BWON and QQQ: EPA’s Enforcement Initiative and What Industry Should be Doing
A RECORDING OF THE WEBINAR IS NOW AVAILABLE. PLEASE COMPLETE FORM BELOW FOR ACCESS.
WHAT’S THE WEBINAR ABOUT? 
U.S. EPA’s recent Enforcement Alert pertaining to 40 CFR Part 61 Subpart FF – National Emission Standard for Benzene Waste Operations (BWON) and 40 CFR Part 60 Subpart QQQ – Standards of Performance for VOC emissions From Petroleum Refinery Wastewater Systems (NSPS QQQ). The webinar will cover:
- Background of the enforcement alert including the latest with consent decrees and inspections.
- What to expect when U.S. EPA (and local agencies) come knocking at your door.
- How to prepare for an inspection and make sure your house is in order.
Learn more about the rule in our article: Enforcement Alert – BWON
WHO SHOULD ATTEND?
Facilities subject to 40 CFR Part 61 Subpart FF – National Emission Standard for Benzene Waste Operations (BWON) and/or 40 CFR Part 60 Subpart QQQ – Standards of Performance for VOC emissions From Petroleum Refinery Wastewater Systems (NSPS QQQ) (e.g., chemical manufacturing plants, coke by-product recovery plants, petroleum refineries, and hazardous waste treatment, storage, and disposal facilities)
WHY ATTEND?
BWON and QQQ are older rules (circa 1980/90s with few updates) with a lot of compliance requirements. U.S. EPA is picking up steam with their training of staff, performing inspections and issuing/negotiating consent decrees. Facilities subject to these rules should expect a visit from U.S. EPA in the future, if they haven’t already been inspected. For those with noncompliance issues identified, consent decree penalties, and requirements are significant. Attend to understand what U.S. EPA is looking for, how to prepare, and what you can do in advance of an inspection.
PRESENTER(s):
Eric Libolt, Washington Office Leader at ALL4
Bob Kuklentz, Directing Consultant at ALL4
Brooklyn Hildebrandt, Managing Associate at Sidley Austin LLP
MODERATOR(s):
Bruce Armbruster, Directing Consultant at ALL4
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