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.
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.
The Colorado regulations allow a source to enter into Voluntary Emissions Reduction Agreements (VERAs) with the Colorado Air Pollution Control Division (APCD). A VERA provides the source with a regulatory assurance period during which the state cannot require installation of additional pollution control equipment or implementation of additional pollution control strategies. Platte River reduced nitrogen oxides (NOx) and sulfur dioxide (SO2) emissions from the coal-fired steam generating unit at the Rawhide Energy Station. To obtain a regulatory assurance period associated with the coal-fired unit’s emission controls, Platte River chose to enter into a VERA. WREG provided technical support to Platte River during the VERA development and negotiations. This support included review of VERA calculations and language, and research into Best Available Retrofit Technology (BART) and Best Available Control Technology (BACT) determinations for coal-fired steam generating units.
Because the project resulted in increases in carbon monoxide (CO) emissions, WREG also assisted Platte River in preparing a construction permit application for the associated emissions increase.
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 worked with a Colorado utility to investigate the feasibility and constraints on building a second coal unit at an existing power station in northern Colorado. The study looked at Class I issues at Rocky Mountain National Park and the Rawah Wilderness Area, as well as local impacts around the power station. Modeling was performed with AERMOD and CALPUFF. Emission development and modeling involved not only coal stack emissions, but also coal, ash, and lime handling, and emissions from existing or proposed gas turbine peaking units at the site.