1. Evaluation of Benzene Fenceline Monitoring Program in USEPA’s Proposed Refinery Sector Rule
BY: Ted Bowie, Carla Kinslow, Steven Ramsey, Shagun Bhat

2. Overview of Refinery Source Category
Data source: USEPA
142 large (major sources) and 7 small (area source) petroleum refineries in the United States
USEPA: Refineries emit ~20,000 tons per year hazardous air pollutants (HAPs)
Proposed rulemaking includes amendments to Maximum Achievable Control Technology (MACT) standards and New Source Performance Standards (NSPS)
MACT 1 (1995) covers non-combustion or evaporative sources (e.g., equipment leaks, tanks, wastewater, miscellaneous process vents, cooling towers)
MACT 2 (2002) covers combustion sources (e.g., catalytic cracking units, catalytic reforming units, and sulfur recovery units)
NSPS J/Ja (2012) covers fuel gas combustion devices, FCCU, sulfur plants, delayed cokers, flares, and process heaters

3. Overview of Proposed Rule
Proposal signed by USEPA on May 15, 2014
Emission control requirements for storage tanks, flares, and coking units
Monitoring of benzene concentrations at refinery fencelines
Eliminate exemptions to emission limits during periods of startup, shutdown, and malfunction
Technical corrections and clarifications to the Petroleum Refinery NSPSs

4. What Does USEPA’s Residual Risk Analysis Show?
Risk deemed to be “acceptable” under 112(f)
Highest maximum individual risk (MIR) estimated at 60 in a million (actuals) and 100 in a million (allowables)
Highest MIR driven by naphthalene and benzene from equipment leaks
Sector-wide population at risk greater than 1 in a million is predicted at 5,000,000
Cancer incidence of 0.3 cases/year driven by delayed cokers (DCU) and PAHs
Maximum chronic non-cancer HI of 0.9 due to emissions hydrogen cyanide from FCCU
Maximum acute non-cancer HQ of 5 due to emissions of nickel from FCCU
Proposed amendments estimated to lower population at risk to 4,000,000, and reduce incidence about 18%

5. Rationale for Benzene Fenceline Monitoring Program
Purpose: “Backstop” to detect under-counted emissions (particularly fugitives)
Certain emissions sources (e.g., fugitive leaks) difficult to quantify with methods currently available
Uncertainties in emissions estimates related to mischaracterization of emission sources:
Exclusion of nonroutine emissions
Omission of sources that are unexpected, not measured, or not considered part of the affected source
Improper characterization of sources for emission models and emission factors
Data source: USEPA
Model Plant Costs (in 2009$) for Fenceline Monitoring
Model Plant
Capital Costs, $
Annualized Cost, $
In-house Analysis
Outsourced Analysis
Small
85,440
21,370
36,300
64,200
Medium
86,650
22,580
41,000
86,900
Large
88,270
23,960
45,900
109,700

6. Fenceline Monitoring Requirements15 30 45 60 75 90
105
120
135
150
165
180
195
210
225
240
255
270
285
300
315
330
345
100 80 60 40 20
340
320
300
280
260
240
220
200
180
160
140
120 90
120
150
180
210
240
270
300
330 30 60
Small
(<750 acres)
12 monitors
30° interval
Medium
(750-1,500 acres)
18 monitors
20° interval
Large
(>1,500 acres)
24 monitors
15° interval

7. Fenceline Monitoring Requirements (cont)
Passive diffusive tube monitors
Annual average of 2-week samples, calculated as:
Compare to action level of 9 µg/m3
Calculate rolling annual average within 30 days of completion of each sampling episode
If exceedance, initiate root cause analysis
Develop corrective action plan and take corrective action
Recordkeeping and Reporting
Report fenceline data within 45 days of the end of semiannual periods
Site specific ambient monitoring plan
HFC = Maximum (MFCi –OSCi)
Data source: USEPA

8. Potential Issues with Benzene Fenceline Monitoring Requirements
Possible community misunderstanding
Monitoring results largely dependent on configuration of benzene sources
Alternative chemicals may be better surrogates of fugitives from some refineries
Identification of background or offsite contributors difficult with passive sampling approach
Monitoring provides little (if any) information regarding which sources to control
Significant cost
No offramp for refineries with low benzene concentrations

9. Public Relations
Fenceline concentrations are not representative of chronic risks, but some members of the public may misunderstand the data
Stated purpose of benzene monitoring is to detect un-reported emissions, but…
Some might attempt to equate benzene concentrations to risks
Data will be publically available

10. Is Benzene the Best Surrogate for Fugitives?
Total VOCs might be a better surrogate
Not all facilities have large benzene emissions
Larger emissions of VOCs easier to measure/detect
Affordable, real-time instrumentation for measurement of total VOCs (e.g., PID) allows correlation with wind direction
Benzene
Total VOCs
Average Fugitive Emissions (% of total)
64%
Total Emissions (1,000 TPY)
1.2 99
Facility Counts
142

11. Identification of Background Difficult with Passive Sampling
Facility 1
Facility 2
Facility 3

12. Identification of Background Difficult with Passive Sampling (cont)
Facility 1
Facility 2
Facility 3

13. Identification of Offsite Contributors Difficult with Passive Sampling
Facility 1
Facility 2
Facility 3

14. Identification of Offsite Contributors Difficult with Passive Sampling (cont)
Facility 1
Facility 2
Facility 3

15. Configuration Determines Whether Monitoring Provides Information on Which Sources to Control

16. Costs for Fenceline Monitoring
Significant Cost
Does not include costs for:
Site specific monitoring plan
Root cause analysis
Corrective action plan and implementation
Costs for Fenceline Monitoring
Model Plant
Capital Costs (US$)
Annualized Cost (US$)
In-House Analysis
Outsourced Analysis
Small
85,440
21,370
36,300
64,200
Medium
86,650
22,580
41,000
86,900
Large
88,270
23,960
45,900
109,700

17. Strategies to Overcome Program Limitations
Conduct dispersion modeling
Identify which sources are driving benzene concentrations
Identify benzene “hot spots”
Perform meteorological data analysis
Determine if winds are consistent, or if diurnal or seasonal variations are present
Identify which monitors are upwind and downwind (if possible)
Model Plant Costs (in 2009$) for Fenceline Monitoring
Model Plant
Capital Costs, $
Annualized Cost, $
In-house Analysis
Outsourced Analysis
Small
85,440
21,370
36,300
64,200
Medium
86,650
22,580
41,000
86,900
Large
88,270
23,960
45,900
109,700

18. Strategies to Overcome Program Limitations (cont)
Consider additional monitors
Offsite monitors can help tease out background and offsite sources
Onsite monitors can help identify larger fugitive sources (e.g., LDAR)
Consider focused real-time monitoring
Determine if concentrations due to onsite or offsite sources
Identify and correct problems quicker than with passive approach
Options range from simplistic (e.g., PID) to more sophisticated (e.g., UV-DOAS)
Model Plant Costs (in 2009$) for Fenceline Monitoring
Model Plant
Capital Costs, $
Annualized Cost, $
In-house Analysis
Outsourced Analysis
Small
85,440
21,370
36,300
64,200
Medium
86,650
22,580
41,000
86,900
Large
88,270
23,960
45,900
109,700

19. Strategies to Overcome Program Limitations (cont)
Potential open-path monitoring approaches:
Short-term surveys to evaluate emissions in detail.
Example technologies: Differential Absorption LIDAR (DIAL) and Solar Occultation Flux (SOF).
Advantages: detailed dimensional evaluation of refinery sources for use in improving understanding of emission sources and effectiveness of potential emission control strategies.
Disadvantages: When used alone, limited value in detecting transient emission events and/or emission sources that evolve over time (e.g. large leaks). Can also be pricey.
Two scan planes of total alkanes at a petroleum refinery as measured by National Physical Laboratory DIAL system
Mass flux of total alkanes and benzene at a refinery tank farm as measured by FluxSense AB SOF system
Model Plant Costs (in 2009$) for Fenceline Monitoring
Model Plant
Capital Costs, $
Annualized Cost, $
In-house Analysis
Outsourced Analysis
Small
85,440
21,370
36,300
64,200
Medium
86,650
22,580
41,000
86,900
Large
88,270
23,960
45,900
109,700

20. Strategies to Overcome Program Limitations (cont)
Long-term / permanent open-path installations.
Can be pollutant specific (e.g. use of UV-DOAS to measure benzene concentrations or can provide information on a wide range of pollutants (e.g. OP-FTIR).
Advantages:
When combined with wind data, can provide near real-time information on direction and magnitude of emission sources – very useful in conducting root cause analyses.
Can also be used to develop an affirmative defense that elevated benzene concentration(s) are exclusively or primarily resulting from off-refinery emission source contributions.
Long-term measurements will capture transient events and/or emissions that develop over time.
Use of OP-FTIR system can give detailed speciation of plumes, additional information that can be used in identifying source(s) of emissions.
Disadvantages:
Density of data is much higher than obtained using passive- diffusive monitors. Unprotected data could be problematic.
Higher cost than passive-diffusive monitoring approach.
Integration of short- and long-term open-path technologies.
Two IMACC OP-FTIR systems have been deployed continuously at TPC Houston Plant for much of the past decade
OPSIS has hundreds or thousands of UV-DOAS systems deployed world-wide
Model Plant Costs (in 2009$) for Fenceline Monitoring
Model Plant
Capital Costs, $
Annualized Cost, $
In-house Analysis
Outsourced Analysis
Small
85,440
21,370
36,300
64,200
Medium
86,650
22,580
41,000
86,900
Large
88,270
23,960
45,900
109,700

21. Risk Communication at the Fenceline
Carla Kinslow, Ph.D.
ENVIRON International Corporation
Houston, TX

22. USEPA Requirement (draft): Data available to the public
“Fenceline data at each monitor location be reported electronically for each semiannual period’s worth of sampling periods (i.e., 13 to week sampling periods per semiannual period). These data would be reported within 45 days of the end of each semiannual period, and will be made available to the public through the USEPA’s electronic reporting and data retrieval portal, in keeping with the USEPA’s efforts to streamline and reduce reporting burden and to move away from hard copy submittals of data where feasible.”

23. What we do not want to see…“ “
More than 200 Arrested in Chevron Richmond Refinery Protest
East Bay Oil Refinery Protest Draws About 100 Demonstrators
By KQED News Staff and Wires
AUG 4, 2013”
CALIFORNIA, CHEVRON, OIL, PROTEST  By Jean Tepperman,  May 21st, 2014 ” ”

24. Website for finding your nearest Oil Refinery Protest:

25. Risk Communication Strategies
Early elements
Early education
Transparency
What you expect
Intentional
Later Elements – Data interpretation
What it means
Open communication
Data summaries
Dialogue to resolve exceedances

26. What will communities expect?
2013 pilot study on Community Advisory Panel (CAP) Topics in the Houston Ship Channel

27. View from the front porch
In the 1990’s - Community Monthly Meetings
Different FLC’s in and around the their industrial areas
Geographic areas
Monthly meetings organized and lead by a non-bias facilitator
The local industry leaders participate
Share concerns, discussions, open forum for concerns for the communities

28. Community No. 1 Fence Line Community Interest Study Main topics of meetings (1997-2013)
We can narrow these interests to about nine (~9) main topics
Constant Topics –
1 – Communication
2 – Safety (Worker Safety)
3 – Air Quality – Environmental/Health impacts from the plants
Proactive Actions – Gaining trust
The first with the information
Plant trips
Educational presentations – what they make
Bring in presenters from regulatory agencies, environmentalist
Address current media issues
Transportation

29. Safety – highest concern
Communities 1, 2 and 3
Fence Line Community Interest Study
Main topics of meetings ( ) 30 25 20 15 10 5
Safety
Air Quality
% of all events (n=40)
Transportation
Better communication
Waste
Future plans
Plant Tours
Water use
Jobs in the industry
Chemistry

30. These findings reflect a relational theory of risk communication
Recognizing the perceived object at risk
Environmental
From the city’s perspective
Safety
Freedom?
Communicating the correct risk object
Toxins in the air
Explosion
Communicating the correct association between the two
Education, Data
Risk communication is a social process
Social trust

31. Communicating inconclusive data
These data are changing
Experts are ok with this – it’s normal
Overcoming the knowledge gap
Taking-on the role of educator
Recognizing and communicating what are the next steps
Example – “the preliminary data says…more data is coming…we will be much more certain when we have…amount/type of data…”
Communicating the strength of evidence
Evidence map
Speaking as a scientist
Non-bias
Weight of evidence

32. A Team Skills Cross trained in the other disciplines
Technical – Geology/Engineering
Health Impacts – Toxicology
Regulatory – various skills
Communications – Seasoned Communicator
Business – Economics
Cross trained in the other disciplines
Culturally educated
Invest in time with the community – visibility

33. Summary Trust and Relationship is gained through Proactive
Consistency
Honesty
Transparency
Proactive
Learning from established FLC
These communities change with time
View the Community as a part of the industry

34. Questions? Ted Bowie, MS, PE, CIH tbowie@environcorp.com
Carla Kinslow, PhD
Steven Ramsey, PE, BCEE
Shagun Bhat, PhD