Delivering a First-of-its-Kind Solution Ahead of Schedule
Challenge
When an air curtain incinerator at a plywood manufacturer became subject to 40 CFR 60 Subpart CCCC Standards of Performance for Commercial and Industrial Solid Waste Incineration Units, it required a major source operating permit. As an existing minor source, the change in facility classification presented a permitting challenge for both the manufacturer and the state regulatory agency.
Relevant Services
Solution
Because there was no permitting mechanism in place, TRC’s air permitting practitioners partnered with the manufacturer’s operational team and with state representatives to define and develop a permitting approach for existing sources. Our team navigated requests from the state agency related to Particulate Matter less than 2.5 microns (PM2.5) air dispersion modeling and new National Ambient Air Quality Standard (NAAQS).
We performed an air quality dispersion modeling analysis for the ACI and existing applicable sources to demonstrate compliance with the NAAQS and with state air toxic standards. Our team held multiple meetings with the state agency’s air permitting staff to discuss comments, implications of agency requests with respect to setting precedence, results of modeling and public notice comments.
We submitted the air quality permit application to the state agency along with the requested addendums ahead of schedule and the permit was issued.
Results
The air curtain incinerator permit was the first of its kind in the plywood manufacturing industry. Effective and frequent communication with both facility stakeholders and state agency personnel ensured that the goal of the project was clear and executed without issue. Our relationship with state agency permit writers resulted in effective meetings and fostered strong communications to complete the work, efficiently and effectively.