How to Prepare Your Site If your site has not already been inspected, Trinity recommends internally auditing your facility. Specifically, Trinity recommends conducting inspections through the lens of current US EPA interpretations. This could include conducting OGI and NDE monitoring for all controlled WMUs. Sites may also benefit from a review of historical monitoring and inspection records to identify if there are issues that could be interpreted as repeat or “chronic” and consider if there are additional measures that could be taken to address those items. Based on U.S. EPA’s public remarks, this initiative is expected to press on at full speed until the majority of industry is covered.
a $19 million civil penalty and approximately $150 million in new capital projects (including a new benzene flash column), it is pretty clear that U.S. EPA has similar expectations regarding the costs that these new BWON CDs should impose across the industry. Though there are differences as to the extent and frequency for some of the new requirements; the Cenovus CD includes all of the main pillars from the BP CD: more frequent monitoring, use of OGI cameras, NDE engineering design documentation, and a root cause analysis to address repeat issues. Based on the similarities between these two CD, facilities can expect U.S. EPA to push for similar requirements in all future consent decrease as part of this initiative. Based on the enforcement alert, consent decree negotiations can also be expected to include capital expenditures for enhanced controls as part of injunctive relief. These projects could include: f Install or upgrades, or both, with benzene emission reduction technologies that treat high benzene process wastes where the waste stream exits the process unit, such as benzene stripper(s) or flash column(s) f Upgrades to dissolved gas flotation and induced gas floatation systems f Upgrades to internal/external floating roof and fixed roof tanks and API separators, including modifying or replacing floating roof tanks and inground APIs separators, as needed f Install or upgrades to covers of aeration basins/enhanced biodegradation units (e.g., improved material selection, vapor tight sealing, and automated and remote monitoring) f Upgrades to barscreen/grit chambers (e.g., capacity expansion, enhanced maintenance and cleaning protocols) f Upgrades to controls on equalization tanks and mixing bays
Stay tuned for additional updates as the enforcement initiative progresses.
For more information on current the enforcement initiative and how Trinity can help, please reach out to David Wall – Director Refinery Sector Services ( dwall@trinityconsultants.com ).
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