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