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Benzene Fenceline Monitoring in Texas

Learn about benzene fenceline monitoring requirements in Texas and the importance of passive diffusive tube monitoring for detecting emissions and ensuring regulatory compliance. Understand sampling requirements and action levels for corrective action.<br>

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Benzene Fenceline Monitoring in Texas

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  1. Benzene Fenceline Monitoring in Texas Mike Miller and Keith Sheedy, P.E.Program Support and Environmental Assistance Division TCEQ Autumn Conference, October 9, 2019

  2. Part 63, Subpart CC Background • The EPA’s Petroleum Refinery Sector Risk and Technology Review (1st proposed in June 2014) stated: “This rule will virtually eliminate smoking flare emissions and upset emission events, and for the first time in a national regulation require refineries to monitor emissions at key emission sources within their facilities and around their fencelines.”

  3. Why Fenceline Monitoring of benzene? • Benzene is a refinery risk driver and also primarily emitted from fugitive sources • Fugitive emission sources could be a significant contributors to overall emissions from a refinery • Potential impacts from fugitive sources would likely occur by the property boundary near ground level • Fenceline monitoring could provide a direct measure of the annual average concentration directly surrounding the refinery Slide information obtained from 2015 EPA Refinery Fenceline Monitoring presentation

  4. Fenceline Monitoring – High-level RequirementsCorrective action and electronic reporting is required • Monitor air concentrations of benzene around the fenceline of a refinery using passive monitoring • Corrective action is required if the monitoring data exceeds an established benzene concentration • Electronically report the monitored benzene concentrations quarterly to the EPA for review and uploading onto public web page

  5. Why Use Passive Diffusive TubeMonitoring? • Allows for continual monitoring of pollutant concentrationsaroundthe entireplant • Has detection limits low enough to be able todetectthe concentrations of the pollutants in the ambient air near a refinery during typical operatingconditions

  6. Sampling Requirements • Sampling conducted along the facility property boundary and samples analyzed in accordance with Methods 325A and 325B • Location of the monitors is dictated by the rules and methods for spacing around perimeter of site • Include need for additional monitors to be placed where sources have potential emissions that contribute to off-property boundaries • The sampling periods is for 14-days • Collect and record meteorological data

  7. Example of FencelineMonitor Placement Slide information obtained from 2015 EPA Refinery Fenceline Monitoring presentation

  8. Fenceline Monitoring – High-level Requirements • Monitor air concentrations of benzene around the fenceline of a refinery using passive monitoring • Corrective action is required if the monitoring data exceeds an established benzene concentration • Electronically report the monitored benzene concentrations quarterly to the EPA for review and uploading onto public web page

  9. Action Level Based Requirements • Within 45 days of end of sampling period – determine if above or below action level • Action level (Δc) is 9 micrograms per cubic meter on an annual average (26 two-week sampling periods) • Δc - calculated as difference in highest and lowest sample results for a given two-week sample period

  10. What is the “Action Level” for FencelineMonitoring? 6.3μg/m3 0.2μg/m3 Δcfor a 2 week period = high - low = 6.3 μg/m3 - 0.2 μg/m3 = 6.1 μg/m3 Action Level = Annual Average Δc< 9μg/m3

  11. Action Level Based Requirements (cont.) • Within 5 days of determining action level has been exceeded for any annual average ∆c and no longer than 50 days after completion of the sampling period – initiate root cause analysis (RCA) and determine appropriate corrective action • RCA may include additional Method 21 monitoring, leak inspection using optical gas imaging, and/or more frequent passive sampling and analysis • Within 45 days of determining annual ∆c exceedance - RCA and initial corrective action analysis shall be COMPLETED and initial corrective actions taken

  12. Corrective Action Plan • If ∆c value for next 14-day sampling period > 9 μg/m3after completion of corrective actions or if all corrective actions measures identified require more than 45 days to implement, submit CAP which includes: • Corrective actions completed to date • Additional measures proposed to reduce fenceline concentrations below the action level • Schedule of completion for these measure

  13. Fenceline Monitoring – High-level RequirementsCorrective action is required • Monitor air concentrations of benzene around the fenceline of a refinery using passive monitoring • Corrective action is required if the monitoring data exceeds an established benzene concentration • Electronically report the monitored benzene concentrations quarterly to the EPA for review and uploading onto public web page

  14. Public Accessibility 30 days after report is submitted via CEDRI, report flows to EPA WebFIRE public database portal on EPA website: https://cfpub.epa.gov/webfire/

  15. Texas Specific Information

  16. Implementation Timeline • 01/30/18 – Petroleum refineries were required to begin collecting data • 05/15/19 – Initial reports were due to EPA’s Compliance and Emissions Data Reporting Interface (CEDRI), which is a reporting portal on EPA’s Central Data Exchange • 08/15/19 and quarterly thereafter – quarterly reports due to CEDRI • State reviewers have 30-day review period prior to report becoming publicly available

  17. EPA Approvals and TCEQ Granted Extensions • There are 26 sites in Texas that are reporting their sampling results • 8 petroleum refineries in Texas received approved site-specific monitoring plan approvals from EPA • 7 petroleum refineries received extensions for specific locations of monitors while alternative monitoring plans for EPA submission were being worked on

  18. Texas Specific Fenceline Data • 99 monitors and 3,527 rows of data from 4 petroleum refineries in TCEQ Region 10 Beaumont office area • 264 monitors and 11,275 rows of data from 9 petroleum refineries in the TCEQ Region 12 Houston office area • 169 monitors and 5,504 rows of data from 6 petroleum refineries in the TCEQ Region 14 Corpus Christi office area • 25,263 total rows of State-wide data reviewed during initial submittals

  19. Texas Specific Fenceline DataContinued • Many refineries began collecting data prior to initial compliance date for internal use • 34 reports submitted by initial compliance deadline of 5/15/19 • 6 sites submitted at least one 2-week sampling period Δc over 50 µg/m3 • 7 refineries reported annual average ∆c above the action level

  20. Observations From 1st Review Period • Supporting documentation submitted with one report for data anomaly in accordance with Section 9.2 of EPA Method 325A • One site voluntarily submitted data from 11/1/16 through end of initial compliance period encapsulated in 10 report submittals • Several companies submitted reports covering multiple facilities

  21. Issues From Review Period • Facility made aware of insufficient data and resubmitted • Samplers labeled as half numbers • Facility contacted and learned that half monitors installed as additional monitors • Reporting of annual average ∆c values prior to initial 26 two-week sampling periods • Facility contacted about over-reporting and resubmitted • Sampling data not reported until 14-day sampling period starting 12/27/18 • Facility contacted and resubmitted

  22. TCEQ Follow-up • During the State’s 30-day review period, the TCEQ has and will be sending letters to any site that reported an annual average ∆c concentrations above the action level. • The letters request an update on; root cause analysis, corrective action analysis, and corrective actions taken • Responses are required to be submitted to the TCEQ, within 30 days

  23. Potential Violations From the 1st of Report Investigations • Benzene action level is not directly enforceable, however, analyses and corrective actions requirements are. For example: • Failure to initiate root cause analysis and initial corrective action analysis within 50 days of the sampling period and completion of the analyses and initial corrective actions taken within 45 days of determining an exceedance • Failure to submit corrective action plan with required criteria within required timeframe

  24. Takeaways? • Per EPA: • Benzene action levels are not an ambient air standard and are not derived from any health-based benzene standard • Fenceline samplers are not intended to provide a measure of benzene levels in the community • While Δc values are not directly enforceable, the data can be used as a screening tool for follow-up investigations • An overall state-wide trend shows a reduction in reported annual Δc values

  25. Questions? Questions?

  26. Contact Information Mike Miller – 512-239-0516 Michael.Miller@tceq.texas.gov Keith Sheedy, P.E. - 512-239-1556 Keith.Sheedy@tceq.texas.gov

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