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Peter Zemek 2 min read

How to Stay BWON Compliant


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Peter Zemek

With over 38 years of experience in environmental, industrial, and process engineering, Dr. Peter Zemek is a recognized leader in emerging contaminant technologies, including PFAS detection and carbon capture. A patent-holding scientist and strategic executive, Peter has led global initiatives in air, soil, and groundwater monitoring, developed cutting-edge spectrometry platforms, and spearheaded regulatory innovations. His work spans technical leadership, M&A strategy, and international client engagement, with successful deployments in over a dozen countries. At RJ Lee Group, he drives innovation in VOC testing, litigation support, and advanced analytical services, helping clients navigate complex compliance landscapes with science-backed solutions.


Staying compliant with the EPA's BWON requirements and consent decrees require more than just sampling — it demands insight. BWON is designed to control benzene emissions from waste streams at facilities such as:

  • Petroleum refineries
  • Chemical plants
  • Coke by-product recovery operations
  • Treatment, storage, and disposal facilities (TSDFs)

Facilities must determine whether they are subject to BWON based on the Total Annual Benzene (TAB) content in their waste streams. TAB is the total mass of benzene in all qualifying waste streams generated at a site. Expert sampling, testing, and analysis are critical to staying compliant. 

RJ Lee Group provides real-time root cause analysis using our mobile laboratories equipped with PTR-TOF-MS and AIMS technology. These advanced analytical platforms detect and identify volatile organics, HAPs, and PFAS precursors at ultra-low part-per-trillion levels, allowing refineries and petrochemical facilities to rapidly pinpoint emission sources and maintain compliance with BWON (Benzene Waste Operations NESHAP) regulations and related Consent Decrees.

Facilities must identify and characterize all benzene-containing waste streams. This includes:

  • Process wastewater
  • Slop oil
  • Spent caustics
  • Sludge
  • Lab wastes
  • Unit washdown materials

The variety of materials that must be tested requires a multi-disciplinary laboratory with the expertise and instrumentation to handle whatever a facility might encounter. Ongoing monitoring, maintenance, and reporting are critical elements of the requirement. Our proven field response teams have supported facilities nationwide with data transparency, defensible results, and actionable insights — helping clients meet EPA expectations and avoid costly downtime.


Advanced Instrumentation. Mobile Response. Defensible Data.

Learn more about RJ Lee Group’s capabilities today.

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