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The study provided an opportunity to educate individuals within EPA and Amoco. Based on plant visits and information exchanges, EPA personnel better understand how a refinery works, the complexities of the refining processes, and the difficulties in obtaining reliable environmental release data. This improved understanding will be useful as the Agency considers future data needs for regulatory development and permits.

Similarly, Amoco personnel better understand how EPA develops regulations, the type of information needed, and the Agency's operating constraints. This will be useful for Amoco in interacting with EPA and other government agencies.

The detailed release information developed in this Project could be useful to all three media offices: air, water, and solid waste.

The Office of Air and Radiation may be able to use air
monitoring and modeling information for developing MACT
standards and improving emission factors.

The Office of Solid Waste should be able to use sampling and monitoring information for characterizing RCRA Subtitle D wastes and management practices.

The Office of Water should be able to use wastewater sampling information to evaluate Petroleum Refining effluent

guidelines, and the biomarkers research results in evaluating aquatic health measurement tools.

The working relationships between various EPA offices, State and Amoco personnel were quite fragile when the Project began. Individuals brought their institutional viewpoints to initial discussions. By agreeing at the beginning of the Project that we may not necessarily agree with all findings and conclusions, people showed a willingness to discuss issues and focus on data and factual information. Many of the perceived and real differences in views were more easily dealt with in a factual setting.

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Explore Opportunities to Produce Better
Environmental Results More Cost-effectively.

Data from this study show that the Refinery can meet a release reduction goal more cost-effectively than by meeting reductions prescribed by current regulatory or legislative requirements.

For example, the ranking analysis shows that given the opportunity the Refinery could remove about 97 percent of tons of airborne hydrocarbons at about 25 percent of the cost of reducing

them under current and anticipated regulations. The costeffectiveness of the flexible option is about $600/ton compared with the cost-effectiveness of $2,400/ton for regulatory requirements.

EPA might evaluate options for setting a goal or target for reducing multi-media releases from a facility, and then allow the facility to develop an alternative compliance strategy to meet the goal. This alternative strategy would allow the facility to meet the goal at a lower cost, include interim milestones, and be enforceable. This strategy would also make appropriate information available to ensure that the reduction targets will be met.

This strategy might also include commitments to other environmental improvements such as cogeneration, additional reductions in releases, wetlands restoration, wildlife habitat enhancement, creation of new wetlands, controls on nonpoint sources of pollution, improved environmental data collection and research. The cost savings realized from meeting requirements under a more flexible approach make it possible to realize additional environmental benefits which are presently foregone because of the high costs of many regulatory programs.


Improve Environmental Release Data Collection,
Analysis and Management.

Data from this study show that an emissions inventory could be improved by measuring releases and developing new emission

For example, the emissions inventory at the beginning of the project did not account for all potential releases to the environment. Some releases were excluded because the Agency has excluded them from reporting (e.g., barge loading operations); some releases were not included because the sources and the amount were thought by Amoco to be insignificant (e.g., blowdown stacks); some emissions were overestimated (e.g., API Separator); and some releases were underestimated (e.g., coker pond). Jointly established sampling and analysis protocols could help improve data quality, so that reported values more accurately portray facility releases.

Data currently collected in response to regulatory or permitting requirements could be evaluated to determine how its utility and quality might be improved. For example, TRI data quality and utility could be improved by:

Providing more inclusive estimates of facility-wide releases to all media. The Project found the exclusion of marine loading operations from TRI reporting requirements conveyed an inaccurate picture of total facility releases.

Reporting groups of chemicals, rather than individual
species, especially if these chemicals have similar
structural, physical and toxicological properties.
Requiring reporting of all VOCs for refineries, rather than
specific compounds like xylene (and its individual isomers),
would provide a meaningful measure of refinery releases.
That is because xylene poses approximately the same risks
and has physical characteristics similar to the hundred of
undifferentiated VOC compounds not covered in TRI.

refinery, where a complex mixture of chemicals are released
from most sources, tracking many separate chemicals does not
make good use of technical, laboratory, and environmental
management resources.

Reporting other selected chemicals of concern for demonstrated human health or ecological impact separately. At a refinery, chemicals such as butadiene, benzene, and nickel may be good indicators of risk/release potential and management practices. Other industrial sectors would need to track different specific chemicals.

Improving emission factors for estimating releases based upon information developed in this project, and additional work by EPA/industry task groups that could focus on the different data collection needs of discrete industry sectors.

The Project had great difficulty collecting and verifying environmental release data from the site. Emissions from these sources are complex and measurement techniques are rudimentary. Many emission measurements varied with time. For example, the Coker pond emissions varied by a factor of three within a few hours. Better sampling and analysis methods and statistical tools are needed to analyze variability. Research is also needed to develop methods that can verify release inventories within reasonable confidence limits, accounting for specific differences in emissions factors.


Provide Incentives for Conducting Facility-wide
Assessments, and Developing multi-media Release
Reduction Strategies. Such Strategies should
Consider Multi-Media Consequences of Environmental
Management Decisions.

This Project demonstrates that more cost-effective environmental protection programs can be designed by allowing companies to consider site specific factors and focus on results.

A detailed facility-wide, multi-media assessment identified the most significant medium (air) and releases sources, both in terms of quantity and impact on the surrounding area. Specific

technology options were then developed to deal with these The significance of sources identified in this Project were not initially known or apparent to the participants. Proposed solutions could not have been developed in the absence of data which identified their importance.

For example, hydrocarbon emissions from barge loading operations (784 tons annually) and blowdown stacks (5,200 tons annually) are significant. However, the Refinery did not know this prior to this Project, nor did the existing regulations require the collection of this data. Thus, it did not develop control options to reduce these emissions.

Several technologies considered for reducing releases, transfer pollutants from one medium to another or convert pollutants to different forms. Since human health and environmental consequences vary from one medium to another, viewing a release problem in the context of net environmental effects is essential to developing more sound solutions.

The current institutional framework and procedures for developing regulations do not include multi-media assessments and analysis. Current practices should be reviewed to determine how they could be modified to use information from such assessments. An integrated pollution prevention and management strategy would facilitate development of release management options that produce better environmental results. (EPA/SAB, 1990a; EPA/SAB, 1990b; OMB, 1991)

At present, industry has little incentive to conduct such assessments because it does not have an opportunity to implement their findings.


Encourage Additional Public/Private Partnerships

on Environmental Management.

The Yorktown experience demonstrates the opportunities and pitfalls that can occur when government and industry work together. The opportunities are significant. The pitfalls are worth overcoming. All organizations--EPA, Virginia and Amoco-sought to develop and test innovative environmental management approaches that, unlike most traditional "command and control" approaches, consider risk reduction, address multi-media concerns, maximize environmental benefits, encourage efficient use of resources, and promote facility-specific implementation choices. While it will take time and patience to overcome decades of distrust, such joint government/industry efforts can result in more cost-effective environmental protection by providing the opportunity to share different viewpoints and skills.

In this study, for example, EPA brought expertise on the type of information needed to develop regulations, and their operating constraints, while Amoco brought an understanding of refinery operations and economics. By helping to educate each other and develop a mutual understanding of issues and technology, Amoco, EPA and the Commonwealth of Virginia together agreed on the most significant emissions from the Refinery and the most promising approaches to reducing them.

Public/Private partnerships could also be used to leverage Agency resources for providing improved data needed to develop regulations. This Project illustrates a possible approach to collecting data, assessing technologies and characterizing a facility within an industry that took less time and Agency resources but relied more on private support.


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

The Refinery is a major source of the area's VOC emissions. However, information on the potential adverse health effects of VOC emissions is rather limited (Graham, 1991). Research is needed to better characterize health and ecological effects of VOCs that can be used in conducting risk assessments. This study could also build on efforts currently underway at the American Petroleum Institute, and the Chemical Industry Institute of Toxicology (CIIT) and others.

EPA should also undertake research to develop indicators that measure impacts on the ecosystem of multi-media releases from industrial facilities. This Project looked at several biomarkers that show promise as indicators in aquatic environments. information and methods for assessing ecological risk limits the ability to conduct comprehensive risk assessments, and measure changes in environmental quality.

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