WREG 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.
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 assisted the Colorado Air Pollution Control Division (APCD) in determining the effectiveness of Maximum Achievable Control Technology (MACT) standards in the state. WREG determined which facilities in Colorado were subject to promulgated MACT standards, then reviewed and tabulated possible emissions reductions resulting from MACT compliance. The agency planned to combine this information with the cost to the state in providing MACT assistance and determine the cost-effectiveness of the emission reductions achieved.
WREG assisted Aspen Publishers, Inc. in writing Guide to MACT Recordkeeping and Reporting. The book summarizes the recordkeeping and reporting requirements for Maximum Achievable Control Technology (MACT) standards, including General Provision requirements and those included by reference to other MACT standards, National Emission Standards for Hazardous Air Pollutants (NESHAP), or New Source Performance Standards (NSPS). The book provides a valuable tool to identify and comply with the complex recordkeeping and reporting requirements of the federal MACT standards.
WREG 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.
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.