The US EPA released a proposed rule which will update the standards for petroleum refineries that release hazardous air pollutants, requiring them to monitor benzene concentrations around the fenceline of their facilities, reduce flaring, and improve emissions controls. The proposed rule was published in the Federal Register on June 30, 2014.
Environmental Standards’ clients, and all refineries, will benefit from focusing on, and being concerned with, quality assurance while meeting the proposed fenceline benzene monitoring requirements. US EPA is proposing to establish an ambient concentration of benzene at the fenceline that would trigger required corrective action in the event of an exceedance. According to the Proposed Rule, costs for the fenceline monitoring methods are dependent on the sampling frequency (for passive and active monitoring locations) and the number of monitoring locations needed based on the size and geometry of the facility. The proposal identifies an annual average benzene concentration standard to be measured via 2-week integrated samples at the refinery fenceline perimeter. Twelve to 24 monitors are required at each facility, dependent on facility size.
The proposal suggests that fenceline data at each monitor location be reported electronically within 45 days of the end of each semi-annual period, and data will be made available to the public.
Based on Environmental Standards’ prior experience with benzene analyses, the amount of data and concentrations of benzene will challenge current analytical methods. We recommend that now is the time to start implementing quality assurance programs to ensure training of sampling personnel, instrument calibration and laboratory qualifications, accurate and defensible results, and properly managed and easily accessible data.
US EPA estimates that the rules will require a capital investment of $240 million, and recurring annual costs of $40 million for all of the nation’s refineries. The cost of building quality assurance into the process and periodically checking it on the back end will be relatively insignificant. If you’re curious about the QA process and how Environmental Standards can help, contact Technical Director of Chemistry/Principal Rock J. Vitale, CEAC at 610.935.5577.
Public comments on the proposed rule are due August 29, 2014. A copy of comments on the information collection provisions are to be submitted to Office of Management and Budget on or before July 30, 2014. US EPA will hold public hearings on July 16, 2014, in Wilmington, California and on August 5, 2014, in Galena Park, Texas. A decision on a final version of the rule is expected by April 17, 2015.
Update: EPA has extended the public comment period for the proposed Petroleum Refinery Risk and Technology Review and New Source Performance by 60 days; the comment period will now close October 28, 2014.