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Petroleum Refinery ICR (4/8/11)

On March 28, 2011 EPA received approval from the Office of Management and Budget (OMB) to carry out a massive information collection request (ICR) for petroleum refineries. According to EPA, the ICR is necessary to reevaluate emission standards for the source category. This is a four component ICR with very rapidly approaching deadlines:

  • Component 1 (Questionnaire): due May 31, 2011 for all refineries

  • Component 2 (Emission Inventory) due June 30, 2011 for all refineries

  • Component 3 (Distillation Feed Sampling) due August 31, 2011 for all refineries

  • Component 4 (Testing and ERT reporting) due August 31, 2011 for 88 selected sources.

In 2010, RMB was involved in assisting over 50 facilities respond to the electric generating units (EGU) ICR. The EGU ICR involved similar reporting tools for Components 1-3 and identical testing methods and reporting tools for Component 4. RMB is uniquely qualified to provide technical support for virtually all aspects of the refinery ICR. RMB is familiar with many different data collection systems and is able to reduce the collected data to the format required by the EPA reporting tools, which are not necessarily intuitive to new users. RMB is qualified to prepare site-specific test plans, address sampling and analytical concerns during the testing, communicate necessary modifications to stack test methodology where appropriate, ensure that proper process data is collected, and assist in the ERT submittals of test data. Refineries must be aware that the quality of the data obtained and reported is of upmost importance since it will be used to establish future regulatory limits. Past experience has shown that poor quality, low level emission test data has resulted in proposed regulatory emission limits that are not achievable in practice. For further information and to discuss the specific needs for your source(s), please contact Bethany White at 919-791-3135.

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RMB Consulting & Research, Inc.
Last Revised: February 22, 2013