Refinery and Tanks at Sunset



Benzene Waste Operations NESHAPS (BWON), 40 CFR Part 61 Subpart FF and Standards of Performance for VOC Emissions from Petroleum Refinery Wastewater Systems (NSPS QQQ), 40 CFR Part 60 Subpart QQQ have been highly enforced regulations for the past two decades. Even following multiple attempts to clarify aspects of the rules, regulated facilities continue to question how to apply them.

Sage ATC helps our clients

After years of focus and growth in the BWON and NSPS QQQ fields, Sage ATC’s expertise and experience is highly recognized and respected by both the industry and government regulators. We have assisted more than 130 facilities with their BWON and NSPS QQQ programs. With such broad benchmarking experience, we understand how to mitigate BWON risk and facilitate sustainable compliance.

Refinery Tanks

Ruth Benning (512) 258-8500



We employ the latest technologies to ensure that our clients build on a strong foundation. One of our most powerful tools is the Microsoft Excel spreadsheet known as the Benzene Waste Operations NESHAP Documentation and Compliance Tool, or BWON-DACT©. The BWON-DACT is designed to contain reference information and the benzene quantity calculation and documentation for each applicable waste stream. Each waste stream documented will also include a description of the equipment where the wastes are generated and the destination of each waste stream, the P&ID drawing number showing the location of the POG for each benzene-containing waste stream, potential alternative lineups for process streams that may represent POGs, and other information.

The BWON-DACT allows for quick and easy reference to the P&ID drawing showing the POG, as well as other non-POG points of interest identified within the facility, including sour water streams, in-process recycle streams, double counts, and excluded wastes. The BWON-DACT allows for easy access and review of other miscellaneous benzene waste sources such as maintenance wastes, vacuum truck movement wastes, turnaround wastes, laboratory sampling wastes, loading wastes and others.

The ultimate value of the BWON-DACT workbook to our clients is that it can be used to not only demonstrate BWON and Consent Decree compliance, but can also be used for HON compliance, 30 TAC 115(b) wastewater compliance, on-going annual TAB determinations, and program management.

Full Lifecycle Support:

We are there for our clients each step of the way – from preliminary site evaluation to ongoing compliance program maintenance. Whether our clients are concerned with BWON implications as their TAB reaches 10 Mg/yr, need help with Consent Decree review and implementation, compliance plan development, 3rd party audit assistance, NSPS QQQ applicability analyses, or general regulatory interpretation advice, we are there for our clients.

Sage’s offerings include:


  • Annual/Quarterly BWON Reporting and Semiannual NSPS Reporting
  • BWON TAB and Uncontrolled Benzene Quantity (2BQ/6BQ) Development and Assessment
  • NSPS QQQ Applicability Determinations
  • Controls Evaluation
  • Compliance Auditing
  • Waste Management Unit Identification, Inspection, and Monitoring
  • Organic, Aqueous, Solid and Gaseous-Phase Sampling


  • Management System/Compliance Program Development
  • Carbon Canister Design Documentation
  • Enforcement Negotiations and Litigation Support
  • Standard Operating Procedure Development
  • Best Practices


  • Review and Verification
  • BWON Third-Party Review Process
  • BWON TAB Updates
  • BWON End-of-Line and POG Plan Development and Implementation
  • BWON Laboratory Audits
  • Controls Strategy and Treatment Process Design


  • BWON Essentials
  • BWON Advanced
  • BWON for Experts
  • BWON for Managers
  • BWON Operator Training
  • BWON Sampling Training
  • NSPS QQQ Essentials
  • Plant-Level BWON/QQQ Awareness Training