Key Things to Keep in Mind for Your First Refinery Fenceline Compliance Report

As we approach the end of January 2019, you probably already have or will soon be placing your 26th set of fenceline compliance samples.  Effective data management is critical in order to stay on top of your data.  Here are a couple of things to keep in mind.

  • EPA’s final amendments, issued on November 8, 2018, finalized reporting deadlines for fenceline monitoring.The first quarterly report is due on May 15, 2019.  Trihydro’s Fenceline ProTM Team is closely tracking the status of EPA’s CEDRI reporting template and will add the fully-formatted reporting feature to our tracking software as soon as it is finalized.
  • Once your 26th set of compliance samples is uploaded, Fenceline ProTM will calculate your first official annual average Δc value.  The annual average Δc is defined in the rule as the average Δc from the 26 most recent 14-day sampling periods.  If your site has seen event Δc values above 9 µg/m3, your annual average Δc may trigger a root cause analysis.  Don’t forget to start the root cause analysis and document corrective actions that you may have already implemented for your facility. Here’s a handy flowchart walking you through those steps.

We can still help get your data in order with Fenceline ProTM, which handles the first compliance report with the click of a button.  Email us at [email protected] to learn more or request a demo.

Calvin Niss
Calvin Niss
Senior Consultant, Laramie, WY

Cal has supervised and managed environmental projects in the petrochemical industry for over 30 years. His experience in the petrochemical industry includes numerous Clean Air Act compliance projects involving Benzene Waste Operations NESHAP (BWON), Consent Decree compliance, Hazardous Organic NESHAP (HON), leak detection and repair (LDAR), Maximum Achievable Control Technology (MACT), Miscellaneous Organic NESHAP (MON), and NSPS Subpart QQQ. He has provided expert testimony on both groundwater and air compliance issues, including testifying as an expert witness for the United States government.

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