As many in the industry are aware, the EPA announced last year that they were initiating focused enforcement on their Benzene NESHAP found in 40 CFR Part 61 S Subpart FF, and the companion regulation found in 40 CFR Part 60 Subpart QQQ, with a particular emphasis on ethylene production facilities, and petroleum refineries.  They have since visited a number of sites in Louisiana and Texas for multiday audits with team members from various EPA Regions and the NEIC. CK has a deep and broad bench for providing BWON assistance to our clients.

‍Our expertise ranges from the longtime BWON rule owner and corporate auditor at a large Baton Rouge Petrochemical Complex to other very experienced former site environmental professionals that set up and managed the BWON programs at their sites from New Orleans to Lake Charles.  We team these experienced Subject Matter Experts (SME’s) with younger staff who have participated in BWON projects and audits for a number of clients under their mentorship and are comfortable managing and analyzing large amounts of data, reviewing and marking up P&ID’s, and mining information out of plant data acquisition systems.

No matter what the need, CK is ready to assist at any point, whether before EPA visits, as we’ve done for virtually 100% of the ethylene crackers in Louisiana (and many in Texas), or working with counsel to develop rebuttals and defenses to EPA findings if the visit has already occurred.  CK has had a long relationship with most of these sites over the past 40+ years, in fact, we are in the process of preparing the TAB and other compliance reports for many of these sites, while training less experienced company rule owners.  We are ready to assist in any way that we can and are very comfortable working under Attorney-Client Privilege and can provide references from both site personnel and third party counsel that will attest to our capabilities and knowledge of this rule.