Before Compliance - Conducting Pilot Programs for Benzene Fenceline Monitoring
On December 1, 2015, the Refinery Sector Rule update was published in the Federal Register. As part of the update, on-going fenceline monitoring of benzene will be required at all existing refineries by February 1, 2018. The new work practice requires placing passive sorbent samplers around the refinery perimeter and measuring benzene concentrations continuously over 14-day periods following EPA Method 325. The goal of the work practice is to provide refineries continuous feedback on the effectiveness of their emission controls. Additionally, the reporting requirements of the rule serve to improve transparency with the community as refineries must post fenceline monitoring results on a public website.
Although refineries are not required to comply with the fenceline monitoring requirement for several years, many are realizing the benefits of conducting pilot programs ahead of the rule timeline. Pilot programs can provide valuable information for refineries to successfully prepare and minimize the anticipated challenges of compliance. Initiating pilot programs allow the refineries to:
- Work through general implementation details including sample collection, media management and tracking, and data management procedures to minimize missteps during compliance, and ensure the selected laboratory is routinely meeting quality and project requirements.
- Identify monitoring station locations based on property size and geometry as well as potential sources within 50m of the property line. Additional stations may be helpful in the pilot stage to identify both near-field and onsite sources. While the rule allows for adjusting benzene concentrations based on contributions from off-site sources near the refinery, a site-specific plan detailing the approach and rationale must be submitted to the EPA prior to compliance.
Determine seasonal variability of fenceline concentrations. Since the action level of 9 µg/m3 is calculated on an annual rolling average, some refineries are considering monitoring over 6-month periods or longer to capture seasonal effects.
- Identify problem areas showing elevated readings and proactively address benzene emission sources. Not only does this information give the refinery the opportunity to reduce fugitive emissions ahead of schedule, but also facilitates the development of procedures for root cause analysis and corrective action prior to compliance. Given that the rule requires root cause analysis and initial corrective action to be conducted within 45 days after determining an exceedance of the action level, having a framework to help navigate this process effectively and efficiently can be helpful once refineries are in the compliance phase.
Team up with Eurofins Air Toxics to support your pilot studies and help navigate the rule requirements with method compliant sampling equipment and analysis. Our experience, capacity, and competitive pricing will ensure your success.
Contact our team to find out more information:
Heidi Hayes, Technical Director, HeidiHayes@eurofinsUS.com;
Carl Skelley, National Air Product Manager, CarlSkelley@eurofinsUS.com