From Air Quality
When it comes to air permitting, it seems that there is no end to the list of rules and regulations surrounding permits relating to EPA guidelines such as New Source Review Authorization, Title V, and more. Sage works with refineries to understand and adhere to these permits, offering the following services:
NEW SOURCE REVIEW AUTHORIZATION
NSR is a preconstruction permitting program that serves two important purposes. First, it ensures that air quality is not significantly degraded from the addition of new and modified factories, industrial boilers and power plants. Second, the NSR program assures people that any large new or modified industrial source in their neighborhoods will be as clean as possible, and that advances in pollution control occur concurrently with industrial expansion. Sage's NSR offerings include:
- Prevention of Significant Deterioration Reviews and Permits
- Minor NSR Pre-construction Permits
- Non-attainment New Source Reviews and Permits
- Standard Exemptions, Permits by Rule
- Permit Amendments and Permit Renewals
- Best Available Control Technology (BACT) Demonstrations
- Lowest Achievable Emission Rate (LAER) Technology Demonstrations
- PSD Air Quality Demonstrations
- Class I Area Evaluations and Federal Land Manager Negotiations
- Emission Reduction Credit (ERC) Documentation
TITLE V OPERATING PERMITS
Federal Operating (Title V) Permits (FOPs) are legally enforceable documents designed to improve compliance by clarifying requirements for facilities to control air pollution. These permits are issued to major sources and a limited number of minor sources (also known as “area” or “non-major” sources). Sage provides client support for all aspects of the Title V FOP program, including:
- Regulatory applicability analysis and documentation
- Initial issuance and revision permit application preparation
- Deviation reporting and compliance certifications
Sage is also able to assist clients with review of major source status, establishment of federally enforceable limitations for minor source status where appropriate, compliance reviews, and management of compliance systems.
ENVIRONMENTAL MANAGEMENT SYSTEMS
Our clients use Environmental Management Systems for a number of reasons. For some, certified programs require this level of organization. Others are simply driven by the concept of a cohesive system that provides structure, documentation and confidence that required tasks are being completed. Sage can help clients implement a purchased EMS, or may build a new system for a plant, depending on the goals and customization requirements. Either way, an EMS offers methods for defining, assigning responsibility, and tracking individual tasks for an entire environmental staff. This is especially useful for projects such as generating compliance deviations for title V reporting purposes.
ON SITE ASSISTANCE
With all that Sage can provide for our clients, it is not unusual for us to get pulled on site to work as a member of the team. When clients have a temporary gap in environmental staff, or are working on a special project that requires a larger team in the short term, they call Sage to supplement the people they currently have. This level of integration and tight relationship has been beneficial for many routine compliance projects.