The Refinery Sector Rule (RSR) establishes a requirement for fenceline monitoring of benzene using passive sampling devices. When the action level for benzene is exceeded, the facility must perform a root cause analysis. If action level exceedances persist following completion of corrective actions, the facility must submit a formal corrective action plan to the regulatory agency. Importantly, the RSR recognizes that some regulated facilities may be affected by benzene emission sources that are not regulated by the RSR, but that may affect fenceline monitoring data. These sources, referred to in the RSR as near-field emission sources, can be recognized and accounted for in a site-specific monitoring plan. This presentation will examine the timeline for root cause analysis and corrective action and explain how near-field benzene emission sources can be addressed to prevent action level exceedances.

Primary Author/Presenter:
David L. Elam, Jr.
Vice President, Project Director
Chapel Hill, North Carolina