Complimentary Benzene Waste Operations NESHAP (BWON) Downstream Verification Webinar

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.

Attendees of this webinar will learn a logical approach to developing a valuable downstream characterization plan, based on evaluating the wastewater system and the POG discharges that aremanaged at the downstream location. The uses, limitations, and benefits of the downstream information will be emphasized.

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