268 



D. Site specific features, determined during the facility-wide assessment affect re- 

 leases and release management options. 



Reducing Releases 



A. A workshop approach, drawing on a diverse group representing government, 

 industry, academic, environmental, and public interests, developed a wide range of 

 release reduction options in a multi-media context more quickly than either EPA or 

 industry alone would do. 



B. Release management frequently involves the transfer or conversion of pollut- 

 ants from one form or medium to another. 



C. Source reduction is not necessarily practical for all release management op- 

 tions, despite its cost effectiveness. 



D. In this Refinery, few release reductions pay for themselves. 



Choosing Alternatives 



A. Ranking the options showed that better environmental results can be obtained 

 more cost effectively. At this facility, about 90 percent of the emission reductions 

 required by regulatory and statutory programs can be achieved for 20-25 percent of 

 their current cost. 



B. All participants agreed on which options were the most effective and which 

 were least, regardless of their ranking criteria or institutional viewpoints. 



Obstacles and Incentives 



A. EPA may not have the statutory flexibility to simply set an emissions reduc- 

 tion "target" without prescribing how this target should or could be met. If a target 

 involves releases in multiple media, current administrative procedures discourage a 

 coordinated approach, including the analysis of risks, benefits, and costs of manag- 

 ing residual pollutants in different media. 



B. Legislative and regulatory programs do not provide implementation schedules 

 compatible with design, engineering, and construction timeframes. Consequently, 

 short-term "fixes" are used at the expense of more effective solutions. 



C. Congress, EPA, and much of industry have developed a mind-set and comfort 

 level with command-and-control, end-of-pipe treatment approaches based on twenty 

 years of experience. Many of today's problems could benefit from a different ap- 

 proach. 



D. Accounting systems in industry and government do not track environmental 

 costs well, nor measure environmental health. Responsibility for pollutant genera- 

 tion and accountability for environmental protection are difficult to monitor. 



Recommendations 



1. Explore opj)ortunities to produce better environmental results more cost-effec- 

 tively. 



2. Improve environmental release data collection, analysis, and management. 



3. Provide incentives for conducting facility- wide assessments, and developing 

 multi-media release reduction strategies. Such strategies must consider the multi- 

 media consequences of environmental management decisions. 



4. Encourage additional public/ private partnerships on environmental manage- 

 ment. 



5. EPA should conduct research on the potential health and ecological effects of 

 VOCs and reformulated gasolines. 



Project Organization, Staffing, and Budget 



Workgroup: Monthly Workgroup meetings provided Project oversight, a forum for 

 presentations on different Project components, and an opportunity for informal dis- 

 cussion of different viewpoints about environmental management. Although attend- 

 ance varied, each meeting included representatives from various EPA offices, the 

 Commonwealth of Virginia and Amoco. 



Peer Review: At the Workgroup's request, EPA arranged for Resources for the 

 Future to assemble a group of outside scientific and technical experts. This Peer 

 Review Group provided evaluation and advice on the Project workplan, sampling, 

 analysis results, and conclusions. Members of this group were paid a small honorar- 

 ia for their participation by EPA. 



Workshop: A special Workshop, held during March 24-27, 1991 in Williamsburg, 

 Virginia, reviewed sampling data and identified reduction options and ranking crite- 

 ria. More than 120 people from diverse backgrounds— EPA, Amoco, Virginia, acade- 

 mia and public interest groups — attended the Workshop. 



