Air Quality

Tank411 - Regulatory

Sage Environmental Consulting offers full-service storage tanks capabilities through our Tank411 (regulatory) and Tank911 (emergency) teams. To us, full service means providing you with regulatory expertise, evaluating of the adequacy of your current program, training or supplementing your current personnel, and performing all of your required inspections, integrity testing, troubleshooting, and emergency response. Tank411 offers you regulatory strategy and compliance software through joining forces with Rob Ferry, TGB Partnership. Rob helped the EPA and the American Petroleum Institute (API) with emissions estimating guidance development and regulatory advocacy.

Regulatory Compliance and Support

Tank411 offers the industry's most respected expertise in regulatory compliance, and we can help you with the following:

  • Permitting (NSR, PSD, PBR, Title V, Dispersion Modeling)
  • LDAR auditing
  • BWON auditing
  • Agency reporting (AEI, TRI, Title V Deviations, TAB),
  • Consent Decree support
  • Due diligence support
  • Risk-management program development

With these specialized programs, and our broad training offerings and other specialty services, we help keep your entire environmental department running smoothly.

RULE COMPLIANCE IMPLEMENTATION

Sage helps clients implement a purchased Environmental Management System (EMS) or build a new system for a plant, depending on the goals and customization requirements. An EMS offers methods for defining, assigning responsibility, and tracking individual tasks for an entire environmental staff.

TOOLS FOR COMPLIANCE:
OUR STATE-OF-THE-ART SOFTWARE EXCEEDS INDUSTRY STANDARDS

There are specific limitations of and inaccuracies in the EPA-issued tank emission software, TANKS4.09. Our tank emissions software programs remedy these deficiencies. (See orange call-out box for more details.)

Rob Ferry of The TGB Partnership developed the tank landing/cleaning emissions estimation methods (API Technical Reports 2567 and 2568) and prepared a compilation of the emission calculation methods for all emission sources at terminals (API Publication 1673).

We provide our clients with the most informed and accurate emissions tools for permitting, compliance demonstration, and agency reporting:

TankESP is a tank emission software program for estimating storage tanks emissions developed by Rob Ferry of The TGB Partnership (TGB). In addition to accurately applying the AP-42 equations for organic liquid storage tanks, TankESP incorporates correct monthly emission estimates, estimates of roof-landing and tank-cleaning emissions, and short-term emissions not available in TANKS4.09. TankESP can be customized to provide reports for all of your needs, including permitting, agency reporting, and internal compliance tracking. Purchase

TankESP Plus is a software program that estimates emissions not only from storage tanks, but also from the other types of emission sources typically found at terminal and pipeline facilities—from loading losses to equipment leaks to spills. TGB is uniquely qualified to develop such a tool, having written the industry publication that compiles methods for estimating emissions at terminal and pipeline facilities (API Publication 1673).Purchase

TankCOP is a database program that reliably and consistently generates tank-specific compliance tasks for both routine and non-routine requirements, schedules when those tasks are due, and maintains a history of compliance activities as they are completed. TankCOP automatically determines which regulations and tasks are applicable to a given tank, including initial, conditional, and periodic compliance tasks, then schedules and manages those tasks.Purchase

Whatever you need in the way of emergency tank services, we provide it: emissions estimating, software solutions, inspection services, air permitting, emergency response and troubleshooting, and program auditing and improvement.

Whether you need Tank911 (maintenance and repairs) or TANK411 (regulatory support), we have the expertise to keep you in top compliance.

OUR REGULATORY TANK EXPERTISE

Together, we can resolve your tank issues and guide you on best practices in the following areas:

Inspection Plans, Audits, and Training
  • Tank environmental inspection services and program audits
  • TankCOP software to manage environmental regulatory compliance
  • API 653 inspection services
  • NACE coatings inspections
  • Training on tank design, air regulations, and emission calculations
  • Due diligence
Emissions Estimation and Improvements
  • TankESP software for storage tank emissions estimation and TankESP Plus software for estimating emissions for all terminal sources
  • In-depth review of operating parameters for accuracy and best practices
  • In-field verification of design parameters and fittings
Compliance and Enforcement Assistance
  • NSPS, NESHAPs, MACT, and GACT compliance
  • Emission control strategy
  • 114 letter requests, Consent Decrees, and auditing assistance
  • Settlement/litigation negotiations assistance
  • Troubleshooting and repairs
  • SPCC plans and SWPPP
New Source Review and Title V Permitting
  • PSD, NSR permits, amendments, and renewals
  • BACT, RACT, LAER determinations
  • Criteria pollutant and HAP emission inventories
  • Recordkeeping, reporting, and monitoring set-up
  • CAM plan development and implementation
Do You Know...

The EPA has not maintained TANKS4.09; therefore, the program is increasingly divergent from EPA's AP-42 methodology for estimating storage tank emissions. TANKS4.09 does not match EPA's AP-42 guidance for the following:

  • Monthly calculations
  • Fixed–roof tank calculations
  • Heated tank calculations
  • Roof landing/cleaning emissions
  • Selected floating roof calculations

Our TankESP software addresses all of these problems.

For more information about the problems with TANKS4.09 and how TankESP fixes them click here or call us for details at
1-855-Tank411.

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