Recently, I have been reading a number of opinion pages and commentaries about a host of environmental topics - the new proposed refinery regulations, the new clean air standards for power plants, new safety standards, proposed labeling standards, concern about GMO, and the list goes on. While the writer or commenter has some valid points, the issue is never as black and white as it seems based on the facts presented.
Let's take, for example, the issue of safety. There was an article that indicated that refineries only get inspected when something goes wrong. This came from a national labor figure. Having worked in refineries for 25 years and as a consultant have seen the insides of many different companies refineries (small and large companies). I know for a fact this is not the case. However, if your perspective is the that the National EPA is the one that should be doing the inspections - then the statement may be correct. However, most refineries have at least one air permit inspection annually from the State agency and for most due to the size of the air permit this inspection is done in four parts - so the inspector is there quarterly. If you add in the water, hazardous waste, and other permits, it is not unusual to have anywhere from 4 to 10 different types of inspections per year. One year at a refinery I was working at there were 26 different inspections, everything from the local county health department to the EPA. I have seen in some jurisdictions that the State or District regulator has been provided office space at the refinery. So, I have at least found it very difficult to agree with the statement that refineries are only inspected when something goes wrong - but could understand if they were discussing a specific type of inspection.
I have learned over time - that perception is reality - particularly when dealing with compliance, and safety issues. Particularly, when you are dealing with the public and those unfamiliar with day-to-day operations of any type of plant. For example: how many time has the local news media photographed from outside a plant when doing an air pollution story focused the camera on a steam plume? It is based on a lack of understanding what they are looking at. So, we as environmental and safety professionals have to be aware of these perceptions.
So, while we are dealing with our day-to-day issues; we in industry also have our frustrations. Think about it - when there is an incident, in general we all are trying to find out what happened so that we can put measures into place to prevent a similar occurrence in our own facilities. Yet, look at how long it takes to get a report out? The Chemical Safety Board (CSB) is just now releasing information on the 2010 Deepwater Horizon Blowout. And, it was on May 1 that they released information about the 2010 accident in a refinery in the northwest. Why? While it is not just the fault of the CSB, who is currently at only two members, and there historically have been five. How can a group that small be expected to investigate the number of incidents that the public expects them to? The CSB has been asking for more resources, yet it seems that this request is going unheard.
There is what is known as organizational memory or cultural memory. This has been seen to be a huge issue when dealing with sensitive issues. Once, I heard a negotiator from the Carter Institute talking about how this factor played a huge role in peace talks. She was specifically discussing the Bosnia/Herzegovina conflict. In their discussions, a battle that featured Vlad the Impaler in the mid-1400s was still a heated topic and formulated impressions that had to be dealt with prior to proceeding. For us in the petroleum industry, we have to face a similar history that impacted the community and/or the national consciousness. We are only as good as how well company X handled the last big crisis, and it doesn't matter if it was a small company or a multinational corporation. We are all painted with the same brush.
And to top it all off, there is not a clear understanding about the unintended consequences of the regulations will or might be, Look at these new proposals on coal power plant emissions. Do we really know the costs? I have seen the government estimates and sure they look good - but the government is using a formula that does not account for future costs because those costs are as yet unknown. We have seen this before when applying a technology. Sure today you can have that particular piece of equipment manufactured for a price x due to the current steel costs and backlogs at the manufacturing plant which historically has only had to produce one or two per year. But, now multiply that by 10 or 100 or 1000 because that technology is mandated and it has to be implemented within three years. The manufacturing plant now has scale up costs as well as higher material costs due to the demand on the raw materials - and the costs rise initially. The entire manufacturing, production, labor, permitting costs, and other "hidden" costs like space. Are not calculated in that tidy government estimate. (Nor, is the paperwork and manpower cost ever tracked about how to build the information gathering systems to obtain the information required by the reporting ever included.)
We have always said that the true impact of a regulation is in the details. The overall intent and concept may be good but when it comes implementation, the unintended consequences appear. A conceptual model is simple. But, try to apply it to a facility that has been in operation, modified, built/rebuilt over a period of 30, 40, or even 70 years? It is similar to making additions to your home - the plan is never going to be as efficient as if you built it from scratch.
I believe we all want to do the right thing. We all want a cleaner environment. But, we also want to fill our cars with relatively inexpensive fuel, have all of our electronics running when we want them, and live in a comfortable air-conditioned home. Thus, we have to make choices, and trade-offs. I wonder what my electric bill will be in 3 years.