Mine Site Air Permitting
Various Locations
Foth’s air permitting experience includes Title V air permitting for large industrial operations including mining and manufacturing in a variety of states.
Challenges
Typically, air permit applications are supported by modeling and analysis for air dispersion and occasionally, air deposition. Although similar to most large project air permits, mining projects have several unusual characteristics. The storage and handling of large quantities of granular materials produces particulate matter (PM) emissions, a large proportion of which are from fugitive (area and volume) sources. New Source Performance Standards apply in rules specific to mining operations. Particular permitting challenges can include the documentation of compliance of air toxics associated with the PM, especially those of the target metals of the mines if they happen to have a low evaluation criterion. Preparing a comprehensive, well-documented emissions inventory, working with the client team to explore which processes and methods of dust suppression are preferable, assisting in the negotiation with the regulatory agency for reasonable permit limits and requirements, and defending the work in highly scrutinized environments are all part of the strategic consulting services Foth provides.
Air deposition modeling and analysis can result in review from multiple-departments at the regulatory agency since air deposition is a multi-media phenomenon. This can be particularly complex in that for the most part, criteria for evaluating deposition effects are not well developed. Similar emerging issues associated with air permit processing include greenhouse gas analysis and carbon footprint analysis. Foth continues to monitor and develop expertise to serve our clients in these areas.
Benefits
Foth strategic consulting services on air permit applications are complemented with the same strategic services provided on other permits associated with a project. On most large projects, there is significant interaction between the project development and the various developing permits. Air permits in particular are sensitive to project changes. Foth is experienced in identifying issues in project, permit, and regulatory developments that can be opportunities and/or challenges to success of the project.
