(Washington, DC - March 06, 2012) The U.S. Environmental Protection Agency (EPA) and the U.S. Department of Justice announced that Coffeyville Resources Refining & Marketing (CRRM) has agreed to pay a civil penalty of more than $970,000 and invest more than $4.25 million on new pollution controls and $6.5 million in operating costs to resolve alleged violations of air, superfund and community right-to-know laws at its Coffeyville, Kan. refinery.

On this page:

• Overview of Company and Location of Facility
• Violations
• Injunctive Relief
• Supplemental Environmental Project (SEP)
• Pollutant Reductions
• Health and Environmental Effects
• Civil Penalty
• State Partners
• Comment Period
• Petroleum Refinery National Initiative Case Results
• Contact

Overview of Company and Location of Facility

Coffeyville Resources Refining & Marketing (CRRM) operates a single refinery in Coffeyville, Kansas with a refining capacity of 115,700 barrels per day, which is less than 1 percent of the total U.S. domestic refining capacity.  CRRM’s refinery produces gasoline, diesel fuels, and propane.

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Violations

The settlement resolves alleged violations of Clean Air Act (CAA)requirements covering the four main sources of emissions of sulfur dioxide (SO₂), nitrogen oxides (NO_x),  volatile organic compounds (VOCs) and benzene:

• New Source Review/Prevention of Significant Deterioration (NSR/PSD), 40 C.F.R. Part 52
• Fluidized Catalytic Cracking Unit (FCCU)
• Refinery Heaters and Boilers

New Source Performance Standards (NSPS), 40 C.F.R. Part 60, Subparts A and J

• Flares
• Sulfur Recovery Units
• Fuel Gas Combustion Devices (including heaters & boilers)

Leak Detection and Repair (LDAR), 40 C.F.R. Part 60, Subpart GGG National Emission Standards for Hazardous Air Pollutants (NESHAP) for benzene wastes, 40 C.F.R. Part 61, Subpart FF

The settlement also resolves alleged violations of Section 103(a) of the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA), 42 U.S.C. § 9603(a), and Section 304(b) and (c) of the Emergency Planning and Community Right-to-Know Act, 42 U.S.C. § 11004(b) and (c).

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Injunctive Relief

The consent decree’s injunctive relief to resolve the CAA claims is outlined below.  The estimated cost of the injunctive relief is $10.75 million, including $4.25 million in capital costs and $6.5 million in operating costs.

New Source Review/Prevention of Significant Deterioration (NSR/PSD) -- FCCU and Heaters and Boilers

• FCCU SO₂ limits no greater than 10 ppm on a 365-day rolling average basis and 18 ppm on a 7-day rolling average basis
• Implementation of NO_x emissions reductions measures on refinery heaters and boilers sufficient to achieve a system-wide NO_x average of no greater than 0.041 lbs/mmBTU
• Performance of a flameless heater demonstration project
• Compliance with NSPS Subpart J at all heaters and boilers
• Restrictions on coal and fuel oil burning in heaters, boilers, and combustion units to control SO₂

New Source Performance Standards (NSPS) and Flaring

• Compliance with SO₂ standards of Subpart J for all combustion devices burning refinery fuel gas, and with Subparts J for refinery flares
• Compliance with SO₂ standards of Subpart J at sulfur recovery processes, including the sulfur pit
• Comply with NSPS Subpart A, General Provisions, 40 C.F.R. § 60.11 (d), by conducting root cause analyses for all flaring events exceeding 500 lb/day of SO₂

Benzene Waste Operations National Emissions Standards for Hazardous Air Pollutants (NESHAP)

• Maintain facility waste at less than 10 megagrams (Mg) of total annual benzene (TAB) per year
• Comply with the “6 BQ” compliance option for benzene if TAB exceeds 10 Mg

Leak Detection and Repair (LDAR) Program

• Refinery-wide compliance with LDAR requirements
• Training, including refresher courses, for refinery personnel with LDAR responsibility
• Required LDAR compliance audits
• Strict internal leak definitions (500 ppm for valves and 2000 ppm for pumps)
• Internal first attempt at repair at 200 ppm for valves 
• More frequent monitoring than required by regulation
• Installation of "low-emissions" valve or valve packing technology

The consent decree requires the following actions to resolve the CERCLA and EPCRA claims:

• Conduct a CERCLA/EPCRA compliance review at the refinery to review and evaluate all episodic or continuous releases of CERCLA hazardous substances and/or EPCRA extremely hazardous substances that were required to be reported under CERCLA and/or EPCRA  and submit a compliance review report summarizing the findings of audit and results of the compliance review to the EPA.
• Submit EPCRA and CERCLA reports that were not previously submitted or were submitted but contained incomplete or inaccurate information. 
• Review all procedures used to gather the information for reporting under the EPCRA/CERCLA release reporting and Toxic Release Inventory programs and Correct and/or update internal release reporting procedures to address any reporting deficiencies.
• Conduct training for environmental department personnel that have EPCRA/CERCLA reporting responsibilities.

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Supplemental Environmental Project (SEP)

CRRM will implement a SEP at its refinery at a cost of $1,265,000 that will have multi-media benefits by reducing air emissions and conserving water. The SEP has three components:

• Enhancement of the wastewater treatment system to reduce fugitive emissions of VOCs and H2S by reducing hydrocarbon carryover into the wastewater treatment system.
•  Reduction of hydrocarbon carryover into the sour water stripper (SWS) and the Sulfur Recovery Unit (SRU), which would help reduce the frequency of future acid gas flaring incidents.
• Conservation of 15 million gallons of water each year by increasing water re-use/recycling by rerouting streams to the SWS and creating additional, clean SWS effluent water, rather than using fresh water from the river. 

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Pollutant Reductions

Once all emissions controls have been installed and implemented at the FCCU, refinery heaters and boilers, and combustion devices burning refinery fuel gas, this settlement is estimated to result in the following emissions reductions in tons per year (tpy):

• NO_x emissions by 200 tpy
• SO₂ emissions by 110 tpy

The settlement will also result in additional reductions of VOCs and other pollutants.

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Health and Environmental Effects

• Nitrogen Oxides – Nitrogen oxides can cause ground-level ozone, acid rain, particulate matter, global warming, water quality deterioration, and visual impairment. Nitrogen oxides play a major role, with volatile organic chemicals, in the atmospheric reactions that produce ozone.  Children, people with lung diseases such as asthma, and people who work or exercise outside are susceptible to adverse effects such as damage to lung tissue and reduction in lung function.

• Sulfur Dioxide – High concentrations of SO₂ affect breathing and may aggravate existing respiratory and cardiovascular disease. Sensitive populations include asthmatics, individuals with bronchitis or emphysema, children and the elderly. Sulfur dioxide is also a primary contributor to acid deposition, or acid rain.

• Volatile Organic Compounds - VOCs, along with NO_x, play a major role in the atmospheric reactions that produce ozone, which is the primary constituent of smog.  People with lung disease, children, older adults, and people who are active can be affected when ozone levels are unhealthy. Ground-level ozone exposure is linked to a variety of short-term health problems, including lung irritation and difficulty breathing, as well as long-term problems, such as permanent lung damage from repeated exposure, aggravated asthma, reduced lung capacity, and increased susceptibility to respiratory illnesses such as pneumonia and bronchitis.

• Benzene - Acute (short-term) inhalation exposure of humans to benzene may cause drowsiness, dizziness, headaches, as well as eye, skin, and respiratory tract irritation, and, at high levels, unconsciousness.  Chronic (long-term) inhalation exposure has caused various disorders in the blood, including reduced numbers of red blood cells and anemia in occupational settings.  Reproductive effects have been reported for women exposed by inhalation to high levels, and adverse effects on the developing fetus have been observed in animal tests.  Increased incidences of leukemia have been observed in humans occupationally exposed to benzene.  EPA has classified benzene as a Group A human carcinogen.

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Civil Penalty

CRRM will pay a $723,125 civil penalty to resolve the CAA violations as follows:

• $361,562 to the United States
• $361,562 to the State of Kansas

CRRM will pay a $250,000 civil penalty to the United States to resolve the CERCLA and EPCRA violations.

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State Partners

The state of Kansas participated in the settlement negotiations and is a party to the settlement.

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Comment Period

The proposed settlement, lodged in the U.S. District Court for the Eastern District of Louisiana, is subject to a 30-day comment period and final court approval.  Information on submitting comment is available at the Department of Justice website.

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Petroleum Refinery National Initiative Case Results

Through multi-issue, multi-facility settlements or detailed investigations and aggressive enforcement, this national priority addresses the most significant Clean Air Act compliance concerns affecting the petroleum refining industry.

See EPA’s National Petroleum Refining Initiative website for more information.

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For more information, contact:

Melanie Shepherdson
Attorney
U.S. Environmental Protection Agency (2242A)
1200 Pennsylvania Ave., N.W.
Washington, DC 20460-0001
(202) 564-8386
sherpherdson.melanie@epa.gov

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