A team approach to implementing MACT standards

Abstract

The requirements of the MACT Standards for Emissions from Leaking Equipment and the requirements of the amended Clean Air Act will change how environmental control programs are administered within plants. No longer will the programs be the responsibility solely of the separate environmental function. The programs will need to be administered via a team of personnel that involves maintenance, computer systems, environmental, emissions measurement specialists, and planning personnel as well as management. Compliance with the rules will be based on an inspection ofpaper records and computer databases. The enforcement penalties will not be trivial, The ability of the plant togrow and be modfied will need to be balanced against the potential benefits from early reduction programs, which will allow for delayed implementation of some programs. EPA RECENTLY COMPLETED a negotiation process that resulted in rules which defme National Emission Standards for Hazardous Air Pollutants (NESHAP) emissions from leaking equipment. These rules apply to emissions from valves, pumps, flanges, compressors, relief valves, agitators, sampling systems, and openended lines. These new rules will be a template for the establishment of Maximum Achievable Control Technology (MACT) requirements under the Clean Air Act Amendments for emissions from leaking equipment. The new fugitive emission rules and the new Clean Air Act requirements are summarized and the implications for plant operations are discussed in this article.The plant performance data summarized below indicate that a quality approach is needed to reduce emissions from leaking equipment. This quality approach is summarized and explained. The approach must involve all aspects that affect emissions from leaking equipment. That is, all the systems affecting equipment emissions must be brought into control to achieve low emission performance. These systems include purchasing, specification, inspection, vendor quality assurance, owner quality assurance, operations, maintenance, and leak detection and repair programs.