ENV-04-171 Conducting Refinery Audits for Benzene Waste Operations NESHAP Compliance

Description:

Over the past several years the USEPA has initiated a nationwide, broad based compliance and enforcement initiative under the Clean Air Act involving the petroleum refining industry (“the Refinery Enforcement Initiative”). As a result of this initiative, various companies have voluntarily entered into air quality related Consent Decrees which require comprehensive audits of on-going compliance programs, including compliance with Benzene Waste Operations NESHAP (BWON). The National Emission Standard for Benzene Waste Operations, 40CFR Part 61, Subpart FF, has been in effect for over 10 years. This air regulation is complex, addressing air, water, and waste issues, and focusing on the identification and quantification of benzene waste emissions sources in operating petroleum refineries. Due to its complexity, the rule 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 permit compliance. The authors have been involved with a number of Refinery Enforcement Initiative 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.