Personnel now at STI helped identify key state and local air regulations and permitting timelines within the states of the East Central Area Reliability Council (ECAR) region, and helped the client obtain preconstruction permits for locating a 520 MW peaking station in either West Virginia and Kentucky (where a Title V Operating Permit was also obtained). The STI personnel developed acceptance/compliance testing protocols for criteria pollutants and HAP through coordination with the vendor and construction contractor, and supervised stack tests. Additionally, the Data Acquisition and Handling System (DAHS) was evaluated, a QA/QC Plan was drafted, and Monitoring Plans and Certification Applications were prepared in accordance with Part 75 requirements. A comprehensive, "plain language" air regulations compliance manual was also prepared for the facility operators.
STI personnel provided extensive regulatory and technical support to this Rhode Island facility, quantifying emissions of aldehydes and other pollutants from batch processes, open tanks, and other sources through a variety of testing and calculational methodologies. Preconstruction permits were obtained, the Title V Operating Permit application was prepared, and an emissions recordkeeping spreadsheet keyed to production data was developed. This facility's compliance with all applicable air regulations was verified by a third-party auditor for US EPA's StarTrack program.
Personnel now at STI planned, coordinated and supervised a series of emissions testing programs at a fertilizer drying facility (432 dry tons/day capacity) in Massachusetts. Emissions units were equipped with variable frequency drive (VFD) fans, air recirculation loops, shared stacks, and adjustable pollution controls for particulate matter, ammonia, total reduced sulfur (TRS), and VOC; variations in dryer feed were also present. Issues associated with process and data variability, low concentrations (near detection limits), cyclonic airflow, effects of different sampling and analysis techniques, non-steady-state (startup) emissions, and hygroscopic particulate matter were addressed through analysis of available process monitoring data, well-planned test programs, and selection/modification of test methodologies for improved reproducibility and precision. Sampling included tests for particulate mass, particle size distribution, ammonia, NOx, CO, VOC, SO2, TRS, multiple metals (Method 29), and chromium-VI.
As part of a PSD permitting process for a 30 MW standby power facility in New Mexico, STI conducted visibility impact modeling (using ISC, CALPUFF and VISCREEN) and determined that it would be beneficial to the client (a 30 MW standby power facility in New Mexico) to incorporate ISC-OLM algorithms (quantifying NOx conversion to NO2, given input data regarding ambient ozone concentrations) into the ISC-PRIME model for greater accuracy at the screening level stage. This enhancement to the screening model prevented the need for more expensive, refined NO2 modeling and was accepted by the U.S. EPA and state regulatory agency. STI also helped draft the PSD permit language, and found and corrected errors in stack testing data.
STI personnel developed and validated a customized complex terrain dispersion model (MPDM) to correct deficiencies in a regulatory screening model applied to a copper smelter in New Mexico. Use of the customized model was subsequently approved by U.S. EPA and New Mexico Environmental Department.