Building a 10 Year Oily Water Sewer Integrity Plan Under an EPA Consent Decree
Overview
A major U.S. refinery was operating under an EPA consent decree involving a $40 million penalty and approximately $250 million in potential exposure. The facility had hundreds of aging oily water sewer lines but no systemwide plan for determining which lines should be inspected, rehabilitated, monitored, or deferred.
The scale of the system made it impractical to address every line at once. Motivo analyzed the available system data, developed a System Prioritization Plan, and created a 10 year inspection, rehabilitation, and budget roadmap.
The Challenge
The refinery’s oily water sewer system included hundreds of buried lines in varying conditions. Some had known problems or histories of failure, while many others had limited inspection records. Without a consistent method for comparing them, the facility was forced to respond to the most visible problem rather than the greatest overall risk.
The consent decree increased the urgency. The refinery needed to demonstrate that it understood the condition and risk of the system and had a defensible plan for addressing it. Inspecting or replacing every line immediately would have been financially and operationally unrealistic, but continuing with reactive repairs would not provide the structure needed to manage compliance.
The Approach
Motivo gathered and organized the available information about the oily water sewer system, including infrastructure characteristics, operating history, known failures, and the potential consequences associated with each line.
The team then developed a System Prioritization Plan that compared the relative likelihood and consequence of failure across the system. Rather than treating every line as equally urgent, the plan created a consistent way to identify the lines requiring near term attention and separate them from those that could be inspected or addressed later.
The results were converted into a prioritized 10 year roadmap. The plan established when lines should be inspected, when rehabilitation should be anticipated, and how the work could be distributed across future annual budgets.
Why a System Prioritization Plan Was the Right Approach
The refinery did not need another list of aging pipes. It needed a practical order of work.
The System Prioritization Plan allowed the facility to focus first on the lines with the greatest combination of failure likelihood and consequence. Lower priority lines could be monitored or scheduled later, while the highest priority lines could move into inspection and rehabilitation planning. This gave the refinery a documented basis for its decisions and allowed limited resources to be directed toward the areas where they would reduce the most risk.
The Result
Motivo established a defensible oily water sewer integrity program that supported the refinery’s EPA compliance obligations. The facility moved from responding to individual failures toward managing the buried system through a structured, long term plan.
The 10 year roadmap also gave the refinery greater visibility into future spending. Instead of facing unpredictable emergency projects, the facility could anticipate inspection and rehabilitation needs and incorporate them into annual planning and budgeting.
A Practical Model for Large Buried Pipe Systems
Facilities with hundreds of aging buried lines often know that problems exist but do not know where to begin. Inspecting every line at once may be unrealistic, while waiting for visible failures can increase environmental, operational, and financial exposure.
A System Prioritization Plan provides a practical starting point. By organizing existing information and comparing the relative priority of each line, a facility can build a phased inspection and rehabilitation plan without waiting for the entire system to fail.
Learn more about our System Prioritization Plan (SPP) capability