Client: Frontier El Dorado Refining Company
Location: El Dorado, Kansas
Project Overview: Trihydro has been assisting Frontier El Dorado Refining Company (FEDRC) with air compliance issues since the refinery was owned by Texaco in the early 1990s. Trihydro completed the initial applicability determinations, compliance strategies, and waste stream inventories for BWON, HON, NSPS Subpart QQQ, and refinery MACT at the time these regulations became final and published in the Federal Register.

Trihydro conducted the original BWON compliance survey of the refinery in 1992. As part of this service, we compiled the original waste stream inventory, conducted extensive Method 25D sampling, suggested control and compliance strategies, and compiled an appropriate waste stream exemption list. Trihydro continues to support FEDRC on BWON compliance issues by routine Method 25D sampling, control device monitoring, waste treatment monitoring, routine reporting, and consulting on compliance strategies. Trihydro also developed for FEDRC a BWON database that is used to track benzene waste on a monthly basis. Trihydro also assisted FEDRC with HON compliance at the time the rule became final. Our services have included:

• Identification and sampling of process waste streams per Method 25D
• Identification and sampling of process vents in chemical processing units for applicability determinations
• Calculation of total resource effectiveness (TRE) values for process vents
• Evaluation of HON applicability for storage tanks, individual drain systems, transfer racks, and control devices
• Evaluation of leak detection and repair (LDAR) provisions, and assisting the plant with an LDAR implementation program
• Development of sampling procedures and locations for cooling water
• Completion of an exhaustive heat exchanger review and inventory for HON applicability
• Development of Startup, Shutdown, and Malfunction Plans for control devices regulated by the HON
• Identification of equipment and development of procedures for routine inspections
• Drafting of the Notification of Compliance Status Report
• Production of semi-annual HON compliance reports

Client:ConocoPhillips
Location: Ponca City, Oklahoma
Project Overview: Trihydro completed a comprehensive review of the facility's Benzene Waste Operations NESHAP (BWON) program. The review included field inspections, field interviews, and Method 25D sampling.

Trihydro spent several weeks inspecting plant operations, interviewing engineering and operations personnel, and reviewing records related to benzene waste operations. Trihydro compiled a comprehensive benzene-containing waste stream inventory, revised the facility's total annual benzene (TAB) report, and compiled an exemption list as appropriate.

Trihydro continues to support the Ponca City facility with Consent Decree-required compliance issues. We have a full-time environmental technician based at the refinery assisting in the management of compliance activities. Trihydro also assists ConocoPhillips with recordkeeping and reporting issues.