June 6, 2019
BWON Fundamentals for Chemical and Refinery Program Managers
Ryan Atkinson, TRICORD Consulting, LLC and Laura Blohm, Senior Project Manager, TRICORD Consulting, LLC
40 CFR 61, Subpart FF (Benzene Waste Operations NESHAPs or BWON) is considered by many program managers and environmental supervisors to present a unique set of compliance challenges which can be difficult to understand and manage effectively. BWON compliance is not often a black and white proposition – the rule is comprised of a complex and nuanced web of requirements that can quickly become confusing to even experienced industry professionals. This presentation will discuss the fundamental concepts of the BWON rule, common program management challenges and approaches, and a comparison between the compliance issues faced by refineries versus those faced by chemical plants.