- Superior Flexibility Project Permitting
Our team prepared two Prevention of Significant Deterioration (PSD) permit applications to support the Superior Flexibility Project. The goal was to improve process feed flexibility and overall operating flexibility at the Superior Refinery. We prepared two complete PSD permit applications, participated in agency negotiations and provided additional technical assistance to the process team on an as-needed basis.
- Permit strategy development
- Permit application development
- BACT assessment
- Air dispersion modeling
- Permit negotiation
Permit strategy development — We worked closely with client environmental staff to develop a complex and flexible air permitting strategy. The project engineering scope was significantly revised multiple times during the permit application development and review process, resulting in multiple options for inclusion in the permit. The project schedule and scope required creative approaches, including splitting the project into multiple aggregated PSD permits, implementing flexible “test-and-set” emission limits, authorizing new flexible process operations, and authorizing a range of crude slates and unit operations that included import of process intermediates.
Engineering project integration — Our environmental professionals integrated into the project design team to improve overall project scope and schedule. This integration allowed environmental cost and schedule impacts of proposed project scope changes to be immediately identified and understood during the scoping phase of the project. In addition, this integration allowed process information to be immediately identified and incorporated into the permitting process as it was developed. This integration allowed the project design team to quickly assess and, where appropriate, implement a wide range of design options as part of overall project scope and cost optimization.
Air dispersion modeling — Our team performed air dispersion modeling for all criteria pollutants following U.S. Environmental Protection Agency (USEPA) and state guidelines. We also performed a complete assessment of multiple pollutants subject to the state hazardous air pollutants program, including air dispersion modeling where required.
Top-down BACT assessment — We performed top-down best available control technology (BACT) assessments involving dozens of potential control technologies applicable to multiple new and modified emission sources. These assessments included detailed technology reviews for technical feasibility, order of magnitude cost evaluations for economic feasibility assessments, and evaluation of existing emission sources to determine hydraulic and pressure-related limitations of potential closed-vent system designs.
Agency negotiation — The team participated in weekly agency technical discussions to support the ongoing technical and administrative permit application review process. These discussions addressed all elements of the review process, including regulatory applicability, emission estimating, air dispersion modeling, identification of modified sources, control technology review, public notice, public comment, and program applicability. Both state and federal agencies were represented weekly, including multiple levels of agency management.
Project aggregation — The scope and nature of the project combined with state and federal guidance resulted in a complex assessment of project aggregation with multiple prior projects. Project aggregation resulted in retrospective top-down BACT assessments for multiple sources, including a fluid catalytic cracker unit.
Test-and-set limits — Certain emission sources at the facility were subject to new BACT limits for criteria pollutants without a monitoring history or applicable vendor guarantees. To obtain the most reasonable emission limit while meeting program requirements, we assisted in negotiating test-and-set emission limits that provided for compliance flexibility while applicable emission rate data was obtained.