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An Overview of Proposed Petroleum Refinery Fenceline Monitoring Requirements A&WMA ACE 2015 Monitoring HAPs in Ambient Air Paper 309 June 23, 2015
An Overview of Proposed Petroleum RefineryFenceline Monitoring Requirements
A&WMA ACE 2015Monitoring HAPs in Ambient Air
Paper 309June 23, 2015
Presentation Objectives
1. Review regulatory framework and recent history2. Provide a broad overview of fenceline monitoring
requirements3. Examine some of the details and challenges associated with
implementing the regulatory requirements.
2
Refinery Emissions Have Been Regulated for Decades By Two Standards
1. New Source Performance Standards (NSPS) 1974: Fuel Gas Combustion Devices, Fluid Cat Cracking Units,
Sulfur Plants 2008: Above plus Delayed Cokers, Flares, Process Heaters
2. Maximum Achievable Control Technology (MACT) Standards 1995 (MACT 1): Non-combustion or Evaporative Sources
(equipment leaks, tanks wastewater, miscellaneous process vents, heat exchange systems, cooling towers) 2002 (MACT 2): Combustion Sources (Cat Cracking Units,
Catalytic Reformer Units, Sulfur Recover Units)
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NSPS and MACT Require Periodic Reviews
NSPS CAA Section 111 (b) requires EPA to set and periodically review
emission standard for new sources of criteria air pollutants, volatile organic compounds, and other pollutants
MACT CAA Section 112 (d) requires EPA to set emission standards for HAP
emitted by major stationary sources based on performance of maximum achievable control technology
Two reviews are required: Residual Risk Assessment – Are further reductions warranted? Technology – Are better controls now available?
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Proposed Rule is Based on Risk and Technology Review
Residual Risk and Technology Review are driving the requirements Signed on 5/15/2014 in compliance with a court order Published in FR on 6/30/2014 (FR 79, 336879) Promulgated rule originally scheduled for 4/17/2015 Date extended to 6/16/15 and then 9/30/15 Proposed Rule modifies
Refinery MACT I, 40 CFR 63 Subpart CC Refinery MACT II, 40 CFR 63 Subpart UUU NSPS Subparts J and Ja
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Proposed Rule Establishes Three Key Requirements
1. Emission control requirements for: Storage Tanks Flares Delayed Coking Units
2. Elimination of exemptions to emission limits during startup, shutdown, and malfunctions
3. Fenceline monitoring for benzene Method 325 A: VOC from Fugitive & Ambient Sources (Sampler
Placement) Method 325 B: VOC from Fugitive & Ambient Sources (Analysis)
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Fenceline Monitoring Program Requirements (1/3)
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Deploy a network of diffusive samplers around the perimeter of the site in accordance with EPA Method 325A. Two deployment options:
1. Placed at different angles circling the geometric center of the facility along the fenceline. Size of property determines the angles.
2. Placed along the fenceline every 2000 meters with additional monitors placed near wastewater treatment units or Group 1 storage vessels. Monitor placed 1.5-3.0 m above the ground.
Monitor Placement Varies with Facility Size (1a/3)
Facility Size, Acres Angle, Degrees Number of Monitors
Less than or equal to 750 30 12
Greater than 750 but less than 1500 20 18
Greater than 1500 acres 15 24
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24 samplers placed along fenceline
Note that extra samplers are required near known sources of VOC emissions
Fenceline Monitoring Program Requirements (2/3)
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Sampling episode is defined as 14 days unless there is a reason to sample for a shorter period. Must be one co-located sample for every 10 collected
samples. Must be one field blank for every 10 collected samples. Background adjustments are allowed if described in a
sampling plan that is submitted to agency for review and approval. Tubes placed in shelters and time and date are noted. Tubes are recovered, thermally desorbed to measure mass
of collected benzene using GC/MS.
Fenceline Monitoring Program Requirements (3/3)
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Benzene concentration determined based on uptake rate and sampling interval. Measured concentration corrected to normal temperature
and pressure. The difference between the highest and lowest measured
benzene concentrations is determined. Annual rolling average of the difference is calculated. Corrective action is required if difference in concentrations
exceeds 9 µg/m3 as a rolling annual average
Concentrations Calculated Based on Uptake Rate and Sampling Interval𝐶𝐶m= 𝑚𝑚 ÷ 𝑈𝑈 × 𝑡𝑡 × 106
Where:
Cm = measured concentration in µg/m3
m = desorbed mass in µgU = diffusion sampler uptake rate in ml/mint = sampling time in minutes
Cm is then corrected to normal temperature and pressure
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Data Must be Evaluated within 30 Days of Sample Collection
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Determine ΔC
Root Cause Analysis within 5 Days:Instrumental leak inspection.
Visual leak inspection.Additional tube measurements.
Is ΔC ≥9 µg/m3?
Is ΔC ≥9 µg/m3?
Conduct Sampling Episode
Repeat Sampling Episode Following Completion of Corrective Actions
Sampling Episodes ContinueDuring this Period
Prepare & Submit Corrective Action Plan to Administrator
Yes
No
No
Yes
Determine highest & lowest benzene concentrations
Complete Corrective Actions within 45 Days
Capped Diffusive Sampling Tube with Diffusion Cap
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Photo courtesy of Enthalpy Analytical, Inc.
Diffusive Sampling Tubes with Diffusion Caps
14Photo courtesy of Camsco, Inc.
Monitoring Shelter Showing Diffusive Sampling Tube
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Photo courtesy of Camsco, Inc.
Monitoring Shelter Showing Diffusive Sampling Tube
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Photo courtesy of Enthalpy Analytical, Inc.
Diffusion Sampling Tubes Loaded into Thermal Desorption Unit
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Photo courtesy of Enthalpy Analytical, Inc.
Fenceline Monitoring Program Design Considerations Although less sophisticated than instrumental measurement methods, defined
protocols govern fenceline monitoring program design. May want to gather a year’s worth of data in advance of the compliance date. Tube inventory should allow for those in sampling mode, those undergoing
analysis, and a reserve inventory. Lab turnaround is an important consideration given that data must be
evaluated within 30 days of sample collection. Efficient program execution will minimize manual data handling and processing. Tube life is generally estimated to be 50 thermal cycles. Root cause analysis and adherence to corrective action plan are important
compliance aspects
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Acknowledgements
Images on slides 14 & 15.Camsco, Inc.6732 Mayard Road, Houston, TX 77041Ying T. Gao, Ph.D.VP Science [email protected]
Images on slides 13, 16 & 17.Enthalpy Analytical, Inc.800 Capitola DriveDurham, NC [email protected]
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Fenceline Monitoring Program Requirements (2/4)
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Key EPA Documents Govern Sampling Program
EPA-454/R-99-005, Meteorological Guidance for Regulatory Modeling Applications, February 2000
EPA-454/B-08-002, Quality Assurance Handbook for Air Pollution Measurement Systems, Volume IV: Meteorological Measurements, March 2008
EPA-454/B-13-003, Quality Assurance Handbook for Air Pollution Measurement Systems, Volume II: Ambient Air Quality Monitoring Program, May 2013
