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.
At the request of the Colorado Air Pollution Control Division (APCD), WREG prepared an air quality guidance document for use by the oil and natural gas industry in Colorado. The guidance document contains descriptions of industry equipment, emission calculation methods, applicable requirements determination worksheets, compliance requirements lists, and discussions of US Environmental Protection Agency (EPA) and APCD policies that affect the industry. Glycol dehydrators, storage tanks, engines, turbines, miscellaneous combustion sources, truck loading, flares and incinerators, sulfur recovery units, fugitive volatile organic compound sources, miscellaneous sources, and non-emitting equipment are addressed. Requirements from the New Source Performance Standards (NSPS), National Emission Standards for Hazardous Air Pollutants (NESHAP), New Source Review (NSR), and state regulations are included. APCD also had WREG present a training workshop for state employees and industry representatives on using the guidance document.
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 prepared quality assurance (QA) plans for the continuous emission monitors (CEMs) at a refinery. Plans were prepared for sulfur dioxide (SO2), nitrogen oxides (NOx), carbon monoxide (CO), hydrogen sulfide (H2S), oxygen (O2), and opacity monitors. The plans were prepared to comply with the New Source Performance Standard (NSPS) requirements outlined in 40 CFR 60, Appendix F, Procedure 1: Quality Assurance Requirements for Gas Continuous Emission Monitoring Systems Used for Compliance Determination. The plans also address requirements found in the Performance Specifications of 40 CFR 60, Appendix B. The plans contain a description of the monitoring system; calibration procedures; accuracy audits; preventive maintenance; corrective actions; and data recording, reporting, and recordkeeping.
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.