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ENV-17-03 Benzene Waste Operations NESHAP Compliance using Optical Gas Imaging

Erin Novini, Trihydro Corporation

Format:
Electronic (digital download/no shipping)

Associate Member, International Member, Petrochemical Member, Refining Member - $0.00
Government, NonMember - $0.00

Description:

By now, most affected petroleum refineries and chemical plants have mature compliance programs under 40 CFR Part 61, Subpart FF: National Emission Standards for Benzene Waste Operations (BWON). Many of these facilities struggle to maintain compliance via the required Method 21 monitoring for BWON programs: Closed Vent System (CVS) monitoring points are often unsafe or difficult to access, and Waste Management Units (WMU) do not always seal well. Additionally, efforts to align BWON regulations with other refinery monitoring programs such as Leak Detection and Repair (LDAR) that allow a variety of monitoring methods (i.e. Optical Gas Imaging [OGI]) have not been accepted by the United States Environmental Protection Agency (USEPA). USEPA, however, has begun to use these “Next Generation” methods during site audits for enforcement action, in particular using OGI options with infrared cameras. In some instances, facilities have been successful at obtaining USEPA approvals for specific OGI opportunities, and it is expected that this trend will continue until it becomes the norm. In this paper, Trihydro Corporation (Trihydro) examines USEPA's process for maintaining Method 21 for BWON inspections and explores a refinery’s options for using OGI to enhance BWON compliance. Trihydro offers project examples to demonstrate areas of success with using OGI. This “Next Generation” method, used in conjunction with Method 21, is recommended for ensuring more accurate monitoring results and reducing incidents of noncompliance and Findings of Violation (FOVs).

Product Details:

Product ID: ENV-17-03
Publication Year: 2017