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Similar to Passive Fence Line Monitoring for Benzene. Coming Soon to Refineries. Who’s next? The Logistical Challenges and Strategic Choices You May Need to Make.
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Passive Fence Line Monitoring for Benzene. Coming Soon to Refineries. Who’s next? The Logistical Challenges and Strategic Choices You May Need to Make.
- 1. Innovation that Provides Sustainable Solutions to Complex Local Challenges, Worldwide Passive Fence Line Monitoring for Benzene. Coming Soon to Refineries. Who’s next? The Logistical Challenges and Strategic Choices You May Need to Make. Christopher Lutes, CH2M Raleigh NC George Lipinski, CH2M Austin TX Steve Engleman, CH2M San Diego CA Presented at A&WMA’s 108th Annual Conference, Raleigh NC, 2015
- 2. 2 Innovation that Provides Sustainable Solutions to Complex Local Challenges, Worldwide • Status of new EPA refinery air toxics rule – finalization delayed to 9/30/15 • Practical considerations in complying with passive sampling requirements • Strategic considerations in passive sampling • Risk Communication Strategies • Broader implications: – EPA policy encouraging citizen science, – future applications of passive sampling Presentation Overview
- 3. 3 Innovation that Provides Sustainable Solutions to Complex Local Challenges, Worldwide • Two week long tube type passive samples, taken continuously at 12 to 24 locations per refinery → 312 to 624 samples per year!; • Starts 3 years after rule goes final, data regularly publically posted on-line • Annual average concentrations below 9 μg/m3 on a background adjusted basis • Default background adjustment based on highest fence line – lowest fence line • Rule allows refiners to distinguish refinery fugitive emissions from co-located sources regulated under hazardous organic NESHAP – sample locations key! • Meteorology data also required Summary of Refinery Rule Passive Sampling Requirement Photo from UTSA.edu
- 4. Continuous Sample and Data Management Cycle Analytical Results Lab Staff Sampling Supervisor/ Back-up Field Sampler Site Data Manager Env. Manager Public Relations Meteorology Data Data Validation Trend Analysis Media returned Samples shipped Sample Location and Duration Information Semi-annual Public Reporting Physical Media Shipping Information Flow People Sample ID, Temperature Ops DataDatabase Background Adjustment Rolling Average
- 5. 5 Innovation that Provides Sustainable Solutions to Complex Local Challenges, Worldwide • The very low detection limit requires care to reduce cross-contamination. • Store sealed sampling media away from rest of refinery. • Rotation multiple sets of dedicated sample media between an off-site high- volume trace production laboratory and a field staging location. • Staff that work in production areas may bring a high risk of inadvertent cross- contamination from clothing or skin. • Continuous nature of monitoring requires local staffing. • Tight regulatory deadlines for reporting → plan backup staffing • Automated sample tracking (bar codes) will help. Practical Considerations – Purity and Staffing
- 6. 6 Innovation that Provides Sustainable Solutions to Complex Local Challenges, Worldwide Passive Sampling Concepts Sorbent Bed Diffusive Barrier L = Diffusive Path Length [VOC] Gradient A = Cross-sectional Area of Sampler A Fick’s 1st Law of Diffusion Uptake Rate = Rate at which VOC vapors pass through opening Uptake Rate α A/L
- 7. 7 Innovation that Provides Sustainable Solutions to Complex Local Challenges, Worldwide Passive Sampling: What Goes into Calculating Your Concentration? Concentration (µg/m3) Analytical Result (µg) Uptake Rate (mL/min) Sampling duration (min) 1000 mL 1L 1000 L m3 X X X Recorded in the field Sampler Geometry specific Chemical specific Temperature Dependent Tabulated values/equations available Measured in lab after solvent extraction or thermal desorption
- 8. 8 Innovation that Provides Sustainable Solutions to Complex Local Challenges, Worldwide Practical Advantages • Easy deployment with little training of field staff required, unobtrusive • Inexpensive to ship Technical Advantages • Range of sampling durations from days to weeks can be accommodated Limitations • Some information on the target compounds and expected concentration ranges needed for selecting the sampler • Expertise and skill is required to select the right passive geometry and sorbent type for a given application • Sampler uptake rate must be known for the compound/sampler combination • Non-target sources must be controlled/understood for full duration Passive Sampling
- 9. 9 Innovation that Provides Sustainable Solutions to Complex Local Challenges, Worldwide • Avoid very windy or still locations – wind effects uptake rate • Protect from moisture • Use a shelter to avoid excessive wind-speeds, precipitation, and direct sunlight • Means to secure the widespread unattended sampling network against theft or tampering suggested. • Can shelters be designed to be camouflaged? Practical Considerations – Sampling Locations
- 10. 10 Innovation that Provides Sustainable Solutions to Complex Local Challenges, Worldwide • Public disclosure of monitoring data required – need public communication plan • Plan site specific strategies to distinguish between on-site and off-site pollution sources as well as between the regulated fugitive sources and other on-site sources. • Additional organic data can help diagnose higher than expected detected benzene concentrations. • May even influence real estate management – More land = higher sampling cost but – more land = easier compliance! Strategic Considerations
- 11. 11 Innovation that Provides Sustainable Solutions to Complex Local Challenges, Worldwide • Exceedances require rapid route cause analysis and corrective action • Sources of atmospheric benzene including cars, diesel engines, gasoline, forest fires and cigarette smoke • Some sources may be significantly time variable – for example a forest or structure fire → questions from the public or distorted rolling averages • Statistical data analysis, informed with dispersion modeling and other refinery observations can help! Distinguishing Sources %? %? %?
- 12. 12 Innovation that Provides Sustainable Solutions to Complex Local Challenges, Worldwide McCarthy: 100% of Ambient Air Stations Exceeded 1x10-6 risk Benzene Ambient Concentrations Make Risk Communication Tough Figure reprinted from McCarthy, M.C. et.all. Environmental Health Perspectives Vol 117, No. 5, May 2009
- 13. 13 Innovation that Provides Sustainable Solutions to Complex Local Challenges, Worldwide The Fenceline Standard is Within the Range Commonly Seen in Residential Indoor Air Nationwide Figure reprinted from EPA 2011: EPA 530-R-10-001
- 14. 14 Innovation that Provides Sustainable Solutions to Complex Local Challenges, Worldwide There are many “outrage factors” that determine public reaction. Some examples are: • Voluntariness • Control • Fairness • Process • Familiarity • Memorability • Dread • Diffusion in time and space Credit: Peter Sandman (http://www.psandman.com/articles/facing.htm)
- 15. 15 Innovation that Provides Sustainable Solutions to Complex Local Challenges, Worldwide 1. Accept and involve the public as a legitimate partner 2. Plan carefully and evaluate your efforts 3. Listen to the public’s specific concerns 4. Be honest, frank and open 5. Coordinate and collaborate with other credible sources 6. Meet the needs of the media 7. Speak clearly and with compassion • Credit Vincent T. Covello and Frederick W. Allen EPA’s Seven Cardinal Rules of Risk Communication
- 16. 16 Innovation that Provides Sustainable Solutions to Complex Local Challenges, Worldwide • Refinery rule timing controlled by consent decree with Earthjustice, Environment Integrity Project, etc. • EPA’s perception of problem: “Widespread noncompliance among largest sources…Major air sources like power plants and refineries…Budgets declining” • EPA’s “Next Generation Compliance” approach emphasizes transparency and advanced monitoring. • EPA’s strategy is explicitly designed to encourage public involvement: “Public posting provides incentive to keep emissions well below the standard to avoid exceedances“ • Low cost monitoring methods and fenceline location could allow stakeholders to collect their own comparison data • Challenge for facilities – sustained, effective risk communication of complex issues to stakeholders with varying degrees of understanding and varying attention spans. Quotes from Giles, USEPA, Asst. Administrator for Enforcement, 2015 http://www.eli.org/sites/default/files/docs/seminars/2015shapiro_giles.pdf “Citizen Science” and Stakeholder Involvement
- 17. 17 Innovation that Provides Sustainable Solutions to Complex Local Challenges, Worldwide • New refinery rule fenceline monitoring poses significant challenges for industry in planning an effective compliance strategy. • Routine, commercial passive monitoring of VOCs is novel in US. • Required routine public disclosure regarding a well known carcinogen requires careful public communications! • Sampling and data analysis strategies using meteorological data and an understanding of background benzene emission sources needed to interpret the temporal variability in the benzene data set. • This rule is likely to set a precedent – stakeholders will likely demand similar continuous monitoring strategies for other sectors and situations. Summary
- 18. Innovation that Provides Sustainable Solutions to Complex Local Challenges, Worldwide Thank You, For Questions: Chris Lutes, Christopher.lutes@ch2m.com George Lipinski, George.Lipinski@ch2m.com Steve Engleman, Steve.Engleman@ch2m.com Thanks to Lorraine Jameson, CH2M Dallas, risk communication information Thanks also to Heidi Hayes, Eurofins Air Toxics for some graphics.
Editor's Notes
- OSHA PEL is 3,250 ug/m3 For example EPA states that “the calculation of the rolling annual average fenceline concentration must be completed within 30 days after the completion of each sampling episode”. Given that standard analytical turn-around times at US commercial laboratories are 2 to 3 weeks, and that a day or more will elapse in sample shipping, this suggests that the company conducting the monitoring must ensure that staff is available during almost every week of the year for sampling and data processing. This staff must be available to review laboratory reports and enter the results into a spreadsheet or database used to calculate the rolling annual average fenceline concentration for each monitoring station. Even such routine events as an employee taking a week’s vacation, sick leave or an email being lost could lead to a violation of this requirement.
- The author’s experience suggests that passive ambient sampling devices, even when of no appreciable resale value, are often lost to theft in urban areas. Thus ingenuity may be required to locate and disguise shelters so that they are unobtrusive and less vulnerable to theft while still meeting the technical requirements.
- Since the rule does not require analysis of additional target compounds, refiners have a strategic choice to make about whether routine acquisition of that data for source allocation purposes will be cost effective. The analytical laboratory cost would only increase modestly with the addition of other analytes. Methods and uptake rates for tube type samplers similar to those used in the new EPA method 325 for a wide variety of compounds have been published internationally (see for example ISO 16017-2)6. Because the rule requires meteorological monitoring and interacts with other methods of fugitive source detection data structures will need to be carefully planned, so exceedances can be diagnosed in terms of process and meteorological variables. For example surveys of individual valves performed with hand-held instruments under US EPA method 21 plus wind speed and direction information could be used to analyze patterns in the fenceline monitoring data set7.
- Voluntariness A voluntary risk is much more acceptable to people than a coerced risk, because it generates no outrage. Consider the difference between getting pushed down a mountain on slippery sticks and deciding to go skiing. Control Almost everybody feels safer driving than riding shotgun. When prevention and mitigation are in the individual’s hands, the risk (though not the hazard) is much lower than when they are in the hands of a government agency. Fairness People who must endure greater risks than their neighbors, without access to greater benefits, are naturally outraged – especially if the rationale for so burdening them looks more like politics than science. Greater outrage, of course, means greater risk. Process Does the agency come across as trustworthy or dishonest, concerned or arrogant? Does it tell the community what’s going on before the real decisions are made? Does it listen and respond to community concerns? Morality society has decided over the last two decades that pollution isn’t just harmful – it’s evil. But talking about cost-risk tradeoffs sounds very callous when the risk is morally relevant. Imagine a police chief insisting that an occasional child-molester is an “acceptable risk.” Familiarity Exotic, high-tech facilities provoke more outrage than familiar risks (your home, your car, your jar of peanut butter). Memorability A memorable accident – Love Canal, Bhopal, Times Beach – makes the risk easier to imagine, and thus (as we have defined the term) more risky. A potent symbol – the 55-gallon drum – can do the same thing. Dread Some illnesses are more dreaded than others; compare AIDS and cancer with, say, emphysema. The long latency of most cancers and the undetectability of most carcinogens add to the dread. Diffusion in time and space Hazard A kills 50 anonymous people a year across the country. Hazard B has one chance in 10 of wiping out its neighborhood of 5,000 people sometime in the next decade. Risk assessment tells us the two have the same expected annual mortality: 50. “Outrage assessment” tells us A is probably acceptable and B is certainly not.
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