BWON Compliance: Common Pitfalls
& Course Offering

Dear Environmental Compliance Professional,

We've identified several critical pitfalls in Benzene Waste Operations NESHAP (BWON) compliance that could put your facility at risk. Our recent inspections have revealed these common issues that often go undetected until an audit:

1

Vapor Control

System Failures

  • •Failure to route all organic vapors to control devices
  • •Pressure exceeding setpoints of pressure relief devices
  • •Carbon canisters not breaking through as expected
  • •Dry or venting loop seals creating illusion of control
2

Waste Management

Unit Infrastructure Decay

  • •Warped covers, cracked sealant, missing bolts
  • •Uneven forebay surfaces causing seal gaps
  • •Unsealed panel seams and joints
  • •Dry water seals and open manhole vents
3

Monitoring &

Reporting Issues

  • •No systematic review of new/changed streams
  • •Improper accounting downstream of POG
  • •Method 21 tests under suboptimal conditions
  • •Failure to inspect all required components
  • •Incomplete or absent design documentation

These issues can lead to serious compliance violations, with incomplete vapor routing potentially requiring all associated waste streams to be reported under 6 BQ or 2 BQ reports. Tank failures, inadequate monitoring practices, and institutional knowledge gaps further compound these risks.

EPA BWON Audits Key Finding, Pitfalls and Preventing Strategies Course

Take a deep dive into the most common issues identified during EPA BWON audits. This course highlights real-world compliance gaps, recurring mistakes, and industry-wide patterns. Gain practical insight into how these findings occur—and what you can do to protect your facility from costly violations and EPA settlements.

Engineer performing equipment assessment at industrial facility

Take Action Today:

  • • Schedule an inspection of your facility
  • • Enroll in our EPA Audit Key Findings, Pitfalls and Preventing Strategies course
  • • Review your current monitoring and reporting practices
  • • Schedule a 30-min free consultation with a BWON Expert
Enroll in Course Schedule an Inspection Free Consultation

Don't wait for an audit to discover these issues. Proactive compliance management saves time, money, and protects your facility's reputation. Contact us today to learn more about upcoming courses.

Regards,
BWON Solutions Compliance Team

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