IOWA ACTION: Help protect air quality in northwest Iowa

This comes from Bleeding Heartland:

An oil refinery proposed for a South Dakota site near Sioux City poses a threat to air quality in northwest Iowa, I recently learned from Dr. Jim Redmond, chair of the Sierra Club's Northwest Iowa Group. The Hyperion Energy Center would be the sixth-largest oil refinery in the country. It would emit large quantities of several pollutants, including particulate matter 2.5, which is hazardous to human health.

The South Dakota Department of Natural Resources (DENR) and the South Dakota Board of Minerals and Environment have issued a preconstruction air permit to the Hyperion Energy Center. Unfortunately, the permit omits relevant information. For instance, instead of using five years of data on ambient air conditions in Sioux Falls and Sioux City, only one year of information for Sioux Falls was used. The environmental impact on Sioux City (25 miles downwind from the proposed facility) will certainly be greater than on Sioux Falls (50 miles upwind).

The Environmental Protection Agency (EPA) criticized the draft air permit for the Hyperion project, but South Dakota's DENR did not incorporate their suggestions.

Because the Hyperion project will adversely affect air quality in and around Sioux City, Iowans should contact the EPA administrator in Region 7 (containing Iowa). South Dakota lies in the EPA's Region 8...

If you're concerned about the Hyperion oil refinery, you can help by sending a short letter to the federal Environmental Protection Agency (EPA) asking that they intervene in the air quality permit process.

Please ask the EPA to overturn the South Dakota Department of Natural Resources (DENR) and the South Dakota Board of Minerals and Environment decision to issue a preconstruction air permit to the Hyperion Energy Center (HEC). Also, ask EPA to require an Environmental Impact Statement (EIS) be assembled for the Hyperion project.

Despite EPA's detailed criticisms of the Hyperion's draft Prevention of Significant Deterioration (PSD) Air Permit, the DENR issued the flawed permit. Few changes were made. The South Dakota Board of Minerals and Environment approved the permit unanimously with little discussion even though numerous flaws and omissions were obvious.

Your letter need not be more than 3-4 paragraphs long. Please sign and make sure your name and address is included. If possible, please save a copy of your letter and send it by email to Jim Redmond at Jim.Redmond@briarcliff.edu

Your letters should be written to the following:
Callie A. Videtich, Director
Air and Radiation Program
US RPA Region 8-80C-EISC
1595 Wynkoop Street
Denver, Colorado 80202-1129
Duplicates should be sent to
Lisa Jackson, Administrator
US Environmental Protection Agency
Ariel Rios Building
1200 Pennsylvania Avenue, N.W.
Washington, DC 20460

Some info on the proposed refinery:

Remember that this proposed refinery will release 19 million tons of carbon dioxide a year along with many tons of carcinogens. Read the synopsis and pick out one or several points and contact EPA, asking that they intervene based on your concerns.

1. There are many omissions and deficiencies in the permit relative to the Best Available Control Technologies (BACT). BACT is mandated by the U.S. Clean Air Act. To determine a BACT a permit must show that a specific technology is selected after considering the types and sources of emission, regional environmental impact, and cost. Hyperions's refinery will be a polluting source that falls under the EPA standard for New Source Review guidelines. The EPA was very critical of the BACT analyses in Hyperion's draft air permit and few changes were made by the DENR.

2. Hyperion did not demonstrate compliance with National Ambient Air Quality Standards (NAAQS). NAAQS requires the EPA to set standards for six criteria air contaminants: ozone, carbon monoxide, sulfur dioxide, nitrogen oxides, lead and particulate matter. There are two classes of particulate matter. PM10 are coarse particles 10 micrometers to 2.5 in diameter. PM2.5 are fine particles and are 2.5 or less. Huge polluting sources must have background analyses of the NAAQS to make certain the new source will not exceed quantities obviously detrimental to health. New source quantities + background = projected post construction quantities.

Strangely, the background data used was from Sioux Falls, more than 50 miles to the north, rather than Sioux City, about 25 miles away. Sioux City has much higher background levels of PM2.5 than Sioux Falls. Had Sioux City been used the background added to the new emission source would almost certainly have exceeded the NAAQS for 24 hour emissions.

Sioux City also shares the same wind patterns as the Hyperion Energy Center. In the winter both have a predominant prevailing wind out of the northwest and in the summer the predominant wind is from the southeast. Both the seasonal wind directions and velocities are somewhat different in Sioux Falls. For both the Hyperion Energy Center and Sioux City the Missouri River valley channels the wind.

While Hyperion recommended using Sioux City ambient data in its modeling protocol, the DENR wanted Sioux Falls. Although both cities had five years of data, the DENR selected only one of the lower years for Sioux Falls rather than averaging for five years.

Five years of data should have been used for both cities, or very good explanations for ignoring both the location and the power of averaging should have been provided. It was not.

3. Key elements required of a Prevention of Significant Deterioration (PSD) were not presented in the permit. There was no plan for dust suppression during construction. There was no flare minimization plan, no Startup, Shutdown and Malfunction plan. The public did not see a BACT analysis for CO2 in time to comment on it, even though this refinery will emit more CO2 per refined barrel than any existing refinery in the United States. Methane and other greenhouse gas emissions were not quantified in the permit.

4. The Board should have required an Environmental Impact Study before issuing a preconstruction air permit. This would be the largest and most polluting single industrial unit ever constructed in South Dakota. Citizens in the region should have a comprehensive view of the impact on health and the environment prior to the DENR issuing a preconstruction permit based only on air emissions. The Hyperion plant will use at least 10 million gallons of water each day, and it will be pumped from a shoreline aquifer along the Missouri River, north of Sioux City. That water will be returned to the river in an unknown condition.

Among the many environmental effects not analyzed are the social and economic impacts of the 4,500 construction workers housed in a temporary work camp. There will be noise and odors that will be detected but not disclosed prior to their arrival.
The regional impact of construction activities and operation are unknown to the public. Local government can't plan for law enforcement, energy, sewage, and traffic and health issues when there is no impact analysis.

Protect Iowa's air quality. Write a letter now.