Suncor Refinery is seeking to renew EPA permits to pollute from Colorado’s Air Pollution Control Division (APCD) for its three plants in Commerce City. Suncor purchased the entire facility in two chunks in 2003 and 2005. The three plants are now under Suncor’s single ownership.

This is important. The APCD has allowed Suncor to operate with two expired EPA pollution permits. For plants 1 and 3, Suncor attempted to renew its permit in 2018 but the state failed to submit it to EPA on time. The state also neglected to submit the renewal application for Suncor’s plant 2 on time. That permit expired in 2009. If the state only had to deal with one permit for the facilities, maybe it could get its act together to submit that one on time.

More important, one EPA pollution permit that rolled up Suncor’s pollution data into one report would be much easier for the public to interpret and evaluate. Families and workers near the refinery would have a clearer picture of the air pollution risk to their health.

But public health doesn’t appear to be Suncor’s main concern. According to the refinery’s website, Suncor has invested $8 million in its surrounding communities in Colorado and Wyoming and produces $2.5 billion in economic value to Colorado every year. It generates 98,000 barrels of various oil and gas products per day. These assertions are supposed to make us Coloradans feel good about this income and job creator.

Suncor’s website doesn’t present the amounts of damage to people and the environment due to its often sloppy operations from old, worn-out pipes, valves, tanks, emission stacks, etc. It doesn’t highlight how much hydrogen cyanide, hydrogen sulfide, benzene, and numerous other cancer-causing Volatile Organic Compounds (VOCs) it throws up into the air each day by weight. It also doesn’t prominently display the amount of per-and-poly-fluoroalkyl substances, also known as “forever chemicals,” used to extinguish oil and gas-based fires and contained in the wastewater pumped into Sand Creek.

It’s no surprise that Suncor doesn’t broadcast its pollution numbers. The refinery is in the business of making fossil fuel products and money for the shareholders of the Canadian company. It’s the state’s job to make it easy for citizens to determine pollution impacts. It’s the state’s job to get the plant to limit pollution to federal Clean Air Act (CAA) standards.

Suncor seeks to solve its non-compliance problems by increasing the amount of allowable pollution by 90 tons. Most Colorado citizens would agree that an increase in pollution is the wrong direction.

One tool for tracking pollution at the refinery is the APEN, the Air Pollution Emission Notice. Any company that emits chemicals such as carbon monoxide, sulfuric acid, lead, VOCs including benzene, etc., must complete an APEN for every piece of equipment that pollutes. The state requires emitters to estimate the amount of pollution from the source of the emission. That’s to receive permission to pollute. Then the state relies on the permitted companies to report on the actual amounts of pollution. In other words, companies monitor themselves for pollution non-compliance.

Suncor has many APENs identified with leaking, flaring, and other polluting equipment. A birds’ eye survey of the locations of submitted APENs appears to show that not all equipment that should be identified as an emission source is identified.

The state also doesn’t ask for continuous monitoring of each emission source. Suncor gives the APCD its best guess of equipment emissions. The state uses EPA tools to estimate the amount of ‘actual’ emissions. This means that the APCD is making its permitting decisions based on EPA formulas and Suncor estimates, not on actual measurements. This is not just a Colorado problem.

The EPA has informed the state that it is not satisfied with how the APCD is producing the numbers that support possible new permits for the plants. One important reason relates to the concept of “social justice,” or improving the communications, yet alone reducing the pollution, in neighborhoods adjacent to the refinery.

The recent permitting process has encouraged feedback from the public. Most commentary confronts the refinery’s pollution breaches and the state’s insufficient compliance efforts. The public wants Suncor to back up its pollution and sustainability statements with extensive corrective action. Or start new somewhere else.