Recently, the Environmental Protection Agency’s (EPA) National Enforcement Investigations Center (NEIC) has been reportedly using their Geospatial Measurement of Air Pollution mobile air monitoring vehicle (GMAP), to conduct real-time monitoring and mapping of pollutants at multiple industrial facilities in Alabama.
The GMAP is equipped with analyzers capable of measuring total volatile organic compounds (VOCs) as well as a few speciated VOCs and hazardous air pollutants (HAPs) such as benzene, toluene, ethylbenzene and xylene, commonly referred to as BTEX. The vehicle is also outfitted with a global positioning system (GPS) and when combined with the emissions monitoring equipment, allows for real-time monitoring and mapping of pollutants while the vehicle is in motion or stationary. The mobile unit can evaluate large geographic areas or be used to take stationary measurements at industrial facilities.
The use of the GMAP aligns with the EPA’s National Compliance Initiatives (NCI) for FY2020-FY2023 as outlined in the June 7, 2019 memorandum distributed to Regional Administrators. The memorandum details priority areas, 3 of which are centered on improving air quality. The first priority area, Creating Cleaner Air for Communities by Reducing Excess Emissions of Harmful Pollutants from Stationary Sources, specifically focuses on reducing emissions of both VOCs and HAPS, which are the primary pollutants the GMAP is designed to monitor.
Link to the NEIC GMAP Fact Sheet: https://www.epa.gov/sites/default/files/2021-01/documents/neic_fb_adv_monitoring_-_gmap_fact_sheet.2020_0.pdf
Background, Past Findings, and Enforcement
For those of you who are unfamiliar, the NEIC is the environmental forensics center for EPA’s enforcement programs. In layman’s terms, they are the real muscle of the EPA, and when they arrive, they usually do so in full-force.
Over the last few years, ethylene oxide (EO) and chloroprene have been a focal point of EPA/NEIC and they have conducted numerous audits/investigations at industrial facilities that manufacture or contain those compounds in their processes/exhausts.
In April 2013, the NEIC conducted mobile air monitoring in and around Deer Park and Texas City, Texas, both heavily industrialized areas with numerous petrochemical facilities. Using the GMAP and air canister sampling, the NEIC detected elevated benzene levels near Vopak Terminal Deer Park and Vopak’s wastewater treatment plant (WWTP).
The data collected during this exercise was used by EPA Region 6 to conduct targeted inspections of the Vopak Terminal facility in 2014 and 2015 which identified leaking tanks, inefficient flares, and open top tanks that were all contributing to the increased benzene concentrations in and around the facility. The end result was an enforcement case against Vopak Terminal Deer Park which included a civil penalty of $2.5 million and also included ~$5 million in facility upgrades targeted at reducing benzene levels.
In summary, if the NEIC happen to pay your facility a visit, you had better hope you’re in compliance with all aspects of your permit and all requirements associated with your facility’s applicable regulations. With the priority areas of the NCI and the recent reports of the GMAP in Alabama, if your facility is a large emitter of VOCs and HAPs, you may have an increased likelihood of a visit from the NEIC.
Feel free to call or email us with any questions on environmental compliance support. You’ll be much better off calling us prior to the NEIC’s arrival than afterwards, believe me.
Isaac A. Smith
Mobile District Manager
Paul Hansen P.E.