Wind River Environmental Group LLC

Tag Archives: Best Available Retrofit Technology (BART) Support

Platte River Power Authority Voluntary Emissions Reduction Agreement

Platte River Power Authority Voluntary Emissions Reduction Agreement

Platte River Power Authority Voluntary Emissions Reduction AgreementThe Colorado regulations allow a source to enter into Voluntary Emissions Reduction Agreements (VERAs) with the Colorado Air Pollution Control Division (APCD). A VERA provides the source with a regulatory assurance period during which the state cannot require installation of additional pollution control equipment or implementation of additional pollution control strategies. Platte River reduced nitrogen oxides (NOx) and sulfur dioxide (SO2) emissions from the coal-fired steam generating unit at the Rawhide Energy Station. To obtain a regulatory assurance period associated with the coal-fired unit’s emission controls, Platte River chose to enter into a VERA. WREG provided technical support to Platte River during the VERA development and negotiations. This support included review of VERA calculations and language, and research into Best Available Retrofit Technology (BART) and Best Available Control Technology (BACT) determinations for coal-fired steam generating units.

Because the project resulted in increases in carbon monoxide (CO) emissions, WREG also assisted Platte River in preparing a construction permit application for the associated emissions increase.

Pharmaceuticals Air Quality Support

Pharmaceuticals Air Quality Support

Pharmaceuticals Air Quality SupportWREG has provided air quality permitting and compliance support to a pharmaceutical plant in Boulder, Colorado. Projects have included determining permitting options for a new pharmaceutical process unit, preparing air quality requirements training for plant staff, assisting the company with the preparation of comments on the Colorado Best Available Retrofit Technology (BART) rulemaking process, and ongoing general support, including Maximum Achievable Control Technology (MACT) requirements for pharmaceuticals production. An operating permit application was also prepared to add a process to the facility. The application included performing a site-wide emission netting analysis to demonstrate that the project was minor, identification of applicable requirements and compliance methods, and the development of draft permit conditions.

Colorado Refining Company/Suncor Energy (USA) Inc.

Colorado Refining Company/Suncor Energy (USA) Inc.

Colorado Refining Company/Suncor Energy (USA) Inc.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.