Business Objective

ALG was approached to perform a comprehensive air audit for a large Title V/RECLAIM facility located in the South Coast air basin. The weeks long intensive audit evaluated the facility's compliance to all current Title V permit requirements, applicable District Rules, Federal MACT/NSPS requirements, and a thorough analysis of all RECLAIM requirements (including analysis of CEMS data, District NOx electronic database records and all other associated reporting and monitoring requirements).

Technical Approach

Based on ALG's significant experience in performing similar detailed environmental audits for expansive facilities, ALG worked to ensure that appropriate facility scheduling and documentation was prepared and confirmed in advance of site visits. This allows for ALG to perform a detailed and comprehensive audit in a systematic way, which minimized total time spent on-site. This included the preparation of a detailed database of all facility requirements based on Title V and other air regulatory requirements that was used to evaluate compliance.

During the process of the audit, a number of non-compliance issues were identified. As a result, ALG worked with the facility to institute new or revised recordkeeping and monitoring protocols to ensure ongoing compliance. This included working with the to perform a complete review of all facility MSDS', and restructuring of material usage/distribution to a central location to allow for ongoing VOC recordkeeping and to ensure all materials used are in compliance with District prohibitory VOC regulations.

Results

ALG identified a number of compliance issues while on site, and as a result ALG worked with facility staff and legal counsel to resolve each of the audit findings; air quality issues and the further refinement of their environmental management program.