MACT Audits: It's Not A Monolithic Process
Posted on: 8 June 2019
Maximum Achievable Control Technology, or MACT, audits are often discussed in general terms. For instance, if you operate a facility held to these emission standards, you know compliance is necessary. What's discussed less often are the varying levels of compliance, as not every audit guideline is the same. If you' are subject to an audit, this information is very important.
Fuel Monitoring
For any MACT audit, it's wise to assume that you will have to submit information on your boiler's fuel monitoring plans as part of the process. Fuel monitoring is important because it helps analyze what pollutants might be circulating within or from the boiler.
As part of the process, a small fuel sample is collected, and its makeup is analyzed. Completing this part of the audit process is less about pass or fail and more about detailing the information so that you can take the appropriate containment steps. However, if a subsequent audit reveals that the makeup of the fuel monitoring analysis has worsened, you might be forced to make changes.
Operation and Maintenance
Any audit for an organization that uses the Portland cement manufacturing process is subject to a review of its operation and maintenance plans for the boiler they use. As part of the process, the company needs to be able to show that they have proper plans in place to control the dust emissions produced from storing the cement materials produced by this intensive heating process.
You will also need to show air pollution control processes and a plan for conducting annual inspections by which these measures are tested and tracked. It's important to note that this plan might also be required at the time of the application for audit for review, so you might need to prepare it early.
Energy Efficiency
If your organization hopes to earn efficiency credits, you will be subject to an energy efficiency audit. A large part of the audit process is producing a detailed plan in which you map out the systems you have in place to reduce the boiler's energy expenditure, as well as how much you intend to save with this plan.
You will also need to provide data to support the plan, such as a series of energy reports from before the plan was introduced, and the reports post-implementation of the plan. Keep in mind that since boiler credits are for individual boilers, each of the boilers onsite must be individually inspected to earn its own credits.
The best way to prepare for a MACT audit is to know what's expected of you in the first place. Make certain you know what type of compliance your facility is being held to before you begin the process.
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