ENV-16-78 Real World RSR Implementation: Lessons Learned on Tanks, SRU, Cokers

Description:

This paper represents a collaborative effort between Phillips 66 Company (Phillips 66), TRICORD Consulting, LLC, and Evergreen Environmental Consulting, LLC to describe a comprehensive program to implement the requirements of the final Petroleum Refinery Residual Risk and Technology Rule (RTR rule). The paper focuses on RTR rule implementation for the following refinery process units at the Phillips 66 Alliance Refinery in Belle Chasse Louisiana (Alliance Refinery): Sulfur Recovery Units, Storage Vessels, and Delayed Coking Units. The paper provides insights into RTR rule specifics as well as the design elements of Phillips 66’s overall program to manage RTR rule implementation. Phillips 66 and the Alliance Refinery utilized historical lessons learned from the implementation of the company’s global Consent Decree as a foundation for RTR rule implementation. These lessons were: (1) plan for a multiyear program; (2) recognize that each affected source category (e.g., Sulfur Recovery Units, Delayed Coking Units, and Storage Vessels), have their own timeline; and, (3) utilize teams that represent both a cross section of the technical experts in each source category and refinery operations and corporate resources.