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releases and improving environmental quality would have been unnecessarily restricted.

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. The 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 pet cost savings to the Refinery.

The Refinery is relatively efficient in managing materials.

An 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.

1.3.3 Choosing alternatives

A.

Ranking the options showed that better environmental results can be obtained more cost-effectively.

Compliance with current and anticipated regulations requires controls for eight sources types, reducing airborne hydrocarbon releases by 7,300 tons/year at an average cost of $2,400/ton. The Refinery could reduce about 7,100 tons of airborne hydrocarbons each year (or about 97 percent) by controlling six sources at about 25 percent of the cost. This cost-effectiveness comparison does not account for possible benefits to other media.

If allowed to address both hydrocarbons and listed hazardous waste, the Refinery could reduce about 7,500 tons per year at an average cost of about $500/ton using its choice of sources and techniques. Table 1.3 provides a more detailed comparison of different Release Management Strategies, results and costs.

These results are all the more significant because the options evaluated were neither selected nor developed ahead of time with a target reduction goal in mind. Nor did the selection process have a goal of meeting regulatory requirements in some alternative fashion. This suggests that even more impressive results might be achieved, if that were the focal point at the beginning.

All participants agreed on which options were the most effective and which were least, regardless of their ranking criteria or institutional viewpoints.

The Project used a multi-dimensional prioritizing process (the Analytical hierarchy Process, AHP) in which weights were developed for all criteria used to rank alternatives. These criteria included cost, release reduction, timeliness and changes in benzene exposure, among others. The process allowed the Workgroup to assess the significance of and interactions between criteria--how changes in one criterion affect other criteria and total rankings.

All options were considered legally acceptable, and no specific regulatory requirements were imposed on the decision making process. Although different organizations brought different perspectives to the discussions, each organization reached the same conclusions about which options would be most effective and which were least. The driving forces in this prioritization were cost and relative risk reduction, as measured by benzene exposure. A variety of sensitivity studies confirmed this initial set of preferences.

Amoco ranked control of marine loading losses as the most effective--though not the lowest cost--option. A second tier of options included installing secondary seals on tanks, instituting a leak detection and repair program, and upgrading blowdown stacks. All four were also viewed as reasonably effective pollution prevention projects. In total these four projects would prevent or capture almost 6,900 tons of releases annually

at a cost of about $510/ton. EPA and Virginia selected the same five options, in this hypothetical case with no specific regulatory requirements. See Items 4 and 5 in Table 1.3. 1.3.4 Obstacles and Incentives to Implementing Pollution

Prevention

After identifying several alternative environmental management options, it is reasonable to ask why these options are not being implemented. What can be done to encourage their use? The following discussion summarizes the general findings based on an assessment of potential obstacles and incentives for implementing five highly ranked options. For more details, see Section 5.0.

A.

EPA does not have an explicit policy goal and may not have
the statutory authority to simply set a release reduction
"target" without prescribing how this target should or could

When the target involves releases in multiple media, current administrative procedures discourage a coordinated approach, including evaluating risks, costs and benefits of managing residual pollutants in different media.

Requirements under many statutes and regulations prescribe how release reductions should be achieved, sometimes in terms of which technology should be used, often in terms of which specific sources should be controlled. For example, the Benzene Waste Operations NESHAP focuses on a specific emissions source to a single medium--benzene emissions from wastewater. The rule requires control of benzene emissions from this single source.

Data from this refinery indicated that wastewater is a small contributor to total benzene releases. Amoco and EPA disagree about some of the specific measurements and results. These are discussed in detail in Air Quality Data, Volume II (Amoco/EPA 1992b).

A number of pollution prevention approaches developed in this Project are more effective in controlling benzene emissions, and less costly to implement than the benzene NESHAP. refineries might find other sources that present more costeffective control opportunities. Focusing on individual sources, rather than on desired overall "performance," limits the ability to achieve the most cost-effective control.

RCRA requires application of the Best Demonstrated Available Technology (BDAT) to a hazardous waste before it can be disposed. BDAT standards are typically based on a destruction technology rather than on methods at the higher end of the pollution prevention hierarchy.

One proposal now before Congress (S. 1081) to reauthorize the Clean Water Act would amend 304 (b) of the Act and require EPA to

promulgate effluent guidelines which reflect the application of best available control technology (BAT) for all categories of pollutants. This Congressional proposal, which does not reflect the Administration's position, could limit the Agency's ability to set environmental protection priorities.

Legislative and regulatory programs do not provide implementation schedules compatible with design, engineering, and construction timeframes.

Most regulatory and statutory programs require compliance within six months to at most three years after promulgation of a final rule. In some cases, compliance requirements do not consider normal maintenance schedules and economic penalties associated with facility-wide shutdowns. Consequently, short-term "fixes" which can meet legal deadlines, are used at the expense of more cost- and environmentally effective, long-term solutions.

A typical refinery project for processing oil using established technology and design procedures, normally takes 2-3 years from initial design to startup, assuming there is agreement on what to build, no unusual equipment delivery problems, no additional safety considerations, and no prolonged startup difficulties. Many projects take longer when regulatory applicability, scope or design criteria are unclear, or new technologies are involved.

For example, the benzene NESHAP rule discussed above was promulgated in March 1990 (under the 1977 Clean Air Act Amendments). Statutory language required compliance with the regulations within two years. In this case, significant differences in interpretation between EPA and the regulated community took more than one year to resolve and to clarify the regulatory requirements. An acceptable understanding is a prerequisite to engineering and construction. It was physically impossible to design, engineer, procure, construct, and start up the required control within the remaining one year compliance time frame.

Congress, EPA and much of industry have become used to command-and-control, end-of-pipe treatment approaches based on twenty years of experience. These well established problem solving approaches are difficult to change.

In the 1970's, environmental regulations successfully helped reduce point source emissions to air and water.End of pipe treatment was successful partly because many industrial firms and permitting authorities had little experience dealing with these problems, and found the specification of technical solutions offered a "road-map" for how to proceed along an uncharted course. These requirements also provided a relatively "level playing field" for us industry. Many of today's problems are

sufficiently different than those of the early 1970's that they can benefit from alternative approaches.

The short time taken by the Virginia Air Pollution Control Board to issue or modify air permits is not a deterrent to installing technologies to reduce airborne emission at this site,

Most of the technical options would reduce air releases at the Refinery. However, obtaining permits to install most of these technologies would probably not be a problem since the Virginia Air Pollution Control Board is estimated to take about six months to issue a permit (Virginia is a delegated state for issuing air permits). However, information generated through a facility-wide multimedia assessment is a necessary first step to not only developing a strategy to reduce these releases, but also to exploring such implementation options as integrated permits.

E.

Inadequate accounting for both the benefits and costs of environmental 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.

At many industrial plants, such as Amoco's, waste management costs are frequently charged to a central environmental management division rather than to the operating unit that generates the waste. Remediation costs for clean-up of contaminated soil, for example, are frequently charged against another cost center, rather than to the generator of the contamination. This separation between release generation and costs is a disincentive to manage releases more effectively. Few EPA accounting systems measure direct benefits of the Agency's activities, such as improved ecological health, biodiversity, reduced risk to human populations, etc. Rather, accomplishments are usually measured in terms of activities such as permits written, amount of fines collected, or number of enforcement actions pursued. (GAO, 1991) The lack of direct connection between Agency activities and environmental results reduces accountability for program costs and benefits. Without adequate measurement systems, it is difficult to tell when environmental management practices actually improve the environment.

1.3.5.

Education/Communications/Working Relationships

This Project enhanced knowledge of both government and industry, and generated information that EPA and Amoco can use.

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