Thursday, April 24, 2014

Fwd: NWCAA news: Shell air permit might not do what you think it does

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From: "Northwest Clean Air Agency" <>
Date: Apr 24, 2014 3:51 PM
Subject: NWCAA news: Shell air permit might not do what you think it does
To: <>

April 30 public hearing not about trains, doesn't increase emissions
April 30 public hearing not about trains, doesn't increase emissions
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Shell refinery air permit might not do what you think it does

Northwest Clean Air Agency public hearing April 30, 2014

The Northwest Clean Air Agency has received about 25 requests for a public hearing since opening the public comment period Feb. 18, 2014, for the Shell Puget Sound Refinery draft air operating permit renewal.
It would have been unprecedented if NWCAA received just one public hearing request.
Many requesting a hearing have expressed concerns about issues outside the scope of the draft air operating permit, and outside NWCAA's jurisdiction, making it clear that the agency should do what it can to help people understand what an air operating permit is, and how public comments can help improve it.
"Considering recent events in the news, we understand why people are sensitive and looking for ways to improve rail and refinery safety," said NWCAA Executive Director Mark Asmundson. "But we want to be straightforward about what our agency and this permit can and can't do, and try to adjust expectations before the hearing."

Top concerns

Public hearing requests for the Shell draft air operating permit renewal have mainly focused on two issues:
  • Delivery of crude oil by rail: The draft air operating permit doesn't address new train projects. Air operating permits don't approve new construction. Shell has applied for different permits from NWCAA for two projects to deliver oil to the refinery by rail that the agency will announce for public comment soon. For those permits, the agency will be looking at emissions from unloading railcars to the refinery, and effects these projects might have on emissions within the existing refinery units. As an air agency that regulates only stationary sources of air pollution, NWCAA has no authority to permit emissions from trains in transit. Skagit County processes development permit applications and is the State Environmental Policy Act lead for the proposed rail projects.
  • Increased refinery emissions: The air operating permit won't allow the Shell refinery to increase its emissions, and it won't require the refinery to decrease emissions. NWCAA does consider increased emissions through different permits that have their own public notification and commenting requirements. The requirements of those other permits are incorporated into air operating permits.

Bringing requirements into one place

The largest air pollution sources, based on their maximum possible air emissions, are required, by law, to have air operating permits.The purpose of an air operating permit is to compile existing regulations into one comprehensive document. They pull together operational and procedural air quality requirements – including monitoring and reporting, emissions standards, and other regulatory requirements.
"These comprehensive documents help the facilities comply with air quality requirements, and help us enforce them," Asmundson said.

How the public can help

The most useful comments will point out if NWCAA missed something or if people disagree with the agency's interpretation of the requirements. Some examples include comments that point out if the agency misapplied or left out a requirement, if the requirements are too vague, or if the monitoring and reporting requirements are inadequate.
"All this attention is a good thing," Asmundson said. "It's an opportunity for us to help people understand what these particular permits do, and for people to help us craft the best possible permit."

Public hearing and comment on Shell Puget Sound Refinery air operating permit

Public hearing – NWCAA will open the public hearing with a short presentation before taking comments for the record. 
10 a.m., April 30, 2014
NWCAA office
1600 South Second St., Mount Vernon

Public comments – NWCAA will accept comments until the close of the public hearing.Prior to the hearing, send comments to:
M.J. "Lyn" Tober, P.E.
Northwest Clean Air Agency
Mount Vernon, WA 98273
Questions: Contact Lyn Tober at 360-428-1617 or

More information


Katie Skipper, Northwest Clean Air Agency Communications Director, office: 360-428-1617 ext. 235, mobile: 360-319-0739,
Mark Asmundson, Northwest Clean Air Agency Executive Director, 360-428-1617 ext. 208
Jeff Gabert, Shell Puget Sound Refinery Communications and Social Performance Manager, 360-293-1552,

The Northwest Clean Air Agency is responsible for enforcing federal, state and local air quality regulations in Island, Skagit and Whatcom counties. In addition to permitting and regulating industrial sources of air pollution, the agency offers services that deal with asbestos, business assistance, climate change, indoor air quality, outdoor burning, woodstoves and fireplaces. More information about the agency is available at

1600 South Second Street | Mount Vernon, WA 98273-5202

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