WREG provided long-term permitting and compliance assistance to a nationwide oil and natural gas midstream company. Permitting and compliance activities included Title V permits, New Source Review (NSR) permits, standard permits and Permits by Rule, emission inventory submittals, screening modeling, and emission estimates for facilities in multiple states, primarily Texas and New Mexico. WREG also assisted the company with compliance data management for air quality and water.
WREG prepared the air quality portions of an International Environmental Best Management Practices Guide for a global oil and gas firm with facilities worldwide. Guidance covered such topics as pollutants and sources, emission calculation methodologies, dispersion modeling and acceptable impacts, control technology review, mitigation measures, monitoring and testing, etc. World Bank/International Finance Corporation Environmental, Health, and Safety Guidelines were incorporated where available. The guidance addressed power generation, heaters and boilers, combustion turbines, glycol dehydrators, reciprocating internal combustion engines, emergency equipment, flaring and venting, fugitive organics, fugitive dust, storage tanks, tank vessel loading, sulfur recovery, amine units, ozone-depleting substances, greenhouse gases, well drilling and testing, mobile sources, etc.
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 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.
WREG provided support to the Colorado Petroleum Association (CPA) during the Denver Early Action Compact (EAC) development and modeling process in 2003. The EAC allowed the Denver area to postpone designation as a nonattainment area with respect to 8-hour ozone standards by reducing emissions and demonstrating attainment on an accelerated schedule. WREG personnel represented CPA on the Modeling Review Panel that was convened by the Regional Air Quality Council to oversee the photochemical modeling demonstrations that were a required portion of the EAC process.
Following the northern Front Range’s designation as nonattainment with the 8-hour ozone standard, WREG assisted oil & gas and downstream petroleum industry clients in the stakeholder process that resulted in an Ozone Action Plan in 2008-2009. WREG personnel attended stakeholder meetings and prepared briefings for clients, helped clients prepare comments, and provided testimony at the December 2008 Colorado Air Quality Control Commission hearings regarding new regulations that were part of the Ozone Action Plan.
WREG prepared dispersion modeling analyses using AERMOD for a proposed onshore natural gas processing facility in Israel for a global oil and gas company. Two locations and several equipment configurations were modeled. Sources evaluated included compressors, emergency equipment such as fire water pumps and emergency generators, and hot oil heaters. The modeling results were compared to the Israel Abatement of Nuisance Regulations.
WREG provided dispersion modeling analyses for permitting an amine plant in northwestern New Mexico. The location of the plant, at the bottom of a canyon, made permitting difficult and required the use of innovative modeling techniques to demonstrate compliance with all standard and increment limitations.
WREG assisted the owner with permitting the original plant, which included three compressor engines, an amine unit, and other facilities, and also assisted in a modification to add three additional compressor engines. WREG also assisted the company with preparation of an operating permit application for the facility.
WREG also prepared dispersion modeling analyses and other portions of a construction permit application for a compressor station a few miles from the original amine plant facility.
WREG performed dispersion modeling in support of permit applications for compressor stations and gas plants in southern Wyoming for an oil and natural gas company. Projects included developing model inputs, analyzing results, and preparing reports for submission to the Wyoming Department of Environmental Quality.