Nick Leone presented, "Curveball Problems for Your Benzene Fenceline Monitoring Program and How to Handle Them" at the AFPM/API Refinery Sector Rule Workshop in February 2016.

1. www.all4inc.com | Philadelphia | Atlanta | Houston | Washington DC
Curveball Problems for Your Benzene
Fenceline Monitoring Program and
How to Handle Them
Nick Leone, P.E.| nleone@all4inc.com | 610.422.1121
With support from Steve Sherk, American Refining Group
AFPM/API Refinery Sector Rule Workshop
February 3, 2016
Presented by All4 Inc.

2. 2 Your environmental compliance is clearly our business.
Agenda
 Scenarios
• Significant Weather Event During 14-Day Sampling Event
• Significant Leak has been Detected
• Elevated Benzene Concentrations are Measured and are
Completely Unexpected
• Labeled Sample Tubes do not Match Chain of Custody Records
 Mitigation Tools
• Sample Schedule Adjustment
• Additional Sampler Deployment
• Expanded Chemical Analysis
• Labeling Considerations

3. 3 Your environmental compliance is clearly our business.
 Day 14 Corresponds to the Arrival of a Category
III+ Hurricane or Winter Storm of the Century
 Pull or Leave - Common sense on day 13
 Applying U.S. EPA Ambient Monitoring Guidance
Significant Weather Event

4. 4 Your environmental compliance is clearly our business.
 Benzene fenceline monitoring is a time integrated
sample over 14 days; no peak concentration.
 Deploy a collocated tube after a repair has been
made.
 The difference between the collocated tubes can
be utilized to delineate post-repair with pre-
repair concentrations levels.
Significant Leak has been Detected

5. 5 Your environmental compliance is clearly our business.
 The anomaly lab result – elevated benzene
concentration.
 A back trajectory analysis is a tool that utilizes
hourly wind direction data to evaluate potential
upwind sources of benzene.
 Use meteorological data to your advantage –
wind direction is being collected.
Elevated Benzene Concentrations are Measured

6. 6 Your environmental compliance is clearly our business.
Elevated Benzene Concentrations are Measured
 Back Trajectory Analysis
Refinery Property Line
Passive Benzene
Monitoring Tubes
Sources of Fugitive
Benzene Emissions
Flow VectorsUnexpected High
Benzene Sample
Result
Source C
Source A
Source B
Source D
Source E

7. 7 Your environmental compliance is clearly our business.
 Expand lab analysis beyond benzene
• Chemical Mass Balance methodology can be used to
with expanded analytical data for source
apportionment
 Hydrogen isotope ratio can help delineate the
source origin of benzene
Expanded Chemical Analysis

8. 8 Your environmental compliance is clearly our business.
 Avoid strictly numeric site IDs
 Implement barcode scanning
 Use effective color coding
 Audio and video recording
 QA immediately after deployment
Labeled Sample Tube Mismatch

9. www.all4inc.com | Philadelphia | Atlanta | Houston | Washington DC
Questions?
Contact Information:
Nick Leone, P.E.
Project Manager
nleone@all4inc.com
610.422.1121
Kristin Gordon, P.E.
Houston Office Director
kgordon@all4inc.com
(281) 937-7553 x301