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ARG has garnered enormous experience with these programs, which are perhaps the two most difficult to understand regulatory programs under the Clean Air Act.
Examples include:
- ARG represented a major 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. This 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 that 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 the 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.
- 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 1960's. ARG also reviewed all existing permits for individual emission points 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 for the facility. 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 provided a state Power Pool with comments on the impacts of new source review regulations on repowering existing facilities.
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