Fugitive Emissions - Consent Decree Compliance Management; It is Possible!

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INTRODUCTION

Fugitive emissions from process equipment such as valves, connectors, pumps, etc. can account for 30 to 60% of a petroleum refinery's total air emissions (1). Leak Detection and Repair (LDAR) regulations imposed by the USEPA and some state environmental agencies mandate that refineries implement an LDAR program to find VOC and HAP leaks and repair them. Audits by regulatory enforcement groups such as the National Enforcement Investigation Center (NEIC) have called into question the effectiveness of some LDAR programs. As a result, some refining companies have entered into a Consent Decree with the EPA to voluntarily impose LDAR work practices that are more stringent than the existing regulations applicable to their facilities.

This paper explores how a data management system can be used for Consent Decree compliance management.

 

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