Business Objective

A Treatment, Storage, and Disposal Facility (TSDF) sought to expand its treatment capacity, and contracted with ALG staff to review permitting issues and to provide general strategic alternatives to permitting strategies. The facility sought to complete the proposed expansion within a compressed schedule.

Technical Approach

ALG reviewed the permitting strategy, and identified additional air permitting requirements under the EPA National Emission Standards for Hazardous Air Pollutants (NESHAPs) that applied to the proposed modification. ALG also identified additional environmental compliance requirements that applied to both the existing and proposed modifications. This permit was not being managed by the existing contractors, and was a critical path to securing necessary permit approvals.

Results

Working together with corporate and facility staff, ALG developed the required compliance programs and permit applications under the EPA Part 61 NSR program applicable to new NESHAP sources. Together with the client, ALG met with EPA regional staff to review the applicable NSR requirements, permit application contents and engineering documentation, assembled these requisite materials, and secured EPA permit approval within 3 months.