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Foreword

This volume provides an executive summary of work completed

during a voluntary, AMOCO/USEPA Pollution Prevention Project

undertaken at Amoco Oil Company's Yorktown, Virginia Refinery. Overall goals of the Project were to (1) inventory releases of

all pollutants to the environment from the Refinery; (2) develop, evaluate and rank process, maintenance and operating options that

reduce these releases; and (3) identify barriers and incentives

to implementing the alternatives identified.

Special thanks are due to the AMOCO/USEPA Workgroup who provided

Project oversight and direction during this two-year, $2.3

million effort.

In addition, more than 200 people, from 35

organizations participated at various times in this unique Project. Their enthusiasm and contributions are obvious from the

wealth of ideas developed, considered and analyzed.

Their

assistance supports a central belief of this Project:

that

developing effective solutions to complex environmental

management problems will take the best efforts of the many

'partners' in our society.

We extend a personal thanks to all

participants.

Howard Klee, Jr.
Amoco Corporation

Mahesh Podar
USEPA

Amoco/USEPA Pollution Prevention Project

ABSTRACT

In late 1989, Amoco Corporation and the United States Environmental Protection Agency began a voluntary, joint project to study pollution prevention opportunities at an industrial facility. The Amoco/EPA Workgroup, composed of EPA, Amoco and Commonwealth of Virginia staff, agreed to use Amoco Oil Company's refinery at Yorktown, Virginia, 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.
Develop options to reduce selected releases identified.
Rank and prioritize the options based on a variety of
criteria and perspectives.

2.

3.

4.

Identify and evaluate factors such as technical, legislative, regulatory, institutional, permitting, and economic, that impede or encourage pollution prevention.

5.

Enhance participants' knowledge of refinery and regulatory systems.

Project Organization, Staffing, and Budget 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. Peer Review: At the Workgroup's request, EPA arranged for Resources for the Future to assemble a group of outside scientific and technical experts. This Peer Review Group provided evaluation and advice on the Project workplan, sampling, analysis results, and conclusions. Members of this group were paid a small honoraria for their participation. Workshop: A special Workshop, held during March 24-27, 1991 in 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.

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Participants: More than 200 people, 35 organizations, and many disciplines were involved in this Project. This reflected a central belief of this project that solving difficult environmental problems must draw on many of society's "partners."

Cost: Total cost for this project was approximately $2.3 million. Amoco Oil Company provided 70 percent of the funding and EPA the remainder.

Lessons and Results

Refinery Release Inventory

A.

Existing estimates of environmental releases were not
adequate for making a chemical-specific, multi-media,
facility-wide assessment of the Refinery.

B.

A substantial portion of pollution generated at this
refinery is not released to the environment.

C.

The Toxic Release Inventory database does not adequately
characterize releases from this Refinery.

D.

site specific features, determined during the facility-wide assessment, affect releases and release management options.

Reducing Releases

A.

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 either
EPA or industry alone would do.

B.

Pollutant: release management frequently involves the
transfer or conversion of pollutants from one form or medium
to another.

C.

Although the Refinery is highly efficient in handling materials (currently recovering 99.7 percent of its feedstock in products and fuel), four source reduction options identified show positive rates of return ranging from one to nineteen percent.

D.

Source reduction is not necessarily practical for all release management options, despite its cost effectiveness. Effective release management requires a combination of source reduction, recycling; treatment and safe disposal.

Choosing Alternatives

A.

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.

B.

Obstacles and Incentives to Implementing Pollution Prevention
A. 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.

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.

B.

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.

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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.

D.

Inadequate accounting for both the benefits and costs of environmental legislation and regulations is an obstacle to developing a more efficient environmental management system.

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