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.