No Slide TitlePage 1 BWON
Is it LDAR or Fugitive Emissions, and Where Does BWON Exist
as an Inspection Program?
Where Does BWON Exist as an
Inspection Program?
Frank Burgard
Dexter Field Services
Page 2 BWON
Is it LDAR or Fugitive Emissions, and Where Does BWON Exist
as an Inspection Program?
40 CFR Part 61, Subpart FF (§61.340 – 61.359)
Air rule that requires control of air emissions from waste and
wastewater
Disposal Facilities
Affected facilities are subject to control if they generate more than 10
Megagrams of benzene containing waste (Total Annual Benzene
Quantity or “TAB” > 10 Megagrams); however, not all wastewater
components require controls
One of the marquis elements of EPA’s Refinery Enforcement Initiative
1st - What is BWON
Page 3 BWON
Is it LDAR or Fugitive Emissions, and Where Does BWON Exist
as an Inspection Program?
Agency Inspection & Enforcement Influence
program.)
enforcement of LDAR versus BWON, drives focus of facility
management. (HSE & above)
Historical BWON Perspective
Page 4 BWON
Is it LDAR or Fugitive Emissions, and Where Does BWON Exist
as an Inspection Program?
program …
BWON program focus is TAB, 6BQ, and verification through EOL
sampling. (i.e., A sampling, not inspection, program.)
Creates gap in understanding the depth of BWON inspection
program requirements.
sale” for resources and struggle to achieve BWON program
health similar to LDAR.
Historical BWON Perspective
Page 5 BWON
Is it LDAR or Fugitive Emissions, and Where Does BWON Exist
as an Inspection Program?
Recognize that BWON is an inspection program, not a sampling
program.
Establishing that compliance sustainability is a core value of the
BWON inspection program as it is in LDAR
Gain understanding of the differences between LDAR
inspections vs. BWON inspection
requirements between the two programs.
Remember it is all about Fugitive Emissions:
Not just LDAR or just BWON but both
Path Forward
Page 6 BWON
Is it LDAR or Fugitive Emissions, and Where Does BWON Exist
as an Inspection Program?
monitoring?
component types?
repair requirements?
compare to LDAR monitoring?
Things to Consider
Page 7 BWON
Is it LDAR or Fugitive Emissions, and Where Does BWON Exist
as an Inspection Program?
requirements?
How might LDAR database tools and tagging be used for BWON
inspection and monitoring program implementation and
management?
challenges?
Things to Consider
Page 8 BWON
Is it LDAR or Fugitive Emissions, and Where Does BWON Exist
as an Inspection Program?
BWON doesn’t define component types; it uses the term “potential leak
interfaces”
(WMUs)
Page 9 BWON
Is it LDAR or Fugitive Emissions, and Where Does BWON Exist
as an Inspection Program?
provide exemptions based on component service
Typical BWON components that may not be LDAR components
• Drains
• Manholes
Page 10 BWON
Is it LDAR or Fugitive Emissions, and Where Does BWON Exist
as an Inspection Program?
Control Device
Water Seals on IDS Drains
Device to Prevent Flow during Normal Operation and a
Flow Indicator on Junction Boxes
Treatment Devices controlled similarly to other WMU (i.e.,
tanks)
Page 11 BWON
Is it LDAR or Fugitive Emissions, and Where Does BWON Exist
as an Inspection Program?
Page 12 BWON
Is it LDAR or Fugitive Emissions, and Where Does BWON Exist
as an Inspection Program?
Page 13 BWON
Is it LDAR or Fugitive Emissions, and Where Does BWON Exist
as an Inspection Program?
BWON program.
Utilize LDAR Technicians for inspections
LDAR Tech will have to be trained up to the BWON Rules
and Sampling
• Combine inspection and repair procedures
Page 14 BWON
Is it LDAR or Fugitive Emissions, and Where Does BWON Exist
as an Inspection Program?
Page 15 BWON
Is it LDAR or Fugitive Emissions, and Where Does BWON Exist
as an Inspection Program?
Page 16 BWON
Is it LDAR or Fugitive Emissions, and Where Does BWON Exist
as an Inspection Program?
Cost savings on resources and equipment
Consolidation of work flows, procedures and processes
BWON inspection and monitoring has been a recent focus area
during EPA audits
components
inventory and equipment integrity
Page 17 BWON
Is it LDAR or Fugitive Emissions, and Where Does BWON Exist
as an Inspection Program?
presentation
Will require some additional resources and cost during the
transition to combine
Remember that it is not “if” the agency will be auditing your
BWON program but “when”
Key Points
Page 18 BWON
Is it LDAR or Fugitive Emissions, and Where Does BWON Exist
as an Inspection Program?
Page 19 BWON
Is it LDAR or Fugitive Emissions, and Where Does BWON Exist
as an Inspection Program?