Document v1x3pnLnDYY8L5Om0OJpvaQVZ

SARA TITLE III Section 313 - Coiwuni cations Meeting March 24, 1988 Place: Houston, Hyatt Regency Time: 3:30 a.m . - 12:30 p.m. Agenda 7:30 - 8:30 Continental Breakfast 8:30 - 8:45 Introduction TGG 8:45 - 9:15 Public Outrage and What They Want to Know MSR 9:15 - 9:45 Needs Assessment - What do we tell? - How do we tell? TGG/MSR - Who tells? (Training Needs) -9-i45 -- 10:00-- 'Break [10:00 - 10:30 10:30 - 11:00 11:00 - 11:15 Possible Elements of a Program LCCC Activities Other Plant Activities TGG MGH/ERT 11:15 - 11:30 11:30 - 11:45 Plan Executive Management Presentation Review Action Items TGG/A11 All Objective: 1) 2) To determine how to address our needs for addressing the impact of SARA 313 emissions reports. Discuss possible elements of a program and current company activities. VAB.0001165025 POSSIBLE FUGITIVE EMISSIONS CONTRACTORS Furmanite Larry Slacik P.0. Box 370 Deer Park, TX 713/476-1701 77536 C-K Associates John Prestridge 11200 Industriple Blvd. Suite 150 Baton Rouge, LA 504/291-3138 Darbonne Services Johnny Darbonne, Jr. Rt. 4, Box 1478 Lake Charles, LA 70611 318/855-4869 Team, Inc. Michael Hebert 575 18th Street, #4 Beaumont, TX 77706 409/832-7220 ERT Dr. Mark Greenbury 696 Virginia Road Concord, MA 01742 617/369-8910 Versar, Inc. Dr. Thomas Drygus 6850 Versar Center Springfield, VA 22151 201/325-1544 Enviro-Plan Dr. Howard Ellis 59 Main Street West Orange, NJ 07052 201/325-1544 Radian Corporation Dr, John Randall 8500 Shoal Creek Austin, TX 78766 512/454-4797 A VAB.0001165026 ASSESSING AMBIENT AIR TOXICS SET-3 A 4 Air quality related issues have taken on new dimensions because of an increased public awareness of toxic air pollutants. In response to this concern, state and federal agencies have been introducing legislation which will restrict public exposure to toxic air pollutants. The states have taken the initiative in developing air toxics regulations which identify specific allowable ambient limits (AALs) for a wide range of potentially toxic compounds. It is becoming increasingly important for industrial facilities to implement programs that will demonstrate compliance with these stringent air toxics regulations. Data regarding ambient compound concentrations are not only desirable for regulatory purposes, but can be of vital importance when dealing with issues involving environmental liability. Scott Environmental Technology, Inc., a leading air pollution consulting firm for ever 25 years, has the knowledge and expertise to assess emissions from a facility and define the precise impact to local air resources. To determine compliance with air toxics regulations, Scott has the ability to determine property-line concentrations through actual on-site monitoring or by applying dispersion modeling techniques to known emission sources. In addition, Scott's regulatory specialists can provide valuable assistance to expedite the often complex permitting process. We would welcome the opportunity to discuss how our Ambient Toxics Assessment Program (ATAP) could benefit your organization. For further information, contact R. P. Newman, Scott Environmental Services. PLUMSTEADVILLE. PA 18949 PHONE: (215) 766-8861 TWX: 510-665-9344 VAB.0001165027 AIR QUALITY MODELING SERVICES 4 The industrial sector is becoming increasingly aware of the need for reliable data for predicting ambient concentrations of atmospheric pollutants produced from facility stacks, vents, and area sources. Scott Environmental Technology, Inc. has been a leader in the field of air pollution consulting since 1959 and offers comprehensive dispersion modeling services. Air quality dispersion modeling programs offered by Scott can assist facility environmental programs in several areas including: Obtaining air quality PSD permits for new or modified sources; Determining if existing or increased emission levels will prevent the maintenance or attainment of ambient air quality standards; To determine the combustion emission impacts of fuel substitution or changes in fuel quality; Principle Organic Hazardous Constituent (POHC) dispersion from incinerator combustion processes; Evaluation of fugitive emissions from area sources; Modeling of emergency releases; and As an internal resource for future contingencies such as plant expansion. Scott has helped hundreds of clients determine atmospheric impacts by the application of state-of-theart modeling. All computer models utilized by Scott are EPA-approved and include: PTPLU Multi-Source Screening Model CRSTER Multi-Source Averaging Model MPTER Multi-Point Model with Terrain Adjustments ISCST Industrial Source Complex Short-Term Model ISCLT Industrial Source Complex Long-Term Model * VALLEY Complex Terrain Stability Class Concentration Model PUFF Short-Term Release Model For more information on the capabilities of computer dispersion models and how their use can provide your facility with important air quality data, contact: R. P. Newman or E.J. Gedney, Scott Environmental Services. Scott Environmental Services A division of Scott Environmental Technology, Inc. Route 611 Plumsteadville, PA 18949 215: 766-8861 San Bernardino, CA Troy, Ml Houston, TX VAB.0001165028 MODELING TOXIC GAS RELEASES Worldwide events and increasing environmental liability in this country have placed emphasis on understanding the implications of the short term release of toxic gases from industrial facilities. The public is becoming acutely aware of the dangers of short term exposures and is insisting the issue be addressed by companies involved with handling toxic substances. In response to this, regulatory agencies are issuing record fines associated with such releases. Scott Environmental Technology, Inc., a leader in air pollution evaluation and research for over 25 years, has developed a dynamic program to project the impact of short term toxic gas releases. The program is designed to predict ambient con centrations of toxic gases by utilizing computer dispersion modeling techniques. The program not only identifies situations which could be extremely dangerous, but helps management demonstrate the scientific basis of contingency plans associated with spills, leaks, etc. Basically, if your facility is in an area in which other proper ties could be impacted by emissions from your plant, a program such as this represents a critical part of an overall environmental/safety plan. Some toxic gas scenarios in which atmospheric releases could effectively be modeled and predicted at varying distances from the plant are summarized as follows: A facility stores tanker cars of chlorine gas to be used in production processes. What would be the atmospheric impact if one or more of these cars ruptured? A plant had a minor leak of toxic gas and several employees were taken to the hospital. What were the likely concentrations of gas to which the employees were exposed? We would like to discuss how our program can help your facility determine the implications of a toxic gas release. For further information, please contact R. P. Newman, Scott Environmental Services. Scott Environmental Technology Inc PLUMSTEADVILLE, PA 18949 PHONE: (215) 766-8861 TWX: 510-665-9344 VAB.0001165029 Basic Program Employee communication t Community communication - nearest neighbors Local authorities and legislators Media h t Consider ongoing process - not single events VAB.0001165030 Possible Activities Employee meetings Employee newsletters (i.e., plant employee newsletters) Community presentations (groups, schools, etc.) Medical community presentations Speakers list Local industry group activities Media days Visits to local legislators/government authorities * Plant open houses VAB.0001165031 Basic Program Local authorities and legislators - Activities similar to employee or community but "briefer" - Avoid "blindsides" Media m - Involve via direct proactive contact - Prepare written background materials & Consider ongoing process - not single events h VAB.0001165032 Basic Program Employee communication - Determine needs or concerns ~ In-plant meeting - explain #'s and risk - Newsletters - consider sending to homes to involve families - Open house for families Community communication - nearest neighbors - Determine needs or concerns - Communicate with meetings or written form - Consider open house - Use LERC if possible - Know what industry neighbors are savina and doing - "coordinate if possible" 9 VAB.0001165033 Possible Audiences Employees and families Plant neighbors Environmentalist Government authorities/regulators/legislators Experts - academia, etc. Media 4 VAB.0001165034 "The chemical industry has, largely unrestrained, become the major threat to environmental quality." Barry Commoner, The New Yorker VAB.0001165035 How Bad Is It X How Likely = Risk (as we define it. "Hazard" as the public defines it.) Hazard + Outrage = Risk as the public defines it VAB.0001165036 Factors the public uses in determining outrage Voluntary vs. Involuntary Familiar vs. Exotic and Unknown Forgettable vs. Memorable Controlled by individual vs. Controlled by system Fair vs. Unfair Trustworthy vs. Untrustworthy Conclusions People respond more to outrage than hazard. People don't listen to risk data when experiencing high outrage. Assuming hazards are low, outrage must be lowered, too. SARA Title 3 is an opportunity, not burden. VAB.0001165038 k What Do People Want to Know? How safe is it? How do you know? What are you doing about it? What can't you do? What can the public do? What is this stuff anyway? Why didn't you tell us sooner? How can we trust you? Don't you care? t VAB.0001165039 i T'- * How easy you make it to get to the data will directly affect how serious the public will believe the problem is. VAB.0001165040 Don't compare risk to cigarette smoking You tolerate X, X is worse than what our company does to you, therefore you have to tolerate what we are doing to you. FALSE! VAB.0001165041 * h What works Comparisons of same risk at two different times. Comparison with a standard. Comparison of estimates. Comparison of risk of doing something vs. the risk of not doing it and shutting down operations. Comparison of alternative solutions. Comparison with same risk elsewhere. VAB.0001165042 I Conclusions Make all the numbers readily available, but don't emphasize them. Find out what people want to know. Don't let a preoccupation with numbers keep you from showing that you care about people. Use easy-to-understand comparisons to explain the numbers. VAB.0001165043 Audiences Employees, retirees and their families, and other plant-related people People near the plants Environmental activists Health professionals, schools, experts of one sort or another Senior citizens, ill people, and other especially vulnerable population groups Emergency-response people Government officials, politicians, regulators, bureaucrats Media VAB.0001165044 1 t The chemical industry has, largely unrestrained, become the major threat to environmental quality Barry Commoner, The New Yorker Unlike the steel, auto and electric-power industries, the petrochemical industry-on its present scale at least, is not essential Nearly all of its products are substitutes for perfectly serviceable preexisting ones; plastics for paper, wood and metals; detergents for soap; nitrogenfertilizer for soil, organic matter, and nitrogen-fixing crops; pesticides for the insects' natural predators. Petrochemical products could be replaced by less hazardous ones. VAB.0001165045 Dr. Peter Sandman, director of the environmental communication research program and professor of journalism at Rutgers University. How Bad Is It x How Likely = Risk as we define it. Hazard Hazard + Outrage = Risk as the public defines it. VAB.0001165046 Factors the public uses in determining outrage 1. Voluntary vs. Involuntary Do people have a choice? Who gets to decide 2. Familiar vs. Exotic and Unknown Oven cleaner, fingernail polish remover vs. tri-methyl meatloaf 3. Forgettable vs. Memorable Are the results known-Bhopal 4. Controlled by individual vs. Controlled by system Share the knife 5. Fair vs. Unfair Where do the poor live. Do they have a choice? More of a share of risk for neighbors, less a share of the benefit. But becareful with riskbenefit. During the past forty years, we have experienced a 180degree change in public attitudes about releases to the VAB. environment. What used to be perfectly okay is agreed upon by our entire society as unacceptable. Moreover, we've made it not just unacceptable, people believe it is wrong to do it. When you say pollution is wrong, it becomes a moral judgement When you're talking morals, risk-benefit language becomes useless 6. Trustworthy vs Untrustworthy People believe we are arrogant, dishonest. Be responsive, not responsible. VAB. Conclusions 1. People respond more to outrage than hazard. Even when hazard is low, risk is high. 2. People don't listen to risk data when experiencing high outrage. They ignore it or mine it for ammunition. Data issue vs. power issue. Who is in control. 3. Assuming hazards are low, outrage must be lowered, too. 4. Sara Title 3 is an opportunity, not a burden. VAB.0001165049 6 find out what people want to know--focus groups 1. How safe is it? Give them some risk estimate-numbers. 2. How do you know? They will be skeptical. Explain uncertainty. That we round up. That our estimates are the absolute worst it could be. 3. What are you doing about it? Tell them what you've done already and Vista has done g IqL Explain management strategy--if the numbers are too high, get them down. What you plan to do. What government and community have been doing with CAER. VAB.0001165050 I 4. What can't you do? Be explicit. Technology limited. Cost far too much. 5. What can the public do? Share the knife. Company had cut emissions as much as possible. Engineers said that any more cuts would not be cost effective. So company gave outside committee budget of $2 million to see what they could do. Engineers came back and said, well wait a minute. Maybe we can come up with something. And besides, anything they come up with will be stupid. It won't be. VAB. 6. What is this stuff anyway. What the stuff is like. What it is used for. Revise MSDS's so they can be read by average citizen. 7. Why didn't you tell us sooner. The only answer is we should have. We didn't trust the public. That was dumb. You have a right to know. We're not going to do it any more. 8. How can we trust you? We don't expect you to and you don't have to anymore. There are plenty of other people involved in the process now. Environmentalists, government officials, agencies. If you don't believe us, ask them. VAB. 9. Don't you care? You need to cross the bridge between engineering, data-oriented person and the feeling, datadistrustful person, often a female. All your training has been away from this. You better learn to think their way, too. How easy you make to to get to the data will directly affect how serious they will view the problem. One company is putting a computer with data, air modeling, etc. in the public library. It will be so familiar, hopefully the company won't be tarred and feathered. Make the data readily available. VAB. How to communicate about the numbers. Don't compare risk to cigarette smoking. When you compare what you do to people with what they choose to do to themselves, you make them furious. You tolerate x, x is worse that what our company does to you, therefore you have to tolerate what we are doing to you. That doesn't compute. VAB.0001165054 What works 1. Comparisons of same risk at two different times. We're emitting 40 percent less than we did two years ago. 2. Comparison with a standard. What we're doing vs. the OSHA standard or the EPA standard. 3. Comparison of estimates. 4. Comparison of risk of doing something vs. the risk of not doing it and shutting down. 5. Comparison of alternative solutions. Landfill vs. incinerators. 6. Comparison with same risk elsewhere. Here vs. Denver. VAB. Conclusions 1. Make all the numbers available, readily available, but don't emphasize them. 2. find out what people want to know 3. Don't let preoccupation with numbers keep you from showing you care. 4. Use comparisons to explain the numbers. VAB.0001165056 Audiences 1. Employees, retirees and their families, and other plantrelated people 2. People near the plants. They shouldn't hear it on TV 3. Environmental activists. They are still undecided about whether to use the information to try to shut us down. 4. Health professionals, schools, experts of one sort or another. 5. Senior citizens, ill people, and other especially vulnerable population groups. 6. Emergency response people 7. Government officials. Just enough to brief and reassure, but don't get too close. They want to be seen as independent. 8. Media. Notice they aren't first. VAB.