Expertise in Air Permitting

MSI has provided turn-key, air quality consulting services for procurement of air permits for numerous sources, including the only "major source" permitted in New York City in the past 10 years.

Below are descriptions of several representative MSI air permitting projects. For those projects which preceded MSI, design and management was provided by Timothy Minnich and/or Robert Scotto while employed by another firm.

Client: Metcalf & Eddy of New York, Inc.
Project: Cogeneration Facility Air Permitting
Location: Brooklyn, New York

In 1997, MSI completed all necessary pre-construction air quality analyses to support permit procurement for a state-of-the-art floating 28.5 megawatt (MW) cogeneration facility to be permanently moored to a pier in the East River. This facility, currently on hold for financial reasons, will supply steam to three Brooklyn housing projects. MSI worked closely with the design engineers to ensure that facility was not defined as a "major source", and that the delicate balance between facility engineering decisions and permit procurement time was maintained while ensuring that power supply contractual provisions were not jeopardized.

Client: G.M.D. Shipyard
Project: Title V Permitting
Location: Brooklyn, New York

In 1997, MSI completed procurement of a facility air permit, in accordance with requirements set forth under Title V of the Clean Air Act, for the G.M.D. Shipyard in the Brooklyn Navy Yard. The shipyard performs ship repair and underside restoration and coating, and generates a significant quantity of volatile organic compounds (VOCs), particulate matter, and hazardous air pollutants (HAP). The facility permit application was prepared in conformance with the 6 NYCRR Part 201 regulations, as revised on March 20, 1996.

Client: Cogeneration Technologies, Inc.
Project: Brooklyn Navy Yard Cogeneration Facility Air Permitting
Location: Brooklyn, New York

In 1995, MSI completed all necessary pre-construction air permitting in support of a major source, gas-fired cogeneration facility in the Brooklyn Navy Yard in Brooklyn, New York. All analyses were performed in accordance with the then-proposed revisions of the New York SIP and provisions of the New York State Environmental Quality Review Regulations as promulgated by the New York State Uniform Procedures Act. A significant accomplishment was the procurement of the required NAA and PSD Permits to Construct within 7 months of application submittal. Work involved demonstration of appropriate pollution controls pursuant to NAA and PSD regulations and identification of available emissions offsets for nonattainment pollutants. BACT engineering analyses were performed for SO2 and PM10, and engineering analyses for NOx, VOCs, and CO. Because the performance on this project was recognized as exceptional, the submittal package was identified by the New York State Department of Environmental Conservation (NYSDEC) as a "Benchmark Permit", toward which other applicants were directed.

Client: EnSafe/Allen & Hoshall
Project: Expedited Technical Review
Location: Charleston, South Carolina

In 1994, MSI performed a comprehensive, expedited technical review of a Focused Field Investigation (FFI) report which was prepared by EnSafe/Allen & Hoshall under its Navy CLEAN Contract. The review addressed the air quality issues associated with a $1 million soil, groundwater, and indoor air study to assess contaminant migration through the vadose zone and into several buildings at Naval Base Charleston. Because results of the FFI are potentially subject to litigation, MSI was requested by the client to perform a comprehensive examination of all air-related aspects of the FFI. We were able to complete this review within 3 weeks and provide the information to USEPA Region 4 to demonstrate the technical validity of the investigation.

Client: Cogeneration Technologies, Inc.
Project: Warbasse Cogeneration Facility Air Permitting
Location: Brooklyn, New York

In 1993, MSI designed and managed a comprehensive air permitting study in support of a project to repower the existing Warbasse Cogeneration Facility in Brooklyn, New York. Analyses were performed to demonstrate compliance with state and federal requirements (NSR, NAA, and PSD) as they apply to existing major NOx sources and with the City of New York's Environmental Quality Review process. MSI also managed all phases of the CEM system procurement effort, including vendor selection and oversight.

Client: Vermont Integrated Waste Solutions, Inc.
Project: Rutland Resource Recovery Facility Air Permitting
Location: Rutland, Vermont

In 1992, MSI performed a comprehensive engineering and permitting assessment of the Rutland Resource Recovery Facility to address a variety of solid waste and air toxics issues as required under Vermont's 1987 Solid Waste Act (Act 78) and its Air Pollution Control Regulation 5-261 (Control of Hazardous Air Contaminants). A detailed review of 26 other mass-burn, energy-recovery municipal solid waste (MSW) incinerators which have come on-line in the US and Europe since 1985 was conducted for a total of 7 contaminants for which facility emission rates were demonstrated as exceeding specified thresholds (action levels). Stack test data were evaluated to determine the lowest emission rate achieved for each contaminant of concern. These emission rates were used to establish a Hazardous Most Stringent Emission Rate (HMSER) for that category of source. A "top-down" BACT analysis was conducted to identify and evaluate several alternate control technologies to reduce facility emissions to the lowest permitted level in practice. Refined air dispersion modeling was also performed. All work was conducted in close cooperation with the Vermont Agency of Natural Resources (ANR).

Client: Westchester County, New York
Project: Yonkers Joint Treatment Plant Air Permitting
Location: Yonkers, New York

In 1994, MSI performed an air quality impact analysis to evaluate hydrogen sulfide and ammonia emission control efficiencies in support of an Application for a Permit to Construct for a proposed dewatering facility at the Joint Treatment Plant in Yonkers, New York. Odor impacts were assessed with respect to established NYSDEC ambient concentrations which may be associated with the occurrence of nuisance odors. All analyses were conducted in accordance with the NYSDEC Air Guide-1.

Client: EnSafe, Inc.
Project: RI/FS Air Pathway Analyses
Location: Olaton, Kentucky

MSI designed and managed the remedial investigation (RI) baseline air pathway analysis (APA), as well as several feasibility study (FS) APAs, to facilitate evaluation of remedial alternatives proposed by the responsible party for the Fort Hartford Mine Quarry Superfund Site in Olaton, Kentucky. The project involved procurement of USEPA Region 4 approval of a site-specific modeling approach to assess both on-site and off-site exposures resulting from the passive-release ammonia gases from a complex underground mine in which by-product salt cake fines generated from secondary aluminum recovery operations were disposed. The RI/FS APA results have been accepted by both the USEPA and the Kentucky Department of Natural Resources and Environmental Protection (KDNREP) pursuant to issuance of an Administrative Consent Order (ACO) detailing the remedial actions to be implemented.

Subsequent to the ACO issuance, MSI provided EnSafe with APA support during preparation of the Remedial Design Work Plan. A primary focus of this effort was the recent design and implementation of a focused perimeter monitoring program to evidence that off-site exposures were not exceeding applicable KDNREP toxic ambient limits (TALs) for ammonia.

© 2002 Minnich and Scotto, Inc.