Risky Analysis Indeed! An Economist's Critique Of Risk Analysis Of Petroleum Refinery FCC Emissions

摘要

The EPA issued proposed the Refinery MACT II rules on 9 September 1998 to control air pollutants from petroleum refinery process units. Daugherty and Hayes (2001) presented results of a risk analysis of FCC emissions. This paper lists and discusses the various deficiencies of risk analysis in the context of setting a risk-based inorganic emission standard for the FCC. It argues that risk analysis is not comprehensive, economically inefficient, uses arbitrary and obsolete risk thresholds, does not consider abatement cost, ignores the impact of other nearby polluting sources, and is equivocal on aggregation of risk from multiple pollutants. The paper discusses why risk analysis is a particularly inappropriate decision tool to use in raw-material-intensive industries processing price and quality-differentiated inputs. It elaborates upon the potential for multi-media risk-exacerbations resulting from inter-unit pollutant transfers and feed quality changes facilitated by cost-reducing advances in refining technology. Critical data omissions and inadequacies are pointed out that potentially nullify risk analysis using such data. The EPA is urged to discard the cancer risk analysis of FCC emissions and cost-effectiveness as decision tools and instead promulgate an 'NSPS-cum-MACT-cum-RCRA rule for FCC pollutants on the basis of the standards proposed by the author (Rao, ACE 2002).