BWON Solutions: Expert Compliance & Risk Management
Your trusted partner for navigating complex Benzene Waste Operations NESHAP challenges.
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About Us
For over two decades, BWON Solutions engineers have been at the forefront of Benzene Waste Operations NESHAP (BWON) compliance for refineries and chemical plants across the nation. Our team combines deep regulatory knowledge with practical field experience to deliver comprehensive compliance solutions.
Our specialists have helped facilities avoid more than $100 million in potential EPA penalties through strategic compliance planning and implementation. We take pride in our ability to transform complex regulatory challenges into manageable, cost-effective solutions.
Expert Team
Engineers, EPA negotiation specialists, LDAR technicians, and OGI specialists with decades of industry experience.
Proven Results
Track record of helping facilities navigate complex regulations and avoid significant penalties through effective compliance programs.
The BWON Rule Explained
The Benzene Waste Operations NESHAP (BWON) regulation (40 CFR 61 Subpart FF) has governed wastewater benzene emissions since 1993, with significantly strengthened enforcement campaigns in 2023-2025. This EPA regulation specifically targets waste streams from petroleum refineries and chemical manufacturing facilities.
No Detectable Emissions (NDE) Requirements
Regulated controlled benzene waste streams must use equipment designed for no detectable emissions, verified through Method 21 readings of ≤500 ppm and tested annually.
Enhanced Enforcement
Recent enforcement includes optical gas imaging (OGI) for leak detection, resulting in high-profile fines and consent decrees with penalties up to $40M and required capital projects reaching $250M.
Waste Management Units
Regulated equipment includes oily water separators, tanks, individual drain systems, containers, control devices, and vent systems – all requiring rigorous documentation and testing.
BWON Resources
Essential Reference Materials
Access critical regulatory information, technical guidelines, and compliance tools to strengthen your BWON program. Our curated resource collection provides the latest updates on enforcement trends and best practices.
Stay informed with real-time compliance data through the EPA Applicability Determination Index and access comprehensive technical guides for audit preparation.
Resources
  • EPA BWON FAQ
  • Applicability Determination Index (ADI)

cfpub.epa.gov

Applicability Determination Index (ADI)

Overview of compliance monitoring activities under the Clean Air Act.

  • BWON Federal Registers
  • BWON Pitfalls
  • Comprehensive Audit Checklists
Services: BWON Auditing
Third-Party Compliance Evaluations
Our independent audits provide unbiased assessment of your BWON program under consent decree or audit privilege protections. We identify compliance gaps before regulators do.
Comprehensive Program Reviews
Full compliance program evaluation including gap analysis and BWON/QQQ cross-checks to ensure all regulated waste streams are properly managed and documented.
Inspection Preparation
Structured preparation for EPA inspections, including evidence gathering, records management, and response protocols to minimize risk exposure during regulatory visits.
Our audit teams deliver actionable remediation plans with clear priorities and implementation timelines.
Services: Data analysis and performance improvement.
Assess your BWON Program through detailed data evaluation.
1
Key Performance Indicators
  • Total Annual Benzene
  • Compliance Option
  • End-of-Line
  • Deficiencies by WMU
2
Repetitive Leak Evaluation
Identify chronic leak sources and take control.
We analyze your monitoring data to pinpoint high-risk components, recurring issues, and systemic problems.
3
Carbon Canister Evaluation
A targeted review of historical breakthrough data vs. design documentation can uncover bypass events, outdated assumptions, or shifts in waste stream characteristics.
Services: TAB Revalidation & Technical Documentation
Accurate Total Annual Benzene (TAB) calculations and comprehensive technical documentation form the foundation of BWON compliance. Our technical specialists develop and revalidate TAB and Compliance Reports (2 BQ or 6 BQ) that meet the exacting standards of EPA requirements. From Piping and Instrumentation Highlighting to interviews with process engineers and operators to field walk-throughs BWON solutions aims to find current waste streams.
We create complete documentation packages including waste management unit lists, Waste Management Schematics, Slop and Wastewater balances to ensure your facility has the technical evidence needed to demonstrate compliance during regulatory inspections.
TAB Report Development
Comprehensive benzene waste streams characterization and quantification.
NDE Documentation
Non-Detectable Emissions engineering assessments and compliance verification.
End-of-Line Calculations
EOL Development and Calculations tailored to your facility designed to validate the 2 or 6 Mg/yr uncontrolled quantity compliance option.
Services: EPA Negotiation, Regulatory Readiness, and Training
EPA Negotiation Support
Expert representation during EPA/DOJ interactions, including findings response, consent decree negotiations, and penalty mitigation strategies.
Regulatory Readiness
Comprehensive preparation through scenario testing, mock inspections, and response protocol development to ensure you're prepared for regulatory scrutiny.
Staff Training
Customized training programs for operators, subject matter experts, and management covering both BWON essentials and advanced compliance techniques.
Our training programs combine theoretical knowledge with practical application, ensuring your team understands not just what to do, but why it matters. From foundational BWON-QQQ Essentials to advanced technical workshops, we build the competency your facility needs for sustainable compliance.
BWON Solutions Training
Comprehensive training modules for Benzene Waste Operations NESHAP (BWON) compliance and management
Contact Us
Whether you're facing an EPA enforcement action or seeking to strengthen your ongoing compliance program, our team is ready to help. BWON Solutions provides short and long-term strategic support tailored to your facility's specific needs.
512-897-9932
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Have questions about BWON compliance, inspections, or program setup?
Schedule a free 30-minute call with one of our experienced BWON specialists to discuss your facility’s needs and how we can help you achieve regulatory compliance.
BWON Solutions: Your trusted partner for navigating complex regulatory challenges with confidence.