Problem
Our client’s Title V and NSR air permits contained a general permit condition that did not align with the original intent of the text and created stack testing requirements that were difficult to meet. In fact, to meet the capacity required during stack testing, additional equipment had to be permitted to supplement the throughput.
Solution
Array worked with the state permit engineer who explained the original purpose of the text and clarified the situation under which the general condition should be applied. Within one month, the general permit condition text was updated by the state agency for all applicants, and relief from the long-standing stack testing burden was lifted.
