Welcome to Sea Rivers Consulting, LLC

Regulatory Impact Review, USPowerGen, New York, New York. SRC staff reviewed the impact of US EPA’s Electric Generating Unit (EGU) mercury and air toxics standards (MATS) on the company’s electric generating assets.  SRC staff evaluated control technology options to comply with the rule, including fuel switching.  As part of the project, SRC staff helped the client prepare a detailed set of comments on the proposed MATS rule that were submitted to US EPA, a number of which were incorporated into the final rule. 

Air Pollution Control Regulations Review, Major Combustion Turbine Manufacturer.  SRC staff managed the review of air pollution control regulations across multiple US states and European countries to determine particulate matter (PM10 and PM2.5) and other pollutant emission control requirements for utility scale combustion turbines.  SRC staff analyzed the impact of current and potential future air pollution control regulations relating to the siting and permitting of large combustion turbines.

Information was compiled to help the Company’s product development team and environmental staff understand current and emergent regulatory requirements that would influence product design.  As part of the project, SRC staff evaluated state and federal New Source Review (NSR) air pollution control regulations and emissions banking and trading programs, e.g., emission reduction credits, required to license new energy projects. 

Mandatory Greenhouse Gas (GHG) Reporting, US Power Generating Company, New York, New York.  SRC staff managed this project to complete a US EPA Mandatory GHG Reporting Rule (MRR) Gap Assessment for this electric power generating company.  US PowerGen generated electricity for sale to Independent System Operators (ISOs) and Regional Transmission Organizations (RTOs).  At the time the Company owned and operated five power stations – three in New York City and two in the Boston metropolitan area.  Work included conducting site visits to evaluate procedures for collecting fuel composition data and fuel flow meter data and also QA/QC procedures.  Gaps were identified with respect to deficiencies in aligning with MRR recordkeeping and monitoring procedures. The project also involved on-line electronic reporting of GHG emissions to US EPA.

Plant Expansion Project, Pennsylvania. SRC staff managed all aspects of environmental permitting of a 125 MW multi-fuel fired (coal, wood, and natural gas) cogeneration power project.  SRC staff directed the air permitting effort that involved completing best available control technology (BACT) and lowest achievable emission (LAER) control technology reviews of affected Prevention of Significant Deterioration (PSD) and non-attainment area New Source Review (NNSR) air pollutants.  Detailed reviews of recent state-issued permits, new emergent technologies, as well as US EPA’s RACT/BACT/LAER Clearinghouse database were conducted.  In addition, SRC staff led the tasks required to secure pre-construction regulatory agency approvals relating to water withdrawal and discharge, stormwater management, cultural resources, threatened and endangered species, wetlands and floodplains, and local permits.

Ammonia Plant Expansion, Louisiana. SRC staff directed this project to permit a major ($1 billion) expansion of a chemical plant.  The client was taking advantage of the abundant supply of low cost natural gas, which is the principal feedstock to produce ammonia, to invest in the future growth of the facility.  SRC staff worked with the client’s corporate development team and outside counsel to identify control technology strategies that would expedite the permitting process.  The scope of work encompassed all aspects of siting and permitting a capital project, including completing BACT analyses for CO2e, PM2.5, CO, and VOC; air dispersion modeling to demonstrate compliance with national ambient air quality standards (NAAQS); and completing an Environment Assessment that defined the socio-economic benefits of the project, identified measures to mitigate impacts, and included an alternatives analysis.

PSD Permitting - Cogeneration Electric Generating Station, Rhode Island.  SRC staff managed the preparation of a PSD permit application for a new cogeneration plant.  The project covered the construction of a 500 MW combined cycle station powered by natural gas-fired combustion turbines, with fuel oil as backup.  The BACT analysis required the investigation and presentation of applicable control technologies for NOx, CO, SO2 and particulate matter emissions.  Control techniques evaluated ranged from low-sulfur oil for SO2 control to selective catalytic reduction (SCR) for NOx control.  The BACT analysis contained a detailed presentation of cost effectiveness and incremental cost data for reducing NOx emissions.

Corporate-Level Compliance Assessment Program, Babcock Power, Worcester, Massachusetts.  SRC staff managed this corporate driven third-party compliance audit program for a multi-billion dollar international company.  The audits were conducted to determine the facility’s compliance with federal, state and local environmental requirements.  Environmental media covered in the audits included air quality, wastewater/storm water, hazardous and solid waste, spill prevention and control, storage tanks, emergency planning and community right-to-know, and toxic substances as well as Corporate-adopted environmental requirements.  Each audit consisted of an opening conference, thorough site-walk to observe facility operations and environmental management procedures, records review and closing conference to discuss preliminary findings.  A comprehensive audit report was prepared presenting the audit findings.

EHS Compliance Program, National Renewable Energy Company, Illinois.  SRC staff managed a third-party EHS compliance assessment program for a US Renewable Energy company that operates several wind energy and fossil combined cycle power plants across the country.  The audits evaluated facility compliance with federal, state and local environmental health and safety requirements.  The audits consisted of an opening conference, a thorough site-walk to observe facility operations and a documents review of EHS procedures, staff interviews, and a closing conference to discuss preliminary findings.  Comprehensive audit reports were prepared documenting audit findings. 

Environmental Compliance Auditing and Due Diligence Program - Magna Services Inc.  -  SRC staff managed a corporate-drive third-party environmental compliance audit (ECA) and due diligence program for this multiple billion dollar international automotive parts manufacturing company.  The Company owns more than 60 facilities across the United States and audited one-third of these facilities each year. The ECA program included performing ASTM Phase I Environmental Site Assessments (ESAs). In addition, one project involved completing Phase I ESAs to support a $500 million acquisition.  The ECAs were conducted to determine the facility’s compliance with federal, state and local environmental requirements.  Environmental programs covered by the audits included air quality, wastewater/storm water, hazardous and solid waste, spill prevention and control, storage tanks, emergency planning and community right-to-know, and toxic substances as well as specific Corporate environmental requirements.