Air Quality

Benzene Waste Operations NESHAPs (BWON)

Carbon Canister Design Documentation

Service:

Granular activated carbon (GAC) is routinely used to control volatile organic compounds (VOCs) and benzene from wastewater collection components at refineries and petrochemical plants. The Benzene Waste Operations NESHAPs (BWON) rule requires that carbon adsorption systems control organic emissions vented to the control device at 95% organic vapor recovery or 98% benzene vapor recovery.  Carbon canister design documentation, an often missed regulatory requirement, is fundamental to managing carbon canister systems under BWON.

To demonstrate that a carbon adsorption system meets the stated control requirements, the BWON requires that the owner or operator either stack-test the carbon adsorption system or prepare engineering calculations and design documentation to demonstrate that control requirements are met. Stack testing is not practical for small-scale carbon adsorption systems with intermittent flows; therefore, carbon canister control device performance is generally demonstrated through the use of engineering calculations and design documentation.

Our Expertise:

Sage personnel are well-versed in the regulatory requirements for carbon canister design, overall challenges to managing carbon canister systems, and gray areas in regulatory requirements and consent decree provisions. We can help you achieve and maintain compliance, avoid penalties, and prepare design documentation for carbon canisters. Our design documentation analyses are based on engineering calculations and/or performance tests for carbon canisters controlling BWON-affected waste management units to meet the requirements promulgated under BWON.

The Work:

Sage prepares the design documentation for any number of carbon canister systems that control BWON-affected waste-management units at our clients’ sites. The carbon canister design documentation work would begin by conducting an in-office preliminary review of the current carbon system documentation and drawings prior to a field verification of each carbon system to confirm the configuration and control standards. Sage gathers representative vent-stream composition data and estimates design flow rates for each carbon adsorption system. We conduct performance tests where deemed necessary, then prepare a report to document the recordkeeping requirements under §61.356(f)(2)(i)(G).

The BWON requires that the design analysis establishes the design exhaust vent stream organic compound or benzene concentration level, constituent concentration, flow rate, relative humidity, temperature, capacity of the carbon bed, type and working capacity of activated carbon used for the carbon bed, and design carbon replacement interval based on the total carbon working capacity of the control device and source operating schedule.

Our Reach:

Sage personnel have considerable experience in carbon canister design and documentation. Our clients include small, medium, and large refineries. A client list can be furnished upon request, along with a statement of qualifications.

Want to learn more about carbon canisters? Check out our carbon canister design case study.

SAGE ATC Environmental Consulting ©2009-2017 Offices conveniently located near you! Phone: 866-234-5768