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Air Permitting & Emissions Modeling

SMG helps maintain compliance with required evaluations and inventories, comprehensive record keeping and reporting obligations. SMG has helped clients begin operations by obtaining authorizations ranging from small source air registrations to complex Title V major source permits. For sites with complex permitting requirements and related impact evaluation, SMG performs required air emissions dispersion modeling and provides recommendations for optimal permitting scenarios that provide operational flexibility.

1/Existing Facility Permitting – Title V Air Permit


PROBLEM

A major source located in Jefferson County, KY was required to renew and update their Title V Operating permit. The facility’s goal was to streamline permit recordkeeping, monitoring and reporting requirements consistent with the facility’s operational practices. In addition, the facility needed to update emissions calculation methodologies for reporting of actual emissions and determination of potential emissions.


SMG'S APPROACH

SMG visited the site, reviewed available information, and helped gather the required data needed to prepare an administratively complete permit application. We collaborated with facility personnel to integrate information from historical applications and internal documents into a Title V permit application package. SMG identified permit conditions which could be relaxed, revised, or removed while maintaining robust compliance demonstration records for regulations applicable to the stationary source. SMG prepared the Title V renewal permit application, met with APCD personnel to expedite the processing, and provided written comments to the client on the draft Title V operating permit.


RESULTS

Emissions reporting was improved using revised calculation methodologies and emissions tracking systems developed by SMG. The updated environmental management tools minimized the potential for calculation errors in regulatory reports and allowed for detailed analysis of facility emissions through custom aggregation tools. Our comprehensive approach allowed the facility to demonstrate compliance with Federal and local APCD emission standards for affected facilities, annual plantwide criteria pollutant emission limits, and daily pollutant emission limits using facility operations data. The application was deemed administratively complete, and we were successful in minimizing required recordkeeping and reporting for the source. MS Access database reports maintained by the facility for production purposes were easily imported into the environmental management tools developed by SMG thereby allowing the client to easily complete emission calculations for numerous affected facilities. The client used the new tools to quickly prepare semiannual monitoring reports and emission inventory submittals required by the local administrator.

2/Air Permitting — Keeping a New Energy project out of PSD Permitting


PROBLEM

A new renewable energy facility was planned to use biomass on a small scale to create electricity. The plan was to stay below the thresholds for “Prevention of Significant Deterioration” permitting that would lengthen the permit time frame dramatically. The project had to be on line in less than 3 years.


SMG'S APPROACH

SMG reviewed air permitting options with the client to determine the best approach. SMG worked with the project design engineers to develop a permit application that would enable the facility to be permitted as a synthetic minor permit, enabling the project to achieve final permits much earlier than predicted. SMG’s relationship with the regulators and proactive management of the permitting process saved time and money for the client.


RESULTS

The permit went through significant revisions with the active engagement of SMG with the regulators. A draft permit was issued within two weeks of notice of a substantially complete application. The project is on schedule to reach its goals.