BTEC provides high-quality environmental consulting and testing services in the following generalized categories:

• Air Pollutant Emissions Testing
• Air Emissions Training
• Ambient Air Monitoring
• Industrial Hygiene Sampling
• New Source Review Permitting
• Title V Permitting
• Air Dispersion Modeling
• Regulatory Compliance Assessments
• Miscellaneous Compliance Assistance
• Air Pollutant Emissions Reporting

The environmental consulting and testing services provided by BTEC pursuant to each of these eight generalized categories are summarized below.

Air Pollutant Emissions Testing

BTEC has the experience, knowledge, and equipment necessary to evaluate air pollutant emission rates from a myriad of air pollution sources. These emissions testing services can be divided into three categories: (1) diagnostic and design testing, (2) performance and engineering testing, and (3) compliance testing. For each testing category, BTEC has the experience and expertise to understand the project goals and requirements and to incorporate these goals and requirements into a site-specific emissions test plan.

Diagnostic and design testing has been conducted by BTEC’s professionals on numerous processes to determine actual baseline concentrations and flow parameters for the purpose of facilitating accurate design specifications. Diagnostic volatile organic compound (VOC) testing on thermal oxidizer control equipment has been utilized to improve destruction efficiency performance. One of the secondary benefits of optimizing the performance of an oxidizer is the ability to perhaps lower the operating temperature, thereby realizing a savings in operating costs. Particle size determination testing has been performed to accurately determine the most efficient method of particulate emissions control.

Performance and engineering testing has been extensively utilized by BTEC personnel for a number of different purposes, the first being to determine if the equipment meets the performance guarantee criteria from the manufacturer. BTEC has conducted engineering emissions test programs to set-up and tune large combustion turbines. Engineering testing can also be used on pilot scale processes and different material formulations to determine their impact on the various emissions and can be conducted in conjunction with permit renewal or revisions to increase production or to place the facility or process in a different category based on actual emissions as opposed to calculated emissions.

Compliance emissions testing is used to show compliance with federal, state, or municipal regulations or permit requirements. Testing of this nature requires a complete knowledge of individual methods and their respective limitations. The most important aspects of compliance testing are coordination between the testing firm, the facility, and the relevant regulatory agency. BTEC personnel have conducted hundreds of compliance tests throughout North America and have worked closely with most agencies in the Midwest as well as agencies in Canada and U.S. EPA.

Appendix A summarizes the process types and industries for which BTEC personnel have extensive emissions testing experience. Table 1 summarizes many of the reference test methods with which BTEC personnel are intimately familiar.

Air Emissions Training

BTEC has experience in the development and presentation of a comprehensive, 2-day training course on air emissions testing for environmental engineers at automobile assembly, parts manufacturing, and foundry facilities throughout North America. The training course was presented at an automotive corporation’s world environmental headquarters and consisted of six segments: Historical Overview, Pretest Activities, Test Activities, Post-Test Activities, Common Test Methods, and Hands-On Test Method/Equipment. Individual topics included compliance and engineering test objectives, process considerations, safety considerations, test method selection, test port location and accessibility, developing a test protocol, monitoring process and abatement systems during testing, interacting with agency personnel, and reporting.

Ambient Air Monitoring

In addition to providing air pollutant emissions testing services, BTEC can provide ambient air monitoring services on a short or long-term basis. These ambient air monitoring services include monitoring for the following parameters:

• Air Toxics
• Oxides of Nitrogen (NOx)
• Ozone (O3)
• Sulfur Dioxide (SO2)
• Total Hydrocarbons (THC)
• Total Suspended Particulate
• Particulate less than 10 Microns (PM10)

BTEC can provide these services on a short or long-term basis. Also, BTEC can provide ongoing sample recovery and analysis and equipment calibration or can rent necessary equipment and train client personnel to operate the equipment.

Industrial Hygiene Sampling

BTEC can also provide personal exposure and area sampling industrial hygiene services on a short or long-term basis. These personal exposure and area sampling services include but are not limited to monitoring for the following parameters:

• Pre demolition paint or material samples
• Lead
• Respirable / total particulates
• Particulate less than 10 Microns (PM10)
• Chromium
• All OSHA and NIOSH sampling methods

BTEC will be working in conjunction (partnership) and under the professional industrial hygiene supervision of Cindy Ostrowski, CIH of CAO Consulting, LLC. Ms. Ostrowski has seventeen years experience as an industrial hygienist. She performs consultative industrial hygiene services that include general safety, job hazard analysis, air monitoring, noise monitoring, ventilation studies, ergonomic surveys and indoor air quality (mold) investigations.

BTEC can provide ongoing sample recovery and analysis and equipment calibration or can rent necessary equipment and train client personnel to operate the equipment and provide professional oversight.

New Source Review Permitting

BTEC’s air quality professionals have prepared a great number of new source review permit applications, specializing in Michigan and Ohio permitting. These permit applications range in complexity from permits to install/construct for relatively inconsequential emission units to the installation of equipment subject to federal Prevention of Significant of Air Quality or Major Offset Source requirements. In addition, BTEC has the broad-based experience necessary to successfully negotiate permit terms and conditions that result in decreased potential liabilities and significant cost savings to clients.

Title V Permitting

BTEC personnel have successfully completed numerous Title V Renewable Operating Permit applications with the majority completed in Michigan and Ohio. In addition, BTEC personnel have developed Title V permit monitoring, recordkeeping, and reporting protocols; developed Title V permit compliance certification protocols; prepared Title V permit minor and significant modification applications; and assisted clients by applying for elimination of permit requirements for which there is no corresponding applicable requirement. Because of this experience, BTEC is well qualified to assist industrial, commercial and institutional clients with Title V permitting requirements.

Air Dispersion Modeling

BTEC personnel have the experience and expertise necessary to perform the majority of regulatory-driven air dispersion modeling analyses required. These air dispersion modeling services include application of the United States Environmental Protection Agency’s (U.S. EPA) SCREEN3, Industrial Source Complex (ISC), or AERMOD atmospheric dispersion modeling programs. The dispersion modeling can be performed to predict toxic air contaminant or criteria pollutant ambient air impacts for comparison to ambient air quality standards (including NAAQS and PSD increment consumption analysis). For air dispersion modeling analyses that exceed the scope of BTEC’s expertise, BTEC has agreements with atmospheric dispersion modeling specialists that have extensive experience in dispersion modeling.

Regulatory Compliance Assessments

BTEC’s combination of over 25 years of air quality permitting, consulting, and testing experience makes the firm well qualified to perform comprehensive air quality compliance assessments. These compliance assessments include:

• Identification of each emission unit
• Evaluation of permit to install/construct applicability including evaluation of process modifications
• Evaluation, if necessary, of potential emission rates
• Evaluation, if necessary, or past PSD or major offset source modifications
• Evaluation of compliance with federal or state emission standard requirements (e.g., NSPS, NESHAP)
• Evaluation of Chemical Accident Prevention Provisions (40 CFR 68) applicability
• Evaluation of compliance with permit requirements (including monitoring, recordkeeping, and reporting)
• Evaluation of compliance with other air quality-related requirements (e.g., ODS requirements pursuant to 40 CFR 82, federal conformity rules, etc.)

BTEC can summarize the compliance assessment in the form is a comprehensive and easily followed summary report that includes identified areas of non-compliance as well as recommendations for corrective actions.

Miscellaneous Compliance Assistance

BTEC’s personnel have extensive experience in providing air quality compliance assistance in a variety of areas including:
• Violation and escalated enforcement support
• Preparation of compliance assurance monitoring plans (40 CFR 64)
• Odor evaluations, corrective actions, and analysis
• Construction strategy development
• Control equipment feasibility analyses and selection

A summary of some relevant miscellaneous compliance assistance project experience is provided in the project experience section.

Air Pollutant Emissions Reporting

BTEC has the technical ability and regulatory knowledge necessary to prepare emissions reporting documents and electronic files in a high-quality and cost-effective manner. Paramount to creating a cost-effective emissions report is the development of spreadsheets or a database that can be used repeatedly to monitor and report emissions on an ongoing basis. Also critical to creating high-quality emissions reports is the regulatory knowledge necessary to evaluate compliance with emission or other requirements when completing the report. BTEC has significant experience in creating annual emissions reports using the Michigan Department of Environmental Quality’s Michigan Air Emission Reporting System (MAERS) and the Ohio Environmental Protection Agency’s STARShip software.

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