Owners and managers of industrial, utility, and institutional facilities are constantly challenged by complex air quality regulations. Regulations such as New Source Review (NSR), Prevention of Significant Deterioration (PSD), and Maximum Available Control Technology (MACT) require a significant level of expertise and resources. In addition to on-going compliance requirements, these regulations may be triggered by facility expansions and/or modifications. However, the speed and cost of facility expansions and modifications are critical to market competitiveness. Specific regulatory expertise and additional resources are often required to expedite the regulatory permit process and increase cost efficiency.
Air Quality: City University of New York (CUNY) – Environmental Compliance Program
The City University of New York (CUNY) is a system of 19 colleges located in New York City. Under a five-year indefinite delivery contract and a two-year follow-up contract, O’Brien & Gere assisted CUNY with its environmental compliance initiative, which addressed diverse, multidisciplinary environmental compliance programs. As one element, O’Brien & Gere evaluated the compliance status of the air programs at each college. Activities included developing individual campus-wide compliance strategies; securing New York State and New York City Department of Environmental Protection air permits; evaluating incinerator operations for regulatory compliance; preparing tracking spreadsheets for nitrogen oxides and other required monitoring; evaluating options for emission reduction credits; and developing greenhouse gas inventories.
Involved concurrent activities on several campuses and multi-jurisdictional compliance assistance (federal, state, and New York City).
Air Quality: Temple University – Alternative Fuel, Air Permitting Process
As part of its commitment to sustainability and environmental stewardship, Temple University chose to use an alternative fuel to offset the use of No. 6 fuel oil in central steam plant boilers at the Main Campus. The University identified several alternative fuel options as part of its Climate Action Plan (CAP), which was prepared in collaboration with O'Brien & Gere. The University retained O'Brien & Gere to assist with alternative fuel selection and to obtain the necessary environmental approvals to use the fuel in its boilers. O'Brien & Gere evaluated the economic feasibility of various alternative fuels such as black waste vegetable oil, vegetable oil, yellow grease, and biodiesel; the economic evaluation focused on current market supply and demand, as well as pricing.
Demonstrated that an alternative fuel would not trigger significant regulatory requirements or equipment modifications.
Air Testing and Engineering Controls Evaluation
O’Brien & Gere provided air quality compliance services to support Akebono’s Clarksville, TN wheel end assembly manufacturing facility. Due to various operations, air emissions were generated consisting of iron dust and graphite, which were dealt with by reconfiguring the exhaust arrangement to vent outdoors resulting in particulate deposition on surfaces in and around the manufacturing building. Air emissions testing of specific emissions sources was conducted in order to discover the main sources of particulate deposition at the facility. Subsequently, testing was completed on four machining lines to develop the emission profile and complete characterization of the quantity and size of particulate emissions generated from process operations. O’Brien & Gere also evaluated additional add-on pollution control equipment and conducted a technical and economic feasibility study for the installation of HEPA-filters in order to reduce particulate matter. Following testing and evaluation, O’Brien & Gere prepared a report summarizing results of the field sampling and engineering controls evaluation in order to assist Akebono with choosing the best strategy to reduce iron dust emissions and eliminate iron deposition.
Conducted a technical/economic feasibility study for the installation of HEPA-filters, conducted air emissions testing, and developed particulate matter facility profile.