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Permitting & Modeling
Bison's 20 years of experience in air quality permitting and regulatory
analysis range from preparation of air permit applications for industrial
facilities to extensive compliance assurance follow-up for many clients.
Our experience allows us to design an approach to air regulatory issues
to meet your needs in a cost-effective manner. The following paragraphs
further explain some of our expertise in key air quality regulatory
areas:
PSD/NSR/State Permit Applications
One of the first critical steps in planning for a new or expanded
industrial facility is assuring the necessary pre-construction permits
are obtained. Bison helps clients apply for and receive appropriate
air quality permits for their facilities. Bison is particularly skilled
at advising our clients of the appropriate permitting path to follow
and the most timely strategy to obtain a permit.
We prepare permit applications ranging from a few pages to several
hundred pages. Our permitting clients include power generation, chemical
manufacturing, petroleum refining, wood products, lime manufacturing,
and cement plants.
Permitting regulations applicable to our permitting projects range
from state or local requirements for minor modifications to federal
Prevention of Significant Deterioration (PSD) or New Source Review
(NSR) rules for major sources.
Title V Operating Permit Applications/Negotiations
Bison has extensive experience in preparing applications for Title
V Operating Permits for major stationary sources. We also provide
consulting services to clients so they can limit emissions and operations
to avoid the need for a Title V Operating Permit. Our permitting strategy
provides complete and accurate applications that promote operational
flexibility and reduce a source's liability and record keeping requirements.
Once applications are reviewed and draft operating permits issued
by the regulatory agency, Bison will help negotiate your permit to
address necessary requirements, while controlling compliance responsibilities
and liabilities.
Dispersion Modeling
In today's regulatory environment, growing and expanding industries
generally require an air quality analysis to modify operations. In
most cases, air quality analysis requires air dispersion modeling.
Bison's reputation for performing dispersion modeling analyses is
well known. Our projects range from installation of an additional
screen at a stone processing facility to performing 1,100+ modeling
runs to demonstrate compliance with State Implementation Plans.
Our 20 years of modeling experience is extensive. Our team is highly
skilled in AERMOD, CALPUFF, ISC3 and ISC-PRIME, as well as the following:
BLP, BPIP, CDM, CMB7, COMPLEX1, CTDM, CTSCREEN, DEGADIS, OCD, PLUVUE,
SCREEN3, SLAB, TSCREEN, VALLEY, and VISCREEN.
Bison has the knowledge and expertise to perform any modeling analyses
required for your facility.
Emissions Inventories
A properly estimated inventory will determine which regulations apply,
what emissions fees need to be paid and what levels of pollution control
should be applied.
Bison employs a variety of accepted emission estimating procedures
to develop a facility's emission inventory. Emissions are often calculated
using emission factors that may be found in several sources. The most
common source is EPA's Compilation of Air Pollutant Emission Factors,
otherwise known as "AP-42 or Air Chief." Additional sources of emission
factors include those from trade journals, trade association studies,
other EPA databases, and those derived by site-specific emissions
tests.
Bison also calculates emissions using mass balances and engineering
judgment. Detailed process engineering analyses may be required to
determine the appropriate pollutant emitting rates. Bison's engineers
are well versed in providing accurate emission estimates.
Compliance Assurance Monitoring Plans
EPA's compliance assurance monitoring (CAM) is applicable to emissions
units located at sources requiring a Title V Operating Permit, that
are subject to an emissions limitation, use an add-on control device
and would be a major stationary source of air pollution without emissions
controls. For most facilities (those with a Title V permit or complete
Title V permit application), a CAM plan will need to be submitted
at the time of renewal of your Title V Operating Permit.
Although a CAM plan may not be required for a number of years for
most facilities, Bison recommends that early determination of the
applicability of the rule is important in allowing you to plan for
implementing CAM requirements. Bison's experience with control technology
and regulatory issues positions us to assist you with the application
of the CAM rule to your facility.
Compliance Tracking Database
Bison developed a Compliance Tracking Database that can help you organize
and address your permit obligations in a timely manner. The database
can be programmed to track permit requirements from all of your facilities.
Features of the database include:
- 30-day, 60-day, and 90-day projections on upcoming issues;
- Word searches for particular requirements or affected sources;
- Records of completed tasks and events; and
- Flagging of past due compliance issues.
With the Bison Engineering Compliance Tracking Database, missing deadlines
can be a thing of the past.
Air Toxics
Bison tracks the development of air toxics requirements under the
Federal Clean Air Act Amendments of 1990. EPA has been slow to promulgate
the National Emissions Standards for Hazardous Air Pollutants (NESHAP),
which define Maximum Achievable Control Technology (MACT) for different
industry categories. For this reason, limited focus has been directed
on air toxics requirements under the federal act. However, for some
industries, MACT requirements can be particularly challenging to achieve.
In addition, interim MACT requirements stemming from Section 112(g)
of the Federal Clean Air Act may apply to new sources or to facility
expansions or modifications. Bison is ready to assist you in analyzing
federal requirements and in determining a compliance strategy.
Control Technology Evaluations
Control technology evaluations play an important role in meeting many
federal and state air pollution regulations. Determining the appropriate
control technology involves a balancing of environmental impacts and
technological feasibility and establishing a dollar valuation for
environmental benefits. Capital costs, operating and maintenance costs
and impacts on the environment are all considerations when evaluating
control technologies.
Bison has conducted control technology evaluations for many types
of industries. We regularly review the EPA Clearinghouse of control
technology determinations and research the latest control technologies.
Our experience provides the foundation for evaluating control technology
for your facility and helps determine an appropriate and cost-effective
technology for your application.
Risk Management Plans
The recent codification of the Risk Management Plan (RMP) Program
required many companies to assess the quantity and quality of materials
stored or handled on site. This program focuses on preventing accidental
chemical and flammable/explosive releases, analyzing the consequences
of potential releases and coordinating with local emergency planning
personnel.
Bison has taken the initiative to explore and refine the most difficult
aspect of this program -- the off-site consequence analysis. Bison
can assist in defining potential release scenarios and analyzing the
consequences of these scenarios. Using a combination of dense gas
release models and explosive release calculations, Bison can refine
potential release scenarios to better reflect actual conditions during
a defined release and to limit the predicted impact from the release.
Emissions Testing &
Monitoring
For over 20 years, Bison has provided a full complement of air quality
services. A major part of our mission is our air emissions testing
services.
Bison is equipped to address air emissions testing requirements for
most pollutants. We work with numerous continuous monitoring systems
and are experienced in certification and auditing requirements. We
also design innovative ways to monitor emissions for industrial facilities.
Listed below are some of the key areas of our expertise.
Source Emissions and Performance Testing
Bison's approach to source testing differs from most testing companies.
We believe in working closely with our clients to prepare for the
emissions test. We continue that working relationship through the
tests and on to submission and acceptance of final test reports.
Bison offers the latest testing equipment and technology for source
emissions and performance testing. For example, our Bison Engineering
Source Testing (BEST) trailer contains a full suite of continuous
analyzers for gaseous pollutants. Once testing is complete, Bison
places a heavy emphasis on quality control checks of the data and
the test report. In many instances, we provide assistance to our clients
in gaining acceptance of the test results by the regulatory agency.
Often we provide assistance, as appropriate, in fine tuning facilities
or processes to achieve production targets while meeting emission
limits. Bison's goal is to provide the right knowledge and experience
to complete emission testing and to ensure emission compliance responsibilities
at facilities are met.
Bison's testing expertise goes beyond the standard EPA reference test
methods, our experience allows us to address the unique configuration
of our client's facilities in conducting required or informational
emissions tests.
We use our 20 years of experience to conduct particulate emissions
tests and fine particulate tests. Our mobile BEST trailer allows us
to pull up to your facility and be testing in a matter of minutes.
The temperature-controlled environment and data acquisition capabilities
of the BEST allow for accurate and timely gaseous emissions data.
Bison also has a mobile laboratory trailer that serves as a base of
operations for extended manual test methods and for conducting on-site
laboratory analysis.
Process optimization studies can be performed in order for a facility
to achieve maximum efficiency and still meet its permit emission limits.
Bison is sensitive to the difficulties industry has with producing
a quality product while complying with state and/or federal requirements.
Bison knows industrial processes and is ready to assist you in bringing
your processes into compliance while achieving production objectives.
Continuous Emissions Monitoring (CEM) Certifications
and Relative Accuracy Test Audits
Our BEST trailer allows us to move on-site and provide a self-supported
monitor certification service. Once the CEM system is installed
and
operational, Bison will complete relative accuracy test audits on
your system. Bison can also assist you in meeting your data reporting
requirements and CEM system quality assurance documentation and testing.
Relative Accuracy Test Audits (RATA) are performed annually on continuous
emissions monitoring (CEM) systems. Bison conducts RATAs on various
industrial processes. The BEST trailer allows for reference method
monitoring of nitrogen oxides (NOx), sulfur dioxide (SO2),
carbon monoxide (CO) and total hydrocarbons (THC). The BEST is used
to perform RATAs on various CEM systems, including those operating
on a wet or dry basis.
Opacity Monitoring
Bison has many years of experience in opacity monitoring and compliance.
We provide system audits, calibrations, operation, maintenance and
conditioning/test periods for Continuous Opacity Monitoring Systems
(COMS). Bison also has several certified and experienced visible emissions
evaluators available for opacity observations (Method 9, Method 22,
etc.).
Predictive Emissions Monitoring (PEM) Systems
Predictive Emissions Monitoring (PEM) systems are accepted by EPA
to take the place of CEMs for some facilities. PEMs predict pollutant
emission rates from a source based on correlating data from measured
operating variables, like system load, fuel usage, temperature and
percent excess oxygen in the stack gas.
The PEMs emissions correlation is typically calculated by first measuring
the actual pollutant at the source. As the pollutant is measured,
parameters, like the system load, fuel usage, temperature and other
factors, are varied and measured simultaneously. The variables are
analyzed with respect to the pollutant and an algorithm is written
to predict the pollutant concentration.
Ambient Monitoring &
Sampling
Bison has been building and operating ambient air and meteorological
monitoring networks since its beginning in 1980. Principals of the
firm have 28 years of experience operating ambient networks. Bison's
past and current projects are located throughout the Western US with
extensive work in the Rocky Mountain Region and the Pacific Northwest.
Currently, Bison operates ambient monitoring networks in Utah, Nevada,
North Dakota, Pennsylvania, Wyoming and Montana. This experience includes
work in PSD, Class I, non-attainment and other environmentally sensitive
areas.
Bison has a proven track record in measurement, evaluation, prediction,
and remediation of pollution effects on the environment. We develop
proven techniques to track and coordinate large amounts of data with
high recovery rates.
Ambient Air Quality Monitoring
Ambient Air Quality Monitoring
Bison's experience in particulate sampling includes:
- PM10 sampling using mass flow controlled
and volumetrically controlled samplers,
- PM2.5 sampling using beta-gauge technology,
and
- Total settled particulate (dustfall) collection.
We have in-house processing of dustfall samples, PM10
filters and PM2.5 filters in a climate-controlled
laboratory. We also offer gaseous ambient monitoring for N0x,
CO, CO2, SO2, and VOCs.
Our services include equipment selection, location siting and installation.
At the client's preference, we can operate the monitoring equipment.
We also offer system audit, calibration and certification services.
We encourage our clients to purchase their own monitoring equipment,
as present regulations usually require ambient air quality monitoring
both before and after a facility is constructed. Bison can also provide
monitoring plans and quality control/assurance manuals as required
by federal and state agencies.
©
Bison Engineering 2000-2004
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