Husky Public Hearing Tuesday August 27th, 12 Noon at the Douglas County Courthouse, Room 270.
Air Emissions PSD Permit Application, Prevention of Significant Deterioration
The DNR has already made a preliminary determination that this application is “approvable”. View here.
Twin Ports Action Alliance’s position is that the DNR does not approve the PSD permit without the conclusion that Hydrogen Fluoride must be discontinued at this site based upon the possibility of a catastrophic accidental release of Hydrogen Fluoride during the installation of the Rapid Acid Transfer System (RTS) or any other construction on site. While Husky has not requested to be authorized under the permit to emit any hydrogen fluoride to ambient air this does not leave out the possibility of an accidental release at this accident-prone facility.
“Detailed information: Superior Refining Company LLC, located at 2407 Stinson Ave., Superior, Douglas County, (FID 816009590), submitted to the Department of Natural Resources a permit application, including plans and specifications for a project to repair or replace damaged equipment at a petroleum refinery. The project includes the installation of two new process heaters, two new asphalt storage tanks and the modification of a number of existing refinery processes, including the fluid catalytic cracking unit, the vacuum unit, portions of the crude unit, the alkylation unit, a petroleum storage tank and cooling tower no. 1. The proposed project is being aggregated with the miscellaneous components project authorized under construction permit 16-RAB-199.”
How does this permit relate to Hydrogen Fluoride use at the Husky Refinery?
the dnr’s response below
"The PSD permit Husky has applied for is only tangentially related to hydrogen fluoride.
Sections 285.60 through 285.69 of the Wisconsin Statutes and chapters NR 405 through NR 409 of the Wisconsin Administrative Code require certain stationary sources of air contaminants to obtain an air pollution control permit. Husky’s refinery in Superior is classified as a major stationary source of air contaminants under the Prevention of Significant Deterioration (PSD) Program because it emits or has the potential to emit more than 100 tons per year of one or more air contaminants regulated under the PSD Program. Because Husky’s proposal to rebuild the damaged portions of its refinery constitutes a major modification of a major PSD source, Husky has submitted a PSD permit application.
Fluorides, including hydrogen fluorides, are regulated by the PSD program, but Husky has not requested to be authorized under the permit to emit any hydrogen fluoride to ambient air. As part of its application, Husky has proposed to install a Rapid Acid Transfer System (RTS) to support the refinery’s existing Alkylation Unit. The proposed RTS would include a vessel and conveyance piping to capture process acid in the event of an acid leak or other emergency. In addition to using the RTS vessel as an alternate storage location for process acid in the event of an emergency, Husky also wishes to have the ability to use it as an alternate storage location during facility shutdowns to support routine maintenance activities. During the course of regularly scheduled maintenance events, the new storage vessel, conveyance piping and connectors of the RTS have the potential to emit volatile organic compounds and ammonia and Husky requests in its application that DNR authorize VOC and ammonia emissions during such scheduled maintenance events.
The Air Program of the Department of Natural Resources does not make safety evaluations and will not review Husky’s proposed RTS as a safety measure for emergency storage of hydrofluoric acid. The air program does review air pollution control permit applications, and will review the proposed RTS as a potential source of VOC and ammonia emissions during regularly scheduled maintenance activities.” - The DNR”