Evaluation of Benzene Fenceline Monitoring Program in USEPA’s Proposed Refinery Sector RuleBY:Ted Bowie, Carla Kinslow, Steven Ramsey, Shagun Bhat

• 142 large (major sources) and 7 small (area source) petroleum refineries in the United States

• USEPA: Refineries emit ~20,000 tons per year hazardous air pollutants (HAPs)

• Proposed rulemaking includes amendments to Maximum Achievable Control Technology (MACT) standards and New Source Performance Standards (NSPS)– MACT 1 (1995) covers non-combustion or evaporative sources

(e.g., equipment leaks, tanks, wastewater, miscellaneous process vents, cooling towers)

– MACT 2 (2002) covers combustion sources (e.g., catalytic cracking units, catalytic reforming units, and sulfur recovery units)

– NSPS J/Ja (2012) covers fuel gas combustion devices, FCCU, sulfur plants, delayed cokers, flares, and process heaters

Overview of Refinery Source Category

Data source: USEPA

Overview of Proposed Rule

• Proposal signed by USEPA onMay 15, 2014

• Emission control requirements for storage tanks, flares, and coking units

• Monitoring of benzene concentrations at refinery fencelines

• Eliminate exemptions to emission limits during periods of startup, shutdown, and malfunction

• Technical corrections and clarifications to the Petroleum Refinery NSPSs

What Does USEPA’s Residual Risk Analysis Show?

• Risk deemed to be “acceptable” under 112(f)

• Highest maximum individual risk (MIR) estimated at 60 in a million (actuals) and 100 in a million (allowables)– Highest MIR driven by naphthalene and benzene from equipment leaks

• Sector-wide population at risk greater than 1 in a million is predicted at 5,000,000– Cancer incidence of 0.3 cases/year driven by delayed cokers (DCU)

and PAHs

• Maximum chronic non-cancer HI of 0.9 due to emissions hydrogen cyanide from FCCU

• Maximum acute non-cancer HQ of 5 due to emissions of nickel from FCCU

• Proposed amendments estimated to lower population at risk to 4,000,000, and reduce incidence about 18%

Rationale for Benzene Fenceline Monitoring Program

• Purpose: “Backstop” to detect under-counted emissions (particularly fugitives)

• Certain emissions sources (e.g., fugitive leaks) difficult to quantify with methods currently available

• Uncertainties in emissions estimates related to mischaracterization of emission sources:– Exclusion of nonroutine emissions

– Omission of sources that are unexpected, not measured, or not considered part of the affected source

– Improper characterization of sources for emission models and emission factors

Data source: USEPA

Fenceline Monitoring Requirements

Small (<750 acres)

12 monitors

30° interval

100

80

60

40

200

340

320

300

280

260

240

220

200180

160

140

120

90

120

150180210

240

270

300

3300 30

60

0 1530

4560

75

90

105

120

135150

165180195210

225

240

255

27

0285

300

315

330345

Medium (750-1,500

acres)

18 monitors

20° interval

Large(>1,500 acres)

24 monitors

15° interval

• Passive diffusive tube monitors• Annual average of 2-week samples,

calculated as:

• Compare to action level of 9 µg/m3

• Calculate rolling annual average within 30 days of completion of each sampling episode– If exceedance, initiate root cause analysis – Develop corrective action plan and take

corrective action

• Recordkeeping and Reporting – Report fenceline data within 45 days of

the end of semiannual periods– Site specific ambient monitoring plan

Fenceline Monitoring Requirements (cont)

HFC = Maximum (MFCi –OSCi)

Data source: USEPA

Potential Issues with Benzene Fenceline Monitoring Requirements

• Possible community misunderstanding

• Monitoring results largely dependent on configuration of benzene sources

• Alternative chemicals may be better surrogates of fugitives from some refineries

• Identification of background or offsite contributors difficult with passive sampling approach

• Monitoring provides little (if any) information regarding which sources to control

• Significant cost

• No offramp for refineries with low benzene concentrations

Public Relations

• Fenceline concentrations are not representative of chronic risks, but some members of the public may misunderstand the data

• Stated purpose of benzene monitoring is to detect un-reported emissions, but…– Some might attempt to equate benzene

concentrations to risks

– Data will be publically available

Is Benzene the Best Surrogate for Fugitives?

Total VOCs might be a better surrogate• Not all facilities have large benzene emissions

• Larger emissions of VOCs easier to measure/detect

• Affordable, real-time instrumentation for measurement of total VOCs (e.g., PID) allows correlation with wind direction

Benzene Total VOCs

Average Fugitive Emissions (% of total) 64% 64%

Total Emissions (1,000 TPY) 1.2 99

Facility Counts 142 142

Identification of Background Difficult with Passive Sampling

Facility 1

Facility 2

Facility 3

Identification of Background Difficult with Passive Sampling (cont)

Facility 1

Facility 2

Facility 3

Identification of Offsite Contributors Difficult with Passive Sampling

Facility 1

Facility 2

Facility 3

Identification of Offsite Contributors Difficult with Passive Sampling (cont)

Facility 1

Facility 2

Facility 3

Configuration Determines Whether Monitoring Provides Information on Which Sources to Control

Significant Cost

Does not include costs for:• Site specific monitoring plan

• Root cause analysis

• Corrective action plan and implementation

Costs for Fenceline Monitoring

Model Plant

Capital Costs (US$) Annualized Cost (US$)

In-House AnalysisOutsourced

AnalysisIn-House Analysis

Outsourced Analysis

Small 85,440 21,370 36,300 64,200

Medium 86,650 22,580 41,000 86,900

Large 88,270 23,960 45,900 109,700

Strategies to Overcome Program Limitations

• Conduct dispersion modeling– Identify which sources are driving

benzene concentrations

– Identify benzene “hot spots”

• Perform meteorological data analysis– Determine if winds are consistent,

or if diurnal or seasonal variations are present

– Identify which monitors are upwind and downwind (if possible)

Strategies to Overcome Program Limitations (cont)

• Consider additional monitors– Offsite monitors can help tease out

background and offsite sources

– Onsite monitors can help identify larger fugitive sources (e.g., LDAR)

• Consider focused real-time monitoring – Determine if concentrations due to

onsite or offsite sources

– Identify and correct problems quicker than with passive approach

– Options range from simplistic (e.g., PID) to more sophisticated (e.g., UV-DOAS)

Strategies to Overcome Program Limitations (cont)

• Potential open-path monitoring approaches:1. Short-term surveys to evaluate emissions in detail.

• Example technologies: Differential Absorption LIDAR (DIAL) and Solar Occultation Flux (SOF).

• Advantages: detailed dimensional evaluation of refinery sources for use in improving understanding of emission sources and effectiveness of potential emission control strategies.

• Disadvantages: When used alone, limited value in detecting transient emission events and/or emission sources that evolve over time (e.g. large leaks). Can also be pricey.

Mass flux of total alkanes and benzene at a refinery tank farm as measured by FluxSense AB SOF system

Two scan planes of total alkanes at a petroleum refinery as measured by National Physical Laboratory DIAL system

Strategies to Overcome Program Limitations (cont)

2. Long-term / permanent open-path installations. • Can be pollutant specific (e.g. use of UV-DOAS to

measure benzene concentrations or can provide information on a wide range of pollutants (e.g. OP-FTIR).

• Advantages:

– When combined with wind data, can provide near real-time information on direction and magnitude of emission sources – very useful in conducting root cause analyses.

– Can also be used to develop an affirmative defense that elevated benzene concentration(s) are exclusively or primarily resulting from off-refinery emission source contributions.

– Long-term measurements will capture transient events and/or emissions that develop over time.

– Use of OP-FTIR system can give detailed speciation of plumes, additional information that can be used in identifying source(s) of emissions.

• Disadvantages:

– Density of data is much higher than obtained using passive-diffusive monitors. Unprotected data could be problematic.

– Higher cost than passive-diffusive monitoring approach.

3. Integration of short- and long-term open-path technologies.

Two IMACC OP-FTIR systems have been deployed continuously at TPC Houston Plant for much of

the past decade

OPSIS has hundreds or thousands of UV-DOAS systems deployed world-wide

Carla Kinslow, Ph.D.ENVIRON International CorporationHouston, TX

Risk Communication at the Fenceline

USEPA Requirement (draft):Data available to the public

“Fenceline data at each monitor location be reported electronically for each semiannual period’s worth of sampling periods (i.e., 13 to 14 2-week sampling periods per semiannual period).

These data would be reported within 45 days of the end of each semiannual period,

and will be made available to the public through the USEPA’s electronic reporting and data retrieval portal, in keeping with the USEPA’s efforts to streamline and reduce reporting burden and to move away from hard copy submittals of data where feasible.”

More than 200 Arrested in Chevron Richmond Refinery Protest

East Bay Oil Refinery Protest Draws About 100 Demonstrators

What we do not want to see…

By KQED News Staff and WiresAUG 4, 2013”

CALIFORNIA, CHEVRON, OIL, PROTEST By Jean Tepperman, www.eastbayexpress.comMay 21st, 2014

“

”

“

”

https://www.google.com/maps/d/viewer?mid=zjpyd3HCGpZc.kGZ_8kcWmueI&hl=en&ie=UTF8&msa=0&ll=56.018775,-3.707972&spn=8.320716,19.248047&z=6

Website for finding your nearest Oil Refinery Protest:

Risk Communication Strategies

• Early elements– Early education

– Transparency

– What you expect

– Intentional

• Later Elements – Data interpretation– What it means

– Open communication

– Data summaries

– Dialogue to resolve exceedances

What will communities expect?

2013 pilot study on Community Advisory Panel (CAP) Topics in the Houston Ship Channel

View from the front porch

Safe

ty

Bette

r com

mun

icat

ions

Air Qua

lity

Tra

nspo

ratio

n

Futu

re p

lans

Plan

t Tou

rs

Jobs

in th

e in

dust

ry

Was

te

Educ

atio

n0

5

10

15

20

25

30

35

% o

f to

tal m

eeti

ngs

Tran

spor

tatio

n

Community No. 1Fence Line Community Interest Study Main topics of meetings (1997-2013)

Safety – highest concern

Communities 1, 2 and 3Fence Line Community Interest StudyMain topics of meetings (2012-2013)

% o

f all

even

ts (

n=

40

)

Jobs in the

industry

Chemistry

30

25

20

15

10

5

0

Safety Air Quality

Transportation Better communicatio

n

Plant Tours

Future plans

Water useWaste

These findings reflect a relational theory of risk communication

• Recognizing the perceived object at risk– Environmental

– From the city’s perspective

– Safety

– Freedom?

• Communicating the correct risk object– Toxins in the air

– Explosion

• Communicating the correct association between the two– Education, Data

• Risk communication is a social process– Social trust

Communicating inconclusive data

• These data are changing– Experts are ok with this – it’s normal

• Overcoming the knowledge gap – Taking-on the role of educator

– Recognizing and communicating what are the next steps• Example – “the preliminary data says…more data is coming…we will be

much more certain when we have…amount/type of data…”

– Communicating the strength of evidence• Evidence map

– Speaking as a scientist • Non-bias

• Weight of evidence

A Team

• Skills– Technical – Geology/Engineering

– Health Impacts – Toxicology

– Regulatory – various skills

– Communications – Seasoned Communicator

– Business – Economics

• Cross trained in the other disciplines

• Culturally educated

• Invest in time with the community – visibility

Summary

• Trust and Relationship is gained through– Consistency

– Honesty

– Transparency

• Proactive

• Learning from established FLC

• These communities change with time

• View the Community as a part of the industry

Questions?

Ted Bowie, MS, PE, CIHtbowie@environcorp.com

Carla Kinslow, PhDckinslow@environcorp.com

Steven Ramsey, PE, BCEEsramsey@environcorp.com

Shagun Bhat, PhDsbhat@envioncorp.com