ENV-06-157 Unresolved BWON Issues

Description:

Ten years ago, most refineries had their Benzene Waste Operations NESHAP (BWON) programs in place and had moved on to other topics. When the Petroleum Refinery Initiative Consent Decree process hit momentum, many of these programs were found to be flawed, and the BWON returned to priority. Not only did BWON programs tighten up, but refineries put more effort into the deeper details of compliance activities. Even those who had worked steadily with the BWON faced issues we had not dealt with before. The author, with more than 15 years of BWON experience and many claims of expertise, found himself answering BWON questions with a frustrating “I don’t know.” This paper examines some unresolved BWON issues, explaining where the ambiguity comes from and presenting rationale behind different compliance approaches. We try to show different sides of issues, but we do not draw conclusions of resolution. We start with issues related to what is a BWON waste, and then discuss waste characterization issues. The final section addresses unresolved issues associated with waste control. The paper is not likely to be unbiased; Brown and Caldwell’s philosophy cannot help but come through. After all, some issues are more unresolved than others. In the Wastes section below, we steer clear of taking stances, while in subsequent sections we are more vocal. EPA weighed in at high volume with the Consent Decree terms, clarifying their position on a number of topics and revealing where their concerns are greatest. Yet even the Consent Decree did not clear everything up.