Monitoring of air toxics through air pathways in support of a No-Migration permit at a refinery land treatment facility

As part of Exxon's petition of the EPA for No-Migration variances, ambient concentrations of toxicants and carcinogens are required to be verified through onsite monitoring for comparison to the appropriate health based limits as well as for calibration of previously used atmospheric dispersion models. Ambient air around land treatment facilities us a very complex, dynamic system of interacting chemicals. Pollutants can be found in the gas phase, in the particulate phase, or in the aerosol phase. The complex nature of the dynamic air system around these facilities contributes to the complexity of the sampling and analytical selection for the identification and quantification for these chemicals. The selection of the proper sampling and analysis methods for a pollutant depends on many important interrelated factors, including compounds of interest, the level of detection required, the degree of specificity needed, and the purpose of the data collected. Other factors which may be as important as the above are cost, the accuracy and precision required, need for real-time versus long-term data, and the need for on-site or off-site analysis. Sampling time, sampling rate, the volume of air to be sampled and the acceptable risk level are also factors which must be considered when choosing a sampling method. The purpose of the ambient air monitoring program is to obtain a comparison of predicted concentration to those measured. This paper will focus on the ambient air monitoring program at Exxon's land treatment facility as part of a No-Migration variance to EPA's Land Ban Regulations. Ambient Air Monitoring data involving volatile, semi-volatile and metals/particulate matter less than ten microns (PM-10) will be presented