Executive Summary
A Fortune 50 refinery operates under a 2023 Consent Decree addressing Clean Air Act violations related to benzene waste and VOC emissions. The decree specifically cites past non-compliance with the Benzene Waste Operations NESHAP (40 CFR Part 61, Subpart FF, commonly known as BWON) and the NSPS wastewater regulations (40 CFR Part 60, Subpart QQQ).
An industrial compliance services provider partnered with Skyello, Inc. to pilot an AI-powered compliance automation platform at the refinery. The goal was to determine if Skyello's "Field IO" mobile inspection app and "Core" cloud platform could improve BWON compliance efficiency and reliability.
Pilot Results
Pilot Overview
The Phase 1 pilot began in mid-October 2025 and ran through mid-December 2025 (~3 months). During this pilot, Skyello was configured to support BWON compliance workflows, including digital checklists and inspection forms aligned to EPA 40 CFR 61 Subpart FF standards, AI-assisted data collection, and automated generation of compliance reports.
Approximately 4,678 BWON "points of generation" (POGs) — such as drains, sumps, and other waste-handling points subject to BWON — were onboarded into Skyello's database for monitoring. The pilot generated 101 inspection instances across 75 unique BWON assets.