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BWON Team
Larry G. Darcey, P.E.
Client Service Manager
Mr. Darcey is Sage Environmental's BWON program subject matter expert and has almost a decade of extensive experience in all facets of BWON.
He has worked BWON compliance issues at more than two-dozen refineries and chemical plans including a wholesale re-development of a many
facilities' TAB and uncontrolled benzene quantity, assistance with Consent Decree BWON requirements, BWON sampling and sampling plan development,
development of BWON compliance programs, assistance in cost-effective design solutions for BWON-compliant wastewater collection and treatment
systems, and preparation of BWON Consent Decree gap analyses for facilities considering consent decrees. Mr. Darcey's unique ability to relate
to client's environmental, engineering, operations, legal and management personnel yields effective solutions to client's BWON problems.
Mr. Darcey has assisted multiple facilities with BWON enforcement negotiations with the Environmental Protection Agency and State agencies.
Mr. Darcey is well respected by regulators and this relationship makes him an excellent resource in settlement negotiations and in supporting
regulatory interpretations. Mr. Darcey also published and presented a paper at the 2003 Air & Waste Management Association Conference entitled
“Documenting, Evaluating and Sustaining Compliance with the Benzene Waste Operations NESHAP” and served as the BWON moderator at the 2006 NPRA Workshop.
Thomas P. Nelson, P.E.
Senior Technical Specialist
Mr. Nelson has over 32 year of professional experience centered in the area of air pollution control technology research, evaluation, and design.
Mr. Nelson has assisted numerous petroleum refineries in the interpretation of the Subpart FF rule and how it applies to their refinery.
Mr. Nelson is also very knowledgeable in the area of criteria pollutant and air toxic regulations including the federal Clean Air Act regulations
associated with PSD, NSPS, NESHAP/MACT, stratospheric ozone depletion, and Title V permitting.
David Monfore, Q.E.P., P.E.
Senior Technical Specialist QA/QC
Mr. Monfore is a professional environmental engineer with over 36 years of field and corporate experience.
David has participated in the joint EPA/TNRCC/TMOGA Roundtable evaluation of compliance problems under Subpart FF for petroleum refineries.
This effort along with the efforts of similar groups in other EPA regions eventually culminated in the release by the EPA of the
“Benzene NESHAP FAQ Handbook for Subparts BB and FF”, September 1997 (EPA/305-B-97-009). He has given numerous presentations and seminars
on a variety of environmental subjects to plant, professional, and educational audiences and has been a member of the
Air and Waste Management Association since 1974.
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Taras Lewus
Client Service Manager
Mr. Lewus has experience in the environmental field focused on air quality compliance, particularly for petroleum refinery, upstream oil and gas,
chemical plant, and pharmaceutical production clients.
Mr. Lewus has assisted multiple refineries nationwide with NESHAP FF compliance issues, including performing compliance audits, developing ground-up
TAB and Uncontrolled Benzene Quantity calculations, developing training and compliance documentation programs, assisting with compliance program
implementation, and other related issues. Mr. Lewus has assisted in the development and enhancements of NESHAP FF programs as required by
“Global Settlement” Consent Decrees for multiple refineries.
Ryan C. Atkinson, E.I.T.
Senior Technical Specialist
Mr. Atkinson has assisted more than 10 refineries nationwide with NESHAP FF compliance issues, including performing compliance audits,
developing ground-up TAB and Uncontrolled Benzene Quantity calculations, developing training and compliance documentation programs,
assisting with compliance program implementation, controls system design, and other related issues. Mr. Atkinson has performed NESHAP
FF training seminars for several dozen refinery environmental professionals.
Ruth (Jimenez) Benning
Senior Technical Specialist
Mrs. Benning has managed development and/or enhancements of benzene waste compliance programs for the NESHAP FF rule for numerous
petroleum refineries, including projects required by “Global Settlement” Consent Decrees. For some of these projects, Mrs. Benning
developed complex spreadsheet-based compliance tools for calculating, recordkeeping and reporting Total Annual Benzene (TAB) values for the NESHAP FF rule.
Dawna Virdell
Regulatory Specialist
Ms. Virdell has been employed as an environmental consultant since February 2006 and the majority of her experience is in Benzene NESHAP (FF) Program Development and Compliance. She has worked on several refineries’ BWON Programs and Total Annual Benzene (TAB) Review and Verification processes.
Ms. Virdell has worked BWON issues at approximately nine facilities including a wholesale re-development of a several refinery’s TAB (Total Annual Benzene) and BQ (Benzene Quantity), assistance with Consent Decree BWON requirements, BWON sampling and sampling plan development, and development of BWON compliance programs.
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Team Testimonials
The current economic value that we provide to our customers comes from identifying and resolving potential compliance issues as soon as possible so that we can mitigate the problems and avoid penalties. Our success hinges on our team of experts that utilize their vast process knowledge of refining and chemical plant operations.
Ruth Benning, Project Manager
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