The U.S. Environmental Protection Agency (EPA) has long considered petroleum refineries a top priority for enforcement because of their large emissions of sulfur dioxide, nitrogen oxides, volatile organic compounds, and hazardous air pollutants. Since the late 1990s, the EPA’s Petroleum Refinery Initiative has pursued sweeping lawsuits that forced refiners to invest billions in upgrades. These enforcement actions changed how the industry operates and set compliance standards that are still in effect today. Below are the ten most significant refinery cases that defined modern environmental law.
1. BP Amoco Global Settlement (2001)
This settlement covered eight refineries and addressed violations of New Source Review, benzene emissions, and hazardous waste rules. BP paid millions in fines and spent heavily on flare modernization, leak detection programs, and wastewater treatment. The case demonstrated the EPA’s willingness to regulate refineries as a sector, not just as individual facilities.
2. Shell and Motiva Deer Park Agreement (2001)
Shell subsidiaries agreed to upgrade nine refineries, including Deer Park in Texas. The deal required $400 million in compliance measures and reduced 8,000 tons of NOx, nearly 50,000 tons of SO₂, and over 1,000 tons of particulate matter annually. This case set a baseline for flare and LDAR controls across the industry.
3. Marathon Ashland Petroleum (2001)
Marathon’s $3.8 million penalty was small compared to the $260 million in required upgrades across seven refineries. The case resulted in 8,000 tons of NOx and 12,800 tons of SO₂ reductions each year, proving that compliance investment would far outweigh fines.
4. Chevron Multi-State Settlement (2003)
Chevron’s refineries in California, Hawaii, Mississippi, and Utah were forced to cut over 10,000 tons of pollutants annually. The settlement emphasized upgrades to catalytic cracking units and flare controls, shaping Chevron’s compliance programs for decades.
5. ConocoPhillips Refinery Settlement (2005)
This $4.5 million penalty came with $525 million in required upgrades across nine refineries. Expected reductions included 10,000 tons of NOx and 37,100 tons of SO₂ annually. The agreement also required Supplemental Environmental Projects, channeling additional benefits to local communities.
6. CITGO Refining Case (2005)
CITGO paid $3.6 million in penalties and committed $320 million in improvements at six refineries. Reductions exceeded 30,000 tons per year, with special emphasis on benzene wastewater management—an early signal of the EPA’s growing focus on toxic chemicals.
7. Valero (Premcor) Settlement (2007)
Valero paid $4.25 million and invested $232 million at facilities in Tennessee, Ohio, and Texas. The result was nearly 2,000 tons each of NOx and SO₂ reduced annually. This case also mandated enforceable flare management plans and continuous monitoring requirements.
8. BP Whiting Refinery, Indiana (2012)
Whiting, BP’s largest U.S. refinery, faced an $8 million penalty and $400 million in upgrades. The settlement required modernization of flare systems, stricter wastewater controls, and improvements to catalytic units. It became one of the largest single-refinery compliance cases.
9. Shell Deer Park Complex (2013)
Shell’s Houston-area refinery and chemical plant paid $2.6 million in fines and invested $115 million in compliance projects. Key upgrades included advanced flare optimization, VOC controls, and real-time flare monitoring, which later became an industry standard.
10. ExxonMobil Baytown Citizen Suit (2010s–2025)
Unlike other cases, Baytown was led by community groups under the Clean Air Act’s citizen enforcement provision. Residents alleged thousands of unreported emissions, and ExxonMobil ultimately paid $14.25 million, the largest citizen-suit penalty in U.S. history. In 2025, the Supreme Court upheld the fine, confirming the role of communities in enforcement.
Key Themes Across Cases
These settlements reveal consistent patterns. The Clean Air Act underpins enforcement, particularly provisions on New Source Review, flaring, benzene handling, and LDAR. Civil fines usually measure in the millions, but injunctive relief often requires hundreds of millions in upgrades. Community health benefits are direct and measurable, from reduced smog days to fewer asthma hospitalizations. Consent decrees and EPA databases ensure oversight continues for decades.
Lasting Impact on Refinery Compliance
The legacy of these cases continues to shape the industry. Even when political shifts reduce regulatory pressure, binding consent decrees prevent rollbacks. The Baytown decision underscores that when the EPA does not act aggressively, communities can still use citizen suits to hold refineries accountable. For companies, the lesson is clear: proactive investment in compliance is cheaper than waiting for enforcement.
FAQ: EPA Refinery Lawsuits and Enforcement
Why does the EPA focus on refineries? They are among the largest stationary sources of air pollution and pose major risks to public health.
How much do settlements cost? Civil fines are usually $2–15 million, but compliance costs often exceed $500 million per case.
Do they reduce pollution? Yes, most agreements require tens of thousands of tons in annual reductions of SO₂, NOx, and VOCs.
Can citizens sue refineries? Yes, under the Clean Air Act, communities can file lawsuits, as seen in the Baytown case.
What is the long-term effect? These cases set nationwide compliance standards, improving air quality for millions of Americans.
Conclusion
The top ten EPA refinery lawsuits are more than legal precedents—they are milestones in environmental compliance. They compelled billions in investments, reduced pollution across the U.S., and empowered communities to demand cleaner air. From BP’s global settlement to ExxonMobil’s citizen-suit defeat, these cases have shaped the refinery industry and continue to influence how companies, regulators, and communities approach environmental accountability today.