Avoidance of Shifting the Risk Burden to Other Areas or Media Clause Samples

Avoidance of Shifting the Risk Burden to Other Areas or Media. Legal Basis for the Project
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Avoidance of Shifting the Risk Burden to Other Areas or Media. The emission reductions anticipated from this innovative process are believed to be true pollution reductions and not merely moving it to another media. As indicated in the comparative emissions data above, the greatest reductions are in NOX, SO2, VOCs, and Particulates. The reduced NOX is a function of NOX control technology in the Gas Boiler. VOCs are converted to energy and the particulates are captured and added to the bed solids as additional sodium carbonate. Some of the sulfur compounds could be purged to the mill wastewater treatment system for assimilation. No significant impact to water quality is anticipated. An area of concern is the potential risk of failure of the gasification technology and the subsequent construction of a recovery boiler. During this construction period the smelters would be operated to maintain production at the mill. This time period could very possibly run past the MACT II compliance date. There then is a risk that total emissions over the project period would exceed emissions if the project were not pursued and conventional technology was put into place by the compliance date. The following table shows emissions in total tons for a set period of time during the project under differing scenarios as described. NOx ▇▇▇ ▇▇▇ ▇▇▇ 717 SO2 27 61 60 62 CO 12474 32625 18157 27578 CO2 509569 493513 554570 514079 VOC 2700 7077 3876 5955 PM 724 1884 1065 1599 The first column of emissions data are the total emissions estimated if the project goes as planned. The second column reflects estimated emissions should the project fail and a recovery boiler needs to be built, during which time the smelters would continue to operate. The third column is an estimate of the emissions if gasification technology is not pursued and the MACT II promulgation date is December 2000. The fourth column of data shows total emissions if we do not pursue gasification technology and the MACT II promulgation date is May 2002. The conclusions which can be drawn from this data are as follows: 1) a successful gasification technology implementation has much lower tons of emissions than the other scenarios; 2) the worst case additional pollutant burden would be the difference between column 2 (failed project) and column 3 (earliest MACT II date w/o Project XL; and
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Avoidance of Shifting the Risk Burden to Other Areas or Media. The project is consistent with Executive Order 12898 on Environmental Justice. It will not result in disproportionately high and adverse human health or environmental effects on minority or low-income populations. It is possible that changes to the City’s water treatment could cause lead levels to rise temporarily for all City residents. However, this project is designed to ensure that lead levels in drinking water will continue to be minimized. Moreover, even if lead levels were to rise and the LSL testing and replacement requirements suspended pending treatment modifications, the project incorporates numerous safeguards, as described above, to protect against any disproportionately high lead levels and adverse health effects to any City residents, including minority or low-income populations. In fact, taken as a whole, the terms and requirements of the SDWA variance which will be used to implement this project, combined with the multimedia impacts of the LCSP, will provide enhanced protection to minority and low-income populations from health and environmental risks caused by potential exposures to lead from multiple sources in the City.
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Avoidance of Shifting the Risk Burden to Other Areas or Media. The emission reductions anticipated from this innovative process are believed to be true pollution reductions and not merely a movement of contaminants to another media. As indicated in the comparative emissions data in Tables 1 and 2 in Section III.A, the greatest reductions are in NOX, SO2, VOCs, CO and Particulates. The reduction in NOX is a function of NOX control technology in the gasification system boiler. Georgia-Pacific intends to utilize low-NOX burners for both natural gas and product gas. VOCs are converted to energy and the particulates are captured and added to the bed solids as additional sodium carbonate. Some of the sulfur compounds could be purged to the Mill wastewater treatment system for assimilation. No significant impact to water quality is anticipated. An area of concern is the potential risk of failure of the black liquor gasification system and the subsequent construction of a recovery boiler. During this construction period the smelters would be operated to maintain production at the Mill. This time period could very possibly run past the MACT II compliance date. There then is a risk that total emissions over the project period would exceed emissions if the project were not pursued and conventional technology was put into place by the compliance date. The following relative time line and data table will help clarify the project schedule and its potential effect on overall project emissions. Table 4 shows emissions in total tons for a set period of time during the project under four different scenarios.
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Avoidance of Shifting the Risk Burden to Other Areas or Media. NBC’s project will have no negative impact, and no adverse shifts in loadings across media. NBC’s current pretreatment program requirements to protect worker health and safety will remain in place.
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Avoidance of Shifting the Risk Burden to Other Areas or Media. The design and remote location of the MRF will protect worker safety and ensure that no one will be subjected to unjust or disproportionate environmental impacts. All Autoliv workers are required to receive extensive safety and explosive training. The processing of all pyrotechnic material will be incorporated into the MRF’s standard operating procedures. All new waste materials will be approved before processing to ensure that no safety risks or unwanted environmental impacts are present. Autoliv’s pyrotechnic expertise and operating record demonstrate the ability to safely and effectively process these materials. The risk burden shifted to the Metals Recovery Facility will not be greater than current operations for the following reasons: The need to transport waste pyrotechnic material off-site to the permitted OB/OD unit will be minimized. The public and other non-Autoliv employees will not be exposed to the risks associated with transportation, loading and unloading of pyrotechnics for off-site transport. This increases public safety. Waste pyrotechnic materials will be processed more regularly, thereby reducing the risk associated with the storage of large quantities of pyrotechnic materials. In addition, all workers will have extensive explosive handling and safety training. Industrial hygiene samples will be completed to insure worker safety. The proposed feed system is designed to prevent propagation of pyrotechnic materials, thus protecting workers and equipment. Processing capabilities, desensitizing agents, limitations, etc. will be strictly defined. By controlling the feed rates and quantities processed, the risk of processing waste pyrotechnics in the Metals Recovery Furnace will be significantly reduced. All processing will be completed as remotely as possible to minimize worker exposure. The risk burden to the environment and general public will be reduced because all emissions will be directed through the air pollution control train before being released to the environment. Current open burning operations allow for no emission controls. Implementing best management handling training, housekeeping and engineering design practices will minimize the risk of fires and explosions. The increased use of the MRF will allow Autoliv to treat its waste in a more environmentally sound manner than what previously exists. No shifting of the risk burden will occur from one media to another.
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Avoidance of Shifting the Risk Burden to Other Areas or Media. The project is consistent with Executive Order 12898 on Environmental Justice. It will not result in disproportionately high and adverse human health or environmental effects on minority or low-income populations. It is possible that changes to the City’s water treatment could cause lead levels to rise temporarily for all City residents. However, this project is designed to ensure that lead levels in drinking water will continue to be minimized. Moreover, even if lead levels were to rise and
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Avoidance of Shifting the Risk Burden to Other Areas or Media. The emission reductions anticipated from this innovative process are believed to be true pollution reductions and not merely moving it to another media. As indicated in the comparative emissions data above, the greatest reductions are in NOX, SO2, VOCs, and Particulates. The reduced NOX is a function of NOX control technology in the Gas Boiler. VOCs are converted to energy and the particulates are captured and added to the bed solids as additional sodium carbonate. Some of the sulfur compounds could be purged to the mill wastewater treatment system for assimilation. No significant impact to water quality is anticipated. Another area of concern is that of Environmental Justice (EJ). The two criteria reviewed to determine if the project area is an EJ area are, 1) Does the area of concern exceed the State average for minority?, and 2) Does the area of concern exceed the state average for poverty?. The Virginia Minority Average is 27.09%, compared to a project area Minority Average of 18.9%. The Virginia Poverty Average is 12.25%, compared to a project area Poverty Average of 5.0%. Both are well below state averages. This is not considered an Environmental Justice community.
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Related to Avoidance of Shifting the Risk Burden to Other Areas or Media

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