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Mr. Billy DeWitt, Air Monitoring Program Manager, at Louisville Metro Air Pollution Control District (APCD) presented an update on recent progress related to toxic air contaminants (TACs) monitoring and the recommissioning of an automated-gas chromatograph system (Auto-GC) during the January 16th, 2019, APCD Board meeting.  The presentation can be downloaded at this link.  The January presentation was a follow-up to the Air Toxics Auto-GC Update presentation in November, 2018.

The first APCD ambient air monitoring station to be outfitted with an Auto‑GC is the Louisville Police Firearms Training site located at 4201 Algonquin Parkway.  The Auto‑GC was initially installed in September 2017 and was reinstalled after system upgrades in December 2018.  The Auto‑GC is providing APCD with near real-time volatile organic compound (VOC) concentrations at the Louisville Police Firearms Training site.  Seventeen (17) VOCs (Primarily Category 1 TACs) are currently monitored; APCD plans to monitor additional VOCs in the future.

Operation and calibration of an Auto‑GC unit is very complicated work.  Standard operating procedures are being vetted; improvements to calibration systems/procedures are pending; and APCD is actively working to address data quality concerns.  System upgrades, including a longer GC column, are planned to address issues related to temperature control, humidity, and coelution.

Future plans include a second Auto-GC unit for installation at the Cannons Lane Photochemical Assessment Monitoring Stations (PAMS) site.   Additionally, APCD plans to report near real‑time data of the Auto-GC results to the Louisville Air Watch website.  Preliminary 1,3-butadiene monthly average concentrations and monthly maximum concentrations summaries were presented for the Louisville Police Firearms Training monitoring site between November 2017 and September 2018.  Successful operation of the Auto-GC units will greatly expand the ambient air quality data available for monitored areas and will potentially provide critical information in the event of an emergency release in or near monitored areas.  Visit the APCD Air Toxics Monitoring Program website  to check for updated information.

SMG routinely assists clients with air permitting and air permit compliance.  Contact me for more information at 502-587-6482 x 211 or pattym@smithmanage.com.

January 16, 2019


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Environmental Management & Engineering

New Facility Permitting


A large alcoholic beverage company was planning to construct a distillery along a lake in Kentucky and use the fresh limestone water for bourbon production. The proposed site was a former farm with historic activities dating back to the 1880s. A water intake structure was required in the lake and along the adjacent shoreline which was owned by others. Several ephemeral and intermittent streams would be impacted by the construction. The client needed a US Army Corps of Engineers (USACE) Clean Water Act (CWA) Section 404 Permit, a Kentucky Division of Water 401 Water Quality Certification, a water withdrawal permit, a permit for construction in and along a stream, and a construction stormwater permit. Additionally, an air permit was required prior to construction for the aging warehouses, distillery equipment, and other emission units. Evaluation for cultural and historic resources and endangered species evaluations were required under the National Environmental Policy Act (NEPA) and Endangered Species Act (ESA).
As the construction proceeded and operations began, a number of operating permits and environmental and hazardous materials compliance plans were required. The project required coordination with the nearby city for drinking water use and industrial wastewater pretreatment and discharge. Recordkeeping and reporting were needed prior to facility personnel being mobilized to the site. Set up and management of environmental systems during the transition to full operations was needed.


During the planning and initial construction phases, SMG managed the environmental permitting and environmental compliance for the site. The process involved application preparation and coordination with multiple regulatory agencies including the USACE, Kentucky Division of Water, Kentucky Division of Air Quality, US Fish and Wildlife Services, Kentucky Department of Fish and Wildlife Resources, Kentucky Heritage Council, and local agencies. Permits included stream mitigation, cultural and historic resources investigation, coordination with state and federal Fish and Wildlife agencies, and State 401 water quality certification, and the Section 404 permit, which required wetland and stream delineation. SMG coordinated with the client’s project team to minimize stream impacts and to adhere to the schedule by expediting the permit processing. State stream construction, water withdrawal, and air permits were also obtained. SMG provided onsite observation to assess contractor compliance with the stormwater permit and managed environmental permit reporting.
During the later construction phase, SMG managed the environmental permitting and compliance for the new distillery. The initial environmental and hazardous material compliance plans (GPP, HMPC, and SWPPP) were prepared and applications for operating permits, such as industrial wastewater pretreatment and discharge and industrial stormwater discharge, were readied and submitted. SMG provided training to the initial employees regarding hazardous material management and groundwater/stormwater protection. SMG worked with the new Risk Manager for the site to transition responsibility for environmental and hazardous material compliance.


SMG’s management of the environmental planning and permitting for the facility, successfully supported the construction schedule and managed environmental compliance for the initial site operations. SMG continued to work with the owner to obtain remaining operational permits and to transition environmental compliance responsibilities to the new facility staff to support startup and initial operations. The facility was completed on schedule and provides a significant economic benefit to the surrounding community.