WREG prepared the Air Pollutant Emission Notice (APEN) and fugitive dust land development permit application for the Golden Prairie Wind Farm located in southeastern Colorado. Based on project data supplied, WREG calculated emissions, determined that a permit was necessary, prepared the APEN and permit forms for signature, and compiled and submitted the required supporting materials to the state. WREG worked with the state permit engineer to ensure that the permit was issued prior to the construction start date, thereby avoiding construction schedule impacts.
WREG prepared a construction permit application for Public Service Company of Colorado for installation of a large natural-gas fired boiler at the State Steam Plant in Denver. Project included calculating emissions, determining applicable requirements, and demonstrating compliance with all permitting requirements including volatile organic compound (VOC) Reasonably Available Control Technology (RACT) requirements.
WREG has provided support to Tri-State Generation and Transmission for a number of facilities in the western United States. Projects have included:
- 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 assisted Toltec Power Station, LLC with permitting for a planned 2,000 megawatt natural gas-fired combustion turbine project near Eloy, Arizona. WREG prepared a combined construction/operating permit application for submission to Pinal County. WREG 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, cumulative National Ambient Air Quality Standards (NAAQS) and Class II increment analyses, and Class I increment consumption modeling.
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.
In the summer of 2001, Platte River Power Authority placed 31 leased, trailer-mounted, diesel-fired power modules at the Rawhide Energy Station in northern Larimer County, Colorado. WREG prepared permit applications and assisted with permit negotiations.
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.
WREG assisted a solution mining and mineral processing client in revising their Prevention of Significant Deterioration (PSD) permits to incorporate a number of substantive technology and emission changes that had occurred since the permits were originally issued. WREG performed dispersion modeling analyses for two widely separated portions of the source, including cumulative impact analyses. WREG also assisted the client in determining Best Available Control Technology (BACT) for a number of unique processes and emission units.
WREG personnel provided Kaiser-Hill Company and the US Department of Energy (DOE) air compliance, monitoring, and research support for the Rocky Flats Environmental Technology Site (RFETS) from 1996-2006. One of WREG’s Principals managed the air quality management organization at RFETS from 1996 to 2000 and continued to support Kaiser-Hill and DOE as the air quality Subject Matter Expert for the site, pending completion of regulatory closure requirements, including Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) requirements.
RFETS was a nuclear weapons production facility established in the early 1950s. The site was decommissioned and cleaned up, with physical completion declared in October 2005. Air compliance issues were challenging, given that the facility and its operations were constantly changing. Support activities included project-by-project regulatory review, emission estimation, compliance auditing, and permit application preparation and negotiation. The site was also subject to the radionuclide National Emission Standards for Hazardous Air Pollutants (NESHAP). Dispersion modeling analyses performed by WREG personnel aided in planning appropriate control measures for remediation and decommissioning projects.
Air monitoring included the acquisition of meteorological data from an on-site tower, continuous ambient monitoring at nearly 40 locations for radioparticulates, and effluent (in-stack) monitoring for particulate and gaseous radionuclides. Monitoring results were analyzed and reported to both regulatory agencies and the general public.
WREG team members also worked with RFETS personnel to research the movement of radionuclide contamination through the air pathway during a five-year actinide migration study. WREG personnel have co-authored several papers based on this research.
WREG assisted a refinery client in Wyoming in preparing two construction permit applications. One was focused on expansion of the crude unit and included a detailed netting analysis to avoid major modification requirements for nitrogen oxides (NOx). The second application involved modification of the coker unit. Wyoming Best Available Control Technology (BACT) analyses were prepared for particulate matter (PM10), sulfur dioxide (SO2), NOx, carbon monoxide (CO), and volatile organic compounds (VOCs) for the sulfur incinerator, heaters, and compressor engines.
WREG has prepared Prevention of Significant Deterioration (PSD) permit applications for five simple-cycle, natural gas-fired combustion turbines at Platte River Power Authority’s Rawhide Energy Station in northern Larimer County, Colorado. The turbine construction projects were developed as three separate projects and three separate permit applications were prepared over a period of several years. Application preparation included conducting a regulatory review, developing Best Available Control Technology (BACT) analyses, and performing necessary dispersion modeling, including modeling of visibility impacts. Since two of the projects were developed in a relatively short period of time, WREG worked with Platte River to provide documentation to the Colorado Air Pollution Control Division (APCD) that a single project had not been split into two projects for the purpose of circumventing PSD requirements. Acid rain documentation for the turbines was also prepared. Following application submission, WREG reviewed draft permit conditions and assisted Platte River with negotiating changes. WREG also prepared operating permit applications for the turbines.
WREG prepared the Prevention of Significant Deterioration (PSD) and operating permit application for the Panda Gila River Project in Maricopa County, Arizona. The project was developed by Panda Gila River, LP. The project is a combined-cycle combustion turbine facility capable of generating 2,080 megawatts of electrical power. WREG prepared an initial permit application including emission estimates, applicable requirements identification, Best Available Control Technology (BACT) analyses, and an air quality impact analysis. During the permit review and negotiation process, WREG 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). WREG also prepared documentation required under the Acid Rain Provisions of the Clean Air Act for submission.
WREG has provided day-to-day permitting and compliance support for a global oil and gas firm for several years. Activities have included preparation of permit applications, notifications, compliance reports/spreadsheets, emission estimates/inventories, Colorado Air Pollutant Emission Notices (APENs), compliance audits/assessments, sampling, and database development. Dispersion modeling has been performed for permitting of facilities in Texas, Wyoming, and Colorado. Additional projects include preparing a response to comprehensive data requests from the Central Region Air Planning Association (CENRAP), the Western Regional Air Partnership, and the Wyoming Department of Environmental Quality; investigation of glycol dehydrator area source Maximum Achievable Control Technology (MACT) notification requirements for multiple states; investigation of methods for estimating methanol emissions from evaporation ponds; and control device performance tracking and analysis.
WREG’s Principals have provided air quality assistance to a major malt beverage manufacturer since the early 1990s. With facilities around the country, including major facilities in Colorado, projects have included:
- Construction permit for a modification of brewlines and associated equipment. The permit contained facility-wide rather than emission unit-specific emission limits, complicating permitting applicability determinations. WREG prepared the application including preparation of Reasonably Available Control Technology (RACT) analyses for volatile organic compounds (VOCs) and fine particulate matter (PM10).
- Major modification permit application for packaging reconfiguration. Application included a Best Available Control Technology (BACT) analysis for VOC emissions.
- Minor modification permit application for replacing biobeds used for odor and VOC emission control from a sludge processing plant with a wet scrubber.
- Update of BACT analysis for a brewery in Virginia. Analysis focused on nitrogen oxide (NOx) emissions from boilers and VOC emissions from brewing and packaging operations.
- Prepared Superfund Amendments and Reauthorization Act (SARA) 313 reports for multiple facilities.
- Provide on-site environmental services support including updating emergency response plans, assisting with chemical inventories, analyzing and reviewing data for chemical tracking, preparing SARA 312 reports, and Materials Safety Data Sheet tracking.
- Prepared a permit application to expand a barley processing facility in Montana. Project included emission calculations, regulatory analysis, and debottlenecking evaluation.
- Emission factor determination and comparison across multiple facilities in different states. Emission factors that might constrain future permitting actions were identified and alternate emission factors determined where possible.
- Stationary internal combustion engine regulations were reviewed and flowcharts and requirements lists developed for Maximum Achievable Control Technology (MACT) standards at 40 CFR 63, Subpart ZZZZ and related New Source Performance Standards (NSPS), 40 CFR 60, Subparts IIII and JJJJ.
Bowie Power Station, LLC, retained WREG to prepare a combined construction/operating air permit application for a 1,000-megawatt natural gas-fired combustion turbine project to be located in southeast Arizona.
The permit application included a description of applicable requirements and compliance methods, Best Available Control Technology (BACT) analyses, and a detailed air quality impact analysis. CALPUFF, VISCREEN, 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. The project was recently repermitted as a 500-megawatt facility with updated BACT and dispersion modeling analyses.
WREG assisted with resolving permitting issues associated with emergency generators located at a computer data center in Boulder, Colorado. The state Air Pollution Control Division (APCD) asserted that Prevention of Significant Deterioration (PSD) requirements had been triggered.
WREG conducted a historic review of generator installation, operations, and emissions. In addition, WREG 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.
WREG prepared permit applications to consolidate boiler permits and to permit several additional large, diesel-fired emergency generators. WREG calculated emissions, performed dispersion modeling, and assisted in negotiating permit conditions with the state air agency.