API’s comments on the Refinery Sector Rule

On 16 July 2014, the API put forward comments at the Environmental Protection Agency (EPA) public hearing on the proposed petroleum refinery sector risk and technology review and new source performance standards. Below are highlights from the comments made by the API.

‘I have three key points I would like to make today. One; air quality in the US has improved significantly, continues to improve, and our industry is doings its part to contribute to this success. Two; after significant effort, the US EPA has concluded in this rulemaking that the public is protected with an ample margin of safety. Three; the safe operation of our refineries to protect our workers and the community is our number one priority.’

Air quality

‘My first point is that air quality has improved significantly, continues to improve and our industry is contributing to these improvements. According to the EPA report on the environment, mean benzene concentrations have dropped by 66% from 1994 – 2009 nationwide. Locally, the improvement has even been more dramatic. California Air Resources Board data show that from 1990 – 2012, right near here in North Long Beach, mean benzene concentrations have dropped by 89%. And the US oil and natural gas industry has been a key part of that improvement, investing over US$ 268 billion since 1990 toward improving the environmental performance of its products, facilities and operations. In this year 2012 alone, approximately US$ 14.9 billion was expended on environmental protection.’

Margin of safety

‘EPA has concluded in this rulemaking that the public is protected with an ample margin of safety from refinery emissions. Once again, EPA has reached this conclusion, this time after developing an entirely new protocol for refineries to report their emissions and a multimillion dollar information collection request, including data collection from every refinery for all emission sources and direct emissions testing for a number of emissions sources. All of this information is then processed through conservative risk modelling which has determined that communities around refineries are protected with an ample margin of safety from refinery emissions.’

Safe refinery operations

‘It goes without saying that the safe operation of our refineries to protect our workers and the community is our number one priority. As such, API will be taking a close look to ensure these proposed regulations don’t compromise the safety of our workers and the community. For example, in this rule, EPA has proposed requirements prohibiting the use of equipment whose sole purpose is to prevent over pressuring of equipment and avoid potentially catastrophic damage. This prohibition will not only increase safety risk but will require many additional flares. Obviously, this part of the proposal needs to be revised from a safety perspective.’

Adapted from testimony by Claira Lloyd

Read the article online at: https://www.hydrocarbonengineering.com/gas-processing/21072014/api-refinery-sector-rule/