Air Permitting

The Gilman Brothers Company Risk Management Plan Preparation

gzadan — Fri, 19 Nov 2021 15:03:16 +0000

The Gilman Brothers Company Risk Management Plan Preparation gzadan Fri, 11/19/2021 - 10:03

Challenge

Gilman Brothers Company (GBC) manufactures polystyrene foam boards at its Gilman Road, Gilman, CT facility (Facility). The blowing agent used in the manufacturing process is isobutane. As isobutane is one of the listed chemicals in 40 CFR 68 and the amount of isobutane handled at the Facility exceeds the 40 CFR 68 threshold, GBC is required to prepare and submit to the United States Environmental Protection Agency (USEPA) a Risk Management Plan (RMP) conforming to 40 CFR 68 requirements for the isobutane process. GBC retained GZA to prepare the RMP and submit it to the USEPA.

Solution

GZA reviewed the isobutane process, related specifications and drawings, process hazard analysis (PHA) report and process safety management (PSM) manual. GZA modified the PHA report and the PSM manual to improve its accuracy and developed the emergency response and prevention program information required for the RMP. Based on the above, GZA developed a hypothetical worst-case accidental release scenario and a scenario that involves a more realistic potential accidental release of isobutane from the Facility. GZA also performed the required Off-site Consequence Analysis (OCA) for these scenarios in accordance with USEPA’s guidance document using USEPA’s RMP-COMP software to assess off-site impacts from these accidental releases.

Benefit

Using the above information, GZA prepared the RMP conforming to 40 CFR 68 and submitted it electronically to the USEPA using USEPA’s web-based RMP*eSubmit submission system.

Process hazard review and revisions
Process safety manual update
Accidental release scenarios
Off-site consequence analysis
Hazard prevention
Emergency response

Industrial

Land Use and Environmental Planning

Columbia University Air Compliance Reporting

gzadan — Thu, 18 Nov 2021 18:33:27 +0000

Columbia University Air Compliance Reporting gzadan Thu, 11/18/2021 - 13:33

Challenge

The main campus of Columbia University, located in the Morningside Heights area of Manhattan, includes several large boilers at its central power plant and other fuel-burning equipment such as emergency engines, boilers, water heaters, chillers, etc. and laboratory hoods throughout the campus that operate under a Title V permit. The Title V permit requires the university to submit quarterly, semi-annual, and annual compliance reports. The university is also required to submit an Emission Statement to NYSDEC on an annual basis, and a Greenhouse Gas Report and a MACT compliance report to the US Environmental Protection Agency.

Solution

Columbia University retained GZA to prepare these reports. GZA reviews the fuel and material usage data, monitoring systems data, fuel analysis data and emission testing reports to collect the data needed. GZA performs the necessary data analyses and calculations to prepare the reports. GZA submits these reports to NYSDEC and EPA using paper forms or web portals as needed. In addition, GZA periodically visits the Columbia University campus to audit the recordkeeping system that generates the reportable data.

Benefit

The client has consistent, clear data for use in its compliance reporting.

Emission monitoring system data review
Process monitoring system data review
Fuel sulfur reporting
Quarterly, semi-annual, and annual Title V reporting
Emission statement preparation
Greenhouse gas reporting
MACT reporting
Data acquisition system audit

Institutional

Land Use and Environmental Planning

Gilman Brothers Extrusion Line Air Permitting

gzadan — ��Ϸ��d, 17 Nov 2021 16:22:27 +0000

Gilman Brothers Extrusion Line Air Permitting gzadan ��Ϸ��d, 11/17/2021 - 11:22

Challenge

Gilman Brothers (GB), a company manufacturing laminated foam boards at its facility by extruding polystyrene resin and a volatile organic compound (VOC) blowing agent (BA), wanted to double its permitted production capacity. The facility, which was a minor source of VOC emissions, did not have any emissions control. Doubling the capacity would make the facility a major source and the Connecticut Department of Environmental Protection (CTDEEP) has never allowed a major source of VOC emissions to operate without any emissions control. The addition of any control device would impact the production cost. As the foam board is a low margin commodity product and as none of the competitors of GB have control devices, any increase in production cost would negatively impact the viability of GB’s business. GZA was contracted to assist GB in obtaining a permit that allows the production increase without the addition of any control device.

Solution

GZA met with CTDEEP to discuss the permitting strategy. CTDEEP indicated that the BACT analysis would determine emission control applicability. GZA performed extensive research to identify polystyrene foam manufacturing emission control practices and justifiable process data for quantification of emission reductions. GZA’s research also included identification of other control options, such as non-traditional control devices, process changes, non-VOC BA usages, etc. GZA demonstrated that very few foam manufacturing facilities and none of the comparable facilities have emissions control. With the client’s assistance, GZA collected realistic economic data for the BACT analysis. GZA prepared and submitted the air permit application package incorporating the BACT analysis. GZA also promptly responded to additional data requests from the CTDEEP.

Benefit

CTDEEP approved the permit that allowed the client to operate at the increased capacity without any emission control.

Air permitting
Permitting strategy
Data research
Best Available Control Technology (BACT) analysis
Negotiations with CTDEEP
Knowledge of the manufacturing process

Industrial

Land Use and Environmental Planning

Algonquin Power Air Turbine Permitting

gzadan — ��Ϸ��d, 17 Nov 2021 15:50:59 +0000

Algonquin Power Air Turbine Permitting gzadan ��Ϸ��d, 11/17/2021 - 10:50

Challenge

GZA was contracted by a long-time client, Algonquin Power Windsor Locks (APWL) to secure expedited permitting for the proposed 15-MW combustion turbine at its existing cogeneration facility in Connecticut. The project received a capital grant of $6.5 million from the Connecticut Department of Public Utility Control (DPUC) contingent upon the turbine being operational within 15 months. As an air permit is required prior to construction, allowing for construction, the permitting needed to be completed within 7 months, which is approximately half of the typical permitting time for a similar project. In addition to the time constraints, the project posed several other challenges. Due to space limitations, the emission control systems had to be custom made and they could only reduce NOx emission to 5.0 ppm. CTDEEP policy limits NOx emissions from similar units to 2.5 ppm. The system data needed for permitting was not available as the system design was not complete. The required pre-permitting activities, such as Connecticut Siting Council (CSC) approval, Natural Diversity Data Base (NDDB) review, were not completed.

Solution

GZA negotiated a permitting strategy with CTDEEP to address the above issues. To reduce project time, GZA used environmental data from past GZA projects at the facility for the pre-permitting requirements including an NDDB review and, absent timely system data from the manufacturer, GZA developed (based on GZA’s knowledge of turbine systems) the required data for various CSC-specified analyses including ambient impact analysis, which satisfied the CSC. GZA performed a rigorous BACT analysis to justify the higher NOx emission limit. GZA ensured that the application addressed all CTDEEP concerns and was in regular communication with CTDEEP during permitting to minimize review time.

Benefit

The permitting was completed within the 7-month deadline which allowed APWL to meet DPUC’s 15-month deadline for turbine start-up and receive the $6.5 million grant.

Air permitting
Negotiation with regulators
Endangered and threatened species compliance
Best Available Control Technology (BACT) analysis to justify higher emissions
Siting Council approvals
Rapid application preparation
Develop turbine performance data
Compressed approval timeline

Energy

Land Use and Environmental Planning