Wind River Environmental Group LLC

Tag Archives: Compliance Assistance

Tri-State Generation and Transmission Support

Tri-State Generation and Transmission Support

Tri-State Generation and Transmission SupportWREG has provided support to Tri-State Generation and Transmission for a number of facilities in the western United States. Projects have included:

  • An operating permit renewal application for the Rifle Generating Station, a combustion turbine station. WREG also assisted Tri-State in verifying that emission units located at the same site but under the control of another company should not be considered part of the source covered by the operating permit and the emission units should be removed from the operating permit.
  • Prepared an operating permit renewal application for the Nucla Generating Station, a coal-fired, atmospheric circulating fluidized-bed combustor producing 100 megawatts of electricity on Colorado’s Western Slope. WREG updated applicable requirements, reviewed operating parameters used to prepare the initial application, prepared Compliance Assurance Monitoring (CAM) plans, and prepared the permit application package.
  • Prepared a construction/ operating permit application for modification of a combustion turbine facility to allow for additional annual operating hours.

Since 2007, one of WREG’s Principals has provided ongoing support to Tri-State for multiple projects in a staff augmentation role. Tasks have included emission estimation, regulatory analysis, dispersion modeling, and compliance assistance.

Oil and Natural Gas Exploration and Production Air Quality Support

Oil and Natural Gas Exploration and Production Air Quality Support

Oil and Natural Gas Exploration and Production Air Quality SupportWREG has provided day-to-day permitting and compliance support for a global oil and gas firm for several years. Activities have included preparation of permit applications, notifications, compliance reports/spreadsheets, emission estimates/inventories, Colorado Air Pollutant Emission Notices (APENs), compliance audits/assessments, sampling, and database development. Dispersion modeling has been performed for permitting of facilities in Texas, Wyoming, and Colorado. Additional projects include preparing a response to comprehensive data requests from the Central Region Air Planning Association (CENRAP), the Western Regional Air Partnership, and the Wyoming Department of Environmental Quality; investigation of glycol dehydrator area source Maximum Achievable Control Technology (MACT) notification requirements for multiple states; investigation of methods for estimating methanol emissions from evaporation ponds; and control device performance tracking and analysis.

Maximum Achievable Control Technology Hammer Support

Maximum Achievable Control Technology Hammer Support

Maximum Achievable Control Technology Effectiveness StudyWREG assisted the Colorado Air Pollution Control Division (APCD) with facility notifications prompted by the Clean Air Act’s “MACT Hammer” rule. The rule requires state agencies to determine and apply Maximum Achievable Control Technology (MACT) standards to major sources in source categories where the US Environmental Protection Agency (EPA) has missed the rule promulgation deadline by 18 months. Major sources potentially subject to these not-yet-promulgated MACT rules were required to submit a Part I operating permit application (essentially a notification) to APCD by May 15, 2002. While there was no penalty for sources that applied but were later found not to be subject to a rule, there was a potential penalty associated with not submitting a timely application. WREG worked with APCD to develop a letter and reply form to notify affected sources of this requirement. WREG then tracked responses, followed up with non-responders, and provided assistance to individual companies in determining their applicability.

Malt Beverages

Malt Beverages

Malt BeveragesWREG’s Principals have provided air quality assistance to a major malt beverage manufacturer since the early 1990s. With facilities around the country, including major facilities in Colorado, projects have included:

  • Construction permit for a modification of brewlines and associated equipment. The permit contained facility-wide rather than emission unit-specific emission limits, complicating permitting applicability determinations. WREG prepared the application including preparation of Reasonably Available Control Technology (RACT) analyses for volatile organic compounds (VOCs) and fine particulate matter (PM10).
  • Major modification permit application for packaging reconfiguration. Application included a Best Available Control Technology (BACT) analysis for VOC emissions.
  • Minor modification permit application for replacing biobeds used for odor and VOC emission control from a sludge processing plant with a wet scrubber.
  • Update of BACT analysis for a brewery in Virginia. Analysis focused on nitrogen oxide (NOx) emissions from boilers and VOC emissions from brewing and packaging operations.
  • Prepared Superfund Amendments and Reauthorization Act (SARA) 313 reports for multiple facilities.
  • Provide on-site environmental services support including updating emergency response plans, assisting with chemical inventories, analyzing and reviewing data for chemical tracking, preparing SARA 312 reports, and Materials Safety Data Sheet tracking.
  • Prepared a permit application to expand a barley processing facility in Montana. Project included emission calculations, regulatory analysis, and debottlenecking evaluation.
  • Emission factor determination and comparison across multiple facilities in different states. Emission factors that might constrain future permitting actions were identified and alternate emission factors determined where possible.
  • Stationary internal combustion engine regulations were reviewed and flowcharts and requirements lists developed for Maximum Achievable Control Technology (MACT) standards at 40 CFR 63, Subpart ZZZZ and related New Source Performance Standards (NSPS), 40 CFR 60, Subparts IIII and JJJJ.
Fiberglass Light Pole Manufacturing

Fiberglass Light Pole Manufacturing

Fiberglass Light Pole ManufacturingWREG has helped a decorative light pole manufacturer with permitting and with Maximum Achievable Control Technology (MACT) compliance. The plant produces and paints fiberglass light poles. The operations are subject to two MACT standards: 40 CFR 63, Subpart PPPP—National Emission Standards for Hazardous Air Pollutants for Surface Coating of Plastic Parts and Products, and 40 CFR 63, Subpart WWWW—National Emission Standards for Hazardous Air Pollutants: Reinforced Plastic Composites Production.

WREG has prepared tools to help the company determine and track compliance with operating permit and MACT conditions. WREG has also assisted with preparation of a permit modification application to add base mold manufacturing operations to the facility and with preparation of an application to renew the facility’s operating permit. WREG also prepared documentation needed to relocate the plant to a new site in Colorado.

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.