WLA prepared and submitted a Prevention of Significant Deterioration (PSD) Air Quality Notification of Construction Application for a proposed large-scale integrated hybrid fuel-grade ethanol manufacturing and cogeneration facility near Hugoton, Kansas. The PSD application contained a detailed project description, potential to emit (PTE) calculations, Best Available Control Technology (BACT) analysis, regulatory applicability analysis, ambient air quality impact assessment (AQIA) and visibility, soil and vegetation, and growth impacts assessment.
The main challenge encountered during the preparation of the PSD application was that the facility design had not been finalized. Various components of the facility were being modified and/or re-configured concurrent with the application preparation activities. WLA developed a comprehensive potential emissions calculation excel workbook that calculated the facility-wide PTE in such a way that the workbook was interactive, allowing for the company to make modifications to the process or projected emissions and obtain revised PTE values immediately. This workbook was critical in the preparation of the BACT analysis, as the final design of certain components / equipment was dependent on the selected BACT.
WLA was also tasked with developing a Risk Management Program and preparing a Risk Management Plan. After evaluation of the proposed operations, WLA established alternative compliance criteria in which the facility could remain below the Section 112(r) applicability thresholds, thereby reducing their reporting and monitoring responsibilities under the Risk Management Program. By establishing the alternative compliance criteria, WLA assisted the company in implementing the best RMP solution for their operation.
Additionally, fugitive dust emissions were determined to be problematic during the AQIA. The Kansas Department of Health and Environment, Bureau of Air and Radiation (BAR) requested that the haul roads be modeled as “area sources”. The U.S. Environmental Protection Agency (EPS) has indicated that they are continuing to assess application issues related to the AERMOD modeling system and modeling impacts from haul roads. Key items that they are focusing on include potential updates to AP42 emission factors, source characterization issues to develop “best practices” recommendations for modeling of haul roads, and consistency issues among EPA regions and State agencies. For the purposes of this project, WLA evaluated nearby State agencies emission calculation methodologies and source characterizations used for modeling, and recommended the use of fugitive dust emissions from process-related traffic on facility haul roads be calculated following the Utah Department of Environmental Quality (DEQ) memorandum, Emission Factors for Paved and Unpaved Haul Roads, March 10, 2008. The Utah DEQ memo recommended using AP-42, Chapter 13.2.2, Unpaved Roads (11.06) with 95% control efficiency for paving the road surface and sweeping and watering Best Management Practices (BMPs). The source characterization parameters used for the AQIA were based on other recently modeled facilities in the State of Kansas.