A Brief Overview of Method 325A/B Fenceline Monitoring
Whether EPA Method 325 is being utilized for fenceline monitoring at a petroleum refinery or storage tank facility, a chemical plant or a fracking site, or as part of a community monitoring effort, there are many challenges to address in order to initiate and maintain a successful sampling program. The ultimate goals are to 1) properly establish a site plan 2) safely and efficiently conduct proper field sampling and 3) generate accurate data through laboratory analysis.
In 2015, EPA Method 325 “Volatile Organic Compounds from Fugitive and Area Sources” was developed to enable petroleum refineries to comply with the updated US federal regulation 40 CFR 63. EPA Method 325 includes two parts, EPA 325A, which covers “Sampler Deployment and VOC Sample Collection” and EPA 325B, which covers “Sample Preparation and Analysis.”
These two methods outline facility siting, field sampling, and laboratory analysis of passive sampling sorbent tubes deployed around a method established perimeter (fenceline). After exposure (generally 14-days), the passive sampling tubes are collected, sent to the laboratory and analyzed using thermal desorption gas chromatograph mass spectrometry (TD-GCMS) analysis. The sampling and analysis methodology can be used to determine Volatile Organic Compound (VOC) and other hazardous air pollutant (HAP) concentrations. Some of the most common target analytes are Benzene, Toluene, Ethylbenzene and Xylenes (BTEX) as well as 1,3-Butadiene, Chloroprene and Ethylene Dichloride.
Tips for Establishing Your Program
Getting a successful sampling program started comes with many questions. Before you start, here are some of the important questions to consider:
- What are the compounds of interest and what detection limits are required? Certain target analytes may require a specific type of sorbent tube for optimal results.
- Is the sampling compliance or engineering/discretionary?
- Will site planning (M325A) involve equal radial or a linear approach? Radial covers areas with less than 750 acres, and samples every 30 degrees based on a central emission source point. Linear covers boundaries with less than 24,000 feet and a minimum of 12 sampling locations evenly spaced ±10%. (Our experts can assist with siting.)
- Would a site-specific monitoring plan (SSMP) be applicable? (Remember, we can assist with siting.)
- Installation and naming of monitoring stations with specially designed shelter housings. (Shelters are available for rent or purchase from our team.)
- Method required QC: co–located duplicates and field blanks. Note: EPA ALT-122 specifies one duplicate for 19 or fewer monitoring locations and 2 duplicates for 20 or more. Only one field blank is required per sampling period.
- Use of an onsite meteorological station (MET) or NOAA data from a local airport within 25 miles for required metadata. (Our experts can assist with MET station installation.)
- Will an internal team member or external contractor conduct the M325A field sampling? What site specific safety considerations should be taken?
- Is your selected laboratory accredited for M325B? (Our laboratories are NELAP accredited and have been on the leading edge of EPA Method 325A/B, assisting the EPA in development and validation well in advance of the method publication.)
- What kind of reporting is required? This includes Turnaround Time (TAT), Electronic Data Deliverable (EDD) format, Level 1-4 pdf data packages, and Compliance and Emissions Data Reporting Interface (CEDRI) reporting.
Tips for Maintaining the Program
Once your FLM program is up and running, you should consider the necessary steps to deliver efficient field sampling and accurate data:
- Communication, communication, communication. Many people are involved including site Environmental Engineers, Field Technicians, Project Managers, Consultants, and Lab Personnel. It is crucial that everyone stays informed throughout the process.
- Proper and legible documentation is important whether submitting a handwritten hardcopy COC or a typed electronic COC.
- Regular inspection and replacement of sampler diffusion caps.
- Ongoing field sampling training.
- Sample shipping/transport logistics. Enthalpy uses FedEx or can provide a courier.
- Use of software/data management programs to help with field sampling, trend analysis and data aggregation. Enthalpy Fenceline web/mobile applications feature wind rose graphs, tabular reports, delta C trends, CEDRI reporting, etc.
One More Recommendation to Ensure Success for your Program
By addressing these common questions and steps for establishing a M325 sampling program, maintaining with a good line of communication and training, and using a reputable laboratory, accurate data can be produced regularly and efficiently.
Whether you’re utilizing M325A/B or possibly even M327 for a HON MACT pilot program, Enthalpy Analytical offers a unique opportunity for a turnkey approach with one contractor handling the program from start to finish.
Matt Cavanaugh
Project Manager
Matt is a Project Manager with 7+ years experience with the Durham, NC laboratory. Matt’s primary support role is managing the M325B Fenceline programs. Matt graduated from North Carolina State University with a Bachelor of Science in Meteorology.
Jim Jacklin
Business Development Manager
Jim is the Business Development Manager for Enthalpy Analytical’s Source Evaluation and Ambient Air Toxics business lines. He has 38+ years of sales & service experience in both the U.S. and Canada with an emphasis on building long-term relationships with the client’s we serve. Jim graduated from Pennsylvania State University with a B.S. in Agricultural Mechanization and has an M.B.A. from Indiana University of Pennsylvania.
