Consent Decree

A number of refiners are starting the consent decree process either as a late-comer, or as a result of new EPA initiatives and a second order to replace one successfully terminated.

 
Data Organization:

While in the past specific systems were used to develop data for CD reporting that in some cases duplicated what was reported for other reasons (e.g., a state emissions inventory, the TRI report, various permitting actions, upset reporting, etc.), the opportunity exists to consolidate some of that effort and have one core set of emissions estimates that feeds these multiple needs.

 

New Process Implementation:

LDAR programs are undergoing changes as new aspects are being introduced by EPA. Low-leak valve and valve packing procurement is typically part of new CD’s, requiring a refinery to revamp its process to meet the procurement requirements (e.g., for nonavailability, manufacturer certification, required replacement for chronic leakers, etc.). Changing refinery processes involves coordination between various departments to develop an effective workflow and communication process, train those who must implement the process, and the design of documentation elements. To make the pieces all fit together in a timely fashion requires a well-thought-out timeline and tracking to see that momentum is maintained.