Betts, Hull & Klodowski
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Pittsburgh, PA 15238
Telephone 412-967-0464
Fax 412-967-0465

6400 Brooktree Court
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Wexford, PA 15090
Telephone 724-940-4000
                724-933-8400
Fax 724-940-4048
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Air Pollution

1997 - 1999 EAF Steel Mill, Pennsylvania. Appealed a construction permit for furnace modification that imposed illegally low limits on steel production. Resolved EPA NOVS for particulate emissions and allegations of failure to obtain a construction permit for plant modifications, and the permit appeal, by settlement with state agency.
1999 Chemical Manufacturer, Pennsylvania. Analyzed agency claims of NSPS violations for industrial boilers and developed compliance strategy with multiple options. Provided legal analyses of EPA position to client, who provided it to the state agency. EPA withdrew applicability determination letter which was adverse to the client.
1995 - present Prepared Requests for Determination of exemption from construction permit applications; minor source construction permit applications; and assisted in major source PSD/NSR construction permit applications.
1995 - present Revised Title V operating permit applications to include accurate emissions inventories and correct listings of applicable requirements; define insignificant activities; permits list rules that do not apply to facility.
1997 University, Allegheny County. Assisted in permitting of gas turbine cogeneration unit.
1995 - 1997 Glass Company, Jeannette, Pennsylvania - Retained by bankruptcy trustee as special counsel for air matters. Appealed DEP decision to add RACT control requirement of low NOX burners to the Environmental Hearing Board. DEP agreed to delete the control requirement, which increased Company's NOX ERC credits by 30%. Obtained federal approval of RACT, ERCs and SIP revision to amend Emissions Inventory. Negotiated sale of ERCs to SONY for more than $1,000,000.
1994 - Present Multinational Manufacturer, New Castle, Pennsylvania - Filed suit to challenge DEP interpretation of 1994 New Source Review rules. Withdrew the appeal when DEP published a new statewide policy allowing minor sources to register ERCs. Sold Emission Reduction Credits.
1994 - 1999 U.S. Steel Group, Pittsburgh, Pennsylvania - Special Counsel on Mon Valley Works ERC matters before DEP and Allegheny County Health Department. Sold Emission Reduction Credits.
1996 EAF Steel Mill, Central Pennsylvania - Obtained Plan Approval to reactivate steel mill in less than 90 days; assist in resolution of air compliance issues.
1993 Inorganic Chemical Facility, West Virginia - Air compliance counseling and permitting, largely for fine particulate emissions.
1990 - 1994 Chemical Manufacturing Plant, Ohio - Defended federal enforcement lawsuit for Vinyl Chloride NESHAPS violations.
Other Clients VOC emission matters for paper coating facility and surface coating plant, Allegheny County; particulate emission enforcement matters for paper product manufacturer, Butler County; air toxics permit for new manufacturer, Allegheny County. Resolved enforcement matters for process and power plant emissions at steel mills; numerous asbestos abatement and ERC registration matters.

Representing clients in the Pittsburgh and Western Pennsylvania area, including communities of Fox Chapel, Sewickley, Mt. Lebanon, Wexford, Oakmont, Bridgeville, Monroeville, and Crafton, and throughout Allegheny, Westmoreland, Washington, Beaver, and Butler counties.

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