Air Resources Group, LLC Air Quality and Environmental Services

New Source Review & Prevention of Significant Deterioration

The complexity of these programs hinder the growth of a facility because of restrictions on new construction and major modifications without proper expert oversight.  ARG has worked with a variety of industrial firms in many states to successfully navigate through the complex requirements.

Examples include:

• ARG represented a major international cement company in performing the necessary NSR review for permitting its proposed new facility.
• ARG represented a major printing company in front of the State Attorney General for violations of NSR. ARG’s negotiation led to a substantial penalty reduction and expedited permitting of the facility.
• ARG represented a major auto parts manufacturer in negotiating a Consent Order to resolve NSR/PSD violations for a major manufacturing facility it was seeking to purchase. This negotiation led to a multi-year study of the facility emissions, development of LAER strategies for process control and emissions control add-ons, and early Title V permitting of the facility. The buyer realized a substantial reduction in penalty as a result of ARG’s work in running penalty permutations using EPA’s BEN model. The project included the first ever interstate trade of VOC emission reduction credits.
• ARG represented a large integrated aluminum facility in PSD negotiations with a state agency. This effort involved the evaluation of the facility’s overall compliance status and the determination of PSD applicability to past practices and modifications made at the facility. The research done for this project included the evaluation of the regulatory history for SO2, fluorides, particulates, and other pollutants for aluminum plants dating to the early 1940’s. ARG also reviewed all existing emission point permits for individual sources and advised on the development of the Title V permit application for the facility.
• For a proposed new large cogeneration facility in a severe non-attainment area, ARG staff negotiated the NSR/PSD permits. The facility was eventually constructed with some of the most sophisticated emissions controls in the country and now serves as a model plant for cogeneration technology. ARG represented the plant in receiving admission to EPA’s Performance Track and New York’s Environmental Leaders programs.  ARG has worked with this facility since the early 1990’s.
• ARG provided a state Power Pool with comments on the impacts of New Source Review regulations on repowering existing facilities.