NSPS/NESHAP Compliance – Custom HVAC Manufacturing Facility, DeSoto, Kansas

SCS Engineers provides air compliance services for custom heating, ventilation and air conditioning related equipment manufacturer located in Desoto, Kansas. Engineering services included the following:

  • Negotiation of a favorable consent agreement with the Kansas Department of Health and Environment (KDHE) to address applicability and compliance with the National Emission Standards for Hazardous Air Pollutants (NESHAPs) for Surface Coating of Miscellaneous Metal Parts and Products (MACT Subpart MMMM) and the Kansas Reasonably Available Control Technology (RACT) regulation 28-19-73, Surface Coating of Miscellaneous Metal Parts and Products and Metal Furniture
  • Preparation of Initial Notification and Notification of Compliance Status for MACT Subpart MMMM
  • Preparation of the Title V Operating Permit application for the facility, which incorporates all applicable federal, state and local air regulations and compliance demonstrations
  • Development of an electronic record keeping database to track paint, sealant, liquid plastic coating, caulk, ink, adhesive, and maskant usage. The database calculates HAP and VOC emissions according to the requirements of MACT Subpart MMMM and the Kansas RACT regulation
  • Completion of quarterly MACT Subpart MMMM and Kansas RACT compliance reports required by the consent agreement and semi-annual compliance reports required by the Title V permit
  • Completion of the facility’s Annual Emission Inventories
  • Completion of indoor air testing to demonstrate compliance with Occupational Health and Safety Administration regulations applicable to the welding and brazing operations at the facility
  • Completed an air construction permit applicability determination for the installation of powder coat operations at the facility. Prepared and submitted subsequent no permit required documentation to the KDHE
  • Obtainment of a No Discharge Certification for the facility’s industrial wastewater activities (the facility is subject to the wastewater regulations found at 40 CFR Part 433, Metal Finishing, due to phosphating and chromating operations on-site)
  • Provided assistance with identification of waste streams subject to regulation on the Resource Conservation and Recovery Act (RCRA)