ENV-09-34 BWON Compliance Benchmarking

Description:

40 CFR 61, Subpart FF - Benzene Waste Operations NESHAPs (BWON) is one of the more complex Federal regulations affecting US refineries. Sustaining compliance with this regulation is challenging, which is apparent from the fact that the BWON is one of the marquee regulatory standards incorporated into refinery global settlements with the United States Environmental Protection Agency (US EPA). A benchmarking study was performed to evaluate certain characteristics of affected facilities and compare those characteristics to BWON compliance metrics. The study identified several common programmatic compliance deficiencies that BWON program coordinators and management should be aware of and understand. Tools and suggestions are provided to assist in correcting these common BWON compliance issues. In addition, publically available BWON reporting data were compiled to provide insight into how a facility’s BWON-related operating parameters might compare to other refineries of similar size or complexity. The parameters evaluated included Total Annual Benzene Quantity (TAB), uncontrolled benzene quantity, and number of waste streams versus refinery throughput. Also presented are comparisons of the managerial dimensions of BWON compliance, such as staffing level and workload versus facility throughput, complexity, and TAB.