- Superior Rebuild Project Permitting
Our team prepared a prevention of significant deterioration (PSD) permit application to authorize emissions from the Superior Refining Company Rebuild Project. The goal was to repair damage from a significant refinery incident and implement process improvements where appropriate. We prepared a complete PSD permit application, participated in agency negotiations and provided additional technical assistance to the process and legal teams on an as-needed basis.
- Permit strategy development
- Permit application development
- BACT assessment
- Air dispersion modeling
- Permit negotiation
- Legal support
- Insurance recovery support
Permit strategy development — Our team worked closely with client environmental and legal staff to develop a permitting strategy appropriate to this unique, event-driven project. Permit strategy development included multiple meetings and calls with the Wisconsin Department of Natural Resources, the U.S. Environmental Protection Agency (USEPA), the Wisconsin Department of Justice, and the U.S. Department of Justice. Due to the aggressive project schedule the strategy development and initial permit application were required before completion of all damage assessments, necessitating a flexible permitting strategy that would accommodate multiple damage assessment outcomes. The final permit strategy supplemented legal and enforcement proceedings while supporting an aggressive project construction schedule and allowing for potential changes to scope as damage assessments were completed.
Engineering project integration — Our environmental professionals integrated into the project design team led by a separate engineering firm 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. This integration also allowed process information to be immediately identified and incorporated into the permitting process as it was developed and allowed certain key scope elements, such as vendor emission guarantees, to be accelerated relative to the typical phased project schedule. This integration allowed the project design team to optimize the overall project scope and schedule while also improving the permit application timeline.
Air dispersion modeling — We performed air dispersion modeling for all criteria pollutants following 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 — Our team 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. Where the engineering design firm had resource limitations due to the aggressive project schedule, we provided supplemental engineering resources to perform engineering assessments and control cost estimates.
Agency negotiation — We 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.
Legal and insurance support — The team provided air quality permitting and compliance experts to support the complex legal efforts associated with the impacts of the refinery incident. In addition, these technical specialists assisted with insurance recovery negotiations associated with the incident and associated business interruptions.