AquAeTer contracted to prepare Title V Air Operating Permit applications for seven Kerr-McGee (now TRONOX) creosote wood treating facilities. First, methodology was developed from available testing data and literature values (AP-42) for standardizing the emission factors for the various processes at a wood treatment facility. Secondly, state agencies were contacted to determined that these facilities were not major sources. In all cases, the facilities were either true minor facilities or synthetic minor facilities for hazardous air pollutants (HAPs). In addition, emissions were calculated for each facility that included point source emissions from production operations, such as, the condenser and vacuum pumps, the work and storage tanks and the gas/oil-fired boilers. Fugitive emissions were calculated for valves, flanges, waste treatment facilities, the retort doors openings, and the treated wood storage yards.
Even though it was a standardized approach, it was adaptable, and was accepted by each of the different States with minor adjustments for specific sites. In conclusion, the permits issued allowed the operational flexibility needed at each site. AquAeTer provided continued support at these sites with annual reporting, SARA reporting, and permit renewals.
AquAeTer provided the following services to its client for this sampling and reporting project:
- Title V Operating and Minor Source Permit Applications and Renewals
- Data Analysis
- Regulatory Support and Compliance
- Emissions Calculations
- Emissions Source Inventories
- Source and Ambient Air Testing
- Consulting and Data Evaluation