(123d) Recent Ethylene Producer’s Consent Decree Fenceline Monitoring and Experience Using Next Gen Enhanced Monitoring

Over the past several years, the USEPA has issued flare related consent decrees to both the refinery and ethylene producer groups that incorporated fenceline monitoring as an additional mitigation measure. Flare improvements are required as part of the Ethylene Production MACT. However, not all ethylene producers have entered into a flare consent decree. A review of these consent decrees and their varying fenceline monitoring requirements will be presented. The recent EMACT regulation did not include any fenceline monitoring provision. Some non-industry groups have petitioned USEPA to incorporate additional fenceline monitoring into all new revised MACT regulations.

Several industry consenters are now providing their Method 325A/B passive tube fenceline monitoring results on various public websites. This data will be summarized and compared to the Petroleum Refinery dashboard now available from EPA wherein monthly fenceline data from all refinery locations is share publicly.

Additionally, USEPA recently announced broad policy actions aimed to protect communities including a new multi-scale monitoring project called the Pollution Accountability Team (PAT). This initiative expands USEPA’s air monitoring capacity by utilizing assets such as a GMAP (Geospatial Measurement of Air Pollutants) mobile air monitoring vehicle and additional air pollution inspectors to enhance compliance inspections and enforcement. Numerous petrochemical facilities have been visited by the USEPA during these recent efforts. Items to be presented will include: real case examples of how the USEPA recently used a GMAP unit, OGI monitors and other enhanced technologies when conducting inspections as part of its multi-scale monitoring project; areas of the facilities targeted during these inspections; and overlapping risks of air compliance programs such as fenceline monitoring, LDAR, BWON and air permits relative to these types of investigations.

Troy Boley from Spectrum Environmental Solutions LLC will provide a summary of the current publicly-available fenceline monitoring results at Ethylene producer facilities resulting from recent EPA enforcement actions.

Laura Blohm and Joe Ibanez with Tricord Consulting LLC will share recent experiences involving these newer, non-passive tube technologies.