The U.S. Environmental Protection Agency (EPA) has spent decades targeting petroleum refineries under the Clean Air Act and other federal statutes. Refineries are among the largest stationary sources of sulfur dioxide (SO₂), nitrogen oxides (NOx), volatile organic compounds (VOCs), and hazardous air pollutants (HAPs). Since the late 1990s, the EPA’s Petroleum Refinery Initiative has produced a string of multi-billion-dollar settlements, forcing companies to upgrade flares, reduce benzene emissions, install leak detection and repair (LDAR) programs, and modernize wastewater treatment.
This article highlights the top 10 EPA enforcement actions and lawsuits against refiners—cases that not only set penalty records but also reshaped compliance strategies across the industry.
1. BP Amoco Global Refinery Settlement (2001)
In 2001, BP Amoco entered into a landmark settlement covering eight refineries across the U.S. This was one of the first comprehensive cases under the Petroleum Refinery Initiative.
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Issues: New Source Review (NSR) and New Source Performance Standards (NSPS) violations, hazardous waste handling, and benzene leaks.
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Outcome: Required large-scale injunctive relief, including flaring controls, LDAR upgrades, and wastewater improvements.
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Impact: Signaled EPA’s intent to treat refineries as a sector requiring systemic reform, not piecemeal enforcement.
2. Motiva, Equilon, and Deer Park (Shell) – 2001
Also in 2001, the EPA secured one of the largest multi-facility settlements of its time with Shell subsidiaries.
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Facilities Covered: Nine refineries nationwide, including Shell’s massive Deer Park complex in Texas.
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Estimated Reductions: 8,000 tons per year (tpy) of NOx, 49,550 tpy of SO₂, and 1,300 tpy of particulate matter (PM).
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Investment: Roughly $400 million in capital projects and operational improvements.
This case cemented flaring control and LDAR as permanent features of refinery compliance programs.
3. Marathon Ashland Petroleum Settlement (2001)
Marathon’s 2001 settlement covered seven refineries in Ohio, Kentucky, Louisiana, Minnesota, Illinois, Michigan, and Texas.
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Penalty: $3.8 million in civil fines.
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Compliance Investment: Over $260 million in pollution controls.
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Projected Benefits: 8,000 tpy NOx and 12,800 tpy SO₂ reductions.
Marathon was forced to overhaul its flaring operations, a common theme across enforcement actions.
4. Chevron U.S.A. Case (2003)
Chevron’s 2003 global settlement extended EPA’s reach into California and Gulf Coast refineries.
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Facilities Covered: Five refineries in California, Hawaii, Mississippi, and Utah.
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Outcome: Multi-site injunctive relief and installation of state-of-the-art emission controls.
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Impact: Cut more than 10,000 tpy of harmful pollutants and served as a model for subsequent Chevron consent decrees.
5. ConocoPhillips Global Refinery Settlement (2005)
In 2005, ConocoPhillips agreed to one of the largest refinery enforcement packages at the time.
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Facilities Covered: Nine refineries across the U.S.
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Civil Penalty: $4.525 million.
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Compliance Costs: More than $525 million in pollution-control investments.
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Environmental Gains: 10,000 tpy NOx and 37,100 tpy SO₂ reductions.
This action highlighted EPA’s use of both penalties and Supplemental Environmental Projects (SEPs) to maximize community benefits.
6. CITGO Refining (2005)
Also in 2005, CITGO entered a sweeping agreement affecting six refineries in five states.
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Civil Penalty: $3.6 million.
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Compliance Spending: Roughly $320 million on injunctive relief.
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Results: More than 30,000 tpy in criteria pollutant reductions.
CITGO’s settlement underscored the EPA’s focus on benzene wastewater controls, in addition to traditional flaring and LDAR upgrades.
7. Valero (Premcor) Settlement (2007)
In 2007, the EPA reached an agreement with Valero Energy Corp., covering three Premcor refineries in Tennessee, Ohio, and Texas.
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Penalty: $4.25 million.
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Compliance Costs: $232 million in new pollution-control technologies.
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Benefits: Cut more than 1,870 tpy of NOx and 1,810 tpy of SO₂.
Valero’s case reinforced EPA’s insistence on enforceable flare management plans.
8. BP Whiting Refinery, Indiana (2012)
The Whiting Refinery in Indiana—BP’s largest U.S. facility—has faced multiple EPA actions. In 2012, EPA targeted flaring practices and wastewater discharges.
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Penalty: $8 million in fines.
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Injunctive Relief: Over $400 million in new controls.
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Results: Major flare upgrades, fluid catalytic cracking unit (FCCU) improvements, and benzene wastewater controls.
Whiting remains a case study in how EPA uses single-facility enforcement to drive large-scale capital projects.
9. Shell Deer Park Refinery & Chemical Plant (2013)
Shell’s Deer Park complex near Houston is among the largest petrochemical hubs in the U.S.
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Penalty: $2.6 million.
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Compliance Spending: More than $115 million on flare optimization and control technology.
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Environmental Gains: Significant reductions in VOCs and HAPs from better flare efficiency.
This settlement also required Shell to adopt real-time flare monitoring, a best practice that spread across the industry.
10. ExxonMobil Baytown Citizen Suit (2010s–2025)
While most refinery cases come from EPA, citizen enforcement suits are also powerful. Residents near ExxonMobil’s Baytown, Texas refinery and chemical plant filed a Clean Air Act case alleging tens of thousands of emission events.
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Penalty: $14.25 million, the largest citizen-suit penalty in CAA history.
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Outcome: The U.S. Supreme Court allowed the penalty to stand in June 2025.
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Significance: Validated the role of community groups in holding refiners accountable when EPA resources are stretched.
Broader Themes in Refinery Enforcement
1. Clean Air Act Dominates
Most refinery cases involve the Clean Air Act, particularly NSR/NSPS, flare emissions, benzene waste operations, and LDAR requirements.
2. Injunctive Relief Outweighs Penalties
While civil penalties range from a few million to tens of millions, injunctive relief investments often exceed $100–500 million per case, driving the bulk of emissions reductions.
3. Community Health Benefits
Reductions in SO₂, NOx, VOCs, and HAPs translate into lower asthma rates, fewer smog days, and cleaner water in refinery communities.
4. Ongoing Scrutiny
EPA continues to monitor refineries through its ECHO database, consent decree compliance reports, and regional enforcement offices. Companies like Shell, BP, Marathon, Chevron, and ExxonMobil remain under long-term obligations.
Why These Cases Matter for Today
Refinery enforcement is more than historical. In 2025, political shifts and regulatory rollbacks are colliding with court decisions that constrain EPA authority. Yet, the legacy of these settlements continues to shape how refiners design, maintain, and operate their plants.
For businesses and policymakers, the key lesson is that environmental compliance is never optional. Even when federal enforcement slows, citizen suits can fill the gap, as Baytown proved.
For communities living near refineries, these cases demonstrate that persistent monitoring, legal action, and EPA oversight remain essential tools for safeguarding air and water quality.
Conclusion
The top 10 refinery enforcement actions represent more than fines and consent decrees—they represent a fundamental shift in how the U.S. petroleum sector balances production with public health. From BP’s early multi-facility settlements to ExxonMobil’s citizen-suit penalty in Baytown, the message is clear: refineries must comply with federal laws or face costly consequences.
As the energy sector evolves and new environmental challenges emerge, these enforcement precedents will continue to guide compliance strategies, legal risks, and community activism around the refinery industry.