Trinity welcomes you to 2026! In industry, the new year is not just about fresh starts; it also marks the start of a new reporting year and the need to stay ahead of critical regulatory deadlines.
For chemical plants; refineries; treatment, storage, and disposal facilities (TSDFs); and coke plants, the Benzene Waste Operations NESHAP (BWON) total annual benzene (TAB) report is due April 7. The clock is ticking towards this deadline. If your facility has been previously exempt from BWON TAB reporting, the new year is a good opportunity to dust off the TAB calculation spreadsheet and verify your facility’s exemption status. With heightened United States Environmental Protection Agency (U.S. EPA) enforcement, proactive compliance is not just smart, it is essential.
Why BWON Compliance Matters
The BWON requirements were promulgated in 1990 and are codified under 40 CFR 61 Subpart FF. Post promulgation, facilities subject to BWON were required to quantify the TAB and submit an initial report to the U.S. EPA by April 7, 1993. For new sources that commenced operation after the effective date, TAB quantifications must be submitted by the initial startup. This initial reporting requirement affects all chemical manufacturing plants, coke by-product recovery plants, and petroleum refineries–even those with no benzene onsite in wastes, products, by-products, or intermediates.
Following the initial reporting requirement, a facility is subject to one of the following subsequent reporting requirements based on the TAB quantification:
- TAB < 1 Mg/yr – maintain the TAB based on current operations;
- 1 Mg/yr ≤ TAB < 10 Mg/yr – submit annual reports to U.S. EPA; and,
- TAB ≥ 10 Mg/yr – submit annual and quarterly reporting, comply with control requirements (i.e. treat or destroy benzene, utilize controlled waste management units, etc.).
The TAB quantification is a powerful tool in determining whether a facility is subject to the BWON control provisions and is not only important for reporting requirements. It can also alert the facility to other important information, such as:
- What are the main contributors to my facility’s total benzene loading in BWON wastes?
- Where are those key contributors located across the facility?
- Which units or areas are insignificant contributors to overall benzene loading?
Does TAB Reporting Apply to Facilities < 1 Mg/yr Benzene?
It sure can! Many facilities take a “one and done” approach to TAB reporting–meaning if the TAB quantification was determined to be less than 1 Mg/yr of benzene, an initial report was submitted on the effective date, and little was done after that. This means that for some facilities, it might have been over 30 years since their TAB quantification was evaluated.
Not only should facilities review their BWON program and TAB quantification after process changes, but maintaining compliance with BWON requirements will spare facilities from enforcement scrutiny. Ongoing compliance with Subpart FF entails assessing several areas of your site’s process and a clear understanding of the different variables that influence your facility’s TAB calculations is essential to ensuring your overall compliance with BWON.
As the annual TAB reporting deadline quickly approaches, consider asking yourself some of these basic questions:
- When was the last time your process, turn-around schedule, or the source of your raw materials changed?
- Have there been any process equipment changes, such as replacements, additions, or removals?
- How are maintenance activities documented, and are those records complete and accurate?
- Does your site’s Management of Change (MOC) review evaluate potential impacts to the TAB calculations?
- When was the last time a BWON walkthrough was performed to verify that the TAB accounts for all of the facility’s benzene waste?
- When was the last time that your site completed a comprehensive BWON program review?
Why Act Now?
The U.S. EPA’s renewed focus on BWON enforcement means facilities that delay or rely on outdated assumptions and TAB quantifications may face increased scrutiny, penalties, and enforcement measures. Staying ahead of regulatory requirements protects your facility and positions you for compliance excellence.
If you are unsure about your facility’s BWON program or TAB calculations, do not wait until the annual deadline arrives. Now is the ideal time to re-evaluate your site’s BWON program. A proactive approach helps ensure compliance, reduces regulatory risk, and positions your site for improved operational efficiency.
Trinity’s chemical sector BWON compliance experts can help you:
- Verify and update your TAB calculations;
- Streamline reporting processes;
- Identify opportunities to reduce benzene waste; and
- Improve overall compliance strategy
Stay ahead of the April 7 deadline. Contact Trinity today to schedule your BWON review and turn regulatory compliance into a competitive advantage.
Trinity Consultants Chemical Sector Services (CSS) group assists industrial facilities nationwide with submittal of initial, quarterly, and annual BWON reports and utilizes our expertise to provide assessments of facilities’ existing TAB calculations. These assessments include a review of waste stream classifications, identification of points of waste generation, assistance and creation of wastewater sampling programs, and an evaluation of the overall accuracy of the TAB calculation.
Trinity’s CSS group supports a full range of compliance, permitting, and strategic planning needs. Whether your facility is navigating current requirements or preparing for future changes, Trinity can provide expert support every step of the way. For more information, please contact Inaas Darrat.
