Trinity helps petroleum refineries to achieve regulatory and environmental compliance while producing the fuels and chemicals upon which people depend. As a complex and highly regulated industry, petroleum refinery projects require a blend of regulatory and technical expertise. Trinity has completed nearly 1,400 projects for petroleum refining clients over the last decade. This project experience combined with our active membership in associations like the American Fuel & Petrochemical Manufacturers (AFPM) keeps us well versed in the environmental issues faced by the refining industry.
"Trinity has helped us with a variety of air and compliance management projects. Its staff has unparalleled expertise in these areas and invariably brings to the table good advice, excellent project management, and concern for clients budgets and time constraints. I enjoy working with Trinity."
Regulatory Round Up
- NSPS Ja. The U.S. Environmental Protection Agency (EPA) published the final revisions to the New Source Performance Standards for Petroleum Refineries for which Construction, Modification, or Reconstruction Commenced after May 14, 2007, 40 CFR 60 Subpart Ja (NSPS Ja) on September 12, 2012. This action removed the December 22, 2008 stay on several flare provisions enacted June 24, 2008, and also made significant revisions to flare and process heater provisions. Refineries now face implementing the various new compliance requirements, particularly for affected flares. These requirements include flow and total reduced sulfur monitoring and the development of a detailed flare management plan. Additional clarifications and revisions are anticipated in 2013.
Uniform Standards. On March 26, 2012, EPA proposed in the Federal Register 40 Code of Federal Regulations (CFR) Part 65, Subpart I (Storage Vessels and Transfer Operations), Subpart J (Equipment Leaks) and Subpart M (Closed Vent Systems and Control Devices), collectively referred to as the Uniform Standards. Additionally, EPA proposed revisions to the general provisions of Part 65, which are contained in Subpart H of 40 CFR 65. Comments on the proposed Uniform Standards were due by September 24, 2012. The American Petroleum Institute (API) and the American Chemistry Council (ACC) as well as several individual refineries and chemical companies prepared extensive comments on the proposed rulemaking.
The intent of the Uniform Standards is to streamline the standards for specific source categories (i.e., transfer racks, storage vessels, equipment leaks, closed vent systems, and control devices) within the chemical and refining sectors. The streamlining would be applied when EPA opens regulations for revision within New Source Performance Standards (NSPS), 40 CFR 60, and the National Emission Standards for Hazardous Air Pollutants , 40 CFR 61 and 40 CFR 63. However, there are significant industry concerns with this proposal as it would appear to institute more stringent control requirements than currently established by existing regulations.
- Flare Consent Decrees and Enforcement Alert. EPA recently entered into consent decrees with two refining companies to resolve concerns regarding proper operation of refinery flares to achieve optimal destruction efficiency. These consent decrees include provisions for more precisely monitoring steam to flow ratios for steam-assisted flares as recent testing has indicated that over-steaming flares (to reduce visible emissions) can lower flare destruction efficiency. The consent decrees also establish “caps” which limit the amount of flaring and may require the installation of flare gas recovery equipment. EPA also issued an enforcement alert summarizing these concerns regarding proper flare operation. Future enforcement action and additional consent decrees are expected across the refining industry.
- Regulatory Comments – Trinity worked with the American Petroleum Institute (API) as well as individual refineries and petrochemical plants to conduct a thorough review of the Uniform Standards proposed rules. Trinity prepared comments detailing regulatory, technical and economic concerns stemming from the proposed new requirements for equipment leaks, storage vessels, loading operations and control devices.
- Construction Permitting – Trinity prepared the permit application for a multi-billion dollar modernization of a large inland refinery. Following permit issuance, Trinity assisted the refinery with various implementation efforts stemming from the new permit requirements.
- Auditing – Trinity has completed a number of compliance auditing projects within the refining industry. Driven by consent decree requirements and internal compliance protocols, these audits have focused on topics ranging from general Title V compliance to historical PSD applicability issues and U.S. EPA enforcement initiative on "marquee" issues such as BWON, NSPS J/Ja, LDAR, and flaring.
Environmental and operations personnel at refineries who need training on the challenging air quality requirements affecting the industry will benefit from Trinity's two-day training course, Clean Air Act Requirements for the Petroleum Refineries.