EQ was retained to serve as a technical and regulatory consultant in all matters relating to air pollution control at a major chemical facility. As participants with project teams on two independent plant expansion projects, EQ provided advice and a technical critique of proposed operations and emission control measures. We held the lead position in preparing air permit applications and technical support documentation for these projects. In support of these projects, EQ performed VOC emission calculations for various pieces of equipment, including reactor vessels, paint production lines, and organic liquid storage tanks. We performed air dispersion modeling analyses of fenceline toxic air contaminant impacts for compliance with Ohio EPA's Toxic Guidance Policy, and we provided in-depth training to the plant engineering staff regarding new source air permitting and other pertinent regulatory issues within the plant. EQ then prepared all emission calculations and technical support documentation for Ohio EPA PTI and PTO applications for miscellaneous modifications to the Resin II facility.

EQ has been involved with numerous air pollution control issues for an integrated steelmaking facility. Our engineering group evaluated particulate emissions from a BOF scrubber system and a quench tower, developed predictive software to categorize and control emission factors, performed engineering evaluations of an LMS (ladle metallurgical station), and designed a secondary capture gas quench system. Other engineering evaluations included capture modifications of the tilting runners and the blast furnace cast house. These highly complex evaluations helped to clarify operational issues and resulted in adjustments that improved overall control and kept the client in compliance with regulations.

For this project contracted out of Brooks AFB, Texas, EQ determined the emission rate of nitrogen oxides (NOX), sulfur dioxide (SO2), total hydrocarbons (THC), carbon monoxide (CO), particulate matter with an aerodynamic diameter less than or equal to a nominal 10 microns (PM10), and hazardous air pollutants (HAPs) for sixteen jet engines, two helicopter engines, and two ancillary power units. Each engine was operated at multiple fuel settings in order to determine fluctuations in emission rates at typical operating modes. This project is part of an ongoing study being conducted by the United States Air Force (USAF) to develop exhaust emission factor data for JP-8 fuel.

In a similar project, EQ conducted emissions sampling at the Hush House at Edwards AFB, California, to develop emission factors for two jet engines burning military JP-8 jet fuel: the Pratt & Whitney F100-PW-200 and the F100-PW-220. Emission factors were developed under varying jet engine load conditions for nitrogen oxides, sulfur dioxide, carbon monoxide, total hydrocarbons, and particulate matter with an aerodynamic diameter less than 10 microns (PM10) under varying jet engine load conditions. These data were used to estimate emissions from the Hush House to support Title V Permit preparation efforts.

Due to the unique exhaust configuration of the Hush House, a source-specific sampling methodology was developed that included the construction of a slipstream sampling system and incorporation of appropriate EPA reference sampling methods and sampling methods from the California Air Resources Board (CARB). The test protocol was reviewed and approved by the Kern County Air Pollution Control District.

As part of an independent study, EQ was directed by the USAF to determine the emission rate of criteria pollutants for two types of Aerospace Ground Support Equipment (AGSE) in order to determine the variance in emission rates based on type of fuel burned and maintenance history of AGSE.

EQ provided engineering services for troubleshooting the existing emission control system and designing a fugitive emission control system for a lime plant. EQ also characterized the lime kiln exhaust at various points in the system (temperature, pressure, flow rate, velocities, oxygen content) to determine system leakage and temperature profiles for use in improving control system performance. The interiors of the preheaters, multiclones, and baghouse were inspected to determine the need for redesigning and/or improving maintenance. A fugitive emission control design was also developed for all lime plant transfer points, storage silos, and housekeeping activities. The equipment additions/replacements/repairs performed for this project resulted in a significant reduction in energy usage and an increase in lime production capabilities. This project resulted in a 20% increase in production and a 25% reduction in client unit energy costs, and brought the facility into compliance.

EQ audited all existing emergency response plans, offsite consequence analyses, and prevention programs at a utility. We examined all safety and hazard operating procedures; training, maintenance, and compliance audits; and incident investigation procedures to determine their conformity with the requirements of the EPA's Accidental Release Prevention Program risk plan. Using current information or client generated updates, we prepared the Risk Management Plan for EPA's outline form and established more detailed internal documentation regarding the client's propane tanks (in Program 2 of ARPP).

EQ performed two comprehensive air emission inventories at the client's manufacturing complex with over 400 sources. The initial inventory evaluated all sources for compliance with applicable permits. As a result, EQ prepared applications for 40 additional sources. In the second inventory conducted in preparation for the Clean Air Act Title V permit, EQ identified applicable regulations and federally enforceable permit conditions, evaluated compliance, and developed a plan to maintain and document compliance activities.

EQ prepared a heat and mass balance for the kiln operation that defines the flue gas volume produced by the kiln operation and fuel gas composition (oxygen, carbon dioxide, sulfur dioxide, nitrogen, and water). An estimate of the dust loading was also prepared. This balance was used to evaluate the use of a fabric filter and ESP and to specify the design and performance.

EQ reviewed the applicable regulatory requirements for PM emissions from the kiln. The review included state implementation plan (SIP) limits (process weight equations), new source performance standards (NSPS), Maximum Achievable Control Technology (MACT) (proposed), opacity, and ambient air quality standards. This analysis was used to determine the maximum permissible opacity and mass emission rate for the proposed air pollution control device.

EQ also prepared an opacity prediction for the required PM emission limit. Kiln gas volume, particulate matter concentration, particle size distribution, and stack diameter data were used in the analysis.

After producing specifications for application of fabric filters and ESP technology for possible replacement of the existing ESP, we prepared a technical report that included the installed cost of each technology and the advantages, disadvantages, operating costs, and effects on process operations. Based on this review, a recommendation for abatement technology was provided.

EQ reviewed applicable sulfur dioxide regulations that may limit sulfur dioxide emissions from the kiln. This analysis was used to provide a target for sulfur dioxide abatement options and the effectiveness of each option.

To determine compliance with the NAAQS (3-hr, 24-hr, annual), EQ conducted a dispersion modeling analysis of sulfur dioxide emissions. A cost/benefit analysis was prepared that compared the cost of additional stack height versus the cost of increased sulfur dioxide control. Additional control methods included fuel sulfur limitations, add-on abatement equipment (adsorbers), and/or process controls.

We also prepared an analysis plan to evaluate the sulfur contribution of each raw material to the kiln. The plan included the number of samples, method of collection (composite, grab, or quarry core sampling, etc.), analytical methods, and reporting requirements. These data were used to recommend possible mix design changes to manage sulfur dioxide emissions.

EQ's air quality staff prepared several air permit applications for a major chemical manufacturer to expand its monomer plant and debottleneck its polymer plant. EQ also documented historic VOC and ozone-depleting substance (CFC and HCFC) emission charges in support of revised permit applications for several new units. Other projects involved emission estimates of criteria pollutants and HAPs. We also worked on behalf of our clients to petition State and Federal agencies for regulatory relief.

EQ's multidisciplinary staff provide key services covering the total spectrum of your environmental engineering requirements from project planning to complex site assessment/remediation projects. This listing contains just a few of the projects that EQ has completed for our clients.

If you would like additional information or if you have any questions concerning these projects please contact Bob McCullough at (800) 229-7495.