Air Quality Permitting
Bison Engineering’s 29+ years of experience in air quality permitting and regulatory analysis range from preparation and submission of air permits to extensive compliance assurance follow-up. Our experience allows us to design an approach to air regulatory issues to meet your needs in a cost-effective manner.
One of the first critical steps in planning for a new or expanded facility is assuring the necessary pre-construction permits are obtained. Bison Engineering helps clients apply for and receive appropriate environmental 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 the permits.
We prepare environmental permit applications ranging from a few pages to several hundred pages. Our permitting clients include power generation, chemical manufacturing, petroleum refining, food products, wood products, mining, lime manufacturing, government agencies, Indian tribes and a host of other small and large industries.
PSD/NSR/State Permit Applications
Permitting regulations that apply to our clients’ projects generally range from state or local requirements for minor modifications to federal Prevention of Significant Deterioration (PSD) or Nonattainment New Source Review (NSR) rules for major sources. As part of our air permitting services, Bison can help your company navigate the sea of regulations to get the right permits at the right time.
Title V Operating Permit Application/Negotiations
Bison Engineering has extensive experience in preparing applications for Title V Operating Permits. In addition, Bison provides consulting services to clients so they can limit emissions to avoid the need for a Title V Operating Permit. Bison’s permitting strategy provides complete and accurate applications that promote operational flexibility and reduce a source’s liability and recordkeeping and reporting requirements. After submission, Bison will also help negotiate your permit with the appropriate regulatory agency to address necessary requirements, while controlling compliance responsibilities and liabilities.
Air Dispersion Modeling
In today’s regulatory environment, growing and expanding industries generally require an air quality analysis to modify operations and permits. In most cases, air quality analysis requires air dispersion modeling.
Bison’s reputation for performing dispersion modeling analysis is well known. Our modeling 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 (SIPs). Our 29+ years of air dispersion modeling experience is extensive and our highly trained team is skilled in the use of all current regulatory models.
Bison has the knowledge, expertise and equipment to perform any air dispersion modeling analysis required for your facility.
A properly estimated inventory will determine which regulations apply, the emissions fees that need to be paid and what level of pollution controls 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 associations studies, other EPA databases and those derived from 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 emissions estimates.
Compliance Assurance Monitoring Plans
EPA’s Compliance Assurance Monitoring (CAM) is applicable to emissions units located at sources that require a Title V Operating Permit, are subject to an emissions limitation, use an add-on control device and would be a major stationary source of air pollution without emission controls. For most facilities (those with a Title V Operating Permit or completed application for one), a CAM plan will need to be submitted at the time of renewal of your Title V Operating Permit.
Bison Engineering 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.
Bison Engineering 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 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 as well as establishing a dollar valuation for the environmental benefits. Capital costs, operating and maintenance costs and impacts on the environment are all considered when evaluating control technologies.
Bison Engineering has conducted control technology evaluations for many types of industries. In fact, we have the distinction of having worked on the first-in-the-nation PM2.5 BACT analysis. We regularly review the EPA Clearinghouse for determinations and research on the latest control technologies. Our experience provides the foundation for evaluating control technologies for your facility and helps determine an appropriate and cost-effective technology for your application.
The 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 release and coordinating with local emergency planning personnel.
Bison Engineering 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 methods 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.
In recent years, states have been implementing permitting programs for the oil and gas industry to account for emissions at operator’s wellsites. At this time, states vary greatly with their programs, registration documentation, and control requirements. Failure to register, lack of required control equipment, or under-reporting of emissions may result in significant penalties. This can be a difficult task for operators since they may operate many wells in various states and must make sure they are complying with the correct regulations for each state.
Bison Engineering will confidentially analyze the emissions from your facility based on your production rates, on-site equipment, and chemical characteristics of the oil and/or gas being produced. Bison can help your company understand the permitting/registration processes for your facility and what actions need to be taken to assure compliance with each state’s regulations.
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