In December 2015, the USEPA finalized a rule updating the “National Emission Standards for Hazardous Air Pollutants for Petroleum Refineries,” which, in 2018, will require all major source refineries to monitor and report volatile benzene concentrations around their fencelines. A new method was issued in support of this rule, which outlines the design, deployment, preparation, and analysis of passive sampling devices suspended around the refinery property line.
As the effective date of the rule quickly approaches, it is critical that refineries subject to the rule develop a site-specific plan to identify, quantify, and eliminate confounding sources. While the EPA projects the annual fiscal impact of this rule on the industry to be approximately $6 million/year, the American Petroleum Institute (API) suggests that the impact will actually be closer to $29 million/year.
Given the range of uncertainty associated with the cost projections, refineries will be paying close attention to the costs for fenceline monitoring. In their efforts to minimize the costs, refineries may inadvertently sacrifice expertise, data quality and service if they select subcontractors that lack adequate expertise.
This paper identifies key parameters that should be considered when contracting fenceline monitoring work, and highlight several pilot studies conducted across the US.
Product Innovation Manager
Simi Valley, California