Cement Industry
Our services cover all aspects of
We are known for our expertise in all aspects of environmental management programs for the cement industry. Through our environmental auditing program, we can evaluate a plant's current status with respect to the spectrum of environmental regulations or management systems. We also routinely track new regulations to maintain corporate programs. On the plant level, we develop compliance plans, permit applications and coordinate with the regulatory agencies. We also provide expert witness services on environmental topics.
Our comprehensive environmental services include permitting and compliance for the spectrum of environmental regulations, preparation of stormwater pollution prevention plans and SPCC plans, recommendations on waste recycling issues, SARA Title III compilation and reporting, and NPDES permitting and sampling at the individual facilities. As part of our environmental services, our staff assists with the interpretation of regulatory applicability, compliance sampling, evaluation of sample results, and report completion. In addition, we perform environmental site assessments for property transactions.
Clean Air Act (CAA)
SYA provides industry with a wide range of high-quality services specific to the CAA. These services include air compliance audits and permitting for PSD, NSR, NSPS, MACT and Title V, and pollutant control strategies to address HAPs, GHGs, and other pollutants. Either as part of a larger project or as independent tasks, we also perform emissions inventories, process hazard review, air contaminant dispersion modeling, air toxic evaluations, stack/source testing oversight, CEM certification, ambient air monitoring and visual emissions assessments.
SYA provides engineering, modeling, permitting, and testing with in-house personnel and resources. We have developed Title V operating permit applications and construction and operating permit applications for multiple cement manufacturing facilities located throughout the United States, including many of the upgraded and new facilities built in recent years. In addition, we develop strategies and prepare CAA permit applications for the use of tires and other alternate fuels and raw materials.
Cement Kiln Dust (CKD) Management
Although final regulations are not issued, facilities are currently contemplating CKD management methods to address specific state requirements and to plan for future management applications. Our engineers and geologists are assisting facilities in developing CKD management plans, communicating with regulators, performing CKD sampling and analysis, performing hydrogeological studies, landfill design, construction oversight and management, preparing permitting applications and negotiating permit conditions for landfill and stormwater permits.
Our background in CKD management is extensive. We were contracted in 1992 by the PCA to define contingent management practices for CKD and to demonstrate this management method as practical and effective. We were also hired by the association in 1993 to craft the technical portions of the cement industry's response to the U.S. EPA's Report to Congress on CKD. Additionally, we compiled the technical response for the industry to the California EPA on a study performed by the University of California on cementitious wastes. Also we have worked with many facilities on their individual CKD activities.
Testing and Data Coordination
We have been involved in stack sampling and fugitive emissions sampling at cement plants since 1986. Our firm has designed test plans, conducted emissions tests, and managed and provided on-site coordination for tests ranging from an individual parameter to complex combustion trial burns. We perform detailed analysis of the results and prepare emissions testing reports. Since 1993, we have worked with agency and industry representatives to develop appropriate facility-specific test protocols that incorporate the overall combustion objectives of RCRA and MACT, while minimizing the complexity of the testing program. Our emissions testing experience, combined with our operations and permitting expertise, provides clients with necessary services for continued compliance with the regulations.
Dioxins Formation Research and Control
SYA has a long term background in addressing dioxin/furan formation and control. Our extensive background in dioxin research and cement kiln technology makes us particularly qualified to develop dioxin strategies specific to a particular plant. Our experience has included working with plants, regulatory agencies, and the public in developing and implementing dioxin testing and control programs for emissions and other media. Since 1979, we have studied the formation and behavior of dioxins and furans and have presented data to EPA headquarters, the regions and state agencies. In 1994, we were retained by the CKRC to analyze and prepare a report on dioxin testing results from several cement plants. Since that time, we have continued to study results from the most recent testing and to develop strategies to address dioxin issues.
Hazardous Waste Combustion Permitting and Compliance
We are known nationwide for our capability to assist in compliance with the complex requirements of the BIF and HWC MACT rules. We have worked through the comprehensive RCRA permitting process for many facilities. In addition, we audit RCRA programs and manage trial burns and risk assessment projects. In addressing RCRA closure and corrective action, we have assisted cement plants in developing and implementing closure plans across the nation. Our work has included developing plans, coordinating meetings with the agency representatives, and providing independent professional engineering oversight of the implemented plans. Our engineers continue to keep abreast of the corrective action issues for solid waste management units. We are familiar with the RFA/RFI process and have worked with the industry to develop appropriate measures for assessing contamination and performing remediation.
Another specialty of our firm is managing work groups on BIF/HWC MACT permitting and compliance issues among the cement industry, the EPA, and state agencies. A sample of the issues discussed in the work group includes HWC MACT compliance, RCRA permitting, indirect risk assessment, metals and chlorine tracking, CKD compliance, CEMS, and closure.
Community Relations/Technical Support
We provide services to our industrial clients including technical support for community relations and related activities to support a client 's needs in addressing environmental issues with the public. Having the necessary background in both the sensitivity of public issues and in the technical aspects of cement operations and associated issues, we support our clients in achieving the goal of building trust and a foundation upon which to exchange information within a community.
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