O&M Plan Template For PCMACT

Transcription

1 Crafting an O&M Plan Template For PCMACT Presented to: IEEE IAS/PCACement IAS/PCA Cement Conference April 29, 2015 Presented by: Lynne Spector Zephyr Environmental Corporation

2 Regulatory Background Subpart LLL revised Feb 2013 with proposed amendments Nov 19, 2014 Compliance Date: Sept 9, 2015 O&Mplans must now include ( ): Operating procedures for all affected sources and air pollution control devices (APCDs) required to meet emissions and operating limits Fugitive dust control measures for clinker storage piles Periods of startup and shutdown ( (g)): Corrective actionsfor visible emissions Inspection procedures for kiln combustion system

3 A Very Critical Aspect The O&M Plan will be part of the Title V permit application Failure to comply pywith any provision of the O&M plan.is a violation of the standard. ( (b)) Thus, the specific text used in the O&M plan should be crafted carefully

4 The Challenge Subpart LLL Requirements X Excessive language g or detail X Referencing Irrelevant information (e.g., unrelated outside documents) Focused document that contains pertinent information on how covered equipment is operated and maintained for PC MACT compliance O&M Plan

5 Creating a Matrix Affected Source Standard/ Pollutant Covered Equipment Startup Normal Shutdown Malfunction Malfunction Response Maintenance Records

6 Developing a Matrix The Matrix: Step 1 Define affected sources and associated standards and operating limits: Ei Existingi Major source Kiln, clinker cooler, raw material dryer, raw mill, finish mill, open clinker storage piles Standards (e.g., kiln) General PM D/F Hg HCl THC Been there done that!

7 The Concept of Covered Equipment The Matrix: Step 2 Your first plan specific definition: Any equipment or equipment components that could reasonably impact compliance with an applicable requirement of the PC MACT (found in Step 1) You will specify each piece of covered equipment that will be addressed in the plan Every other part of the plan will flow from here and be parallel l with ihthose identified ifi d

8 Covered Equipment Components include only those which are required for compliance Continuous monitoring systems (CMSs) Emissions: i CEMs (e.g., THC, SO 2 ) Parameter Systems: CPMS (e.g., T, O 2, PM operating parameter limit) Opacity: COMs Other: Weigh Scales APCDs (e.g., baghouse, sorbent systems) Specific equipment of an affected source (e.g., kiln burner) Clinker storage piles

9 Operations The Matrix Step 3 Categories of Operation Startup Operating Modes Shutdown Malfunctions Malfunction Response corrective action in the event of a malfunction of covered equipment t( (which hhave been defined dfi din Step 2)

10 Operations: Startup & Action Verbs Startup: Verify, Inspect Keep language general when developing the matrix General: Verify a clean fuel is used until the kiln reaches a temperature of 1200F Particulate: Inspect baghouse for proper operation D/F: Verify carrier gas CMS is operational and / y g p recording valid data

11 Operations: Normal & Action Verbs Normal Operation: Maintain, Monitor Particulate: Monitor the hourly clinker production rate in accordance with clinker production rate monitoring requirements D/F: Continuously monitor kiln exhaust temperature with kiln exhaust temperature CMS in accordance with D/F monitoring requirements Hg: Maintain mercury control system to ensure compliance with mercury limits.

12 Operations: Shutdown & Action Verbs Shutdown Verify D/F: Verify activated carbon injection rate is within range Particulate: Verify baghouse is operational HCl: Verify lime injection system is operational

13 Operations: Malfunctions Specify operating conditions that indicate a malfunction Failure to, Exceedance of Particulate: Failure to continuously monitor PM parameter with the PM CPMS Particulate: Failure to operate a baghouse properly. D/F: Failure to continuously monitor kiln exhaust temperature with kiln exhaust temperature CMS in accordance with D/F monitoring requirements THC: Exceedance of the THC limit

14 Operations: Malfunctions & Corrective Actions Corrective Actions Re establish, Repair Particulate: Repair malfunctioning baghouse components Particulate: Re establish baghouse operation within acceptable operating range(s) D/F: Repair malfunctioning carrier gas CMS THC: Repair malfunctioning O 2 CMS

15 Filling in Your Matrix Operation Affected Source Standard/ Pollutant Covered Equipment Startup Normal Shutdown Malfunction Malfunction Response Maintenance Records Kiln PM PM CPMS Kiln PM Dust Collector Kiln THC THC CEMS

16 Filling in the Matrix Operation Example: Major Source, Existing, Preheater Kiln Affected Source Standard/Pollutant Covered Equipment Startup Normal Shutdown Malfunction Malfunction Response Corrective Action Kiln D/F Kiln Exhaust T CMS Verify thermocouple is operational Continuously monitor kiln exhaust temperature Verify thermocouple is operational Failure to monitor kiln exhaust temperature Repair malfunctioning kiln exhaust temperature CMS

17 Filling in the Matrix Operation Example continues with controls Affected Source Kiln Standard/Pollutant d/p t t D/F Covered Equipment Startup Normal Shutdown Malfunction Activated Carbon Injection System Verify sorbent feed rate is in range Inspect injection system for proper operation Maintain sorbent feed within range Verify activated carbon sorbent injection feed rate is in range Failure to maintain feed rate within range Mlf ti R Repair malfunctioning sorbent injection system Malfunction Response Corrective Action

18 Filling in Your Matrix Maintenance Affected Source Standard/ Pollutant Covered Equipment Startup Normal Shutdown Malfunction Malfunction Response Maintenance Records Kiln D/F T CMS Kiln PM AC Inj. System

19 Maintenance Categories of Maintenance Preventive Maintenance Repair of covered oeredequipment

20 Maintenance and Action Verbs Specify: Preventive maintenance activity needed to ensure ongoing compliance with PCMACT requirements. Inspect, Replace, Check, Calibrate, Perform

21 Maintenance Examples Particulate Check calibration of clinker monitoring system and recalibrate if out of tolerance Perform PM PCMS QA/QC activities Inspect baghouse per preventive maintenance schedule Repair malfunctioning baghouse components as p g g p necessary

22 Filling in the Matrix Affected Source Standard/Pollutant Covered Equipment... Maintenance Kiln D/F Activated Carbon Injection System... Inspect sorbent injection system per PM schedule Repair malfunctioning system components as necessary

23 Filling in the Matrix Records Affected Source Standard/ Pollutant Covered Equipment Startup Normal Shutdown Malfunction Malfunction Response Maintenance Records Kiln D/F T CMS Kiln PM AC Inj. System

24 Filling in the Matrix Affected Source Pollutant/Standard Covered Equipment.. Activated Carbon. Injection System Records Kiln D/F Activated dcarbon Injection System... Brand and type of sorbent used Maintenance and repair records

25 Turn the Matrix into a Plan 1. Purpose 2. Plant Description i and Scope 3. Definitions 4. Operating Plan a) Kiln b) Clinker cooler c) Raw mill d) Finish mill e) Open Clinker storage piles 5. Maintenance Plan a) Kiln, etc. 6. Records a) Kiln, etc.

26 The Final Touch Examples Appendices Any supporting procedures or blank forms Dust collector preventive maintenance procedure Daily Visible emissions monitoring procedure Visible emissions observation form Annual combustionsystem system inspection form Area map with clinker piles noted Instrument calibrationform Preventive maintenance checklists Instrument calibration form

27 Overall Thoughts Pertaining to O&M Plans Final O&M Plan should be sufficiently detailed to identify the applicable standards and limitations for each piece of covered equipment Definitions need to be specific to the plan Verbiage should indicate actions to be taken Records are used to demonstrate compliance with PC MACT standards/limitations

28 Overall Thoughts Pertaining to O&M Plans (cont.) Do not include anything (e.g., maintenance, corrective action) not specific to showing compliance with PC MACT Do not wholly reference external documents if they contain material not relevant to PC MACT compliance Can reference specific portions of these documents Avoid detailed step by step procedures, stay high level

29 Summary O & M Plan Procedures for proper operation and maintenance of all covered equipment : Includes operation procedures during normal operation, startup and shutdown necessary to show compliance with the PCMACT Includes dfi defined dmalfunctions that could inhibit or prevent compliance with PCMACT and corrective actions during these malfunctions Malfunctions no longer affirmative defense Includes open clinker storage piles

30 Thank you! Lynne Spector Zephyr Environmental Corporation Phone: Visit us at p y and