Refineries

Tank bottoms may also leak from corrosion or other causes, and if the secondary containment for ASTs has become damaged or cracked, leaks and spills could be released from the containment structure. These releases could result in environmental impacts on-site or off-site.

Stormwater run-off captured in secondary containment structures and from other areas of the refineries could come in contact with chemicals, debris, waste, and other outside storage. Contaminated stormwater could impact soil, groundwater, or surface water if not properly monitored or contained.

Underground storage tanks, oil water separators, underground piping systems, and wastewater collection systems can also be present at refineries. They can be subject to leaks or spills if they become damaged or cracked if not adequately monitored or properly maintained. Spills or releases to the subsurface can migrate to groundwater and impact drinking water sources, such as public water supply wells, private potable wells, or surface waters. Releases to soil and groundwater can also produce toxic vapors that can migrate upward and into buildings causing indoor air issues.

On-site wastewater treatment plants often treat wastewater generated at refineries and stormwater that has come in contact with chemicals. Refineries generate wastewater from processes, cooling water, condensate blowdown, raw water treatment, laboratories, and equipment cleaning. Wastewater holding or treatment tanks, piping systems, treatment chemical storage areas, or waste storage areas can have leaks or spills, creating environmental risks. Sludge may be generated that could be classified as hazardous waste. These waste materials would need to be taken to a non-owned disposal facility approved to take such wastes. Improper waste disposal could lead to environmental liability or legal consequences for violating regulatory requirements.

Accidental releases during the transportation of chemicals, fuels, or wastes due to vehicle accidents, improper cargo securement, or a broken or loose valve can result in a release on the roadway. Depending on the extent of a release and where it migrates, it could trigger emergency response costs, cleanup costs, third-party claims, and natural resource damage claims.

Air emissions emanate from refining processes, storage tanks, loading/unloading racks, and other sources within refineries. Permit violations and improper control of emissions can result in civil fines, third-party bodily injury, and property damage claims.

Solid, regulated, and hazardous wastes are generated in petroleum refineries. Releases or spills can occur during waste handling, storage, or transport, creating environmental risks. Additionally, these wastes may be taken to non-owned disposal facilities. Improper waste disposal could lead to environmental liability or legal consequences for violating regulatory requirements. As a waste generator, the refinery can be responsible for pollution incidents at non-owned disposal facilities where their waste was sent.

Past disposal of wastes could have occurred on the refinery property in surface impoundments, land treatment units, waste piles, etc. These units may not have undergone clean closure, and environmental liabilities may remain from past on-site disposal practices.

Due to the flammability of the chemicals handled at petroleum refineries, fires, and explosions can occur at these facilities. Firefighting foam containing per-and polyfluoroalkyl substances (PFAS) may be used on fires, past or present. Fires and explosions can release toxic chemicals into the air, soil, groundwater, or surface water. Third parties can be impacted by exposure to toxic chemicals in the air, shock waves from explosions, or migration of contaminants in groundwater or stormwater. Drinking water sources can be impacted, and chemicals can be released into surface waters, damaging natural resources.

Refineries are often located next to water bodies, and large volumes of crude oil are delivered by ship to the refinery. Leaks or spills can occur over water or land from piping systems, tank overfills, pump failures, etc. Releases can result in many environmental liabilities on-site and off-site, including natural resource damage claims.