THE CHROMIUM NESHAP AND EPAS FOCUS ON OPERATION AND MAINTENANCE PLANS- AVOIDING THE HIDDEN PITFALLS

Plating shop personnel and environmental staff have been preparing for the Chromium NESHAP since the final rule publication date of January 1995, Much of the focus has been on upgrading and/or adding control eq uipment by the compliance date of January 25, 1997. Another compliance concern exists, however. A facility's written and performed work prac tice standards are subject to enforcement and inspection, beginning on the same date. The recording of a scrubber pressure drop, for instanc e, is no longer strictly a shop concern, because record keeping is enf orceable and must be maintained as specified in the regulation. The Op erations and Maintenance (O & M) Plan must ensure that equipment or pr ocess malfunctions resulting from preventable conditions do not occur. Although required as part of the NESHAP compliance, the Plan is an op erations and maintenance manual and is to be utilized as such, Practic al suggestions for lessening the paperwork burden and improving the us e of the Plan are discussed, and solutions to the environmental compli ance vs. operating personnel responsibility issue are presented.