Strategy:  Utilize Generic Compliance Plans to Reduce Development Costs 

Candidates:  Boilers, Industrial Furnaces, Cement Kilns, Lightweight Aggregate Kilns, Incinerators, Vent Gas control Systems, Flares, Cooling Tower Heat Exchange Systems, etc.

Potential Cost Savings:  $5,000 to Greater than $30,000 per Plan

Facilities operating hazardous waste combustion (HWC) units are required to develop and implement HWC MACT Plans in accordance with the Clean Air Act regulations. The development cost for each plan is significant. Utilizing Generic HWC MACT Plans allows a facility to satisfy the regulatory requirements and minimize the development cost of the plans. The Generic HWC MACT Plans developed by and available from CS2 Inc. include the following:

• MACT Recordkeeping and Reporting Guidelines
  
• Startup, Shutdown, and Malfunction Plan
  
• Operation and Maintenance Plan
  
• Operator Training and Certification Program
  
• Feedstream Analysis Plan
  
• Continuous Emission Monitoring System Quality Assurance Plan
  
• Continuous Monitoring System Evaluation Plan and Test Plan

Facilities operating vent gas control systems, flares, and cooling tower heat exchange systems that emit highly-reactive volatile organic compounds (HRVOCs) are required to develop and implement Quality Assurance Plans in accordance with State requirements, such as the Texas Commission on Environmental Quality (TCEQ) regulations. The development cost for each plan is significant. Utilizing Generic Quality Assurance Plans allows a facility to satisfy the regulatory requirements and minimize the development cost of the plans. The Generic Quality Assurance Plans (QAP) developed by and available from CS2 Inc. include the following:

• QAP for Monitoring Vent Gas Control Systems
• QAP for Monitoring Flares
• QAP for Monitoring Cooling Tower Heat Exchange Systems

Each Generic Compliance Plan contains an electronic and paper copy of the generic plan, instructions and example text for use in customizing the plan, and a regulatory cross-reference document. In addition, the training and certification program contains the complete training and certification materials necessary for a facility to implement the program. In the event of an audit, the regulatory cross-reference documents can assist facilities in demonstrating compliance.

CS2 Inc.’s Generic Compliance Plans meet the compliance needs and cost concerns of facilities. The use of Generic Compliance Plans is a smart compliance strategy.