Projects

Non-Recovery Coking Plant. LMG has led all Major Source PSD permitting efforts for the 1.44 million ton per year FDS Coke Plant proposed for Toledo, Ohio. The permitting efforts have included obtaining the initial final PSD permit to install (PTI) within 120 days and two subsequent PTI modification applications. We have also provided extensive technical information to Ohio EPA characterizing all coke plant process operations, estimating air pollutant emissions from more than 50 different sources, conducting air dispersion modeling, and determining Ohio BAT/BACT compliance.

The BACT study included development and successful incorporation of the use of an innovative horizontal coke pushing process into an enclosed quench car controlled with a baghouse. LMG prepared the submittial and obtained a MACT compliance determination from USEPA Region V authorizing the use of this innovative approach. The flat pushing of coke into an enclosed quench car is expected to reduce construction and operating costs associated with controlling pushing air pollutant emissions by more than $10 million over the life of the project.

Industrial Rubber Tire Manufacturing Plant. LMG prepared a Permit to Install (PTI) application package and subsequent Title V permit renewal application for an industrial rubber tire manufacturing plant that is a major hazardous air pollutant (HAP) source. The project included reviewing facility equipment, practices, and operational data for accuracy and applicability to state and federal environmental regulations. We also managed the preparation and submittal of 3 PTI applications as part of the Title V renewal that clarified application data, provided increased operation flexibility, and proposed less restrictive operating conditions. This process included utilizing dispersion modeling results and production planning input to demonstrate regulatory compliance with higher emission rates.

Reinforced Composite Plastics Plant. LMG prepared a Permit to Install (PTI) application package, Title V Applicability Assessment and subsequent Title V permit application re-submittal for a fiberglass reinforce plastic (FRP) composite fabricating facility that was a major source of hazardous air pollutants (HAPs) such as styrene. The project included reviewing practices and facility operational data for applicability to state and federal environmental regulations and determined the facility to be applicable to the Title V permit application process. We also managed the preparation and submittal of 30 PTI applications for existing equipment that resulted in less restrictive permit conditions. This included utilizing dispersion modeling results and production planning input to determine modified emission rates that allowed operational flexibility while attaining regulatory compliance with permit Terms and Conditions.

Automotive Parts Supplier. LMG reviewed and revised a FESOP permit and conduct air toxics modeling for a major plastic automotive parts manufacturer. The original facility permit restricted the use of paints to specific booths and operating hours to keep VOC emissions below 100 tpy and HAPs below 25 tpy total. We worked with the paint supplier to determine specific non-VOC and non-HAP paints as alternatives to the current paints used. Realistic paint schedules and operating hours were determined by production departments and through the use of reduced HAPs and a VOC bubble permit the facility was able to gain the flexibility to use any paint in any booth within limited operating hours. This allowed the facility the ability to respond to rush orders and last minute scheduling and overtime needs

Ohio Industrial Manufacturing Plant. LMG provided Clean Air Act (CAA) regulatory compliance assistance and technical advice during negotiations for the successful resolution without penalty of a USEPA Region V Notice of Violation (NOV) for a Title V industrial manufacturing plant in Ohio. As part of these activities, we worked with outside counsel to advise senior management on specific technical issues and resulting operation changes associated with strategies for NOV resolution.

LMG was a key participant in direct discussions with USEPA Region V staff regarding the key issues raised in the NOV and the facility’s positions. We also concieved and conduced benchmarking studies to support facility regulatory positions. In addition, LMG managed the preparation and was the primary author of the facility’s response to a CAA Section 114 Request issued by USEPA Region V.

Non-Recovery Coke Plant. LMG is providing ongoing technical assistance regarding an appeal to the Ohio Environmental Review Board (ERB) of the final Permit to Install issued for the FDS Coking Plant in Lucas County, Ohio. As part of these activities, we have worked with outside counsel to advise senior management on specific technical issues associated with the final PTI and drafted the technical basis for the appeal. LMG is a key participant in direct discussions with Ohio EPA regarding the key issues raised in the appeal and the FDS Coke Plant’s positions.

Industrial Rubber Tire Manufacturing Plant. LMG prepared a MACT Applicability Determination Request submitted to USEPA Region V for an Industrial Rubber Tire Manufacturing (RTM) Plant that was a Title V facility. The applicability determination was a key component of the company’s long-term strategy to avoid the addition of costly air pollution controls to an adhesive application process associated with an industrial tire manufacturing process. Based on the information provided within the request the Title V facility was determined to fall within a MACT rule that allowed application of an adhesive coating with more than 10 times the hazardous air pollutant (HAP) content than specified under a secondary MACT rule that other operations were required to met at the facility.

Grey Iron and Steel Foundry. LMG provided expert assistance associated with an air emission odor investigation initiated by the New York Department of Environmental Conservation (NYDEC) against a grey iron and steel casting operation in New York. The assistance included design and implementation of a strategic response to isolated neighborhood complaints and NYDEC requests for corrective actions. We also met with NYDEC personnel to provide additional information associated with alternative sources of odors in the area and inconsistencies in the nature and timing of the odor complaints. Based on this information, NYDEC discontinued all enforcement actions and the client avoided unnecessary capital costs associated with construction of a super stack and additional air collection system for the metal casting operation.

Metal Products and Resin Manufacturing. LMG has provided expert regulatory compliance assistance and project management for the successful completion of an Ohio EPA Consent Orders and resolution of Notice of Violation (NOV) letters associated with hazardous waste management at metal products, plating, medical device manufacturing, and resin manufacturing facilities in Ohio.

Project activities have included the preparation of facility responses to Ohio EPA, writing hazardous waste management procedures for implementation by the operations, preparation of a RCRA contingency plans, performance of employee RCRA training, and oversight of the RCRA generator closure of a 90-day accumulation area at the facilities. LMG closure tasks have included design of a cost-effective work plan approved by Ohio EPA, contractor oversight, final inspection and sampling of the area, and preparation of the final closure report.

Sign Manufacturing & Installation Company. LMG provided expert regulatory compliance assistance and project management for the successful completion of an Ohio EPA Consent Orders associated with closure of an unpermitted hazardous waste management unit at a sign manufacturing and installation company. Project activities included preparation of a Sampling and Analysis Plan (SAP), Remedial Action Plan (RAP), and management/oversight of the final closure remediation activities. LMG closure tasks included design of a cost-effective soil removal work plan that was approved by Ohio EPA, contractor oversight, final inspection and sampling of the area, and preparation of the final closure report.