The document discusses the Benzene Waste Operations National Emission Standards for Hazardous Air Pollutants (BWON), applicable to certain chemical manufacturing and petroleum refining facilities, stating enforcement requirements and compliance options. It highlights recent EPA actions utilizing infrared technology for leak detection in waste management units and outlines potential regulatory ramifications for non-compliance. Best practices for effective BWON programs include enhanced inspection frequencies and proactive monitoring to address emissions.

1. 3/9/2016 Page 1
Benzene Waste Operation NESHAP
in the FLIR Age
Benzene Waste Operations
NESHAP in the FLIR Age
Qualities for a Sustainable Program
Cal Niss
Senior Vice President
Air and Process Services
Trihydro Corporation
Laramie, Wyoming

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Benzene Waste Operation NESHAP
in the FLIR Age
BWON Background
• Benzene Waste Operations NESHAP – effective date January 7, 1993
• BWON applies to owners / operators of chemical manufacturing plants,
coke-by-product recovery plants and petroleum refineries
• Refineries are subject to the rule if 40 CFR Part 61, Subpart FF, if they
generate greater than 10 Mg of benzene as waste and affected facilities
must comply with either the 6 BQ or 2 Mg options
• Recent enforcement and approaches provide some concepts to
sustainably upgrade BWON compliance programs

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Benzene Waste Operation NESHAP
in the FLIR Age
Waste Management Unit Standards
• Waste management units must be controlled for emissions unless allowable exemption is used
(e.g., they are included in the 6 BQ option)
• Periodic inspections are required for all waste management units
• Waste management unit categories
• Tanks
• Containers
• IDS
• Oil – water separators
• Treatment processes
• Closed vent systems and control devices

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Benzene Waste Operation NESHAP
in the FLIR Age
BWON Inspection Requirements
• New WMU’s are required to inspected initially (within 180 days)
• Quarterly visual and M21 annually
• NDE is defined as < 500 ppm
• Storage tanks – 45 days; surface impoundments, containers, IDS,
separators – 15 days for first attempt at repair
• Closed vent system – first attempt w/5 days and final attempt w/15 days
• BWON – Delay of repair (DOR) provision
• BWON – Does not allow components to be classified as DTM / UTM

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Benzene Waste Operation NESHAP
in the FLIR Age
Recent EPA Actions
• EPA has started to use “next
generation” approaches during
petroleum refinery BWON
inspections
• EPA’s focus on field inspections
of refinery BWON “waste
management units”
• EPA is using an infrared camera
to locate potential VOC leaks
from waste management units
and wastewater treatment
facilities, followed by FID M21
measurements to verify leaks

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Benzene Waste Operation NESHAP
in the FLIR Age
What is EPA finding?
• IR cameras are finding leaks,
ultimately confirmed to be greater
than 500 ppmv, on covers and
hatches associated with lift
stations, oil/water separators,
and tanks
• Camera observations also finding
leaks from bleeder vents on
regulated tanks, and seam weld
leaks on covers on wastewater
treatment process units,
equipment not regularly reviewed

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Benzene Waste Operation NESHAP
in the FLIR Age
Potential Regulatory Ramifications
• Failure to design and operate an IDS with no
detectable emissions
• Failure to design and operate tank roof covers
and all openings with no detectable emissions
• Failure to design and operate oil-water
separator with no detectable emissions
• Failure to seal all openings in the wastewater
treatment system
• Failure to maintain gaskets on bleeder vents
• Failure to monitor seams on DNF covers
AND
• Failure to meet 6 Mg or 2 Mg options

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Benzene Waste Operation NESHAP
in the FLIR Age
Storage Tank Monitoring Alternative
• Refinery obtained Alternative
Monitoring approval for BWON
tank seal inspections
• Slop oil storage tank controlled
with external floating roof
• Camera inspections in lieu of
on-the deck seal gap
inspections, repairs required if
emissions noted with camera

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Benzene Waste Operation NESHAP
in the FLIR Age
What Should You Consider?
• EPA will use FLIR technology during
inspections
• EPA may consider one violation to be
two – failure to control waste
management units and exceeding the
applicable benzene limit
• Will EPA use FLIR technology for
enforcement on other regulations
(e.g., NSPS Subpart QQQ)?

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Benzene Waste Operation NESHAP
in the FLIR Age
Best Practices
• Rule specifies annual NDE inspections;
facilities should consider conducting NDE
inspections more frequently
• Proactively incorporate FLIR technology
into BWON inspection program and/or
include in LDAR program
• How to handle known chronically leaking
components
• Are all components identified? Can FLIR
technology be used to find “hidden” and
“potential” leaks?

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Benzene Waste Operation NESHAP
in the FLIR Age
Qualities – Best in Class BWON Programs
• Annual review of waste stream inventory
• Periodic sampling program
• Annual review of sour water system and waste streams
• Review & upgrade inspection program
• Management of Change
• Vacuum truck and Frac Tank Management

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Benzene Waste Operation NESHAP
in the FLIR Age
Qualities – Best in Class BWON Programs
• BWON SME – Turnaround Planning
• BWON Training – Facility Personnel
• Procedures and Roles and Responsibilities
• Verification of End-of-Line Program

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Benzene Waste Operation NESHAP
in the FLIR Age
David Wolfe
BWON – Team Leader
dwolfe@trihydro.com
Calvin Niss
Senior Vice President -
Air and Process Services
cniss@trihydro.com