ENFORCEMENT NEGOTIATION AND LITIGATION SUPPORT

The BWON rule has been one of the most litigated and enforced regulations for the past two decades. As a result of our extensive practice, Sage has become skilled in dealing with environmental regulatory agencies throughout the U.S., particularly with the staff of the EPA’s National Environmental Investigation Center (NEIC). We have worked closely with the EPA to develop, on behalf of our clients, a number of favorable interpretations of and exemptions from provisions of the BWON rule. We also represent clients in connection with EPA inspection, investigation, and administrative and injunctive proceedings. In this area, we offer:

• Litigation Support
• Enforcement Negotiations
• Expert Witness

CONSENT DECREE ASSISTANCE

Sage has not only assisted with implementation of many consent decrees, but has supported facilities that have had recurring problems with their End of Line (EOL) estimates and solved those problems. We are well versed in all aspects of BWON compliance requirements, including compliance with Consent Decree BWON Enhancements as part of the Refinery and Chemical Enforcement Initiatives. Our services include:

• Review and Verification
• Third Party Review Process
• TAB Updates
• Compliance Action Plan Development and Implementation
• EOL Plan Development and Implementation
• Laboratory Audits
• BWON Standard Operating Procedure Development
• BWON Best Practices and Sustainability Programs
• Controls Strategy and Treatment Process Design