Regulatory Requirements and Project Options

As indicated in Table X, 8 of the 12 project options would, if implemented, contribute to meeting current or anticipated regulatory and statutory program requirements. Legal requirements dictate that these options or an equivalent be undertaken at the refinery. The characteristics of these 8 options are summarized in Table XTV, 

For purposes of comparison, an analysis was conducted to assess what options might be selected to achieve comparable release reduction and exposure reduction objectives in the absence of the existing regulatory constraints. To avoid double counting in this analysis, a specific alternative was selected for those options involving multiple alternatives. The alternative options selected were 3b for FCU fines recovery, 5c for secondary seals, and lib for LDAR. The goal in this analysis was to attain the desired environmental targets— release reduction or exposure reduction—at a lesser cost. 

The 12 options are ranked in Table XV with respect to cost effectiveness of release reduction, expressed in dollars per ton. The results indicate that five options—11b, Quarterly LDAR 5c, Secondary Seals on Storage Tanks 7a, Blowdown System Upgrade 6, Soils Control and 8, Modify Sampling—are the most cost effective with regard to release reduction. Taken together, these five options attain a release reduction of 6700 tons of hydrocarbons and hazardous solid waste per year at an annual cost of 2.2 million. Note that while soils control is a good pollution prevention option since it prevents the generation of hazardous waste, it 

Cost-Effective Benzene Exposure Reduction Ranking 

A similar analysis is shown for exposure reduction in Table XVI. In this case, six options—5c, Secondary Seals on Storage Tanks 9, Barge Loading 11b, Quarterly LDAR 7a, Blowdown System Upgrade 4, Eliminate Coker Pond and 1, Reroute Desalter—are much more cost effective than the next two options in terms of benzene exposure reduction. The six options collectively attain 90% benzene exposure reduction of the full set of eight regulatory requirements at about 20% of the annual cost. Four options achieve no reduction in benzene exposure. 

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