Air Compliance Management Services
Posted on August 5, 2015
Client: Compendium of Private Sector and Municipal Clients
Project Type: Air Compliance Management Services
- Title V Air Permitting
- Emission Statements
- Emission Reduction Credits
- Environmental Compliance Audits
- Air Quality Compliance
- Air Emission Control Technology Evaluations
As a result of the Clean Air Act Amendments of 1990, air quality management has become an increasingly important environmental issue. The firm has been providing air compliance management services to industrial clients and small business concerns since the passage of the Clean Air Act in 1970. Projects undertaken by the firm have ranged from a small business with a single emission point to multi-facility compliance programs involving literally hundreds of point sources. The firm has expertise with federal, state and local regulatory programs to provide air quality management services with respect to compliance audits, regulatory compliance strategies, air permitting, air quality impact analyses, sampling and monitoring, pollution control technology evaluation and design, preparation of emission reduction credit (ERC) applications, accidental release prevention and RCRA air emission programs.
The firm has provided air quality management services for the following private sector clients among other municipalities and public authorities:
• Northrop Grumman Corporation
• Clean Water of New York, Inc.
• Newsday, Inc.
• Safety-Kleen Corporation
• Altana Incorporated
• Robert Martin Corporation
• Burns and Ricker, Inc.
• EDO Corporation
• Regence Picture Frames, Inc.
• T.J. Ronan Corporation
• International Business Machines Corporation
Northrop Grumman Corporation
Air Compliance Management Services, Various Facilities
Northrop Grumman Corporation (NGC), one of the nation’s leading aerospace defense contractors, operates facilities throughout the U.S. which have been used for the manufacture of various aircraft and aerospace systems, as well as other defense systems and civilian projects. As a result of the extensive new regulatory requirements affecting emission sources in New York State, the firm was selected to provide comprehensive air compliance management services to NGC for its Bethpage and Great River, New York, facilities. These facilities cumulatively represented over 500 air emission sources. The firm has also provided air compliance management services at Northrop Grumman’s Calverton, New York, and Benton Park, Pennsylvania, facilities.
Air Compliance Management – Bethpage and Great River, New York
The firm performed extensive air compliance management services in support of process operations at these facilities, including the following:
• The firm conducted a comprehensive audit to compile information regarding existing air emission sources, and to identify the current and proposed regulatory requirements which were applicable to the facility.
• The firm conducted comprehensive site inspections of both facilities to determine the nature and status of each source.
• As part of the audit process, permit information was supplemented with interviews of on-site personnel and review of technical information, including process diagrams and equipment drawings, operating records and test reports.
• During this phase of the project, a representative of the firm was in residence at NGC’s Bethpage facility.
• Emission estimates were performed and comprehensive emission inventories were prepared for both facilities.
• The firm completed a detailed review and assessment of federal and state environmental regulations which the facility was potentially subject to, in order to develop a management strategy to achieve compliance with the regulations.
CSP Low NOx Burner Air Permitting – Bethpage, New York
The firm prepared air permit applications for four 95 million BTU/hr dual fuel steam boilers at the Bethpage, New York facility Central Steam Plant. The permit applications were prepared in support of the facility’s 6 NYCRR 227 RACT compliance plan which included the installation of low NOx burners.
As part of this effort, the firm prepared estimates of hourly and annual emissions of combustion related compounds using USEPA and vendor supplied emission factors and projected use of each fuel (natural gas and fuel oil). The applications were approved by NYSDEC without comment, allowing the retrofit of the boilers to proceed on schedule.
Corporate Environmental Audit – Bethpage, New York
The firm was retained in support of a corporate environmental audit conducted at the Bethpage Facility. The firm’s responsibilities consisted of providing information and engineering and technical assistance relating to air quality issues during the pre-audit, audit and post-audit phases.
Plant 5 Air Permitting – Bethpage, New York
The firm prepared permit to construct/certificate to operate applications for several process operations associated with Plant 5 in Bethpage, New York. The firm performed a site inspection prior to installation of the equipment and reviewed information regarding the proposed process equipment.
Emission estimates were prepared based on a review of the materials used, knowledge of the processes, and anticipated operating schedules. An air quality impact evaluation was performed using NYSDEC Air Guide-1 procedures to predict the maximum off-site ground level concentration of each air contaminant.
Plant 10 Air Permitting – Bethpage, New York
The firm prepared permit to construct/certificate to operate applications for numerous laboratory exhausts located at Plant 10. The firm completed a site inspection, reviewed information regarding associated process equipment and compiled an inventory of the chemicals used by each laboratory exhaust. Emission estimates were prepared based on the physical properties and the projected use of approximately 40 chemicals. An air quality impact evaluation was undertaken using the refined screening modeling procedures outlined in the NYSDEC Air Guide-1 guidance document to predict the maximum off-site ground level concentration of each air contaminant.
Emission Statements – Bethpage, New York
The firm was retained to prepare the 1995 Emission Statement for the Bethpage facility in accordance with 6 NYCRR Part 202 requirements. The emission statement provides NYSDEC with an annual inventory of emissions from major facilities and certain other regulated facilities.
The emission inventory prepared by the firm was used to develop a comprehensive list of operating emission sources and identify the scope of the emission statement. Based on the initial work, the firm interviewed operating personnel to obtain critical information, such as operating schedules, quantities of materials actually used, and operating parameters. If the desired information was not available, the firm prepared emission estimates using secondary information (e.g., storage and waste quantities). Emission estimate calculations were then performed for dozens of operating sources and the Emission Statement was completed by the firm on behalf of NGC.
The firm also prepared the 1997 Emission Statement. The firm reviewed the source inventory previously prepared to determine whether permitted and exempt sources were shut down or modified. A site inspection was performed to obtain operating information on existing sources, and to determine whether any new sources commenced operation since the preparation of the previous emission statement.
Emission Reduction Credits – Bethpage, New York
A preliminary assessment of the potential quantity of NOx and VOC Emission Reduction Credits (ERCs) was initially conducted for the Bethpage Facility. The firm also performed a market assessment of the potential for sale of ERCs resulting from the curtailment or shutdown of NGC operations, and prepared estimates of the potential value of the ERCs based on recent sales within in the Northeast Ozone Transport Region. The firm has also provided NGC with updated information regarding emission reduction credit regulations and market opportunities.
Based on these efforts, the firm was directed to prepare ERC applications for a number of VOC sources. The sources consisted of coating processes and degreasers formerly operated at the facility. The firm reviewed detailed records of chemical formulations and usage to estimate actual emissions prior to planned shutdown. The firm prepared, and subsequently negotiated with NYSDEC Region 1, a strategy to estimate emissions eligible to be credited. As a result, the firm was able to secure a total of 11.5 tons of VOC ERCs on behalf of NGC.
Title V Air Permitting – Bethpage and Great River, New York
The firm was initially selected to perform an analysis of the applicability of the Part 201 operating permit (i.e., Title V) regulations to the Bethpage and Great River facilities. The purpose of the analysis was to determine whether Title V requirements were applicable and to explore options for capping emissions at each facility. The assessment concluded that the Bethpage Facility would require a Title V permit due to the total emission potential of NOx from operating boilers. The Great River Facility was determined to be exempt from the Title V operating permit requirements.
Based on this determination, the firm was requested to prepare the Phase I Title V application for the Bethpage Facility. The Phase I application consisted of a facility description, identification of federal regulations applicable to the facility, a summary of all regulated pollutants emitted from the facility and an identification of those pollutants for which the facility exceeds a Title V major source threshold.
The firm was also requested to prepare the final Title V application. The application identified federal and state regulations applicable to each source at the facility. In addition, monitoring conditions were developed to ensure enforceable compliance. A comprehensive inventory of emissions was also included in the application.
Calverton Steam Plant – Calverton, New York
The firm was retained to provide air compliance management services for the Naval Weapons Industrial Reserve Plant in Calverton, New York. NGC operated a steam plant at this facility on behalf of the U.S. Navy. The steam plant consists of three new No. 6 fuel oil-fired steam boilers, which were installed to replace the original coal-fired boilers. The boilers were fitted with low NOx burners to comply with the reasonably available control technology (RACT) requirements of 6 NYCRR Part 227.
In support of compliance efforts associated with the permit to construct, the firm completed the following activities:
• Prepared the Preliminary Monitoring Plan (PMP) for the opacity continuous emission monitoring system (COMS) installed on two 58-MMBtu/hr boilers. The PMP provided information regarding the performance specifications of the CEMS and the proposed installation. It also provided QA/QC procedures to be followed.
• Prepared specifications for the procurement of stack performance testing and COMS certification testing services. Procurement assistance was also provided to identify eligible testing firms, review the qualifications of bidders, and assist in the selection of the lowest bidder.
• Provided regulatory assistance regarding aspects of the permit to construct. The firm reviewed the permit to construct and successfully negotiated the elimination of several special conditions regarding performance testing and operating requirements. This reduced the testing and operating costs associated with the steam plant. In addition, the firm provided NGC with a detailed assessment of the fuel oil sulfur sampling required by federal regulations (i.e., 40 CFR 60 Dc).
The firm also provided engineering oversight during the performance testing phase, including the review of all protocols and reports prepared by the testing services contractor, and on-site witnessing of emission tests. In addition, the firm provided technical guidance to ensure that facility operation and monitoring satisfy the applicable regulatory requirements.
Air Compliance Report – Benton Park, Pennsylvania
The Benton Park, Pennsylvania, facility is involved in the testing, integration and repair of printed circuit boards (PCBs) produced by other NGC facilities. The firm was retained by NGC in support of a corporate environmental audit to be conducted at the facility. To assist facility personnel in preparing for the audit, the firm was responsible for preparing an Air Compliance Report that provided a review of the facility’s air emission sources and their compliance status with respect to federal and state regulations.
Clean Water of New York, Inc.
Air Quality Management Services, Staten Island, New York
Clean Water of New York, Inc. (CWNY) is a permitted New York State waste oil reprocessing/ recycling and storage facility located in Staten Island, New York. A major function of the facility, among numerous others, is to separate water and oil recovered from barges which are transported to the facility for cleaning and/or servicing. The firm was retained by CWNY to conduct an air compliance assessment at its facility. The purpose of the assessment was to determine the facility’s compliance status with respect to USEPA, NYSDEC and NYCDEP air quality regulations.
The firm initially conducted a site inspection to identify operating emission sources. Operating information was obtained for each source identified during the site inspection which consisted of combustion sources such as boilers, space heaters and internal combustion engines, and process emission sources associated with the waste oil reprocessing operations. Emissions of regulated compounds were estimated using published emission factors or process mass balance information. A comprehensive regulatory review was then conducted to determine the potential applicability of U.S. Coast Guard, USEPA, NYSDEC and NYCDEP regulations to the facility. Based on the results of the assessment, a number of emission sources requiring state and/or local permits were identified.
During the next phase of the project, the firm prepared permit applications for regulated processes. A state facility permit application was prepared and submitted to NYSDEC. The purpose of the state facility application was to cap emissions of nitrogen oxides (NOx) below the Title V major source threshold. In order to ensure compliance with the emission limit specified under the emission cap, monitoring conditions were developed to calculate monthly NOx emissions through fuel and equipment usage record keeping. NYCDEP permits and registrations applications were prepared for a number of process and combustion emission sources.
Pinelawn Facility, Air Permitting and Compliance, Melville, New York
Approximately 700,000 newspapers are printed daily at Newsday’s 500,000-square foot Pinelawn Facility located in Melville, New York. The firm was initially selected to provide environmental engineering services with an independent, detailed analysis of the environmental programs in place at the facility. The firm used a team of environmental engineers to inspect the Pinelawn Facility, review pertinent records, evaluate and report on Newsday’s environmental compliance efforts, as well as prepare specific recommendations for enhancing compliance efforts. The scope of the audit included an evaluation of existing environmental programs, including air quality. A regulatory review was conducted with respect to the following federal, state and local regulations:
• 40 CFR Part 60 Subpart Dc – Standards of Performance for Small Industrial – Commercial – Institutional Steam Generating Units
• 40 CFR Part 82 – Protection of Stratospheric Ozone
• 6 NYCRR Part 201 – Permits and Registrations
• 6 NYCRR Subpart 202-2 – Emission Statements
• 6 NYCRR Part 212 – General Process Emission Sources
• 6 NYCRR Part 225 – Fuel Composition and Use
• 6 NYCRR Part 227 – Stationary Combustion Installations
• 6 NYCRR Part 234 – Graphic Arts
The recommendations of the audit included proceeding with the preparation of a state facility permit application, in order to cap emissions of regulated pollutants (e.g., nitrogen oxides) below Title V major source thresholds. Based on the audit, Newsday requested the firm to proceed with preparing a state facility permit application. The application included a listing of specific regulations applicable to the facility and detailed calculations for regulated pollutants. In addition, the application presented a description of the procedures to be used to demonstrate compliance with the facility emission cap, as well as compliance strategies for meeting other emission limits.
Air Quality Compliance and Permitting Services, Buffalo, New York
The firm was retained by Safety-Kleen Corp., recognized throughout North America as a leader in waste oil recycling, in connection with the permitting of a 150-million gallon per year reprocessing facility in Buffalo, New York. The primary functions of the Katherine Street facility include the removal of water from used oil and treatment of nonhazardous wastewater. Major unit operations include used oil receiving, storage, emulsion breaking and dehydration; wastewater pretreatment and discharge; and reprocessed oil shipment.
In support of air permitting and compliance efforts, the firm performed the following activities:
• The firm initially performed a detailed review of Safety-Kleen’s air permit files, including existing and former facility permits. After reviewing this information, the firm conducted an inspection of each process are at the facility in order to identify all emission sources and discharge points and to confirm the information contained in existing air permits.
• Air emission estimate calculations were prepared by the firm and an emissions inventory was prepared in support of applicability determinations with respect to 6 NYCRR Part 212 and 6 NYCRR Part 227 RACT regulations and proposed regulations implementing the Operating Permit requirements of Title V of the Clean Air Act Amendments of 1990 (i.e., 6 NYCRR Part 201).
• Air permit applications were prepared for one industrial boiler and a dehydration process vent.
The firm was also successful in negotiating exemptions for storage tank vents, as well as air emission vents on wastewater pretreatment equipment.
Environmental Compliance Audit, Nassau and Suffolk Counties, New York
Altana Incorporated, a manufacturer of pharmaceutical products, selected the firm to conduct an environmental audit at its facilities in Melville and Hicksville, New York. Both of the facilities are used to manufacture various pharmaceutical oils and creams.
The firm conducted a multimedia compliance audit of each facility, including an environmental compliance audit of air contamination source activities. Regarding air quality, the following tasks were performed:
• On-site inspections of both facilities to identify sources of air contamination; and
• Regulatory review to identify applicable federal, state and local air quality regulations. This included review of the following specific regulations:
— 40 CFR 60 Db and Dc – New Source Performance Standards for Steam Generating Units
— 6 NYCRR Part 201 – Construction and Operating Permits
— 6 NYCRR Part 212 – General Process Emission Sources
— 6 NYCRR Part 227 – Stationary Combustion Installations
— 6 NYCRR Part 233 – Pharmaceutical and Manufacturing Processes
Areas of potential non-compliance were identified in a compliance audit report. In addition, where appropriate, specific recommendations for corrective action were developed.
Robert Martin Corporation
Air Quality Assessment and Permitting Services, Pearl River, New York
Robert Martin Corporation, a real estate owner/operator headquartered in Westchester County, New York, selected the firm to provide engineering and environmental services associated with one of its properties, Blue Hill Plaza, located in Pearl River, Rockland County, New York. Blue Hill Plaza is a large commercial office complex which includes a central steam plant consisting of three commercial-size steam generating boilers which provide heating and cooling comfort to the complex’s occupants.
The firm provided the following services for this project:
• Completed an environmental audit of the Blue Hill steam plant boilers which included a site inspection, interviews with operators regarding the history and operation of the boilers and a review of fuel-use information.
• Completed a review of federal, state and local regulations, as well as preliminary emissions calculations to complete regulatory applicability determinations.
• Determined that the boilers required a certificate to operate in accordance with 6 NYCRR Part 201.
• Determined that the facility could “cap out” of otherwise applicable 6 NYCRR 227-2 reasonably available control technology (RACT) requirements for stationary combustion installations, as well as Title V Operating Permit requirements, without compromising operational demands at the steam plant.
• Prepared the necessary 6 NYCRR 201 applications for certificates to operate. The firm reviewed existing engineering drawings to complete the permit applications. Historical fuel use information was used to develop projected maximum annual use of natural gas and fuel oil, and to calculate emission rates of combustion related compounds.
The permit application included a federally enforceable emission cap based on a 12-month rolling average fuel use limit, in accordance with the guidance provided in NYSDEC Air Guide-10. This allows Robert Martin Corp. to continue operating the steam plant without retrofitting the unit to meet RACT requirements. In addition, Title V permitting was avoided by applying for the emission cap.
Burns and Ricker, Inc.
Air Permitting Services, South Brunswick, New Jersey
Burns and Ricker own a number of food production facilities, including a facility in South Brunswick, New Jersey operated by B&G Foods, which produces snack foods. The firm was retained to prepare air permits for the relocation of and installation of process equipment to this facility. The firm initially performed a site inspection of the facility to identify sources of air emissions and obtain process information. The purpose of the visit was also to identify the location and arrangement of the relocated process equipment and related exhaust systems.
Permit applications were prepared for a total of five emission sources, representing thirteen emission points, and were submitted to the New Jersey Department of Environmental Protection (NJDEP).
Air Quality Compliance and Permitting Program, College Point, New York
The EDO Corporation College Point facility is a Department of Defense contractor which manufactures a “sled” which is towed along the surface of the water by a Navy helicopter for the purpose of identifying and destroying mines. EDO retained the firm to provide engineering services related to assuring compliance with various air emission requirements at the federal, New York State and local New York City level. The goal of the program was to achieve compliance with all applicable federal, state and local emission standards without requiring the installation of sophisticated emission control equipment.
The firm provided the following services for this project:
• Conducted a detailed audit of the entire manufacturing operation at the EDO College Point facility. This included inspections of the various manufacturing operations in order to identify all existing emission sources. Activities such as spray painting operations, powder coating, soldering and welding were evaluated for potential emission sources.
• Completed emission calculations identifying applicable regulatory requirements to support the preparation of air permit applications.
• Prepared detailed engineering drawings to identify how emissions were generated, captured, and conveyed to an emission point.
Overall, inspection services, preparation of engineering drawings and detailed emission calculations were completed for 57 emission points. Based on these initial calculations, in certain cases, reformulated products such as paint and epoxy with lower volatile organic compound concentrations, and soldering products with alternative chemical constituents were utilized in lieu of recommending the design of emission controls.
Regence Picture Frames, Inc.
Air Permitting Services, Queens, New York
The firm was retained by Regence Picture Frames, Inc. for the permitting of two coating spray booths at its Queens, New York, manufacturing facility. The firm’s activities on this project included the following:
• Conducted an environmental audit at the facility to identify applicable air quality regulations and inspect the emission points in support of permitting efforts.
• Completed a regulatory review to identify the control, monitoring, reporting and record keeping requirements applicable to each emission point.
• Prepared and submitted an application for a permit to construct/certificate to operate a process, exhaust or ventilation system for each of the two coating spray booths in accordance with regulatory requirements.
Based on the information obtained from the environmental audit, the firm developed process equipment drawings and plot plans which were submitted along with the permit applications.
T.J. Ronan Paint Corporation
Air Permitting Services, Bronx, New York
T.J. Ronan Corporation operates a paint manufacturing facility located in Bronx, New York. In support of the manufacturing operation, the firm was retained to conduct an audit to determine compliance with applicable emission regulations. Based on the findings of the audit, the firm prepared complete applications for a permit to construct/certificate to operate a process, exhaust or ventilation system for the following emission points:
• Three gravity storage vents associated with a number of storage tanks; and
• Two building exhausts used to provide ventilation for various paint mixing areas in the building.
International Business Machines Corporation
Air Emission Control Technology Evaluation, East Fishkill, New York
The firm provided support to the facilities engineering department at the East Fishkill facility regarding the upgrade of existing control technology associated with the emission of volatile organic compounds (VOCs) from various on-site processes. Five air abatement technologies were assessed by the firm, including recuperative, regenerative and catalytic incineration, carbon adsorption and a Brayton cycle heat pump system. The technologies were evaluated based on effectiveness, capital cost, operating and maintenance cost, and regulatory permit requirements for a number of different contaminant loading scenarios and various design parameters.
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