The company proposing an oil refinery near Theodore Roosevelt National Park says it will not be visible from the park, but its analysis is limited to five observation points in the 46,000-acre South Unit.
Meridian Energy Group conducted a study to determine whether the water vapor plume from a cooling tower at the proposed Davis Refinery could be seen from within the park.
The study was requested by the North Dakota Department of Health, but is not a requirement for the air quality permit the agency is reviewing.
The analysis considered four points within the South Unit of the park: Buck Hill, Painted Canyon visitor center, the main visitor center and the park amphitheater.
It concluded that from Buck Hill, the highest observation point in the park, the plume could be visible for an estimated 15 daylight hours a year. The plume would be about 7 miles away and at most would be visible 24 feet above the horizon, typically on cold days with no wind, said Dan Hedrington, senior project manager for SEH Consulting.
“It’s not going to be this huge column of smoke that people are envisioning,” Hedrington said.
But those who oppose building a refinery 3 miles away from Theodore Roosevelt National Park say the company’s analysis doesn’t consider views from the eastern portion of the park, such as from the Rim Trail.
“There are a lot of people that hike in the park that go off the beaten path and off the driving trail,” said Connie Triplett, a former state legislator and consultant for the National Parks Conservation Association. “I don’t put a lot of stock that the view from Buck Hill is the be all and end all.”
An early analysis from the National Park Service showed the refinery could potentially be seen from 630 acres in the park, including large sections of the eastern side. Theodore Roosevelt National Park Superintendent Wendy Ross said the agency conducted a viewshed analysis of the park using computer algorithms and dimensions of the facility provided by Meridian.
But Ross said some plans for the refinery have changed since the review was conducted.
“I can’t say definitively what the view would be from the park with the new equipment,” Ross said. “They haven't shared that with us.”
Hedrington said he was not aware of the Park Service analysis, adding that the consultants focused on public gathering areas in the park.
In addition to the plume visibility analysis, consultants for Meridian also conducted line-of-sight modeling studies to determine if the tallest units in the refinery could be seen from three park locations. Those studies looked at Buck Hill, Painted Canyon and the far southeast corner of the park, which is 3.2 miles from the refinery.
Hedrington said the modeling concluded that people would not be able to see the tallest structure in the refinery, 150 feet tall, from those three locations.
To illustrate that to the public, Meridian Energy conducted a demonstration in 2016 using a red kite that was 11 feet wide, representing the approximate width of a crude tower for the proposed refinery. The company flew the kite from the refinery location and observers with binoculars could not see it from Buck Hill when it was flown 150 feet high. When the kite was raised to 250 feet, one observer with a high-powered scope saw a dot in the sky, Hedrington said.
Julie Fedorchak, a member of the Public Service Commission who has said Meridian is “just basically skirting” the state’s requirements for siting refineries, pressed the company about the kite demonstration during an informal meeting with the company in December.
“The lights, I would assume, would be visible at night,” Fedorchak said, adding later in the meeting, “How do you make a kite look like a tower?”
Meridian CEO William Prentice said the Davis Refinery would not be “lit up like a Christmas tree” like other refineries. He said plans call for downcast, low-impact lighting, only turned on at night if required by the Occupational Safety and Health Administration.
The refinery will go through a review by the Federal Aviation Administration to determine if lighting is required for the tallest structures, Hedrington said.
Other potential light impacts include flare stacks at the refinery capable of burning off gas during plant startups or shutdowns or in an emergency to relieve pressure.
The first phase of the refinery, which will process 27,500 barrels of oil per day, would have three flare stacks. An enclosed hydrocarbon operating flare stack would be 50 feet tall, while an acid gas flare stack and a secondary hydrocarbon flare stack would each be 150 feet tall, according to information submitted to the health department.
If the refinery expands to process 55,000 barrels a day, it would have a fourth flare stack, also 150 feet tall, said Terry O’Clair, director of the health department’s Division of Air Quality.
Hedrington said the flares should not be visible from the five observation points in the park the company analyzed, citing the company's modeling studies.
O’Clair said it’s difficult to predict how often the refinery would flare because it would only be used in an emergency.
The health department would regulate flaring from the refinery to ensure emissions don’t exceed air quality standards, but being able to see a flare from the park doesn’t fall under the agency’s jurisdiction, O’Clair said.
No comprehensive review
While the impact of the refinery on park views and dark night skies are major concerns for conservationists, those factors won’t be analyzed by any state agency.
The Public Service Commission is the only state agency that could do a comprehensive review of the project, including evaluating the company’s line-of-sight modeling and looking at the impact of light, noise, dust and truck traffic to the park and surrounding area.
The agency requires a permit for refineries that process 50,000 barrels of oil per day, and Meridian initially promoted the Davis Refinery as expanding to 55,000 barrels. Recently the company revised its website to say 49,500 barrels.
Fedorchak urged the company to apply for a siting permit during the December meeting and said last week she continues to believe the company should go through the siting process.
Prentice has said the proposal was scrutinized by Billings County officials and the company currently has no plans to expand beyond a first phase.
The company emphasized during the meeting steps it’s taking to minimize impacts, including creating a natural buffer around the refinery.
“We’re going to try to disguise the project with trees and agricultural buffer from both from the interstate and the city of Belfield,” Prentice said. “Our objective is not to be able to see it at all.”
Triplett, who attended the meeting for the National Parks Conservation Association, said the refinery will be visible from the interstate to tourists heading to Theodore Roosevelt National Park.
“For a lot of people, their only experience of being in North Dakota may be getting to Theodore Roosevelt National Park along the interstate,” she said. “The notion that you can hide a refinery behind a row of trees seems a little far-fetched to me.”