Development and Implementation of Operation and Maintenance Plans and Startup, Shutdown, and Malfunction Plans for the Portland Cement Manufacturing and Hazardous Waste Combustion Industries: Lessons Learned

摘要

Trinity Consultants, Inc. (Trinity) worked with Ash Grove Cement Company (Ash Grove) to prepare for compliance with the National Emission Standards for Hazardous Air Pollutants (NESHAP) regulations applicable to Ash Grove's reconstructed portland cement manufacturing and hazardous waste combustion facility in Chanute, Kansas. These regulations, which are known as the Portland Cement NESHAP (40 CFR Part 63, Subpart LLL) and the Hazardous Waste Combustor NESHAP (40 CFR Part 63, Subpart EEE), require facilities to develop a Startup, Shutdown, and Malfunction Plan (SSMP) and an Operation and Maintenance Plan (OMP) for all process equipment, air pollution control devices, and continuous monitoring systems used to comply with the regulations. Developing the OMPs and SSMPs required identifying all applicable regulatory requirements, developing strategies for compliance with these requirements, and determining the organization of and format for these documents. Trinity and Ash Grove found that one of the most challenging aspects of this process was determining the meaning of ambiguous regulatory requirements, such as the requirement to record startups and shutdowns of each affected source. Implementing the OMPs and SSMPs also was a challenge and involved designing electronic systems to record startups and shutdowns and periodic visible emissions monitoring of affected sources. As other facilities subject to these NESHAPs begin to prepare for compliance, they should be prepared to commit a significant amount of process and environmental personnel resources to the process of developing OMPs and SSMPs and to developing guidelines and templates for this work. Environmental and process personnel should be prepared to encounter ambiguities in the regulations that may not be satisfactorily addressed for some time. Plant operators also should be prepared to adapt plant operations to accommodate the increased recordkeeping and maintenance activities that result from these new regulations.