ENV-08-001 A Potential Residual Risk Regulatory Requirement for Refineries: Fenceline Monitoring for Benzene

Description:

The concerns about the effect of low bias on emission data driving residual risk assessments, coupled with general air quality concern in refinery communities, may drive some state or local governments to promulgate regulations requiring fenceline monitoring. In fact, there are pressures for such programs in California, Louisiana, and Texas. Furthermore, numerous court decisions over the past 2 years in which MACT standards have been vacated illustrate that promulgated regulations are far from certain, particularly when there is controversy about underlying data and the ability of a standard to achieve its goal relative to the Clean Air Act Amendments. Thus, fenceline monitoring for benzene remains an issue that individual refineries should understand.