Emissions unit source controls and work practice standards can become required by a wide variety of routes. These include BACT under PSD, LAER under NNSR, MACT, NSPS, state rules, and others. Following the startup, initial shake-down period, and performance testing for this equipment (which is addressed in the Startup and performance test planning section of this website), the regulatory control must be maintained for the duration of operational life of the equipment. Additionally, the monitoring, recordkeeping, and reporting requirements must also be initiated, completed, and maintained for the long-haul. Sage is very well qualified to provide assistance for these kinds of activities to facilities.
The keys to a successful implementation of a regulatory control program start with having a written compliance plan that addresses in a comprehensive way all of the applicable regulatory and permit requirements, the affected sources, the control options and why they were selected, the monitoring options and why they were selected, and contains the recordkeeping, and reporting requirements. The compliance plan would also contain or reference guidelines, procedures, decision trees, required plans, and key correspondence that facilitate or are required for compliance. An over-arching compliance plan is a Best Management Practice (BMP) that is highly recommended for facilities wishing to be on top of the game. Sage is able to write comprehensive compliance plans for your facility, either prior to startup (preferred) or down the line to help assurance continuing compliance.
A pocket-sized environmental compliance manual is also used as a BMP for top performers. This would contain all of the environmental regulatory and permit requirements for the facility and is usually highly welcomed by Operations personnel since it is readily available and informative. Sage is well able to prepare these type of compliance manuals as well.
Whether or not a written compliance plan exists, the facility must do all of the requirements that achieve and maintain compliance with the standard and permit requirements for the equipment. At a minimum, the facility should have written procedures that address the operation, maintenance, monitoring, and reporting/recordkeeping of the equipment. Again, this is a BMP for top performers. One additional advantage for having written procedures for regulatory compliance requirements is for personnel changeover. Training and performance of a new employee or a existing employee in a new job are greatly enhanced and improved by the existence of these kinds of procedures. Additionally, the facility must produce any required regulatory plans such as startup, shutdown, or malfunction (SSM) plans or operation, maintenance, and monitoring (OMM) plans. Sage is well-experienced and able to assist the facility in developing procedures and plans for any regulatory emissions control or work practice standard.
In order to assess emissions, demonstrate continuing compliance, and record emissions for reporting purposes, some form of recordkeeping and calculation tool is required. Often spreadsheets are the tool of choice for facility environmental staff. Sage has developed many spreadsheets to help with these requirements. Such spreadsheets can be linked to process historians as well as Title V compliance systems. Sage can also develop databases, reporting schedules, and compliance tools as needed to help the facility comply with the recordkeeping and reporting requirements. Sage is both experienced and capable in the preparation of these type of tools.
Sage personnel have a great deal of experience with implementation of regulatory programs. Additionally, some of our personnel have facility backgrounds and have been exposed to certain regulatory and permit compliance programs and systems in great detail.
Compliance implementation should begin before affected facility startup ideally. Often, this is not the case, and a facility must either scramble to get all of these requirements together at time of startup or must develop better systems down the road from those of initial application. The work would begin with an assessment of the regulatory and permit requirements being complied with followed by the development of a scope of work to address all known requirements. The use of the BMP program elements mentioned above is highly recommended, but Sage will work with the facility as required to fully implement the compliance program and assure continuing compliance.
All documents, plans, and tools developed by Sage would be formatted and internally reviewed by Sage prior to submission to the facility. Sage would review these items with the facility, make changes as required, issue the items for the record, review the items with facility personnel, and assist in the implementation of these items as directed by the facility.
Sage personnel have considerable experience in helping clients with implementation of compliance for regulatory compliance and permit requirements. A client list can be furnished upon request, along with a statement of qualifications.