Aspen Law and Business MACT
Book
Wind
River assisted Aspen Law and Business, which publishes the Air
Pollution Consultant journal, in writing Guide to MACT
Recordkeeping and Reporting. The book summarizes all the
recordkeeping and reporting requirements for each promulgated
Maximum Achievable Control Technology (MACT) standard, including
General Provision requirements and those included by reference to
other MACT, National Emission Standards for Hazardous Air Pollutants
(NESHAP), or New Source Performance Standards (NSPS). The book provides a valuable
tool to identify and comply with the complex recordkeeping and
reporting requirements of the voluminous MACT
standards.
Colorado Refining
Company
Wind
River personnel have been providing air compliance, permitting, and
training support to Colorado Refining Company (CRC) since 1995. One of Wind River’s
principals has provided continuous support to the refinery over the
past four years. Wind
River has conducted audits, researched regulatory issues, and
developed environmental management procedures. Wind River has also provided
training to the refinery environmental, operations, and maintenance
staff.
Kaiser-Hill Company RFETS
Support
Wind
River personnel have been providing Kaiser-Hill Company and the U.S.
Department of Energy (DOE) air compliance, monitoring, and research
support for the Rocky Flats Environmental Technology Site (RFETS)
since 1996. One of Wind
River’s principals managed the air quality management organization
at RFETS from 1996 to 2000 and continues to provide support to this
group. Wind River team
members have worked with RFETS personnel to research the movement of
radionuclide contamination through the air pathway during a
multi-year actinide migration study. Wind River personnel have
co-authored several papers based on this research and continue to
report findings and conclusions to the public and regulators at
periodic workshops and public meetings.
Toltec Power
Station Permit Application and Support
Toltec
Power Station, LLC is planning to construct a 2,000 megawatt natural
gas-fired combustion turbine project 10 miles south of Eloy,
Arizona. Wind River was
retained to prepare the Major Source Permit application for
submission to Pinal County.
The Major Source Permit is a combined construction and
operating permit. Wind
River identified all applicable requirements, prepared Best
Available Control Technology (BACT) analyses, and analyzed air
quality impacts. The
air quality impact assessment included estimation of Class I and
Class II visibility impacts using PLUVUE and CALPUFF, full National
Ambient Air Quality Standards (NAAQS) and Class II increment
analyses, and Class I increment consumption modeling. Wind River also supported
the applicant in hearings for a Certificate of Environmental
Compatibility (CEC) from the State Siting Committee of the Arizona
Corporation Commission (ACC).
As part of the hearing process, Wind River conducted cooling
tower visible plume modeling using the SACTI model. Wind River also prepared
Acid Rain Provision documentation for
submission.
Bowie Power Station Permit
Application and Support
Bowie
Power Station, LLC retained Wind River to prepare the Class I air
permit application for a 1,000 megawatt natural gas-fired combustion
turbine project to be located in southeast Arizona. The Arizona Department of
Environmental Quality is the permitting agency for this project and
a Class I permit is a combined construction and operating
permit. The permit
application included a description of applicable requirements and
compliance methods, BACT analyses, and a detailed air quality impact
analysis. CALPUFF and
PLUVUE were used to estimate visibility impacts in nearby Class II
areas, as well as visibility effects in four Class I areas. Acid Rain Provision
documentation was also prepared.
Rocky Mountain Metal Container
– Cans
Rocky
Mountain Metal Container – Cans is upgrading its facility located in
Golden, Colorado. The
project involves the replacement and upgrade of equipment, and
changes in the inks, coatings, and cleaners used. The project constitutes a
major prevention of significant deterioration (PSD)
modification. Wind
River prepared the permit application for submission to the Colorado
Department of Public Health and Environment, Air Pollution Control
Division. Application
preparation included BACT review for volatile organic compounds and
air quality dispersion modeling for oxides of nitrogen. The agency also required a
detailed vegetation impact analysis for ozone. This analysis was conducted
using the Texas Natural Resources Conservation Commission
methodology for estimating ozone impacts from individual
sources. Wind River
also assisted Rocky Mountain Metal Container in negotiating permit
conditions.
Panda Gila
River Project PSD and Operating Permit
Application
Wind River
prepared the PSD and Operating Permit application for the Panda Gila
River Project in Maricopa County, Arizona. The project was developed by
Panda Gila River, L.P.
The project is a combined-cycle combustion turbine facility
capable of generating 2,080 megawatts of electrical power. Wind River prepared an
initial permit application including emission estimates, applicable
requirements identification, BACT analyses, and an air quality
impact analysis. The
project configuration was changed and Wind River prepared a second
permit application.
During the permit review and negotiation process, Wind River
conducted analyses on fugitive particulate matter emission
reductions associated with the project, and prepared an ambient
particulate matter monitoring plan/Quality Assurance Project Plan
(QAPP). Wind River also
prepared documentation required under the Acid Rain Provisions of
the Clean Air Act for submission.
Long-Range Resource Plan
Wind River’s principals
prepared a long-range resource plan for a large Arizona electric
utility client. The
project included identifying permitting requirements, costs, and
lead time associated with various future additional generating
options. The project
evaluated 15 generating changes to five separate facilities. The proposed changes ranged
from adding combustion turbines to existing facilities to upgrading
existing coal-fired boilers.
IBM
Emergency Generator Permit Support
International
Business Machines (IBM) retained Wind River to assist with resolving
permitting issues associated with emergency generators located at
the IBM computer service center in Boulder, Colorado. The Colorado Department of
Public Health and Environment, Air Pollution Control Division
asserted that PSD requirements had been triggered. Wind River conducted a
historic review of generator installation, operations, and
emissions. In addition,
Wind River researched past and current federal and state policies on
calculating potential to emit for emergency equipment. The analyses demonstrated
that the PSD requirements did not apply to the generators.
Boulder Facility Operating
Permit Modification
Wind
River prepared a minor operating permit application to add a process
to the Roche Colorado Corporation (RCC) Boulder facility located in
Boulder, Colorado. The
application was prepared in accordance with Colorado regulations and
the provisions of the existing operating permit. The application included
performing a site-wide emission netting analysis to demonstrate that
the project was minor, identification of applicable requirements and
compliance methods, and the development of draft permit
conditions.
Rawhide Simple Cycle 2001
Project PSD Permit Application
Platte River Power Authority (Platte River), a
political subdivision of the State of Colorado owned by the cities
of Estes Park, Fort Collins, Longmont, and Loveland, retained Wind
River to prepare the PSD permit application for two simple-cycle,
natural gas-fired combustion turbines. The units, referred to as
Units B and C, are located at the Rawhide Energy Station in northern
Larimer County, Colorado.
Application preparation included conducting a regulatory
review, developing BACT analyses, and performing necessary
dispersion modeling, including modeling of visibility impacts. Acid rain documentation was
also prepared for submission.
Following application submission, Wind River reviewed draft
permit conditions and assisted Platte River with negotiating
changes.
Rawhide
Temporary Power Modules Minor Source Permit
Applications
In the summer of 2001, Platte River placed 31
leased, trailer-mounted, diesel-fired power modules at the Rawhide
Energy Station in northern Larimer County, Colorado. Because planning for leasing
of the power modules occurred at the same time that permitting was
being pursued, two permit applications were prepared, one for 20
power modules and one for 11 power modules. Wind River prepared the
permit applications for these power modules and assisted with permit
negotiations. One of
the permit applications was prepared in conjunction with another
local consulting company.
Rio Grande Portland Cement
Plant Permitting Process Review
Wind
River was retained by the Pueblo Economic Development Corporation
(PEDCo) to conduct an independent review of the Rio Grande Portland
Cement Corporation’s (Rio Grande) Colorado PSD permit application
and the draft permit that was proposed to be issued by the Colorado
Department of Public Health and Environment, Air Pollution Control
Division. The PSD
permit application was submitted to construct a new Portland cement
plant in Pueblo County.
The review was conducted to provide insight to PEDCo on the
PSD permitting process associated with the proposed new facility and
an assessment of how the issues raised during the public review
process had been addressed.
Front Range Power
Project
The Front Range Power Project added 480 megawatts
of generating capacity to the Ray M. Nixon Power Station in
Fountain, Colorado through the construction of two natural gas-fired
combustion turbines.
Under subcontract to URS-Radian, Wind River estimated emissions, wrote the
project description, conducted the BACT analyses, identified
applicable regulations, researched regulatory issues, and provided
permit negotiation support.
Arizona Power Plant Siting
Study
Wind
River assisted the Environmental Planning Group in conducting
environmental feasibility studies for a new 1,000 megawatt power
plant in Arizona. Nine
candidate sites were systematically evaluated based on conceptual
project plans. Wind
River identified and ranked air quality issues associated with each
site.
Operating
Permit Reviews
Wind
River reviewed draft Operating Permits for the Coors Brewing Company
Brewery, Glass Plant, and Can Plant in Colorado, as well as a
Packaging Facility in Virginia. Wind River advised Coors on
regulatory applicability, permit condition wording, and negotiating
strategies. Wind
River’s principals had previously worked with a Coors Brewing
Company team to prepare the Title V applications for the Colorado
facilities.
Moapa-Paiute
Generating Station Environmental Impact Statement
Review
The
Bureau of Indian Affairs (BIA), in cooperation with the Bureau of
Land Management, prepared an Environmental Impact Statement (EIS)
for a 760 megawatt generating station to be located on the Moapa
Indian Reservation in Clark County, Nevada. Environmental Planning Group
and Wind River were retained to assist the BIA in the review of the
EIS and the environmental documentation associated with preparation
of the EIS. Wind River
conducted a comprehensive air quality technical review of the EIS
and associated documentation.
Bighorn
Generation Facility Environmental Assessment
Review
Reliant
Energy Bighorn LLC proposes to construct a natural gas-fired
generating station to operate as a peaking facility during periods
of high energy demand, along with a combined-cycle facility to
provide a year-round source of energy. The proposed facility will
be located near Primm, Nevada, in southern Clark County. Wind River and the
Environmental Planning Group were retained to assist Reliant in the
review of an Environmental Assessment (EA) for the facility. Wind River prepared a
comprehensive review of the air quality analyses and documentation
for the facility.
IBM Boiler Permit
Application
Wind
River prepared an application to consolidate the permits for boilers
located at the IBM computer service center in Boulder,
Colorado. The facility
includes four boilers for which two separate construction permits
had been issued. The
application was prepared to request consolidation of the
permits. Prior to
preparing the application, Wind River analyzed emissions to ensure
that no additional requirements, including permitting requirements,
would be triggered by consolidating the permits. Following application
submission, Wind River assisted in negotiating permit conditions
with the Colorado Department of Public Health and Environment, Air
Pollution Control Division.
MACT
Effectiveness Study
Wind
River assisted the Colorado Department of Public Health and
Environment, Air Pollution Control Division, in determining the
effectiveness of MACT standards in the state. Wind River determined which
facilities in Colorado were subject to promulgated MACT standards,
then reviewed and tabulated possible emissions reductions resulting
from MACT compliance.
The agency hopes to combine this information with the cost to
the state in providing MACT assistance and determine the
cost-effectiveness of the emission reductions achieved.
Bio-Gas Flare Self
Certification
Coors Brewing Company installed a flare to
combust biogas from wastewater treatment. Wind River reviewed
compliance with each construction permit condition in the air
quality construction permit issued for the flare and prepared the
required self-certification package for submission to the Colorado
Department of Public Health and Environment, Air Pollution Control
Division.
Confidential
Client Operating Permit Compliance Audit and Compliance Tool
Development
Wind River
was retained to develop compliance certification tools and conduct a
facility assessment against the conditions in an Operating Permit
that was undergoing public review. Since the Operating Permit
was not yet in force, the review focused on identifying those
conditions for which compliance methods required institution or
improvement. The
facility for which the assessment was conducted is subject to MACT
standards, NESHAP, and several NSPS.
Confidential Client Refinery
Audits
Wind River was retained to conduct compliance
audits at two regional refineries. The audits covered 40 CFR
60, NSPS, and 40 CFR 61 and 63, NESHAP. The scope included Leak
Detection and Repair, Benzene Waste Operations, and Hazardous
Organic NESHAP control technology requirements. In addition, compliance with
mandatory Comprehensive Environmental Response, Compensation, and
Liability Act, Section 103, and Emergency Planning and Community
Right-to-Know Act, Section 304 release reporting requirements is
also being reviewed.
MACT
Hammer Support
Wind
River assisted the Colorado Department of Public Health and
Environment, Air Pollution Control Division with facility
notifications prompted by the U.S. Environmental Protection Agency’s
(EPA’s) “MACT HAMMER” rule.
The rule requires state agencies to determine and apply MACT
standards to major sources in source categories where EPA has missed
the rule promulgation deadline by 18 months. Major sources potentially
subject to these not-yet-promulgated MACT rules were required to
submit a Part I operating permit application (essentially a
notification) by May 15, 2002.
While there is no penalty for sources that apply but are
later found not to be subject to a rule, there is a potential
penalty associated with not submitting a timely application. Wind River worked with the
agency to develop a letter and reply form to notify affected sources
of this requirement.
Wind River then tracked responses, followed up with
non-responders, and provided assistance to individual companies in
determining their applicability through a voice mail box
system.
Confidential
Client Refinery Modeling Analysis and Compliance
Support
Wind River reviewed and updated modeling analyses
for a regional petroleum refinery as part of an effort to finalize
construction permits for refinery modifications. Since the initial modeling
was performed, the refinery discovered a number of inconsistencies
with actual operation and also needed to revise certain permit
limits. Wind River
obtained the earlier modeling files, reviewed them against current
refinery information, and, where necessary, calculated revised
emissions. Refinery
emissions were modeled and compared to state and federal limits,
then documented in a report to be submitted with revised permit
applications.
Additional work for this refinery has included a review of
stack test data and comparison with EPA standard methods for
measuring particulate matter and fine particulate matter
(PM10).
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