Page 24 - Environmental Control in Petroleum Engineering
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Introduction to Environmental Control in the Petroleum Industry  13


   Because funds available for environmental compliance are limited
 to those received within a project's minimum profitability level, these
 funds should be spent in ways that provide maximum protection
 for the environment. Bad regulations can require that available funds
 be spent in ways that provide little environmental protection. This
 increases the cost of doing business and can make many marginal projects
 uneconomical, resulting in a loss of jobs and reduction in domestic
 production. Thus, the conflict between the benefits of inexpensive energy
 and environmental protection are magnified by bad regulations.
   The following hypothetical situation illustrates how misinformation
 and misunderstanding about sound scientific environmental principles
 can lead to the economic destruction of an industry:

      A company applied for a discharge permit for a process and
   reported that the effluent concentrations of a particular chemical
   would be 75 parts per thousand. The discharge permit was denied
   on the grounds that the effluent concentration was too high. The
   company then spent thousands of dollars to upgrade their waste
   treatment stream and reduced the effluent concentration to 75
   parts per million. Their discharge permit was again denied on the
   same grounds. The company then spent millions of dollars more
   to install the best available technology for treating the waste
   effluent. They successfully reduced the discharge concentration
   to 75 parts per billion. Unfortunately, the discharge permit was
   again denied on the grounds that the effluent concentration was
   still to high. The company then invested billions of dollars in
   research and development to create a new way to treat the
   effluent and lower the discharge concentration to 75 parts per
   trillion. The discharge permit was again denied. At this point, the
   company went bankrupt and was forced out of business because
   it spent all of its money trying to comply with environmental
   regulations. When they asked the permitting agency why their
   discharge permits were denied, they were simply told that 75
   parts was just too high.

 Although this story incorrectly implies that regulatory agencies do not
 base their regulations on sound scientific principles, the sad truth is
 that regulatory agencies must operate within laws passed by people
 who may lack an understanding of scientific environmental principles.
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