An Overview of Proposed Petroleum Refinery Fenceline Monitoring Requirements. A&WMA ACE 2015 Monitoring HAPs in Ambient Air Paper 309 June 23, 2015

Transcription

1 An Overview of Proposed Petroleum Refinery Fenceline Monitoring Requirements A&WMA ACE 2015 Monitoring HAPs in Ambient Air Paper 309 June 23, 2015

2 Presentation Objectives 1. Review regulatory framework and recent history 2. Provide a broad overview of fenceline monitoring requirements 3. Examine some of the details and challenges associated with implementing the regulatory requirements. 2

3 Refinery Emissions Have Been Regulated for Decades By Two Standards 1. New Source Performance Standards (NSPS) 1974: Fuel Gas Combustion Devices, Fluid Cat Cracking Units, Sulfur Plants 2008: Above plus Delayed Cokers, Flares, Process Heaters 2. Maximum Achievable Control Technology (MACT) Standards 1995 (MACT 1): Non-combustion or Evaporative Sources (equipment leaks, tanks wastewater, miscellaneous process vents, heat exchange systems, cooling towers) 2002 (MACT 2): Combustion Sources (Cat Cracking Units, Catalytic Reformer Units, Sulfur Recover Units) 3

4 NSPS and MACT Require Periodic Reviews NSPS CAA Section 111 (b) requires EPA to set and periodically review emission standard for new sources of criteria air pollutants, volatile organic compounds, and other pollutants MACT CAA Section 112 (d) requires EPA to set emission standards for HAP emitted by major stationary sources based on performance of maximum achievable control technology Two reviews are required: Residual Risk Assessment Are further reductions warranted? Technology Are better controls now available? 4

5 Proposed Rule is Based on Risk and Technology Review Residual Risk and Technology Review are driving the requirements Signed on 5/15/2014 in compliance with a court order Published in FR on 6/30/2014 (FR 79, ) Promulgated rule originally scheduled for 4/17/2015 Date extended to 6/16/15 and then 9/30/15 Proposed Rule modifies Refinery MACT I, 40 CFR 63 Subpart CC Refinery MACT II, 40 CFR 63 Subpart UUU NSPS Subparts J and Ja 5

6 Proposed Rule Establishes Three Key Requirements 1. Emission control requirements for: Storage Tanks Flares Delayed Coking Units 2. Elimination of exemptions to emission limits during startup, shutdown, and malfunctions 3. Fenceline monitoring for benzene Method 325 A: VOC from Fugitive & Ambient Sources (Sampler Placement) Method 325 B: VOC from Fugitive & Ambient Sources (Analysis) 6

7 Fenceline Monitoring Program Requirements (1/3) Deploy a network of diffusive samplers around the perimeter of the site in accordance with EPA Method 325A. Two deployment options: 1. Placed at different angles circling the geometric center of the facility along the fenceline. Size of property determines the angles. 2. Placed along the fenceline every 2000 meters with additional monitors placed near wastewater treatment units or Group 1 storage vessels. Monitor placed m above the ground. 7

8 Monitor Placement Varies with Facility Size (1a/3) Facility Size, Acres Angle, Degrees Number of Monitors Less than or equal to Greater than 750 but less than Greater than 1500 acres samplers placed along fenceline Note that extra samplers are required near known sources of VOC emissions 8

9 Fenceline Monitoring Program Requirements (2/3) Sampling episode is defined as 14 days unless there is a reason to sample for a shorter period. Must be one co-located sample for every 10 collected samples. Must be one field blank for every 10 collected samples. Background adjustments are allowed if described in a sampling plan that is submitted to agency for review and approval. Tubes placed in shelters and time and date are noted. Tubes are recovered, thermally desorbed to measure mass of collected benzene using GC/MS. 9

10 Fenceline Monitoring Program Requirements (3/3) Benzene concentration determined based on uptake rate and sampling interval. Measured concentration corrected to normal temperature and pressure. The difference between the highest and lowest measured benzene concentrations is determined. Annual rolling average of the difference is calculated. Corrective action is required if difference in concentrations exceeds 9 µg/m 3 as a rolling annual average 10

11 Concentrations Calculated Based on Uptake Rate and Sampling Interval CC m = mm UU tt 10 6 Where: C m = measured concentration in µg/m 3 m = desorbed mass in µg U = diffusion sampler uptake rate in ml/min t = sampling time in minutes C m is then corrected to normal temperature and pressure 11

12 Data Must be Evaluated within 30 Days of Sample Collection Determine highest & lowest benzene concentrations Determine ΔC Conduct Sampling Episode No Is ΔC 9 µg/m3? Yes Root Cause Analysis within 5 Days: Instrumental leak inspection. Visual leak inspection. Additional tube measurements. Sampling Episodes Continue During this Period Complete Corrective Actions within 45 Days Repeat Sampling Episode Following Completion of Corrective Actions No Is ΔC 9 µg/m3? Yes Prepare & Submit Corrective Action Plan to Administrator 12

13 Capped Diffusive Sampling Tube with Diffusion Cap Photo courtesy of Enthalpy Analytical, Inc. 13

14 Diffusive Sampling Tubes with Diffusion Caps Photo courtesy of Camsco, Inc. 14

15 Monitoring Shelter Showing Diffusive Sampling Tube Photo courtesy of Camsco, Inc. 15

16 Monitoring Shelter Showing Diffusive Sampling Tube Photo courtesy of Enthalpy Analytical, Inc. 16

17 Diffusion Sampling Tubes Loaded into Thermal Desorption Unit Photo courtesy of Enthalpy Analytical, Inc. 17

18 Fenceline Monitoring Program Design Considerations Although less sophisticated than instrumental measurement methods, defined protocols govern fenceline monitoring program design. May want to gather a year s worth of data in advance of the compliance date. Tube inventory should allow for those in sampling mode, those undergoing analysis, and a reserve inventory. Lab turnaround is an important consideration given that data must be evaluated within 30 days of sample collection. Efficient program execution will minimize manual data handling and processing. Tube life is generally estimated to be 50 thermal cycles. Root cause analysis and adherence to corrective action plan are important compliance aspects 18

19 Acknowledgements Images on slides 14 & 15. Camsco, Inc Mayard Road, Houston, TX Ying T. Gao, Ph.D. VP Science Director Images on slides 13, 16 & 17. Enthalpy Analytical, Inc. 800 Capitola Drive Durham, NC

20 Questions? David Elam P: E: 20

21 Fenceline Monitoring Program Requirements (2/4) Key EPA Documents Govern Sampling Program EPA-454/R , Meteorological Guidance for Regulatory Modeling Applications, February 2000 EPA-454/B , Quality Assurance Handbook for Air Pollution Measurement Systems, Volume IV: Meteorological Measurements, March 2008 EPA-454/B , Quality Assurance Handbook for Air Pollution Measurement Systems, Volume II: Ambient Air Quality Monitoring Program, May