Options for Reducing Total Releases

Amoco/EPA Project Pollution Prevention Option Characteristics 

The ranking analysis discussed in the remainder of this section used benzene exposure at a nearby residence as a proxy for the risk associated with population exposure to refinery releases. In Table X, the share each option represents of the total benzene exposure reduction achieved by implementing all options is given in the column labeled Benzene exposure reduction. The barge loading option accounts for 55% of the benzene exposure reduction attributable to all options. In cost-effectiveness terms, the cost for a 1% benzene exposure reduction ranges from 9000 for secondary seals to 1.48 million for upgrading the wastewater treatment plant. 

The statutory requirements addressed by each option are identified in the seventh column of Table X titled Statutory program. The specified compliance dates for each statutory program are also shown in the table, as are the implementation times for each option. Since the maximum achievable control technology (MACT) requirements have not yet been specified by EPA, projects directed toward those requirements have not yet been undertaken. That being the case, the implementation times identified indicate that options 5, 8, and 9 may have difficulty achieving timely compliance with these regulatory requirements. To proceed with the analysis, requirements that might be imposed under MACT were hypothesized to specify the performance characteristics of the associated pollution prevention options. It should be noted that only those options related with compliance with the Benzene Waste NESHAP (National Emissions Standard for 

Hazardous Air Pollutants) requirements deal specifically with benzene release options other rules address emissions of hydrocarbon and VOCs, not only benzene. 

The project s Peer Review Committee suggested the options be ranked according to a single criterion risk reduction. In addition to risk reduction, two other single criterion rankings are of interest total tonnage reduction and cost. 

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