Oil & Gas

What regulations have been issued to refineries?

On March 11, 2021, the State Water Resources Control Board issued investigative orders to over 160 refineries and bulk fuel storage terminals in over 30 California counties, requiring environmental investigation and sampling for per- and polyfluoroalkyl substances, known as “PFAS.” This most recent wave of PFAS investigation orders is consistent with California’s increasingly aggressive approach to regulating and investigating PFAS in everything from soil, groundwater, food packaging, and consumer products.

The initial State mandated work plan requests directed the refineries to complete a PFAS investigation work plan by June 2, 2021, however, these work plans were extensive and needed copious amounts of internal facility research prior to completion. Refineries acting in good faith were granted extensions in some regions to complete the comprehensive internal facility records review of historical leaks, run-off water discharges, and AFFF use and storage areas.

The PFAS investigation orders will have broad implications not only for refineries and bulk fuel storage terminals but also for the larger regulated community as California continues to aggressively investigate PFAS contamination across the state and identify responsible parties.