Rule’s technical staff has experience preparing plans applications for new permits and permit modifications, and conducting compliance audits and implementation projects for:
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 applicability with the requirements of the regulation and outlines a compliance strategy, and…
Prepare a 404 permit application to reroute an intermittent stream that was in the location of a proposed corrective measure. The permit consists of a Pre-Construction Notification and includes wetland delineation, identification of an area for wetland mitigation and preparation…
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…
Obtained an Underground Injection Control (UIC), Class V, Beneficial Use Permit to support bio-augmentation using periodic microbe batch injections.
Spill Prevention Control and Countermeasure Plans
Colorado, Wyoming, Oklahoma and Texas Refineries
See MoreEvaluated each facility for applicability and performed a gap analysis on existing plans. Used site-specific observations, measurements, maps and other documentation to address SPCC requirements. Planning distances were calculated and documented. Inspection forms, procedures and response plans were prepared based…
Rule worked with refinery Engineering, Operations, Maintenance and Environmental Departments to create a comprehensive set of underground oily water sewer maps. Flow tests using dye and volume were extensively used to document connections. Dry weather flow contributors were identified. Individual…
Facility Response and Integrated Contingency Plans
Wyoming and Texas Refineries
See MoreEmergency 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.
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…
