Letters. Offshore Drilling

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LETTERS Ozone correction

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Environmental Science & Technology

Dear Sir: In the story, “Ozone can help clean water and air” (€SAT, July 1975, p 618) there are some words about my city, Quebec, and its water treatment plant. Since we are very proud of our treatment plant, we are always very happy when it is the subject of a discussion or when it is stated as an example of water treatment technology. In that issue, it was written, “lnterestingly enough, Quebec City ozonates prior to activated carbon filtration, whereas . . Such a statement is incorrect since our water is ozonated in the final steps of the treatment. In fact, the treatment goes like this: pre-chlorination of the raw water at a rate of ARB as making a correction or retrac:ion. The enclosed material, taken from lata of the Western Oil and Gas Associ3tion (WOGA) clearly illustrates the irre;ponsible actions of Tom Quinn and the sntire CARB, and items such as yours mly add to the problem in that thousands of readers only hear the CARB jide of what is happening to California md unfortunately the poor results of the

CA B and the voice of the taxpayer go unheard. CHARGE: CARB reported that the Federal Government’s proposed offshore oil-drilling program could have disastrous air quality impacts in Southern California-creating as much smog as at least 900000 new cars. (CARB press release, Sept. 29, 1975) RESPONSE: This didn’t make any sense at all to the WOGA, which charged that CARB apparently couldn’t tell an oil well from an oil refinery. The WOGA found that CARB took Environmental Protection Agency refinery emission factors that are to be used to estimate total emissions from all the valves in a refinery and applied those factors to each valve on offshore platforms, to each valve in the treating facilities, and to each valve in the loading and unloading facilities. In other words, CARE3 took the EPA’s 28 lb/day/1000 barrels refining capacity for all valves in a refinery, and applied that number to each valve in the anticipated production facilities. CARB compounded these errors by applying an emission factor for an entire refinery to a production facility that is equal to no more than a small part, such as a single unit, of a refinery. Further, CARB disregarded the fact that the vast majority of these production facilities handles liquids and gases of a less volatile nature and usually at much lower temperatures and pressures. All of this contributes to CARB’s gross overstatement of emissions from Outer Continental Shelf (OCS) production facilities. CARB also assumed erroneously that all crude oil would be stored in tanks of 40 000-gallon (952-barrel) capacity or smaller, without vapor control devices. Crude tanks being built at the present time are far larger than 952-barrel capacity and have the most modern vapor control devices. In calculating impact, CARB estimated more than 17 tons a day of reactive hydrocarbons from 100 000 barrels a day of production, whereas WOGA estimates less than one ton a day from the same amount of production. Moreover, CARB assumed the efficiency of a sulfur removal unit in a gastreating facility to be only 80% and thus concluded that 8.1 tons of SOp/ day/ 100 000 barrels of produced crude would be emitted. The facts are that gas-treating facilities would have an efficiency greater than 99.5% and thus less than 0.1 tons/day/100 000 barrels would be emitted. Raymond H . Bever Huntington Beach, Calif. 92646