Air Permitting Compliance Support for Industrial Laundry Facilities
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Project Objective

Faced with a United States Environmental Protection Agency Consent Agreement and Final Order, a confidential industrial laundry client engaged Geosyntec to evaluate air emissions at 35 of its facilities in 15 states and bring them into compliance with federal and state requirements governing air emissions and permitting. The client needed help managing the operation as well as engaging in regulatory agency negotiations to obtain the necessary permits.

Geosyntec’s Scope of Services

Working state by state, Geosyntec’s approach began by developing a template spreadsheet tool for field data collection and for calculating emissions from our client’s primary sources: industrial washing, drying, wastewater treatment, and fuel combustion, particularly from industrial boilers. Using this tool, Geosyntec visited each facility and inventoried facility equipment and processes. Based on the specific equipment and design of each facility, Geosyntec calculated potential and actual emissions on a source-by-source basis, including for criteria pollutants and hazardous air pollutants.

After completing emission calculations for each facility, Geosyntec assessed the applicable regulatory requirements for each site and then met with each involved regulatory agency to disclose the intent to permit, present the calculated emissions, and develop a pathway for permitting. In some cases, the permitting pathway was straightforward: completion of a simple registration form or standard permit application. In other cases, the pathway involved dispersion modeling using AERSCREEN or AERMOD, detailed regulatory assessments for Best Available Control Technology (BACT) applicability and compliance, air toxics evaluations, preparation of construction or operating permit applications, and development of capping strategies to maintain emissions below Title V thresholds.

Notable Accomplishments

Geosyntec worked closely with the client to communicate clearly with the involved agencies, respond to agency questions, and review draft permits, ultimately allowing our client to obtain its permits without incurring penalties associated with the previously unpermitted sources. Effective project management allowed Geosyntec to successfully manage the varied permitting pathways for the 35 facilities. Our strong relationships with the regulatory communities across multiple states facilitated the permitting process.