In this project, we applied to renew the air emission permit for a very large chemical plant which, in addition to the renewal, sought to implement planned changes to its production lines and operating units. Notable characteristics of the facility include its proximity to residential areas and the wide variety of feedstocks, products, and manufacturing processes on site.

As part of the renewal process, we were required to migrate a broad and complex database from the previous permit and align it with the Ministry of Environmental Protection’s updated application package (Version 5). We then updated all variable data necessary for the renewal submission.

Among the variable data were:

• Stack sampling reports for point sources (stacks)

• A review of non-point/fugitive emission sources (e.g., forklift operations, storage tanks)

• Procurement and sales reports

• Additional supporting operational and emissions records

Consistent with our approach in emission permit renewal projects, we met with the client’s designated point of contact, conducted a site tour to familiarize ourselves with the plant, obtained the previous emission permit application materials, and compiled a detailed data request list to initiate project execution.

As part of the application, we assessed gaps between current operations and the regulator’s updated requirements regarding Best Available Techniques (BAT). Based on the identified gaps, we prepared an environmental regulatory plan that sets out the facility’s commitment to upgrade systems and minimize air emissions.

In addition, we prepared and submitted a request for recognition of the facility’s trade secrets to ensure that its proprietary production processes are not publicly disclosed, thereby safeguarding its competitive advantage.