2,000 tons/year of biosolids are produced by treating wastewater in the Refinery's activated sludge system. c. The TRI database does not adequately characterize releases from this Refinery. Title III of SARA, Emergency Planning and Community Right-to-Know Act, created the Toxic Release Inventory (TRI) in 1986. Title III requires regulated facilities in SIC Code 20-39 to submit annual release data on more than 300 chemicals manufactured, produced or otherwise used in quantities exceeding certain threshold values. Releases to all media must be reported. TRI is one way of focusing corporate attention on release reduction opportunities. The TRI reports are based on either emission estimates, direct measurements or a combination of both methods. Each facility is responsible for the accuracy of the data reported. Industrial facilities frequently file amendments to TRI reports to reflect improvements in the accuracy of the estimation and measurement techniques. The TRI database has become the de facto national release inventory. The quality and utility of data reported can vary widely. At a plant that uses a single solvent to wash manufactured parts, and that purchases extra solvent every year to make up for evaporative losses, the quantity of solvent emissions is well known and tracked through monthly purchasing records. A TRI report which included this solvent and plant should be quite accurate. However, at the Refinery, the TRI does not report total facility emissions because: The TRI is based on estimates rather than measurements. One The measurement phase of this Project revealed substantially The TRI focuses on specific chemicals which account for only a portion of the total emissions. In the Refinery's case, the TRI report covers only 9 percent of the total hydrocarbons released, and only 2.4 percent of the total releases to all media. Criteria pollutants--CO, NOX, SO2, and PM-10--are not reportable in the TRI. Some activities and emissions are excluded by EPA from record Finally, TRI provides an approximate inventory of selected materials released to the environment. TRI data by itself does not allow for meaningful risk evaluation or comparisons on a facility basis, because it does not define the facility's relationship to nearby populations and ecosystems. D. Site specific features determined during the facility-wide assessment, affect releases and release management options. National programs, by design, address overall problems in specific media. But these programs seldom consider site-specific differences in developing standards. Other refineries, and indeed other industrial facilities, can use the general sampling approach developed here to obtain the facility-wide release inventory. However, each site will exhibit unique geophysical and process characteristics. Each assessment plan must include these site-specific characteristics in its design and focus. As an example, the Yorktown Refinery does not have a hydrofluoric acid (HP) alkylation unit and HF was not measured. HF can pose a significant health risk if managed improperly, and may need to be tracked at facilities that use it. Groundwater: As a result of a clay soil layer, unique hydrogeology, the placement of the underground drainage system relative to the water table, and local climate, groundwater movement at this site is minimal. In fact, the underground drainage system is acting as a groundwater collection unit, sending groundwater to the Refinery's wastewater treatment plant. Thus, groundwater at this site is not leaving the property. Furthermore, sampling showed surprisingly low levels of groundwater contamination, compared to other refineries (LA Times, 1988). Marine Loading Emissions: Yorktown Refinery uses marine transportation for receiving all crude oil and shipping more than 80 percent of its products. Estimated releases from product loading operations are 784 tons/year of VOCs. Computer modeling analysis showed this source had the greatest impact on exposure of nearby residences to Refinery hydrocarbon emissions. Therefore, it would be useful to include marine loading emissions in this facility's environmental management plans. Many other refineries rely more on pipeline, rail and truck shipments to handle crude and products, and would thus not expect to find the same potential impact from marine operations. Airshed Status: As discussed in Appendix A, the Refinery is located in an airshed classified as an attainment area for all criteria pollutants including ozone. Therefore, relatively few hydrocarbon emission controls have been required or installed at this facility. The sampling program and release reduction options focused on hydrocarbon releases. Many other refineries in ozone non-attainment areas have already installed extensive hydrocarbon emission controls. Consequently, other facilities may have a significantly lower percentage of hydrocarbon emissions. Similarly, NOX, CO, PM-10 and SO2 emissions have been more tightly controlled in some other airsheds (such as the Los Angeles basin) which do not meet NAAQS for these pollutants. A. 1.3.2 Release Reduction Options A workshop approach, drawing on a diverse group representing government, industry, academic, environmental and public interests developed a wide range of release reduction options in a multi-media context more quickly than EPA or industry alone would do. The release inventory described in 1.3.1 above, served as the basis for identifying ways to reduce releases. A 3-day brainstorming Workshop, held in Williamsburg, Virginia generated more than 50 potential release reduction options for the Refinery. These ranged from producing a single grade of gasoline to specific technical options for particular equipment or processes. Table 3.1 lists all options identified. The Workgroup subsequently narrowed this list to 12 options for more careful, quantitative analysis. This winnowing process considered only those options that were technically feasible now, offered potentially large release reductions, addressed different environmental media, and posed no process or worker safety problems. Projects designed to comply with several current or anticipated regulations were also included. Table 3.2 lists engineering projects included for further analysis. The Workshop also addressed screening criteria to help prioritize the options, potential barriers and incentives for implementation, and permitting concerns. The diverse viewpoints brought to all these discussions helped guide subsequent Project activities. These views reinforced the Workgroup's desire to consider broader issues such as multi-media release management consequences, future liability impacts, etc. The Workshop was able to consider these issues more comprehensively than either government or industry alone would normally do. B. Release management frequently involves the transfer or conversion of pollutants from one form or medium to another. It is not at all unusual for pollutants to be converted and transferred from one form or media to another as part of a pollution control practice. For example, scrubbers used to remove acidic pollutants from many electric utility stacks generate large volumes of calcium sulfate sludge (EPRI, 1983) which must also be managed. For options developed at the Yorktown Refinery: Modifications of the underground drainage system and process water treatment plant (required under the Benzene Waste Operations NESHAP; Federal Register, 1990) will improve process water treatment and reduce air emissions, but produce more solid waste such as biosolids and fully spent activated carbon. The Refinery has limited sludge processing capacity. Keeping soils out of sewers would reduce the amount of sludge in the API Separator and thus allow for more on-site management of other solid wastes, reducing offsite disposal. Installing an electrostatic precipitator would reduce FCU particulate (PM-10) emissions (catalyst fines), but transfer the additional collected particulates to land disposal. Burning hydrocarbons that cannot be economically recovered generates other criteria pollutants which may also need to be managed. None of these transfers or transformations are bad, in and of themselves. The Project simply pointed out the need to recognize, plan, and manage these changes at an early stage of the release management cycle. c. Source reduction options were more cost-effective than most treatment and disposal alternatives. Nevertheless, source reduction alone was not adequate to achieve all the desired or legally required release reductions. The Workgroup agreed to consider the waste management hierarchy--source reduction, recycling, treatment, and safe disposal--as the basis for developing release reduction options. Technologies identified and analyzed fit into this hierarchy. Time and budget constraints limited technology choices to conventional, proven solutions rather than exploring innovative alternatives. However, less than half the options identified qualified as "source reduction." Had the options been limited to only source reduction, the scope of potential opportunities for reducing releases and improving environmental quality would have been unnecessarily restricted. The If all source reduction options identified in this Project were implemented, benzene and total hydrocarbon emissions would be reduced by about 25 percent and 16 percent, respectively. Workgroup concluded that a cost-effective strategy for the Refinery would have to include a mix of source reduction, recycling, treatment and disposal options. of the source reduction options considered, most appear to be significantly lower cost than recycling, treatment, and disposal. Source reduction options considered have had an average cost of $650/ton of pollutant recovered. The remaining seven options analyzed had an average cost of $3,200/ton, nearly 5 times higher. The cost-effectiveness of individual options varied form a low of $190/ton for secondary seals on gasoline storage tanks to a high of $128,000/ton for the treatment plant upgrade. D. While release reductions do not always pay for themselves, some environmental improvements can be made at a net cost savings to the Refinery. An The Refinery is relatively efficient in managing materials. ongoing weight-loss management program to capture lost material has been in place at all Amoco refineries for a number of years. Approximately 99.7 percent of the incoming crude is converted to useful products and refinery fuel. The hydrocarbon release reduction options identified in this Project dealt with the remaining 0.3 percent. Despite the relative efficiency of the Refinery, two source reduction options--seals on gasoline tanks and a leak detection and repair program--have net cost savings and a positive rate of return. Amoco did not know this before this Project. On the other hand, some of the source reduction options and all treatment options were not economic investments for the Refinery. For example, fitting all fixed roof storage tanks with secondary seals would result in much higher cost for relatively little additional reduction in hydrocarbon emissions compared to fitting only gasoline storage tanks. Treatment options generally require significant capital outlays with no return in the form of recaptured or improved product. Technology options with positive rates of return are shown in Figure 3.9. Options that have negative return are not shown. A. 1.3.3 Choosing Alternatives Ranking the options showed that better environmental results can be obtained more cost-effectively. |