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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!
thank you for publicizing the events concerning Hyperion Resources.
ReplyDelete1. Hyperion says in its application that since a refinery hasn't been built in 30 years this will be a "state of the art" refinery. Hyperion also says that they will use what is called BACT (best availabl) standards, which by the way, is the minimum level that EPA will allow. since they are going to be a "State of the Art" i would think they would want to set a standard for others to follow and use the best level of pollution control called LAER (Least Acceptable emissions release) which is an oxymoron because this standard is very strict on pollution control and is expensive. if someone is going to build an oil refinery in south dakota i think it is only right that since it is going to pollute the air that it be absolutely the best possible of standards that are used don't you? i have an old saying that if you but something cheap, you get something cheap.
Hyperion appears to argue that LAER, not BACT, is the proper standard to apply to the air pollution control requirements—see Enclosure B, pp. 1–2 (sorry, still PDF). Any engineers in the audience care to clarify?
ReplyDeleteBACT, best available control technoloty, is the standard established by the EPA. The individual states administer EPA regulations in their borders. EPA regulations are the minimum standards allowed. LAER, least acceptable emissions release, is a standard for the amount of regulated toxins released into the atmosphere. There is no standard for unregulated compounds released into the atmosphere. There is a great deal we don't know about the affect some compounds will have on our natural resources.
ReplyDeleteHyperion is going to challenge the DENR whenever their approach will cost money over and above what Hyperion's engineers feel is fiscally responsible. DENR is charged with protection of our natural resources and elimination and avoidance of pollution. Hyperion is a for profit industry. Look at the incentives and who signs the respective paychecks.
The larger questions for the residents of Eastern South Dakota are; do we want a large industrial facility in our back yard and who is paying for this?
JNNelsen
The question, "who is paying for this?" is an excellent one.
ReplyDeleteConsidering Hyperion expected Clay Rural Water Systems (a community-owned corporation) to pay for all necessary infrastructure to deliver water to them, and then they'd pay for the water itself, we may not be able to afford to bring this supposed economic development goldmine into the area.