`Utilizing Compliance Management Solutions to Implement an Effective SSM plan,` published in Chemical Engineering Progress, August 2002

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Courtesy of Trinity Consultants

Section 112(d) of the Clean Air Act, as amended in 1990, mandates EPA to regulate HazardousAir Pollutants (HAPs) for a variety of source categories. The intent of these regulations is torequire affected major sources to apply the Maximum Achievable Control Technology (MACT)as a method for minimizing HAP emissions.1 These MACT standards are also known as NationalEmission Standard for Hazardous Air Pollutants (NESHAPs) and are codified in 40 CFR 63.Subpart A contains the General Provisions applicable to all the MACT standards promulgated in1994. Detailed standards for specific source categories are still being developed and should bepromulgated by 2002.

Under the Operation and Maintenance Requirements of the MACT General Provisions (40 CFR63.6(e)), affected sources must develop and implement a written Startup, Shutdown andMalfunction (SSM) Plan. The SSM plan has two purposes: (1) To ensure the use of good airpollution control practices, and (2) To correct malfunctions as soon as practicable. The deadlinefor the plan is the compliance date for the source’s relevant MACT standard, and the plan isincorporated by reference into the source’s Title V permit.

Development of the SSM plan requires a joint effort between environmental and operationspersonnel and, in the case of complex sources, may benefit from outside assistance. In orderstreamline and simplify the SSM implementation process, many companies are seeking dedicatedcompliance management solutions. These solutions provide a way to improve accuracy, reduceredundancy, and centralize data storage, thus improving the form and function of an SSM plan.

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