Among the standards and regulations set for industry by the Environmental Protection Agency (EPA), risk and technology reviews may be among the most challenging.
Steve Smith, manager of environmental issues for LyondellBasell, said a risk and technology review is done eight years after a maximum standard is passed.
"We set some standards in the original maximum standard, and those standards were supposed to reduce the risk of certain toxins that they're concerned with in that particular industry or that particular process or chemistry," Smith explained. "The question is: Is the risk today as a result of implementing that low enough and is it acceptable?"
According to Smith, while industry companies are required to conduct emissions inventories to help assess risk, errors occur as the data makes it way through various reporting factions before arriving at the EPA.
"So many translations occur after it leaves our hands and lands in the hands of the EPA," Smith said, addressing delegates to the Environmental, Health and Safety Seminar held recently in Galveston, Texas. "For example, I saw the modeling file that EPA had for one of our sites, and it was an area source ⦠that basically covered the trailer park next to our facility. I am pretty sure we don't have any operations in that trailer park, and I'm pretty sure that if they rule the model with our emissions in the trailer park, there will be an impact in the trailer park, which will be unacceptable."
Smith cited other examples of errors that have occurred.
"One of our sites is actually some distance off the highway, but the points that they put in for our emissions were out on the highway," he said. "They put the emissions out in the middle of the cornfield. I don't know how they got there. But these are the kinds of errors that we're concerned about as they do this modeling. You've got to have the emissions in the right place, and then you can do the modeling."
'Quick and dirty' version of technical review process
If the valid risk of emissions levels is found to be unacceptable, a technology review is conducted to determine what technology can be used to impact and mitigate the risk, including air models, Smith said.
Air model results indicate the concentrations of emissions in the community, or the HEM (human exposure model), which measures those concentrations and translates them into a risk number.
"They do that for each of the compounds of concern," Smith said. "They do that for cancer and for non-cancer."
The review of the data determines whether that level is acceptable. If it does not fall within acceptable levels, a technology review becomes necessary.
"When the standard was published in the beginning, 'double widgets' were the technology that was used to control the tetraethyl depth -- the 'bad stuff,'" Smith said.
However, Smith does not believe "double widgets" are still the appropriate apparatus for controlling "tetraethyl bad stuff."
"'Widgets and gizmos' are whatever control technologies you have to apply," Smith said. "And the tetraethyl 'bad stuff' is whatever chemical compound is the compound of concern for whatever your process is that is being reviewed."
"'Triple gizmos,'" Smith said, are in development but have not been demonstrated. "They're not going to push to that technology because it hasn't been applied in the field," he said.
The cost of these "gizmos," Smith said, when they finally come out, "is going to be in excess of $20,000 per ton reduced. But that's not cost-effective; therefore, we're not going to require that."
The "widgets," he said, are still cost effective.
"And that's the real 'quick and dirty' version of the technology review that goes on," Smith concluded.
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