As described under the services section, BTEC’s professionals have extensive experience in the following generalized air quality service categories:

• Air Pollutant Emissions Testing
• Ambient Air Monitoring
• Industrial Hygiene Sampling
• New Source Review Permitting
• Title V Permitting
• Air Dispersion Modeling
• Regulatory Compliance Assessments
• Miscellaneous Compliance Assistance
• Air Pollutant Emissions Reporting

A portion of the myriad of BTEC’s relevant project experience in each of the eight generalized categories listed above is summarized below.

Air Pollutant Emissions Testing

Automotive Surface Coating – BTEC personnel performed diagnostic testing on a regenerative thermal oxidizer controlling emissions from automotive surface coating operations. After the initial test, it was discovered that the device was not meeting its design criteria. BTEC personnel and representatives of the control device manufacturer devised a test plan to evaluate various thermal oxidizer operating parameters including combustion temperature, valve timing and sequencing, burner optimization, and flow profile characterization. Using a combination of real time analyzers and field data evaluation, BTEC personnel were able to support the control device manufacturer in optimizing performance in the most efficiency and cost effective manner.

Fiberglass Manufacturing – BTEC personnel performed engineering testing on numerous processes at a fiberglass material manufacturing facility. Testing was conducted for various purposes including process expansion design testing, the impact of production rate increases on emission rates, and determination of actual emission rates for permit application technical support. BTEC personnel worked closely with the facility to plan a testing schedule that would yield valid results and take into account the production parameters that affect emission rates.

Foundry Industry – BTEC personnel have performed compliance testing on numerous processes at many foundry facilities. Compliance testing was conducted to meet various permit and regulatory requirements (e.g., Title V permit requirements, Iron and Steel Foundry MACT). Virtually all process operations (e.g., cupola, core and mold making, pouring and cooling, shakeout, and finishing operations) at foundry facilities have been evaluated by BTEC personnel. BTEC’s personnel have worked closely with facility and regulatory agency representatives to modify sampling methods and devise a sampling plan to coordinate production rates and schedules to yield representative results.

Public Utility and Industrial Power Boilers – BTEC personnel have performed numerous Relative Accuracy Test Audits (RATAs), engineering testing programs, and compliance testing programs at coal- and gas-fired power generation plants and gas turbine peaker units. BTEC’s senior project management has managed over 40 projects directly involving public utility, industrial power boilers, and facility steam boilers

Air Emissions Training

Automobile Industry, Air Emissions Training – BTEC personnel developed and presented a comprehensive, 2-day training course on air emissions testing for environmental engineers at automobile assembly, parts manufacturing, and foundry facilities throughout North America. The training consisted of six segments: Historical Overview, Pretest Activities, Test Activities, Post-Test Activities, Common Test Methods, and Hands-On Test Method/Equipment. Individual topics included compliance and engineering test objectives, process considerations, safety considerations, test method selection, test port location and accessibility, developing a test protocol, monitoring process and abatement systems during testing, interacting with agency personnel, and reporting.

Ambient Air Monitoring

Ambient Air Monitoring, Electroplating Facility Fire – BTEC personnel were retained to perform toxic air contaminant ambient air monitoring during a fire that destroyed an electroplating facility. Nitric acid, sulfuric acid, hydrochloric acid, and carbon monoxide concentrations were monitored in several areas surrounding the burning building for the entire duration of the fire. These ambient air monitoring results were subsequently used in litigation to argue that the health of residents in the areas surrounding the fire was not compromised.

Ambient Air Monitoring, Soil Remediation Site – BTEC personnel were retained to conduct ambient air monitoring during excavation activities performed in support of a large soil remediation project. Particulate matter concentrations were monitored at several locations surrounding the excavation site for the duration of excavation work (approximately seven weeks). These ambient air monitoring results were subsequently used to support a conclusion that the excavation work had a negligible impact on ambient air quality in the area surrounding the work site.

Ambient Air Monitoring, Soil Remediation Site - BTEC personnel were retained to conduct ambient air monitoring during excavation activities performed in support of a soil remediation project at a former hard chromium electroplating facility. Hexavalent chromium concentrations were monitored at several locations surrounding the excavation site for the duration of excavation work (approximately two weeks). These ambient air monitoring results were subsequently used to support a conclusion that the excavation work had a negligible impact on ambient air quality in the area surrounding the work site.

Industrial Hygiene Sampling

Personal and Area Air Monitoring – BTEC personnel were retained to perform personal exposure monitoring and area air contaminant ambient air monitoring during the demolition of a dormitory next to an elementary school. The pre demolition survey included sampling of paint, plaster, ceiling tiles, and pipe insulation for various compounds including lead, chromium, silica, and asbestos. During the demolition phase of the project personal samplers were placed on the excavator operators and laborers at the site to determine exposure levels and show compliance with OSHA regulations. Area monitoring was also conducted around the parameter of the demolition site to determine the off site exposure levels and ensure that the elementary school was not negatively impacted.

Workplace Personal Air Monitoring – BTEC personnel were retained to perform personal exposure monitoring at an industrial workplace to determine the exposure levels for the employees in different areas of the facility. At the completion of the sampling program compliance with OSHA limits were determined and recommendations were presented with the guidance of BTEC’s CIH on call.

New Source Review Permitting

New Gas Turbines, Institutional Powerhouse – BTEC personnel prepared applications for permits to install two replacement natural gas and fuel oil-fired combustion turbines at an institutional powerhouse. Both permit applications were potentially subject to the federal PSD permit program (40 CFR 52.21). However, BTEC’s review concluded that actual emissions from the existing gas turbines has been under-reported for ten years. After revising the emission totals submitted to the statewide emission inventory system, both gas turbines were able to “net out” of PSD. In addition, the gas turbines are part of a cogeneration system that includes two turbines, two duct burners, and two heat recovery boilers. In reviewing permit terms and conditions, it became apparent that the cogeneration system could not meet its emission limitations based on the duct burner emission estimates supplied in the original cogeneration system permit application. BTEC successfully assisted in the negotiation of increased cogeneration system emission limits thereby avoiding potential liabilities associated with a subsequent emissions test requirement.

Process Rate Increase Project, Chemical Plant – BTEC personnel prepared a comprehensive permit to install application for a process rate increase project at a large chemical manufacturing plant. The project involved the replacement of an existing thermal oxidizer exhaust fan with a larger fan, thereby (1) reducing the residence time of the process gas in the thermal oxidizer and (2) increasing the capacity of the production plant. BTEC conducted the necessary regulatory analysis, estimated air pollutant emission rates, prepared the required best available control technology (BACT) analysis, estimated toxic air contaminant emission rates, and prepared the necessary application documents. In addition, BTEC assisted in the review and negotiation of permit terms and conditions, resulting in a successful permitting project.

Dynamometer Test Cells, Racing Engine Test and Development Facility – BTEC personnel assisted an automobile manufacturing company in addressing air quality requirements and obtaining required construction permit for a new racing engine test and development facility in southern California. The facility includes four methanol-fueled racing engine dynamometer test cells as well as some ancillary emission units (e.g., methanol storage tank). BTEC personnel evaluated air pollutant emission rates from the test cells (in terms of lbs/gal) and worked closely with the facility in an attempt to evaluate combinations of test cell fuel usage rates (gal/yr) and exhaust stack parameters that would allow for the emissions to be discharged uncontrolled. However, because of elevated maximum hourly carbon monoxide (CO) emission rates coupled with facility topography and stringent hourly average CO ambient impact requirements, the facility was required to install emissions control. BTEC personnel performed a feasibility analysis that resulted in an innovative control design with individual catalytic oxidizers serving each of the four test cells. This design will save the facility significant cost in the coming years because of its relatively low operating expense.

Title V Permitting

Title V Permit Application, Army Battle Tank Plant – BTEC personnel prepared a complete Title V permit application for an army battle tank manufacturing facility in Ohio. Included in the permit application was identification of each individual emission unit; classification of each as trivial, insignificant, or non-insignificant; evaluation of applicable requirements and the compliance status of each emission unit; development of emission estimation protocols and spreadsheets for estimating emissions annually; and preparation of the permit application documents. In addition, as a result of several areas of non-compliance, BTEC personnel prepared the necessary permit to install applications or assisted the facility in attaining compliance with the applicable requirements.

Title V Permit Application, Chemical Manufacturing Plant Site – BTEC personnel prepared complete Title V permit applications for three stationary sources (each with several semi-autonomous manufacturing plants belonging to separate major industrial groupings) collocated on the same site. Included in the permit application was identification of each individual emission unit; classification of each as insignificant, exempt, or non-exempt; evaluation of applicable requirements and the compliance status of each emission unit; development of emission estimation protocols and spreadsheets for estimating emissions annually; and preparation of the permit application documents. As part of the application process, BTEC was able to identify (1) numerous emission units for which a permit to install had been issued although the unit is exempt from permitting and (2) numerous permits that included requirements for which there is no corresponding underlying applicable requirement. By proposing the permits/requirements for deletion in the Title V permit application, the manufacturing site was able to avoid significant compliance cost associated with non-applicable requirements.

Title V Permit Compliance Certification Protocol, Industrial Container Cleaning Facility – BTEC personnel developed a Title V permit compliance certification protocol for an industrial container cleaning facility located in Michigan. This compliance certification protocol identifies each individual permit applicable requirement (both general and process-specific) and requires the facility to identify the compliance status of the facility with respect to the requirement, whether compliance is based on continuous or intermittent monitoring, and the basis for certifying compliance. In addition, the protocol includes guidance regarding certifying compliance with certain permits terms and conditions (e.g., the requirement not to modify a process without applying for a permit to install. This compliance certification protocol has allowed the facility to avoid potentially costly liabilities associated with non-compliance.

Air Dispersion Modeling

PSD Increment Consumption Analysis, Metal Heat Treat Process Lines – BTEC personnel prepared a PSD increment consumption analysis in support of an application for a permit to install four large continuous metal heat treat process lines in Michigan. After estimating maximum PM10 emission rates from the proposed process lines, it was apparent that the proposed project would result in a net PM10 emissions increase greater than 15 tons per year and, consequently, would be a major modification for PM10. BTEC personnel performed the ambient impact analysis using U.S. EPA’s ISC modeling software. Prior to preparing the analysis a modeling protocol was submitted to the Air Quality Division of Michigan’s Department of Environmental Quality identifying other post-baseline PM10 sources constructed in the area, PM10 background concentrations in the area, and the proposes modeling methodology. Based on the results of the modeling analysis, the facility was allowed to install the heat treat process lines as designed (without emissions control equipment) but with an annual throughput limit less than its corresponding maximum rate. After the equipment was installed and operating, BTEC personnel conducted an emissions test program to evaluate “as-built” PM10 emission rates. Because these as-built PM10 emission rates were less than the initial estimates, BTEC personnel were able to successfully apply for increased process line throughput limits that correspond to the maximum capacity of the equipment.

Toxic Air Contaminant Ambient Impacts Analysis, Hospital Ethylene Oxide Sterilizers – BTEC personnel prepared an ethylene oxide sterilizer toxic air contaminant ambient impact analysis for a large hospital that had operated the sterilizers without emissions control for several years. U.S. EPA’s ISC model software was used to predict ethylene oxide ambient air concentrations in the area surrounding the hospital including hospital air intake points. By preparing a dispersion modeling analysis and a BACT analysis, BTEC personnel were able to demonstrate that emissions control equipment had not been required when the equipment was installed and, consequently, the administrative penalty was significantly reduced.

Hydrogen Chloride Ambient Impacts Analysis, Coal-Fired Boilers – BTEC personnel used U.S. EPA’s ISC model software to predict hydrogen chloride ambient air impacts and corresponding hazard index for use in evaluating the need hydrogen chloride control equipment to comply with the Industrial, Commercial, and Institutional Boiler NESHAP (40 CFR 63, Subpart DDDDD). The dispersion modeling analysis demonstrated that hydrogen chloride emissions from the powerhouse exhaust stacks would not result in a hazard index value exceeding 1.0 and, consequently, no additional emissions control equipment was required.

Regulatory Compliance Assessments

Regulatory Compliance Assessment, Gear and Axle Manufacturing Site – BTEC personnel prepared an air quality regulatory compliance assessment at a large automotive gear and axle manufacturing facility. The manufacturing facility consisted of nine large plant buildings that included steel shot blasting, forging, machining and finishing, heat treating, and assembly as well as ancillary operations. As a result of the compliance assessment, the facility was able to (1) obtain a permit to install for equipment that had been assumed exempt from permitting but had excluded from exemption by federal PSD requirements and (2) obtain a permit to install for equipment that had significant potential for odor issues.

Regulatory Compliance Assessment, Electroplating Facility – BTEC personnel prepared a comprehensive air quality regulatory compliance assessment for an electroplating facility that included hard chromium, acid nickel, copper cyanide, and cadmium cyanide plating as well as associated degreasing, cleaning, etching, and finishing operations. As a result of this compliance assessment, the facility was able to attain compliance with hard chromium electroplating NESHAP requirements (40 CFR 63, Subpart N) and obtain permits to install for other equipment that was installed in violation of permit to install requirements.

Regulatory Compliance Assessment, Large Metropolitan Airport – BTEC personnel prepared an air quality regulatory compliance assessment for a large publicly owned airport. Project tasks include identification of each emission unit, determination of permit to install requirements applicability, calculation of potential emission rates from each identified emission unit, and determination of the compliance status of each unit. As a result of the compliance assessment, the airport was able to (1) establish that each historical modification of the airport did not violate federal PSD requirements, (2) submit permit to install applications for five separate emission units subject to the permit to install program, (3) identify boilers that were being operated in excess of corresponding fuel usage rate limitations and submit an application to revise the fuel usage rate limitations, (4) identify incinerator records that were not being maintained, and (5) submit an application for a Title V permit.

Miscellaneous Compliance Assistance

Emissions Control Equipment Analysis, Chemical Manufacturing Plant – After estimating emission rates and toxic air contaminant ambient impacts from a proposed series of new polyurethane reactors, BTEC was able to determine that toluene diisocyanate (TDI) ambient impacts were such that emissions control equipment would be required. However, although TDI ambient impacts exceeded allowable thresholds because of its relative toxicity, the majority of emissions from the process would be NMP. By working with a carbon vendor, BTEC personnel were able to demonstrate to the regulatory agency that, because carbon has a much greater affinity for TDI than for NMP, the carbon could become saturated with NMP and TDI would subsequently displace the NMP and adsorb to the carbon. By doing this, the company was able to discharge the NMP uncontrolled while controlling the TDI with a relatively small carbon bed.

Compliance Assurance Monitoring Plan, Brick Manufacturing Plant – BTEC personnel prepared a compliance assurance monitoring plan (40 CFR 64) for a brick kiln with emissions controlled by a lime-injected baghouse. This monitoring plan was able to justify no change in the monitoring previously performed by the facility and the plan was approved by the regulatory agency.

Technical and Economic Feasibility Analysis, Hospital Medical Waste Incinerator – BTEC personnel prepared a technical and economic feasibility analysis for a hospital that was operating a large hospital/medical/infectious waste incinerator to be affected by the corresponding NSPS (40 CFR 60, Subpart Ce). The technical and economic feasibility analysis evaluated the (1) the technical feasibility of installing various air pollution control equipment necessary to comply with the standard, (2) the cost of installing and operating the emissions control equipment (including regulatory compliance and testing costs), and (3) the capital and operating cost of waste management alternatives to incineration (e.g., landfill, autoclave, plasma arc). Based on the results of the analysis, the hospital decided to accept the recommendation to discontinue operations of the incinerator and ship infectious waste to an outside autoclave facility while disposing of general hospital waste in a landfill.

Air Pollutant Emissions Reporting

Annual Air Pollutant Emissions Report, Chemical Manufacturing Company – BTEC personnel prepared a site-wide annual air pollutant emissions report for large chemical manufacturing plant site. The emissions reporting spreadsheets were subsequently used by the company for several years.

Annual Air Pollutant Emissions Report , Electric Utility Power Plant – BTEC personnel prepared an annual air pollutant emissions report for an electric utility power plant. In preparing the report, BTEC’s associate noticed that, although the boilers were capable of firing fuel oil, none had been used for a number of years and the facility had stopped including fuel oil as an activity in the annual air emissions report. BTEC’s associated was able to work with the regulatory agency to revise previous annual air pollutant emissions reports to include the fuel oil activity with a usage rate of zero gallons. Consequently, the facility was able to retain the ability to fire fuel oil without applying for permit modifications (and likely requiring emissions control modifications).

Annual Air Pollutant Emissions Report, Surface Coating Application Facility – BTEC personnel prepared an annual air pollutant emissions report for a surface coating application facility located in Michigan. The emissions reporting spreadsheets were subsequently used by the company for several years.