BLEST was recently awarded a contract by one of its key
accounts to prepare all environmental permits applications for a new production
plant that will convert natural gas into diesel fuel and paraffin waxes. The
new plant is to be built in modular stages with each stage capable of producing
200 barrel per day of liquid fuel, with an eventual goal of ten production
units, with an eventual total production capacity of 2,000 barrels per day of
synthesized diesel fuel and waxes.
Environmental permitting is central to the plant design process and it
is imperative to develop a full understanding of the permitting issues in order
to make informed design decisions.
This project is a great example of the sort of environmental
permitting work that BLEST conducts for industry, and why permitting is so
important in North America’s highly regulated manufacturing arena . For that
reason, we’ve taken a few paragraphs to explain the process for this contract
and discuss the rationale behind some of the permitting process.
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| An LNG Plant |
The first phase of the project is to prepare a permitting strategy document that records our evaluation of which potentially applicable environmental regulations and how they may impact design and operation of the proposed facility. The permitting approach can be categorized by media, that is: emissions to the air, emissions to the water and solid waste. There are numerous potential regulations that may apply for each of the media, including, but certainly not limited to the broad Federal regulatory categories below:
- Resource Conservation and Recovery Act
- Clean Air Act Amendments Title V
- Clean Air Act Amendments Title III
- New Source Performance Standards, New Source Review
- Prevention of Significant Deterioration (PSD)
- Toxic Substances Control Act
- National Pollutant Discharge Elimination System
- Process Safety Management
In addition to the Federal regulations that may apply, each
state and many cities and counties have regulations for specific parameters
that must be considered during the design process. In total, a new plant may be required to
comply with over thirty separate environmental regulations, some of which may
conflict, making compliance impossible.
Permitting is often considered an afterthought or a
“sideline” issue during the plant design process. However, incorporating the permitting
strategy in the design process can save both time and money. There are numerous thresholds built into the
regulations that, if exceeded, escalate permitting fees, design and operating
costs and extend the time from inception to operation by an order of
magnitude. For example, if PSD is
triggered, it becomes necessary to conduct an ambient air study and collect
data for a calendar year before a permit application can be considered. The site-specific ambient air quality data
establishes a baseline air quality that, under PSD, cannot be appreciably
impacted by emissions from the proposed plant.
By designing the scale of the proposed plant so that PSD is not
triggered, at least a year can be saved between inception and plant
operation. Conversely, if PSD is not
considered in the early planning process, the plant operation can be delayed by
at least a year and potentially be denied permission to construct due to local
ambient air quality impacts. This
outcome requires the plant to be completely redesigned and likely reduced in
scale, which could make the economics of the entire endeavor prohibitive.
Early and thorough regulatory planning is imperative to a
successful project. Under today’s
regulatory setting, designing in ignorance of regulatory requirements is
tantamount to project failure.
What is a BioLargo
Spotlight?
It’s an exciting time
at BioLargo. We’re moving fast, and it can be difficult to keep our
stockholders and the investing public informed of our progress. In light of
this, we will be posting a series of short articles titled “BioLargo
Spotlight”, highlighting certain business activities and other important
information in between our required SEC filings. Of course, these do not
replace our public filings, which contain more complete information than can be
delivered in this forum, and thus we urge you to carefully read and rely on
those filings for definitive information, and to review our risk factors and
caution regarding forward-looking statements. We are optimistic about our
business as we work hard to continue to grow and ultimately generate profits
for our stockholders.
Legal Disclaimer
Our attorneys remind
us that while we believe these developments are important and that these small
victories could add up and lead to big victories, at this stage they do not
rise to the level of an official material disclosure. As the size and magnitude
of these developments become material, we will naturally report that
information in an 8-K and our regular SEC filings.
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