For 2018, Resolve to Know Your Permits

A suggested New Year’s resolution: know your permits.  While facility management teams generally know the numerical parameters that the facility must meet, some fail to keep other permit requirements in focus. Facilities can violate their permit even without emitting or discharging anything illegal, by failing to comply with the numerous narrative requirements. Also, for those […]

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Focus on Flares: ExxonMobil Agrees to Multi-Million Dollar Settlement

ExxonMobil, a company not afraid to fight the federal government (See last week’s Alert), has agreed to a multi-million dollar settlement with the United States Environmental Protection Agency (“EPA”), the United States Department of Justice (“DOJ”) and the Louisiana Department of Environmental Quality (“LDEQ”) over allegations of improper operation and inadequate monitoring of flares. Federal […]

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ExxonMobil’s Good Faith Consideration of Required Factors Defeats PHMSA Order

When agency regulations require that a company employ a process for detecting and responding to threats of leaks, the company satisfies those regulations by employing that process in good faith, even if doing so failed to prevent a serious accident.  An agency’s after the fact criticisms of how the company employed the process will not […]

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