ENV-09-11 Opportunities and Limitations in the Use of Optical Remote Sensing Technologies

Description:

Optical remote sensing (ORS) technologies have been used to evaluate emissions performance at petroleum refineries in Europe for nearly two decades. The Differential Absorption LIDAR (DIAL) technology was, in fact, developed by BP and Shell for that purpose. While not a new technology, the use of ORS to evaluate refinery emission performance is relatively new to the US. In recent years, the use of passive infrared cameras has become commonplace. Now calls for routine use of ORS technologies have started to spread, including a stipulation in a recent consent order for measurement of emissions from wastewater treatment units using DIAL and EPA‘s commitment to use ORS technologies to improve emission estimation methods at petroleum refineries and chemical plants. While ORS technologies are terrific tools that can help gain a better understanding of the sources of hydrocarbon emissions and improve emission estimation methods, the proper use and limitations of ORS need to be understood and recognized. This caution is especially relevant now that regulatory agencies and other interested concerns are starting to use ORS survey findings in enforcement proceedings and in the court of public opinion. Included in this paper is a brief overview of the ORS technologies in question, how those technologies are currently being used (and may be used in the near future), technical limitations, and pertinent legal issues such as how to protect internal ORS survey findings and how to defend against use of these technologies by external parties.