The overall objective of the Benzene NESHAP Compliance Improvement (BNCI) project is to meet the consent decree which requires the mass of benzene in an uncontrolled sewer system to be less than 4.8 mega-grams per year (MG/yr) and provide additional protection against spills and upsets within the Petrochemical (P-Chem) Units. The amount of benzene will be measured at the discharge of the API Separators. The refinery currently meets the requirements of the Benzene Waste Organic NESHAP (BWON), 40 CFR 61, Subpart FF, by operating two separate sewer systems. One sewer system is controlled per the BWON requirements, while the other system is uncontrolled. The consent decree applies to the uncontrolled sewer system.
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