CASE STUDY
Compliance register for Ethylene MACT Rule Updates
An American-based ethylene manufacturer faced the challenge of planning comprehensive facility updates to comply with the latest revisions to the Ethylene MACT standards.
BACKGROUND
The Ethylene Maximum Achievable Control Technology (MACT) standards are part of the EPA's efforts to regulate hazardous air pollutants (HAPs) from industrial sources. These standards are designed to ensure that emissions from ethylene production processes are controlled using the best available technology. The MACT standards aim to minimize the release of harmful pollutants, thereby protecting public health and the environment. Ethylene, a key component in the production of plastics and other chemicals, is produced in large quantities, making stringent controls essential to mitigate its environmental impact.
Recent updates to the Ethylene MACT standards include revisions to address typographical errors and clarifications, as well as significant changes to certain provisions. For instance, the EPA has proposed removing force majeure provisions from pressure release device regulations to prevent misuse and simplify compliance. Additionally, new requirements for storage tank degassing and modifications to delay of repair provisions for ethylene cracking furnaces have been introduced. These updates reflect the EPA's ongoing commitment to enhancing regulatory frameworks and ensuring that industrial practices evolve to meet higher environmental standards.
The Client’s Challenge
The client needed support systematically mapping applicable rule changes, cataloging required changes, prioritizing the facility program updates, and road mapping an implementation plan.
OUR SOLUTION
JBE implemented a structured approach to address these challenges:
Mapping Applicable Rule Changes: JBE reviewed the latest Ethylene MACT updates to understand specific changes and new requirements, create a detailed list of all applicable rule changes, and compared these changes with current compliance practices to identify gaps and areas needing adjustment.
Cataloging Required Changes: JBE evaluated how each rule change affects different aspects of the facility's operations, cataloged the specific actions required to comply with each change, and identified the teams or individuals responsible for implementing each change.
Prioritizing Facility Program Updates: JBE conducted a risk assessment to prioritize updates based on their impact on compliance and operational efficiency, allocated resources including budget and personnel to high-priority updates, and developed a timeline for implementing updates, focusing on critical changes first.
Road-mapping an Implementation Plan: JBE reviewed the latest Ethylene MACT updates to understand specific changes and new requirements, created a detailed list of all applicable rule changes, and compared these changes with current compliance practices to identify gaps and areas needing adjustment.
OUR IMPACT
As a result of this project, we helped ensure enhanced regulatory compliance and reduced the risk of non-compliance and associated penalties. We streamlined processes and prioritized updates, leading to improved operational efficiency and better resource allocation. Additionally, the project helped identify and implement measures to reduce hazardous emissions, contributing to better air quality and environmental protection.
This project provided a clear roadmap for compliance, enabling proactive management and long-term planning, while also enhancing data transparency and quality assurance, fostering trust and accountability within the organization and with external stakeholders.