Projects

PSD and Title V Permitting. 
Vehicle Assembly Plant (Ohio).

Managed and implemented preparation of a Prevention of Significant Deterioration (PSD) application for volatile organic compound (VOC) emissions from a new paint system with new thermal oxidizer. Work that was performed for the construction and modification of air emissions units at this vehicle assembly facility included emissions calculations, capture efficiency demonstration evaluation, Permit to Install (PTI) application, Ohio air toxics modeling, Best Available Control Technology (BACT) analysis, Title V Significant Permit Modification, PSD avoidance for PM₁₀ and NO_X, writing draft PSD PTI terms and conditions (T&Cs) for Ohio EPA, and permit negotiation with Ohio Environmental Protection Agency (Ohio EPA). Worked with client and Ohio EPA to design monitoring/recordkeeping program to fit client’s needs. Key issues for this project were working with client and project design firm to submit timely application, and attaining quick permit issuance from Ohio EPA. Also assisted client with reviewing Title V permit and provided comments/modifications to provide client with more flexible, less restrictive and burdensome permit. Also assisted client with managing compliance stack testing for permit compliance demonstration.

PSD Avoidance and Title V Permitting.   
General Dynamics Land Systems (Lima, Ohio).

Developed facility-wide air emissions inventory to document emissions and permit status/applicability and to identify permitting gaps for all emissions units at this U.S. Department of Defense/U.S. Army land and amphibious combat vehicle and systems assembly facility.  Prepared synthetic minor PTI applications to avoid PSD permitting for several emissions units/projects, including developing strategies to avoid PSD for each project.  Also prepared Title V modification applications for each project, and Title V renewal application for entire facility.  Negotiated all permits with Ohio EPA on behalf of GDLS.  Prepared annual Title V fee reports.  Assisted with preparing initial Air Services Facility Profile for use in subsequent permit-related submittals to Ohio EPA.  Also assisted facility with attaining compliance with Mandatory Greenhouse Gas (GHG) Reporting Rule, including applicability determination, Monitoring Plan preparation, recordkeeping system development, and annual reporting.

NSR Avoidance and Title V Permitting.   
Wausau Paper (Middletown, Ohio).

Managed and implemented preparation of a synthetic minor PTI application for avoidance of Major New Source Review (NSR), including both PSD and non-attainment NSR (NANSR) for PM/PM10, SO2, NOX, VOC, and CO emissions for a major plant expansion including new de-inking and paper production lines, new natural gas boiler, and modifications to coal boilers.  Developed new emissions calculation methods for VOC using mass balance and vapor-liquid equilibrium methods and for PM/PM10 using historical tests and future estimates.  Through strategic and creative emissions calculation/netting methods, avoided PSD and NANSR for a project that greatly increased plant production capacity.  Project also included PTI application, Ohio air toxics modeling, Title V Significant Permit Modification, writing draft PTI T&Cs for Ohio EPA, negotiation of PTI requirements with Ohio EPA, and assistance with developing a specialized emissions testing program to demonstrate compliance with PTI.

Enforcement Resolution, Agency Negotiation, and Synthetic Minor Permitting. 
The Ruscoe Company (Akron, Ohio).

Developed a facility-wide air emissions inventory for sealant and adhesive manufacturing facility, based on chemical-specific factors, including designing and implementing a customized testing program to develop emissions factors for specific criteria and hazardous pollutants.  This data was then used to interpolate/extrapolate emissions factors for several additional chemical pollutants.  Prepared PTI and Federally Enforceable State Operating Permit (FESOP) applications, performed air dispersion modeling, and developed complex requirements and associated monitoring/recordkeeping strategies to avoid Title V and Maximum Achievable Control Technology (MACT) requirements and to maintain compliance with applicable regulations/requirements for applicable emission units.  Assisted Ohio EPA in drafting PTI and FESOP T&Cs for applicable operations.  Negotiated with Ohio EPA to develop permitting and compliance strategies, including resolution of enforcement case.  Later prepared Federally Enforceable Permit to Install and Operate (FEPTIO) applications for permit renewals, and to simplify permit requirements based on reduced facility emissions.  Also prepared annual fee reports and quarterly deviation reports for applicable operations.  Prepared initial Air Services Facility Profile for use in subsequent permit-related submittals to Ohio EPA.

PSD Avoidance and Title V Permitting.   
Chemical Manufacturing Facility (Ohio).

Developed facility-wide air emissions inventory to document emissions and permit status/applicability and to identify permitting gaps for all air emissions units at this inorganic chemical manufacturing facility.  Prepared synthetic minor PTI applications to avoid PSD permitting for several facility expansion projects.  PSD avoidance strategies included use of “actual-to-projected-actual” test along with “could have accommodated” emissions estimates from NSR Reform rules.  Permitting projects also included dispersion modeling for criteria and air toxic emissions.  Also prepared Title V modification applications for each project, Title V renewal application for entire facility, and annual Title V fee reports.  Negotiated all permits with Ohio EPA on behalf of client.  Assisted with preparing initial Air Services Facility Profile for use in subsequent permit-related submittals to Ohio EPA.  Also assisted facility with attaining compliance with Mandatory GHG Reporting Rule, including applicability determination, Monitoring Plan preparation, recordkeeping system development, and annual reporting.

Air Permitting and Regulatory Support.     
Food Preparation Company (Ohio).

Developed facility-wide air emissions inventory to document emissions and permit status/applicability and to identify permitting gaps for all emissions units at this food preparation facility. Prepared several Permit to Install and Operate (PTIO) and General Permit (GP) applications and Permit-by-Rule (PBR) notifications. Determined applicability and requirements of several federal regulatory programs (i.e., NSPS, MACT) to client’s operations. Negotiated all permits with Ohio EPA on behalf of client. Also provided technical memo describing permit (non-)applicability and regulatory justification for all emissions units at the facility.

Enforcement Resolution, Agency Negotiation, Synthetic Minor Permitting.     
Verantis Environmental Solutions Group (LaGrange, Ohio) (formerly Ceilcote Air Pollution Control).

Developed a facility-wide air emissions inventory for fiberglass reinforced plastics composites production facility. Negotiated with Ohio EPA to determine permitting strategies, including resolution of enforcement case.  Prepared PTI and FESOP applications, performed air dispersion modeling, and developed monitoring/recordkeeping strategies to maintain compliance with regulations for emission units. Developed monitoring/recordkeeping spreadsheet tracking system to assist client in demonstrating ongoing compliance with permit T&Cs. Later prepared Federally Enforceable Permit to Install and Operate (FEPTIO) applications for permit renewals, and to simplify permit requirements based on reduced facility emissions. Also prepared annual fee reports and quarterly deviation reports for applicable operations. Prepared initial Air Services Facility Profile for use in subsequent permit-related submittals to Ohio EPA.

Permitting and Compliance Assistance.     
Johns Manville (Ohio, Indiana, Georgia, Texas, California).

Provided fiberglass manufacturer with wide variety of compliance assistance, including air permitting, on-site environmental, health and safety (EHS) assistance, and data management services, as follows:

• Air Permitting – Provided four Title V facilities in Ohio with air permitting assistance, including PTIs, PSD-avoidance, Title V permit modifications/renewals, and permit negotiation.
• On-Site EHS Assistance – Managed staff to provide four facilities in Indiana, Georgia, Texas and California with extended on-site EHS assistance during manager transition periods, to perform gap analyses and attain/maintain compliance.
• Data Management – Assisted two Title V facilities in Ohio with creating data monitoring/recordkeeping system for large Title V permits (>1,000 pages), and developed a comprehensive database program to manage all Title V-related monitoring tasks, house all recordkeeping data, and create all regulatory deviation reports for Ohio EPA.
  

MACT Compliance Assistance.     
INEOS (Lima, Ohio).

Assisted chemical manufacturing facility with auditing to determine applicability, requirements, and compliance with various MACT standards, including Cyanide Chemicals, Miscellaneous Organic Chemical Manufacturing (MON), Organic Liquid Distribution (OLD), and Hazardous Organic NESHAP (HON) (Subparts YY, FFFF, EEEE, and F/G/H/I, respectively).  Assisted with preparation of Notification of Compliance Status (NOCS), Startup, Shutdown, and Malfunction Plans (SSMP), periodic reports, and other documentation.  Assisted facility with annual Title V fee reports and with several air permitting projects, including identification of regulatory status of all air emissions units for entire facility and Title V renewal application and permit negotiation.


Air Dispersion Modeling.     
Laboratory Facility (Ohio).

Conducted air dispersion modeling study to determine existence and extent of predicted exceedances of ACGIH TLV-TWA concentrations of an air toxic pollutant from a proposed new operation. Modeling was conducted using SCREEN3, using many model runs to create a 3-dimensional receptor grid to predict locations/distances from the stack which could exceed applicable ACGIH TLV-TWA concentrations, in order to prevent employee exposure to elevated airborne pollutant concentrations. Model results were converted to a color-coded graphical summary to enable efficient review of model results.


Title V Permitting and Air Permit Management.     
Thomson Consumer Electronics, Inc. (aka RCA – Circleville, Ohio).

Prepared an electronic database to manage Title V permit compliance, including task management, data recordkeeping, and reporting functionality.  Updated the facility-wide air emissions inventory, prepared a Title V permit application, reviewed the draft Title V permit, and negotiated with Ohio EPA regarding revisions to Title V permit on behalf of this glass television tube manufacturing facility.  Also managed permit status of several emission units throughout the facility, adding some new permits and purging several old permits.  A key element of the Title V permit negotiation was incorporating current regulations with historical verbal agreements between Thomson and Ohio EPA.


Title V Annual Compliance Certifications.     
Ashland/Marathon (Illinois, Pennsylvania, West Virginia, Georgia).

Assisted several specialty chemicals manufacturing facilities with performing detailed annual air audits of compliance with Title V permits and federal and state/local air regulations, providing complete written results of the evaluations and any findings and recommendations, and completing annual Title V Compliance Certification forms for submittal to appropriate state/local agencies.


Title V Annual Fee Reports.     
Lafarge North America (Paulding, Ohio).

Assisted portland cement manufacturing facility with creating system to document all emissions calculations for all emissions units from 1995 to present (including emission factors, throughputs, control efficiencies, etc.), and preparing annual Title V fee reports for submittal to Ohio EPA. Also assisted facility with negotiating and obtaining PTIs and Title V modifications for several projects, some on expedited basis (for one project, obtained final PTI within four weeks of initial contact with client about project), and with Consent Decree compliance. Also assisted facility with determining requirements of 40 CFR 75 Subpart D (Continuous Emission Monitoring – Missing Data Substitution Procedures).

Synthetic Minor and Minor Source Air Permitting.     
American Standard, Inc. (Tiffin, Ohio).

Prepared facility-wide air emission inventory, developed limitations to avoid Title V permitting for vitreous china ware production facility.  Prepared several PTI applications and FESOP applications and updates for several air emission units at the facility over a period of several years.

PSD Permitting.     
Lone Star Industries, Inc. (Greencastle, Indiana).

Managed and implemented PSD application preparation and submittal, including BACT analysis, for plant-wide expansion and production increase at a portland cement manufacturing facility.  Performed all complex air dispersion modeling (using ISCST3) for several pollutants to attain compliance with applicable air quality standards. Organized the facility operations into manageable groups of air emission units for emission calculations. Dispersion modeling was a key project element.

PSD Permitting.     
Ethanol and Feed Producer (Illinois).

Managed and implemented the preparation of PSD and Title V applications, including BACT analysis, for facility that produces alcohol and animal feed through the fermentation of grain into beer, and subsequent distillation/separation into the two product streams.  Performed all complex air dispersion modeling (using ISCST3) including negotiation with Illinois Environmental Protection Agency (Illinois EPA), which was a key project element, to attain compliance with applicable air quality standards.

Air Quality Study.     
Grey/Ductile Iron Foundry (Ohio).

Conducted air quality studies to determine potential cause(s) of air pollution at facilities and surrounding areas.  Studies included identifying potential pollution sources, laboratory analyses of air samples, and conducting scanning electron microscopy analyses of dust samples.