Ehs Management Systems for Hwc Mact Compliance

On September 30, 2003, existing hazardous waste combustors (HWCs) began operating under the HWC Maximum Achievable Control Technology (MACT) standards. The HWC MACT standards include recordkeeping and reporting requirements that are typically more extensive than previous facility requirements. Facilities are required to keep detailed records of items such as emission exceedances, startups, shutdowns, and malfunctions. Additionally, there are reporting requirements throughout the MACT regulations, some of which require immediate action. The recordkeeping and reporting burden may be one of the most significant changes to facility operations under the HWC MACT standards. This paper will explore the synergies between the HWC MACT requirements and Environmental, Health, and Safety (EHS) Management Systems. The discussion will focus on how HWC MACT compliance fits within this philosophy and will describe tools that can be used to facilitate its implementation. Practical examples will be provided to show how information management systems can aid in thorough and cost effective administration of HWC MACT compliance issues.