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Title V Permit
Application Preparation
HRP prepared an Operating Permit Application for compliance with
Title V of the Clean Air Act. This application process included
a comprehensive air emission assessment of the facility to
identify all existing point and fugitive sources of air
emissions. Process specific data was collected to quantify both
actual and potential emissions for all regulated pollutants.
Emission estimation techniques included use of emission factors,
mass balance, predictive models and engineering judgments.
Over a hundred emission units were identified and evaluated.
These emission units included numerous electroplating tanks,
electro-deposition paint dipping operations, batch vapor
degreasing, abrasive blasting, and fuel burning operations. HRP
worked with facility personnel and the Connecticut Department of
Environmental Protection during the application process to
discuss critical Title V issues and permit strategies in order
to obtain a flexible Title V permit.
HRP also conducted a thorough review of all state and federal
air regulations in order to identify those applicable to on-site
operations. The facility’s compliance status associated with
each applicable requirement was determined and submitted as part
of the Title V application. These applicable requirements
included numerous state regulations as well as federal NESHAPs
(e.g. Chromium Electroplative and Anodizing MACT and the
Halogenated Solvent Cleaning MACT). Compliance dates were
determined for any non-compliance issues. HRP helped the
facility achieve compliance with various state regulations
through subsequent individual permit application submittals as
well as stack testing.
New Source Review Permit Application
HRP Associates, Inc. prepared a Permit Application for New
Source Review Stationary Sources of Air Pollution (NSR) for an
8.4 BTU/hour Cleaver Brooks industrial boiler. The boiler
provides steam for building heating and manufacturing processes
and may be fired by either #6 fuel oil or natural gas. The
company operates under an interruptible service agreement with
its gas supplier.
The application included a stack analysis and an associated
Hazardous Air Pollutants (HAP) analysis. Actual and maximum
stack emissions were calculated and were compared to evaluate
the adequacy of the existing stack. As a result, a new stack was
constructed that allow all pollutant emissions to comply with
their respective MASCs.
HRP also completed a Best Available Control Technology (BACT)
Analysis because the boiler had potential NOx and SOx emissions
greater than the allowable threshold. Continued burning of #6
fuel oil, when gas prices are non-competitive, was shown to be
the BACT. This was justified by demonstrating excessive economic
impact on the company in terms of the cost per ton to reduce
emissions if #2 fuel oil replaced #6 fuel oil.
HRP successfully negotiated the terms of the final NSR permit
that limited the annual hours of fuel oil burning to a level
acceptable to both the company and the Connecticut Department of
Environmental Protection.
Air Emissions Audit & Permit Preparation
HRP conducted an air compliance audit of a 500-bed hospital that
occupies 11 buildings in Brooklyn, NY. The audit included the
identification of all emission sources, and an evaluation of the
emission sources compliance with applicable local, state and
federal regulation.
Based upon the audit, HRP made recommendations to achieve
compliance including, submission of a Title V permit application
and capping of the facility fuel usage to avoid PSD and NOx RACT,
and the institution of an emission tracking system to comply
with permitting requirements. Following review of the audit
report HRP completed and submitted a Title V air permit
application to the NYSDEC which included appropriate caps.
For more
information, please contact
Jennifer Shea, P.E.
or Tad
Goetcheus, P.E. at 1-800-246-9021
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