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 has provided support to Tri-State Generation and Transmission for a number of facilities in the western United States. Projects have included:
- An operating permit renewal application for the Rifle Generating Station, a combustion turbine station. WREG also assisted Tri-State in verifying that emission units located at the same site but under the control of another company should not be considered part of the source covered by the operating permit and the emission units should be removed from the operating permit.
- Prepared an operating permit renewal application for the Nucla Generating Station, a coal-fired, atmospheric circulating fluidized-bed combustor producing 100 megawatts of electricity on Colorado’s Western Slope. WREG updated applicable requirements, reviewed operating parameters used to prepare the initial application, prepared Compliance Assurance Monitoring (CAM) plans, and prepared the permit application package.
- Prepared a construction/ operating permit application for modification of a combustion turbine facility to allow for additional annual operating hours.
Since 2007, one of WREG’s Principals has provided ongoing support to Tri-State for multiple projects in a staff augmentation role. Tasks have included emission estimation, regulatory analysis, dispersion modeling, and compliance assistance.
In the summer of 2001, Platte River Power Authority placed 31 leased, trailer-mounted, diesel-fired power modules at the Rawhide Energy Station in northern Larimer County, Colorado. WREG prepared permit applications and assisted with permit negotiations.
The power modules had a potential to increase emissions from the Rawhide Energy Station by significant amounts, were temporary, and met the definition of non-road engines. These facts made determining the proper permit required by the Colorado regulations difficult. WREG assisted Platte River in obtaining a determination from the Colorado Air Pollution Control Division (APCD) that Prevention of Significant Deterioration (PSD) permits were not necessary. Platte River agreed to conduct analyses not normally necessary for minor source permits. WREG prepared the permit applications, including conducting dispersion modeling and preparing Best Available Control Technology (BACT) analyses for nitrogen oxides (NOx) at the agency’s request. WREG also assisted with permit condition negotiation and submission of compliance plans.
WREG personnel provided Kaiser-Hill Company and the US Department of Energy (DOE) air compliance, monitoring, and research support for the Rocky Flats Environmental Technology Site (RFETS) from 1996-2006. One of WREG’s Principals managed the air quality management organization at RFETS from 1996 to 2000 and continued to support Kaiser-Hill and DOE as the air quality Subject Matter Expert for the site, pending completion of regulatory closure requirements, including Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) requirements.
RFETS was a nuclear weapons production facility established in the early 1950s. The site was decommissioned and cleaned up, with physical completion declared in October 2005. Air compliance issues were challenging, given that the facility and its operations were constantly changing. Support activities included project-by-project regulatory review, emission estimation, compliance auditing, and permit application preparation and negotiation. The site was also subject to the radionuclide National Emission Standards for Hazardous Air Pollutants (NESHAP). Dispersion modeling analyses performed by WREG personnel aided in planning appropriate control measures for remediation and decommissioning projects.
Air monitoring included the acquisition of meteorological data from an on-site tower, continuous ambient monitoring at nearly 40 locations for radioparticulates, and effluent (in-stack) monitoring for particulate and gaseous radionuclides. Monitoring results were analyzed and reported to both regulatory agencies and the general public.
WREG team members also worked with RFETS personnel to research the movement of radionuclide contamination through the air pathway during a five-year actinide migration study. WREG personnel have co-authored several papers based on this research.
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 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’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 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.