Choosing Alternatives A. B. Ranking the options showed that better environmental results can be obtained more cost-effectively. At this facility, about 97 percent of the release reductions that regulatory and statutory programs require can be achieved for about 25 percent of today's cost for these programs. Table 1.3 summarizes several management options. These savings could be achieved if a facility-wide release reduction target existed, if statutes and regulations did not prescribe the methods to use, and if facility operators could determine the best approach to reach that target. All participants agreed on which options were the most effective and which were least, regardless of their institutional viewpoints and preferred ranking criteria. Obstacles and Incentives to Implementing Pollution Prevention EPA does not have the policy goal and may not have the statutory authority to simply set an emissions reduction "target" without prescribing how this target should or could be met. Current administrative procedures discourage such an approach, including the analysis of tradeoffs in risks, benefits, and costs of managing residual pollutants in different media. A. B. C. D. The Agency is required to implement media-specific legislation enacted by Congress. In addition, EPA does not have the technical and analytical skills to determine if multi-media, facility-wide reduction plans are meeting the requirements established in single medium-specific legislation. This would make compliance monitoring and enforcement more difficult than present approaches. Many legislative and regulatory programs do not provide implementation schedules compatible with design, engineering, and construction timeframes. Consequently, short-term "fixes" which meet legal deadlines are used at the expense of more cost- and environmentally effective, long-term, solutions. Well established problem-solving approaches are difficult to change. Congress, EPA, and much of industry are used to command-and-control, end-of-pipe treatment approaches based on twenty years of experience. Many of today's problems could benefit from a different approach. Inadequate accounting for both the benefits and costs of environmental legislation and regulations is an obstacle to developing a more efficient environmental management system. Responsibility for pollutant generation and accountability for environmental protection are difficult to quantify. Recommendations 1. Explore Opportunities to Produce Better Environmental Results More Cost-effectively. 2. 3. 5. Improve Environmental Release Data Collection, Analysis Provide Incentives for Conducting Facility-wide Conduct Research on the Potential Health and Ecological SUMMARY 1.1 Project Goals In late 1989, Amoco Corporation (Amoco) and the United States Environmental Protection Agency (EPA) began a voluntary, joint project to study pollution prevention opportunities at an industrial facility. The Amoco/EPA workgroup (Workgroup), composed of EPA, Amoco, and Commonwealth of Virginia staff, agreed to use Amoco Oil Company's refinery at Yorktown, Virginia (the Refinery), to conduct a multi-media assessment of releases to the environment, then to develop and evaluate options to reduce these releases. The Workgroup identified five tasks for this study: 1. Inventory refinery releases to the environment to define their chemical type, quantity, source, and medium of release. 2. Develop options to reduce selected releases identified. 3. 4. 5. Rank and prioritize the options using a variety of Identify and evaluate factors such as technical, Enhance participants' knowledge of refinery and Figure 3.1 shows a schematic diagram of the Refinery, potential release sources, and a number of pollution prevention options identified in this Project. Table 3.2 describes specific options to reduce releases. At the time this Project began, pollution prevention was a concept predicated on reducing or eliminating releases of materials into the environment rather than managing the releases later. The Workgroup adopted this general concept and agreed to consider all opportunities--source reduction, recycling, treatment, and environmentally sound disposal--as potential choices in pollution management. Since then, Congress, in the Pollution Prevention Act of 1990, and other organizations, have put greater emphasis on source reduction as the primary, if not the exclusive, means to accomplish pollution prevention. A central goal of this Project was to identify criteria and develop a ranking system for prioritizing environmental management opportunities that recognized a variety of factors including release reduction, technical feasibility, cost, environmental impact, human health risk, and risk reduction potential. Due to the inherent uncertainties in risk assessments, the Project focused on relative changes in risk compared to current levels, rather than establishing absolute risk levels. Because of difficulties in quantifying changes in ecological impact from airborne emissions, changes in relative risk were based primarily on human health effects indicated by changes in exposure to benzene. The risk assessment did not include a quantitative analysis of VOCs due to limited information on their health effects. This project focused on pollution and potential risks posed by normal operation of the Refinery and chronic exposure to its releases into the environment. Minimizing emergency and upset events is a top priority of Amoco's facility managers. Such events can have catastrophic results. However, they were not studied in this project because: (a) prevention and control of such events involves significantly different skills, technical resources, and analyses than controlling releases from day-to-day operations (AIChE, 1985); (b) the number, type, and frequency of incidents at Yorktown is very low; and (c) data regarding the type of release, and relevant meteorology during the release are not available for analysis. Appendix D describes potential emergency and upset events that might occur at a petroleum refinery and the general preventative measures used to minimize their severity and the likelihood of their occurrence. 1.2 Project Organization, Staffing and Budget Project Content: The Pollution Prevention Project has many components. Each component defines and addresses an issue associated with pollution prevention and facility management choices. These include pollutant source identification, sampling, exposure modeling, risk assessment, etc. Table 1.1 provides a complete list of the components in this Project. Project workplan outlined the purpose and content for most of these components (Amoco/EPA, 1990). Exclusions/Limitations: The A number of areas specifically excluded or limited in this Project are described in Appendix B. Some are listed below: Limited sampling time and data provided a "snapshot" of Very few generally accepted methodologies exist for the sampling used to obtain a site-wide release inventory, particularly for measuring air emissions. Both EPA and Amoco concerns about specific sampling issues are highlighted in Appendix B and discussed in more detail in Air Quality Data, Volume II (Amoco/EPA, 1992 b). The Project considered available technologies rather than • Chemical changes of airborne pollutants were not evaluated. Data and analysis focused on the Yorktown Refinery. Sitespecific features of this facility and its emissions may not apply to other refineries. Broader regional concerns were not evaluated. The forthcoming human health risk assessment focuses on Peer Review: At the Workgroup's request, Resources for the Future organized a group of outside scientific and technical experts. This Peer Review Group provided evaluation and advice on the Project workplan, sampling, analytical results, and conclusions. Members of this group were paid a small honoraria for their participation and reimbursed for travel expenses to Washington by EPA. A report summarizing their comments is included as part of the documentation for this Project. C lists all Project documentation. Appendix Workgroup: Monthly Workgroup meetings provided Project oversight, a forum for presentations on different Project components, and an opportunity for informal discussion of differing viewpoints about environmental management. Although attendance varied, each meeting included representatives from various EPA offices, the Commonwealth of Virginia, and Amoco. Workshop: A special Workshop, held during March 24-27, 1991, Williamsburg, Virginia, reviewed sampling data and identified reduction options and ranking criteria. More than 120 people from diverse backgrounds--EPA, Amoco, Virginia, academia and public interest groups--attended the Workshop. The Workshop sessions resulted in suggestions that further refined and directed Project activities (Amoco/EPA, 1991a). in Participants: More than 200 people, 35 organizations, and many disciplines have been involved in this Project. Table 1.2 lists the various participating organizations. Cost: Total cost for this Project was approximately $2.3 million. Amoco Oil Company provided 70 percent of the funding and EPA the remainder. A. Existing estimates of environmental releases were not adequate for making a chemical-specific, multi-media, facility-wide assessment. |