April 7th is right around the corner, which means that the BWON TAB Reports are due! This report usually requires some heavy lifting to get all the calculation updates and inspection data in order.
What is Required to be Reported on the TAB?
BWON annual reports are required to contain a lot of very specific information. There are typically three (3) parts to the annual submittal.
- Inspection and Monitoring (I&M) exceptions
- TAB Estimate
- Uncontrolled Benzene Quantity Estimate based on chosen compliance option (i.e., 2BQ or 6BQ), as applicable
For the I&M exception list, facilities must provide:
- A summary of all visual inspection and Method 21 leak detection monitoring
events in which:
- Detectable emissions (i.e., >500 ppmv VOC) are measured; OR
- A problem (such as a broken seal, gap or other problem) that could result in benzene emissions is identified.
- Information about the repairs or corrective action taken.
Some facilities choose to also reiterate treatment process and control device monitoring results from their previously submitted Quarterly Reports from the reporting year.
The TAB estimate must represent current configuration and operating conditions and should include the following documentation of each waste stream:
- Control status
- Whether or not the water content is greater than 10% by weight or commingles at any time to become greater than 10% water by weight
- The classification of the waste stream (i.e., process wastewater, product tank drawdown, or landfill leachate)
- Annual waste quantity for each waste stream, in Mg/yr
- Range of benzene concentrations for the waste stream (both aqueous and organic), in ppmw
- Flow‐weighted annual average benzene concentration, in ppmw
- Annual benzene quantity for each waste stream, in Mg/yr
The annual benzene quantity associated with each TAB stream is then summed to provide the site’s Total Annual Benzene quantity.
Each facility with a TAB greater than 10 Mg/yr is required to follow a regulated compliance option, most commonly the 2BQ or 6BQ options. Each of these has unique and specific reporting requirements.
Which Estimates Should I Actually Update Annually?
While updating every individual waste stream quantity annually would be ideal, facilities should focus on specific waste types and systems to report the most accurate value possible, including:
- Internal facility vacuum truck movements
- Spent caustic generation (as applicable)
- Wastes shipped offsite for disposal, including waste generated from tank cleanings
- Spills
- Turnaround, pump, exchanger, compressor and filter related maintenance wastes
- Laboratory related wastes, including knock engine labs (as applicable) and sample purge wastes
- Dock, rail or other loading related wastes
- Sour water stripper effluent (as applicable)
- Any streams with a large impact on your TAB (>0.5 Mg), 2BQ (>0.05 Mg) or 6BQ (>0.1 Mg) totals
It is common for these wastes to vary from year to year; therefore, facilities should take the time to review their stream inventories to make sure they are kept up-to-date.
Management of Change
Another important tool for Annual TAB updates is the facility Management of Change program. The MOC’s should be reviewed regularly, but at least annual, for impacts to the BWON Compliance Program. Look out for projects and changes that may impact your:
- Waste Stream Inventory – Is a new waste stream being added, or an old one being removed?
- Waste Quantities – Is a setpoint being changed? Will oil/water separation be more accurate?
- Benzene Concentrations – Are the distillation cuts changing? Are feed or product specs changing?
- Waste Stream Control Status – Are new/replacement controls being installed? Is a bypass being added to an existing system?
- Inspection and Monitoring Requirements – Are new sewer components (drains, unburied lines) being added? Is a tank floating roof seal being replaced with a different type?
- Impacts on Control and Treatment System Parameter Monitoring – Are changes being made to how a combustion device operates? Is a new vent line being added to an existing closed-vent system?
Commonly Missed Wastes
Does your TAB estimate have all of these wastes correctly accounted for?
- Alternative waste stream lineups
- Flare knockout wastes and flare header low point drains
- Filter changeout waste
- Sample purges
- Dilution steam blowdown (as applicable)
- Desalter mudwashing and try-line checks (as applicable)
- Tank water draws
- Level gauge draining
- Fuel gas header knockout drums
- Blowdown of suspect steam condensate due to exchanger leaks
- Knock engine wastes (as applicable)
- Bundle pad/maintenance pad wastes
- Blend deck wastes
Contact one of TRICORD’s Client Relationship Managers to make sure your BWON Annual Report is ready for submittal!
