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API: EPA Risk Assessment Makes Unrealistic Assumptions on Key Refining Chemical

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WASHINGTON, August 2, 2022 – The American Petroleum Institute (API) yesterday filed comments with the U.S. Environmental Protection Agency (EPA), highlighting concern that EPA’s risk evaluation proposed changes to perchloroethylene (PCE) regulations are not based on the best available science and could lead to serious impediments to the refining process. 

Petroleum refineries use PCE as a chloriding agent to regenerate catalysts, a process that is essential to create fuels compliant with EPA regulations. Approximately 45% of gasoline blends in the U.S. are processed using PCE as it helps lower reaction temperatures, reducing safety risks and carbon dioxide emissions of refining operations. 

“The alternatives to PCE are either less efficient, which requires larger amounts of hazardous materials onsite and leads to increased exposure possibilities, or more hazardous,” API said in comments submitted to the EPA. “EPA’s initial and re-evaluated risk evaluation for PCE does not take into account the unique conditions of use in petroleum refineries.”

EPA’s initial risk evaluation for PCE was based on an unrealistic model, assuming “PCE is used 250 times per year, resulting in accidental releases every time it is used” and that “workers would get splashed by the accidental release and leave it on the skin for 8 hours.” These assumptions ignore industry safety standards and best practices as well as safety regulations from other regulatory bodies like the Occupational Safety and Health Administration (OSHA). 

“API urges EPA to reevaluate the risk finding according to the new modeling outputs and assume a more realistic condition of use where accidental releases do not occur every time PCE is used, and that OSHA regulations and basic industrial hygiene standards are being followed,” the comments said. 

API represents all segments of America’s natural gas and oil industry, which supports more than 11 million U.S. jobs and is backed by a growing grassroots movement of millions of Americans. Our nearly 600 members produce, process and distribute the majority of the nation’s energy, and participate in API Energy Excellence®, which is accelerating environmental and safety progress by fostering new technologies and transparent reporting. API was formed in 1919 as a standards-setting organization and has developed more than 700 standards to enhance operational and environmental safety, efficiency and sustainability.


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