Is it LDAR or Fugitive Emissions, and Where Does BWON ...

BWON

Is it LDAR or Fugitive Emissions, and Where Does BWON Exist

as an Inspection Program?

BWON

Is it LDAR or Fugitive Emissions, and

Where Does BWON Exist as an

Inspection Program?

Frank Burgard

CEO

Dexter Field Services

BWON



Benzene Waste Operations NESHAP (BWON)

40 CFR Part 61, Subpart FF (§61.340 – 61.359)

Air rule that requires control of air emissions from waste and

wastewater

BWON Affected Facilities: Refineries, Chemical Plants, Coke By-

Product Recovery Plants, and RCRA Treatment Storage and

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

BWON



Agency Inspection & Enforcement Influence

Agency focus on TAB, and not inspection program. (As

compared to high levels of scrutiny on LDAR inspection

program.)

Apparent exposure level, observed during audits and

enforcement of LDAR versus BWON, drives focus of facility

management. (HSE & above)

Historical BWON Perspective

BWON



Continued

As a result of selective scrutiny of inspection

program …

LDAR program receives funding and management attention.

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.

BWON program Administrator and Contractors have a “tough

sale” for resources and struggle to achieve BWON program

health similar to LDAR.

Historical BWON Perspective

BWON



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

Evaluate the synergies between the resources, equipment and

requirements between the two programs.

Remember it is all about Fugitive Emissions:

Not just LDAR or just BWON but both

Path Forward

BWON



What “components” are subject to BWON inspection and

monitoring?

How do BWON “components” compare to LDAR

component types?

What are the specific BWON inspection, monitoring and

repair requirements?

How do BWON inspection and monitoring requirements

compare to LDAR monitoring?

What is considered a “leak” under BWON?

Things to Consider

BWON



Continued

What are the BWON inspection and monitoring recordkeeping

requirements?

How might LDAR database tools and tagging be used for BWON

inspection and monitoring program implementation and

management?

What are some BWON inspection and monitoring program

challenges?

Things to Consider

BWON



BWON doesn’t define component types; it uses the term “potential leak

interfaces”

Inspection and monitoring required on controlled waste management units

(WMUs)

Waste Management Units include:

• Individual Drain Systems

• Tanks

• Oil Water Separators

• Surface Impoundments

• Containers

• Treatment Processes

• Closed Vent Systems

BWON Equipment

BWON



Continued

BWON includes “non-traditional” components and does not

provide exemptions based on component service

Typical BWON components that may not be LDAR components

• Drains

• Manholes

• Junction boxes

• Hatches

• Roof seams

• Vacuum Trucks

BWON Equipment

BWON



Continued

Sealed Cover venting through Closed Vent System to a

Control Device

• Alternative - Floating Roofs on Tanks and Separators

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)

BWON Equipment

BWON



BWON



Synergies

BWON



Bridging the Gap

Incorporate all the LDAR processes & checks into the

BWON program.

Utilize LDAR Technicians for inspections

LDAR Tech will have to be trained up to the BWON Rules

and Sampling

• Incorporate special training for BWON samplers (e.g., SW846)

• Combine inspection and repair procedures

BWON



BWON



Continued

Procedure

BWON



Already embedded into organization. (Relationships)

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

• EPA using infrared camera to identify leaks on BWON

components

• EPA has been finding deficiencies in BWON component

inventory and equipment integrity

It Just makes good business sense!

Benefits to a Fugitive Emissions Program

BWON



BWON program management goes deeper than this

presentation

The transition to combine the programs takes time

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”

Strive for compliance sustainability not just compliance

Key Points

BWON



Questions

BWON



Frank Burgard

CEO

Dexter Field Services

Is it LDAR or Fugitive Emissions, and Where Does BWON ...

Documents

Transcript of Is it LDAR or Fugitive Emissions, and Where Does BWON ...