Prepared a FMP to comply with the final Standards of Performance for Petroleum Refineries (NSPS Subpart Ja). The plan provides the specifications of the flare system, documents the applicable regulatory requirements, and outlines a compliance strategy.
Category: Plans, Permits, Compliance Projects
404 Permitting for Corrective Action Project
Rule prepared a 404 permit application to reroute an intermittent stream that was in the location of a proposed corrective measure. The permit consisted of a Pre-Construction Notification, wetland delineation, identification of an area for wetland mitigation, and a Wetland Mitigation Plan.
Air and Land Use Permitting
Prepared state and county major impact land use permit applications for a centralized E&P waste management facility, including: facility operations and contingency plans, storm water management, hydrology, geologic hazards, a sensitive area analysis with wildlife impact/habitat BMPs, land suitability and impact analysis, and property owner notifications
Underground Injection Control Permit
Rule obtained an Underground Injection Control (UIC), Class V, Beneficial Use Permit for a refinery to support bio-augmentation using periodic microbe batch injections.
Spill Prevention Control and Countermeasure Plans
Rule evaluated several refineries for applicable SPCC regulations and performed a gap analysis on existing plans. Site-specific observations, measurements, maps and other documentation were used to address SPCC requirements.
Refinery Oily Water Sewer Mapping
Rule worked with refinery Engineering, Operations, Maintenance and Environmental Departments to create a comprehensive set of underground oily water sewer maps.
Facility Response and Integrated Contingency Plans
Emergency response plans were written to address specific regulatory requirements under 40 CFR §112.20. Care was taken to use facility practices and procedures where possible; recommendations for satisfying data gaps were made and follow-up work completed.
GHG Monitoring Plan and Emissions Inventory
Rule gathered data from existing refinery fuel gas flow meters and CO2 CEMS, set up a calibration schedule, drafted a Green House Gas (GHG) Monitoring Plan and prepared and submitted the annual emissions inventory. The work was completed in compliance with the Green House Gas Reporting Program (40 CFR Part 98).
