WREG prepared a construction permit application for Public Service Company of Colorado for installation of a large natural-gas fired boiler at the State Steam Plant in Denver. Project included calculating emissions, determining applicable requirements, and demonstrating compliance with all permitting requirements including volatile organic compound (VOC) Reasonably Available Control Technology (RACT) requirements.
WREG’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.
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.
WREG has assisted a Colorado bottle manufacturing facility with several permitting actions, including:
- Minor modification permit application and self-certification package for a furnace rebuild, including Reasonably Available Control Technology (RACT) analyses for volatile organic compounds (VOCs) and fine particulate matter (PM10).
- Operating permit renewal application and Compliance Assurance Monitoring (CAM) plans. Requirements added from recent construction permits, parts washing tank requirements added, emission unit removed, insignificant activities updated, and CAM plan prepared for materials storage silos.
- Quality Assurance Plan for continuous emission monitoring system, including nitrogen oxides (NOx), sulfur dioxide (SO2), and oxygen (O2) monitors.