In completing the air quality specialist report, WREG addressed designated indicators, including emissions related to vehicles, heavy equipment, and diesel generators; emissions related to temporary venting or flaring of natural gas; greenhouse gases and climate change; noise and odor; near-field air quality from fugitive dust during construction activities; near-field air quality related to operation and maintenance of well facilities; effects on air-quality-related values (AQRVs) including visibility impairment (regional haze) and acid deposition at Class I and sensitive Class II areas; compliance with Colorado and National Ambient Air Quality Standards (NAAQS); and compliance with Wilderness Act requirements to maintain or enhance conditions in designated wilderness areas. The impact analysis addressed how the next 20 years of oil and gas activity could affect each of the designated indicators.

• An operating permit renewal application for the Rifle Generating Station, a combustion turbine station. WREG also assisted Tri-State in verifying that emission units located at the same site but under the control of another company should not be considered part of the source covered by the operating permit and the emission units should be removed from the operating permit.
• Prepared an operating permit renewal application for the Nucla Generating Station, a coal-fired, atmospheric circulating fluidized-bed combustor producing 100 megawatts of electricity on Colorado’s Western Slope. WREG updated applicable requirements, reviewed operating parameters used to prepare the initial application, prepared Compliance Assurance Monitoring (CAM) plans, and prepared the permit application package.
• Prepared a construction/ operating permit application for modification of a combustion turbine facility to allow for additional annual operating hours.

Since 2007, one of WREG’s Principals has provided ongoing support to Tri-State for multiple projects in a staff augmentation role. Tasks have included emission estimation, regulatory analysis, dispersion modeling, and compliance assistance.

WREG also prepared air quality analyses and document sections for Rocky Mountain Power’s proposed Sigurd to Red Butte No. 2 345kV Transmission Project EIS and for the initial geotechnical investigation. In addition to the emission source types evaluated for the Mona-Oquirrh project, WREG determined emissions from helicopters proposed for use in both the geotechnical work and during transmission line construction. A total of 12 alternate routes were evaluated, as well as expansion of two existing substations and construction/operation of a concrete batch plant.

WREG also supported the applicant in hearings for a Certificate of Environmental Compatibility (CEC) from the State Siting Committee of the Arizona Corporation Commission. As part of the hearing process, WREG conducted cooling tower visible plume modeling using the SACTI model. WREG also prepared Acid Rain Provision documentation.

The power modules had a potential to increase emissions from the Rawhide Energy Station by significant amounts, were temporary, and met the definition of non-road engines. These facts made determining the proper permit required by the Colorado regulations difficult. WREG assisted Platte River in obtaining a determination from the Colorado Air Pollution Control Division (APCD) that Prevention of Significant Deterioration (PSD) permits were not necessary. Platte River agreed to conduct analyses not normally necessary for minor source permits. WREG prepared the permit applications, including conducting dispersion modeling and preparing Best Available Control Technology (BACT) analyses for nitrogen oxides (NOx) at the agency’s request. WREG also assisted with permit condition negotiation and submission of compliance plans.