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EES 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:
• Comparative permitting studies
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 listed to the right.
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.
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.
Permitting 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.
Title V Permitting Supports
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 Support
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.
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.
Control Technology Assessment
Covanta Power Pacific EES performed a technology and regulatory assessment of emissions control technologies for engine (power generators) retrofits and engine modifications, back-end and post combustion control technologies, and engine replacements. EES also outlined budgetary estimates of control technologies assessed and prepared a technical report detailing the findings and results of the assessment.
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. |
Overview
Title V Applicability Determination PSD Applicability Review and Compliance Plan Development HAPs Evaluation and Emissions Inventory Submittal Compliance Demonstration with PTO Permit to Operate Application New Source Review Feasibility Study New Source Review Permit Application Permitting Support Services Title V Permitting Support Permit to Operate Control Technology Assessment Air Quality Compliance Audit Title V Compliance Demonstration Program Environmental Information Report General Compliance Support Services CAA Transportation Intermodal Study Environmental Assessment Project Health Safety and Environmental Review (PHSER) |