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.
A permitted manufacturing facility in Kentucky had stopped using equipment and wanted to make operational changes which were not reflected on their air permit. Large old boilers which had not been used for several years were still active on the site’s air permit. Additionally, the facility wanted to increase operating hours for certain affected facilities.
The old boilers were the reason that the site had federally enforceable limits for sulfur dioxide in their permit and were subject to the National Emission Standard for Hazardous Air Pollutants for Industrial, Commercial, and Institutional Boilers Area Sources. This status resulted in additional requirements, higher monitoring and reporting costs, and higher fees to the regulatory agency. Changes to operations required a reevaluation of the site’s potential emissions.
Smith Management Group evaluated the permit requirements and operational data. SMG calculated the potential to emit without the large boilers and with the expanded hours. SMG’s assisted the facility in updating the correspondence and permit with the regulatory authority to change the facility status to minor source.
SMG helped the source update their air permit to represent current site conditions and allow for expanded operations. The source fully decommissioned the large oil boilers in place, successfully transitioned from a permit with federal limits (FEDOOP/FESOP) to a minor source permit and updated their potential-to-emit calculations to represent new operating parameters. These changes saved the facility money in monitoring, reporting, and fees and also allowed for expanded operations in compliance with air regulations.
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 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.
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.
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 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.
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.