Compliance Program Development
Part 63 MACT programs contain many emission limitation and work practice standards that require a significant effort to understand, develop a compliance program for, and implement. If the client wishes to do the program implementation themselves, but needs assistance in developing the compliance strategy and the selection of the most cost-effective compliance option(s), Sage is able to provide this high-level assistance. Sage would assist the facility by helping the client understand the regulatory requirements (including any important nuances found in the rule preface, proposed rule, and background information documents), helping the client assess the current compliance posture of the facility to the new rule, helping the client to select cost-effective controls and alternatives, helping the client to evaluate the monitoring requirements and select the most cost-effective monitoring alternatives or alternative monitoring plans, helping the client understand the recordkeeping, reporting, and notification requirements, and providing expert-level guidance as needed for implementation.
Sage personnel have considerable experience with MACT programs. A partial list of MACT programs worked on include the following:
- Subpart F, G, and H - SOCMI HON
- Subpart Y - Marine Loading
- Subpart CC - Refinery MACT I
- Subpart UUU - Refinery MACT II
- Subpart EEEE - Organic Liquid Distribution
- Subpart FFFF - Miscellaneous Organic NESHAP
- Subpart ZZZZ - Reciprocating Internal Combustion Engines
- Subpart DDDDD - Boiler and Process Heater
- Subpart GGGGG - Site Remediation MACT
and many others. Don’t see your particular MACT on there? Just ask!
For high-level compliance strategy, Sage would provide an experienced senior regulatory specialist that would work with the facility and provide these important services. The Senior regulatory specialist would be assisted as needed by other Sage resources, including a client service manager, other senior regulatory specialists, a project manager, a quality control officer, and junior personnel who execute portions of the work under the leadership of the more senior personnel. An excellent way to provide this type of assistance would be to develop a compliance plan for the facility that captures all of the important details of the rule, identifies the affected sources and their current compliance status, and provides the recommended implementation strategy. If a lowest-cost approach is preferred by the facility, then Sage can provide a senior regulatory specialist who would visit the facility, discuss (usually supplemented with a PowerPoint presentation) the regulatory requirements with the facility staff, review the facility sources and their current compliance posture, and then provide an opinion of the most cost-effective compliance strategy for the facility based on information provided prior to the visit and during the visit.
Sage personnel have worked on MACT compliance issues with many clients. The typical clients include major refining and chemical complexes, major refineries, major chemical plants, and medium to smaller refineries and chemical plants. Sage has produced several NPRA papers on MACT program implementation.