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

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

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

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%

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

Fenceline Monitoring Requirements 15 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

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

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

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

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

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

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

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

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

Configuration Determines Whether Monitoring Provides Information on Which Sources to Control

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

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

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

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

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

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

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 14 2- 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.”

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,  www.eastbayexpress.com May 21st, 2014 ” ”

Website for finding your nearest Oil Refinery Protest: https://www.google.com/maps/d/viewer?mid=zjpyd3HCGpZc.kGZ_8kcWmueI&hl=en&ie=UTF8&msa=0&ll=56.018775,-3.707972&spn=8.320716,19.248047&z=6

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

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

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

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

Safety – highest concern Communities 1, 2 and 3 Fence Line Community Interest Study Main topics of meetings (2012-2013) 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

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

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

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

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

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