WREG evaluated the risks and potential consequences of two permitting options for a partially constructed facility in Virginia, whose operating permit was about to expire: 1) continue construction and maintain the existing permit, or 2) allow the construction authorization to lapse and apply for a new construction permit at a later date. WREG reviewed permitting issues encountered by recent permit applicants in the area, investigated control technology requirements that had been instituted since the existing permit was issued, predicted impacts of future regulatory changes on each option, and developed potential construction permitting strategies that could be employed if the construction permit was not maintained.
WREG’s Principals have provided air quality assistance to a major malt beverage manufacturer since the early 1990s. With facilities around the country, including major facilities in Colorado, projects have included:
- Construction permit for a modification of brewlines and associated equipment. The permit contained facility-wide rather than emission unit-specific emission limits, complicating permitting applicability determinations. WREG prepared the application including preparation of Reasonably Available Control Technology (RACT) analyses for volatile organic compounds (VOCs) and fine particulate matter (PM10).
- Major modification permit application for packaging reconfiguration. Application included a Best Available Control Technology (BACT) analysis for VOC emissions.
- Minor modification permit application for replacing biobeds used for odor and VOC emission control from a sludge processing plant with a wet scrubber.
- Update of BACT analysis for a brewery in Virginia. Analysis focused on nitrogen oxide (NOx) emissions from boilers and VOC emissions from brewing and packaging operations.
- Prepared Superfund Amendments and Reauthorization Act (SARA) 313 reports for multiple facilities.
- Provide on-site environmental services support including updating emergency response plans, assisting with chemical inventories, analyzing and reviewing data for chemical tracking, preparing SARA 312 reports, and Materials Safety Data Sheet tracking.
- Prepared a permit application to expand a barley processing facility in Montana. Project included emission calculations, regulatory analysis, and debottlenecking evaluation.
- Emission factor determination and comparison across multiple facilities in different states. Emission factors that might constrain future permitting actions were identified and alternate emission factors determined where possible.
- Stationary internal combustion engine regulations were reviewed and flowcharts and requirements lists developed for Maximum Achievable Control Technology (MACT) standards at 40 CFR 63, Subpart ZZZZ and related New Source Performance Standards (NSPS), 40 CFR 60, Subparts IIII and JJJJ.
WREG developed content for the air quality section of a client’s Intranet, used to disseminate information to multiple facilities. WREG wrote overviews and descriptions of air quality topics, converted existing air quality procedures to Web content, and identified links to useful air quality materials. Topics for which materials were developed included: emission inventories, permitting, reporting, regulatory agencies, opacity readings, and source testing.
WREG has aided a coffee roasting company with air quality permitting and compliance support. Activities have included preparation of construction permit applications, air quality compliance evaluations, investigations of emission controls, recordkeeping and reporting assistance, and evaluation of procedures to reduce odors.