From the Trenches: Living Chemical Industry MACT Compliance

Joshua D. Marteny, P.E. Project Engineer
Tiffany L. Dillow, REMSenior Project Scientist

Josh: Alabama, West Virginia, Ohio, Florida, California, Louisiana, Michigan, and South Carolina. That isn’t generally a list of locations that would be the foci of work for environmental consultants with a three-person office in Baltimore, MD – but in our case it was. Our previous company was small enough that approximately 80% of our workload for the better part of 20 years was derived from a few industry segments’ regulatory compliance with one set of EPA regulations.

My first solo trip for Maximum Achievable Control Technology (MACT) compliance efforts was a crutches-enhanced trip to an FDA-controlled facility. There, process modeling was completed while literally locked in a windowless room due to the sensitivity of the pharmaceutical recipe information obtained. I found out afterwards that that week’s garage-based meth lab explosion in a nearby housing development was relatively standard for the area, among its former technicians trying to recreate recipes from memory.

Tiffany: One of my last MACT compliance trips involved a hotel stay hours’ drive from the facility (due to Hurricane Ivan’s wrath) during the summer in the Florida panhandle with no air conditioning. Chemical facilities are often located far from population centers for obvious reasons – with sites commonly situated over 100 miles from the nearest “restaurant” or hotel.

Numerous flights via small, rural airports (very often delayed) bookended long work weeks with skeptical plant personnel. Our presence at some sites became so frequent and infamous among plant engineers, operators, and technicians that our meeting invitations were only accepted via donut-based bribery.

Every environmental consultant who has ever helped a client has had to explain the difference between the way the regulators and site personnel view a facility. The MACT rules for the chemical industry added another significant hurdle – these rules viewed those same facilities through a mind-numbing third perspective. Out-the-pipe emissions and off-the-process emissions were of little concern – rather these rules are only concerned with air emissions before control devices but after process condensers and vacuum pumps. Waste discharges were similarly mangled from their usual environmental perspectives – even blurring the lines between waste and wastewater. Those nuances would repeatedly become quite troublesome issues.

Josh: Some facilities were only able to achieve compliance via the development of two or three completely different sets of emission inventories. Conversations with environmental departments, process engineers, equipment operators, and (especially) IT personnel which would eventually lead to those inventories were always lengthy, routinely convoluted, and sometimes heated.

Color-coded applicability diagrams and determinations for coconut oil, polymer, pesticide, and pharmaceutical plants have become forever ingrained in both of our heads. Zephyr’s Staff Scientist and GIS expert Jennifer Knowles was unlucky enough to have to deal with my insistence on certain colors for a figure she assembled for a client earlier this year – simply because any other set of colors sent my mind into a panic.

Data collection ranged from hours spent in rooms grilling process engineers to late-night sampling of wastewater from batch processes; often multi-million dollar control system requirements hung in the balance. The scope of information collected for each site over the course of three to six years frequently resulted in multi-volume submittals to regulatory agency personnel who knew little about the regulation themselves.

Tiffany & Josh: The good news is that we enjoyed rare opportunities to spend enough time working at a facility to really get to know its inner workings and the people there. We got to see a Star Trek-based wedding video at one site, and were invited to a Sheep & Wool Festival at another. Minor league baseball games and post-work craft beer tastings became the norm at one facility, while an 80s-themed sushi restaurant became a monthly destination at another.

On our first trip together, Tiffany was “forced” to drive a convertible yellow Ford Mustang to a pesticide plant after a mix-up at the rental car desk. We both were introduced to the concept of a “prayer button” (a sticker for the underside of hardhats that changes color when you’ve likely already received a lethal dose of Phosgene). And our catfish lunch was delayed because they had to first be caught from the stocked pond out back. Little did we both know that that was just the beginning of where MACT would lead us.


By | 2017-03-01T23:15:38+00:00 March 1st, 2017|Articles, Home Page|