
A printing company sought assistance in obtaining an air use permit for new equipment. All existing equipment at the site had been previously permitted. Upon investigation, it was determined that the client was not in compliance with air rules and was possibly exceeding the hourly limits in three of its five air use permits. A Freedom of Information Act (FOIA) request was sent to the MDEQ and it was discovered that, in the initial issuance of the air use permits, the rules had been improperly interpreted and the hourly limits had been improperly calculated.
Varnum provided guidance during installation of pollution control equipment under a newly adopted permit exemption; this allowed printing operations to go forward and minimized the risk of a letter of violation being issued by the MDEQ. When the facility was in compliance it was able to approach the MDEQ to obtain a new facility-wide air use permit incorporating a proper interpretation of the existing rules and flexibility in the hourly use limits.