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.
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 conducted air quality feasibility/siting studies for a new 1,000 megawatt power plant in Arizona. Nine candidate sites were systematically evaluated based on conceptual project plans. WREG identified and ranked air quality issues associated with each site.
WREG evaluated the risks and potential consequences of two permitting options for a partially constructed facility in Virginia, whose operating permit was about to expire: 1) continue construction and maintain the existing permit, or 2) allow the construction authorization to lapse and apply for a new construction permit at a later date. WREG reviewed permitting issues encountered by recent permit applicants in the area, investigated control technology requirements that had been instituted since the existing permit was issued, predicted impacts of future regulatory changes on each option, and developed potential construction permitting strategies that could be employed if the construction permit was not maintained.
WREG researched the status of integrated gasification combined cycle (IGCC) technology for a client in the Rocky Mountain region. We evaluated gasification technologies, gas composition, emissions, emission controls and control opportunities (mercury and carbon dioxide [CO2]), air permits issued to IGCC projects, other environmental considerations, capital costs, operating and maintenance costs, status of US Department of Energy (DOE) research, and availability of DOE funding. The client will use the information developed in evaluating future resource options. WREG also prepared feasibility studies, including emission calculation, extensive dispersion modeling, and Best Available Control Technology (BACT) research, for an IGCC plant considered for a site in southeastern Arizona.
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.