DASNY: Air Permitting and Compliance Services for NYS Office of Mental Health

Comprehensive Air Permitting and Compliance Services

LaBella has provided comprehensive air permitting and compliance services for
23 campuses of the NYS Office of Mental Health since 1995. The program is ongoing, and LaBella has maintained these services under a term agreement since 2008. Services include evaluation of facility emissions for permitting and compliance strategy development, regulatory applicability determinations, permit preparation, and staff training.

Project Tasks Included the Following:

Permit Maintenance

LaBella has prepared Title V, Air State Facility, and Air Facility Registration applications, modifications, and renewals for all 17 of the currently permitted OMH facilities and manages relevant correspondence with the permitting authorities.

Compliance Reporting

LaBella collects data from OMH staff, contractors, and consultants for analysis and submittal of required annual compliance certification reports, semi-annual monitoring reports, semi-annual New Source Performance Standards reports, and annual emission statements, as well as occasional additional informational requests forwarded by the regulating authorities. Reporting has also been implemented for new federal regulatory initiatives, including diesel emissions and area source programs, among others.

Compliance Assistance

LaBella remains available to OMH staff for assistance with environmental compliance issues such as the analysis of the impact of new regulations on OMH facilities or the development of compliance protocols when regulations or permit requirements change. LaBella also provides technical assistance to OMH attorneys for enforcement matters and assists in negotiations at informal hearings.

Permit Compliance Workshops

LaBella provides biannual workshops that have trained scores of OMH plant employees and managers in maintaining compliance with air permit requirements. We also develop and update (as needed) permit compliance handbooks specific to each facility’s permit, and distribute various tools to assist in compliance. Such tools include emissions calculation spreadsheets, forms, inventories, and web-based information sources. Additionally, we provide presentations on the compliance programs for OMH meetings and gatherings.

Opacity Observations

LaBella retains a Certified Visual Emissions Evaluator on staff and provides the required 15 annual opacity observations at 8 OMH facilities where this monitoring is required.

Stack Testing

LaBella manages stack testing for particulates and NOx at facilities whose permits require such testing. We prepare testing protocols for review by DEC, procure testing services, and coordinate testing and reporting at subject facilities.

Safety Training

LaBella retains 2 Authorized OSHA Outreach Trainers on staff and has provided several full series of multi-site OSHA 10-hour trainings to work control, safety, and housekeeping staffs. To date, over 500 OMH staff have been trained and received 10-hour course completion cards. In addition, targeted short-term safety training sessions have been provided to Revitalization teams and other OMH staff groups. These include aerial lift and forklift operator training programs. Consulting Fees: $1,105,000 (since 2008)