Air Quality

Benzene Waste Operations NESHAPs (BWON)

Controls Strategy and Treatment Process Design


The BWON program enhancements section of refinery Consent Decrees requires the development of a compliance strategy plan and schedule and subsequent implementation of the strategy for attainment of the BWON regulatory standard. In all Consent Decrees reviewed, the EPA always requires that the 6 megagram per year (6 BQ) compliance option be used at the subject facilities unless the facility has had a prior and competent 2 megagram per year (2 BQ) compliance program. It is assumed hereon that the 6 BQ program is required for compliance at the facility.

Sage provides services that encompass all aspects of compliance strategy development for the BWON rule. Sage personnel have evaluated and seen many types of control systems for BWON purposes and are able to help in evaluation and selection of the optimal control strategy. By optimal, we mean that the control strategy would be the most cost-effective solution with the least disruption to process operations.

Although Sage does not provide process design services, Sage is able to recommend competent process design services and can work with the process designer to design and implement the selected BWON control strategy.

Our Expertise:

Sage personnel have participated in numerous BWON programs and have helped select control strategies for a number of clients. Most of our BWON team personnel have Chemical Engineering degrees and include a number of registered Professional Engineer (P.E.) certifications in a variety of states.

The Work:

The control strategy work would begin with the identification of various waste control scenarios (i.e., compliance options) that would cost-effectively allow the facility to achieve compliance with the BWON 6BQ program. This effort would include evaluating both the waste quantity and concentration of each waste stream and assessing potential control options for each. Some control options may represent an obvious choice while others may require more evaluation in order to assess their efficacy and cost effectiveness.

At the end of the evaluation phase, a report and a presentation would be prepared and delivered in a face-to-face presentation to facility management. The presentation would contain a number of engineering control options that would enable the client to comply with a 6BQ program. As part of this report and presentation, Sage would identify and justify what we believe represents the best available 6BQ control strategy for the facility. At the facility option, Sage could also prepare an Excel spreadsheet tool that would contain a simplified wastewater flow diagram which would allow relatively quick evaluation of multiple compliance options. Such a spreadsheet has been prepared for several clients and has proven itself to be very useful.

Following the client’s selection of a final 6BQ control strategy, Sage would prepare the formal BWON Compliance Plan for the client to submit to EPA and LDEQ. Following receipt of the plan, EPA would evaluate the plan and either approve it or return it for corrections. Although full approval of the plan would be expected, Sage would work with the facility for any required plan corrections and resubmittal if required.

If the facility wishes to have process design assistance, then a Sage senior engineer would work as a design team member to complete the process design necessary for installation of the wastewater system controls. Sage can also recommend competent process design firms for client evaluation.

Our Reach:

Sage personnel have considerable experience in evaluating and implementing BWON controls. Our clients have included small, medium, and large refineries. A client list can be furnished upon request, along with a statement of qualifications.

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