A representative description of projects completed by the Prince Environmental staff while at Prince Environmental and for former employers is presented below.
NSR Permit / Regulatory Liaison - Chemical Plant
Secured TCEQ air permit for new production units at a gulf coast chemical manufacturing facility. Because of elevated SO2 concentrations at a nearby TCEQ monitor, TCEQ had taken a position that no permits for new sources of SO2 would be issued to plants in the area. In response, prepared sound technical analyses demonstrating (1) the site could not have been the cause of the high SO2 levels using process data and dispersion modeling based on actual meteorological conditions at the time of the monitored concentrations, and (2) the site had actually helped to improve air quality in the area by reducing actual SO2 emissions by more than 80% over the prior five years. These analyses were presented to the TCEQ Executive Director and the TCEQ legal, permitting and enforcement staff, and resulted in issuance of the needed permit prior to the expiration of creditable emission reductions that allowed the site to net out of PSD review.
NSR Permit / Regulatory Liaison - Manufacturing Operation
Provided air permit and regulatory liaison support for two trailer manufacturing operations in Texas. Prince Environmental was retained by client after efforts by prior consultant had resulted in the permit renewal deadline for one site being missed and the permit amendment for the second site being voided. TCEQ staff’s initial position was that the first site was operating without a permit and thus was considered to be a “new site” required to install a thermal oxidizer per BACT VOC control requirements for new facilities. Key support consisted of performing a Tier-III BACT evaluation that included an economic analysis concluding the estimated $1.4 million in thermal oxidizer capital costs were economically unreasonable and an evaluation demonstrating TCEQ should in fact not require controls based on published TCEQ permitting policy and recent TCEQ permitting actions for similar facilities. The analysis was then presented in a face-to-face meeting with the Director of the TCEQ Air Permits Division and resulted in TCEQ agreeing that a thermal oxidizer would in fact not be required. The project concluded with the issuance of permits for both sites that were protective of the client’s interests.
PSD Permit / Expert Testimony - Coal Fired Power Plant
PSD permit application for expansions to a coal-fired power plant in Texas. Tasks included calculating criteria pollutant, heavy metal and fugitive particulate emission rates, performing BACT and PSD pre-construction monitoring analyses, and conducting PSD increment consumption and heavy metals modeling. Provided expert testimony in contested case hearing on emissions and dispersion modeling that resulted in successful permit issuance.
NSR Permit / Expert Testimony - Concrete Crushing Facility
Provided expert testimony in a TCEQ contested case hearing for relocation of an existing concrete recycling operation in Houston. Support including preparing air emissions calculations for recycled concrete hauling, crushing, transfer and storage operations, evaluating the effectiveness of emissions control measures, performing air dispersion modeling, and providing expert testimony that supported permit issuance. Key to the project was successfully demonstrating that the approach used to calculate emissions, perform air dispersion modeling and establish ambient background concentrations was technically superior to the analyses performed by the plaintiff’s experts. A permit was subsequently issued by TCEQ based on the testimony provided and the recommendations of the Administrative Law Judge (ALJ) presiding in the case.
Litigation Support - Wood Preservatives Plant
Provided Toxic Tort litigation support to a wood preservative plant alleged to be the source of adverse health effects in the surrounding community. Support included critical review of expert reports for the plaintiff’s air emissions and dispersion modeling expert. Based on this review, assisted defendant’s expert in preparing opinions pointing out the invalid nature of the emissions calculation methodologies, dispersion modeling techniques, and conclusions reached, by the plaintiff’s expert.
Fast Track NSR Permit - Chemical Plant
Prepared a fast track TCEQ permit application that allowed for an approximate two-fold production increase at a major Gulf Coast chemical manufacturing plant. Key project strategies included working closely with client's environmental, process and design staff, stressing the net environmental benefits of the project in the application, and drafting the initial draft permit provisions to allow negotiations to start at a point most favorable to the client.
Title V Permitting - Petroleum Pipeline System
Managed the preparation of 29 Title V and synthetic minor air permit applications in 11 states for a petroleum products pipeline system. Project included site visits to identify emission source types and preparing prototype emission calculation spreadsheets, applicable requirements and monitoring recordkeeping and reporting requirements for inclusion in a prototype permit application. Prototype application was then used as template for efficient preparation of remaining applications.
Title V Permit - Marine Terminal
Managed the preparation of a Title V permit application for a major Gulf Coast Marine Terminal. Project included identifying site marketing goals, defining applicable requirements, calculating potential to emit emission, proposing cost-efficient monitoring, recordkeeping and reporting, identifying potential sources of emission offsets and preparing the Title V application. The project was executed in a manner that facilitated the ability to capitalize on future market opportunities while also limiting ongoing recordkeeping and reporting costs.
Retrospective PSD Review - Refinery
PSD analysis pursuant to EPA enforcement action at a Midwest U.S. Refinery. Project included obtaining production, emission inventory, engineering design and emissions monitoring information over a 23 year period for use in calculating FCCU regenerator actual and potential emissions. Emissions estimates were used for the purposes of identifying whether physical and operational changes had triggered PSD review.
Retrospective PSD Review - Chemical Plant
PSD / Non-Attainment NSR analysis for Petrochemical facility in anticipation of EPA enforcement initiative. Reviewed capital authorization requests, changes in emissions and engineering data over a 25-year period to determine if PSD or NNSR had been triggered.
Dispersion Modeling / Regulatory Liaison - Synthetic Rubber Plant
Provided comprehensive air quality support for a Gulf Coast styrene-butadiene rubber (SBR) manufacturer related to predicted off-site concentrations of styrene, 1-3 butadiene and various other chemical species. Monitoring conducted by TCEQ in the heavily industrialized area near the plant indicated 1-3 butadiene concentrations high enough to have the area placed on TCEQ’s “Air Pollutant Watch List” (APWL). With the APWL designation came an increased level of scrutiny by the TCEQ Toxicology Section of any air permitting actions requesting an increase in 1-3 butadiene emissions. Support provided by Prince Environmental included performing TIER III air dispersion modeling studies for two 1-3 butadiene air permitting actions, and meeting with TCEQ permitting and toxicology staff to advocate the acceptability of the proposed projects. Key arguments put forth in these meetings were the acceptability of predicted off-site impacts, the robust nature of emissions control measures being proposed, and past efforts by the site that resulted in significant reductions in 1-3 butadiene emissions. Follow-up support including representing the client’s interests in TCEQ stakeholder group meetings on modeling and effects review policy for ESL pollutants, tracking and commenting on TCEQ’s development of new ESLs for styrene and 1-3 butadiene, and meeting with TCEQ, client and client’s toxicologist to proactively advocate the TCEQ develop new ESLs for additional constituents that included consideration of health effects study data compiled by the client.
Due Diligence Audit - Natural Gas Processing and Transmission
Directed air quality portion of a due diligence audit for multi-billion dollar acquisition of natural gas processing and transmission assets in 20 different states. Work included reviewing air permit, compliance and emission inventory records to identify potential future costs associated with Title V permit preparation and compliance efforts, and emissions abatement retrofit costs pursuant to pending enforcement actions and future MACT requirements.
Compliance Audit - Cogeneration Facility
Performed PSD permit compliance audit pursuant to state audit privilege act program for a major Gulf Coast cogeneration facility. Scope of audit included compliance with terms of existing PSD permit and NSPS requirements. Key portions of the audit included review of CEMS data and interviews of site personnel to determine if the plant was being operated in accordance with the current permit, and if current emission levels constituted a major modification that triggered the need for a PSD permit amendment.