Air Emissions Stack Testing,
and Compliance Plan Implementation
Stack Testing: Clean Air Act Compliance with MACT & RACT regulations
Petroleum Bulk Storage Tank Sampling and Testing
ECI provides facility-wide EH&S
ECI assists client comply with state and
NOx RACT air regulations
Since 1998 ECI has provided numerous industrial process facilities, food & beverage processors, and municipal facility wide environmental, health, and safety regulatory compliance “Turnkey” (i.e., one-source) services including but not limited to design, permitting, construction, training, and management services.
These process facilities were provided multimedia environmental, health, and safety evaluations/reviews that identified regulatory areas of potential concern that were subsequently corrected with the guidance and support of ECI personnel including “Turnkey” operations for complex and multi-disciplinary projects.
The multimedia evaluations reviewed on-site documentation and operational practices related to hazardous waste generation, storage, and disposal practices; emergency planning and community-right-to-know (EPCRA) issues; petroleum and chemical bulk storage including spill prevention and countermeasure contingency plans, spill prevention plans, and design and installation of off-loading and storage buildings and systems; boiler emissions, operations, and related fossil fuel burning issues; process and process emissions and by-products; contingency plan and emergency procedures; wastewater and storm water discharges; process safety management (PSM), risk management program (RMP), process safety assessment (PSA), and process hazard assessment (PHA) documentation; OSHA standards; and other appropriate regulatory compliance requirements.
ECI provides additional services as follows:
- Engineering process and least cost regulatory compliance evaluations;
- MACT, RACT, and BACT air emissions permit and compliance activities;
- Greenhouse Gas Reporting & Monitoring Plans;
- Stack test guidance, protocol development, and oversight activities;
- Indoor air quality and personnel monitoring;
- Dose/Exposure Assessment and Pathway Analysis;
- Health Physics and Radiation Protection and associated Quality Assurance;
- EPA, OSHA, NRC, or State compliance document development and training;
- Vehicle and fleet emissions testing and studies;
- Ground water, storm water, and well monitoring;
- NPDES/SPDES permit application and compliance activities;
- Phase I, II, and III Audits;
- Acquisition due diligence, equipment cost/worth evaluation, and environmental compliance needs and cost analysis;
- Electric Rate Analysis including Facility Peak Shaving/Self Generation and rate reduction negotiations;
- Emergency Response;
- RCRA facility investigation (RFI) and solid waste management unit (SWMU) activities;
- Site and SWMU stabilization/remediation activities including design, specifications, cost
estimates, bid evaluations, and agency submittals;
- Ammonia refrigeration design, as-built drawings, and compliance;
- EPCRA documentation: RMP, PHA, PSM, and PSA;
- Petroleum and chemical bulk storage tank design, installation, product transfer, and closure;
- Waste water treatment systems design and operations;
- Multi-pathway risk assessments; and
- Agency negotiations.
Compliance Cost Savings
ECI provides industrial process plants, food & beverage processors, and municipalities facility-wide environmental, health, and safety (EH&S) regulatory compliance including design and construction management services. ECI provides process facilities with multimedia EH&S evaluations/reviews that identify regulatory compliance issues of concern. These issues of concern are subsequently corrected with the guidance and support of ECI personnel including “Turnkey” operations (i.e., one source) for complex and multi-disciplinary projects.
In addition, ECI is proficient in developing and implementing least-cost-compliance strategies to meet EH&S regulations including permit(s) that encumber the facility. ECI provides outsource services such as sampling/analysis, monitoring, report/permit generation and filing, record keeping, agency negotiations, and training that support on-site facility personnel.
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.
When a large chemical production facility failed to meet specific regulatory air emissions standards they called ECI for assistance. ECI provided air emissions stack testing and equipment adjustment expertise to comply with the applicable air emissions regulatory standards. ECI provided necessary expertise to allow the boiler operators to adjust the existing combustion equipment to meet current regulatory emissions requirements and save the company over $100,000 in capital expenses. These capital expenses were proposed by the equipment manufacturer to accomplish the same regulatory emissions compliance.
ECI provided an on-site facility audit that identified chemical bulk storage off-loading non-compliance. ECI provided a compliance strategy/plan that saved the company over $37,000 by employing a $3,000 poly-tank catch basin rather than an entire concrete containment system that was proposed by another consultant. Subsequently, the ECI compliance plan (i.e., Spill Prevention Report) and physical structure was inspected and approved by the New York State Department of Conservation.
ECI has provided a number of clients with regulatory compliance and engineering expertise for installation of stationary internal combustion engines to operate electirc generators and compressors. ECI has provided engineering analysis of air emissions, identified related impacts to facility permits, and provided guidance including cost estimates on specific technologies and equipment to reduce/mitigate air emissions that ultimately and signifcantly reduced the cost of regulatory compliance.
ECI Domestic Case Studies
ECI provided a food & beverage processing company located in Western New York that included three (4) milk-products processing facilities, two (2) truck garages/terminals, and a corporate office building with compliance support for environmental, health, and safety regulations. ECI provided on-going operations environmental, health, and safety evaluations to determine non-compliance issues, estimate the cost of potential agency fines, and estimate the line item costs to bring the facility into compliance. ECI provided turnkey chemical bulk storage tank replacement and upgrade to meet appropriate regulatory requirements; petroleum bulk storage tank evaluations and costs for their truck terminal and garages; closure of two 25,000 gallon underground storage tanks (USTs); OSHA training; due diligence for a new facility; evaluated the corporate building and warehouse for indoor air quality and mold, making several recommendations that eliminated employee complaints; evaluated a company’s process that was proposing to lease a vacant building owned by the food processor; provided design improvements and installation for least-cost compliance with chemical storage areas; reviewed documentation for compliance with regulations pertaining to ammonia refrigeration system including drawings, Emergency Planning and Community Right-to-Know Act (EPCRA) and Contingency Plan and Emergency Procedures documentation (filed Form R and Tier II Forms), Process Safety Analysis and Management (PSA and PSM), Risk Management Program (RMP), and Process Hazard Analysis (PHA). In addition, ECI has worked with and trained site personnel and safety committees to improve compliance with OSHA standards/regulations developing and implementing over 5,000 employee hours of facility specific training programs.
ECI provided a food processing company with ammonia refrigeration system compliance services regarding two cheese processing facilities located in Ohio and New York. ECI developed as-built ammonia refrigeration system drawings, and brought the facilities PSA, PSM, RMP, and PHA documentation into compliance. ECI incorporated the as-built drawings into the aforementioned documentation and provided appropriate on-site training. ECI prepared management personnel (i.e., pre-audit preparation) for both federal and state agency audits of the ammonia refrigeration system and documentation. ECI developed air emissions calculation software for compliance with appropriate regulations and permitted bio-fuel (i.e., methane from an anaerobic wastewater treatment plant) combustion sources at the New York facility.
ECI provided two aerospace metal parts manufacturing facilities located in Western New York all their environmental, health, safety, and ISO14001 compliance requirements. ECI developed a 12-month VOC Emissions Study during 2001 that was used to support the development of a logical/engineering estimating procedure for air emissions at the facility. The study was used in the determination for monthly and 12-month rolling average estimated VOC emissions from the facility. ECI subsequently filed a State Facility Permit Application and negotiated the permit conditions. For the second facility ECI developed the information included in the emission points and emission source engineering drawing for submittal as part of the State Facility Air Permit Application. For both facilities ECI provided the management documentation, filing system, and personnel training for over 500 employees for ISO14001 compliance; and provided coordination of all EPCRA and Contingency Plan and Emergency Procedures documentation. The ISO14001 compliance included developing and arranging a filing index/system at both facilities for environmental, health and safety management and regulatory requirements. ECI provided over 7,000 employee hours of OSHA training to over 700 employees through a grant program. ECI identified the grant program for the client and then authored the application.
ECI provided two merchant producers of foundry coke with review of draft Title V air permits. ECI developed reports that identified a number of compliance issues regarding written permit conditions. These issues were developed into a letter to the NYSDEC that provided comments from the facility on proposed permit conditions. The final Title V permits reflected the comments and allowed the facilities to better comply with the permit conditions and at a lower cost for compliance. ECI also provided comments and compliance strategy on NOx emissions from combusting coke-gas in the facility’s boilers and emissions from their coke oven stacks. 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 has provided POTW and SPDES permit modification assistance for the facility. Documentation of processes and schematic piping diagrams, analytical data review, permit strategy development, and agency negotiations were all part of the permit modification assistance. ECI was able to achieve lower cost compliance for waste water discharges for the New York facility.
ECI assisted a chemical processing company with over 15 facilities in the United States. ECI provided direct assistance to their facilities located in Upstate New York, Northern Pennsylvania, and North Carolina. For the New York facility ECI lowered their operating costs and improved their operating flexibility by successfully modifying their facility air permit. ECI developed a Performance Test Protocol and Compliance Plan that was negotiated at length with EPA Region II and the EPA Washington DC office. The impact to the facility and the industry in total was to improve operating flexibility and lower operating costs. The facility Performance Test Protocol was developed using state-of-the-art sampling and analytical methods that had been employed for other industries/processing equipment but had not been used for the specific industry. The Compliance Plan was developed to allow for significantly improved operating/chemical processing flexibility and reduced operating costs. For their Pennsylvania facility ECI recommended a number of process/material storage modifications to reduce VOC emissions. For their North Carolina facility ECI provided strategy development for their Title V air permit application and compliance plan.