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Supporting Kentucky Aluminum Facility’s Complex PSD/NSR Air Permitting and Compliance Strategy

Supporting Kentucky Aluminum Facility’s Complex PSD/NSR Air Permitting and Compliance Strategy

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Environmental ConsultingEnvironmental Consulting

Industry

Manufacturing

Location

United States

When a Kentucky aluminum facility needed support on their complex air permitting and compliance challenge, they wanted a partner in devising a solution, not a one-off checklist. Trinity worked with the client to identify equipment planned, complete preliminary emission calculations and air dispersion modeling, review regulatory and permitting implications, and develop initial project description and process flow diagrams. The goal was to provide opinions, recommendations, and work products towards defining an air permitting strategy that optimally meets the various technical, cost, timing, and risk objectives for the client. The client had two site locations in mind, so Trinity provided input on which location would be best suited.

Challenge

After establishing a foundation for the facility’s equipment and project description, the next stage involved completing the required modeling analyses as well as the control technology analysis from preliminary work. Trinity prepared a permit application outline and integrated the work products already prepared into the outline. To streamline the path towards a final air permit, Trinity conducted a pre-application call with the Agency to present the proposed project and regulatory implications.

Drawing on their established regulatory relationships, the Trinity team finalized for submittal any remaining elements of the application package including the project description, emissions documentation, regulatory analyses, and the proposed compliance demonstration methods.

Solutions

Following submittal of the application, Trinity participated in calls and meetings with the Agency to discuss questions or other issues from the permit writer’s review. Trinity prepared formal responses to the Agency’s Notices of Deficiency (NODs). Once a pre-draft permit was prepared by the Agency, Trinity conducted a detailed review and advised the client of any recommended changes to ensure the client’s ability to comply with the permit moving forward.

Services Performed

Trinity delivered targeted air permitting support that included preliminary emissions calculations, air dispersion modeling, regulatory analysis, and development of an air permitting strategy. The team prepared application materials, coordinated with the Agency, addressed Notices of Deficiency, and reviewed the pre-draft permit. As construction advanced, they developed compliance documentation, supported NESHAP Subpart RRR requirements, and assisted with planning and execution of compliance testing to demonstrate adherence to permit limits.

Results

As the project moved into the construction phase, Trinity supported development of compliance documentation such as an air emissions tracker, required 40 CFR 63, Subpart RRR documentation, and work practices plans for state-only requirements. The team supported the development of compliance testing plans, provided remote support during testing, and generated an executive summary-type section of the stack test report to demonstrate that the testing program satisfied the permit requirements and that the client will be able to achieve compliance with the applicable emission limits driving the testing program.