BWON Services
Total Annual Benzene (TAB) Assessment
Sage Environmental prepares the documentation for the facility TAB by thoroughly reviewing the P&IDs/PFDs for each process unit, as appropriate. Sage interviews operations and engineering to support stream characterization, tours units to field observe each waste stream identified and how each stream is being managed. The points of waste generation, sour water streams, double counts, and excluded wastes are identified and rigorously documented. In addition, maintenance streams are identified through the use of rotating equipment lists, maintenance schedules, reliability studies, and heat exchanger lists.
Control Evaluation and Strategy
Sage Environmental offers control evaluation and strategy on a conceptual basis only and is based upon the current controls in place and the piping line-ups available. Sage performs a controls evaluation to determine whether streams and waste management units identified in the facility’s strategy are controlled in accordance with the requirements of the BWON.
Compliance Program Development
Sage Environmental develops comprehensive and sustainable BWON compliance programs. Sage Environmental provides the architecture for the program and the base requirements in a written document prepared specifically for each facility. The compliance program is developed focusing on planning, implementation and operation, and compliance assurance and corrective action.
The compliance program specifically addresses regulatory applicability and assessment, self-monitoring for day-to-day compliance, forward planning and management of change and roles and responsibilities.
The report describes each element of the Subpart FF compliance program and provides job aids to ease the burden of compliance. Job aids will include check sheets for routine inspections, inspection forms, and procedures for quarterly and annual reports.
Consent Decree BWON Program Assistance
Third Party Review and Verification
Sage Environmental offers the preparation of the “BWON Compliance Review and Verification Report” as required per the client specific Consent decree. This report will discuss the methodology used to generate the TAB by identifying each waste stream at the client facility, develop waste quantities for each waste stream identified and document the basis for each, identify the benzene concentration for each waste stream using sampling consistent with the requirements of §61.355(c), and perform a control evaluation to determine whether each stream is controlled pursuant to the requirements of the BWON.
It is anticipated that through review and verification process, that the facility’s most recently-filed TAB report will not be consistent with actual refinery operations. Therefore, the client will be required to submit an amended BWON Annual Report. Sage Environmental offers to prepare the Annual Report on behalf of client.
End of Line (EOL) Assistance
Sage Environmental develops Waste/Slop/Off-Spec Oil schematics that depict organic waste management units, the control status of each waste management unit, and how the oil is transferred within the facility. Sage performs field walkthrough of the facility’s wastewater collection and treatment system to evaluate control equipment configuration relative to BWON requirements.
Sage Environmental develops a methodology for quantifying organic waste movements that are not controlled. Sage Environmental then designs an End of Line (EOL) Sampling Plan pursuant to the provisions of the client-specific consent decree. The sampling plan includes the proposed sampling locations, methods for determination of waste flows, and guidance for calculating quarterly and projected calendar year benzene quantities using EOL sampling results.
CD Laboratory BWON Audits
Sage conducts audits of laboratories that perform analyses of benzene waste NESHAP samples to ensure that proper analytical and quality assurance/quality control procedures are followed. Sage has developed an audit protocol for the CD laboratory audits based on “NELAC” principles. Based on this audit, Sage will prepare an audit report detailing the audit and any potential associated findings.
Waste Stream Sampling
Sage Environmental develops sampling plans, health and safety plans, and performs sampling according to §61.355(c)(3) to develop an analytical basis for the benzene concentrations. The sampling plan will outline proper sampling procedures, and quality assurance/quality control procedures, and provide documentation of sampling locations and protocols in order to assist facility personnel in performing future sampling.
The sampling plan can serve as the procedural training guidelines for BWON sampling. In addition, Sage Environmental provides sampling training to facility personnel and builds NESHAPs FF sampling devices.