(122a) National Environmental Performance Track Case Study

Authors: 
Young, K., ENVIRON International Corporation
Dows, W. (., Marathon Petroleum LLC
Bracey, J., Marathon Ashland Petroleum, LLC
Laffoon, C., ENVIRON International Corporation
Kurtz, A., ENVIRON International Corporation


Case Study: Implementation of NEPT at Marathon Petroleum's Louisiana and Texas Refining Divisions

EPA has a well established program, the National Environmental Performance Track (NEPT), that provides industry with incentives to go ?beyond compliance?. Numerous industry sectors have been accepted into this program including Marathon Petroleum's Corporate Group in Findley, Ohio and their Louisiana Refining Division in Garyville, Louisiana. Additionally, Marathon Petroleum's Texas Refining Division is in the process of obtaining acceptance into the program. This presentation will provide a case study on the lessons learned during the implementation of the NEPT program by Marathon Petroleum's Louisiana Refining Division (LRD) in 2002 compared to new challenges and program changes for an organization, in particular the Texas Refining Division (TRD), applying in 2007. The presentation will also include changes and enhancements implemented by the EPA since the program inception in 2000 as well as overall benefits and environmental performance improvement recognized by LRD.

What is NEPT?

In 2000, EPA rolled-out the NEPT program to recognize and encourage top environmental performers ? those who go beyond compliance with regulatory requirements ? to attain levels of environmental performance and management that benefit people, communities, and the environment.

To qualify for NEPT, a facility will have to demonstrate that it has the following systems in place:

? Environmental Management System: Has adopted and implemented an environmental management system (EMS) that includes the following elements: policy, planning, implementation and operation, checking and corrective action, and management review; and has had the system verified and/or certified by an independent, EPA approved 3rd party.

? Performance Reporting: Is able to demonstrate specific environmental achievements and commit to continued improvement (through annual performance reporting based on Global Reporting Initiative framework);

? Public Outreach: Commits to public outreach and performance reporting (through community advisory panels, Responsible Care program, etc.);

? Environmental Compliance: Has a record of sustained compliance with environmental requirements; and

? Continual Improvement: Demonstrates past environmental achievement and commits to future continued improvement in environmental performance.

Why Marathon Petroleum Elected to Participate in NEPT

To promote participation in the NEPT program, EPA currently offers some incentives and is considering others. The current and proposed benefits that EPA is offering to NEPT participants can be significant ?drivers? for organizations to participate in the program. Some incentives currently available to NEPT members include:

? Low priority for inspection targeting purposes;

? Discretionary factor in the assessment of penalties;

? Use of NEPT logo; and

? Visibility and recognition through articles, press releases, etc. and listing on NEPT website.

Additionally, EPA is also considering other Administrative Actions such as reduced reporting and monitoring for certain programs.

Overview of NEPT Implementation by the LRD and Development/Implementation at TRD

Part of this presentation will discuss the implementation process conducted by the LRD in 2002 compared to implementation in 2007 by TRD, including:

? Application and notification process;

? Project tools used in the implementation process;

? Steps taken for modifying/upgrading existing programs;

? Significant hurdles encountered; and

? Protocol used by EPA inspectors during the site visits.

Lessons Learned at LRD to consider when applying in 2007

From the application/notification phase to the awarding of the ?Performance Track? status, this section will discuss the ?lessons learned' on implementing the NEPT program at a major refinery in 2002 and how these were transferred to aid in streamlining the process for the TRD in 2007. In addition, this section will highlight the hurdles that were cleared during the process, and how to help streamline them when applying in 2007.