FAULT TREE ANALYSIS: IDENTIFYING MALFUNCTIONS TO SUPPORT APPROVAL OF THE SSMP

摘要

The preamble to the February 13, 2002 Hazardous Waste Combustor (HWC) Maximum Achievable Control Technology (MACT) Interim Standards Final Rule provides the following guidance for the Start Up, Shutdown and Malfunction Plan (SSMP), "You may develop a fault tree analysis, for example, to identify malfunctions and develop measures to minimize the frequency and severity of those malfunctions." Fault tree analysis is offered in this rulemaking as a means of ensuring that the SSMP is both proactive (I.e. minimizing the frequency and severity of malfunctions) as well as reactive in promptly responding to and correcting malfunctions. Demonstrating that the SSMP is both proactive and reactive is noted as key criteria for agency approval of the Plan. Fault tree analysis is a deductive failure analysis method that focuses on identifying the credible ways that can cause an undesired event to occur. Fault tree analysis provides a systematic, highly structured approach to identify malfunctions, identify actions currently being taken to mitigate malfunctions, and identify actions or procedures, which may be recommended to address likely malfunctions. This provides supporting documentation that the SSMP is proactive and reactive in responding to the malfunctions identified. This paper will briefly review Fault Tree Analysis methodology and describe how the methodology has been used to support the preparation of a SSMP.