Facilities deadlines

In addition to specific deadlines for each task and subtask, you should also consider program milestones, key pcrints in the plan at which you will want to review progress to date and make any necessary adjustments. For example, if you have adopted an element-by-element approach, you could consider completion of each PSM element as a milestone similarly, each facility s program would constitute a milestone, if that is the approach you ve chosen. 

Keep in mind that the pilot test may have taken more time than a comparable facility would need for installation once the system has been refined. At the same time, take care not to be unrealistic it s always better to beat a deadline than to miss it. 

The CAA compliance deadline may cause companies to install simple end-of-pipe emissions controls, instead of pollution prevention process changes. In order to limit this practice and encourage waste minimization, U.S. EPA allows owners and operators of combustion facilities to request a one-year extension to the compliance period in cases where additional time is needed to install pollution prevention and waste minimization measures that reduce the amount of hazardous waste entering combustion feedstreams.16 Requests for a one-year extension must reasonably document that the waste minimization measures could not be installed in time to meet the three-year compliance period. Decisions to grant the extensions will be made by U.S. EPA or authorized state programs. 

Until U.S. EPA calls in the facility s Part B permit application, where precise permit conditions will be established through a trial burn, owners/operators of interim status BIFs must ensure compliance with emission standards by showing certification of precompliance and certification of compliance. As the deadlines for these certifications have already passed, all interim status BIFs, except for possible extenuating circumstances, should be in the compliance stage. 

Interim status combustion facilities subject to the MACT standards also have to meet the three-year deadline. Interim status facilities are allowed to implement certain facility changes if the changes do not amount to reconstruction. To ensure that the reconstruction clause does not present an obstacle for interim status facilities trying to implement changes to meet the new MACT emissions levels, U.S. EPA exempted changes necessary to comply with the MACT standards from the reconstruction limit. 

After a prioritized list of processes is developed, a plan for PrHAs can be established. This plan must follow the minimum schedule in the PSM Rule, listed in Section 2.2.1, with no less than one-fourth of the PrHAs completed by May 26, 1994 and one-fourth completed each succeeding year. All PrHAs must be completed by May 26, 1997. However, the PSM Rule also states that PrHAs are to be done "as soon as possible, but no later than [the following schedule...]." This point is stated explicitly in the OSHA inspector s compliance guidelines, so it must be demonstrated that scheduled PrHAs were completed before the annual deadlines and that no intentional delays were incorporated into the PrHA schedule. For example, a large site might have mostly office and laboratory facilities, and only two processes covered by the PSM Rule. If manpower is available to conduct two PrHAs in parallel within the first year, then the PrHA schedule should not be extended over a 3-year period. 

Boatbuilders who use composites have, at most, just one more year before they have to reduce emissions to meet National Emission Standards for Hazardous Air Pollutants (NESH AP), also known as Maximum Achievable Control Technology (MACT) standards. By 23rd Aug. 2004, most boat manufacturing facilities subject to NESHAP must comply with 40 Code of Federal Regulations (CFR) Part 63, Subpart VVW. The deadline applies to existing boat manufacturing facilities that are major sources of hazardous air pollutants (HAPs). Existing sources are those that commenced construction on or before July 14, 2000. ( New sources , those that commenced construction after this date, must comply with emission limits at startup.) Major sources are facilities that have the potential to... 

Facilities that produce PETP will have an additional six months, until August 27, to comply with new equipment leak standards, it is briefly reported. The EPA has said an extension of the February 27 compliance deadline was necessary because the agency is reviewing petitions filed by PETP producers for reconsideration of the 1996 standards, which are part of the National Emission Standard for Hazardous Air Pollutants for group IV polymers and resins. 

The U.S. Army is in the process of destroying the country s stockpile of aging chemical weapons, stored at eight locations in the continental United States and on Johnston Atoll in the Pacific Ocean. The deadline for completing the destruction of these weapons, as specified by the Chemical Weapons Convention (CWC) international treaty, is April 29, 2007. Originally, the Army selected incineration as the preferred baseline destruction technology, and it currently operates two incineration facilities—one on Johnston Atoll and one at the Deseret Chemical Depot near Tooele, Utah. The Johnston Atoll Chemical Agent Disposal System (JACADS) completed destruction of the stockpile on Johnston Island in late 2000, and closure of the... 

In more recent years, in an attempt to overcome these problems, it has become fashionable to include more centres than what may be necessary in a study on the basis that some will be successful at recruiting whereas others will not. All, of course, have to be assessed to ensure that they can operate within the principles of GCP. It is important to be realistic in estimating the speed at which recruitment will occur and even in common disease areas, it is often unreasonable to expect centres to recruit at the rate of more than 1-2 patients per month. Nevertheless, the geographical distribution of clinical research is of major commercial concern because involvement of influential clinicians in the evaluation of a product is vital. It necessarily follows that involvement of influential clinicians in potentially large markets is of prime importance. Studies should, therefore, be conducted in these areas as first choice. However, this mandates willingness on behalf of the investigator to participate in pivotal studies and to meet development deadlines, which, of course, assumes the existence of an appropriate patient population and facilities for the conduct of the study. 

Constraints physical (space, facility), financial, and project deadline... 

The process to select a technology for the Pueblo Chemical Agent Disposal Facility (PUCDF) was defined in a notice of intent (NOI) published in the Federal Register on April 20, 2000. Environmental impact statements required by the National Environmental Policy Act will be developed for all the candidate technologies. The final choice will be made by the DoD from the technologies certified to be as safe and cost efficient as the baseline incineration system, as well as capable of completing destruction of the Pueblo stockpile either by the CWC treaty deadline (April 29, 2007) or the date that would be achievable by the baseline system, whichever is later. The decision tentatively will be made in early fiscal year 2002. 

Obtaining approvals for off-site transport might cause delays. If the destruction of energetics must be completed by the CWC deadline, PMCD should set a date by which construction of the DFS must be started if no off-site permit has been received or if the receiving facility does not have a valid permit. A permit for DFS construction should be relatively easy to obtain because of its successful use at both JACADS and TOCDF. However, enough time must be allowed in the schedule for permit application and approval. In view of the opposition to incineration by some Pueblo stakeholders, the prompt receipt of a DFS permit cannot be assumed. 

These deadlines were not met. In the listing of July 30, 1943,22 delivery of both units is announced for early October . Further, the hourly capacity of each unit is given as = 625 men = 15,000 men per 24 hours. Thus, the total capacity of both shortwave facilities amounted to the clothing of 30,000 persons per day. On August 27, 1943, the construction costs of the stationary facility are given as RM 98,000,54 which translates into approximately DM 1,568,000 today (ca. 870,000). A notice of December 11, 1943,55 stated that the materials and apparatus had already been received. The installation date for SSW is given as January 16, 1944, at the earliest. Work actually began on February 16, 1944. 

Information about the destruction of India s declared chemical weapons stockpile is sparse. One may speculate that India, having been the site of the worst industrial chemical accident in history at the Union Carbide facility in Bhopal, is extremely sensitive to legitimate public opinion. India has consistently completed destruction ahead of the Convention s deadlines at its one declared destruction facUity. Understandable pride has been expressed in the rate at which stockpile destruction has been ac-comphshed, with more than 40 per cent having been eliminated. ... 

In 1977, this Act was amended to extend the deadline of meeting the motor vehicle emissions standards. These amendments also made a first attempt to control stratospheric ozone and created the New Source Review, which required older grandfathered facilities to install pollution control technologies as they modernized. 

The development of a VMP requires several decisions. If the facility is new, due consideration is given to determine, on time, the target dates for routine production to ensure completion of validation for facility approval otherwise manufacturing at risk is the alternative choice. The deadline determination provides ample opportunity to perform validation of utilities, critical equipment installation, and qualification prior to construction work. In addition, it provides a sufficient time frame to identify the critical processes and steps involved. The parameters critical for each step shall be established. The critical equipment required shall be determined. Critical processes, steps involved, parameters, and equipment are identified. For existing facilities, establish the criteria for revalidation based on known vulnerabilities and engineering projects in progress. 

Under the CWC, countries may apply for an extension of the deadline of up to 5 years. The United States has acknowledged that some of the stockpile destruction facilities are likely to continue to operate for several years beyond 2007. The Product Manager for Non-Stockpile Chemical Materiel (PMNSCM) has indicated to the committee that the PMNSCM intends to meet the 2007 deadline for destruction of all recovered non-stockpile materiel currently in storage. 

Finding 2-lb. The task of destroying the very large qnantity of NSCWM at Pine Blnff Arsenal by 2007 is dannting, given that the planned non-stockpile facilities are not expected to be operational nntil 2006. As far as the committee can ascertain, the Army has not developed a timetable for destmction of this NSCWM that is both realistic and consistent with cnrrent treaty deadlines. The committee is concerned that withont clear planning and extraordinary efforts, the treaty deadlines will almost certainly not be met. 

Since buried CWM is known to exist at many sites (both current and former military facilities), the transition should include an assessment to ensure that these sites have treatment facilities that are adequate to treat the type and volume of buried CWM. Although the pressure of meeting the treaty deadline does not exist for buried NSCWM items, the Army still needs to set a reasonable schedule for the eventual destruction of this buried materiel. It is likely that the removal of buried CWM from the ground prior to destruction will pose the greatest risk, so the Army must have in place sufficient measures to ensure that human health is protected during removal operations. 

All of these items can also be processed at the Army s CAMDS facility, at Deseret. CAMDS operates under a RCRA operating permit and, as a non-stockpile disposal facility, is not affected by the 2007 CWC treaty deadline. CAMDS also has other missions and tests to conduct, however, and completing the destruction of the non-stockpile items listed above before 2007 will require some scheduling prioritization. 

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