West Texas Gas, Inc. – Air Quality Permitting and Compliance Support
RPS provides ongoing state and federal NSR permitting, Title V permitting, and compliance support at more than 50 sites (compressor stations and natural gas processing plants) owned and/or operated by West Texas Gas and its subsidiaries in Texas, New Mexico, Colorado, Oklahoma, and Kansas. Compliance support projects have included preparing routine regulatory reports (e.g., emission inventories, emission event notifications, and Title V deviation reports), internal compliance audits, negotiating with regulatory agencies regarding alleged compliance issues, representation during regulatory inspections, and implementation of an environmental management system. Other worked performed for this client has included assistance in the preparation of SPCC plans and representing the client in negotiations with Region 6 Environmental Protection Agency regarding the closing of waste management units.
Motiva Enterprises
RPS served as the primary air quality consultant in the effort to secure authorization for a 325,000 barrel-per-day expansion of the Port Arthur Refinery in Port Arthur, Texas. This expansion is the largest refinery construction project in the United States since the 1970’s. RPS prepared the state and federal air quality permit applications, consulted with refinery staff on pollution control technologies, and provided the technical expertise for negotiations with the U.S. Environmental Protection Agency (EPA), the Texas Commission on Environmental Quality (TCEQ), and community activist groups.
Valero Energy Corporation – Refinery MACT Audits
RPS completed MACT Subpart CC compliance audits at eleven refineries in the United States to satisfy the requirements of a consent decree issued as part of EPA’s Refinery Enforcement Initiative. The scope of the audit included the following types of emissions units subject to MACT CC:
Miscellaneous Process Vents (MPVs)
Storage Vessels
Equipment Leaks
Gasoline Loading Racks
Marine Vessel Loading Operations
In addition, the requirements of 40 CFR Part 63 Subpart A pertaining to control devices (40 CFR §63.11) and startup, shutdown, and malfunction plans (40 CFR §63.6(e) (3)) were reviewed to the extent that these requirements applied to these emission units.