Zephyr prepared a state minor NSR air permit application for an industrial wastewater treatment plant in an ozone non-attainment area. The permit application involved very complex emission calculations for over 200 compounds and 20 operating scenarios using an alternate calculation model for emissions from water (not EPA’s Water 9). The emission calculations for individual compounds were relied upon as the basis for demonstrating compliance with state health effects levels for the proposed 200 compounds and to develop a permit provision which provided for future authorization to emit other compounds without additional agency review. Nonattainment NSR applicability analysis was performed by calculating the net emission increase over two year actual emissions. A customized data management tool was developed to provide the records and compliance demonstrations required by the issued permit.