Creating the Right Solutions Together

Example Projects

• 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.