Prevention of Significant Deterioration (PSD) , Permitting of Major Refinery Expansion Projects (An Important Case Study)

Williams Refining, LLC (Williams) operates an integrated petroleum refinery in Memphis, Tennessee. In the fall of 1997, Williams began the process of new source review (NSR) permitting under the Clean Air Act (CAA) Prevention of Significant Deterioration (PSD) regulations. The focus of the permitting was on two major expansion projects: 1) Expansion of the east and west crude units 2) Installation of a new continuous catalytic reforming (CCR) unit and upgrades to the fluid catalytic cracking unit (FCCU), Naphtha HDS, Alkylation, and Distillate HDS units When complete, these projects will expand the refining capacity by more than 30%. A detailed review of these expansion projects was presented in the March 22, 1999, edition of the Oil & Gas Journal. This paper focuses on the PSD permitting of the projects described in the Oil & Gas Journal article. The PSD permitting process involves the development of a comprehensive permit application (including a dispersion modeling analysis and a control device review), presentation of the application and the associated analyses to the local environmental permitting agency, development and negotiation of permit conditions, public notice, and final permit approval. The entire PSD permitting process can require two years (or more) to complete unless a systematic permit strategy is employed to streamline the process. This paper describes the process employed by Williams to obtain PSD permit approval in less than one year and in less than 5 months from initial application submittal. The resulting permit contains permit conditions that protect the local environment, allow for operational flexibility, and set the stage for future expansion at the refinery. The specific details addressed in this technical paper include: 1) The collaboration process employed by the Williams permitting team (composed of refinery management, process engineers, environmental staff, environmental consultants, and outside legal counsel). 2) The communication links created between the permitting team and the local permitting agency. 3) The development of the environmental and regulatory assessments (including the control device and ambient impact assessments), and the methods used to communicate these to the local permitting agency. 4) The application follow-up and permit issuance process.

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