Date: March 5, 2014 To: Brenda Shine, EPA/OAQPS/SPPD From: Kristin Sroka Subject: Meeting Minutes for February 5, 2014, Meeting Between the U.S. EPA and a Representative of Marathon Petroleum Company
On February 5, 2014, representatives of th e U.S. Environmental Protection Agency (EPA) and their contractor (RTI International) part icipated in a meeting w ith a representative of the Marathon Petroleum Company LP (MPC). The names and affiliations of the participants are included in Attachment 1 . The purpose of the meeting was to discuss MPC’s experiences with conducting diffusion tube pa ssive sampling concurrently with the EPA. The MPC representative provided a presentation summariz ing the passive sampling; the presentation is included as Attachment 2 to this memorandum. Additional informa tion provided by the MPC representative following the meeting is included as Attachment 3 to this memorandum. The passive sampling was performed at the MPC Texas City Refinery and a nearby tank farm. The MPC representative noted that the company recently purchased a refinery from BP that was referred to as the Texas City Refinery as well; MPC now refers to it as their Galveston Bay Refinery. The Texas City Refinery is bord ered on the west by the Galveston Bay Refinery, on the south by a refinery owned by Valero Energy Corporation, and on the east by the Galveston Bay. The tank farm is to the southeast of the refinery. The wind is almost always from the south, but during the 4 days of sampling, it wa s blowing from the north part of the time. The MPC representative noted that there have been ambient benzene monitors located outside of the Texas City Refinery for a numbe r of years. For example, the Texas Commission on Environmental Quality’s 11 th Street monitor, located to the north of the Texas City Refinery, did have exceedances of the be nzene effects screening level (E SL) of 1.4 ppb (annual average) in the 2008/2009 calendar years. The MPC representative’s understa nding was that the refinery implemented corrective actions to identify the source of the benzene, which was a benzene storage tank, and they took steps to upgrade seals to mechanical shoe-type seals. They also changed the way the tanks were operated to re duce working losses. Since 2010, the monitored levels have been below the ES L and continue to decrease. The MPC representative indicated that there was some variability between MPC’s results and the EPA’s concurrent results. These differences may be attributed to the fact that the EPA recommended that MPC use a differe nt type of sampling tube (with a different mesh size) than the EPA testers themselves were using. Based on an initial review of the concentration results presented at this meeting, the EPA representatives noted that, given the diffe rences in the type of2 sampling tube and the fact that the samples were analyzed by different laboratories, the MPC results seemed to agree we ll with the EPA results. The highest benzene concentration found dur ing the passive sampling was in the tank farm, at a level 4 times higher than the other ne arby samplers. This sampler was near a benzene tank, so slightly higher concentr ations of benzene would be exp ected. However, all the tank seals were checked and were operating properly, and the tank was not involved in degassing or a turnaround during the sampling. The facility across the street from the tank farm produced benzene at one time but does not do so currently. Th erefore, the MPC representative was not sure of the exact source of the benzene. The second highest benzene concentration was measured at the dock. The MPC representative stated that MP C sends only gasoline to the dock for shipping, so he suggested that the sources of the high benz ene concentrations from this sampler are likely from other facilities and operations. For example, there are other manufacturing facilities using the docks to ship their products. The MPC repr esentative also suggest ed the wind could be carrying benzene emissions from barges out on the bay. Based on their experience, the MPC repr esentative had a few suggestions for implementing a fenceline monitoring program in a rulemaking. First, he noted that the EPA used two samplers in each location during their study, a nd they removed the results from one location because the results from the two samplers did not agree. He asked the EPA representatives to consider providing a mechanism in the rule that would allow for removal of suspect or suspicious results in a program that does not require two co-located monitors. Second, he suggested reducing the amount of monitors required by not requiring monitors to be placed near units that would not be expect ed to have high concentrations of benzene (such as gasoline product streams). Third, he noted that when a sampling tube shows hi gh concentrations of benzene, it may take a little bit of work to determ ine the source, even with tools such as infrared cameras. If the source is not inside the refinery fenceline ( i.e. , the high benzene concentrations are from something off-site), it becomes even more difficult to determine the exact source. He recommended that the rule include some sort of provision for refinery owners or operators to show that the high benzene concentrati ons are not coming from their facility.Attachment 1 Participants in February 5, 2014 EPA/MPC Meeting MPC Representatives Charlie Bennett U.S. EPA Representatives Andrew Bouchard Jason DeWees Eric Goehl Penny Lassiter Nick Parsons Brenda Shine Eben Thoma RTI International (EPA contractor) Kristin SrokaAttachment 2 Presentation Slides Refinery Passive Sampling Data Marathon Petroleum Company LP

# Refinery Passive **Sampling Data**

1

# Refinery Diffusion Tube Passive Sampling

 Diffusion tube readings taken at the Continuous Monitoring System (CMS) GC location were higher than the CMS GC readings. These readings were lower than applicable standards.
 Sampling results around the refiner and tank farm varied significantly on average and individually.
 Contributing to variability is the:

 Average uptake rate for diffusion tubes is +/

- 9.0%

 Lab error at an estimated +/

- 2% to +/

- 4% 

##  1 out of 25 EPA sample locations was discounted because of apparent error.
 Sampling results in locations between industrial areas were significantly lower that OSHA levels of concerns.  Follow

- up with IR camera within the MPC Refinery showed no leaks from MPC operations.
 There was no feasible way to determine if there were unusual operations from adjoining, nonMPC operations.

2

# Benzene Passive Diffusion Tube Sampling

 MPC took duplicate samples at same locations as EPA  MPC used Carbograph X 40/60 sampling tubes  EPA used CarboPack X sampling tubes

 The 2

- week benzene diffusive uptake rate for Carbopack X has been determined to be (1.99 ± 0.18) ng ppm−1 min−1 for environmental applications, and was found to be constant over a wide range of VOC concentrations.



### 3

# MPC / EPA Preliminary non **- QA/QC**  **Benzene Monitoring (ppb) All neighborhood public receptors within TCEQ annual limits** 

**11 th**  **St. CEM: 0.56 ppb 0.31/NA**  **0.21/0.46**

**0.65/0.60 0.53/0.41**  **0.40/0.28**

**0.49/0.36**

**0.35/0.42 0.43/0.35**  **0.79/0.75 0.91/0.55**  **1.00/1.40 0.55/0.43** 

**4.00/3.35 0.70/0.88** 

**0.71/0.69 1.00/1.14**  **0.71/0.66 0.74/0.65** 
**0.78/0.71 0.65/0.56**  **0.59/0.60 0.64/0.77**  **0.49/0.64 0.58/0.60** 

**Dock 18 3.5/3.1** 

### 4

# Areas of Note

 Passive sampling results appear to bias toward a higher reading than CMS GC ranging from 7.1% to 16.1%
 4% of EPA results needed to be discounted for no identifiable reason
 EPA average same location results varied by 13.3%
 EPA individual same location results varied from 0.0% to 40.0%
 MPC to EPA average same location results varied by 21.8%
 MPC to EPA individual location results varied from 1.7% to 73.7%
 Identifiable areas of variability include:

 Average uptake rate for diffusion tubes is +/

- 9.0%

 Lab error is at an estimated +/- 2% to +/

- 4%
 No feasible method was determined how to identify possible sources of emissions from non -MPC facilities.

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**Bo iler**  **and I C**  **En gines**  

# EPA Data **Shows Refinery Toxics Emissions are Low** 

6Attachment 3 Follow-up Information on Texas City Fenceline Monitoring Email from Charlie Bennett to Brenda Shine February 6, 2014From: Bennett, Charles D. (MPC) <cdbennett@marathonpetroleum.com> Sent: Thursday, February 06, 2014 11:18 AM To: Shine, Brenda Cc: Scott Jr, Harold R. (MPC) Subject: Texas City Fenceline Monitoring
Brenda, I wanted to provide the following follow-up information on Dock 18 and also on the 11 th street monitor. I received some questions on the 11 th street monitor and wanted to provide the specifics after I discussed with our Texas City Refinery. Please forward. Thanks. Charlie
Dock 18 is permitted to load benzene, but was not loading benzene during the sampling period (gasoline was loaded). 11 th street monitoring information: 1. TCEQ ESL is 1.4 ppb annual average 2. The monitoring station was established in ~2004 as part of agreement with TQEQ based on TCEQ mobile monitoring 3. In 2008 and 2009, the ESL was exceeded and corrective actions were taken a. Investigations including use of IR camera plant-wide b. Voluntarily, both of the benzene tanks were taken out of service and Texas city upgraded the seals to mechanical shoe seals (existing seals were compliant) c. Texas City changed the way the tanks are used in a manner to reduce working losses of the tanks 4. Since 2010, the monitored levels have been below the ESL and continue to decrease