BWON

Ruth Benning
BWON Essentials
This workshop will teach you how to effectively and affordably establish a BWON compliance program. Designed for individuals new to BWON roles or with less than 5 years of experience, this training recognizes the need for adaptability in a constantly evolving environment.
Room 408
Tuesday 8:00 AM
5:00 PM

Horiuchi, Kelly
Total Petroleum Hydrocarbon (TPH) Analytical Techniques – Shovel vs Scalpel?
Analytical techniques for TPH have not been updated for more than a decade. Risk management decisions at petroleum release sites generally require some level of understanding of the hydrocarbon composition. However, traditional TPH analytical techniques provide no speciated data regarding the hydrocarbon composition. Considering that TPH analyses and standards are inconsistent, determination of health risks and development of toxicity values for mixtures of hydrocarbons are problematic. Most risk assessors prefer to assess individual constituents rather than evaluate TPH concentrations. Providing a more applicable, fractionated TPH concentration has been used via Massachusetts Department of Environmental Protection. The next evolution in analytical technique is available. TPH speciation through forensic fingerprinting, with target compound selectivity, two-dimensional resolution, and peak differentiation provides an accurate tool to better define the nature and associated risk of hydrocarbon mixtures at petroleum release sites. These improved TPH methods would avoid unnecessary remediation or even more important underestimation of potential risks attributed to petroleum hydrocarbons in various media. It is time to stop using a catch all total value “shovel” method and implement precision science-based technology to ensure people, the environment, as well as profits are protected.
Room 408
Tuesday 4:00 PM
4:45 PM

Warren Merriman
Minimizing VOC Emissions During Tank De-Watering
Over time, water accumulates in tanks and must be removed, but traditional methods can lead to high levels of hydrocarbon discharge. This presentation will discuss a novel approach to minimize the release of hydrocarbons, such as colorless Benzene, into the Effluent System during Tank De-Watering. The results demonstrate a significant reduction in VOC breakthrough, with less than 1 gallon of hydrocarbon per draw-off event, improving operator safety and plant mass balance data for Yield Accounting.
Room 408
Wednesday 11:00 AM
11:44 AM


BWON Auditing: Post Ken Garing
BWON auditing post Ken Garing may be more about actual emissions than all the details of compliance with all the typical BWON Checklist Items from the 90s and early 2000s.   The actual emissions from the hundreds of thousands of individual pieces of equipment may now be more germane.  For example, bellows valves on PRVs, PVRVs on storage tanks, loading lines and couplings, API gaskets, and many more non-traditional sources add up to many gray areas.   What will be the impact of so many non-traditional sources now that OGI cameras and one of the 20 other technologies become widely available to regulators and community action groups?   There are around 100 to 1,000 components leaking at any given time in a refinery or chemical plant with 100,000 to 1,000,000 component interfaces.  Finding these leaks in a matter of hours or days may become imperative in the new world of technology-based compliance monitoring.   Recordkeeping and reporting may still contribute to consent decrees, but the actual emissions may be the conductor driving the consent decree train.
Room 408
Wednesday 1:00 PM
1:45 PM

Fricker, David
Conforming to ASTM-D7036: Self-Declaration vs. ThirdParty Accreditation
Room 408
Thursday 2:30 PM
3:15 PM

Dean Barnes
Tank Top Venting Issues
Tank venting equipment such as blanketing regulators, thief hatches, pressure/vacuum relief valves and emergency vents are needed to safely operate AST's. If these devices are not correctly sized and selected, excessive fugitive emissions and increased maintenance costs can occur. This session will cover the basic principles of tank vent sizing and selection to help control fugitive emissions as well as how to use remote monitoring and the ProductionManager EDGE™ software to gain a better understanding of what is happening on top of the tank and quantify releases in the event these devices open to relieve pressure
Room 408
Wednesday 10:15 AM
11:00 AM

Brian Ledeboer
A New Way to Measure Toxic Gases with Wireless and IIoT and Fenceline Monitoring
Room 408
Wednesday 1:45 PM
2:30 PM

Aaron Medema
BWON Observed Through a New Lens
Room 408
Wednesday 1:00 PM
1:44 PM

BWON Observed Through a New Lens
Room 408
Wednesday 8:00 AM
8:44 AM

Troy Boley
Flare Essentials Training Part 1
Spectrum is hosting a comprehensive 1-Day event for both newcomers and experienced professionals in the field of flaring. The workshop will delve into the Regulatory Overview of Modern Flare Requirements, covering topics such as Refinery, Ethylene, MON, and OLD "MACT" requirements. In addition, Spectrum's experts will be introducing Special Flare Topics including Consent Decrees, Emissions Reporting, Future Regulations, Oil & Gas, Methane related issues, Smoke Monitoring and Control, and more. With decades of experience in flare instrumentation and regulatory assessment, Spectrum's Flare Team is excited to share their knowledge with attendees. Don't miss this opportunity to learn from the best in the industry!
Room 406
Tuesday 8:00 AM
11:00 AM

Redlinger, Tom
Flare Test  in the Oil and Gas World
The newest oil and gas regulations have complicated and conflicting provisions regarding the stack testing components.  What to do?  When, How much and for How long?  Are there options in the regulations?  These questions and more are answered in this presentation.
Room 406
Tuesday 8:45 AM
9:29 AM

Yousheng Zeng
Video Imaging Spectral Radiometry as an Alternative Monitoring Method for the Refinery Sector Rule
The focus of instrumentation for flare monitoring has traditionally been on the feed side, neglecting feedback on actual flare performance. However, a new technology called Video Imaging Spectro-Radiometry (VISR) now allows for remote monitoring of flare performance and instant feedback to operators. This course will cover traditional flare feed side instrumentation, VISR technology, and the flare dashboard, providing operators with essential information to optimize flare performance day or night. Additionally, regulatory compliance topics such as flare monitoring requirements in the Refinery Sector Rule will be discussed.
Room 406
Tuesday 9:30 AM
10:14 AM

Herman Holm
Flares Essentials
Flares have found their way to the top of EPA's list of priorities - from a National Enforcement Initiative to Consent Decrees, to NSPS Subpart Ja. The Flares Essentials course discusses the finer points of these regulations, walks you through the fundamentals of flaring, and uncovers opportunities for you to maximize your flare performance. It's the right training at the right time to build a flares foundation for the future.
Room 406
Tuesday 10:45 AM
11:30 AM

Mark Nixon
Early Prediction of Flare - Big Data
Our presentation showcases a Data Analytics System that accurately predicts 79% of flare events. We demonstrate the effectiveness of a hierarchically distributed monitoring approach for flare event prediction in a refinery with a flare gas recovery system. By utilizing tools such as principal component analysis, slow feature analysis, and wavelet transform within a distributed process monitoring framework, we have developed successful monitoring solutions. Our application of a hierarchically distributed monitoring framework, incorporating both time and frequency domain techniques, has enabled us to detect 11 out of 14 events before they occur.
Room 406
Tuesday 3:15 PM
3:59 PM

Mark Smith
Remote Monitoring & Management: How to Improve Safety by Reducing Call-Outs by 85%
This presentation will share a case study on improving safety performance with remote monitoring and management techniques that result in call-out reductions of 85%.
Room 406
Wednesday 8:00 AM
8:44 AM


Steam Flare Efficiency
Room 406
Wednesday 8:45 AM
9:29 AM

Jon Morris
Measured Methane Emissions from Flares and Their ESG Implication
The focus on methane emissions from flaring has increased in recent years due to corporate and regulatory interest. While only a small number of flares at petroleum refineries and ethylene plants have been monitored, the majority of flares have not been measured for their actual emissions. With advancements in technology, measuring and monitoring flare emissions is now feasible, practical, and cost-effective. This presentation will discuss findings from Providence's measurements of flare efficiencies, based on over a thousand individual flare measurements. The analysis includes a look at the distribution of flare efficiencies and the monetary value of quantified methane emissions, as well as the broader implications of measuring flare emissions from an ESG perspective.
Room 406
Wednesday 9:30 AM
10:14 AM

Brian, Cochren
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Room 406
Thursday 8:00 AM
8:44 AM

Herman Holm
Flare Special Topics
Spectrum is hosting a comprehensive 1-Day event for both newcomers and experienced professionals in the field of flaring. The workshop will delve into the Regulatory Overview of Modern Flare Requirements, covering topics such as Refinery, Ethylene, MON, and OLD "MACT" requirements. In addition, Spectrum's experts will be introducing Special Flare Topics including Consent Decrees, Emissions Reporting, Future Regulations, Oil & Gas, Methane related issues, Smoke Monitoring and Control, and more. With decades of experience in flare instrumentation and regulatory assessment, Spectrum's Flare Team is excited to share their knowledge with attendees. Don't miss this opportunity to learn from the best in the industry!
Room 406
Thursday 10:00 AM
5:00 PM

Jon Morris
Advanced Topics in Quantitative Optical Gas Imaging
The presentation will cover the increasing acceptance of Optical Gas Imaging (OGI) in the petroleum and petrochemical industries for safety and environmental purposes. It will discuss how the new NSPS OOOOa and BLM regulations now allow OGI as the primary Leak Detection and Repair (LDAR) technology. The presentation will also explore the new requirements for OGI inspections and the advancements in OGI technology, including the introduction of a Quantitative Optical Gas Imaging (QOGI) method for real-time leak rate measurements. Additionally, the course will review the basics of OGI and its connection to the new regulations, as well as the OGI requirements for a OOOOa compliant monitoring plan. Results from blind testing and comparisons to other quantitative methods will be shared, along with applications for QOGI in the oil and gas industry. The presentation will conclude with an overview of the latest developments in Optical Gas Imaging, focusing on its applications in the petroleum and petrochemical sectors.
Room 406
Thursday 11:00 AM
11:44 AM

De Carlo, Chuck
Flares for Experts: Flare Instrumentation and Analyzers
Led by Mike Hahn and Troy Boley, this presentation features insights on flow/composition measurement technologies and flare control techniques from industry leaders such as Spectrum, Vector Controls and Automation Group, Baker Hughes GE Oil and Gas, Extrel Core Mass Spectrometers, Environmental Systems Corporation, Emerson Process Management, and Airgas.
Room 406
Thursday 3:15 PM
3:59 PM

Yousheng Zeng
VISR Enabled Dashboard for Flare Operators
The presentation will focus on the lack of instrumentation for providing feedback to flare operators on flare performance, and introduce a new technology called Video Imaging Spectro-Radiometry (VISR) that can remotely monitor flare performance and provide instant feedback. The course will cover flare feed side instrumentation, VISR technology, flare dashboard, and relevant regulatory compliance topics.
Room 406
Friday 8:45 AM
9:29 AM

Olstowsky, Franek
Total Sulfur in Flare Gas: Fast, Linear, Online Analysis with Excimer UV Fluorescence (EUVF)
The presentation will cover the use of Excimer UV Fluorescence (EUVF) technology for detecting and quantifying trace amounts of chemicals and pollutants in various samples. EUVF technology utilizes ultraviolet light and a gas mixture to create an excited state called an excimer, which emits ultraviolet light to excite molecules in the sample, causing them to fluoresce. This technique is highly sensitive and selective, capable of detecting chemicals at parts-per-trillion or parts-per-billion levels without the need for sample preparation. EUVF is a non-destructive and efficient analytical tool that has been widely used in industrial settings for low-level sulfur analysis.
Room 406
Friday 11:00 AM
11:44 AM

Dustin Beebe
Flare System Control and Compliance
The presentation will cover the recent updates to environmental compliance for flare operations, specifically focusing on changes to 40 CFR §63.670/1. The main objective of the control algorithms for flare steam and supplemental gas is to ensure a destruction efficiency of 98% while also preventing visible emissions. The algorithms for process control (63.670) are distinct from those for compliance demonstration (63.671). To uphold the integrity of the flare's operation, the control algorithms utilize real-time data. Emerson has created solutions to effectively control these parameters and ensure compliance across various control system platforms.
Room 406
Friday 2:30 PM
3:14 PM

Charles De Carlo
Flare Gas Analyzers: Three Leading Technologies, Multiple Regulations- Hands-on Training for the Cal
This presentation will provide distinct viewpoints on technologies for measuring flare flow composition from various leading providers of flare monitoring systems.
Room 406
Friday 3:15 PM
3:59 PM

Holm, Herman
Flares Essentials: Flare Regulatory Compliance
Flares have found their way to the top of EPA’s list of priorities – from a National Enforcement Initiative to Consent Decrees, to NSPS Subpart Ja. The Flares Essentials course discusses the finer points of these regulations, walks you through the fundamentals of flaring, and uncovers opportunities for you to maximize your flare performance. It’s the right training at the right time to build a flares foundation for the future.
Room 406
Tuesday 10:15 AM
11:00 AM

Holm, Herman
Flares Essentials: Flare Regulatory Compliance
Flares have found their way to the top of EPA’s list of priorities – from a National Enforcement Initiative to Consent Decrees, to NSPS Subpart Ja. The Flares Essentials course discusses the finer points of these regulations, walks you through the fundamentals of flaring, and uncovers opportunities for you to maximize your flare performance. It’s the right training at the right time to build a flares foundation for the future.
Room 406
Tuesday 11:30 AM
12:15 PM

Holm, Herman
New Flare Requirements within the Ethylene, MON, and OLD MACTs
Regulations requiring improved monitoring and control of flares at petroleum refineries are starting to be passed along to other manufacturing sectors. In October 2019, the U.S. EPA proposed amendments to the Generic Maximum Achievable Control Technology Standards for Ethylene Production (EMACT). Among those amendments are new monitoring and operational requirements related to flares at ethylene production facilities. Also, in recent months, the U.S. EPA has published draft rules affecting organic liquid distribution (OLD) operations and portions of the chemical sector. These requirements are found in what are commonly referred to as the OLD MACT and Miscellaneous Organic NESHAP (MON). This presentation will summarize the new flare requirements and will draw heavily on the lessons learned from implementing the similar flare requirements in the refining sector.
Room 406
Wednesday 10:00 AM
10:45 AM

Yousheng Zeng
Actual vs. Presumed Methane Emissions from Flares, Providence Photonics
Methane emissions from flares have received a great deal of attention in recent years, both from corporate initiatives and regulatory rulemaking. With exception of a small fraction of flares at petroleum refineries and ethylene plants, the vast majority of flares, hundreds of thousands of them in the US alone, have not been measured or monitored for their actual emissions. The methane emissions from these flares are estimated based on estimated or measured flow rate and a presumed flare efficiency (typically 98%). With the advancement in flare measurement and monitoring technology, measuring or continuously monitoring flare emissions is becoming technically feasible, practical, and cost-effective. In this presentation, we will discuss the current trend in flare emissions measurement and compare the actual methane emissions vs. presumed methane emissions based on a large number of field measurements of flares. We will also compare the currently available methods to measure or monitor the actual methane emissions in terms of their practicality, cost, and regulatory impact.
Room 406
Thursday 9:30 AM
10:14 AM

Boley, Troy
Looking Down the Road: The Future of Ground Flares and AMELs
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Room 406
Thursday 3:30 PM
4:15 PM


What's Going On Up There? How To Control and Reduce Tank Vent Fugitive Emissions and Maintenance
Tank related emissions are a major driver in the BWON world.  If a tank vent fails the EPA may consider the emissions to be uncontrolled under 40 CFR Part 61 Subpart FF.   This interpretation is the subject of much discussion.  This presentation covers some of the possible fixes to the problem of being designed to be leak free.  Does a contact switch meet the definition of designed to be leak free?  The solution will at least reduce the time the tank is venting to the atmosphere in an uncontrolled manner.   Stormwater Tanks, Trans Mix Tanks, Slop Oil Tanks, and other tanks with low vapor pressure may contribute to ambient background concentrations of benzene and not be detectable with Method 21 unless the tank is being filled.
Room 408
Thursday 10:00 AM
10:45 AM

Earl Richard
What's Going On Up There?  How To Control and Reduce Tank Vent Fugitive Emissions and Maintenance
Tank venting equipment such as blanketing regulators, thief hatches, pressure/vacuum relief valves and emergency vents are needed to safely operate AST's.  If these devices are not correctly sized and selected, excessive fugitive emissions and increased maintenance costs can occur.  This session will cover the basic principles of tank vent sizing and selection to help control fugitive emissions as well as how to use remote monitoring and the ProductionManager EDGE™ software to gain a better understanding of what is happening on top of the tank and quantify releases in the event these devices open to relieve pressure
Room 408
Wednesday 2:30 PM
3:14 PM

Peter Weaver
Using New Generation Satellite Platforms to Identify Product Releases and Assess Threats to Infrastr
The presentation will discuss how the rapid expansion of regulations is driving the development of new technology capabilities, particularly in the deployment of small satellites for tailored commercial solutions. With advanced imaging platforms like hyperspectral imaging (HSI), operators can now detect pipeline leaks, spills, and other threats from space, meeting stringent operational and management demands. The session will explore how satellite technology can enhance environmental compliance and ESG reporting, highlighting their essential role in asset stewardship practices.
Room 400
Tuesday 10:15 AM
10:59 AM


Understanding How Various Leak Detection and Prevention Programs Work Together
For over four decades, Leak Detection and Repair (LDAR) has relied on EPA Method 21 for regulation and assessment. However, with a plethora of leak detection and mitigation technologies now available, determining the most effective approach can be daunting. In this presentation, we explore the optimal strategies for LDAR programs, addressing questions such as which technologies offer the best value for investment and how to develop a comprehensive LDAR program that incorporates these technologies. Attendees will gain valuable insights into optimizing their LDAR initiatives and enhancing environmental protection efforts.
Room 402
Tuesday 11:00 AM
11:44 AM

Brian Taylor
The Evolving Regulatory Landscape of Alternative Monitoring
The presentation will explore how alternative monitoring solutions are transforming the approach to Leak Detection and Repair Programs in companies. By leveraging these technologies in a favorable regulatory environment, companies can mitigate risks and detect and address leaks more efficiently. The evolving regulatory framework presents an opportunity to enhance detection technologies and move towards a decarbonized future.
Room 402
Tuesday 3:15 PM
3:59 PM

David Fotouhi
Clean Water Act Jurisdiction After Sackett: What’s In, What’s Out, and What It Means for Permitting
Join our presenter for an overview of the basic structure of the Clean Water Act and its jurisdictional provision, a brief history of agency interpretations of Clean Water Act jurisdiction and the term “Waters of the United States,” and an overview of Supreme Court precedent addressing the scope of the Clean Water Act. With this background, the session will discuss the Supreme Court’s recent decision in Sackett v. Environmental Protection Agency (2023) and what it means for the future of federal jurisdiction. The program will then focus on EPA and the Army Corps of Engineers’ implementation of the Sackett decision and its impact on permitting obligations for regulated entities. The program also will discuss the pending litigation and how it impacts the current application of the Clean Water Act in different states.
Room 402
Wednesday 10:15 AM
10:59 AM

Franek Olstowski
Total Sulfur in Flare Gas: Fast, Linear, Online Analysis with Excimer UV Fluorescence (EUVF)
The presentation will cover the use of Excimer UV Fluorescence (EUVF) technology for detecting and quantifying trace amounts of chemicals and pollutants in various samples. EUVF technology utilizes ultraviolet light and a gas mixture to create an excited state called an excimer, which emits ultraviolet light to excite molecules in the sample, causing them to fluoresce. This technique is highly sensitive and selective, capable of detecting chemicals at parts-per-trillion or parts-per-billion levels without the need for sample preparation. EUVF is a non-destructive and efficient analytical tool that has been widely used in industrial settings for low-level sulfur analysis.
Room 406
Tuesday 8:00 AM
9:00 AM

Tom Watson
Meeting Flare Emissions Regulations with BTU Measurement
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Room 406
Wednesday 10:15 AM
10:59 AM

Charles De Carlo
Flares for Experts Class: Flare Composition/BTU Measurement
This presentation will provide cutting-edge insights into the latest technologies for measuring flare flow composition from leading flare monitoring system providers.
Room 406
Wednesday 1:00 PM
1:44 PM

Gilad Shpitzer
Financial Impacts of Instrument Selection for Fenceline Monitoring at Terminals
Fenceline monitoring rules are currently impacting California and Colorado and are expected to be implemented in additional States. Monitoring fuel terminals’ emissions at the fenceline is becoming mandatory, leading to specific monitoring requirements. These requirements, beginning with Colorado Rule HB21-1189 and continuing with South Coast AQMD Rule 1180 add fenceline regulation to terminal facilities related to refineries. These rules specify a list of chemicals to be monitored, including BTEX, total alkanes, acrolein, aldehydes, and others. The regulator states in its financial impact statements that multiple instruments are required, resulting in an average capital expense of $1.5 - $3MM.  The Regulator assumes that both open path instruments, FTIR and UV DOAS instruments, along with the hydrogen sulfide (H2S) point monitor, are needed to meet the compound list detection requirements. However, Atmosfir Optics suggests that, besides the H2S, the required compounds can be measured with good open path FTIR, enhanced by a real-time spectral analysis algorithm. Choosing the appropriate FTIR, along with the spectral analysis algorithm can eliminate the need for integrating both the UV DOAS and FTIR. Implementing FTIR technology, alone, with the required point monitors can meet the Rules’ requirements, saving industry 40% of the expected cost. Each UV DOAS that can be eliminated will reduce the capital expense and installation costs by approximately $250 K, and results in a 30% reduction of ongoing operation and maintenance costs.  Attached are the 12 organic compounds and hydrogen sulfide required to be monitored with the required detection limits, comparison table of compounds measured with the different techniques at the California refineries, and the D-fenceline tables demonstrating measurement of all compounds below threshold utilizing a cost-saving, single technique.
Room 406
Wednesday 2:30 PM
3:14 PM

Charles De Carlo
Flare Gas Analyzers for NHV (or BTU) and Flare Control in and Midstream, EMACT, RSR, MON, HON
The new Quad O and HON updates include requirements to ensure that flares in the affected industries are meeting the destruction efficiencies required. Compliance with these new rules will follow a pattern established previously in the refinery and ethylene/chemical sector. This discussion will focus on the regulations and the gas analyzer technologies used to measure vent gas composition and BTU.
Room 406
Thursday 8:45 AM
9:29 AM

Franek Olstowski
Flare Compliance Gas Analyzers: Mass Spec, Calorimeter, Total Sulfur- Operation and Maintenance
This presentation offers hands-on training for individuals working with flare gas analyzers and compliance. Participants will learn about the operation, calibration, and maintenance of three different analyzers - a mass spectrometer, calorimeter, and sulfur analyzer. Experts will be available to provide guidance on each technology. Flare analysis involves measuring various vent gas parameters such as heating value and total sulfur, depending on the process. Matching analyzer capabilities to regulations is crucial for ensuring flare compliance and control in the long term. Attendees will have the opportunity to gain practical experience with these technologies, which are commonly used on regulated flares. Join us to learn, ask questions, and enhance your understanding of flare gas analysis.
Room 406
Thursday 2:30 PM
3:14 PM

Brian Whitley
BWON Program Land Mines and other Oddities
If you have a BWON Program, you may be encountering issues that are flying under your radar. The EPA's new perspective has caused significant challenges recently. Regrettably, the actions taken by many during recent inspections are exacerbating the situation and creating further complications for both them and you.To effectively navigate these challenges and pinpoint the trouble spots in your BWON database, be sure to attend our presentation. Whether you are currently facing scrutiny or preparing for potential inspections, discover the true meaning of mitigation. Learn how to strengthen your facility and eliminate existing pitfalls in your database before they are uncovered.
Room 408
Wednesday 8:45 AM
9:29 AM

David Wall
EPA's Recent BWON Enforcement Alert
Breakdown This presentation will be of great interest to anyone in the petroleum refining an petrochemical industries with appliable to the Benzene Waste Operations NESHAP. U.S. EPA has undertaken a renewed BWON enforcement effort of the last 18+ months. This effort has included new focus areas and has challenged prior compliance interpretations. U.S. EPA recently released an enforcement alert spelling out the various elements of this renewed effort and summarizing the first of what are to be expected to be several new BWON consent decrees. This presentation will breakdown each of the elements of the enforcement alert and discuss the regulatory basis as well as highlight practical experience with recent enforcement efforts.
Room 408
Wednesday 9:30 AM
10:15 AM


Continuous Benzene Monitoring with a 1 km range
scanfeld is a revolutionary system for remotely detecting dangerous gas emissions and improving the safety of chemical processing plants. The Grandperspective scanfeld system shortens the time to alert if gases such as ammonia are accidentally released. The passive infrared optical measurement technology covers vast areas of more than 1 km² per sensor. Based on a spectroscopic technology the scanfeld sensors provide chemical speciation and quantification of gases that are a danger to plant operators, the environment, and the immediate neighborhood. The real time tomographic reconstruction of the clouds permits to follow and predict the impact towards neighboring areas and has a direct benefit for accident mitigation. As an early warning solution, it enables plant operators and emergency responders to react swiftly in case of unexpected emissions. By monitoring minor or near incidents (‘near miss’) the solution provides additional barriers preventing major accidents. By real-time monitoring, the propagation of a gas cloud in the course of an event, safety barriers for incident mitigation such as swift alert and coordinated evacuation are established.
Room 408
Wednesday 1:00 PM
1:45 PM

Ruth Benning
Frequently Missed BWON Streams
There are BWON streams common to nearly every refinery and chemical plant.  Interstage coolers, compressor lube oil, flare knock-out pots, etc.   For a complete list of streams frequently missed at chemical plants and refineries attend the class and hear Ruth Benning cover the details of waste streams covered by 40 CFR Part 61 Subpart FF.
Room 408
Wednesday 1:00 PM
1:45 PM

Ruth Benning
BWON for Experts Part 1
Ruth Benning will share strategies for successful BWON audits, including identifying commonly missed streams, addressing common violations, and implementing best management practices for sustainable programs with minimal compliance costs. Whether your BWON program is thriving, in need of improvement, or struggling, this presentation offers valuable insights and opportunities for collaboration. The importance of quantitative benzene monitoring and maintaining situational awareness will also be emphasized.
Room 408
Thursday 8:00 AM
11:00 AM

Bart Leininger
Using a Risk-Based Approach to Manage BWON Compliance
The BWON is a complicated regulation that creates significant potential compliance exposures for industrial sites.  With a regulatory program that has so many compliance pitfalls, where does one begin to identify and rank those exposures?  How should the environmental compliance team prioritize its efforts to improve its overall level of compliance with the BWON?  This presentation provides a risk-based framework to evaluate and manage compliance with the BWON.  The presentation provides practical and specific recommendations to improve compliance in an era of increased regulatory scrutiny.
Room 408
Thursday 1:00 PM
1:44 PM

Ruth Benning
BWON Auditing for Experts
This session will address complex BWON questions and regulatory issues, such as: Is it necessary to conduct flare performance tests while loading a barge that takes approximately 24 hours? What constitutes a loading cycle? How should the total annual benzene quantity be calculated for proper management? Do hydrocarbons, specifically benzene, lost through leaks or spills at a refinery and collected underground on groundwater qualify as waste under the Benzene Waste NESHAP? Do cooling towers meet the criteria of a process unit under the Benzene Waste NESHAP? Are individual drain systems, including junction boxes, considered waste management units under 40 CFR §61.346? What is the definition of a wastestream? Is spent caustic always classified as waste under 40 CFR §61.341? Should spent caustic be included in a refinery's total annual benzene determination? Are facilities opting for compliance with 40 CFR §61.342(e) required to include the benzene quantity of all spent caustic waste in the determination as outlined in 40 CFR §61.355(k)?
Room 408
Thursday 2:30 PM
4:00 PM

Ruth Benning
BWON for Experts Part 2
During the presentation, Ruth Benning will share valuable advice on conducting successful audits for BWON programs. She will discuss frequently overlooked streams, common violations, suggestions for implementing best management practices, and essential components of cost-effective compliance programs. Whether your BWON program is running smoothly, could use some improvement, or is struggling, this is a not-to-be-missed chance to engage with a wealth of knowledge and expertise.
Room 408
Friday 1:00 PM
3:44 PM