The Refinery “RTR” rule was final as of September 30, 2015. The ruling is complex with wide-spread consequences for all U.S. Refiners. The regulations range from new benzene fenceline monitoring, storage tank, marine vessel loading and venting requirements to more complex requirements for key refinery processing units. Previously exempted startup, shutdown and malfunction (SSM) events must now meet emission limits and other requirements. This requires the refiner to make careful reviews of operating procedures and history during SSM periods for the Delayed Coking Unit (DCU), Fluid Catalytic Cracking Unit (FCCU), Catalytic Reforming Unit (CRU) and Sulfur Recovery Units (SRU). Flares must meet new flare requirements which now apply during SSM periods. Given a compliance deadline of late 2018, the need to install new equipment could result in a compressed EPC schedule to achieve compliance. This presentation will provide an overview of the new Refinery “RTR” Rule and will highlight cost-effective solutions we have determined for compliance.
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