Fenceline

Sell, Jeremy
Proposed Fenceline Monitoring in HON and Lessons Learned from RSR Implementation 
Thursday 2:30 PM
On April 25, 2023, the United States Environmental Protection Agency (EPA) published proposed amendments to the New Source Performance Standards (NSPS) that apply to the Synthetic Organic Chemical Manufacturing Industry (SOCMI) and to the National Emissions Standards for Hazardous Air Pollutants  (NESHAP) that apply to Hazardous Organic NESHAP (HON) and Group I and II Polymers and Resins Industries.  These amendments will require fenceline monitoring similar to the December 2015 Refinery Sector Rule (RSR) MACT Subpart CC fenceline monitoring requirements.  These amendments will require fenceline monitoring for six key air toxics (ethylene oxide (EtO), chloroprene, benzene, 1,3-butadiene, ethylene dichloride, and vinyl chloride) if facilities use, produce, store, or emit any of six key air toxics.  

Trihydro has supported implementation of RSR fenceline monitoring requirements at 10 refineries and has provided data management and reporting support at over 50 refineries.  Since publication of the Final RSR in December 2015, Trihydro has supported all aspects of the rule including pilot study preparation, sample station siting, compliance manual development, field data collection, laboratory coordination, software implementation, root cause analysis, and corrective action implementation.  In this presentation we will review the proposed fenceline monitoring requirements for HON facilities, including applicability determination, sample station siting using EPA Method 325A for passive diffusion sampling, sample station siting for summa canister sampling, sampling requirements, root cause analysis process, and corrective actions.  We will also share lessons learned from assisting refineries with implementation and support of their fenceline monitoring programs.

Espinosa, Joe
Proposed EPA Method 327 – Challenges and Insights
Thursday 8:00 AM
This presentation will discuss Method 327 and highlight the enhanced QA requirements of the method and the challenges they present to field sampling and laboratories.

Ledeboer, Brian
A New Way to Measure Toxic Gases with Wireless and IIoT and Fenceline Monitoring
Wednesday 3:15 PM
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Ward, Kari
Proposed Fenceline Monitoring in HON and Lessons Learned from RSR Implementation 
Wednesday 2:30 PM
On April 25, 2023, the United States Environmental Protection Agency (EPA) published proposed amendments to the New Source Performance Standards (NSPS) that apply to the Synthetic Organic Chemical Manufacturing Industry (SOCMI) and to the National Emissions Standards for Hazardous Air Pollutants  (NESHAP) that apply to Hazardous Organic NESHAP (HON) and Group I and II Polymers and Resins Industries.  These amendments will require fenceline monitoring similar to the December 2015 Refinery Sector Rule (RSR) MACT Subpart CC fenceline monitoring requirements.  These amendments will require fenceline monitoring for six key air toxics (ethylene oxide (EtO), chloroprene, benzene, 1,3-butadiene, ethylene dichloride, and vinyl chloride) if facilities use, produce, store, or emit any of six key air toxics.  

Trihydro has supported implementation of RSR fenceline monitoring requirements at 10 refineries and has provided data management and reporting support at over 50 refineries.  Since publication of the Final RSR in December 2015, Trihydro has supported all aspects of the rule including pilot study preparation, sample station siting, compliance manual development, field data collection, laboratory coordination, software implementation, root cause analysis, and corrective action implementation.  In this presentation we will review the proposed fenceline monitoring requirements for HON facilities, including applicability determination, sample station siting using EPA Method 325A for passive diffusion sampling, sample station siting for summa canister sampling, sampling requirements, root cause analysis process, and corrective actions.  We will also share lessons learned from assisting refineries with implementation and support of their fenceline monitoring programs.