I have a question regarding permitting and more specifically emissions. A locality is giving one of my friends a hard time about how much solvent (heptane) will be emitted during the operation. This is a closed loop system that won’t be allowing for much emission at all. They want something from another lab or the equipment manufacturer that states that our low emission projections are correct. I checked and the manufacturer has no data.
Has anyone been in a situation like this or have any tips about how to get through this?
So what my company ended up having to do was go through EGLE (Basically DNR and the DOE put together) and we had to do the math ourselves then get a consultant who worked with EGLE to review it before we submitted to the state
You can also just do air sampling for VOC. If they are concerned about vapor emissions, take samples of the air in the extraction room, where it would most likely be the most concentrated before leaving the building. Analyze the air sample through GC analysis and determine your emissions concentration.
You can do the engineering math as well if that’s what they want, but I think it would be hard to argue with lab testing results of air quality.
Edit To be clear, have the air samples taken by the analytical testing lab performing the analysis. Ideally you are able to find a lab that is recognized by your state for performing these types of tests where the state will accept the results. Many states have a published list of laboratories that they have recognized the various accreditations said lab has attained, and will accept results reported by them for regulatory purposes.
Thanks for the replies. The facility is not operational yet as they need to get this permit to get the go ahead to finish construction and set the machinery. I will see if anyone else has any thoughts and then try to formulate a plan.
Had a follow up today with the city.
We presented diagrams showing the crystallization setup that we are trying to get permitted and how it is a closed loop. The manufacturer has no emissions data themselves as they claim it is a closed loop system with hard piping.
The city will not approve the permit until they get hard data to back up any projections we made on the emissions. I don’t know how we will get the emissions data off this manufacturers crystallization reactor and falling film without actually running the unit and doing a mass balance calculation of how much heptane went in, and how much came out.
Checking to see if anyone has found another way to provide the city with what they need to approve a hemp extraction/crystallizatoin operation. It seems that since they have not worked with any hemp processors in the past they are being overly cautious on this permit.