Is it LDAR or Fugitive Emissions, and Where Does BWON ...
Transcript of Is it LDAR or Fugitive Emissions, and Where Does BWON ...
Page 1BWON
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
Page 2BWON
Is it LDAR or Fugitive Emissions, and Where Does BWON Exist
as an Inspection Program?
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
Page 3BWON
Is it LDAR or Fugitive Emissions, and Where Does BWON Exist
as an Inspection Program?
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
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Is it LDAR or Fugitive Emissions, and Where Does BWON Exist
as an Inspection Program?
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
Page 5BWON
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
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
Page 6BWON
Is it LDAR or Fugitive Emissions, and Where Does BWON Exist
as an Inspection Program?
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
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Is it LDAR or Fugitive Emissions, and Where Does BWON Exist
as an Inspection Program?
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
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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”
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
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Is it LDAR or Fugitive Emissions, and Where Does BWON Exist
as an Inspection Program?
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
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Is it LDAR or Fugitive Emissions, and Where Does BWON Exist
as an Inspection Program?
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
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Is it LDAR or Fugitive Emissions, and Where Does BWON Exist
as an Inspection Program?
Synergies
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Is it LDAR or Fugitive Emissions, and Where Does BWON Exist
as an Inspection Program?
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
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Is it LDAR or Fugitive Emissions, and Where Does BWON Exist
as an Inspection Program?
Continued
Procedure
Page 16BWON
Is it LDAR or Fugitive Emissions, and Where Does BWON Exist
as an Inspection Program?
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
Page 17BWON
Is it LDAR or Fugitive Emissions, and Where Does BWON Exist
as an Inspection Program?
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
Page 18BWON
Is it LDAR or Fugitive Emissions, and Where Does BWON Exist
as an Inspection Program?
Questions