Trinity Consultants

Benzene Waste Operations NESHAP



This 1-day course is designed for petroleum refining, chemical plant, and TSDF environmental staff and management who need an understanding of the Benzene Waste Operations NESHAP (BWON). The course covers such essential topics as rule applicability, point of generation (POG) determination, total annual benzene (TAB) calculations, 2 Mg and 6 Mg compliance options, and control requirements under the rule. The course format includes lectures and case studies (including agency applicability interpretations and enforcement cases) to maximize understanding of this challenging material.

Course completion enables attendees to: 

  • Understand what waste streams to include in a facility’s TAB
  • Determine applicable control requirements for various waste management units
  • Understand BWON compliance options and “benzene quantity” (BQ) calculations
  • Apply industry best practices for a BWON compliance program

Course Topics

  • Applicability of Control Standards
    • 10 Mg exemption
    • Fuel gas exemption
    • 2 Mg/yr and 6 Mg/yr benzene quantity (BQ) exemptions
    • Identifying waste streams
    • Identifying waste management units
  • Compliance Requirements
    • Control standards
    • Treatment standards
    • Compliance options
    • Monitoring
    • Recordkeeping
  • Reporting
    • Point of generation sampling
    • End of line sampling
    • Intermittent waste streams
    • BQ and TAB calculation methodology
    • Quarterly and Annual Reports
  • Compliance Pitfalls
    • Cooling towers
    • Flare knockout drums
    • Spent caustic
    • Enforcement actions

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