If your facility has been exempt from BWON TAB reporting in the past, now is a good opportunity to dust off the TAB calculation spreadsheet and verify the exempt status.
The BWON requirements are codified under 40 CFR 61 Subpart FF. All subject facilities are required to calculate the TAB and submit an initial report to USEPA. This initial reporting requirement affects all chemical manufacturing plants, coke by-product recovery plants, and petroleum refineries, even those with no benzene onsite in wastes, products, by-products, or intermediates. Following the initial reporting requirement, a facility is subject to one of the following subsequent reporting requirements based on the TAB calculations:
- TAB < 1 Mg/yr - maintain the TAB based on current operations;
- 1 Mg/yr ≤ TAB < 10 Mg/yr - submit annual reports to USEPA; and
- TAB ≥ 10 Mg/yr - submit annual and quarterly reporting, comply with control requirements.
Maintaining compliance with BWON requirements entails assessing several areas of your site's process. Being fully aware of the factors that affect your site's TAB calculation is essential to ensuring your overall compliance with the BWON. As the TAB annual reporting deadline quickly approaches, ask yourself some of the basics:
- When was the last time you changed your process, turn-around schedule, and/or the source of your raw materials?
- Have there been any changes to your process equipment such as replacement, addition, and/or removal?
- How are you maintaining your maintenance records, and are they correct?
- Does your site's MOC review include potential impacts to the TAB calculations?
- When was the last time you performed a BWON walk through to verify the TAB accounts for all of the benzene waste?
- When was the last time that your site underwent a complete BWON review?
If you are unsure of how to answer any of these questions, now is a good time to the re-evaluate your site's BWON program. Chemical manufacturing plants should pay additional attention to the BWON program since EPA has recently used MON inspections as an opportunity to investigate BWON applicability under EPA's national enforcement initiative.
Should you believe your site could be better informed and prepared in years to come, Trinity is well-positioned to provide BWON assistance with a multitude of BWON experience in the chemical manufacturing and petroleum refining industries. Our experience includes assistance with submittal of initial, quarterly, and annual BWON reports and utilizing our expertise to provide assessments of the existing TAB calculations, including review of waste stream classifications, identification of points of waste generation, and an evaluation of the overall accuracy of the TAB calculation.
For more information on how Trinity can assist your BWON compliance efforts, please contact Inaas Darrat, P.E., at (713) 552-1371 or your local Trinity office.