Comprehensive/Turnkey Program Development
(Initial reporting to comply with Standards, Recordkeeping, Reporting, and Monitoring Requirements)
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. Sage is able to provide a complete turnkey approach for compliance with a MACT standard. This would include assessing the regulatory requirements, assessing the compliance posture of the facility to the new rule, selecting cost effective controls and alternatives, obtaining the services of subcontractors to design and install these controls, evaluating the monitoring requirements, selecting and implementing via subcontractors the most cost-effective monitoring alternatives or alternative monitoring plans, developing recordkeeping, reporting, and notification procedures, making the initial notification and notification of compliance strategy submittals, as required, developing computer software tools (spreadsheets, databases, forms, etc.) to assess compliance and track emissions, developing and implementing source sampling plans, both pre- and post-compliance as needed, developing monitoring plans, startup, shutdown, and malfunction plans, and operation, monitoring, and maintenance plans, and providing both expert-level guidance and project management 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!
Sage typically develops a team that is composed of a client service manager, one or more 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. For a turnkey approach, the team would likely be supplemented with subcontractors that specialize in the design and installation of controls and monitoring. The work usually begins with the development of a Needs List and a Kickoff meeting agenda that are sent to the client prior to the Kickoff Meeting to facilitate data gathering. At the on-site Kickoff Meeting, the project objectives, schedule, budget, communications, data gathering methods, action items, deliverables, and assignments are outlined and agreed upon.
Data gathering and key personnel interviews are completed as soon as possible after the Kickoff Meeting. The schedule would be developed into a Gantt chart that shows key tasks and deadlines that would be tracked for project management purposes. Project deliverables are developed in draft form and are formatted and given an internal quality assurance review prior to being sent to the client. Client edits and changes are incorporated into final work products that are delivered along with electronic supporting files and computer tools in accordance with the project schedule. One of the keys to a successful project is communications. Periodic meetings, usually by telephone and WebEx, but sometimes on-site, are used to communicate project progress and work through any issues. For a turnkey project, an on-site project manager would likely be furnished for project duration.
Installation of emission controls would be coordinated with facility management to minimize work disruptions and process downtime to the extent practicable. Extensions of MACT compliance deadlines would be sought if justified and beneficial to the client. Final work products, installed controls, and monitoring systems are delivered in accordance with project expectations, schedule, and budget. Post-installation review, start-up, acceptance testing, compliance testing, and program turn-over to facility staff would be completed as needed. Sage would also be available post-project closure on an as-needed basis for consultation or assistance.
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.