{"id":840,"date":"2019-10-01T23:53:09","date_gmt":"2019-10-01T23:53:09","guid":{"rendered":"http:\/\/devint.tricordconsulting.com\/?page_id=840"},"modified":"2019-12-11T19:49:46","modified_gmt":"2019-12-11T19:49:46","slug":"bwon-nsps-qqq","status":"publish","type":"page","link":"https:\/\/tricordconsulting.com\/index.php\/bwon-nsps-qqq\/","title":{"rendered":"BWON and NSPS QQQ Compliance"},"content":{"rendered":"
<\/div><\/div><\/div>\n
<\/span><\/span><\/div>\n

<\/h2>\n

BWON and NSPS QQQ Compliance<\/strong><\/h2>\n

40 CFR Part 61, Subpart FF (Benzene Waste Operations NESHAPs or \u2018BWON\u2019) and 40 CFR Part 60, Subpart QQQ (NSPS QQQ) are two notable federal emissions standards which often present unique challenges which reflect their dual nature both focusing on the regulation of air emissions generated by wastewater systems.\u00a0 Despite being promulgated more than 25 years ago, BWON and NSPS QQQ are complex regulations which continue to be a source of confusion to many in the regulated community.\u00a0 With this confusion, there is the potential for risk \u2013 risk of regulatory enforcement, fines, and punitive Consent Decrees.\u00a0 In many cases, folks may not even know where they stand with relation to compliance with these rules.\u00a0 They may be doing too much, or too little, with little understanding of whether their BWON and QQQ compliance programs are on the right track or are headed for trouble.<\/p>\n

With TRICORD as a partner, you can achieve clarity and peace of mind where there used to be confusion and doubt. TRICORD\u2019s mission is to serve the regulated community by providing a team of top-quality environmental, health, and safety (EHS) specialists with the technical expertise and relationship-driven approach to help you achieve your goals.\u00a0 For BWON and NSPS QQQ, TRICORD is proud to offer a team of recognized subject-matter experts with a proven track record of excellence established over many decades of combined experience.<\/p>\n

BWON<\/strong><\/p>\n

BWON, also commonly referred to as \u2018NESHAPs FF or Benzene NESHAPs\u2019, regulates benzene emissions from waste operations occurring at refineries, chemical plants, Treatment, Storage, and Disposal Facilities (TSDFs), and coke by-product recovery plants.\u00a0 Applicability to BWON control standards is determined by calculating the Total Annual Benzene (TAB) for an affected facility, which is the annual mass of benzene contained in the waste streams generated by that site.\u00a0 Facilities with a TAB quantity of greater than 10 Megagrams per year (Mg\/yr) are required to control and treat selected facility waste streams in accordance with one of the available BWON compliance options (generally either the 2 Mg\/yr segregate-and-treat option or the 6 Mg\/yr treat-to-target option, also referred to as the \u20182BQ\u2019 and \u20186BQ\u2019 compliance options, accordingly).<\/p>\n

Although it is possible to describe the BWON regulation in only a few sentences, the stories of the many challenges faced by the regulated community since the promulgation of this rule in 1993 are sufficient to fill volumes.\u00a0 BWON\u2019s complexity is such that it seems to impact almost every functional area at a facility \u2013 environmental, capital projects, process engineering, operations, maintenance\/turnaround, even the laboratory!\u00a0 Adding to this complexity are the BWON enhancement provisions that are part of many refinery and chemical plant Consent Decrees, which impose additional requirements that are above-and-beyond those which are part of the rule itself.\u00a0 Added together, managing a compliant BWON program is a challenging proposition which demands daily vigilance.<\/p>\n

\u00a0<\/strong><\/p>\n

NSPS QQQ<\/strong><\/p>\n

Specifically affecting only petroleum refineries, NSPS QQQ is a federal standard which requires air emissions controls on certain oily wastewater collection and treatment equipment in Volatile Organic Compound (VOC) service, which has been constructed, reconstructed, or modified after the regulatory effective date of May 4, 1987.\u00a0 Affected sources under NSPS QQQ include:<\/p>\n