WREG conducted compliance audits at two regional refineries. The audits covered 40 CFR 60, New Source Performance Standards (NSPS), and 40 CFR 61 and 63, National Emission Standards for Hazardous Air Pollutants (NESHAP). The scope included Leak Detection and Repair, Benzene Waste Operations, and Hazardous Organic NESHAP control technology requirements, as well as flaring practices under NSPS Subpart J. In addition, compliance with mandatory Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA), Section 103, and Emergency Planning and Community Right-to-Know Act, Section 304 release reporting requirements was also reviewed.
One of WREG’s Principals has developed considerable expertise in the air quality regulations affecting petroleum storage tanks at refineries and bulk terminals, including both internal and external floating roof tanks. Projects have included air quality permitting, compliance evaluations, inspections for compliance with New Source Performance Standards (NSPS) and Maximum Achievable Control Technology (MACT) requirements, recordkeeping and reporting, and control technology evaluations, including dispersion modeling.
WREG personnel provided air compliance, permitting, and training support to the Colorado Refining Company (CRC) from 1995 to 2005. Following the purchase of CRC’s Denver refinery by Suncor Energy (USA) Inc. in 2005, WREG has continued to provide support to the combined Suncor/CRC facility (known as the Commerce City Refinery). One of WREG’s Principals has provided continuous support to the refinery since 1997. Proposed changes are reviewed for air regulatory consequences. Emissions estimates and regulatory applicability reviews are performed, and, if necessary, permit applications are prepared and negotiated.
WREG’s Principals prepared the Title V operating permit application for CRC’s refinery and assisted with the negotiation of the permit terms and conditions. WREG has also prepared a number of construction permit applications and performed dispersion modeling as needed. Other tasks include conducting audits, researching regulatory issues, inspecting tanks for regulatory compliance, and developing environmental management procedures. Major regulatory programs addressed include leak detection and repair requirements, benzene waste monitoring and reporting, National Emission Standards for Hazardous Air Pollutants (NESHAP)/Maximum Achievable Control Technology (MACT) applicability, and New Source Performance Standard (NSPS) applicability, monitoring, recordkeeping, and reporting.
WREG prepared Startup, Shutdown, and Malfunction Plans (SSMPs) for several of the refinery’s units for compliance with MACT standards. Plans were prepared for storage vessels, loading racks (truck and railcar), and equipment leaks for compliance with 40 CFR 63, Subpart CC, and for the catalytic cracking unit, catalytic reforming unit, and sulfur recovery unit for compliance with 40 CFR 63, Subpart UUU.
WREG has also provided training to the refinery staff. Training topics have included refinery compliance goals and procedures, as well as monitoring, recordkeeping, and reporting requirements for storage vessels and wastewater systems. WREG also provided Best Available Retrofit Technology (BART) rulemaking support on behalf of the refinery.