The University of Massachusetts Amherst undertook an ambitious plan to build a new Central Heating Plant (CHP) that would replace its outdated coal-fired facility and bring state-of-the-art power and steam generation to the campus. The UMass Building Authority and the UMass Amherst Physical Plant Department reached out to Woodard & Curran to provide strategic permitting and air consulting assistance for final construction and then operation of the new CHP.
RENEGOTIATING PERMITS WITH REGULATORS
Woodard & Curran provided key support for several critical state and federal permits for this facility that included: MassDEP construction permits (7.02), an updated EPA Prevention of Significant Deterioration (PSD) Permit, and a new Title V operating permit for the whole campus. Woodard & Curran successfully negotiated permits with all regulatory agencies to create clear and reasonable permits in order to replace the old coal-fired power plant with the new, state-of-the-art, natural gas-fired cogeneration plant.
ESSENTIAL ADVISORY ROLE DURING TESTING, CERTIFICATION, AND TROUBLESHOOTING
Throughout the project, Woodard & Curran coordinated between the multiple parties involved in the power plant design, testing, emissions, modeling, and construction as well as with MassDEP and federal EPA regulators in order to meet the project timelines. The firm provided guidance and practical advice through the stack testing process, CEMS certification, MassDEP inspections, EPA inspections, and occasional troubleshooting issues associated with the shakedown period of the plant. This was compounded by the reinstatement of responsibility of the federal construction permitting process from EPA back to MassDEP. Throughout, Woodard & Curran served as the primary negotiator with the regulatory agencies who consistently held high regard for the University’s efforts to maintain compliance through the process.
ONSITE AND ON-CALL ENVIRONMENTAL COMPLIANCE SUPPORT FOR CHP
The Central Heating Plant (CHP) is a large, complicated facility that has ever-shifting staffing needs due to promotions, transfers, and retirements. Since the facility’s start-up, Woodard & Curran has worked with the university in various staffing roles—both short and long term, onsite and off—to back-fill positions with air quality and environmental compliance responsibilities. Our staff has acted as the onsite environmental manager to ensure that the CHP’s continuous emissions monitoring systems (CEMS) are performing reliably and accurately. We provided technical expertise troubleshooting the CEMS as needed and kept the facility abreast of regulatory changes. We also compiled any necessary reports required by MassDEP and EPA and conducted CEMS trainings, allowing the CHP to continue functioning successfully and in compliance with its permits in the midst of various transitions.
