Environmental Compliance Presentations for Refining, Chemical, Oil & Gas
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2020

BWON Compliance Post-Consent Decree Era

Kati Petersburg - Trinity Consultants

Description

The refinery Consent Decrees added “enhanced provisions” to the BWON. Refineries complied by doing more than the BWON citations required, with the enhanced provisions sometimes dominating compliance demonstration. So what will happen as the Consent Decrees are terminated? Will all those enhanced provisions become a thing of the past? Or will it perhaps be advisable to retain some of them with as much attention as ever? The speaker brings decades of BWON compliance experience to a strategic analysis of what to do in the post-CD era.

Date

Thursday, February 20, 2020

Time

3:30PM

Location

Room 402

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BWON

Downstream Confirmation of Benzene Loading

Kati Petersburg - Trinity Consultants

Description

Downstream flow rates and concentrations can reflect the characteristics of the total wastewater throughput managed at the facility, where all sewered wastewaters have come together into one stream. Experience indicates that downstream characterization can provide the most accurate values for facility wastewaters. However, the BWON citations emphasize the need to characterize wastes upstream, at the points of generation (POGs), because the rule-writers were concerned that benzene could volatilize from the waste as it flowed through the waste management system. Thus, the TAB quantification must be based on the upstream POG characterizations. It is valuable to assess the accuracy of POG results by comparing the downstream values with the sum of upstream POG values in the sewered streams. Although benzene is dynamic in a refinery sewer system—potentially volatilizing or transferring between the oil and water phases—it is reasonable to expect downstream loadings to be similar to the values derived from summing POG numbers. Agreement in the upstream-downstream evaluation lends confidence to the TAB quantification, the 6BQ or 2-Mg quantification (if needed), and the overall claim of the facility that the BWON wastes were properly identified.

Date

Thursday, February 20, 2020

Time

2:00PM

Location

Room 402

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BWON

On-Going BWON Compliance Concerns

Ken Garing - Ken Garing & Associates

Description

Compliance issues with the BWON requirements have evolved since the regulation was introduced in the 90’s. In the early 2000’s, numerous deficiencies, ranging from the identification of regulated waste streams to the proper operation of control equipment, resulted in enhanced BWON requirements being included in the refinery global consent decrees. Since that time, a tremendous amount of work has been directed to this effort and the refining sector has made great strides in improving compliance with the BWON regulation. Mr. Garing will present his thoughts on where current efforts could be focused to further improve compliance.

Date

Thursday, February 20, 2020

Time

10:30AM

Location

Room 402

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BWON

Vapor Lock Scrubber Technology Reducing Carbon Usage for BWON Compliance

Jim Woodard, Jeff St. Amant - Vapor Point, LLC

Description

Vapor Point has been contracted by many refining clients, who have been challenged with the proper design of BWON related controls, to determine the most effective control system when considering cost and efficiency. The challenge with many BWON applications is the significant variability in contaminate concentrations which poses challenges in designing the vapor control system. Predominately, activated carbon is considered a BACT for BWON applications, while thermal oxidizers/combustors are also considered BACT, but not as widely utilized. Changing emissions characteristics of a refinery waste system, can render a well-conceived design selection ineffective. This discussion will focus on carbon absorption systems and how incorporating the VaporLockTM under the correct circumstances improves the system design providing improved margins through direct (activated carbon changeouts), and indirect costs savings (unaccounted for man hours for carbon changeouts/exchanges, and environmental management associated with monitoring and NESHAP requirements for new and spent carbon canisters). We’d like to further highlight, that over the past nine years, we have encountered several clients that elected to utilize a combustion device due to the peak loading during high emission events, ultimately recognizing increased costs due to propane/fuel consumption and maintenance downtime due to the operating conditions of the combustion device. This presentation will review a specific application where Vapor Point was enlisted by a Major Gulf Coast Refinery to investigate the ability to decrease carbon usage at a sump emissions control point which was part of the facilities BWON program. Vapor phase carbon is required per the site’s consent decree as the primary control device at various control points across the facility. The client selected one area where a significant increase in carbon consumption had occurred over a period of time. This sump emissions control point was selected as the pilot project for the installation of Vapor Point’s proprietary liquid scrubber system to decrease the loading of volatile organic compounds (VOCs) and specifically the benzene on the primary control device, vapor phase carbon.

Date

Thursday, February 20, 2020

Time

3:00PM

Location

Room 402

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BWON

A Wastewater Solution for an Air Pollution Problem

Todd Lusk - SLR Consulting

Description

The regulatory requirements for managing benzene- and VOC-laden streams from wastewater treatment units require refineries to implement vapor control technologies that are often expensive to implement and/or operate. This session presents another option – the VOC BioTreatTM process, an alternative control technology that utilizes unit operations already in place at most wastewater treatment facilities and can substantially reduce the costs associated with BWON compliance. The presentation will provide information on the necessary steps to evaluate, model, test, and implement the VOC BioTreatTM process, and will describe case studies to support the economic and environmental benefits.

Date

Thursday, February 20, 2020

Time

11:00AM

Location

Room 402

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BWON

BWON Auditing

Bart Leininger - Ashworth Leininger Group

Description

The National Emission Standard for Benzene Waste Operations (BWON or Subpart FF) is a complex regulation that is difficult to assess in the context of a due diligence assessment. These assessments are conducted within compressed schedules, essential documentation is typically limited or unavailable, and the liabilities for non-compliance are significant. Given the complexity of the BWON regulation, even a seasoned practitioner can miss a significant compliance issue, which could result in a costly corrective actions and potential enforcement exposure for a new owner. Further complicating the due diligence are Subpart FF enhanced requirements mandated in Consent Decrees. Assessing compliance with these enhanced requirements is just as important as compliance with the regulation itself. Given this complex backdrop, Subpart FF assessment during a due diligence must have a laser focus on those requirements of most importance for the acquisition. This presentation draws upon the presenter’s experience in performing detailed Subpart FF assessments in the context of a due diligence and from litigation related to BWON compliance. The presentation uses case study examples to illustrate key areas of inquiry that should be part of the assessment, and provides helpful and practical recommendations for evaluating key aspects of a Subpart FF compliance program. This presentation will also be of interest to BWON professionals with ongoing operations as it provides a “mental checklist” of areas of potential exposure in their BWON compliance program.

Date

Thursday, February 20, 2020

Time

11:30AM

Location

Room 402

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BWON

BWON Masterclass

Steve Probst - 4C Marketplace and Conference

Description

Coming soon.

Date

Thursday, February 20, 2020

Time

12:00PM

Location

Room 402

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BWON

BWON Compliance Sampling

Chad Vogele - Think Environmental

Description

Description coming soon.

Date

Thursday, February 20, 2020

Time

1:30PM

Location

Room 402

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