CCES Performs Critical Review of Issued Air Permit
For a confidential industrial client, CCES performed a review of an issued PSD air permit, allowing construction to begin for a new chemical manufacturing facility. The technical review of the air permit application and the approaches used to estimate worst-case emissions and regulatory applicability resulted in the demonstration of emission rates of a number of air toxic compounds that were significantly lower than what would have resulted by conventional approaches, without explanation. In addition, it was believed that several BACT analyses were not performed per the USEPA’s approved methodology. These have major implications concerning regulatory applicability, control equipment assessment, and ground-level impacts of air toxic compounds.