You can read the full rebuttal in project manager Colin Campbell's October 27, 2008, letter [PDF alert!] to DENR's Brian Gustafson on the DENR website. Two arguments stand out:
- Hyperion says their proposed emissions control technology, internal floating roofs, is more cost-effective in allowing more flexible refinery operations.
- Hyperion says internal foating roofs are a better solution because they have no moving parts and consume no energy, while the oxidizers use energy and emit more pollutants due to combustion (see Enclosure B, page 3).
Hyperion is also resisting some stringent water quality requirements. DENR wants Hyperion to collect and test hourly wastewater samples for benzene concentration. Hyperion finds that requirement "excessive and unwarranted" and argues in favor of monthly water samples, in accordance with federal regulations (see Enclosure A, page 1, item 8).
Hyperion also points out a number of "errors" in the DENR's math... significantly more of which show DENR calculating emissions limits that are lower that what Hyperion says the formulas should produce. Interesting: I hope we can get some good independent checking of everybody's math!