Emissions testing program: Title V permit, EPA approved alternative monitoring plan and emissions testing requirements (saved client over $300,000 per year)
EPA/DOE combined project: international development of speciated metals continuous emissions monitoring device
ECI designed, permitted and installed this chemical bulk storage system
Stormwater pollution prevention plan (SWP3) development including mapping and drainage requirements
Spill prevention control and countermeasure plan (SPCC) development and appropriate state oil tank permitting (photo: underground below vehicle oil change area)
Environmental Compliance, Inc. (ECI) has obtained permits for:
- Heavy industry;
- Commercial industry;
- Food and beverage; and
- Municipal facilities
- Air emissions;
- Wastewater discharges;
- Storm water;
- Chemical bulk storage (CBS);
- Petroleum bulk storage (PBS); and
- Numerous other required operating/permit conditions.
ECI has provided services that either separate or combine permits (i.e., separate owners/operators with one permit or multiple separate facility permits). ECI has successfully negotiated with federal and state lead agencies permit conditions that have saved ECI clients millions of dollars in compliance and operations costs (i.e., capital and operations and maintenance costs).
ECI provided a specialty chemical company located near Albany, New York with air emissions compliance/permitting services, successfully obtaining EPA and New York State approval for an alternative emissions monitoring plan (AMP) saving the client over $300,000 per year. In general, the chemical industry had been trying to obtain an AMP for over a decade based on federal 40 CFR regulations. ECI developed and implemented an AMP that was submitted to the United States Environmental Protection Agency (USEPA) Region II for approval. Region II agreed to the AMP based on the results of the Performance Test. ECI developed and submitted the “Performance Test Protocol’’ document to Region II and included the New York Department of Environmental Conservation (NYSDEC) in the communications loop while this 12 month effort was in progress. ECI managed the stack test witnessed by the NYSDEC and developed the stack test report that was presented to Region II and the NYSDEC. Region II accepted the results of the stack test that proved the AMP was appropriate for the facility. Region II sent approval to the NYSDEC of the AMP and ECI worked closely with the NYSDEC to modify the State Facility Air Permit to reflect the approved AMP. The facility is the first formaldehyde production plant in the United States to receive approval of an AMP that allows the facility to comply with a decade old federal regulation for “Standards of Performance for Volatile Organic Compound (VOC) Emission from Synthetic Organic Chemical Manufacturing Industry (SOCMI) Air Oxidation Unit Processes. This has allowed the facility to save hundreds of thousands of dollars each year and to improve production efficiencies.
ECI has provided two (2) metallurgical coke production facilities (i.e., New York and Pennsylvania locations) with permitting and compliance services regarding air and wastewater emissions reduction strategies and designed numerous air and wastewater pollution reduction systems. ECI designed and estimated the cost to install a large wastewater treatment plant for the New York metallurgical coke production facility. This included use of the river water and its discharge after its use back into the river. After the EPA published new wastewater pre-treatment regulations ECI developed and submitted the first Fundamentally Different Factors (FDF) variance application to EPA Region II in over 20 years. Subsequently ECI has prepared additional information requested by the EPA including but not limited to a complete preliminary design of a sophisticated wastewater treatment facility with diversion of storm water, dissolved air floatation, metals removal, and biological system. ECI prepared system sizing and engineering costs as well as schematics of the system. ECI provided the permit application for a National Pollution Discharge Elimination System (NPDES) permit for the state of Pennsylvania for one of the metallurgical coke production facilities. The Pennsylvania Department of Environmental Protection (PADEP) approved the application on the first submittal. ECI also worked closely with the client to obtain the SPDES permit for the New York facility.
ECI provided review and comments on the Title V air permits and has identified federal regulations that impact air emission from the combustion of coal and coke oven gas in boilers and coke oven stacks. ECI developed a Best Achievable Control Technology (BACT) document for the New York facility as a condition with the client’s Title V air permit. The BACT presents extensive research and engineering costs data that went into the BACT analysis that identified a number of potential alternatives to the ammonia stills current operations that emit ammonia to the atmosphere. The BACT analysis examined the potential to produce ammonium sulfate either in finished form (i.e., dry and bagged) or as an intermediate product (i.e., a water solution of 40 plus percent crystals); ammonium hydroxide; and treat the off-gas by catalytic or thermal incineration. The extensive analysis reviewed the potential market for byproducts [i.e., ammonium sulfate either in finished form (i.e., dry and bagged) or as an intermediate product (i.e., a water solution of 40 plus percent crystals); and ammonium hydroxide]. All potential applications went through an engineering design and cost analysis to determine the cost per ton of emissions reduction. The New York State Department of Environmental Conservation readily accepted the BACT analysis.
ECI provided turnkey design, installation, permitting, and start-up of a chemical bulk storage (CBS) system near JFK Airport in Long Island, New York. When a large national company ran into problems obtaining the proper operating documents for the design, permitting, and construction of a chemical bulk storage system (CBS) they removed the engineering and separate construction companies from the 18 month stalled project and contracted with ECI to provide the CBS system turnkey. ECI worked closely with the chemical supplier and client to ensure the design and installation met State and local (Nassau County Health Department) regulations. ECI designed the off-loading containment system, the off-loading pipeline system in 316-Stainless Steel, the high-level alarm and level gauge system, tank venting system, pumping system for the day tanks, and the day tank fill system and pipelines with safety key (spring loaded) system. ECI received permits for the CBS tanks/system from the DEC and permits from the local agency for the smaller day tanks. The client has used ECI for similar projects since that time.