Air Quality Compliance and Permitting
StanTech conducted a comprehensive review and assessment of refinery operations for compliance with EPA’s Mandatory Reporting Rule (MRR) for Greenhouse Gases. Tasks completed included: (1) a summary of monitoring, reporting, and recordkeeping requirements applicable to refinery processes/emission sources; (2) development of an action plan to identify modifications needed to current operations to achieve compliance with the MRR; and (3) preparation of the GHG Monitoring Plan for the facility.
Air Quality Consulting and Permitting Services
StanTech prepared construction air permit applications for the integration of two refineries located in the United States. The refineries were previously owned by separate companies, and were purchased by a single company. The state agency determined that the combined refineries were to become a single refinery. This action was considered a change in method of operation, thus requiring PSD applicability review. In addition, for PSD review, the state agency required that future, proposed projects be aggregated with the integration process. The approach required consideration of future emissions increases for all process units at both refineries. StanTech developed a permitting approach to avoid triggering the PSD permitting process. This approach substantially accelerated completion of the integration process, and avoided potential hurdles from PSD permitting.
Air Emissions Inventory Services
StanTech conducted a comprehensive review of facility air emissions inventory spreadsheets/calculations, and provided technical assistance with updates and modifications to the facility emissions inventory data management system. Emissions calculations spreadsheets were populated with current air emission inventory data for entry into the ODEQ Redbud System within the regulatory timeframe specified in State air pollution control regulations. Redbud is a comprehensive web-based application for reporting Annual Air Emissions Inventories from point sources at regulated facilities.
Air Permitting Services
Natural Gas Compressor Stations
StanTech conducted air emissions calculations, conducted regulatory applicability determinations, and prepared Air Quality Synthetic Minor Source Construction Permit Applications for natural gas compressor stations located in Oklahoma. The purpose of the applications was to obtain authorization to construct and operate additional proposed emission sources at the facilities.
Leak Detection and Repair (LDAR) Support Services
StanTech conducted numerous tasks associated with the refinery Leak Detection and Repair (LDAR) program. StanTech updated over 600 Process & Instrument Diagrams (P&IDs) and utilized AutoCAD LT® to highlight each identified product stream. Additionally, StanTech provided field support services and conducted fugitive emissions monitoring for LDAR compliance. During the project, StanTech calibrated and operated analyzers used to measure organic vapor leaks; conducted quality assurance/quality control review on calibration drifts and monitoring data collected; performed visual inspections of equipment monitored; conducted routine Method 21 monitoring of regulated constituents; and performed and documented necessary repairs in the field.
Emission Reduction Supplemental Environmental Project (SEP)
StanTech prepared a detailed Statement of Work (SOW) for a Truck and Vehicle Emission Reduction Supplemental Environmental Project (SEP) for a petroleum products refinery. The project involved the retrofitting of high-emitting, in-service, heavy-duty diesel vehicles owned and operated by a municipality with diesel particulate filters designed to reduce particulate emissions by up to 90%. StanTech conducted necessary research pertaining to EPA-approved control technologies and SEP policies, and performed calculations to quantify emissions reductions. The SEP Work Plan was accepted with no modifications by the regulatory authorities.
Emission Inventory Submittals
Natural Gas Transmission and Processing Facilities
StanTech was hired by the client to enter emission inventory data for 200 facilities into the Oklahoma Department of Environmental Quality (ODEQ) Redbud System within the regulatory timeframe.
StanTech provided air quality compliance support services for a CEPOL (Converting Environmental Permits into Operating Limits) project at an Oklahoma refinery. The project involved the conversion of 44 separate air permits for aboveground storage tanks (ASTs) at the refinery. StanTech created a master CEPOL tanks table utilizing Excel® software. The project involved the assimilation of specific tank information such as tank identifications, tank dimensions, tank capacities and contents, and tank dike capacities; review of all existing permits; entry of data into the master table; validation and documentation of data for a “4-tank trial”; validation of existing regulatory applicability determinations; and identification of data gaps.
Air Quality and Regulatory Applicability Determinations
StanTech has conducted numerous air quality determinations for soil vapor extraction (SVE) remediation systems at petroleum storage tank (PST) release and refinery sites in order to assess the need for air permitting. This task requires collection of air samples, measurement of flow rates, and calculation of air emissions. Additionally, applicability determinations have been conducted for an LNAPL product recovery trench remediation system potentially subject to Subpart GGGGG of 40 CFR Part 63.
Toxic Release Inventory (TRI)
Petroleum Products Refinery
StanTech was hired to complete a comprehensive review of TRI calculation workbooks for a major products refiner located in Oklahoma. Tasks included verification of emission data and creation of a comprehensive, user-friendly interface to ensure accurate reporting of TRI chemicals to the EPA.
Air Emissions Inventory & Toxic Release Inventory (TRI)
StanTech completed AEI calculations and submissions for two manufacturing facilities located in Oklahoma. Tasks included creation of calculation spreadsheets, QA/QC of facility-provided data, and submission of results within the regulatory timeframe using ODEQ’s Redbud system. Additionally, StanTech completed TRI calculations and submissions for the two facilities. Tasks included creation of calculation spreadsheets, QA/QC of facility data, and submission of results using EPA’s TRI-ME web system.
StanTech is providing on-site assistance for populating and integrating a new Environmental Management System (ACTS) for an independent oil and gas exploration and production company in Oklahoma. Tasks include populating the EMS with facility-specific data for over 100 facilities in five states and verifying proper data input through a rigorous QAQC process. The EMS will eventually be used for emission calculations, regulatory reporting, task generation based on regulatory requirements, and as a repository for all historical site information.
Semi-Annual and Annual Title V Compliance Reporting and Certification
Brick Manufacturing Facility
StanTech conducted Semi-Annual Compliance Reporting and Annual Title V certifications for a brick manufacturing facility in Oklahoma. Tasks included gathering and collating supporting documentation to provide ODEQ with proof of compliance.
Emission Calculation Spreadsheet
Brick Manufacturing Facility
StanTech created an emission calculation spreadsheet for a brick manufacturing company in Oklahoma. This spreadsheet was created in order to allow the facility manager to monitor emissions throughout the year and determine production rates based on permitting limits. Production data were entered into a table (based on monthly totals) and multiplied by an emission factor to obtain emission rates. These emission rates were then compared to permitted limits and signified as ‘pass/fail’ on a monthly basis.
Air Permitting Services
Natural Gas Compressor Sites
StanTech conducted air emissions calculations, emissions inventory preparation, regulatory applicability determinations, environmental management system maintenance and quality control, and prepared Air Quality Operating permit and permit renewal applications for natural gas compressor stations located in Oklahoma. The scope included Synthetic Minor, Construction, Modifications, and Title V permits.
|Oklahoma City – Corporate Office
4300 N. Lincoln Blvd.
Oklahoma City, Oklahoma 73105-5106
FAX (405) 424-8129