Suncor Title V Air Permit Renewal Comments to Colorado Department of Public Health
Our TCHD Air Quality experts collaborated with the Denver Department of Health and Environment (DDPHE), the City of Commerce City, and Adams County in June to submit recommendations to the Colorado Department of Public Health and Environment (CDPHE) aimed at reducing polluting emissions from the Suncor refinery. Each organization submitted comments prior to the hearing with the Air Quality Control Commission.
Summary of Recommendations
To protect the health of our community, and within the authority of the Colorado Title V Program, we recommend that CDPHE:
- Require Suncor to develop a compliance plan and schedule of specific actions to bring the refinery into compliance with current air quality regulations. (Authority: AQCC 5 CCR 1001-5 (Regulation 3), Part C, III.C.8 and III.C.9)
- Require Suncor to quantify pollution from excess emissions and make the reports and data easily accessible to the public on the APCD’s website, including mass emissions calculated in pounds per hour, 12 month rolling totals of annual excess emissions to date, and explanation of why a past corrective action failed
- Require a stronger source-specific, root cause investigation reporting requirement as part of the operating permit to determine the root causes of emission exceedances from four sources: two fluid catalyst cracking units and two sulfur recovery units.
- Require fenceline air quality monitoring in the communities surrounding the refinery, specifically for carbon monoxide (CO), hydrogen sulfide (H2S), sulfur dioxide (SO2), nitrous oxides (NOx), and particulate matter (PM2.5 and PM10).
- Conduct emissions modeling specific to the entire Suncor complex. Dispersion modeling that estimates pollutant impacts outside of the refinery’s fenceline to ensure the National Ambient Air Quality Standards are met.
- Combine Suncor’s two operating permits into one to cover the entire complex to apply consistent requirements on similar types of equipment between Plant 2 and Plants 1 and 3.
We further recommend that future rulemakings, CDPHE compliance settlements, or other actions by CDPHE include:
- Developing additional regulatory measures that require the refinery to undergo more extensive evaluation(s) and set lower thresholds to trigger tighter emission controls when minor modifications are made to the facility.
- Pursuing increased emission controls on flaring, specifically with higher required destruction efficiencies and implementation of flaring minimization plans.
- Leading a stakeholder group to provide a set of policy recommendations for future refinery-specific air quality rulemakings, including a rulemaking to consider adding refinery-specific requirements to Colorado Air Quality Regulations.
- Strengthen requirements for facilities that have multiple nuisance violations or confirmed complaints, especially with odor.
- Conducting a refinery assessment of a broader range of air toxics, including a health risk analysis in the communities living near the refinery, and revise the regulated list of hazardous air pollutants in Colorado Air Quality Regulation 3, as necessary.
Make Your Voice Heard
Comments from the community are a powerful way for policy-makers to understand your perspective and concerns. You can get involved by:
- Submitting written comments prior to the Air Quality Control Commission’s monthly meetings on July 15 and August 18. Email comments to firstname.lastname@example.org. You can also review comments made so far.
- Providing oral comments at the Air Quality Control Commission’s monthly meetings. Advanced registration.
- Writing your state representative and state senator asking that they submit comments as well.