Letter: A Prevention of Significant Deterioration review should be required

By Laura Grzanic
Feb 13, 2018

With Meridian Energy Group — Davis Refinery, applying for a synthetic minor source air quality permit, there is a concern that a Prevention of Significant Deterioration review will not be done. A PSD review is under the Clean Air Act and protects areas from an increase of emissions due to degrading industrial equipment. It’s meant to protect public health and welfare, preserve, protect and enhance the air quality in national parks and other areas. It is to ensure that economic growth will occur in a manner consistent with the preservation of existing clean air resources. I suggested during the recent public comment period for the Davis Refinery air quality permit, that the emission calculations should be for the lifetime of the refinery, with accurate emission projections for the entire facility. A PSD review applies to new, large facilities or major changes that could increase air pollution in an area. The Davis Refinery — Meridian Energy Group would fall under this category. Peak emission amounts from startup, shutdown, malfunctions, repairs, and upsets are unknown. Hazardous Air Pollutants were not included in the emission testing at startup. The impact of cancer-causing pollutants were not addressed in the emissions.

The language of the permit has no enforcement capability. The words “expected to be” are written for the limitations of emissions. The margin of error is enormous. In my submission to the Air Quality Division during the public comment session, I suggested a closer review and independent analysis be done before construction. Thoughtful consideration should be taken to make this a major source permit with a PSD review, not a synthetic minor source air quality permit, that falls below the threshold of regulation — once again.

Grzanic is a member of the Dakota Resource Council living in Belfield, N.D.


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