ENV-16-73 Refinery Fenceline Monitoring Implications for Petrochemical Industry

Description:

Due to the proximity of petrochemical facilities to petroleum refineries in many places, the petrochemical sector inevitably will be affected by the refinery fenceline monitoring required by the refining sector’s Risk and Technology Review (RTR) rule. Although the refinery RTR rule covers only sources subject to Refinery MACT 1 and MACT 2, the fenceline monitoring provisions require the collection of samples which represent fenceline ambient benzene concentrations, and those ambient benzene concentrations can include contributions from petrochemical units both onsite at refineries and offsite. The U.S. Environmental Protection Agency (EPA) acknowledged these potential contributions from sources not subject to Refinery MACT requirements and included specific provisions for excluding contributions from such “near-field interfering sources” (NFS) from a refinery’s reported ambient benzene concentrations. In the site-specific fenceline monitoring plans required for excluding NFS contributions, the individual NFS must be identified, and the NFS contribution to refinery ambient benzene concentrations must be quantified in some form. This paper will explore some of the potential air permitting and enforcement implications of the refinery fenceline monitoring requirements on petrochemical facilities and some considerations for petrochemical facilities that may be identified as NFS in refinery site-specific fenceline monitoring plans.