CONDUCTING REFINERY AUDITS FOR BENZENE
WASTE OPERATIONS - NESHAP COMPLIANCE
Calvin Niss*
David Wolfe
TriHydro Corporation
920 Sheridan Street
Laramie, WY 82070
Voice: 307-745-7474
Fax: 307-745-7729
E-mail: cniss@trihydro.com
Cindy Mueller
ConocoPhillips
Houston, TX
Over the past several years, the USEPA has initiated a nationwide, broad based compliance and enforcement initiative involving the petroleum refinery industry. In this regard, various companies have entered into air quality related Consent Decrees, several of which require comprehensive audits of ongoing compliance programs, including Benzene Waste Operations NESHAP (BWON). The National Emission Standard for Benzene Waste Operations Subpart FF has been in effect for over 10 years. This regulation is complex, addressing air, water, and waste, and focusing on the identification and quantification of benzene waste emissions sources in operating refineries. It has been interpreted differently between various refineries, leading to considerable enforcement exposure to the regulated community. The BWON rule has also become increasingly important to facilities certifying Title V compliance.
The authors have been involved in a number of Consent Decrees related to BWON audits and have developed an auditing "tool box" to streamline the audit process and minimize the potential for errors and regulatory exposure. In this poster presentation, we address how to implement and apply the BWON rule and provide an overview of a BWON Audit Tool Guide that has been successfully implemented in audits for several major refineries.