Permitting and Compliance Consulting

Procter & Gamble Paper Products Company (P&G) owns and operates a diaper and paper products facility in Jackson, Missouri. It submitted its original Intermediate Air Permit application in 1996. At that time, the facility had approximately 30 to 40 sources. Since that submission, the facility has had two major additions (adding 15 to 20 new sources) to its operation. As a result, the facility is now considered to be a Title V major source.

Because of these additions, the facility also needed to add its own wastewater treatment operations. Permitted discharge limits granted at the time by the State of Missouri were very restrictive.

Air Quality Services

• An air compliance assessment
• A source survey of existing emission sources identified in the 1999 Emission Inventory Questionnaire (EIQ)
• Completion of construction permit applications for sources not previously identified
• Identification and review of present and projected alternative operating scenarios
• Identification and review of sources subject to the Compliance Assurance Monitoring (CAM) Requirements as required under 40CFR Part 64
• Preparation of the air operating permit application forms and supporting documentation
• Support in regulatory negotiations with the Missouri Department of Natural Resources (MDNR).

Water Quality Services

Due to the permitted limitations, P&G sought ways to modify the performance of a wastewater treatment system designed for less-restrictive discharge limitations.

GEI’s services included:

• Evaluation of the existing wastewater treatment system
• Review of sampling data
• Recommendations for modifications and process revisions to the existing system
• Regulatory compliance support with MDNR