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Keeping your LDAR Program Current
It is time to start watching - S697
New Chemicals under Prop 65
Toxicity - Sensationalism versus reality


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Keeping your LDAR Program Current

The 15th LDAR Symposium Sponsored by the ISA just concluded in New Orleans.  If you were unable to attend that session, here is a webinar that was presented prior to the Symposium "Keeping your LDAR Program Current."

The Chemical Safety Board & the Chevron Refinery Incident

The Chemical Safety Board (CSB) had released its final report on the Chevron Refinery Incident that occurred on August 6, 2012.  (The final report can be foundhere.)  Additionally, the CSB has issued some recommendations regarding how refineries should be regulated.  (See the CSBpress release) At issue is the process safety management (PSM) program and how it is managed.  Today the CSB sees PSM as primarily reactive rather than a proactive adapted program. 

PSM and other regulations such as the SARA Community Right to Know have been under a great deal of scrutiny of late due to incidents like this one and the one that occurred in West, TX.

Need a detailed look at the Proposed Refinery Air Rule?

October 28, is the current deadline for comments to the Proposed Refinery Air Regulations.  You can find a copy of the rule making and supporting information on EPA's website. This site has links to all the petroleum refinery air regulations as well as information about the current rule making.  If you want to get an overview of some of the critical portions of the rule - Check out this month's cover story in Pollution Engineering.

The CSB was busy last week

In addition to the Chemical Safety Board's release of the analysis on the 2014 Sulfuric Acid release at a refinery in California, it also "closed the book" on the Anacortes refinery 2010 explosion.  The CSB's analysis on the Sulfuric Acid release can be foundhere. And while the final report on the 2010 explosion was released earlier this year, there were some legal questions being investigated.  The final report can be foundherealong with recommendations from the American Petroleum Institute, the Environmental Protection Agency, and others.

Safety Information - Refinery.

The Chemical Safety Board released its report on a release of sulfuric acid.  Here is the report.

Update - Proposed Petroleum Refinery Air Rule

One may have anticipated that an extension period was likely in the Proposed Petroleum Refinery Risk and Technology Review and New Source Performance Standards rule making process.  EPA has made it official - the comment period on the the proposed rule will now close on October 28, 2014.  (You can see the Extension Noticehere.The Federal Register Notices is locatedhere.

The Public Hearings on the proposed rule have been very active, if local newspaper accounts are to be believed.

The extension in this case is very much needed due to the breadth and scope of the proposed rule making.

Interesting perspective - Blog from the Huffington Post

For those of you following the newly proposed rule for petroleum refineries - this might be an interesting perspective to read.

Flares - the compliance world is changing.

On June 30, 2014, EPA published the long awaited and much anticipated Petroleum Refinery Sector Proposed Air Rules.  For those working as environmental compliance managers in air at petroleum refineries, this rulemaking has been a hot topic ever since the initial residual risk rule came out a number of years ago, and has only heated up.  As EPA has issued the general rules on heat exchangers, and issued the Information Collection Request in 2011.  Add to that the decision in Sierra Club v.

It has made it to the Federal Register - Proposed Petroleum Refinery Sector Risk and Technology Review

Well it has finally made it to the Federal Register, the long awaited residual risk rule for petroleum refineries.  You may have missed it, of course, as you might have been getting ready for the Fourth of July or you might still be on vacation.  But, it is here.  You can download the pdf version of the rule fromhere.

EPA will be holding two public hearings - one in Wilmington, CA (July 16, 2014) and one in Galena Park, TX (August 5, 2014). The proposed comment period is from June 30, 2014 through August 29, 2014.

New Proposed Refinery Rules

Keep checking back here to follow an assessment of the new refining rules.  The EPA Fact Sheet only goes so far in outlining the proposed changes.

There are some LDAR provisions and tightening of start-up, shutdown and malfunction items.

As with all EPA proposals - we are going to have to look at the individual provisions with a careful reading.
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