Air Permitting and Compliance

GEI provided air permitting and compliance consulting services for two bulk transfer operations to Slay Industries of St. Louis, Missouri.

The Slay facility in Sauget, Illinois operates as Cahokia Marine Service and transfers a variety of materials from barges to rail or truck for further distribution. These materials include benzene, lead, coal, grain and various chemicals. The Slay facility in St. Louis operates as Slay Bulk Terminals and transfers mainly liquid chemicals or gasoline from barges, trucks or rail for further distribution.

At the Cahokia Marine facility the benzene transfer operation is subject to the National Emissions Standards for Hazardous Air Pollutants (NESHAP). Specifically, the facility is required to comply with Subpart V-National Emission Standards for Equipment Leaks.
GEI was responsible for conducting quarterly fugitive emissions monitoring and preparing the semi-annual and annual reports for the benzene transfer operation. We maintained a component identification system and notified maintenance personnel of needed repairs. We also conducted ambient air monitoring and worker exposure monitoring as part of the benzene transfer program.

GEI prepared a benzene worker monitoring plan that was implemented at the facility to comply with Occupational Health and Safety Administration guidelines. We also conducted worker exposure monitoring for airborne lead during the transfer of lead from barges to trucks.

In addition, GEI prepared an air quality permit application to amend the facility’s existing Lifetime Operating Permit to include a transloading operation that involved the transfer of bulk liquid products from a U.S. Department of Transportation (DOT) specification container to another USDOT specification container using bottom loading techniques with existing pumping equipment at the facility.

GEI also negotiated with the Illinois Environmental Protection Agency (IEPA) language in the permit to allow the facility to transload from rail tank cars to tank trailers, rail tank cars to barges and to storage tanks and from tank trailers to rail cars, barges, and storage tanks. In addition, the permit language allowed the facility to transload other products, including ethanol, from these various modes of transportation.

At the Slay Bulk Transfer facility in St. Louis, GEI was responsible for the preparation of an air quality permit application for a new “natural” gasoline transfer operation. The application included the determination of gasoline throughput in order to maintain minor source status as well as evaluation of proposed emission controls for the transfer operation. GEI prepared the permit application and negotiated the conditions of the permit with the city to ensure maximum flexibility for the facility.