You’ve spent a small (or not so small) fortune on developing your total annual benzene (TAB) and uncontrolled waste stream calculations, your control and treatment strategy, your operating procedures, and all the other pieces that a BWON compliance program requires. Still, how do you gauge how well those systems are working? How are you doing in comparison with your fellow Benzene Waste Operations NESHAPs (BWON) facilities? What places you at the head of the class, and where do you need shoring up?
The EPA, with the assistance of the National Enforcement Investigations Center (NEIC), has conducted targeted BWON compliance audits at several facilities. BWON audits, or compliance reviews, are not mandated by the rule, but it is widely considered good practice to keep a sustainable and compliant BWON program. For facilities that have consent decrees, one of the typical provisions seen under the BWON Enhancement Provisions is to conduct facility-wide audits to determine compliance with BWON and to create a corrective action plan to resolve noncompliance.
Sage Environmental Consulting, L.P., has a successful history of auditing BWON programs at refineries and chemical plants. Through this experience, Sage’s engineers have developed knowledge of typical BWON program deficiencies and have established best practices and procedures to help facilities resolve or avoid these deficiencies.
Sage BWON audits are valuable because they identify and resolve potential compliance issues as soon as possible so that you can mitigate problems and avoid penalties. Sage will address each concern and present a recommended course of action based on our knowledge of how similar facilities have approached similar issues, our understanding of industry standards, and the EPA’s stance on various issues. Sage’s unique relationship with government regulators and industry leaders allows us to understand the forthcoming BWON issues that will impact the BWON program at your facility.
Our audits combine off-site office reviews of pertinent BWON information with on-site field reviews. We review facility documentation and records pertaining to BWON, perform site walk-throughs to visually verify potential waste sources and sampling methodology, and conduct interviews with key members of refinery environmental and Operations staff.
Our audit team emphasizes reviewing the quality and completeness of records associated with the areas of concentration identified below and reviewing the BWON program in the context of the EPA’s BWON enforcement and audit initiatives.
Upon completion of the on-site review, Sage will prepare an audit report that describes findings and areas of potential improvement that were observed during the audit. We will present our observations by rule citation, accompanied by a written report describing the areas of focus of the review, the review methodology, and detailed descriptions of each observation. Sage also will present a recommended course of action to address each concern in a complete and effective manner.
Our BWON audits focus on the following areas:
- TAB and Uncontrolled Benzene Quantity(BQ) Assessment
TAB/BQ accuracy and completeness
- Qualitative comparison of existing waste-stream inventory with that identified by Sage for select process units
- Identification of commonly missed/miscalculated waste streams
- Waste stream inventory and comparison with similar facilities
- Annual waste stream quantities review
- Flow-weighted annual average benzene concentrations review
- TAB calculation methodology
- High-level water balance and TAB review [i.e., end-of-line (EOL)-type calculation]
- High-level slop oil balance and TAB review (i.e., TAB balance)
- TAB/BQ accuracy and completeness
- Recordkeeping and Reporting
- Assessment of records program management/completeness
- Review of TAB waste stream recordkeeping requirements
- Review of report submittals for proper inclusion of all reporting requirements
- Sampling Program Review
- Standard operating procedure (SOP) review
- Sampling methodology review for compliance with §61.355(c)(3)
- Field verification of sampling point locations for each different type of stream sampled (e.g., EOL sampling, points of generation, products, and intermediates)
Sage has evaluated and audited BWON compliance at more than 50 facilities across the United States. We understand BWON program complexities, solutions, and regulators’ concerns. We have audited facilities in Alabama, California, Colorado, Illinois, Kentucky, Louisiana, Michigan, Minnesota, Mississippi, New Jersey, Ohio, Oklahoma, Pennsylvania, Tennessee, Texas, Virginia, Washington, Wisconsin, Wyoming, and the U.S. Virgin Islands.