3/9/2016 Page 1Benzene Waste Operation NESHAP in the FLIR Age

Benzene Waste Operations NESHAP in the FLIR AgeQualities for a Sustainable Program

Cal NissSenior Vice PresidentAir and Process ServicesTrihydro CorporationLaramie, Wyoming

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BWON Background• Benzene Waste Operations NESHAP – effective date January 7, 1993

• BWON applies to owners / operators of chemical manufacturing plants, coke-by-product recovery plants and petroleum refineries

• Refineries are subject to the rule if 40 CFR Part 61, Subpart FF, if they generate greater than 10 Mg of benzene as waste and affected facilities must comply with either the 6 BQ or 2 Mg options

• Recent enforcement and approaches provide some concepts to sustainably upgrade BWON compliance programs

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Waste Management Unit Standards • Waste management units must be controlled for emissions unless allowable exemption is used

(e.g., they are included in the 6 BQ option)

• Periodic inspections are required for all waste management units

• Waste management unit categories

• Tanks

• Containers

• IDS

• Oil – water separators

• Treatment processes

• Closed vent systems and control devices

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BWON Inspection Requirements • New WMU’s are required to inspected initially (within 180 days)

• Quarterly visual and M21 annually

• NDE is defined as < 500 ppm

• Storage tanks – 45 days; surface impoundments, containers, IDS, separators – 15 days for first attempt at repair

• Closed vent system – first attempt w/5 days and final attempt w/15 days

• BWON – Delay of repair (DOR) provision

• BWON – Does not allow components to be classified as DTM / UTM

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Recent EPA Actions• EPA has started to use “next

generation” approaches during petroleum refinery BWON inspections

• EPA’s focus on field inspections of refinery BWON “waste management units”

• EPA is using an infrared camera to locate potential VOC leaks from waste management units and wastewater treatment facilities, followed by FID M21 measurements to verify leaks

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What is EPA finding?• IR cameras are finding leaks,

ultimately confirmed to be greater than 500 ppmv, on covers and hatches associated with lift stations, oil/water separators, and tanks

• Camera observations also finding leaks from bleeder vents on regulated tanks, and seam weld leaks on covers on wastewater treatment process units, equipment not regularly reviewed

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Potential Regulatory Ramifications• Failure to design and operate an IDS with no

detectable emissions

• Failure to design and operate tank roof covers and all openings with no detectable emissions

• Failure to design and operate oil-water separator with no detectable emissions

• Failure to seal all openings in the wastewater treatment system

• Failure to maintain gaskets on bleeder vents

• Failure to monitor seams on DNF covers

AND

• Failure to meet 6 Mg or 2 Mg options

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Storage Tank Monitoring Alternative• Refinery obtained Alternative

Monitoring approval for BWON tank seal inspections

• Slop oil storage tank controlled with external floating roof

• Camera inspections in lieu of on-the deck seal gap inspections, repairs required if emissions noted with camera

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What Should You Consider?• EPA will use FLIR technology during

inspections

• EPA may consider one violation to be two – failure to control waste management units and exceeding the applicable benzene limit

• Will EPA use FLIR technology for enforcement on other regulations (e.g., NSPS Subpart QQQ)?

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Best Practices• Rule specifies annual NDE inspections;

facilities should consider conducting NDE inspections more frequently

• Proactively incorporate FLIR technology into BWON inspection program and/or include in LDAR program

• How to handle known chronically leaking components

• Are all components identified? Can FLIR technology be used to find “hidden” and “potential” leaks?

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Qualities – Best in Class BWON Programs • Annual review of waste stream inventory

• Periodic sampling program

• Annual review of sour water system and waste streams

• Review & upgrade inspection program

• Management of Change

• Vacuum truck and Frac Tank Management

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Qualities – Best in Class BWON Programs • BWON SME – Turnaround Planning

• BWON Training – Facility Personnel

• Procedures and Roles and Responsibilities

• Verification of End-of-Line Program

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David WolfeBWON – Team Leaderdwolfe@trihydro.com

Calvin NissSenior Vice President -

Air and Process Servicescniss@trihydro.com