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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.

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Improve Environmental Release Data collection, Analysis and Management.

Provide Incentives for conducting Facility-wide
Assessments, and Developing multi-media Release Reduction
strategies. Such strategies must consider the Multi-
Media consequences of Environmental Management Decisions.

4.

Encourage Additional Public/Private Partnerships on
Environmental Management.

5.

Conduct Research on the Potential Health and Ecological
Effects of VOCS.

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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:

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.

Rank and prioritize the options using a variety of
criteria and perspectives.
Identify and evaluate factors such as technical,
legislative, regulatory, institutional, permitting, and
economic, that impede or invite pollution prevention.

4.

5. Enhance participants' knowledge of refinery and

regulatory systems.

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. The Project workplan outlined the purpose and content for most of these components (Amoco/EPA, 1990).

Exclusions/Limitations: 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
releases rather than measured annual values.

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
exploring innovative techniques for reducing releases.

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
potential cancer risks associated with benzene exposure
outside the facility fenceline.

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. Appendix c lists all Project documentation.

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, 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. The Workshop sessions resulted in suggestions that further refined and directed Project activities (Amoco/EPA, 1991a).

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.

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A.

Existing estimates of environmental releases were not
adequate for making a chenical-specific, multi-nedia,
facility-vide assessment.

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The Yorktown Refinery had good information about the quantity of material released to the York River from NPDES Permit monitoring requirements, and for solid wastes as a result of internal programs and participation in recent American Petroleum Institute surveys (API, 1991b). These releases, however, made up only 11 percent of the total releases from the facility. Available data did not include adequate chemical-specific characterization of the water discharge or solid waste streams.

The Refinery (and other refineries as well) could not easily identify specific airborne hydrocarbon compounds released or the quantity released because:

(a)

Refineries typically do not manufacture products with
specific chemical compositions, and therefore do not
routinely measure chemical compositions of their
products or emissions. Rather, refinery products
have specific properties such as octane, freeze
point, and sulfur content. Crude oil, the raw
material used to make these products, contains
thousands of distinct chemicals that are never fully
separated during the manufacturing processes.
Airborne releases from this kind of facility are
similarly complex.

(b)

Most hydrocarbons are released through a large number
of widely distributed sources (valves, flanges, pump
seals and tank vents). Even a small refinery may
have more than 10,000 potentially different sources.
Direct measurement of each of these sources is not
practical.

(c) The quantities released through any single source are

extremely small--on the order of pounds per
year--dilute and difficult to measure. In addition,
some large sources that emit pollutants in the amount
of tons per year are difficult to measure and
quantify. Total hydrocarbons released from Yorktown
Refinery from all sources were approximately 0.3
weight percent of the total crude oil processed.
Therefore, they would not be detected through normal

mass balances and materials accounting (NRC, 1990). Thus, collecting detailed, chemical specific release information used to characterize the Refinery was expensive and time consuming. This Project developed a sampling and monitoring program that included about 1,000 samples (see Figure 2.2). Each sample was analyzed for 15-20 chemicals. The sampling program took about 12 months to complete at a cost of about $1 million. Even with this time and dollar commitment, only selected sources were sampled. The final release inventory was assembled using a

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