The EPAs 2015 Petroleum Refinery Sector Rule Still Remains Impactful for Facilities from Other Sectors
August 12, 2021
By: David Berkowitz
Unanticipated issues with passive tube fenceline monitoring programs have led to a number of challenges at petroleum refineries. In today’s blog post, David Berkowitz shares some information on how to avoid some of these pitfalls, and why these programs aren’t just for the petroleum industry anymore.
To further control toxic emissions that impact public communities and the environment, the US EPA finalized and published amendments to 40 CFR Part 63, Subpart CC – National Emission Standard for Hazardous Air Pollutants from Petroleum Refineries in late 2015. Affected petroleum refineries were required to regularly monitor fencelines for their concentration of benzene emissions around the perimeter, typically done using passive tubes that are changed out every 14 days.
While compliance data for this low-level monitoring has been collected by facilities for the last three years since the finalization of these provisions, some facilities are still dealing with unanticipated issues affecting their data and dealing with consequences from issued missed during preparation ahead of their compliance programs. A few of the difficulties they have faced during the process of implementing compliance fenceline monitoring programs have been:
- Unoptimized setup and installation of passive monitors
- The discovery of unexpected sources benzene, both on and off site
- The need for Site Specific Monitoring Plans (SSMP) outlining the procedures for the subtraction of emissions from off-site and known on-site exempt sources
These difficulties encountered have led to some refineries recognizing that they are in worse shape than they expected, both with their monitoring practices and the level of benzene emissions they produce. While fenceline monitoring is currently only required for the petroleum refining sector, it is being incorporated into the Consent Decrees of facilities from other sectors. The EPA is also considering including these provisions in rule updates for other sectors as well. This begs the question of what the implications of improper benzene fenceline monitoring implementation is and how it can negatively impact a variety of facilities for years to come.
What Are the Implications of Ineffective Preparation for an EPA Method 325 Fenceline Monitoring Program?
The refinery sector rule includes a rolling annual average difference concentration of benzene (known as delta C) action level of 9 ug/m3. Once a facility reaches this threshold, they are required to conduct a root cause analysis and take corrective action to fix the issue(s) causing these fugitive emissions. While this provision includes an action limit as opposed to an emission limit, ongoing exceedances could conceivably result in enforcement action by the EPA. So, it is important to identify and remediate any issues that cause “hot spots” at the facility fenceline.
How Montrose Can Help
For years Montrose has supported routine operations of pilot (pre-compliance) and compliance fenceline monitoring programs. We have also worked closely with facilities to recognize/identify any trouble spots that may lead to the inability to remain below the action limit of 9 ug/m3. The various services Montrose provides to assist these facilities include:
- Optimized monitor siting following EPA Method 325A
- Meteorological station installation, data management, and routine audits
- Sample tube deployment and retrieval
- Laboratory Analysis using our National Environmental Laboratory Accreditation Program (NELAP) accredited in-house laboratory (Enthalpy Analytical, LLC)
- Fenceline data management and reporting software including mobile application to capture field data
- Fenceline data webpage development, hosting, and management.
- Generation of Compliance and Emissions Data Reporting Interface (CEDR) formatted report
- Identification of sources of benzene emissions, both on and off-site using various techniques such as strategically placed extra tubes and real time monitoring technologies such as:
- Proton Transfer Time of Flight Mass Spectrometry (PTR-TOF-MS) mobile laboratory
- Low cost sensors
- Low cost auto gas chromatograph (GC)
- Open path and extractive Ultraviolet Doppler Optical Absorption Spectroscopy (UV DOAS)
- Assistance with root cause analysis and corrective action plans
Montrose has assisted many facilities with program setup and routine operations and is ready to leverage this experience to help you avoid the pitfalls that can derail your compliance program. From informative consultation services to providing you with the best monitoring technology and reporting software, we are your one-stop-shop to on-going compliance at all your facilities. Reach out today for further assistance!
Fenceline Monitoring Expert
David Berkowitz brings over 29 years of industry expertise to the Montrose team where he currently works as our Fenceline Monitoring Testing expert. Prior to joining Montrose, he worked for Enthalpy Analytical and Triangle Laboratories. David is a member of the Air and Waste Management Association, the American Fuel and Petrochemical Association, and the American Chemical Society. He holds a Bachelor’s degree from North Carolina State University.