Comments on Writing O&M Plans

The EPA requires, in 40CFR Subpart LLL, that an Operation and Maintenance Plan and a Startup, Shutdown and Malfunction Plan be written for each cement production facility. The regulations that detail the O&M and SSM plan requirements were written prior to 1994. They have been revised somewhat since then, but have not been significantly changed. Consequently, these requirements, like a lot of what the cement industry saw with respect to the BIF regulations and the early HWC MACT proposals, have the feel of regulations more applicable to purpose built incinerators or boilers than the complex processing attributable to cement production.

The EPA uses the classification of “area” and “major” source to determine the extent of the provisions of the regulations over the various operational equipment in the facility. Frequently the major source category is triggered by emissions such as HCl/Cl₂or Formaldehyde. This classification as a major source then requires the facility to institute a number of testing, monitoring and operations practices, including the O&M and SSM plans, on all parts of the facility. This means extensive monitoring and operational requirements for all sources of particulate emissions, i.e. the raw mill, clinker cooler, finish mill and transfer, bin storage or bagging systems. How such a particulate emissions control scheme is required, when a facility is deemed a major source due to HCl/Cl₂or Formaldehyde emissions, is not evident. If the major source facility sold its clinker to an off-site facility for processing, would that cement grinding facility have to implement the major source requirements for its process? Not as long as it could demonstrate that it was otherwise an area source. It’s not fair, but “that’s life”.

For newer facilities with integrated process control computer systems meeting the monitoring requirements for a major source facility, while troublesome, is a manageable problem. For older facilities without an integrated computer control system, and frequently with a number of smaller processing units rather than the large roller mills typical of newer technology, monitoring the startup, shutdown, malfunctions and O&M plan requirements for every dust emissions source, no matter how small or infrequently used, becomes extremely burdensome if not intrinsically impossible.

Add to this the propensity for state agencies to have the attitude that the more verbose the plan the better and one can easily see a “fine meter” clicking off the dollars for every miss-step waiting on the day an enforcement agent stops by to collect the fee. This is of course the worst scenario. It need not be this way. There are a number of things that can be done to minimize the burden and the potential for fines.

The operations and maintenance plan and startup, shutdown and malfunction plan requirements are detailed in 40CFR 63.6(e). In addition 40CFR 63.1350(a) requires that the application for a part 70 permit include specific information pertaining to a written operation and maintenance plan. Certainly 63.1350(a) does not supercede 63.6(e), but 63.1350(a) does clearly focus the cement facility’s effort on meeting the emission limits and operating/maintaining the pollution control equipment rather than the entire process as implied by the more broadly written operations and maintenance plan requirements of 63.6(e). Nor does 63.1350(a) reinforce the requirements of 63.6(e) (the O&M plan requirements) by specifically referencing 63.6(e). Clearly PC MACT’s focus is on the affected sources and air pollution control devices not whether or not a written procedure has been followed and documented to start or stop an individual conveyor. In addition, the EPA definition for a “malfunction” is certainly very different from that of a cement plant engineer: “Malfunction means any sudden, infrequent, and not reasonably preventable failure of air pollution control monitoring equipment, process equipment, or a process to operate in a normal or usual manner. Failures that are caused in part by poor maintenance or careless operation are not malfunctions.”

Comments on Writing an Operations and Maintenance Plan (O&M Plan)

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