201803 BWON Workshop Manual

BWON Fundamentals -

Implementing a Comprehensive BWON Program

Welcome

BWON Fundamentals -Implementing a Comprehensive BWON Program


BWON Workshop Agenda

• Overview of the BWON Rule

• Definitions and Applicability

• Compliance Options and Exercises

• Control Requirements and Treatment Standards

• Creating BWON TAB Reports / TAB Tool

• Question and Answer / Open Forum / Reception




Disclaimer

• Workshop materials include summaries of regulatory text, preambles, technical amendments, Consent Decrees, applicability determinations, and interpretative materials. Not all BWON rule requirements are discussed.

• Refer to the current Code of Federal Regulations (CFR) and company legal and regulatory expertise for all regulatory and compliance decision – making.



Workshop Materials• Presentation manual contains:

• Copies of the presentations

• Downloadable Info:• BWON preambles and 40 CFR Part

61 Subpart FF• Copies of EPA determinations and

Consent Decrees• Copies from the EPA Applicability

Determination Index (ADI) - also cited in the presentations

• Proposed BWON Technical Amendments, BWON FAQ, and select EPA published guidance and determinations

Cal Niss

Senior Vice [email protected]

(307) 745-7474

Erin Novini, P.E.

Project [email protected]

(714) 399-1561

Presenters




Overview of the BWON Rule

• Review of Definitions

• Key Concepts

• Inspection Requirements



BWON Overview

• Unique rule that is a cross between an air rule and a waste / wastewater rule

• Intended to reduce benzene emissions from waste and wastewater

• Abbreviations and more acronyms • BWON – Benzene Waste Operations NESHAPs

• BQ – Benzene Quantity

• TAB – Total Annual Benzene Quantity

• NESHAPs – National Emission Standards for Hazardous Air Pollutants

• WMU – Waste Management Unit

• POG – Point of Waste Generation



General Requirements

• Calculate the Total Annual Benzene (TAB) Quantity at Point of Generation (POG)

• If the TAB Quantity is:• Less than 1 Mg/yr – submit initial report only

• Greater than 1 Mg/yr but less than 10 Mg/yr – submit annual report

• Greater than or equal to 10 Mg/yr

• Select compliance option

• Control / treat wastes

• Monitor operations

• Submit periodic / annual reports



Requirements Based on Facility TAB Quantity (See “Handouts” Section of Manual)



Total Annual Benzene (TAB)

• Total amount of benzene (controlled and uncontrolled) produced by the facility as waste

• TAB determines compliance level

• Facilities must include the POG aqueous waste and any organics (hydrocarbons) that are co-mingled with aqueous wastes in the TAB

• Affected facility generates > 10 Mg of benzene as waste



Where is the “Point of Waste Generation”?

• The location where the TAB determination must be made• Where a waste exits a piece of equipment that is integral to the

process (Process Vessel) and prior to management or treatment in an operation or equipment that is not integral to the production process (Waste Management Unit)

• Location is prior to handling and treatment of a waste and before any opportunity for benzene losses

• Wastes received by a Treatment/Storage/Disposal Facility (TSDF) from offsite quantified at point of entry

• For wastes with multiple phases, the determination shall provide the flow-weighted average benzene concentration for each phase of the waste relative to the proportion of the phase



POG Exceptions

• Exit from the sour water stripper (refinery)

• Exit from the process unit component or waste management unit (coke by-product)

• Point where the waste enters the hazardous waste treatment, storage, or disposal facility

• Turnaround for each subsequent year until the unit undergoes the next process unit turnaround



Waste & Waste Streams

• Waste – 61.341• Any material…that is discarded or is being accumulated, stored,

or physically, chemically, thermally, or biologically treated prior to being discarded, recycled, or discharged.

• BWON definition of waste is different than RCRA. For example, recycled materials can still be considered wastes at their POG under BWON.

• Wastes are considered to be recycled once they are fed to a process as a feed stock, or are fed to a process feed tank. • Prior to and during recycle, wastes are regulated by BWON.

• After recycle, wastes are no longer regulated by BWON.



• Slop oil routed to slop tanks• Spent caustics- even if recycled or

sold • (FAQ Questions 18 to 22)

• Benzene-containing waste materials (sludge, DAF float) sent off-site for recycle or other use

• Pump drainages including drainage from low points in lines

• Laboratory waste (sample wastes) and knock engine lab wastes

• Unit wash downs

Waste Examples



Waste Streams: Identify the POG• Means the waste generated by a particular process unit, product

tank, or waste management unit

• Characteristics are determined at the point of generation



Waste Streams To Be Counted

• 61.342(a) • The total annual benzene quantity from facility waste is the sum of each waste

stream at the facility that has a flow-weighted annual average water content greater than 10% or that is mixed with water, or other wastes and the mixture has an annual average water content greater than 10%

• The benzene quantity is to be counted only once without multiple counting if other waste streams are mixed with or generated from the original waste stream

• Aqueous • Short hand for materials that have a flow-weighted annual average water content

>10% or that is mixed with water or other wastes at anytime (61.355(a)(1))

• EPA intended for sources to include the benzene in organic waste in the TAB if the organic waste is mixed with wastewater at some point after its generation (FAQ Question 29)

Waste Streams To Be Counted

Note:Slop Tank is not a BWON regulated tank.




• If waste is introduced to a process feed vessel to a process unit, or

• If waste is introduced directly to the process unit

For example, crude oil storage tanks (yes) and slop oil tanks (no)

Recycled Waste

Benzene Concentration

Knowledge of the waste or Sampling




What is “Knowledge of the Waste”

• The owner or operator shall provide sufficient information to document the flow-weighted annual average benzene concentration of each waste stream. Examples of information that could constitute knowledge include material balances, records of chemical purchases, or previous test results provided the results are still relevant to the current waste stream conditions. If test data are used, then the owner or operator shall provide documentation describing the testing protocol and the means by which sampling variability and analytical variability were accounted for in the determination of the flow-weighted annual average benzene concentration for the waste stream.



Determining Benzene Concentration/Sampling

• Sampling per 40 CFR 61.355(c)(3) • Three representative samples

• Minimize exposure to atmosphere

• Chill samples to less than 10°C (50°F)

• Analyze sample per Methods 8020, 8021, 8240, 8260, 602 or 624

BWON Sample Cooler



Sampling | Method 25D

• Acceptable bubble size – “pea size” or ¼ inch or 6mm in diameter

• Use of field forms• Record the sample’s physical characteristics (e.g., clear with solids,

black green, etc.)

• Record what type of sample method you use (cooler or grab) and the specific cooler number

• Record the date, time, sampler, vessel location, unit, facility, etc.

• Record the sample ID (as it appears on the COC) and the stream description

• Record the temperature

Sampling |Method 25D

(See “Handouts” Section of Manual)



Sampling | Method 25D

• QA/QC

• Blind duplicates

• Trip blanks

• Field blanks

• Equipment blanks

• Conduct EPA Methods Tier I and Tier II data validations



Sampling | Method 25D –Decontamination

• If sampling equipment is not disposable or dedicated to a sample location, it should be decontaminated and have an equipment blank analyzed.

• Decontamination is not specified in the rule.



Waste Quantity • Highest annual quantity of

waste generated from past 5 years of historical records

• Maximum design capacity of the waste management unit

• Measurements that are representative of maximum waste generation rates

• Turnarounds may be annualized



Concentration Rule of Thumb

If oil‐phase concentration is known, but aqueous phase is unknown: Aqueous Phase Benzene (ppmw) = Oil Phase Benzene (ppmw) / 100

The basis for this rule of thumb is based on the effective benzene solubility

Generally, a conservative estimate of aqueous‐phase benzene concentration

Not conservative estimate of oil‐phase benzene if calculation is reversed Oil Phase Benzene (ppmw) = 120 x Aqueous Phase Benzene (ppmw)

Aqueous benzene concentration not normally greater than 1,400 to 1,600 ppmw



TAB Accounting Exceptions

• Remediation wastes are not required to be included in the TAB calculation • Waste generated by turnaround activities may be averaged over the turnaround

cycle for TAB determination (up to 5 years) and included in the next TAB • Waste streams that contain no benzene and have no potential to contain

benzene are not counted towards the TAB or included in the TAB• Streams containing less than 10% water by volume and do not mix with water or

wastes to become greater than 10 % water by volume are not counted towards the TAB

• Aqueous wastes generated infrequently, accidentally, or intermittently are counted towards TAB

• Streams containing greater than 10 ppmw sulfur or ammonia and which are managed in “enclosed system” systems en route to a sour water stripper are counted at the exit of the stripper



BWON Compliance Options

Facilities with a TAB of greater than 10 Mg/yr are required to control/treat benzene containing waste streams

Compliance Options • 1 Mg /yr Target for Process Wastewater – 61.342(d)

• Not generally used if at all

• Segregate-and-Treat Option – 2 Mg Compliance Option – 61.342 (c) (2)

• Treat-to-Target Quantity – 6 Mg/yr compliance option or “6BQ” –61.342 (e)



2 Mg Compliance Option | 61.342(c)(2)“Segregate and Treat”

• Exempt waste streams from control as long as the benzene quantity from those waste streams at the POG is less than 2 Mg/yr

• Exclude less than 10 ppmw benzene streams from control but do not count toward the 2 Mg/yr ledger – must demonstrate exemptions at least annually

• Uncontrolled waste must be counted at the POG

• Uncontrolled turnaround waste must be counted toward the 2 Mg/yr ledger for the year generated (no averaging)

• Excluded wastes – uncontrolled remediation wastes and uncontrolled organic waste streams must be counted toward the 2 Mg/yr ledger



• The uncontrolled BQ must be less than 6 Mg/yr• The uncontrolled BQ for each waste stream is counted at the point where it

enters the first uncontrolled WMU • Treated wastes must be counted where they enter the first uncontrolled WMU or

where they are sent offsite• Wastes shipped offsite must be counted when the waste leaves the facility

unless documentation is provided by receiving facility that the waste is controlled • Organic waste streams must be controlled until treated or recycled in

accordance with 61.342 (c) (1)• The “classic” treatment standards / demonstrations do not apply to treatment at

6 BQ facilities. As previously mentioned, the 6 BQ is a “treat-to-target” option• Benzene quantity (BQ) under the 6 BQ option is considered a running total

during the reporting year, compliance cannot be reestablished• EPA’s favored compliance option

6 BQ Compliance Option | 61.342(e)“Treat‐to‐Target”



2 Mg vs. 6 BQ | Buckets of Benzene

• 2 Mg gets two “buckets”• One bucket for all

uncontrolled wastes greater than 10 ppmw with a size limit of 2 Mg/yr

• One bucket for all uncontrolled less than 10 ppmw that could be “infinite” size

• 6 BQ get one “bucket” for all uncontrolled waste regardless of concentration

Table 1. Overview of the BWON Rule(See “Handouts” Section of Manual)

STREAM TYPE INCLUDED IN TAB INCLUDED IN 6 BQ INCLUDED IN 2 Mg

Uncontrolled < 10 ppmw benzene

YES YES NO

Uncontrolled >= 10 ppmw benzene

YES YES YES

Controlled YES At entrance to first uncontrolled WMU or when shipped offsite

NO - But if becomes uncontrolled

Remediation Wastes NO YES - if uncontrolled YES - if uncontrolled and >= 10 ppmw benzene

Organic Stream - < 10 % water

NO Controls are required YES - if uncontrolled and >= 10 ppmw benzene

Organic Stream - > 10 % water

YES YES - If uncontrolled YES - If uncontrolled and >= 10 ppmw benzene

Turnaround Waste YES - can average over turnaround cycle

YES - counted in year waste is generated

YES - counted in year waste is generated if >= 10 ppmw benzene

Maintenance Waste YES YES - year generated YES - if uncontrolled and >= 10 ppmw benzene

No Potential to Contain Benzene

NO NO NO

Treated Waste NO YES - At entrance to first uncontrolled waste management unit

NO - if all waste management units are controlled up to treatment 61.348

Sour Water Stream YES - counted at exit of the sour water stripper

Counted at exit of the stripper if the stripper effluent uncontrolled

Counted at exit of the stripper if the stripper effluent is uncontrolled and >= 10 ppmw benzene

Breakout Session #1

Waste Management Units



Control Requirements and Treatment Standards: What is Meant by Control?

• For a waste to be considered “controlled” it must be managed in controlled “waste management units” (WMUs) from the POG to treatment, recycle, or point of 6BQ accounting

• Control requirements for each type of WMU and treatment processes are promulgated in 61.343 through 61.349.

• Controls generally include closed vent systems to control devices or floating roofs (control device options include carbon, combustion controls, flares, etc.)

• In addition to physical controls, initial and quarterly visual inspections and initial and annual Method 21 instrument leak detection monitoring must be performed on controlled WMUs



BWON | Waste Management Unit Control Standards

• Individual Drain Systems

• Storage Tanks

• Oil-Water Separators

• Containers

• Surface Impoundments

• Treatment Devices

• Closed-Vent Systems

• Flare Gas Recovery



Individual Drain Systems

Individual Drain Systems (IDS)

• Systems used to convey waste from a process unit, product storage tank, or waste management unit. These systems include completely closed drain systems, gravity flow systems, and unburied sewer lines; drains must be closed or have “p-traps”, and junction boxes require either a cover or closed vent system (CVS) to control or prevent flow to the atmosphere and flow indicator (i.e., conservation vent or water seal).



IDS Controls | Drain with Water Seal



IDS Controls | P-Trap Insert



IDS Controls | Closed Drain

IDS Controls | Caps or Plugs


Junction Box with Changing Level


Water Sealed Junction Box




Tanks – Stationary waste management units designed to contain an accumulation of waste and constructed primarily of non-earthen materials.

• Fixed roof (or inside a total enclosure) and all vapors must be routed through a closed vent system to a control device:• Conservation vent allowed and no

closed vent system to control device required if tank manages less than 10 % water waste and size /vapor pressure requirements are met.

• Internal floating roof and a fixed roof which meets the requirements of NSPS Kb – 60.112b(a)

• External floating roof meeting the requirement of NSPS Kb-60.112b(a)(2)

• Tank openings may remain open if tank operates under vacuum

Storage Tanks



Oil-Water Separators

• These WMUs are generally a tank or surface impoundment, used to separate oil from water and include: • API Separators

• Corrugated Plate Interceptors

• Parallel Plate Interceptors

• Dissolved Air Floatation (DAF) Separators

• Dissolved Nitrogen Floatation (DNF) Separators

• Vessels equipped with internal weirs / skimmers



Oil-Water Separators

• Includes the separating unit, forebay and afterbay and other separator basins, skimmers, weirs, grit chambers, sludge hoppers, and bar screens located directly after the individual drain system and prior to additional treatment units such as an air floatation unit, clarifier, or biological treatment unit.

• Control options include:• Fixed roof cover vented through a CVS and control device • Floating roof compliant with NSPS QQQ

• Fixed roof portions of floating roof oil-water separators must be controlled per FF.

• Secondary seal – inspected annually• Primary seal – inspected every 5 years



Containers

Examples of containers applicable to the rule include: • Drums • Frac (or Baker) tanks • Barrels • Tank trucks • Vacuum trucks • Roll-off boxes • Barges • Dumpsters • Tank cars • Dump trucks• Marine vessels (ships)

Containers are > 26 gallons by definition and consist of any portable WMU in which a waste material is stored, transported or handled.



Container Standards

• Must be equipped with a cover designed to operate with no detectable emissions

• Cover openings must be maintained in a closed, sealed position at all times that waste is in the container, except during waste loading, removal, inspection or sampling.

• If the waste is pumped into the container, the waste must be transferred into a container by use of a submerged fill pipe within two pipe diameters of the bottom of the container.

• Treatment of a waste in a container, including aeration, thermal or other treatment, can only be performed if the container is vented to a CVS and control device.

• Containers with capacity less than 111 gallons and which meet DOT requirements under 49 CFR Part 178 are exempt from BWON monitoring requirements if vapor tight.



Miscellaneous Waste Management Units

• Surface Impoundments • Man-made or natural basins, pits, ponds and lagoons • Control standards are a cover and CVS to control device • Not typical in BWON facilities

• Treatment units / equipment • Equipment used to remove or destroy benzene from a waste • Control standards are to follow the requirements for one of the other BWON

WMU’s• Stripper tower operates as a treatment unit but follows relevant control standards

for fixed roof tanks

• Fuel Gas – gaseous stream from a WMU, treatment process, or wastewater treatment system routed to a fuel gas system is exempt from the rule



Closed Vent System Standards

• A system that is not open to the atmosphere and is comprised of piping, ductwork, connections and if necessary, flow-inducing devices that transport gas or vapor from an emission source to a control device.

• Must vent to control device at all times that WMU or treatment system is operating.

• On bypass lines that could divert the vent stream away from a control device, either: • Install a flow indicator to record when the vent stream is routed away from a

control device; or • Secure the bypass line with a car seal or a lock-and-key device and inspect

monthly

• May be equipped with safety devices that vent directly to the atmosphere when the device to prevent physical damage to the vent system ( i.e., conservation vent).



Control Device Standards

• An enclosed combustion device must be designed and operated to meet one of the following: • Reduce organic emissions vented to it by 95 % wt. or greater;• Achieve a total organic compound concentration of 20 ppmv (corrected to 3%

organics); or • Provide a minimum residence time of 0.5 seconds at a minimum temperature of

1400°F

• Vapor recovery systems (e.g., carbon canisters) must recover or control organic emissions with an efficiency of 95 weight percent or greater, benzene with an efficiency of 98 weight percent or greater

• Flares must comply with the requirements of 40 CFR 60.18 • Each CVS and control device in BWON service must be operated at all

times when waste is managed in a unit vented to a control device



Control Device Standards

• Regular monitoring of Control Device operating parameters is required• Flare pilot flame presence, combustion device temperature, vapor space pressure

of equipment operated at less than atmospheric pressure.

• Carbon canisters are required to be regularly monitored for “breakthrough” of VOCs• Monitoring frequency is daily or at 20 % of design carbon breakthrough frequency.• VOC or benzene breakthrough concentrations defined by 95% VOC or 98%

benzene reduction of vent stream to carbon canisters.• Design calculations form basis for monitoring frequency and breakthrough

concentrations. • Carbon canister standards often enhanced by Consent Decree requirements.



Initial and Final Repairs

• Typically a first attempt at repair must be made within 15 days for most defects except:• Closed vent systems – 5 days

• Tanks complying with Kb

• Oil-water separator cover – not specified

• Final Repairs• Oil-water separator cover – 30 days

• Not specified in the rule for most cases



Delay of Repair

• Allowed if the repair is technically impossible without a complete or potential facility or unit shutdown

• Examples of repairs that are not allowed to be delayed:• Collapsed drains

• Junction box cover repairs

• Above-ground line (IDs) repairs

• Vacuum truck repairs

• Carbon canister repairs/change outs

Note: the rule does not allow components to be classified as Difficult to Monitor (DTM) or Unsafe to Monitor (UTM).



2 Mg Treatment Standard

• Treatment Options • Remove benzene to a level less than 10 ppmw without dilution • Remove 99 percent or more benzene on a mass basis • Use an Enhanced Biodegradation Unit (EBU) • Other treatment options: Deep well injection, RCRA permitted combustions

source, POTW, etc.

• Treatment equipment must meet BWON control requirements except for EBUs

• Examples of treatment processes – sour water stripper, benzene stripper, and brine treatment systems

• The 6BQ compliance option does not require compliance with the treatment standards in 61.348



Enhanced Biodegradation Units (EBU)

• Activated sludge process that “is a suspended growth process that generates biomass, uses recycled biomass, and periodically removes biomass from the process”

• Allowable treatment process for 2 Mg option provided that inlet stream is less than 2 ppmw benzene

• Under the 6BQ, controlled waste streams entering an EBU are not counted toward the 6BQ if combined EBU inlet stream is less than 10 ppmw benzene

• Typical EBU operating parameters

• Food to microorganism ratio = 0.05 to 1.0 kg BOD per kg biomass

• Mixed liquor suspended solids = 1 to 8 grams per liter

• Residence time = 3 to 36 hours

Breakout Session #2

Discussion & Questions


Creating and Maintaining a Compliant TAB Report



Purpose of the Presentation

• Review of the fundamentals

• How to acquire the necessary data

• How to organize the data

• How to maintain an up-to-date report

• A better way to maintain a compliant TAB report



Fundamentals/Creating TAB

• Total Annual Benzene Quantity

• Waste stream

• Compliance options

• Determining the TAB



Waste Stream Exemptions

• Specific exemptions• Gases and vapors emitted from process fluids

• Waste contained in segregated storm water sewers

• Sour water • Shift the POG to the effluent of the sour water stripper

• Definition of sour water • Contains ammonia /sulfur compounds of 10 ppm weight or more

• Generated from separation of water from oil containing ammonia/sulfur compounds

• Requires treatment to remove ammonia/sulfur compounds



Definition of Sour Water Stripper

• Designed and operated to remove ammonia/sulfur compounds from sour water

• Receives sour water through enclosed system

• Off-gases sent to sulfur recovery, incinerator, process unit flare or other combustion device

• Pit- Falls • Non-sour streams routed to a sour water stripper

• Strippers not meeting the definition of sour water stripper

• Oil entrained in sour water



Review of Compliance Options

• 2 Mg Exemption

• May exempt waste streams containing less than 10 ppmw benzene

• May exempt organic waste streams

• Benzene quantity determined at POG

• Treat to a quantity of 6 Mg ( 6 BQ Option)• May not exempt waste streams containing less than 10 ppmw

benzene

• Must control all organic waste streams

• Benzene quantity determined at first uncontrolled waste management unit (i.e., may treat to comply)



Determining the TAB | Basic Concept

• TAB vs Exempted Benzene Quantity• TAB determines facility’s status with regard to the rule (less or

greater than 10 Mg)• Exempted benzene quantity determines facility’s status with regard

to the compliance option• Both situations require an accurate inventory of waste streams

• Facilities with a TAB of less than 10 Mg• Focus on the major streams – high volume, high benzene

concentrations

• Facilities with a TAB greater than 10 Mg• Focus on the uncontrolled waste streams



Determining the TAB

• Facility TAB is equal to the sum of the TAB of all waste streams in the facility

• The TAB for each waste stream is equal to the annual waste quantity multiplied by the flow-weighted annual average benzene concentration of the waste stream

• Determining the TAB requires:• Inventory of all waste streams

• Annual waste quantity of each waste stream

• Annual average benzene concentration of each waste stream



Determining the TAB |Compiling the Inventory

• Organization

• P&ID review

• Information to include:

• POG ID

• POG description

• Waste stream type

• Drawing number

• Disposition

• Control status

• Contents

• Percent aqueous/organic

• Organic phase density

• Benzene concentration (aqueous and organic)

• Volume

• Flow




(See “Handouts” Section of Manual)

• Example of waste stream inventoryEquipment/

POG ID Description Waste Stream Type Drawing Number Disposition Controlled Contents Percent Aqueous

Percent Organic

Organic Density (lbs/ft3)

Benzene Aqueous

(mg/L)

Benzene Organic (mg/kg)

Volume (gallons)

Flow (gpm)

D-1 Feed Drum D-XXX-XXX-1 Crude OilD-2 Desalter Drum D-XXX-XXX-2 Crude Oil

Desalter WaterD-3 Recycle Coalescer D-XXX-XXX-1 Crude Tower OverheadD-4 Flare Knockout Drum D-XXX-XXX-14 Flare KnockoutE-1 Reboiler D-XXX-XXX-1 Crude Tower Bottoms

SteamE-2 Overhead Condenser D-XXX-XXX-3 Crude Tower Overhead

Cooling WaterE-3 Reboiler D-XXX-XXX-3 Crude Tower Bottoms

SteamP-1 Feed Pump D-XXX-XXX-12 Crude OilP-2 Lube Oil Pump D-XXX-XXX-15 Lube OilP-3 Distillate Pump D-XXX-XXX-8 DistillateT-1 Fractionator D-XXX-XXX-7 Crude Oil

NaphthaT-2 Vacuum Tower D-XXX-XXX-6 Crude Tower Bottoms

Heavy Gas Oil



• Waste stream type• Process wastewater

• Maintenance/turnaround

• Tank water draw

• Remediation

• Spills/miscellaneous




Determining the TAB | Identifying Process Waste Streams

• Identify potential process waste streams on P&IDs• Common process waste streams

• Desalters (effluent, rag layer testing, mudwashes)• Coalescers• Reflux drums• Blowdown/knockout drums (flare, fuel gas)• Feed drums• Coke drums• Caustic washing/treating• Sour water strippers• Sour water charge tanks/drums• Compressor drains• Filters• Sample collection points

Determining the TAB | Identifying Process Waste Streams

Equipment/ POG ID Description Waste Stream Type Drawing Number Disposition Controlled Contents Percent

AqueousPercent Organic


Benzene Aqueous

(mg/L)


Volume (gallons)

Flow (gpm)

D-1 Feed Drum D-XXX-XXX-1 Crude OilD-2 Desalter Drum D-XXX-XXX-2 Crude Oil

Desalter WaterD-3 Recycle Coalescer D-XXX-XXX-1 Crude Tower OverheadD-4 Flare Knockout Drum D-XXX-XXX-14 Flare KnockoutE-1 Reboiler D-XXX-XXX-1 Crude Tower Bottoms

SteamE-2 Overhead Condenser D-XXX-XXX-3 Crude Tower Overhead

Cooling WaterE-3 Reboiler D-XXX-XXX-3 Crude Tower Bottoms

SteamP-1 Feed Pump D-XXX-XXX-12 Crude OilP-2 Lube Oil Pump D-XXX-XXX-15 Lube OilP-3 Distillate Pump D-XXX-XXX-8 DistillateT-1 Fractionator D-XXX-XXX-7 Crude Oil

NaphthaT-2 Vacuum Tower D-XXX-XXX-6 Crude Tower Bottoms

Heavy Gas Oil




• Visit each process unit/area• Bring the waste stream

inventory• Focus first on highlighted

POGs• Ask the following or similar

questions:• Is this piece of equipment

routinely drained?• If so, how often?• How much is drained each

time?• Where is the material drained

to?

Determining the TAB | Process Unit Visits/Operator Interviews

I’m here with the Refinery Environmental Department, compiling a waste stream inventory…



• Ask about other routine streams that you have not already discussed

• Ask about routine sampling procedures

• Ask about leaking equipment

• Ask to inspect waste management units




• Tips for conducting operator interviews• Make an appointment • Try to interview senior

operators• Try to interview multiple

operators• You are compiling a waste

stream inventory, not a TAB• Be prepared to walk the

unit• Bring a hard copy of the

waste stream inventory and P&IDs




Determining the TAB |Process Unit Visits/Operator Interviews

• Waste stream type and dispositionEquipment/


Percent Organic


Benzene Aqueous

(mg/L)


Volume (gallons)

Flow (gpm)

D-1 Feed Drum Maintenance/Turnaround D-XXX-XXX-1 Sewer Controlled Crude OilD-2 Desalter Drum Process D-XXX-XXX-2 D-7 Controlled Crude Oil

Desalter WaterD-3 Recycle Coalescer Process D-XXX-XXX-1 D-4 Controlled Crude Tower OverheadD-4 Flare Knockout Drum Process D-XXX-XXX-14 Sewer Controlled Flare KnockoutE-1 Reboiler Maintenance/Turnaround D-XXX-XXX-1 Frac Tank Uncontrolled Crude Tower Bottoms

SteamE-2 Overhead Condenser Maintenance/Turnaround D-XXX-XXX-3 Frac Tank Uncontrolled Crude Tower Overhead

Cooling WaterE-3 Reboiler Maintenance/Turnaround D-XXX-XXX-3 Frac Tank Uncontrolled Crude Tower Bottoms

SteamP-1 Feed Pump Maintenance/Turnaround D-XXX-XXX-12 Sewer Controlled Crude OilP-2 Lube Oil Pump Maintenance/Turnaround D-XXX-XXX-15 Sewer Controlled Lube OilP-3 Distillate Pump Maintenance/Turnaround D-XXX-XXX-8 Sewer Controlled DistillateT-1 Fractionator Maintenance/Turnaround D-XXX-XXX-7 Frac Tank Uncontrolled Crude Oil

NaphthaT-2 Vacuum Tower Process D-XXX-XXX-6 D-4 Controlled Crude Tower Bottoms

Vac Tower Overhead



• Three methods to determine annual waste quantity• Historical records

• Design capacity

• Measurements

• Must estimate maximum waste generation rates

• Slop oil balance

Determining the TAB |Annual Waste Quantity



Determining the TAB | Annual Waste Quantity

• Historical records – example• Records show that the maximum water charge rates to the Desalter

were as follows:• 2012 – 87 gpm

• 2013 – 85 gpm

• 2014 – 90 gpm

• 2015 – 107 gpm

• 2016 – 103 gpm

• 2017 – 110 gpm

• The flow rate for the desalter effluent waste stream would be 110 gpm



• Design capacity – example

• Process unit sends process wastewater to a local separator

• The maximum design throughput capacity of the separator is 100 gpm

• The sum of the waste quantity for streams routed to the separator must equal 100 gpm




• Measurements –example (common)• Operator: drum is drained

three times per day

• Operator: maximum amount drained each time is 10 barrels

• (3X/day)(10 bbls)(1 day/24 hrs)(1 hrs/60 min)(42 gal/bbls) = 0.875 gpm





• Annual waste quantity for one-time or unique events• Maintenance/turnaround

• Laboratory waste

• Spills

• In general, use volume per year




• Applying the dataEquipment/


Percent Organic


Benzene Aqueous

(mg/L)


Volume (gallons)

Flow (gpm)

D-1 Feed Drum Maintenance/Turnaround D-XXX-XXX-1 Sewer Controlled Crude Oil 5600 NAD-2 Desalter Drum Process D-XXX-XXX-2 D-7 Controlled Crude Oil 8100 110.00

Desalter WaterD-3 Recycle Coalescer Process D-XXX-XXX-1 D-4 Controlled Crude Tower Overhead 500 0.05D-4 Flare Knockout Drum Process D-XXX-XXX-14 Sewer Controlled Flare Knockout 1250 0.25E-1 Reboiler Maintenance/Turnaround D-XXX-XXX-1 Frac Tank Uncontrolled Crude Tower Bottoms 4000 NA

SteamE-2 Overhead Condenser Maintenance/Turnaround D-XXX-XXX-3 Frac Tank Uncontrolled Crude Tower Overhead 2000 NA

Cooling WaterE-3 Reboiler Maintenance/Turnaround D-XXX-XXX-3 Frac Tank Uncontrolled Crude Tower Bottoms 5500 NA

SteamP-1 Feed Pump Maintenance/Turnaround D-XXX-XXX-12 Sewer Controlled Crude Oil 100 NAP-2 Lube Oil Pump Maintenance/Turnaround D-XXX-XXX-15 Sewer Controlled Lube Oil 5 NAP-3 Distillate Pump Maintenance/Turnaround D-XXX-XXX-8 Sewer Controlled Distillate 25 NAT-1 Fractionator Maintenance/Turnaround D-XXX-XXX-7 Frac Tank Uncontrolled Crude Oil 12000 NA

NaphthaT-2 Vacuum Tower Process D-XXX-XXX-6 D-4 Controlled Crude Tower Bottoms 20000 5.00

Vac Tower Overhead



Determining the TAB |Benzene Concentration

• Fraction by weight of benzene in waste

• Flow-weighted annual average

• Determined at the Point of Generation

• Exceptions:• Sour water streams

• Coke by-product plants

• Waste received from off-site




• Multi-Phase waste streams• Determine the make up of the waste stream

• Weighted-average benzene concentration

• Specific gravity/density of organic phase




• Multi-Phase waste streamsEquipment/


Percent Organic


Benzene Aqueous

(mg/L)


Volume (gallons)

Flow (gpm)

D-1 Feed Drum Maintenance/Turnaround D-XXX-XXX-1 Sewer Controlled Crude Oil 98.00 2.00 51.79 5600 NAD-2 Desalter Drum Process D-XXX-XXX-2 D-7 Controlled Crude Oil 99.95 0.05 51.79 8100 110.00

Desalter WaterD-3 Recycle Coalescer Process D-XXX-XXX-1 D-4 Controlled Crude Tower Overhead 95.00 5.00 43.12 500 0.05D-4 Flare Knockout Drum Process D-XXX-XXX-14 Sewer Controlled Flare Knockout 50.00 50.00 51.92 1250 0.25E-1 Reboiler Maintenance/Turnaround D-XXX-XXX-1 Frac Tank Uncontrolled Crude Tower Bottoms 0.00 100.00 59.72 4000 NA

SteamE-2 Overhead Condenser Maintenance/Turnaround D-XXX-XXX-3 Frac Tank Uncontrolled Crude Tower Overhead 95.00 5.00 43.12 2000 NA

Cooling WaterE-3 Reboiler Maintenance/Turnaround D-XXX-XXX-3 Frac Tank Uncontrolled Crude Tower Bottoms 0.00 100.00 59.72 5500 NA

SteamP-1 Feed Pump Maintenance/Turnaround D-XXX-XXX-12 Sewer Controlled Crude Oil 0.00 100.00 51.79 100 NAP-2 Lube Oil Pump Maintenance/Turnaround D-XXX-XXX-15 Sewer Controlled Lube Oil 0.00 100.00 49.11 5 NAP-3 Distillate Pump Maintenance/Turnaround D-XXX-XXX-8 Sewer Controlled Distillate 0.00 100.00 55.29 25 NAT-1 Fractionator Maintenance/Turnaround D-XXX-XXX-7 Frac Tank Uncontrolled Crude Oil 0.00 100.00 51.79 12000 NA

Naphtha 0.00 100.00 46.18T-2 Vacuum Tower Process D-XXX-XXX-6 D-4 Controlled Crude Tower Bottoms 0.00 100.00 59.72 20000 5.00

Vac Tower Overhead 0.00 100.00 51.79


Determining the TAB | Benzene Concentration

Knowledge of waste:

• Material balances

• Purchase records

• Previous test results

Sampling:• Modified Method 25D

• Minimize exposure to atmosphere

• Average of three representative samples

• Acceptable analytical methods: 8020, 8021, 8240, 8260, 602, 624• Recommend building a sample data base for your facility

• Concentrate on those streams that affect your compliance status




Equipment/ POG ID Description Waste Stream Type Drawing Number Disposition Controlled Contents Percent

AqueousPercent Organic


Benzene Aqueous

(mg/L)


Volume (gallons)

Flow (gpm)

D-1 Feed Drum Maintenance/Turnaround D-XXX-XXX-1 Sewer Controlled Crude Oil 98.00 2.00 51.79 27.60 3810.37 5600 NAD-2 Desalter Drum Process D-XXX-XXX-2 D-7 Controlled Crude Oil 99.95 0.05 51.79 27.60 3810.37 8100 110.00

Desalter WaterD-3 Recycle Coalescer Process D-XXX-XXX-1 D-4 Controlled Crude Tower Overhead 95.00 5.00 43.12 49.27 17000.00 500 0.05D-4 Flare Knockout Drum Process D-XXX-XXX-14 Sewer Controlled Flare Knockout 50.00 50.00 51.92 37.77 3540.00 1250 0.25E-1 Reboiler Maintenance/Turnaround D-XXX-XXX-1 Frac Tank Uncontrolled Crude Tower Bottoms 0.00 100.00 59.72 NA 0.19 4000 NA

SteamE-2 Overhead Condenser Maintenance/Turnaround D-XXX-XXX-3 Frac Tank Uncontrolled Crude Tower Overhead 95.00 5.00 43.12 49.27 17000.00 2000 NA

Cooling WaterE-3 Reboiler Maintenance/Turnaround D-XXX-XXX-3 Frac Tank Uncontrolled Crude Tower Bottoms 0.00 100.00 59.72 NA 0.19 5500 NA

SteamP-1 Feed Pump Maintenance/Turnaround D-XXX-XXX-12 Sewer Controlled Crude Oil 0.00 100.00 51.79 NA 3810.37 100 NAP-2 Lube Oil Pump Maintenance/Turnaround D-XXX-XXX-15 Sewer Controlled Lube Oil 0.00 100.00 49.11 NA 2.43 5 NAP-3 Distillate Pump Maintenance/Turnaround D-XXX-XXX-8 Sewer Controlled Distillate 0.00 100.00 55.29 NA 84.67 25 NAT-1 Fractionator Maintenance/Turnaround D-XXX-XXX-7 Frac Tank Uncontrolled Crude Oil 0.00 100.00 51.79 NA 3810.37 12000 NA

Naphtha 0.00 100.00 46.18 5406.67T-2 Vacuum Tower Process D-XXX-XXX-6 D-4 Controlled Crude Tower Bottoms 0.00 100.00 59.72 NA 0.19 20000 5.00

Vac Tower Overhead 0.00 100.00 51.79 NA 580.00



• Organization

• Use of inventory

• Calculations

Determining the TAB |Building the TAB Report



Determining the TAB | Building the TAB Report (See “Handouts” Section of Manual)

• Calculations• Annual average benzene content

• TAB and BQ

Lft

lbskg

ftlbsDensityHCHC

ftlbsOH

HCGravSpkgmgBzHCHC

LmgOBzHOH

.

. % .%

. . % %

32281

204621

100462

100

1001003

332

22

lbs . .

,,, . . %

,,, . %

204621348

00000000011

100

000000000117853

10022

kggallon

lbsmg

MgHCGravSpyeargallonsFlow

kgmgBzHCHC

mgMg

gallonL

yeargallonsFlow

LmgOBzHOH




• Trihydro’s report• Overall summary table

• Process unit process waste streams

• Source areas

• Maintenance and turnaround




• Trihydro’s report – overall summary table example




• Trihydro’s report – process unit process waste streams example




• Trihydro’s report – source area example




• Trihydro’s report – maintenance/turnaround example



Recordkeeping & Reporting



• Why is this so important ?

• This is how you demonstrate compliance

• Records provide backup when you face inspectors

• Reports are your primary way of communicating to EPA

• Consolidate all of your BWON records in one place

Recordkeeping



Control Device Recordkeeping

• For each CVS and Control Device, facilities are required to demonstrate compliance of the control device through one of the following methods:

• Engineering calculations

• Performance test

• All control devices must have a statement signed and dated by the owner or operator certifying that the CVS and control device is designed to operate at the documented performance level when the WMU is vented to the control device at the highest load expected to occur.

• If engineering calculations are used to determine control device performance, facilities are required to maintain design documentation

• Device specific specifications, drawings, schematics, and piping and instrumentation (P&ID) drawings



• For a carbon adsorption system that does not regenerate the carbon bed directly on-site in the control device, such as a carbon canister:

• Vent stream composition

• Constituent concentration

• Flow rate

• Relative humidity

• Temperature

• Design exhaust vent stream organic compound concentration

Design Documentation – Carbon Canisters

level or the design exhaust vent stream benzene concentration level

• Capacity of carbon bed

• Type and working capacity of activated carbon used for carbon bed

• Design carbon replacement interval



Recordkeeping Requirements

• Control Device/Treatment System Operating Records • Dates of startup and shutdown

• Description of operating parameters monitored

• Monitoring data that indicates deviations from normal operating conditions

• Period when unit is not operating as designed

• Control device bypass records



• BWON Annual TAB Report• Typically submitted by April 7th of

the previous calendar year

• TAB waste stream information and estimate

• 6BQ or 2 Mg uncontrolled /exempt waste stream list and benzene quantity estimate

• Report that summarizes all inspection and monitoring facilities and the corrective actions taken

Reporting Requirements



BWON Quarterly Reports

• BWON Quarterly Reports • Typically submitted on a calendar quarter basis within 30 days of the

end of the quarter • Certify that all inspection and monitoring has been completed • Report any periods when control device/treatment device monitoring

data was out of the regulatory range• Flare pilot outages, EBU inlet sampling, benzene stripper outlet

sampling • Report seal gas measurement on floating roof oil-water separators

that were out of range • Floating roof tank seal gas measurement (NSPS Kb) that are outside

regulatory limits



Consent Decrees

• A consent decree (CD) is the result of a settlement between the government (EPA) and a specific company and may include one or more facilities owned by that company

• A CD is logged as a result of perceived or actual compliance issues found during EPA audits; used in lieu of an enforcement action, the company has to improve operations and prevent future violations of environmental laws at their facilities

• CDs are often called “global settlements” since they include many facilities owned by a company and multiple regulatory programs



BWON Provisions of Consent Decrees

• Earlier in the 2000s, a refinery enforcement initiative began to address marquis regulatory programs, including BWON

• A total of > 40 refiners are now under settlement, covering 90+ % of the US refining capacity; the remaining “small refiners” are being pursued on a local effort by state and EPA regions

• Each refinery consent decree can be found on the following website: http://www.epa.gov/compliance/resources/cases/civil/caa/oil/index/html



Typical BWON Enhancement Provisions

• TAB Review and Verification (R&V)• Audit of waste stream inventory and compliance

• Controls evaluation

• TAB update required if previous TAB was determined to be incorrect

• BWON Corrective Action Plan for problems found during R&V

• Standard Operating Procedures Development for BWON Control Equipment

• Upgrade Emissions Controls (Dual Carbon Canister Systems)

• Slop Oil/Wastewater Flow Diagrams Development



• End-of-Line Sampling Plans and Sampling

• BWON Sampling Training for Employees and Contractors Performing BWON Sampling

• Training for Employees and Contractors Operating BWON Control Equipment

• Stipulated Penalties for Future Non-Compliance

• Increased Monitoring, Inspections and Reporting Requirements

Typical BWON Enhancement Provisions (con’t)



Consent Decree Sampling Enhancements

• End-of-Line (EOL) Sampling Plans • The purpose of the EOL Plan is to quantify the uncontrolled benzene

waste quantity through identification of EOL sampling points, sampling and flow measurement

• Is unique to each refinery based on wastewater collection and treatment system

• A schematic must be prepared that depicts the waste management units that handle, store, and transfer wastes

• Routine Uncontrolled POG Sampling • May include monthly or quarterly sampling of certain POGs • Typically all uncontrolled POGs that contribute an annual quantity of

benzene above a certain threshold level (i.e., > 0.05 Mg/yr)



EOL Sampling and Benzene Quantity Determination

• Monthly sampling of each EOL location used along with flow estimates to generate uncontrolled benzene quantity

• Includes “classic” EOL locations plus uncontrolled non-routine wastes generated such as maintenance, spills, and wastes shipped offsite

• If quarterly EOL indicates greater than quarterly or annual benzene quantity limits, an explanation and/or corrective action plan must be prepared



What is an EOL Point?

• Typically located at or near the front end of the wastewater treatment plant (i.e., inlet to API separator and skim oil from separator)

• May also be at manhole, sumps, or lift stations located downstream of or within process units • Uncontrolled IDS with > 10 % water that is directly recycled (to Crude

Tank, etc.) • Uncontrolled IDS that pumps into a controlled system

• Wastewater surge tanks can also serve as the centralized location for EOL accounting



EOL Sampling Plan



BWON Lessons Learned/Best Practices



BWON Lessons Learned/Best Practices

• BWON Rules of Thumb• Compliance Review• Common Audit Findings• Commonly Missed Waste Streams• Integral to the Process• Adjacent Facilities• Maintenance Waste• Annual Review/Management of Change• Spills• Recent EPA Enforcement



• Refineries > 70,000 bbls should have TAB > 10 Mg/year

• Desalter effluent water flow should be 3 to 6% of crude flow rate

• Slop oil recovery rate is frequently 0.1% of crude flow rate

• Roughly the same amount of benzene (Mg) found in the oil and water phases at the API separator

• Benzene concentration in water phase should be roughly 1% of the oil phase concentration

BWON Rules of Thumb



Compliance Review

• Initial review required by consent decrees (with subsequent annual reviews)

• Initial review is larger than many think it is going to be - compliance issues are common• Detailed audit

• Independent viewpoints

• Field verification

• Collect adequate sampling data

• Getting it right avoids future headaches and penalties• Annual review can be used to update TAB report• Many plants perform an additional detailed compliance review every

2-3 years



Compliance Review –What to Include for All Facilities

• Waste Streams -• Include aqueous and non-aqueous

• Process wastes, maintenance and turnaround wastes, spills, etc.

• Include what is drained to sewer system, unit oil/water separators or slop oil system

• Methods for flow rate determination

• Benzene analyses and estimation techniques

• Phase percentages

• Ancillary facilities• Terminals, loading facilities, remediation systems, etc.

• Laboratory operations

• Potential Applicability• Flare System

• Slop Oil System

• Sour Water System



Compliance Review –What to Include for Facilities >10 Mg

• Controls –• From each POG to wastewater treatment plant or other WMU

• Within wastewater treatment plant (to bio unit)

• Process and storm water sewer systems

• Remediation systems

• Compliance Programs -• Inspection programs

• Container management

• Solid and hazardous waste management

• BWON reporting



Examples of Controlled WMUs

• Above ground piping that is visually inspected quarterly

• Tanks inspected under Kb

• Closed drain systems (p-traps or other water seal/cap)

• Frac tanks that are sealed or equipped with carbon canisters

• Vacuum trucks inspected visually each quarter and with NDE monitoring annually

• 55 gal DOT drums that are visually inspected quarterly



• Uncovered sump or catch basin

• Drain system without p-trap controls

• Fixed-roof tank not vented to carbon canisters or flare system

• Frac tank used for treating wastes without a carbon canister system

Examples of Uncontrolled WMUs



Common Audit Findings

• Missing waste streams• Waste streams not quantified at the POG• <10 Mg facilities found to be >10 Mg• Uncontrolled quantities exceeding 2 Mg or 6 Mg• Outdated estimates of flow rates, phase percentages, or

benzene concentrations• Applicable WMUs not included in inspection programs• Expected controls not in place • Out of date inspection lists• Missed inspections and repairs



Commonly Missed Waste Streams –Process/Routine Wastes

• Desalter effluent, mudwashing, upsets, bypasses

• Spent caustic and tank oil skims

• Sour water tanks oil skim

• Sampling purges

• Loading area drainings

• Laboratory sample wastes

• Retain sample wastes

• Knock engine lab wastes



• Salt filter discharge and recharge wastes

• Compressor suction drains, discharge bottles, and knockout drums

• Compressor lube oil• Reformer hydrogen

compressor knockouts• Tank water draws• Slop oil• Blowdown system wastes• Fuel gas knockout drums





• Coker quench water reject

• FCCU scrubber water drain

• Steam drum condensate

• Condensate return oil skims

• Reformer water washes and regen wastes

• Sour water stripper blowdown

• Dilution steam blowdown

• Alternate waste stream lineups (from controlled system to uncontrolled)



Commonly Missed Waste Streams –Maintenance and Turnaround

• Flare header low point drains

• Pump screen cleanouts

• Filter change outs

• Truck rack, terminal, and pipeline meter proving wastes

• Truck heel drains from loading racks and terminals



Commonly Missed Waste Streams –Maintenance and Turnaround

• Pump water draw off for freeze protection

• Pump barrier fluid change outs

• Instrument leg drains (sight glasses, level indicators)

• Chemical hose drainings

• Thermal liquid reliefs



Integral to the Process

• Waste management unit vs. process unit• Stream meets definition of waste

• WMU not integral to the process

• Preambles• Offer some guidance for determination

• Integral to the process is made on a case-by-case basis

• Examples of what EPA considers “integral to the process”




• Preamble example• Desalter case

• Desalter effluent contains high quantity of oil

• The oil recovery from the oily water effluent is an essential part of the production operation

• Desalter vessel is integral to the process

• Oily water is not a waste until it exits the process after further oil water separation



Integral to the Process: Monochlorobenzene




• Other examples• Vacuum tower overhead water is routed to desalter as “clean”

desalter water for use in the desalting process

• Where is the POG? Is there a POG?

• Integral to the process?



Adjacent Facilities

• FAQs clarify adjacent and contiguous• Located on contiguous property

• Commonly owned or operated by a petroleum refinery, chemical plant, or coke byproduct plant

• Onsite terminal waste would not be excluded from treatment under the benzene waste standard



Maintenance Waste

• Use facility’s equipment list for the TAB report• Estimate waste quantity from

• Exchangers• Pumps• Towers

• Develop maintenance and turnaround procedures• Involve environmental staff in turnaround planning• Track and control maintenance wastes

Proper job planning and knowledge of the benzene content of the materials you work with are essential in limiting benzene

wastes to the sewers



Annual Review/MOC

• Standard MOC process is not enough• Add BWON items to MOC checklist and develop “BWON MOC”

process

• New connections to flare, sewer, slop oil

• New drains

• Operational changes (e.g., draining of water boots, frequency of tank water draws)

• Include in annual TAB update

• Utilize internal audit processes when possible



Spills

• Controlled or uncontrolled?

• Estimation methods

• Tracking system

• Include in TAB report (Consent Decree driven)

• Organic and aqueous



• EPA has started to use “Next Generation” approaches during NESHAP inspections

• EPA’s focus on field inspections of refinery waste management units

• EPA is using FLIR technology to identify VOC leaks from waste management units and wastewater treatment facilities, followed by Method 21 monitoring

Inspection Programs – Recent EPA Enforcement



Inspection Programs – Recent EPA Enforcement

• Failure to design and operate an IDS with no detectable emissions

• Failure to define and operate tank roof covers and all openings with no detectable emissions

• Failure to design and operate oil-water separator with no detectable emissions

• Failure to seal all openings in the wastewater treatment system

• Failure to maintain gaskets on bleeder vents

• Failure to monitor seams on DNF covers

AND

• Failure to meet 6 Mg or 2 Mg compliance



Cal Niss

Senior Vice [email protected]

(307) 745-7474

Erin Novini, P.E.

Project [email protected]

(714) 399-1561

Presenters


Documents

201803 BWON Workshop Manual