PROJECT SUMMARY
WHAT:
Initial Compliance Demonstration
WHO:
Bruce Raff
WHERE:
Organic Chemical Manufacturer Geismar, Louisiana
WHEN:
2016
BACKGROUND
K assisted a major organic chemical manufacturing facility obtain a Title V Operating Permit for a new production unit. This facility is subject to the Hazardous Organic NESHAPS (HON) and was required to conduct an Initial Demonstration of Compliance via stack testing followed by submission of a Notification of Compliance Status.
FINDINGS
teps involved were:
- Determine regulatory testing requirements
- Devise a testing program to determine process monitoring requirements and operating limits during testing which establish continuous compliance operating limits with minimal impact on operations
- Procure, coordinate, and schedule a stack testing firm
- Develop, submit, and obtain approval of an LDEQ Compliance Test Protocol
- Perform stack test and collect required process data
- Compile stack test report containing LD E Q ’s required information and in the required format
- Establish minimum operating conditions to ensure continued compliance
- Prepare a Notification of Compliance Status and amend the Title V Operating Permit.
RESOLUTION
K worked closely with the client, the testing firm, and the LDEQ to accomplish all of these requirements within the regulatory timeframe and helped establish operating limits that ensured compliance while having a minimal impact on the facilities operations.
PROJECT SUMMARY
WHAT:
Initial Compliance Demonstration
WHO:
Bruce Raff
WHERE:
Organic Chemical Manufacturer Geismar, Louisiana
WHEN:
2016
BACKGROUND
K assisted a major organic chemical manufacturing facility obtain a Title V Operating Permit for a new production unit. This facility is subject to the Hazardous Organic NESHAPS (HON) and was required to conduct an Initial Demonstration of Compliance via stack testing followed by submission of a Notification of Compliance Status.
FINDINGS
teps involved were:
- Determine regulatory testing requirements
- Devise a testing program to determine process monitoring requirements and operating limits during testing which establish continuous compliance operating limits with minimal impact on operations
- Procure, coordinate, and schedule a stack testing firm
- Develop, submit, and obtain approval of an LDEQ Compliance Test Protocol
- Perform stack test and collect required process data
- Compile stack test report containing LD E Q ’s required information and in the required format
- Establish minimum operating conditions to ensure continued compliance
- Prepare a Notification of Compliance Status and amend the Title V Operating Permit.
RESOLUTION
y providing a high quality permit application and proactive communication with the regulatory agencies, the PSD/GHG/Part 70 Permit was obtained in less than one year to meet the construction schedule. CK is currently assisting Corrigan OSB in obtaining the SOP and compliance and reporting needs under the initial NSR/PSD/GHG permit.