Improving Your Refinery’s Response to 325 Monitoring Issues

April 2, 2018

High concentrations from a refinery’s fenceline monitoring program are subject to the EPA’s reporting requirements and are available for processing by the general public. Any refinery reporting frequent high concentrations will be put immediately under the gun to minimize future elevated offsite impacts as soon as possible.

A failure to correct these issues quickly can have additional consequences. Sustained high fenceline monitoring values can result in future permitting/modeling scrutiny, additional future EPA regulations, added operational requirements and/or additional process controls. They can even result in future court settlement agreements with the EPA or members of the public.

The Typical 325 Monitoring Process

The typical 325 monitoring process goes something like this:

  • Sampling tubes are deployed along the fenceline.
  • A 14-day sampling period is initiated.
  • The refinery waits up to 30 days to complete its analytical/reporting period.
  • 45 days later, the refinery is notified of the sampled concentrations, as well as the possible presence of elevated concentrations.
  • If elevated concentrations are measured, then the refinery is obligated to attempt to determine what caused the elevated concentrations and make adjustments to avoid future elevated concentrations.

However, by the time the refinery begins to dig into their data, it is already 30 to 45 days old. At that point, it is very difficult to determine when the high event occurred. It could have happened during a singular event in the 14-day sampling period, or it could have been a steady release over that same period. Plus, any back trajectories will likely be based on wind direction/wind speed data, which is also averaged over the 14-day period.

Then, if a cause can be determined, corrective action must be undertaken. But if the wrong cause is chosen, and measures are taken to correct the wrong problem, then it is likely that future samples will also have higher concentrations. Any continued elevated readings may be a flag to the EPA and/or public for future scrutiny.  In addition, a record to the EPA (and the general public) of a measured high concentration will always be available for review and possible litigation.

To Summarize: The typical 325 monitoring process involves refineries waiting passively to fix problems after they have been reported and hoping their responses will be sufficient to avoid future regulatory or economic repercussions.

Proactive Benzene Monitoring

If the previous few paragraphs sound like your refinery, it’s important to know that there is a solution: Proactive Benzene Monitoring (PBM). PBM attempts to detect the presence of benzene within minutes should a release occur. PBM data coupled with wind data allows for quick and easy corrective action.

PBM using near real-time benzene monitors can determine expected impacts from major on-site and off-site sources. These monitors can trigger alarms to operating personnel when elevated concentrations occur onsite. Finding and correcting elevated Benzene concentrations onsite quickly minimizes the 14-day average concentrations measured at the fenceline, possibly to values below the EPA guidance threshold concentration.  Concentrations below the threshold should not be of concern to the EPA and the general public.

When you couple your benzene monitoring with onsite met data, impacts from offsite sources can be minimized. Source identification can be enhanced by combining summa canisters with the onsite Benzene monitoring. Any corrective action performed on sources identified through this process is more likely to accurately identify the true cause of airborne emissions.  Concentrating on correcting the true cause(s) should result in lower concentrations measured at the fenceline monitors.

To Summarize: Proactive monitoring allows refineries to address problems in a real-time environment, saving you time and money and will help promote the refinery as a good (concerned) neighbor.

Integrating Proactive Monitoring, Fenceline Monitoring and Beyond

Shell Engineering can assist refineries in the transition from typical fenceline monitoring to proactive monitoring. Near real-time benzene monitors (NRTBM) can be set up on a short-term basis for each refinery to assess its benefits. Results from that short-term monitoring period can be used to optimize the number and placement of NRTBM and fine-tune the operation of each.

However, we understand that refineries are in the refinery business, not the monitoring business. That is why Shell Engineering’s ProActive Monitoring Programs are turnkey projects. We provide the data to allow you to make the decision you need to make, and we do so in a timely manner.

With that said, ProActive Monitoring is only the beginning of services Shell Engineering can provide. Additional services include:

  • Management/integration of 325 programs
  • Regulatory compliance
  • Criteria pollutant and GHG studies
  • Dispersion modeling
  • Data software development
  • Emission inventory review
  • Operating permit assistance

Shell Engineering has been solving industrial air-quality issues since 1975. Please let us know how we can assist you.

Contact Shell Engineering to Begin Your ProActive Monitoring Program

Shell Engineering is an environmental consulting company located in Columbia, Mo. We are in no way affiliated with Shell Oil.