10 Best Practices for a BWON Sustainability Program
The BWON rule delineates standards for reducing benzene air emissions from waste streams, and U.S. EPA-driven Consent Decrees (CDs) mandate BWON program enhancements—but maybe your program is still not in shape. Because we have helped multiple clients comply with the BWON rule, we have gained insight into what can make your program foolproof. Below are some extra steps your facility can follow to keep a BWON program sustainable and evergreen and to avoid penalties.
- Identification of BWON-Affected Equipment—The first step is to complete a waste-stream characterization inventory for Total Annual Benzene (TAB) and a field survey to verify controls. Once they are completed, the facility can use this information as a basis to identify which equipment will require regular inspection and monitoring. To ensure a sustainable program, it is recommended that a facility also identify closed-vent system bypasses, conservation vents, locations of water-trapped drains requiring visual inspection or monthly water addition, the Points of Generation (POGs) and product streams that should be sampled regularly, where bypasses from controlled to uncontrolled line-ups exist, and areas where problems could arise.
- Verification and Augmentation of the End-of-Line (EOL) Program—EOL sampling locations and methodology are an ongoing challenge for every facility under a CD. At many facilities, the personnel achieve a minimum level of compliance and then worry about an EPA audit. It’s not that the existing EOL sampling locations are wrong, usually, but sampling does not indicate where problems are arising or how to fix them. A proper EOL sampling program should include regular, frequent sampling upstream of major EOL points at junction boxes and other early-warning systems. Many refineries EOL-sample only once a quarter or possibly once a month—that is not often enough. A facility with a dedicated BWON manager should be able to sustain weekly sampling of all EOL points and the upstream areas. Then, when problems with EOL results are found, the manager will know immediately which upstream point is the problem and can institute further sampling and notification programs to find the faulty equipment or party. These procedures need to be fully documented and implemented. Frequent sampling will allow the problem to be corrected and more compliance-friendly data points to be averaged for the quarter.
- Revitalize your Inspection and Monitoring Program—Sage recommends marking up piping and instrumentation diagrams (P&IDs), updating sewer and benzene treatment system drawings, updating BWON-affected components in the LDAR databases, taking digital photographs of each affected component, and digitally marking where leak interfaces are. In addition to the usual quarterly visual inspections and annual No-Detect Monitoring (Method 21), facilities also are recommended to develop complete systems to identify and maintain monitoring programs for the following:
- A weekly closed-vent system to control device bypass monitoring
- Quarterly oil water separator NDE monitoring (CD requirement)
- Weekly or monthly conservation vent monitoring
- Monthly individual drain system visual inspections
- Management of Change Forms (MOCs)—An annual P&ID review/interview process does not always uncover all BWON-related issues. Sage recommends reviewing MOCs to assess for BWON impacts. Removal of a BWON car seal, even temporarily, should require an MOC. To help the BWON coordinator review MOCs monthly, Sage recommends having a quick-reference guide for each process unit that identifies equipment and streams that contain high-benzene materials for which the addition of a new drain or other POG should trigger an alarm that the uncontrolled Benzene Quantity (BQ) will increase as a result. A refinery or chemical plant that correctly tracks MOCs for BWON is far less likely to require extensive TAB revisions and top-down R&V programs than facilities that don’t.
- Bypass Management—Each location where a controlled stream may be bypassed to an uncontrolled location should be car-sealed and tagged for monthly inspection by LDAR technicians. The monthly car-seal-inspection program is no different from the weekly BWON rule requirement to inspect bypasses on closed-vent systems to carbon canisters. Sage recommends that you car-seal and inspect closed “turnaround” or “maintenance” drains to uncontrolled sewer systems that operators may claim are never used. Turnarounds often cause a significant amount of uncontrolled waste generation in a facility. EOL results often triple or quadruple during turnarounds, and oil-removal rates at the uncontrolled WWTP increase substantially. It is critical to make sure that no one takes shortcuts to get a turnaround completed on time because it can cause a facility to violate its CD requirements. Any turnaround planning by the facility should include a discussion about when these car seals are to be removed and the date when they are to be put back in place—every piece of equipment. If there are no convenient drains to drain into, or using them requires an MOC form to be filled out, turnaround crews often default to the next easiest option, which is to call in a vacuum truck or put the waste into a roll-off box. Both options are likely to be part of a BWON-controlled waste-management system at the facility.
- Vacuum Truck and Frac Tank Management—All vacuum truck movements and frac tanks should be tracked using a log sheet that is approved by an environmental administrative assistant. Data such as the amount, estimated benzene concentration, and pick-up and drop-off locations should be entered onto the log sheets by the vacuum truck or frac tank contractor’s company as part of the regular daily operation of the vacuum trucks. Sage recommends instituting a permit requirement for offloading a vacuum truck to an uncontrolled location, with the material that is picked up being verified independently by a facility environmental staff member prior to offloading.
- BWON Incident Self-Reporting Form—Each facility process unit should be provided with a list of approved waste streams that may go to uncontrolled Waste Management Unit (WMU) locations. Any waste that is allowed to enter the uncontrolled sewer that deviates from this list of streams, including spills washed down into deck or area drains, must be reported on a customized BWON incident form.
- No Oil to the Sewer (NOTS) Policy (if applicable)—For facilities that are configured to manage the waste in management units other than the sewer system, it is critical for every staff member to understand that no oil should be released into the sewer. Employees need to be shown alternative, controlled solutions for dealing with common waste-generating occurrences at a facility. Sage recommends making NOTS propaganda by putting out posters or mats reminding employees not to release oil to the sewer.
- Facility Benzene NESHAPs Knowledge Training—Sage recommends training non-environmental personnel, including supervisors and operations managers, on BWON compliance. The training should include an explanation about how the refinery or chemical plant has to comply with the BWON rule in terms of a 2BQ or 6BQ, EOL sampling, and what happens if the facility exceeds the quarterly EOL level. We encourage and emphasize self-reporting and proactive prevention.
- Procedures and Roles and Responsibilities—Sage recommends that every facility have comprehensive BWON procedures in place, to include decision-making flow charts, emergency-response contacts, FAQs, and how-to’s regarding inspection and monitoring techniques.