Construction needed to be completed as quickly as practical for this 96 megawatt natural gas-fired power plant and 2.4 mile natural gas pipeline. Approvals and/or input were required from the California Energy Commission (CEC), California Department of Fish and Wildlife (CDFW), California Department of Environmental Health (CDEH), Regional Water Quality Control Board (RWQCB), Caltrans, Air Pollution Control District (APCD), and the County of San Diego. Permit conditions required hundreds of submittals before ground-breaking and other construction milestones could proceed. Construction was in an area with more than ten protected species, three sensitive habitat types, sensitive cultural resources, and multiple surface drainage crossings that needed to be avoided. Submittals, monitoring, and reporting needed to be highly efficient and effective to keep up with construction progress and CEC documentation procedures. Additionally, the CEC rejected an initial application for the project filed under the Small Power Plant Exemption process due to a change in the pipeline route to sensitive habitat areas.
TRC assembled an experienced team of professionals and technicians to fulfill
construction monitoring and reporting requirements with high efficiency. TRC used
compliance management and tracking tools proven through experience on
similar projects to expedite CEC approvals needed for ground-breaking and other
project milestones. Continuous coordination with J-Power USA, construction
contractors, subcontractors, and the construction work crew was used to stress and
encourage a culture of safety and environmental compliance through all levels of
the project team to minimize the potential for issues that could trigger construction
TRC coordinated closely with the J-Power USA development team providing design
input to avoid impacts to threatened and endangered species and jurisdictional
waters. Avoiding these impacts eliminated the need for a Clean Water Act Section
404 permit and 401 certification and formal consultation with U.S. Fish and
Wildlife Service. TRC prepared and supported all applications required for the
project’s environmental permits and worked closely with agency staff to expedite
environmental review and permit processing timelines. The critical path project permits from the CEC and APCD were obtained in 9
months, saving 6 months compared to the 15 month timeline that was typical
during the time period. TRC’s project design input reduced the permitting schedule
by an additional year or more by avoiding impacts to waters and protected wildlife.
TRC’s work helped J-Power USA bring this project online as quickly as practical to generate revenues from their investment and meet contract obligations. Approval for groundbreaking was obtained without delay following completion of required engineering, and construction was completed without environmental compliance delaying the construction schedule. These benefits translate to optimized return on investment as well as direct time savings for the J-Power USA development team resources.
In addition, TRC's ongoing support of this facility includes the development of a comprehensive environmental compliance program to track and streamline routine compliance and to facilitate consistent training.
A compliance program manual outlines the program framework and includes
procedures, schedules, checklists, and other implementation tools for use by staff
and management to assure compliance is consistently maintained. Tools are
incorporated to facilitate report preparation, compliance inspections, recordkeeping,
environmental sampling, pollution prevention, hazardous materials compliance,
ammonia risk management, natural resource protection, environmental training, and