Complex Air Permitting

Biodiesel Manufacturing
North Haverhill, New Hampshire

Client Challenge

Renewable Fuels by Peterson (formerly White Mountain Biodiesel) planned to expand operations at their New Hampshire biodiesel manufacturing plant, which would increase potential emissions and require a Title V major source air permit before construction could begin.  Aries was brought on board to assist due to our regulatory expertise and experience negotiating with regulatory agencies.

Comprehensive Solution

Aries conducted applicability assessments of multiple New Source Performance Standards (NSPS) and National Emission Standards for Hazardous Air Pollutants (NESHAP) rules relevant to the biodiesel manufacturing process and associated equipment. To meet the needs of our client, Aries prepared one of the most complex air permit applications reviewed by the New Hampshire Department of Environmental Services (NHDES), which included:

• Process descriptions

• List of applicable process devices

• Federal and state rule applicability determination

• Process emission estimates

• Air dispersion modeling results

Aries successfully negotiated the conditions of the final air permit with the NHDES, which led to the issuance of the final Title V air permit. Following issuance of the final permit, Aries developed New Hampshire’s first Leak Detection and Repair (LDAR) program as required by federal rules.

Beneficial Outcome

Our client and their legal team faced a critical situation involving potentially significant increased scrutiny from both federal and state regulatory agencies. Our client was able to rely on our air permitting expertise, our ability to navigate complex requirements related to the biodiesel industry, our ability to correctly interpret applicable regulations, and our working relationship with regulators to negotiate permit conditions. Aries submitted a complete permit application and secured approvals in a timely manner, which allowed the facility expansion to commence.

Our compliance team successfully balanced discussions between the EPA, NHDES, and the client's legal team. We transformed a regulatory challenge into sustainable compliance solutions, while protecting our client’s business interests and ensuring long-term operational sustainability.

Note: The EPA withdrew their “Once In Always In” Policy related to Title V. Aries was able to assist the company in downgrading from a Title V permit to a State Permit to Operate, greatly reducing the company’s regulatory burden.