One Year Later – What Challenges Have You Faced with Benzene Fenceline Monitoring?

The Petroleum Refinery Sector Rule in 40 CFR 63, Subpart CC (National Emission Standards for Hazardous Air Pollutants from Petroleum Refineries or Refinery NESHAP) generally applies to all petroleum refineries in the United States. Did the monitoring program at your facility go as smoothly as you hoped, or did you encounter unanticipated issues resulting from higher than expected benzene concentrations? Your 12-month rolling average emissions results will now be available to the public, and you may need to educate and engage with your surrounding community to understand the results.

It is extremely important to evaluate the one-year benzene concentrations for each monitoring location around the fenceline. Momentary benzene contributions from nearby offsite sources, as well as facility-specific fugitive emissions, can be difficult to resolve. Identifying contributing benzene sources can be a challenge using the requisite Method 325 time-integrated measurement results of sorbent tube samplers.  One can’t tell when and from where the benzene originated.

ALL4 has years of technical experience and regulatory relationships to support your entire Method 325 (Volatile Organic Compounds from Fugitive and Area Sources) – Benzene Fenceline Monitoring (BFM) related services including:

• Assisting in identifying facility sources of emissions both onsite and offsite with real-time data generating methods
• Modeling and analyzing unusual localized meteorological conditions, such as microclimates
• Preparing site-specific monitoring plans (SSMP), which can take several months to develop and obtain approval, for additional sampling events and onsite requirement for meteorological monitoring
• Providing ALL4 meteorologists who can site, design, and install a meteorological tower(s) specific to your facilities conditions and will be operated in accordance with the guidance contained in U.S. EPA’s “Meteorological Monitoring Guidance for Regulatory Modeling Application” (U.S. EPA 2000)
• Coordinating sample media and managing data packages from your contracted certified laboratory.

ALL4 can provide consulting and support throughout your annual monitoring events, offering BFM support for the follow:

1. Review of existing monitoring design and implementation: ALL4 can audit and review your existing monitoring locations and provide insight regarding optimizing locations based on the size and shape of your facility to validate the monitoring program meets the requirements of Method 325A. We can troubleshoot and identify local, offsite emissions which may be impacting your monitoring results.
2. Comprehensive support: We assist our clients throughout the entire BFM monitoring year including creating the SSMP and meteorological tower installation and data collection.  We can investigate the releases of fugitive emissions with special event data collection and/or real-time “open-path” monitoring equipment which measures benzene concentrations from one or more discrete points along the fenceline. The optical remote sensing methods, along with on-site meteorological data, can determine with high certainty the concentration and direction of the source emissions. By measuring the offsite sources in real-time, the U.S. EPA will allow you to exclude (subtract out) these influences.
3. Extensive Industry Experience: We are a full-service air quality consulting company with extensive experience in a wide range of industrial sectors including petroleum refining. We bring a team of meteorologists who have designed, sited, and installed the fenceline monitoring samplers in accordance with Method 325A.
4. Provide Unique Technology-Driven Options: Our team provides new and unique remote sensing capabilities for real-time and meteorological data connection. Installing a real-time monitoring system at sections of facility boundaries that have shown repeated ambient benzene concentrations of concern can be of value for mapping benzene plumes and identifying contributing sources.
5. Relationships with Local Authorities and State/Federal Regulators: ALL4’s technical staff has years of experience and relationships with State and Federal Regulators. ALL4 has supported the regulatory development process at the local, state and federal levels.

The goal is to understand the emission profile of your facility and to identify local contributing sources inside and/or outside of the fenceline well ahead of compliance issues.  Our team of ex-regulators, former senior corporate and facility environmental managers, and life-long consultants provides a holistic review of regulatory developments and ‘high end’ strategic consulting. It’s never too late to re-evaluate your BFM program or created a SSMP for onsite meteorological data collection.

ALL4 will manage your entire Method 325 program from coordinating the sampling team, your laboratory contractor, the regulatory agencies, and your surrounding community. For more information on how ALL4 can provide support throughout your 2019 monitoring events, please contact me at 610.933.5246 x169 or at dpelc@all4inc.com.