ENV-17-36 Three Year Benzene Pilot Study Yields Valuable Data and Solutions

Description:

In 2014, the American Petroleum Institute (API) published findings of a six-week fenceline monitoring study of benzene at 12 refineries as part of a response to the USEPA “Petroleum Refinery Sector Risk and Technology Review and New Source Performance Standards: Proposed Rule” at 79 Fed. Reg. 36880 (June 30, 2014). While the outcomes of this study may be considered sufficient in some instances in characterizing fugitive emissions data, the six-week time frame may not adequately capture the range of emissions that may occur over the course of a 52-week year. In an effort to establish a reliable baseline concentration at the Marathon Robinson, IL refinery, the benzene pilot study has continued for the three years since the API study was completed. In that time, variables that impact emissions have occurred, such as turnaround/maintenance and ambient temperature fluctuations. Commencing in 2018, refineries throughout the US will be required to comply with the Fenceline Monitoring requirements outlined in the Refinery Sector Rule. During this extended study, the Marathon Robinson facility has been able to pinpoint and troubleshoot areas along the fenceline prior to rule implementation. This paper outlines the fundamentals of passive fenceline monitoring, including tube preparation and placement, replacement requirements, shipping logistics and chain of custody preparation, report formats, units and timing. This paper also elaborates on lessons learned regarding the impact of meteorological differences, troubleshooting and preventative maintenance near aromatic tanks and other known sources, streamlining of sampling logistics, general approaches when situations such as exceedances were experienced, and discusses the importance of the relationship between facility and laboratory for successful implementation and execution of a monitoring program.