For nearly two decades, Barr has provided air permitting and compliance assistance to a confidential water filter manufacturing client that owns and operates a coating facility subject to 40 Code of Federal Regulations (CFR) 60 Subpart VVV, Standards of Performance for Polymeric Coating of Supporting Substrates (Subpart VVV).
Over the years, the manufacturing facility has had several coating line additions. For each addition, Barr’s team of permitting experts has helped our client navigate major modifications to the air quality permit. Our emissions testing group has also performed emissions testing to demonstrate post-project Subpart VVV compliance. Barr has prepared permit applications and worked with the client and the Minnesota Pollution Control Agency (MPCA) to develop agreeable permit language.
In 2010, Barr worked with our client to gain Environmental Protection Agency (EPA) approval for an alternative compliance test. The manufacturing facility’s emissions unit uses water baths as part of its process, which also partitions volatile organic compounds (VOCs) and hazardous air pollutants (HAPs) emissions to the water. Removal of VOCs and HAPs via the water stream serves as the air pollution control method for the process. Therefore, Barr collects and analyzes water samples to demonstrate air compliance. The EPA-approved alternative compliance test must be repeated every five years. The last test was performed in 2022. Barr assisted in test plan preparation, performed test oversight, and prepared the compliance test report.
(stock photo shown above)