A refinery client asked WREG to identify all discharges from the refinery’s sulfur recovery complex. For each unit in the sulfur recovery complex, WREG prepared a process unit block diagram and a discharge matrix. The process block diagram displayed the process and each emission or waste stream released into the environment from the process. The matrix for each unit contained a description of each air, water, and waste released during normal operation; periods of startup, shutdown and malfunction; and during anticipated maintenance activities.
WREG revised and updated the startup, shutdown, and malfunction plans (SSMPs) for the Maximum Achievable Control Technology (MACT)-regulated units at two refineries. Both refineries contain units that are subject to the refinery MACT standards in 40 CFR 63, Subparts CC and UUU. Development of the plans required determining the process units subject to MACT emission limits, followed by identification of startup, shutdown, or malfunction situations that could cause the emission limit to be exceeded. Procedures for responding to events that can cause the emission limit to be exceeded were refined or developed for inclusion in the plans. The plans also contain procedures for addressing emission control and monitoring system malfunctions.
In conjunction with a law firm, WREG reviewed Fluid Catalytic Cracking Unit (FCCU) changes planned for a rapidly approaching refinery turnaround and assisted the client in obtaining a determination from the State of Oklahoma that the changes qualified as routine maintenance, repair, and replacement. The client had previously submitted materials and a permitting applicability analysis associated with the planned changes to the state. Based on that information, the state determined that the project constituted a major modification subject to Prevention of Significant Deterioration (PSD) review. If a PSD permit had been required, the changes could not have been made as scheduled. WREG reviewed the project and determined that the changes would qualify as routine maintenance, repair, and replacement. A new permitting applicability analysis was prepared and presented to the state. The state agreed with WREG’s interpretation and determined that PSD review was unnecessary.
WREG reviewed and updated modeling analyses for a regional petroleum refinery as part of an effort to finalize construction permits for refinery modifications. Since the initial modeling was performed, the refinery had discovered a number of inconsistencies in permit information and also needed to revise certain permit limits. WREG obtained the earlier modeling files, reviewed them against current refinery information, and, where necessary, calculated revised emissions. Refinery emissions were modeled and compared to state and federal limits, then documented in a report to be submitted with revised permit applications. Additional work for this refinery has included a review of stack test data and comparison with US Environmental Protection Agency (EPA) standard methods for measuring particulate matter and fine particulate matter (PM10), as well as a siting study for PM10 monitors.
WREG assisted a refinery client in Wyoming in preparing two construction permit applications. One was focused on expansion of the crude unit and included a detailed netting analysis to avoid major modification requirements for nitrogen oxides (NOx). The second application involved modification of the coker unit. Wyoming Best Available Control Technology (BACT) analyses were prepared for particulate matter (PM10), sulfur dioxide (SO2), NOx, carbon monoxide (CO), and volatile organic compounds (VOCs) for the sulfur incinerator, heaters, and compressor engines.
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 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 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.