Management System/Compliance Program Development
Sage Environmental can evaluate, develop, and implement comprehensive and sustainable compliance programs tailored to your facility to meet 40 CFR 61 Subpart FF. During compliance program development, Sage interfaces with your facility’s personnel to focus on planning, implementation/operation, compliance assurance, and corrective action.
Sage has extensive experience helping facilities assess and achieve compliance. Sage has helped consent decree facilities with their compliance action plans under the Benzene Waste Operations NESHAPs (BWON) enhancement provisions.
Sage’s compliance programs focus on five sub-elements:
Regulatory Applicability and Assessment —We will document the individual recordkeeping, reporting, and monitoring requirements for each piece of equipment subject to a Subpart FF standard (i.e., tank, oil/water separator).
Compliance with Requirements —Sage determines if the facility is complying with the regulatory requirements and provides a list of equipment subject to the BWON rule and the associated control requirements for each piece of equipment. The applicable requirements are outlined in checklists for the waste streams and each equipment type under Subpart FF. These checklists also may be used in internal audits to verify and document compliance with the regulatory requirements.
Self-Monitoring for Day-to-Day Compliance —The compliance program includes the necessary procedures and forms to meet the monitoring, inspection, recordkeeping, and reporting requirements of Subpart FF. Sage develops tools and job aids to help personnel gather data and archive records and to ease the burden of compliance. Job aids include check sheets, inspection forms, and written operating procedures. We tailor the checklists to the current applicable requirements and integrate job-specific check sheets into Operations for day-to-day monitoring.
Sage also designs a recordkeeping system that includes an environmental filing system and Subpart FF environmental records index to facilitate the retrieval of records required to document compliance.
Forward Planning and Management of Change —Management of change (MOC) is one of the most critical aspects of the compliance program needed to facilitate sustained compliance. Changes in the process, equipment, procedures, and/or regulations must be reviewed to determine their impact on your BWON compliance program.
Sage will review the existing MOC forms and processes for improvements to provide ongoing compliance with Subpart FF requirements. The MOC procedure provides for the identification, communication, and review of changes and their impact on Operations, safety, and environmental compliance. While the Environmental Department oversees the site environmental programs, Operations and environmental personnel are responsible for compliance. Each person identified in the compliance program has a responsibility in the MOC procedure.
Roles and Responsibilities —Sage will assign an individual and/or position responsibility for each monitoring, recordkeeping, and reporting requirement. In addition, we will establish management oversight consistent with quality assurance principles.
Sage personnel have considerable experience in evaluating and implementing BWON compliance systems. Our clients have included small, medium, and large refineries. We can furnish a client list on request, along with a statement of qualifications.