267 



novel regulatory approaches could be tested and companies could come forward with 

 their own innovative approaches, as long as the end result is just as good or better 

 for the environment." 



In The Greening of America 's Taxes: Pollution Charges and Environmental Pro- 

 action, Harvard University Assistant Professor Robert Stavins concludes that 

 "Command and control rules can hamper technological innovation by locking firms 

 into outdated pollution control equipment. They ignore important differences among 

 individuals, firms, and regions." 



With or without a legislative mandate, the EPA or Department of the Environ- 

 ment should pursue further demonstration projects where the following can be eval- 

 uated: 



(1) the extent that regulatory incentives, such as the modification of the require- 

 ments imposed by terms of all or part of any permit, can be more effective in pre- 

 venting pollution than current regulations allow. For example, investigate instances 

 where control of all sources of emissions at a facility could be more cost-effective 

 than mere compliance with facility permit requirements. 



(2) that greater net protection of human health and the environment can be ob- 

 tained by preventing pollution rather than by controlling pollution after it is gener- 

 ated, i.e., focus resources on pollution prevention efforts rather than on prescriptive 

 pollution control. 



(3) whether a multi-media approach to facility permitting will be more effective in 

 reducing the overall risk from a facility, and whether a multi-media permit ap- 

 proach will be more likely to ensure that environmental risks are not shifted from 

 one medium to another. 



These demonstration projects may require an amendment to the Pollution Pre- 

 vention Act. However, Amoco would be willing to work with Ck)ngress and the EPA 

 or Department of the Environment to pursue the appropriate legal mechanisms. 



rV. Conclusion 



Amoco appreciates the opportunity to provide comments on S. 171. As demonstrat- 

 ed by Amoco 's involvement with the EPA in the cooperative study at the Yorktown 

 refinery, Amoco is committed to protecting human health and the environment, and 

 continually strives to ensure that our investments benefit both our environment 

 and our economy. 



March 2, 1993 



Amoco/USEPA Pollution Prevention Project 



EXECUTIVE SUMMARY 



In late 1989, Amoco Corporation and the United States Environmental Protection 

 Agency began a voluntary, joint project to study pollution prevention opportunities 

 at an industrial facility. The Amoco/EPA Workgroup, composed of EPA, Amoco and 

 Commonwealth of Virginia staff, agreed to use Amoco Oil Company's refinery at 

 Yorktown, Virginia, to conduct a multi-media assessment of releases to the environ- 

 ment, then to develop and evaluate options to reduce these releases. The Workgroup 

 identified five tasks for this study: 



1. 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. 



3. Rank and prioritize the options based on a variety of criteria and perspectives. 



4. Identify and evaluate factors such as technical, legislative, regulatory, institu- 

 tional, permitting, £ind economic, that impede or encourage pollution prevention. 



5. Enhance participants' knowledge of refinery and regulatory systems. 



Lessons and Results 



Refinery Release Inventory 



A. Existing estimates of environmental releases were not adequate for making a 

 chemical-specific, multi-media, facility-wide assessment of the Refinery. 



B. Pollutant generation and internal transfers differ substantially from pollutant 

 releases to the environment. 



C. The TRI database does not adequately characterize releases from this Refinery. 

 Better environmental data can improve environmental management decisions. 



