Content area
Full text
Environmental Protection
Follow these steps to prepare a plan that mitigates excess emissions of hazardous air pollutants.
Facilities that emit hazardous air pollutants (HAPs) are required to apply the Maximum Achievable Control Technology (MACT) for minimizing HAP emissions. These MACT standards, also known as National Emission Standards for Hazardous Air Pollutants (NESHAPs), include General Provisions (40 CFR 63.6(e)) that require affected sources to develop and implement a written Startup, Shutdown and Malfunction (SSM) Plan. The two main purposes of this plan are to ensure the use of good air-pollution control practices and the correction of malfunctions as soon as practicable. The deadline for completion of the plan is the compliance date for the source's relevant MACT standard, and the plan is incorporated by reference into the source's Title V operating permit.
Development of the SSM plan should be a joint effort between environmental and operations personnel; complex sources may require outside assistance. This article offers advice on how to prepare an SSM plan, and how to incorporate computer-based compliance-management tools (CMTs) into its monitoring and recordkeeping elements.
Applicable equipment
The first step in developing an SSM plan is to make a list of the equipment subject to the MACT standards. This list should include equipment such as process equipment (e.g., reactors, centrifuges, distillation columns), storage tanks, recovery devices (e.g., oil-water separators, strippers), control devices (e.g., thermal oxidizers, scrubbers), and continuous monitoring systems (CMS; i.e., monitoring systems used to demonstrate compliance with the MACT standards during normal operation).
Potential malfunctions
The next step is to develop a list of all potential malfunction scenarios for the applicable equipment. Discuss with operations personnel each scenario to determine whether a particular malfunction could result in excess HAP emissions. Some good resources for identifying and evaluating malfunctions are standard operating procedures (SOPs), existing alarms in the process automation system, release reports submitted to the EPA and/or the state and local regulatory agency, and, most importantly, brainstorming sessions with operating personnel.
Examples of some potential malfunctions that may result in excess HAP emissions include:
* high pressure in a reaction vessel
* low flow to a scrubber
* low temperature in a thermal oxidizer
* high level in a storage vessel.
Corrective actions
Corrective actions must be identified for...