EHS Management

Fence Line Monitoring: Will We See More?

On September 29, 2015, the U.S. Environmental Protection Agency (EPA) finalized revisions to regulations governing the petroleum refinery sector, including applicable New Source Performance Standards (NSPS) and National Emissions Standards for Hazardous Air Pollutants (NESHAP). This is significant because, in addition to other changes, these regulations require refineries to continuously monitor emissions at the fence lines of their facilities, which is the first time a national regulation requires such actions. This begs the question, can we expect similar requirements for other sources?

Under the revised regulations, refineries must continuously monitor benzene concentrations at the fence line in order to appropriately manage toxic emissions from fugitive sources such as leaking equipment and wastewater treatment. The monitors must surround the facility to account for variable wind direction, and any exceedance measured at the fence line will trigger corrective actions, resulting in significantly improved air quality in neighborhoods near petroleum refineries.

The communities located near the fence lines of refineries have low income and minority populations at nearly twice the rate as the general population. During the revisions process, the EPA engaged these communities, and this engagement brought about the possibility of fence line monitoring. Therefore, these regulations became some of the first to actively incorporate environmental justice concerns.

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