Rule Engineering

  • Assessment & Remediation Projects

    • E&P Groundwater Remediation

      Project Location:

      Western Colorado

      Groundwater contamination due to migration from a natural gas well along natural fractures resulted in exceedances of benzene and methane in surface­ water and groundwater.  After several years of operating a sparge system with little progress, Rule was selected to provide remediation for the site.  Our evaluation concluded that the existing system was not effective and in fact due to the high groundwater flow rates in the aquifer, natural attenuation processes were adequate to control the plume migration.  The case for monitored natural attenuation supported by fate and transport modeling was presented to the COGCC and the proposal to shut off the system and reduce the monitoring program was approved.  Rule continues to monitor the groundwater with the data supporting our conclusions for natural attenuation and reduce the ongoing costs for our client.

      E&P Tank Closures

      Project Location:

      Northwestern Colorado

      Closures were completed on over 70 produced water holding tanks covering a large area in a remote part of northwestern Colorado.  The replacement of the existing culvert pit holding tanks was coordinated with the oil and gas operator to install above-ground tanks with minimal downtime.  The tanks and impacted soils above state cleanup levels were removed where practical under a group COGCC Form 27.  Clearance samples were collected from the excavation and impacted soil placed in a landfarm on each pad.  Landfarm soils were amended with nutrients and moisture, and mixed periodically.  After remediation, landfarm soils were used to fill the excavation and COGCC Form 4's were submitted for closure that included data collected from each pad. 

      UST Remediation AS/SVE System

      Project Location:

      Denver Metro Area, Colorado

      An air sparge/soil vapor extraction (AS/SVE) remediation system was designed based on pilot test data.  A total of 6 AS wells and 5 SVE wells were to remediate gasoline constituents in the groundwater by directly volatilizing the constituents and supplying oxygen for aerobic biodegradation.  The work included preparation of construction plans, specifications and bid documents, construction oversight and quality control, preparation of an APEN emissions notification, performance evaluation, and long-­term performance monitoring.

      UST Remediation LNAPL Multiphase System

      Project Location:

      Denver Metro Area, Colorado

      A multi­phase extraction system was designed to address an extensive LNAPL plume spanning multiple off-site properties to dewater the upper low-permeability zone and allow product recovery and vapor extraction in the sand units where the NAPL was trapped.  Based on extensive aquifer testing and site characterization, a system of six dual phase (liquid and vapor) wells were installed and piped to a treatment system with an oil/water separator for LNAPL removal and an air stripper for water treatment.  A waste water discharge permit with continuous remote monitoring was approved by the local POTW.  The system was effective in removing all mobile NAPL and reducing groundwater concentrations of petroleum hydrocarbons.

      Refinery Groundwater Containment System

      Project Location:

      Wyoming

      A containment system was designed under a Consent Order with the WDEQ to prevent off-site migration of contaminated groundwater and LNAPL.  An alternative evaluation design was used to select a soil bentonite slurry wall with a series of interceptor.  Data from a detailed subsurface investigation was used to design a 1,700-foot long by 25-foot deep slurry wall with 500 feet of interceptor trenches using biodegradable polymer construction techniques with consideration for pipelines and other utilities at an active refinery. The work included preparation of construction plans, construction oversight, performance evaluation, and long-term performance monitoring.  A groundwater treatment system was designed and an NPDES permit application was submitted and approved for treated water discharge to a creek.  The treatment system consisted of an oil/water separator and an air stripper with pretreatment to reduce maintenance due to fouling.  

      Refinery Groundwater Modeling

      Project Location:

      Wyoming

      A groundwater model was developed to address corrective actions under the WDEQ to provide an understanding of remedial alternatives to prevent off-site migration of contaminated groundwater and LNAPL.  A three-dimensional finite-difference groundwater model was used to assist with the design and placement of a groundwater interceptor trench.  The model utilized detailed subsurface characterization to simulate aquifer layers of various permeability to represent bedrock, sand/gravel and clay zones.  The model was also used to simulate existing pumping systems, planned and existing interceptor trenches, wastewater ponds, as well as, creeks.  Visual MODFLOW was used to generate the model, which works in conjunction with mapping programs to generate groundwater maps which can be incorporated into technical documents.

    Plans, Permits, Compliance Projects

    • Underground Injection Control Permit

      Project Location:

      Wyoming Refinery

      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

      Project Location:

      Colorado, Wyoming, Oklahoma and Texas Refineries

      Evaluated 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 upon facility practices.  SPCC plans were written to meet all new requirements while minimizing unnecessary paperwork and procedures.  CADD drawings were prepared or revised to support the projects.

      Refinery Oily Water Sewer Mapping

      Project Location:

      Texas Refinery

      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 drain systems were precisely located and placed into the refinery CADD system.  QQQ applicability was determined and a compliance plan was developed. 

      Facility Response and Integrated Contingency Plans

      Project Location:

      Wyoming and Texas Refineries

      Emergency 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.

      GHG Monitoring Plan and Emissions Inventory

      Project Location:

      Texas Refinery

      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 the Green House Gas Reporting Program (40 CFR Part 98).

      Flare Management Plan for NSPS Subpart Ja

      Project Location:

      Texas Refinery

      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 included devising the best compliance strategy, calculating a baseline flare flow rate, drafting the flare gas recovery system procedures and working with process control engineers to meet flare flow monitoring requirements.

      404 Permitting for Corrective Action Project

      Project Location:

      Wyoming Refinery

      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 of a Wetland Mitigation Plan.  Endangered and threatened species, and historic properties listed on the National Register of Historic Places were researched.   

      Air and Land Use Permitting

      Project Location:

      Colorado E&P Waste Management Facility

      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 impact analysis, and property owner notifications.  Analyzed potential air emissions using mass balance and modeling approaches, and prepared an air pollution emission notification.

    Safety Projects

    • Industrial Hygiene Services Investigating Air Quality

      Project Location:

      Colorado

      Provide industrial hygiene services to investigate indoor air quality (IAQ) issues and employee complaints regarding allergy type symptoms allegedly relating to the office environment and workspace.  Analysis and report reviewed water leaks, furniture construction, floor covering, paints, maintenance of HVAC, space remodeling and reconfiguration, employee reorganization, CO, CO2, mold spore potential and other issues that can influence eclectic symptoms.

      Safety and Industrial Hygiene Services

      Project Location:

      Colorado

      Provide safety and industrial hygiene services to a pilot plant that required a PPE assessment for unique exposures for the prototype processes to determine employee potential exposures.  A matrix had to be developed that would provide the documentation of the margins of safety through engineering controls, administrative controls and PPE that would be protective of employees completing their tasks. JHA’s of the tasks were completed and training on the results.  A specific PPE type and use matrix was completed for all involved employees for all tasks.

      Provide Management Training and Field Assessment

      Project Location:

      Colorado

      Provide management training/ consultation and field assessment, training and consultation for VPP candidates.  BCI (a local Colorado GC achieved site merit status for a Ft. Carson facility remodel that had special considerations for infection control, ventilation, hours of work, modification of work methods, means of egress, access (full medical, dental and PT facility for military families and wounded soldiers).

      Strategic Partnership for Insurance Broker

      Project Location:

      Colorado

      Provide Strategic partnership to an insurance Broker for specific clients including traditional loss control plus environmental consultation services for insured clients.

      Training for Colorado Contractors Association

      Project Location:

      Colorado

      Provide trainers and SME for Traffic Control Supervisor, Excavation & Trenching, Confined Space Entry and “Introduction to Supervision” training for the Colorado Contractors Association and members.

      Review and Rewrite Safety Programs

      Project Location:

      Colorado

      Review and rewrite a cogent safety policy statement and OSHA compliant safety program for an engineering firm that is transitioning from a specific trade engineering firm to a construction management firm.