BWON Operator Training
Managing waste is a serious job, and environmental coordinators know that operations personnel can have great impact on BWON compliance. Operators handle and manage waste streams on a daily basis and have the ability to alter a waste stream’s control status, possibly impacting a facility’s BWON compliance status without even knowing it. Sage Environmental Consulting, L.P., recommends continual BWON training for non-environmental personnel. Sage’s training for BWON operators covers BWON compliance from an operational point of view and outlines the implications to daily operations, providing operators with the knowledge they need to make the right decisions when it comes to waste management.
Our course outlines the general BWON requirements and how to comply with the BWON rule, demonstrates the impact a single person can have on overall compliance, depicts real-life situations and suggested techniques for controlling waste streams, emphasizes waste-management practices, and explains what it means to “control” a waste that is generated. The course also covers reporting and recordkeeping requirements such as how to log inspections and what to do if you find a problem with an inspection, provides tools to support program improvement, and concludes by allowing the attendees to ask questions of the course instructor in a round-table format.
The following types of waste are discussed in this course: wastewaters, slop oils and sludges, off-spec material, spent caustics, spent acid, and any other material that is not recycled directly back to the process (e.g., crude tank, unit overhead, or other process vessel). The training helps BWON operators manage these wastes in a way that complies with regulations so they can maintain the most effective BWON operation possible.
Participants in this course will be administered a written test, and those who complete the course and pass the test will receive a certificate of completion acknowledging their understanding of BWON waste handling.
Here is an overview of our agenda:
- General BWON requirements at a refinery
- Implications to day-to-day operations
- How to determine which wastes need to be controlled
- What it means to “control” a waste that is generated
- Real-life situations and suggested techniques for controlling wastes
- How to conduct quarterly visual inspections
- How to log inspections
- What to do if you find a problem
Larry G. Darcey, P.E., delivers this training. He is a Client Service Manager in Sage’s Houston office, serving as one of the company’s premier BWON subject-matter experts. Over the past decade, he has led Sage’s efforts in performing BWON compliance work.
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