AM-02-11 IMPLEMENTING YOUR CONSENT DECREE? ORGANIZE FOR SUCCESS

Description:

In the last twelve months or so, several major refiners including BP, Equilon, Motiva, Deer Park Refining and Marathon Ashland Petroleum have penned Consent Decree agreements with USEPA. These agreements require member refineries to achieve simultaneous reductions in pollutants such as NOx, SOx, particulates, benzene, VOC's and air toxics at multiple locations and on multiple facilities. Impacted are heaters, burners, FCCU regenerators, Sulfur Plants, Flares, Continuous on-line analyzers, CO Boilers and pump and compressor seals. Never before in the history of refining in the US has so much equipment, at so many refineries, been put on a modification and compliance schedule so tight. Literally thousands of individual pieces of equipment need to be examined, documented, and cataloged. Then each needs to be modified in some way to achieve compliance. Then the major process equipment needs to be retrofitted with compliance monitoring analyzers to report results. This unprecedented scope of work comes at a time of severe shortage of experienced resources both within the refining industry and the engineering and construction industry supporting it. Refiners are faced with the challenges of high cost capital investment and lost opportunities associated with retrofit work during turnarounds. More importantly, process unit performance must not be adversely compromised as a result of compliance driven modifications. This paper describes the details of how a coalition of suppliers to the refining industry can be brought together in one umbrella organization to manage, plan, communicate and execute the complex logistics required to achieve required results in a timely and cost effective manner. It describes the Key Performance Indices needed for success, the critical organizational features that assure economic environmental compliance and shows how the right team can often achieve synergies across vast refining systems with their inherent cultural differences.