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Case Studies

We invite you to review select case studies that span our services areas and our client's wide array of industries.  The Case Studies present our Client's Challenge, ALL4's Solution, and The Results.  

Air Quality Compliance

Compliance Assistance

Client’s Challenge: Lehigh Cement Company located in Evansville, PA is subject to 40 CFR 63 Subpart LLL and 25 Pa. Code §139.102(3).  These rules require that compliance with the facility’s emission limits be demonstrated using continuous monitoring systems (CMS).  The CMS data collected during the reporting period must be evaluated for validity and representativeness. 

Managing the recordkeeping and reporting processes are very involved and requiring an in-depth understanding of the applicable regulations.  ALL4 was tasked with overseeing of all aspects of the compliance program.

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MACT Support

Client’s Challenge: ALL4’s client is a major manufacturer of Portland cement that operates two long-wet kilns that fire a variety of fuels including hazardous waste fuels.  The facility is subject to a number of different Subparts of the National Emissions Standards for Hazardous Air Pollutants for Source Categories also known as the Maximum Achievable Control Technology or MACT standards.   Since the facility fires hazardous waste fuels, a critical rule for the facility is 40 CFR Part 63, Subpart EEE the MACT standards for hazardous waste combustors.  ALL4 was asked to assist in all aspects of the client’s planning for, and demonstrating compliance with Subpart EEE. 

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Air Quality Permitting

Plantwide Applicability Limit (PAL) Permit

Client’s Challenge: The facility operates multiple adhesive machines on which specialty adhesive materials (formulated on-site) are applied to substrate (e.g., paper).  The facility was constrained from a flexibility standpoint as every “physical change or change in the method of operation” was potentially subject to permitting including a New Source Review (NSR) applicability analysis.  Changes in critical products and processes were routinely delayed for months while permit applications were being prepared and reviewed.

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Natural Gas Combustion Turbine

Client’s challenge: The client desired to install a natural gas-fired combustion turbine with a heat recovery steam generator (HRSG) to provide onsite electricity for the Pennsylvania manufacturing facility.  Because of the timing of the project just prior to implementation of the Prevention of Significant Deterioration (PSD) and Title V Greenhouse Gas (GHG) Tailoring Rule, the client was concerned for major delays in the permitting process.  Of specific concern was the potential for unknown issues with regard to addressing the requirement to determine the Best Available Control Technology (BACT) for GHG emissions; an analysis for which there was no regulatory precedent.  The client’s goal was to acquire the necessary Plan Approval and begin actual construction prior to the effective date of Step 2 of the Tailoring Rule.

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Prevention of Significant Deterioration (PSD) Permit Application

Client's Challenge: ALL4 was asked to assist the client’s Corporate and Mill staff with developing an air permitting strategy for major facility upgrades that were being planned.  The client’s goal was to replace older inefficient equipment in the power generation and chemical recovery areas with new units designed to increase efficiency, increase the Mill’s capacity to fire biomass fuels, and generate additional electric power to replace purchased power, while at the same time reducing the Mill’s overall environmental footprint.  ALL4 was also assigned responsibility for supporting the client’s negotiations with the State Agency and with developing the requisite air permit application and supporting documentation including air quality dispersion modeling.

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Air Quality Dispersion Modeling

Air Toxics Screening Tool

Client’s Challenge: The client is a carpet manufacturing facility that operates several similar processing lines that apply finishes to the back of carpets. The finish being applied is dependent on a wide range of customer specifications, and thus a diverse mixture of finishes with different individual components is required.  Customer demands often dictate that a new finishing material be entered into the production process, often times on a quick turnaround.  Meeting customer needs is challenging in a state that requires complex air toxics modeling for any air toxics emissions increase or when any new air toxic not previously emitted is introduced to the production line.  To address the need to perform frequent air toxics modeling quickly, the client needed a screening toxics modeling tool that could automatically and quickly quantify air toxics concentrations based on the entry of new finishes and their individual components.

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Dispersion Modeling Analysis

Client’s Challenge: The client planned to make modifications to their Lime Kilns that included installing natural gas burners.  The modification required a construction permit under the Clean Air Act (CAA) Prevention of Deterioration (PSD) permit program.  The modification to the Lime Kilns resulted in a significant increase in nitrogen dioxide (NO2) emissions.  Under the PSD program any criteria pollutant emissions that results in a significant increase (as defined by the program) requires an air dispersion modeling analysis to demonstrate that the increase in emissions will not exceed the National Ambient Air Quality Standards (NAAQS).  At the time of the project the NO2 NAAQS had just been updated to a more stringent 1-hour standard.

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Continuous, Ambient, and Meteorological Monitoring

Meteorological Monitoring System

Client’s Challenge: The client operates a pulp and paper mill in Pennsylvania which is situated in a valley with elevation changes of over 500 feet from the valley floor to the peaks of the surrounding hills.  Because of the location of the mill the meteorological conditions presented at the mill are significantly influenced by the surrounding terrain.  If the mill were to add any new emission units or modify any emission units that would require a Prevention of Significant Deterioration (PSD) permit and the modifications resulted in project emissions exceeding the PSD significance levels an air quality modeling analysis would be required.  To complete an air quality modeling analysis meteorological data that is representative of the atmospheric conditions at the Mill would be required.  Given the topographic setting of the mill the client would be unable to justify the use of nearby National Weather Service (NWS) data that is collected in an entirely different topographic setting.  Therefore, a minimum of one (1) year of onsite meteorological data would need to be collected in order to perform an air quality analysis in support of a PSD permit application, resulting in significant increases in the duration of any future permitting effort and impacting the Mill’s ability to obtain major source permits.

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Revision 8 Implementation

Client’s Challenge: The Pennsylvania Department of Environmental Protection (PADEP) promulgated Revision 8 of the Continuous Source Monitoring Manual (“Manual”) affecting over 95 facilities in Pennsylvania that utilize continuous monitoring systems (CMS) to comply with the monitoring requirements of 25 Pa. Code §139.102(3).  The Manual contains requirements for the design, performance, testing, recordkeeping, reporting, and quality assurance (QA) activities for CMS and was developed to provide consistency with 40 CFR 75. 

Revision 8 of the Manual required all affected sources to upgrade their data acquisition and handling system (DAHS) to meet the new data validation and electronic recordkeeping and reporting requirements, as well as to demonstrate compliance with the more stringent monitoring and quality assurance requirements.

ALL4 was tasked with implementation of all aspects of the Manual for various facilities in the utility, lime, cement, pulp and paper, and wood products sectors

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Environmental Program Management

Air Quality Regulatory Updates

Client’s Challenge: Providing air quality regulatory updates from a corporate level to 30 plus Mills to ensure a transfer of current knowledge and overall consistency in the company’s approach to air quality requirements.

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Overall Plant Air Quality/Environmental Support

Client’s Challenge: East Penn Manufacturing Co., Inc. (EPM) is comprised of six (6) lead acid battery manufacturing facilities, thirty-four (34) lead oxide production units, a secondary lead smelter, a plastic recovery facility, a sulfuric acid recovery facility, a plastic injection molding facility, and miscellaneous support operations.  EPM wanted an air quality consulting firm that could handle all of the facilities air quality needs including compliance, permitting, monitoring, modeling, climate change, and program management.  EPM selected All4 in 2004 to assist with the management of the EPM air quality program.

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Multimedia Regulatory Analysis

Multimedia Regulatory Compliance and Analysis

Client’s Challenge: The Client has five (5) closed landfills in the state of New Jersey that are subject to a variety of regulations and are operating pursuant to different environmental permits.  As landfills that are closed, they represent a cost and liability, but do not provide any additional opportunities for revenue and/or profit.  As such, the Client’s goals are simply to (1) ensure compliance with environmental requirements, and (2) control costs and expenses at these sites.

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Preparation of Greenhouse Gas Monitoring Plan

Client’s Challenge: The U.S. Environmental Protection Agency (U.S. EPA) developed proposed revisions to 40 CFR Part 60, Subparts Ce and Ec that dramatically changed the process for developing emission limits and, ultimately, the emission limits themselves.  In addition, there were other proposed revisions to waste management planning, monitoring, and overall compliance management.  These proposed revisions drastically impacted an entire industry sector and required the development of a technical and legal comment document to address the potential impacts on the industry and to preserve the industry’s right for further legal action.

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Climate Change

Preparation of Comments on the Proposed Mandatory Reporting of Greenhouse Gases Rule

Client’s Challenge: U.S. EPA proposed the Mandatory Reporting of Greenhouse Gases Rule (the GHG Reporting Rule) on April 10, 2009.  This proposed new rule would require certain industrial facilities to monitor and report to U.S. EPA their annual emissions of Greenhouse Gases (GHG).  Member companies of an industry trade association in the U.S. would become subject to this proposed rule when it became final.  This would result in the additional burdens on production facilities within this industry group to monitor data, calculate GHG emissions and submit annual reports to U.S. EPA.  The trade association representing these companies wished to submit comments to the U.S. EPA on the proposed GHG Reporting Rule.  Comments on this proposed rule were due by June 9, 2009.

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Preparation of Greenhouse Gas Monitoring Plan

Client’s Challenge: U.S. EPA issued the Mandatory Reporting of Greenhouse Gases Rule (the GHG Reporting Rule) on October 30, 2009.  The GHG Reporting Rule requires certain facilities to monitor and report annual emissions of Greenhouse Gases (GHG).  Facilities and suppliers that are subject to the GHG Reporting Rule must comply with the General Provisions (40 CFR Part 98, Subpart A) and the provisions of all other applicable subparts of 40 CFR Part 98, which include, but are not limited to, requirements for data monitoring, quality assurance, recordkeeping, a variety of required or available specific emissions calculation methodologies, and reporting content.  Data monitoring and recordkeeping requirements for reporting year 2010 began January 1, 2010.  Included as part of the GHG Reporting Rule is a requirement to prepare and maintain a written GHG Monitoring Plan.  All4 prepared written GHG Monitoring Plans for numerous facilities in a variety of industries including, but not limited to, pulp and paper manufacturing, lead production and petroleum refineries and suppliers of petroleum products.

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