Introducing Girls to Female Role Models

For those of you who are women or have special women in your lives, check it out!  “A Mighty Girl” has released eight downloadable and free posters to introduce girls to female role models in the areas of science, mathematics, and technology.  The posters, created by Nevertheless, feature eight trailblazing women who have made an impact in STEM fields. Each poster is also uniquely designed by a different female artist from around the world.  How cool is that?!?  The intent of these posters is that you will download and print them out for your school, home, or workplace; or simply spread the word.  The website, “A Mighty Girl”, includes additional information about each woman. They also have a list of 70 books to inspire science-loving girls.

Also worth checking out is the Nevertheless podcast, which celebrates women transforming teaching and learning through technology.

Manufacturing Facility in Denver, Colorado


Personnel turnovers and a loss of institutional knowledge at the site created problems when the facility needed to make changes to their air permit. Not understanding the RACT requirements that come into play for permit modifications in non-attainment areas, they reached out to Array for help.



Array reviewed the facility’s historic information, including previously rejected air pollution emission notices (APENs); interviewed personnel; and conducted a site visit to understand the emission sources present. Based on this information, we were able to submit revised APENs and a RACT analysis with a limited scope of control technology options. Having conversations with the Division at the beginning of the project fostered these important relationships, cleared up some previously confusing correspondence, and enabled both parties to have a clear view of the scope, which ultimately saved our client time and money.

Mine and Mill in New Mexico


Our client’s Title V and NSR air permits contained a general permit condition that did not align with the original intent of the text and created stack testing requirements that were difficult to meet. In fact, to meet the capacity required during stack testing, additional equipment had to be permitted to supplement the throughput.



Array worked with the state permit engineer who explained the original purpose of the text and clarified the situation under which the general condition should be applied. Within one month, the general permit condition text was updated by the state agency for all applicants, and relief from the long-standing stack testing burden was lifted.

Colorado Updated Air Fee’s

Colorado’s following APEN, permitting, and annual fees have been updated.


Type of fee Amount Effective Date
APEN Submittal Fee $191.13/APEN July 1, 2018
Permit Processing Fee $95.56/hour July 1, 2018
Annual APEN Fee – Regulated Pollutants $28.63/ton November 2018 (est.)
Annual APEN Fee – Hazardous Pollutants $191.13/ton November 2018 (est.)


Here is the Division’s fact sheet on these fees:

3 Key A&WMA Takeaways

I attended an A&WMA webinar on TANKS 4.09D today; and among all the great information that was presented, here are the three most important takeaways:

  1. EPA enforcement has stated that reliance on TANKS 4.09D is not an effective defense even if a state agency has approved and/or required it. As such, EPA can over-file if they feel a state agency has made an incorrect determination in allowing the use of TANKS 4.09D.
  2. TANKS 4.09D is only good at estimating annual emissions for floating roof tanks in equilibrium with ambient temperatures where actual stock data (i.e., no defaults) are used with the actual guide pole status. If all of these conditions are met, the TANKS results can be relied upon.
  3. EPA is revising AP-42 Chapter 7.1 to include clarifications, corrections, adjustments to some of the equations; and emission calculations for additional scenarios (e.g., tank cleaning losses). Once the new version of AP-42 is out, any further use of TANKS 4.09D should cease.

Colorado Smoking Vehicle Hotline

Did you know that Colorado has a Smoking Vehicle Hotline where you can anonymously call in or email information regarding vehicles that you see on the road that have really bad exhaust?!? All you need is the Colorado vehicle’s license plate number. Once you call it in, the CDPHE will send the owner of the vehicle a notification to take an emissions test; and if they fail the test; repairs will be required.

The hotline number is 303-692-3211 and the hotline email is

Please do not call or email while driving!

Ozone Level Alerts in Colorado for June-August

Colorado is now forecasting ozone levels from June 1st to August 31st. When ozone levels are anticipated to be high, an Ozone Action Alert email will be sent to various people and groups, including industries, who have signed up to receive these alerts. The alerts cover a 24-hour period and are sent out 2 to 4 days in advance of the expected high ozone day to afford people time to adjust their planned activities. Some industries are taking active measures during these high ozone days to minimize the release of NOx and VOC to the atmosphere by not performing certain industrial activities such as meter testing, tank cleanings, well unloading, and well depressurization; not making non-essential trips to the field to minimize driving distances; and reminding employees of actions they can take at home such as carpooling, not idling in vehicles, fueling vehicles after sunset and stop fueling at the “click”, mowing the lawn in the evenings, using electric yard appliances, postpone painting or staining activities, etc.

You can find more information on the status of Colorado’s air and sign up to receive the ozone alerts here:

Colorado APEN Fee Invoice Review Reminder

This is a public service announcement for the folks in Colorado to check your annual APEN fee invoice as soon as possible. You have 30 days from the date of the invoice (usually dated late February) to request changes to your annual fee if you find that the emissions in your invoice are wrong. Let me know if you have any questions about your invoice since I’ve had a few conversations with the CDPHE about my client’s invoices and can probably provide some insight. Also, if you found errors but already paid, reach out to me and I’ll send you the email of the person at CDPHE who will go ahead and fix it before the next invoice is sent out.

Updates on NMED AEIR Web Application Process

I attended the New Mexico Environment Department’s (NMED) annual emissions inventory reporting (AEIR) webinar and learned that NMED is continuing the improve the AEIR web application.

This year we will see some of the data from previous years retained in the web application and the ability to save a page without having everything filled out. However, if you started working in the online application before mid-February 2018, these features weren’t completely rolled out, so you might not be seeing this improvement yet.

I also learned that if you are an AEIR administrator, you will not be able to remove any previous submitters that show up under the “Admin Tools” list.  This is intended to help NMED keep track of who submitted previous reports in case any issues arise.

Because the due date is April 1, 2018, administrators should make sure that the correct certifiers are showing up in their list with a check-mark by their name. In addition, make sure your certifier has registered for the application, received a corresponding email from NMED with access instructions, and knows where to go within the application to certify. This is a very deliberate multi-step process, so don’t wait till the last minute!

AP-42 Data and Air Permit Stack Test Requirements

If you use data from AP-42 to calculate particulate matter emissions, it is highly likely that this data represents only filterable particulate matter and no condensable particulate matter. As such, make sure any stack test requirements in your air permit reflect the same particulate matter basis that was used to estimate your emissions (i.e., filterable, condensable, or both). Otherwise, you might be comparing apples-to-oranges, which is less than desirable for compliance purposes.