Environmental Impact Assessment Projects

Steigers Corporation prepared a Prevention of Significant Deterioration (PSD) Construction Permit application for Westward Seafoods’ Dutch Harbor Seafood Processing Plant. The project involved resolution of complex air dispersion modeling issues using improved regulatory modeling techniques to demonstrate compliance with National Ambient Air Quality Standards and PSD increments. For dispersion modeling we successfully reprocessed a meteorological data set that had previously been collected and processed by another consultant but rejected by the Alaska Department of Environmental Conservation. Our modeling efforts significantly reduced the height and cost of the stack design.

Steigers Corporation also completed the Best Available Control Technology (BACT) analysis for the PSD Permit, including an innovative economic evaluation of alternative control technologies that justified the use of the client’s preferred low-NO_x combustion system in lieu of more costly Selective Catalytic Reduction.

Steigers Corporation had previously accomplished the compliance effort addressing an Environmental Protection Agency (EPA) Compliance Order requiring submittal of a Title V Operating Permit application. The final Title V Operating Permit application included a complete facility description, inventory of emissions, calculation of emission fees, compilation of all enforceable operating requirements, and the status of compliance with each requirement. The application was submitted to the EPA Region 10 and the State of Alaska and was deemed complete well ahead of the deadline required for Westward Seafoods to avoid all penalties and other enforcement action.

Steigers Corporation prepared an air quality Construction Permit application to resolve a potential regional air quality problem in a Sulfur Dioxide (SO₂) Special Protection Area in Alaska. To support the permitting effort, Steigers Corporation conducted air quality dispersion modeling for the St. Paul Seafood Processing Plant and other regional emission sources. The modeling analyses for the St. Paul Processing Plant included evaluation of multiple operating scenarios to demonstrate compliance with National Ambient Air Quality Standards and Prevention of Significant Deterioration increments. The project successfully coordinated air quality permit approvals for several competing industrial facilities in St. Paul to the satisfaction of all involved.

Steigers Corporation also prepared a Title V Operating Permit application for the St. Paul Seafood Processing Plant that was deemed complete by the Alaska Department of Environmental Conservation. We provided comments on the draft Title V Operating Permit on behalf of our client to modify or remove terms and conditions lacking a legal basis.

Steigers Corporation provided air quality permitting and support services for the owner/operator of various floating seafood processing vessels in Alaska. The Alaska Department of Environmental Conservation (ADEC) had improperly asserted that one vessel, the Arctic Star, was required to obtain a Title V Operating Permit because its nitrogen oxide (NO_X) emissions exceeded 100 tons per year (tpy). Steigers Corporation explained to ADEC that (1) under 40 CFR 89, every diesel-fired engine aboard the Arctic Star is a non-road engine due to the Arctic Star’s annual operation pattern and (2) after excluding all non-road engine emissions, the annual emission rate of every pollutant falls below the Title V threshold.

To save the time and expense of obtaining an unnecessary and unwarranted Title V Operating Permit, Steigers Corporation approached various EPA offices and succeeded in obtaining a formal determination. As a result, ADEC withdrew its demand for a Title V Operating Permit.

Steigers Corporation also prepared the air quality application for an Owner Requested Limit (ORL) for the Arctic Star to resolve a potential regional air quality problem in an SO₂ Special Protection Area in Alaska. To support the permitting effort, Steigers Corporation worked closely with ADEC to develop a regional emission inventory and conduct air quality dispersion modeling for the Arctic Star and other regional emission sources. The project successfully coordinated permit approvals for several competing industrial facilities in the region.

Steigers Corporation prepared a Prevention of Significant Deterioration (PSD) Construction Permit application for the Dillingham Power Plant, an existing 5.4-MW diesel power plant for which an additional 1.0 MW of power generation capacity was planned. Steigers resolved the issue of installing retroactive Best Available Control Technology (BACT) on aging diesel-fired power generation equipment and by negotiating an agreement with the Alaska Department of Environmental Conservation (ADEC) that allows continued operation of the power generation equipment without implementing BACT until the existing units are replaced. Steigers Corporation’s client thereby avoided the need to install expensive nitrogen oxide (NO_X) emission controls on aging equipment and was allowed to direct limited resources to better use on more efficient and lower-polluting new units.

Moreover, Steigers Corporation used consumer rate increase data to convince ADEC and the Environmental Protection Agency (EPA) that NO_x emission control with Selective Catalytic Reduction (SCR) was too costly to be considered BACT.

Despite the limited availability of key meteorological data inputs for air dispersion modeling, a meteorological data set was developed that met EPA’s and ADEC’s approval, thereby avoiding time-consuming monitoring that would have delayed the project approximately 18 months. After ADEC drafted the PSD Construction Permit, Steigers Corporation reviewed the document and convinced ADEC to agree to a reasonable construction schedule and to delete unjustified conditions and requirements.

In 2010, the country built its first full height 48-step-pool ladder, designed specifically for bull trout, and commenced operations at the Thompson Falls Dam. During the first operating season, over 1,800 fish ascended the ladder, including two bull trout.

From the initial stages, Steigers Corporation’s fisheries biologists and scientists participated in the development of studies, data analysis, biological monitoring, report preparation, and regulatory compliance efforts. In addition, we contributed to preparation and technical review of the Biological Evaluation (BE). The BE required extensive coordination with federal, state, tribal, and local entities and consultation with U.S. Fish and Wildlife Service (USFWS).

Prior to construction, our scientists and managers coordinated with agencies, engineers, and the owner to identify regulatory compliance requirements and prepared the necessary permit applications for submittal to the U.S. Army Corps of Engineers, Montana Department of Environmental Quality, Sanders County Flood Plain Administrator, and Green Mountain Conservation District. Construction commenced on schedule in spring 2009 and was completed in fall 2010.

Steigers Corporation also developed a 10-year plan evaluating the upstream fish passage efficiency, including short-term and long-term studies to assess optimum operations such as attractant flow and weir mode (v-notch versus orifice mode). In addition, we provided statistical analysis and prepared an annual report for submittal to FERC and other agencies that summarized annual fish passage numbers, species, timing of ladder ascent, recaptures, and estimate of fish that fallback via spill or turbines.

Mystic Lake Dam is nestled in the Absoraka-Beartooth Mountains. The dam has a generating capacity of 12 megawatts and began operation in 1925. Mystic Dam occupies approximately 674 acres of federal lands in the Custer National Forest located on West Rosebud Creek.

Steigers Corporation’s staff participated in the Mystic Lake Federal Energy Regulatory Commission (FERC) relicensing process and assisted in preparation of compliance documents, including the pre-application document, study plans, and the final license application. Mystic Lake Dam was issued the first license in the nation by FERC using the Integrated Licensing Process (ILP) and was recognized for the quality and thoroughness of the application. The new license was approved and made effective by FERC January 1, 2009.

Steigers was responsible for compliance with the following environmental components of the facility’s FERC license, which included:

• Analyzed fisheries data and prepared the Annual Fisheries Monitoring Report
• Developed a 10-year water quality monitoring plan
• Implemented a 5-year wildlife management plan
• Completed annual bald eagle monitoring and Harlequin duck surveys
• Development and implementation of a weed management program

The aging power generation infrastructure at the Rainbow Hydroelectric Development, originally built in 1910, is located on the Missouri River near Great Falls. The $250 million Rainbow Redevelopment Project provided an enormous economic boost for the Great Falls region and was the largest private sector project, in terms of dollars, completed in Cascade County to date.

During the design, construction, and post-construction phases of the project, our client relied exclusively on Steigers Corporation’s staff to identify, execute, and manage project-wide regulatory compliance as required for our client as well as all contractors. Steigers Corporation consulted and coordinated with all participating federal, state, and local agencies to prepare, submit, and maintain permits on the behalf of our client and its contractors. The project included a significant Federal Energy Regulatory Commission (FERC) component, including preparation of numerous articles and FERC submittals. We developed a comprehensive environmental compliance inspection program for the construction management inspectors and completed independent quarterly environmental inspections for overall compliance.

As with any project, particularly multi-year projects, change during construction is inevitable. As design changes were made for the Rainbow Redevelopment Project, Steigers Corporation provided immediate compliance solutions. Steigers Corporation’s staff coordinated with contractors, engineers, the owner, and agencies to prepare and submit necessary applications and supporting documents for regulatory compliance.

The Black Eagle Project required replacement of an existing, aging 100-kV radial line and wooden H-frame structures and the addition of All-Dielectric Self-Supporting fiber optic cable along sections of a 2.5-mile corridor that interconnects the Black Eagle Hydroelectric Plant to NorthWestern Energy’s Riverview substation.

The Black Eagle Project provided significant levels of complexity from the standpoint of land use and ownership, access, easements, right-of-ways, a state recreation area, presence of an active bald eagle nest during construction, and potential for encountering hazardous waste as a result of historic smelter operations. Not only did the project area traverse multiple land ownerships and land use, approximately half of the corridor was located on the former Anaconda Copper Mining Company and Smelter and Refinery Site that is listed on the Superfund National Priorities List.

Steigers Corporation was tasked with providing regulatory management and oversight for all phases of the Black Eagle Project. Preliminary design through post-construction, including, but not limited to the preparation of permit applications and supporting documents, compliance with the Federal Energy Regulatory Commission license, coordination with private landowners, biological field investigations, post-construction revegetation monitoring, and development and implementation of multiple environmental plans.

Steigers Corporation’s role also included direct communication and coordination with the owner, design engineers, contractors, legal counsel, and construction management team to meet critical project milestones and deadlines, address design changes and implications to regulatory compliance, and obtain necessary permit authorizations from the appropriate federal, state, and/or local entities in a timely manner prior to commencing construction.

Steigers Corporation staff began work on the Healy Clean Coal Project in January 1990 through December 2010. We provided environmental program management and permitting services to the State of Alaska for development and construction of a new 50-MW Clean Coal project.

Project management services included overseeing all field data collection and investigations for preparation of an Environmental Information Volume to support development of the federal EIS and multiple permit applications. Most notably Steigers Corporation managed all environmental studies, analyses, and environmental subcontractors; reviewed environmental documents produced by federal and state agencies; monitoring all permit applications; liaised with federal agency personnel on environmental issues relating to the EIS; and provided support during negotiations with the National Park Service and others.

Sited near Denali National Park and Preserve, a federal Class I air quality non-degradation area, the project required extensive consultation and coordination for air quality and visibility modeling, Best Available Control Technology (BACT) analysis, and documentation of impacts on Air Quality Related Values (AQRV). Steigers Corporation provided these services, prepared and coordinated the Prevention of Significant Deterioration (PSD) air permit application, and expedited completion of agency permitting responsibilities. The PSD permit application was the first major PSD permit application the State of Alaska deemed to be technically complete as originally submitted.

The Healy Clean Coal Project was highly politically sensitive, ultimately resulting in a negotiated settlement agreement involving signatory by the Secretaries of the U.S. Department of the Interior and the U.S. Department of Energy.