Johnson-Koch L.M.,DLA Piper LLP U.S. |
Magill A.H.,DLA Piper LLP U.S.
NPRA Environmental Conference Papers | Year: 2010
Although ∼ 90% of the US refining capacity has entered into global settlements under the Clean Air Act, the pace of EPA enforcement on air issues does not appear to have slowed. While some refiners are still negotiating global settlements, earlier global settlers are addressing new marquee issues and, in some instances, responding to new information requests on old ones. A discussion covers some of the refinery-focused enforcement priorities that refiners may encounter in the coming years; flaring and flare combustion efficiency; refineries with cokers; a new BWON enforcement initiative; EPA's policy for calculating the economic benefit to be recouped by the government; CERCLA/EPCRA Release Reporting; and surface impoundments. This is an abstract of a paper presented at the 2010 Environmental Conference (San Antonio, TX 9/20-21/2010). Source