Air-Permitting Support for Medical-Device Packaging Sterilization Company

Medical device packaging sterilization company

Challenge

A new startup company with a proven technology for sterilizing medical packaging established a business in central Texas. The site is located within a region of Texas that received a federal non-attainment designation of “serious” for ozone. The facility process, which emits ozone, was not supported by the state’s permit-by-rule application process. The Texas Commission on Environmental Quality (TCEQ) required new-source review, including dispersion modeling, and a best available control technology (BACT) evaluation and cost assessment as part of the permitting process.  

GES Solution

GES was engaged to provide permitting and engineering support for our client’s entry into Texas. The TCEQ required GES to complete the online permit application process, which entailed providing supporting documentation, such as modeling input and output files, process design drawings, and a detailed project description. 
New source permitting in this region of Texas requires engineering knowledge of the process and what abatement controls are available and whether they are technically feasible and cost effective, GES provided a BACT evaluation that addressed technical merits, cost implications, and costs assessments comparing several abatement options on a $/ton ozone-reduction basis. The cost comparison was presented to TCEQ for review. 
GES provided and/or suggested various methods to secure a construction and operating permit that provided flexible conditional requirements. Our support provided strategic compliance assistance by identifying what would be required to keep the TCEQ’s evaluation of the project as a minor new source rather than a significant non-attainment new source. This saved evaluation time and lessened the stringency of the permit conditions that would have likely been imposed. 

Client Benefits

GES explained all permitting nuances to the client before submitting the permit application with its various supporting documents. GES worked closely with our client and the regulatory agency to keep the facility’s new-source review within the TCEQ’s designation of “minor”.