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ENV-13-13 2011 Refinery ICR Submittals Impact on TRI & Other Regulatory Issues
Jon Brockhaus, Jon Brubaker, Karl Duckworth, Melissa Hart, Kari Keegan and Ashok Patel Sage Environmental
Format:
Electronic (digital download/no shipping)
Associate Member, International Member, Petrochemical Member, Refining Member -
$0.00
Government, NonMember -
$35.00
Description:
On March 31, 2011, the United States Environmental Protection Agency’s (EPA’s) Office of Air and Radiation (OAR), sent a letter to all petroleum refineries operating under the North American Industry Classification System (NAICS) Code of 32411 notifying them of OAR’s Information Collection Request (ICR). Refineries classified under this NAICS Code were asked to submit monitoring, air release, and stack test data that included methodology which potentially conflicted with current permitting methodology. As part of the request, stack testing or other sampling was requested for Fluidized Catalytic Cracking Units, Delayed Coking Units, Hydrogen Plant Units, Sulfur Recovery Units, Catalytic Reforming Units, Cooling Water Systems, Fuel Gas Systems, and Wastewater Treatment Systems. Reported air release and testing data submitted for these units and systems were subsequently compared by the EPA’s Toxic Release Chemical Inventory (TRI) Program Section to data submitted as part of EPCRA Section 313 TRI Reporting for the same calendar year. The EPA issued Data Quality Question Letters to these same facilities offering an opportunity to review TRI Report submissions for chemicals that may have potentially either not been, or reported incorrectly. Consequences of failure to report or incorrect reporting are significant, and facilities have been urged to respond to these letters with revisions where appropriate. The implications of the air release and testing data submitted extend beyond TRI and have the potential to impact air permitting and emission inventories for all refineries
Product Details:
Product ID: | ENV-13-13 |
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Publication Year: | 2013 |