When a thick layer of bad air hangs over the Salt Lake Valley, much of the talk is either about the amount of mobile pollution (traffic) or large point sources such Kennecott Utah Copper. But it’s also important to recognize the impacts that oil refineries have on our airshed as well.
The Holly Refinery, immediately north of Salt Lake City and part of the refinery complex often referred to as Refinery Row, is one of two refineries that are in the permitting process to significantly expand their operations. (Tesoro is the other.)
Both refinery expansions — and talk of future expansion by others — are largely based on new found markets for huge amounts of black wax crude that will be extracted from the Uintah Basin in future years. This is mostly coming from one company: Newfield Exploration Company.
Because black wax crude has the consistency of wax, it cannot be piped to the refineries for processing. It has to be trucked. But, before it can be trucked, it needs to be heated so the material becomes liquid. Then, it must be transported in heated trucks. According to inside sources, the distance from the oil fields in northeastern Utah to the refineries is such that the drivers have little time to spare before arriving at Refinery Row. If too much time has lapsed, the waxy crude sets up, resulting in the refineries having to heat up the trucks, a costly process for both time and money. (More information is availalbe in this April 2012 Salt Lake Tribune article.)
According to the permit before the Utah Division of Air Quality, Holly is expecting to increase their processing of black wax crude from 27,000 barrels per day to roughly 65,000 barrels per day. (A barrel is roughly 42 U.S. gallons). They plan to accomodate this expansion by first purchasing an old refinery in Bloomington, New Mexico, dismantling and shipping it to Utah, and reassembling it into a working refinery.
In other words, Holly is building another refinery here in the Salt Lake Valley, and this will cause their emissions to increase dramatically. Unfortunately, that is not what Holly is claiming in their permit application. In fact, they are claiming their emissions will actually go down, something that UDAQ engineers are so far willing to believe.
Holly is making this claim by basically gaming the system, subtracting emission levels from their projected post-expansion emissions. The subtracted amounts come from actual emission reductions that Holly achieved by order of the Environmental Protection Agency as part of a 2008 Consent Decree, after they were found to be violating their permitted emission levels. The Consent Decree ordered them to install new pollution reduction equipment to get them back down to permitted levels, and the agreement gave them until December 31, 2012 to comply, which they apparently did.
The Consent Decree also mandated that Holly could not use those emission reductions as credits to be applied towards any future project (a common practice in the industry). But that is exactly what Holly is currently doing as part of their permit application for expansion.
The other harmful component to this equation is related to truck traffic coming into the Salt Lake valley from the Uintah Basin. If Holly is permitted to expand, it is expected that the amount of truck traffic coming into the valley every day from the Uintah Basin will approach roughly 375 tanker trucks. That means Highway 40 through Heber City, I-80 through Park City and down Parleys Canyon, and along I-15 north. That is roughly one truck every four minutes, every day, 24 hours a day, 365 days a year.
Reports by the Associated Press, confirmed by internal EPA memos, indicate that because of thousands of leaky valves, — which release fugitive, unmitigated emissions — the average refinery in the United States is responsible for pollution between 3 and 100 times greater than what is officially reported. The problem was also laid out in a 1999 Congressional Report presented by Representative Henry Waxman (D-CA). There is little, if any, doubt that this is also true of the refineries in North Salt Lake. This means that refineries actually contribute much more to the air pollution along the Wasatch Front than is reflected in their permit or acknowledged by state agencies. This also means that expansion of those refineries is a very serious issue.
It is important to consider these issues in the context of voluntary plans to address air quality, such as ‘Clear the Air Challenge’ or Governor Gary Herbert’s “UCAIR.” These programs are more about individuals taking voluntary actions such as driving less. Yes, cars and consumers are also a significant part of our air quality problem. But absent from any air quality talk from the Governor’s office is any mention of refinery expansions and the related mobile source increases that will come with it. Anyone who thinks this is only coincidence should think again. Take a look at what industries contribute the most to the Governor's election campaign. Adding insult to injury, the Governor’s voluntary air quality initiative has a page dedicated to Holly Refinery’s propaganda.
Working with the Utah Physicians of a Healthy Environment and others, the Utah Chapter Sierra Club has submitted comments to the DAQ regarding Holly’s expansion permit.