used the most current guidance document prepared
by EPA (AP-42 emission factors for stationary sources) as well as the
EPA software program Tanks 2.0 version to effectively determine the
most applicable emission factors. Permit
Application Preparation Compliance
Demonstration with PTO Vulcan Materials Co. EES staff conducted a comprehensive analysis for a
750 Hp generator to demonstrate compliance with the San Diego air
district emission standards of Rule 69.4.1.
The analysis included emission quantifications using
manufacturer’s specifications and engineering calculations and
analysis of required equipment specifications, record-keeping and
monitoring requirements. EES
engineers were able to show that the engine was exempt from the NOx
standards of Rule 69.4.1 and therefore, was not subject to any add-on
control devices or BACT. Compliance Demonstration with PTO Acco Brands EES staff conducted a comprehensive regulatory
analysis for a shredder, cyclone, and bailer system to demonstrate
compliance with the SCAQMD Rules and Regulations.
The analysis included emission quantifications using
manufacturer’s specifications and engineering calculations, analysis
of applicable rules and compliance requirements, and analysis of the
facility current status with applicable rules and requirements.
The detailed analysis of the system showed that the system can
be exempt from all permitting requirements. Permit
to Operate Application Hanson Aggregates EES
staff prepared a permit application for the installation of a new
aggregate processing and handling system including a grizzly feeder,
jaw and cones crushers, screens, belt conveyors, materials storage,
and dust collection systems. The
project involved emissions quantification, Best Available Control
Technology (BACT) analysis, production of material process flow
diagrams, compliance demonstration with San Diego rules and
regulations, and preparation of a draft permit terms and conditions.
New
Source Review Feasibility Study SeaWorld Adventure Park EES
staff conducted a comprehensive regulatory requirement analysis and
identified necessary controls and emissions offsets required to permit
a 5 MW solar turbine cogeneration facility.
The project involved detailed analysis of the local Air
Pollution Control District (APCD) rules and regulations applicable to
the facility and a comprehensive emissions inventory of all permitted
and non-permitted sources to determine potential available emission
reduction credits that can be generated at the facility level.
New
Source Review Permit Application Lynwood Town Center EES
prepared a permit application for the underground vapor extraction and
treatment system. The
application package included emission calculations of criteria and
toxic pollutants, screening risk assessment for air toxics, and a
comprehensive analysis of applicable SCAQMD rules and regulations. Permitting
Support Services BFGoodrich Aerospace EES
engineers prepared several permit applications for aerospace coating
operations and chemical process tanks.
Applications included engineering drawings, emission
calculations, equipment specifications and controls, applicable rules
and regulations, and analysis of potential risk associated with these
operations. Title
V Permitting Support March AFB EES staff prepared the Title V Permit application for
the March AFB. The base
was occupied at the time by the reserves, Air National Guard, active
duty personnel, and the DoD. Responsibilities
involved developing a comprehensive emissions inventory including
emissions from aircraft, ground support equipment, test cells,
maintenance shops, fuel handling equipment and storage, boilers, paint
booths, and many other activities.
EES staff also developed a master list of applicable federal,
state, and local rules and regulations and monitoring and
record-keeping requirements.
Several alternative operating scenarios were evaluated by EES
staff and included in the permit application increasing operation
flexibility for the base. Title
V Permitting Multiple Facilities/Industries EES staff
managed several projects involving the preparation of Title V Federal
Permit Application in compliance with the Clean Air Act Amendment of
1990. The following is a
list of clients/industries served: (1) two facilities owned by
Riverside Cement Company and located within the jurisdiction of the
South Coast Air Quality Management District (SCAQMD) and the Mojave
Desert Air Quality Management District (MDAQMD), (2) GST Steel Company
located in Kansas City (MO), (3) Huntington Memorial Hospital in
the SCAQMD, (4) four facilities owned by Holnam Cement Company and
located in Artesia (MS), Portland and Fort Collins (CO), and Dundee
(MI); in addition, acted as a technical director for 11 cement
facilities owned by Holnam Inc., (5) two asphalt facilities owned by
Grace Pacific Corporation and located in Honolulu (HI), (6) Gay and
Robinsons sugar plantation facility located in Kauai (HI), (7) VA
Medical Centre in Long Beach (CA) under the jurisdiction of the SCAQMD,
and (8) Cast Alloys Inc. in Northridge under SCAQMD’s
jurisdiction.
Support Services Huntington Memorial Hospital EES
staff managed a master environmental services contract for Huntington
Memorial Hospital providing a broad spectrum of permitting and
environmental compliance services.
EES staff completed Permit to Construct/Operate Applications
for three 1,750-kilowatt emergency diesel generators, two
40,000-gallon underground storage tanks, three chillers, and a cooling
tower. In addition, EES
staff performed a comprehensive air quality and compliance audit
program for the hospital that lead to a streamlined Title V
application submittal. Permit
to Operate Mitsubishi Cement Co. EES
staff prepared a permit to operate application for Mitsubishi Cement
terminal in compliance with the South Coast Air Quality Management
District’s Rules and Regulations.
The project involved source testing of three baghouse vents,
emissions quantification, risk assessment, and compliance
demonstration with applicable district regulations. Compliance
Activities Covanta
Power Pacific Air Quality Compliance
Audit San Diego Unified Port District EES conducted a
comprehensive air quality compliance audit for all the San Diego
Unified Port District facilities including the National City Marine
Terminal, 10th Avenue Marine Terminal, Maintenance and
General Services facility, International Airport including the Central
Power Plant, and the Administration Building.
The Audit included detailed site visits and personnel were
interviewed for data collection and compliance issues.
EES has also developed a master list of existing stationary
permitted and non-permitted equipment, sizes, and equipment
specifications. EES
reviewed existing air permits, analyzed applicable rules and
regulations, and determined compliance monitoring and recordkeeping
requirements. EES drafted
an air quality audit report outlining the findings and recommendations
for corrective actions. EES
also developed air quality compliance demonstration templates to aid
the District track the compliance status of its facilities. Title V Compliance
Demonstration Program Califronia Portland Cement Co. EES engineers designed and managed the development of
a comprehensive compliance and record-keeping templates to streamline
the Title V annual compliance certification process as mandated by the
CAA. Compliance
demonstration methods and procedures as required by applicable rules
and regulations are included in the templates.
Facility personnel to verify the compliance status of the
facility with the Title V permit will use the templates.
EES staff also prepared a Title V compliance binder which
include compliance documents for all monitoring requirements
specifying different methods and procedures to be used (i.e. Method 9,
source testing, etc.), guidance document for record-keeping
requirements and frequency, guidance document for reporting frequency
and requirements, and a comprehensive list of compliance dates.
Also performed a one-day training workshop on-site covering all
elements contained in the compliance demonstration binder.
In addition, EES staff conducted an on-site audit of the
facility’s monitoring, record-keeping, and reporting practices to
ensure that they are being adequately implemented. Environmental
Information Report Al-Jubail Petrochemical Co.
(Kemya) EES
staff managed a multitask and multidiscipline comprehensive
environmental information report (EIR) for the construction and
expansion of a polyethylene facility owned by Al-Jubail Petrochemical
Co. (Kemya) in Saudi Arabia. The
EIR addressed potential environmental impacts on all media (air,
water, solid waste, and others) in compliance with the Royal
Commission (RC) Environmental Regulations.
Through effective interaction and close coordination with
project designers, engineers, and environmental professionals,
environmental compliance issues were resolved at their inception and
appropriate mitigation measures were implemented.
This effort saved the project over 30 percent of the
environmental compliance budget. Responsibilities involved developing project work and
management plans, scheduling and man-hour loading, tracking of
progress reports and percent completion, and interfacing with other
engineering disciplines analyzing the potential environmental impacts
from all process designs and ensuring their compliance with the RC
regulations. General
Compliance Support Services Hallmark
Circuits EES
staff managed a variety of air quality support services including the
preparation of four variances and four permit applications for drill
presses and routing machines. In
addition, EES staff attended the San Diego County APCD hearing board
meetings to support the petition for the variances.
Reviewed the permit application of the Electroless Copper
plating operation to ensure that the final permit terms and conditions
satisfied and met Hallmark objectives with minimum monitoring and
record-keeping requirements. CAA
Transportation Intermodal Study Kirtland
AFB EES
staff conducted a transportation study to determine the best traffic
flow patterns to minimize automobile air pollution.
EES engineers performed air quality analysis to determine
potential impacts on air quality from existing and proposed growth of
vehicular traffic at Kirtland AFB.
The study addressed the impacts of the existing roadway
alignments, circulation, traffic volume during peak periods, level of
service, and intersection queuing analyses.
The study also evaluated the potential future impacts
associated with traffic growth in the event that no changes are made
to current traffic patterns. Environmental
Assessment Kirtland
AFB EES
staff prepared the air quality impact analysis section of the EA
document for the new CV-22 (Osprey) aircraft flights and beddown
operations. Impact
analysis addressed the replacement of 11 aging MH‑53 helicopters
with 7 new CV-22 tilt-rotor aircraft.
The analysis accounted for the associated personnel increases
and renovation activities as well. Project
Health Safety and Environmental Review (PHSER) Kuwait-Oil
Co. EES
engineers conducted a comprehensive study and a review of the
environmental and engineering design criteria for a gas processing and
purification facility owned by Kuwait-Oil.
The objective of the study was to ensure that the design
proceeded in a manner that minimized risk to the facility and its
workers, minimized adverse impact to the environment, and ensured
technical integrity. |
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