In 2009, the U.S. Environmental Protection Agency enacted a rule requiring the mandatory reporting of greenhouse gases (GHGs) from significant emissions sources across the nation. Facilities emitting 25,000 metric tons or more of carbon dioxide equivalent (CO2e) annually must comply with the comprehensive reporting framework outlined in 40 CFR Part 98 Subpart W, referred to as the Greenhouse Gas Reporting Program. The program is intended to provide a detailed and accurate portrayal of emissions from key market sectors and guide development of policies and initiatives to curb GHG emissions.

Compliance with Subpart W is intricate and rigorous, particularly for energy companies like Summit Midstream Corporation, which must meticulously report emissions from its extensive network of petroleum and natural-gas gathering and boosting basins, as well as natural-gas processing plants. Summit relies on Barr’s comprehensive emissions-reporting services to simplify compliance and help ensure timely and accurate reporting. 

Our assistance incorporates cutting-edge tools and expert analysis to address every aspect of the program, from data collection to final submittals, including:

Adding to the challenge of complying with Subpart W is the EPA’s annual March 31 reporting deadline, which requires a swift and precise reporting effort for the previous year’s emissions data. Because Barr has in-depth familiarity with both the regulatory framework and Summit’s data, however, we can help the company effectively mitigate deadline pressure and help ensure a seamless submittal process.

Since 2023, Barr Engineering Co. has been providing engineering and environmental services to Nevada Gold Mines (NGM). 

NGM hired Barr to study air emissions from three facilities: the roaster at the Gold Quarry mine and the roaster and autoclave at the Goldstrike mine. The company wanted to understand whether increasing throughput at the three facilities would jeopardize compliance with the limits specified in their air permits. The goal of the study was to determine how expanded operations might affect compliance with air emission limits at facilities that use performance testing or continuous emission-monitoring systems (CEMS) to measure emissions. 

Barr took a five-step approach to completing the evaluation: 

  1. Summarized baseline emissions from five years’ worth of performance-test data and CEMS data, where applicable.
     
  2. Created a preliminary estimate of future emissions by employing descriptive statistics and projected future operating rates.
     
  3. Assessed the risk of emissions exceeding permit limits at each source to determine where additional analysis was warranted.
     
  4. To recommend the most promising strategies for lowering the risk of exceedances, developed multiple linear-regression models for further studying the impact of future operating rates on emissions; better assessing the compliance risk for emission sources flagged in step 3; and evaluating the degree to which modifying processes might maintain or reduce emissions. 
     
  5. Identify potential actions such as combustion tuning, process optimization, process modifications, and emissions testing campaigns that could minimize the potential for exceeding permitted emission limits.

At a facility in Iowa, a release of denatured ethanol occurred during material transfer in the tank farm. The farm is underlain by a liner, but soils above the liner were impacted by the release. Barr was providing on-site environmental management assistance when the release occurred, and we were asked to evaluate the release.

Our investigation did not identify impacts to soil or groundwater outside of the secondary containment; however, review of facility drawings identified the presence of drain tile in the secondary containment area, which could provide a groundwater-flow pathway. Subsequent soil sampling of the drain-tile-discharge ditch showed no soil impacts in the ditch, and surface water was not present.

Barr’s on-site presence, familiarity with the facility and operations, and experience with petroleum investigation and remediation allowed for an efficient, thorough evaluation of site conditions. These factors contributed to a rapid resolution with no facility downtime.

After a fire at a large industrial facility, Barr was hired to provide emergency response services and longer-term environmental monitoring activities. One of the primary concerns was addressing contamination of per- and polyfluoroalkyl substances (PFAS), contained in fire-fighting foams, in stormwater and fire-water ponds. We also provided general environmental compliance support during site cleanup and reconstruction activities.

Barr conducted sampling and observation activities associated with PFAS-impacted water and potential stormwater runoff, collecting samples in accordance with industry best practices to prevent cross-contamination. We also inspected off-site surface-water bodies, from stream banks and by boat, for evidence of fire-related contamination.

In addition, Barr worked with our client and the state environmental agency to determine treatment objectives and permit a system for removing PFAS compounds from water before it was discharged. We assisted with the design, permitting, and installation of a system that used granular activated carbon and ion exchange to remove PFAS. Once the system was operational, we conducted routine treatment-system sampling activities and tracked operational effectiveness. Finally, we helped identify regulatory requirements triggered by the event; prepared incident follow-up reports; assisted with waste management and disposal; and provided contractor oversight.

 

(Photo above is a stock image) 

A chemical-processing facility in Washington hired Barr to provide a third-party applicability and compliance review of the Resource Conservation and Recovery Act (RCRA) following an inspection by the regulating agency. The facility uses flammable liquids as solvents in their synthesis process and produces hazardous waste consisting of those solvents. Barr completed an independent review of the requirements focused on Subparts J, AA, BB, and CC, which encompass the hazardous waste tanks and piping systems. Barr then supported negotiations with the regulatory agency to resolve the alleged violations.

As part of this work, Barr supported the specification, procurement, and mechanical and structural design for the installation of closure devices for sump and hazardous waste tank systems. The scope of work also consisted of completing necessary inspections as well as developing hazardous waste tank system certifications and applications for flammable and combustible liquids stationary tank and piping permits for the modifications to the tank systems. Barr also scoped the leak detection and repair (LDAR) program requirements under Subpart BB for implementation by the facility and a local contractor.

The modified hazardous waste tank system was certified following installation of the closure devices. As a result, the facility was able to resolve the alleged violations and continue operations.

Since 2006, Barr has provided a range of environmental services at a confidential manufacturing client’s Upper Midwest facility and in support of corporate environmental initiatives. At the client’s facility, Barr has helped develop a long-term remediation plan to voluntarily clean up historical contamination.  

Due to unique site challenges, including contamination in fine-grained soils beneath the active facility, Barr evaluated alternatives for innovative remedial solutions. Remedy design is underway with implementation to follow shortly thereafter.  

In addition to the remediation, Barr has completed groundwater monitoring and reporting, groundwater modeling services, geotechnical work, NPDES permitting assistance, liability estimating, vapor-intrusion evaluation, and water treatment system upgrades. Barr has also provided environmental permitting and compliance support, including NPDES permitting, wastewater treatment system design, and PFAS evaluations.

Storms in July 2018 flooded a refinery’s combination unit, oil-water separator, roadside drainage ditches, and the laydown yard where a new processing unit was being constructed on a tight schedule.

In the combo unit, up to 8 inches of standing water posed operational safety concerns, and standing water in ditches caused condensation inside steam pipes, resulting in pressure drops that reduced process efficiency. The refinery asked Barr to develop emergency flood-mitigation measures to divert standing water from the combo unit and laydown yard until we could design a permanent stormwater-management solution. 

Within a week of receiving notice to proceed, we had made multiple visits to the refinery; designed two temporary lift stations and associated outlet works; developed an O&M plan for ditches; and secured a commitment from a vendor to deliver and install pumps and fittings that met our specifications.

Having dozens of qualified engineers allowed Barr to provide immediate assistance, and their expertise enabled the fast-track design of a reliable solution despite dual constraints: the site’s limited stormwater-conveyance capacity and the client’s special request for electric rather than diesel-powered pumps. 

Barr is currently leading the design of a permanent stormwater-management solution, which comprises the combination of a lift station, open-channel flow, and additional stormwater storage. The project is still in the feasibility phase; construction is expected to begin in mid-2024.

The emerging contaminants 1,4-dioxane and perfluoroalkyl substances (PFAS) were recently discovered in the groundwater at two of the Minnesota Pollution Control Agency’s closed landfills, the East Bethel and WDE landfills. Existing remediation systems have been in operation for many years to address volatile organic compounds in groundwater at these two landfills. Based on updated groundwater regulatory guidance for these emerging compounds, it was determined that the existing remediation systems have not fully captured the larger plumes associated with 1,4-dioxane and PFAS. The MPCA hired Barr to help understand the extent of the contamination by developing updated conceptual models for the two sites.

Barr conducted groundwater modeling and planned additional site investigation with the MPCA to create an updated conceptual model of the plumes. Based on this information, we expanded the groundwater monitoring network and identified potential remediation approaches and alternate treatment technologies to address the plumes and the emerging regulatory guidance for 1,4-dioxane and PFAS.

Barr has completed two projects for the Prairie Island Tribe related to access to the tribe’s reservation and casino, located near Red Wing, Minnesota, on an island between the Vermillion and Mississippi Rivers. The island has a single highway access.  Barr’s first project consisted of designing and coordinating the emergency raising of the access road to the island during the June 1993 Mississippi River floods. We designed an innovative method of raising the road without widening, which would have required permits to fill in the adjacent wetlands. Concrete road barriers were used to contain road fill and to provide erosion protection above the raised portion of the roadway. The temporary road raise was constructed in less than a week and removed after the threat of flooding ended. The entire project cost less than the revenues the tribe would have lost in a single day had floods washed out the highway.  Barr’s second project for the tribe involved preparing conceptual designs for a second road access to the Prairie Island during floods and other transportation emergencies. We pre-pared a joint permit application that included supplemental information for both a U.S. Army Corps of Engineers Section 404 permit to place fill in waters, and a Minnesota Department of Natural Resources permit to work in protected waters. Barr staff also assisted the tribe in presenting the proposed project to local, regional, state, and federal agencies. 

Barr assisted the Ramsey-Washington Metro Watershed District with reducing flood risk in the Snail Lake and Grass Lake areas. We evaluated ways to lower flood levels in the area’s water bodies, reduce the risk of flooding to habitable structures, and lessen the impacts to surrounding properties. Specifically, we studied possible changes to overflow and outlet elevations of water bodies in the system, pipe changes to modify discharge rates and volumes, and the possibility of lowering the existing 15-inch reinforced-concrete pipe under Highway 694.

To evaluate the risks involved in undertaking the recommended actions, Barr surveyed low points of concern not covered by recent previous surveys. We used monitoring data that the district had collected for the area and expanded an existing XP-SWMM model. In addition, the Metropolitan Council’s groundwater flow model of the Twin Cities was employed to create a more localized, detailed version for use in evaluating options.

The outcomes of this study are updated flood levels of Snail and Grass lakes for potential management and regulatory use by the district and the implementation of flood management features that optimize flood storage while protecting habitable structures. In addition, modeling results were shared regularly with the district’s member cities to help them in their own flood-management and communication efforts in the area.