NPRA Environmental Conference, September 2009 Case Study: Carbon Canister Design Documentation under Benzene Waste Operations

摘要

The lack of design documentation for carbon adsorption systems used to control air emissions from Benzene Waste Operations NESHAP (BWON) affected waste management units (WMUs), such as individual drain systems, junction boxes, tanks, containers, and wastewater treatment system components, is a routine finding during refinery BWON audits. Regulated facilities often rely on empirical data to determine carbon usage and monitoring frequencies and do not develop the design documentation required by the BWON. Additionally, it is common for regulated facilities to neglect to update design documentation or monitoring frequencies when changes are made that may affect the characteristics of the wastes or wastewaters managed by BWON- affected WMUs. EPA has attempted to improve the operation of these carbon adsorption systems by developing specific protocols in refinery global settlements, or Consent Decrees. However, this provides refiners with a false sense of security because compliance with Consent Decree provisions does not necessarily fulfill the underlying regulatory requirements. In fact, the carbon canister provisions in a Consent Decree, namely the breakthrough concentration, are not always as stringent as the underlying regulatory requirements.