Wind River Environmental Group LLC

Tag Archives: Operating Permits

Tri-State Generation and Transmission Support

Tri-State Generation and Transmission Support

Tri-State Generation and Transmission SupportWREG 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.

Toltec Power Station Permit Application

Toltec Power Station Permit Application

Toltec Power Station Permit ApplicationWREG 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.

Rocky Flats Environmental Technology Site Support

Rocky Flats Environmental Technology Site Support

Rocky Flats Environmental Technology Site SupportWREG 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.

Pharmaceuticals Air Quality Support

Pharmaceuticals Air Quality Support

Pharmaceuticals Air Quality SupportWREG has provided air quality permitting and compliance support to a pharmaceutical plant in Boulder, Colorado. Projects have included determining permitting options for a new pharmaceutical process unit, preparing air quality requirements training for plant staff, assisting the company with the preparation of comments on the Colorado Best Available Retrofit Technology (BART) rulemaking process, and ongoing general support, including Maximum Achievable Control Technology (MACT) requirements for pharmaceuticals production. An operating permit application was also prepared to add a process to the facility. 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.

Panda Gila River Project Permit

Panda Gila River Project Permit

Panda Gila River Project PermitWREG 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.

Fiberglass Light Pole Manufacturing

Fiberglass Light Pole Manufacturing

Fiberglass Light Pole ManufacturingWREG has helped a decorative light pole manufacturer with permitting and with Maximum Achievable Control Technology (MACT) compliance. The plant produces and paints fiberglass light poles. The operations are subject to two MACT standards: 40 CFR 63, Subpart PPPP—National Emission Standards for Hazardous Air Pollutants for Surface Coating of Plastic Parts and Products, and 40 CFR 63, Subpart WWWW—National Emission Standards for Hazardous Air Pollutants: Reinforced Plastic Composites Production.

WREG has prepared tools to help the company determine and track compliance with operating permit and MACT conditions. WREG has also assisted with preparation of a permit modification application to add base mold manufacturing operations to the facility and with preparation of an application to renew the facility’s operating permit. WREG also prepared documentation needed to relocate the plant to a new site in Colorado.

Colorado Refining Company/Suncor Energy (USA) Inc.

Colorado Refining Company/Suncor Energy (USA) Inc.

Colorado Refining Company/Suncor Energy (USA) Inc.WREG personnel provided air compliance, permitting, and training support to the Colorado Refining Company (CRC) from 1995 to 2005. Following the purchase of CRC’s Denver refinery by Suncor Energy (USA) Inc. in 2005, WREG has continued to provide support to the combined Suncor/CRC facility (known as the Commerce City Refinery). One of WREG’s Principals has provided continuous support to the refinery since 1997. Proposed changes are reviewed for air regulatory consequences. Emissions estimates and regulatory applicability reviews are performed, and, if necessary, permit applications are prepared and negotiated.

WREG’s Principals prepared the Title V operating permit application for CRC’s refinery and assisted with the negotiation of the permit terms and conditions. WREG has also prepared a number of construction permit applications and performed dispersion modeling as needed. Other tasks include conducting audits, researching regulatory issues, inspecting tanks for regulatory compliance, and developing environmental management procedures. Major regulatory programs addressed include leak detection and repair requirements, benzene waste monitoring and reporting, National Emission Standards for Hazardous Air Pollutants (NESHAP)/Maximum Achievable Control Technology (MACT) applicability, and New Source Performance Standard (NSPS) applicability, monitoring, recordkeeping, and reporting.

WREG prepared Startup, Shutdown, and Malfunction Plans (SSMPs) for several of the refinery’s units for compliance with MACT standards. Plans were prepared for storage vessels, loading racks (truck and railcar), and equipment leaks for compliance with 40 CFR 63, Subpart CC, and for the catalytic cracking unit, catalytic reforming unit, and sulfur recovery unit for compliance with 40 CFR 63, Subpart UUU.

WREG has also provided training to the refinery staff. Training topics have included refinery compliance goals and procedures, as well as monitoring, recordkeeping, and reporting requirements for storage vessels and wastewater systems. WREG also provided Best Available Retrofit Technology (BART) rulemaking support on behalf of the refinery.

Bowie Power Station Permit Application

Bowie Power Station Permit Application

Bowie Power Station Permit ApplicationBowie 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.