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Show is unlikely to be met by source testing alone. Certainly there are some preliminary measurement programs that have been of great value in roughly describing the breadth and abundance of toxic byproducts from some petroleum industry combustion sources. But they have produced more questions than answers. The industry's tried-and-true "Let's just go out and make a few measurements!" approach simply won't work this time, as has already become abundantly clear. The problem is, in part, simply one of economics. Reliable measurements of trace toxics are difficult, tedious, and exorbitantly expensive, as some have already found out; realistically, nobody can afford to pay for the number of measurements that would be needed to span the range of combustion parameters. A more basic problem with source testing, even if time and money were not the severe limitations that they are, is that the purely empirical approach does not provide understanding. Empirically-based "theories" are merely glorified regressions on vast or, in some cases, half-vast collections of data, providing absolutely no fundamental understanding of what is going on, nor any hint as to what might happen "outside the range." In the absence of fundamental understanding, w e can't possibly assert with any confidence that a test made today has anything at all to do with what w e might find tomorrow on the same device, let alone a "similar" device, if w e were to test it again. In fact, unless w e understand what parameters affect combustion air toxics and how they do so, w e can't even know what "similar" means. Small wonder that recent industry measurement programs have acknowledged the need to understand the formation and destruction of pollutants in the extremely complex combustion process, and lamented the fact that measurements to date have provided more puzzles, uncertainties and inconsistencies than understanding. However, ongoing and future measurement programs can provide much needed validation of a more fundamental approach to the problem of combustion air toxics. The collaborative R & D program that P E R F Project No. 92-19 seeks to establish, with the cooperation of the U. S. Department of Energy, envisions a major (particularly as to cost) empirical element, leveraged by a supporting fundamental effort that capitalizes upon powerful new techniques for gaseous combustion. l C A A section 112(d)(3) 2 C A A section 112(a)(1) 3 Federal Register, Vol. 57, No. 186, Thursday, September 24,1992, p. 44156. 4 C A A section 112(f)(2)(A) 5 Almega Corporation, AB2588 Pooled Source Emission Test Program, Report for Western States Petroleum Association, Aug 31,1990. 6 Stockdale, R. M . Lev-On, N. Meeks, C. H. Reheis. Western States Petroleum Association (WSPA) Pooled Source Test Program: Industry Specific Air Toxics Emission Factors. Presented at the Air & Waste Management Association Meeting, Pittsburgh, March, 1991. 7 Hansell, D. W., G. C. England, N. Soelberg, W . R. Seeker, M . Lev-On, S Folkarkow. Development of Air Toxics Emission Factors for Petroleum Industry Combustion Devices. Presented at the Air & Waste Management Association 85th Annual Meeting, Kansas City, June, 1992. 8 Data and source confidential. 9 Stockdale, et al, op. cit. •0 Hansell, et al, op. cit. 3 1-3 |