Start-up, Shutdown and Malfunction Plans equipment, process equipment, or a process to operate in a...

StartStart--up, Shutdown and up, Shutdown and Malfunction PlansMalfunction Plans

Norman L. MorrowNorman L. MorrowFresh Air ConsultingFresh Air Consulting

January 19, 2006January 19, 2006 Fresh Air ConsultingFresh Air Consulting Slide Slide 22

DisclaimerDisclaimer

This presentation provides a summary of This presentation provides a summary of some SS&M provisions and is not a some SS&M provisions and is not a complete description.complete description.Refer to the current Code of Federal Refer to the current Code of Federal Regulations and company legal and Regulations and company legal and regulatory expertise for all regulatory and regulatory expertise for all regulatory and compliance decisioncompliance decision--making.making.


IntroductionIntroduction

Per Per §§63.6(f)(1), 63.6(f)(1), ““The nonThe non--opacity emission opacity emission standards set forth in [Part 63] shall apply at standards set forth in [Part 63] shall apply at all times except during periods of SS&M, ...all times except during periods of SS&M, ...””Instead, during SS&M periods, you must Instead, during SS&M periods, you must achieve the achieve the ““general dutygeneral duty”” requirements to requirements to minimize HAP emissions and correct minimize HAP emissions and correct malfunctions as soon as practicable.malfunctions as soon as practicable.


You must have a StartYou must have a Start--up, Shutdown and up, Shutdown and Malfunction Plan (SSMP) that identifies how Malfunction Plan (SSMP) that identifies how you will accomplish the general duty.you will accomplish the general duty.For Subparts KK (Printing and Publishing) For Subparts KK (Printing and Publishing) and JJJJ (Paper and Other Web Coating), and JJJJ (Paper and Other Web Coating), the SS&M requirements only apply if you the SS&M requirements only apply if you are using addare using add--on controls.on controls.


SS&M and SSMP requirements are in SS&M and SSMP requirements are in Part 63 Subpart A (Part 63 Subpart A (§§63.163.1--63.1663.16) of the ) of the CFR and are referenced from Subparts CFR and are referenced from Subparts KK and JJJJ.KK and JJJJ.–– Originally promulgated 3/16/94.Originally promulgated 3/16/94.–– Significantly amended as recently as 5/30/03.Significantly amended as recently as 5/30/03.–– Additional amendments proposed July 29, Additional amendments proposed July 29,

2005.2005.–– Still in litigation.Still in litigation.

Thus, SS&M requirements do change.Thus, SS&M requirements do change.


The SSMP does not become part of your The SSMP does not become part of your Title V permit, rather your permit must Title V permit, rather your permit must require you to have an SS&M plan.require you to have an SS&M plan.Thus, Title V revision procedures do not Thus, Title V revision procedures do not apply to SSMP changes.apply to SSMP changes.


§§63.6(e)(1)(i) 63.6(e)(1)(i) ““At all times, including periods of At all times, including periods of SS&M, the O/O must operate and maintain SS&M, the O/O must operate and maintain any affected source, including associated air any affected source, including associated air pollution control equipment and monitoring pollution control equipment and monitoring equipment, in a manner consistent with safety equipment, in a manner consistent with safety and good air pollution control practices for and good air pollution control practices for minimizing emissions. minimizing emissions. During a period of During a period of SS&M, this general duty to minimize SS&M, this general duty to minimize emissions requires that the O/O reduce emissions requires that the O/O reduce emissions from the affected source to the emissions from the affected source to the greatest extent which is consistent with safety greatest extent which is consistent with safety

The General DutyThe General Duty


and good air pollution control practices. The and good air pollution control practices. The general duty to minimize emissions during a general duty to minimize emissions during a period of SS&M does not require the O/O to period of SS&M does not require the O/O to achieve emission levels that would be achieve emission levels that would be required by the applicable standard at other required by the applicable standard at other times if this is not consistent with safety and times if this is not consistent with safety and good air pollution control practices, nor does good air pollution control practices, nor does it require the O/O to make any further efforts it require the O/O to make any further efforts to reduce emissions if levels required by the to reduce emissions if levels required by the applicable standard have been achievedapplicable standard have been achieved . . .. . .””

[[Underlined added 5/30/03]Underlined added 5/30/03]


§§63.6(e)(1)(ii) Malfunctions must be 63.6(e)(1)(ii) Malfunctions must be corrected as soon as practicable after their corrected as soon as practicable after their occurrence in accordance with the SS&M occurrence in accordance with the SS&M plan required in paragraph (e)(3) of this plan required in paragraph (e)(3) of this section. To the extent that an unexpected section. To the extent that an unexpected event arises during a SS&M, an O/O must event arises during a SS&M, an O/O must comply by minimizing emissions during such comply by minimizing emissions during such a SS&M event consistent with safety and a SS&M event consistent with safety and good air pollution control practices. good air pollution control practices.


What is a StartWhat is a Start--up?up?

Subpart A defines startSubpart A defines start--up as:up as:–– ““the setting in operation of an affected source the setting in operation of an affected source

or portion of an affected source for any or portion of an affected source for any purpose.purpose.”” ((§§63.2 )63.2 )


What is Shutdown?What is Shutdown?

Subpart A defines shutdown as:Subpart A defines shutdown as:–– ““the cessation of operation of an affected the cessation of operation of an affected

source or portion of an affected source for any source or portion of an affected source for any purpose.purpose.”” ((§§63.2)63.2)


What is a Malfunction?What is a Malfunction?

Subpart A defines malfunction as:Subpart A defines malfunction as:–– ““any sudden, infrequent, and not reasonably any sudden, infrequent, and not reasonably

preventable failure of air pollution control preventable failure of air pollution control and and monitoringmonitoring equipment, process equipment, or a equipment, process equipment, or a process to operate in a normal or usual manner process to operate in a normal or usual manner which causes, or has the potential to cause, the which causes, or has the potential to cause, the emission limitations in an applicable standard to emission limitations in an applicable standard to be exceededbe exceeded. Failures that are caused in part by . Failures that are caused in part by poor maintenance or careless operation are not poor maintenance or careless operation are not malfunctions.malfunctions.”” ((§§63.2)63.2)

UnderlinedUnderlined addedadded 5/30/035/30/03..


Thus, since May 2003, SS&M requirements Thus, since May 2003, SS&M requirements only apply to upsets which are sudden, only apply to upsets which are sudden, infrequent, not reasonably preventable infrequent, not reasonably preventable andandwhich exceed or have the potential to which exceed or have the potential to exceed normal emission limits.exceed normal emission limits.–– The emission limits in Subparts KK and JJJJ The emission limits in Subparts KK and JJJJ

apply to other upsets.apply to other upsets.


In the Subparts KK and JJJJ, the criteria In the Subparts KK and JJJJ, the criteria for identifying an exceedance was for identifying an exceedance was specified in the rule or established by the specified in the rule or established by the source in their monitoring plan source in their monitoring plan submission as part of the compliance submission as part of the compliance status report.status report.


Where the emission limitation is expressed Where the emission limitation is expressed in terms of control requirements (e.g., route in terms of control requirements (e.g., route to oxidizer, destroy 95%), malfunctions to oxidizer, destroy 95%), malfunctions typically only happen if the control does not typically only happen if the control does not meet requirements (e.g., outside 3 hour meet requirements (e.g., outside 3 hour temperature limit) or there is a capture temperature limit) or there is a capture system failure or bypass. system failure or bypass.


What Equipment is Covered What Equipment is Covered by the SS&M Provisions?by the SS&M Provisions?

SS&M requirements apply to:SS&M requirements apply to:––Processes or portions thereof.Processes or portions thereof.––Controls and monitors.Controls and monitors.


SSMP ScheduleSSMP Schedule

The SSMP must be in place by the The SSMP must be in place by the compliance date.compliance date.You must update your SSMP within 45 You must update your SSMP within 45 days if there is a malfunction that is not days if there is a malfunction that is not covered by the existing plan. covered by the existing plan. [[§§63.6(e)(3)(viii)]63.6(e)(3)(viii)]


Otherwise, there is no formal requirement to Otherwise, there is no formal requirement to regularly update the SSMP, regularly update the SSMP, butbut§§63.6(e)(3)(viii) says: 63.6(e)(3)(viii) says: ““The owner or operator may periodically revise The owner or operator may periodically revise

the SS&M plan for the affected source as the SS&M plan for the affected source as necessary to satisfy the requirements of this necessary to satisfy the requirements of this part or to reflect changes in equipment or part or to reflect changes in equipment or procedures at the affected source. procedures at the affected source. ...”...”


And EPA has stated that such updating is And EPA has stated that such updating is a criteria in deciding if a plan is adequate. a criteria in deciding if a plan is adequate. –– ““the general duty to minimize emissions the general duty to minimize emissions

requires that owners or operators review their requires that owners or operators review their SSMP on an ongoing basis and make SSMP on an ongoing basis and make appropriate improvements to ensure that appropriate improvements to ensure that excess emissions are avoided.excess emissions are avoided.”” [68 FR [68 FR 32590, May 30, 2003].32590, May 30, 2003].


EPA takes the position that following an EPA takes the position that following an inadequate SS&M plan does not meet inadequate SS&M plan does not meet the general duty requirement.the general duty requirement.–– ‘‘‘‘.. .. . compliance with an inadequate or . compliance with an inadequate or

improperly developed SSM plan is no improperly developed SSM plan is no defense for failing to minimize emissions.defense for failing to minimize emissions.’’’’(66 FR 16327, March 23, 2001)(66 FR 16327, March 23, 2001)


If the EPA or permitting authority If the EPA or permitting authority determine the procedures in an SSMP do determine the procedures in an SSMP do not adequately address the general duty not adequately address the general duty or are otherwise inadequate they can or are otherwise inadequate they can require you to change them. require you to change them. ((§§63.6(e)(3)(vii))63.6(e)(3)(vii))


SSMP ContentSSMP Content

The only specific SSMP content The only specific SSMP content requirements are in requirements are in §§63.6(e)(3)(i).63.6(e)(3)(i).–– Describe, Describe, in detailin detail, the procedures for , the procedures for

operating and maintaining the source during operating and maintaining the source during SS&M periods.SS&M periods.

–– Describe a program of corrective actions for Describe a program of corrective actions for malfunctioning process, air pollution control malfunctioning process, air pollution control and monitoring equipment.and monitoring equipment.


Remembering that achieving the General Remembering that achieving the General Duty is the goal, the procedures should Duty is the goal, the procedures should focus on minimizing excess emission focus on minimizing excess emission (magnitude and duration) and provide for (magnitude and duration) and provide for immediate corrective actions when immediate corrective actions when malfunctions occur.malfunctions occur.


The level of detail expected in an SSMP is The level of detail expected in an SSMP is unclear, but appears to be significantly less unclear, but appears to be significantly less than identifying individual operator actions. than identifying individual operator actions. Rather identification of broad steps (e.g., Rather identification of broad steps (e.g., route startroute start--up purge streams to the flare, up purge streams to the flare, immediately notify Maintenance of a immediately notify Maintenance of a monitor malfunction) appear appropriate.monitor malfunction) appear appropriate.


Of particular importance is inclusion of Of particular importance is inclusion of any situation where a control device or any situation where a control device or monitor must be bypassed. Identifying monitor must be bypassed. Identifying such events in the plan and including such events in the plan and including steps to minimize emissions during those steps to minimize emissions during those times can meet the general duty, even if times can meet the general duty, even if bypassing is necessary.bypassing is necessary.


While monitors are expected to operate While monitors are expected to operate during SS&M under these subparts, during SS&M under these subparts, unless they are malfunctioning, controls unless they are malfunctioning, controls and monitors may be bypassed when and monitors may be bypassed when safety or monitor integrity requires, if safety or monitor integrity requires, if specified in the SSMP.specified in the SSMP.

Secondary Aluminum NESHAP40 CFR Part 63 Subpart RRR

Example Malfunction Plan for Plant ABC

Final April 3, 2003

Information Transfer and Program Integration DivisionOffice of Air Quality Planning StandardsU.S. Environmental Protection Agency

Research Triangle Park, NC 27711

This is an example of one way to write a malfunction plan. Citations to Federal

requirements found in Title 40 of the Code of Federal Regulations (CFR) are provided for

reference, as applicable.

From: http://www.epa.gov/ttn/atw/alum2nd/alum2pg.html

5-5Loss of Utilities: Power, Gas, Water, etc.

(as applicable to facility equipment)

• Ensure that the situation has become stable and the hazards have been cleared before proceeding further.

• Confirm the system status and note which equipment is off-line or otherwise impaired.

• Notify appropriate maintenance or other responsible personnel (see Section 5-8).

• Respond to correct or repair the malfunction in a safe, efficient and timely manner as soon as it is practicable, for example:

a Call power company or 911 if power failure seems plant-wide; if not, trace power failure from equipment to power source;

b Check source of gas or water;c Trace gas or water line from equipment to the source and determine whether any leaks or breaks

in line exist; andd Repair any breaks or leaks that are found in the utility system at the facility.

• Suspend operations as soon as practicable until compliance can be assured if failure cannot be repaired in a timely manner.

• Record pertinent information (see Section 5-7) on record sheets (see Section 5-9) to log date, time, duration, cause of malfunction, and corrective action taken. Make sure to record whether the Malfunction Plan was followed for each event.

• Submit the Malfunction Report Form to the appropriate Plant ABC personnel (see Section 5-8).

Plant ABC Malfunction Plan

This is an example malfunction plan and it is not intended to be used for regulatory purposes. Citations to Federal requirements found in Title 40 of the CFR are provided for reference, as applicable.

5-6Sudden and Unavoidable Failure of Equipment*

(not due to poor operation or maintenance)

• Ensure that the situation has become stable and the hazards have been cleared before proceeding further.

• Confirm the system status and note which equipment is off-line or otherwise impaired.

• Notify appropriate maintenance or other responsible personnel.

• Respond to correct or repair the malfunction in a safe, efficient and timely manner as soon as it is practicable, for example:

a Replace deficient part, if spares are available; andb Call maintenance for assistance if needed.

• Suspend operations as soon as practicable until compliance can be assured if failure cannot be repaired in a timely manner.

• Record pertinent information on record sheets (attached) to log date, time, duration, cause of malfunction, and corrective action taken.

• Record whether the Malfunction Plan was followed for each event.

* Such as sudden fan failure, lime feeder failure, broken salt feeder, numerous simultaneous bag breaks/leaks, etc.



5-9Plant ABC Malfunction Report Form

Date:Malfunctioning device:Time malfunction began (estimated):Time malfunction ended:Total duration of malfunction: hours minutesSuspected cause of malfunction:Corrective action(s) taken:Was this malfunction covered by the Malfunction Plan?Yes � No�

Were your actions consistent with the Plant ABC Malfunction Plan during the malfunction? Yes � No�

If your actions were not consistent with the Plant ABC Malfunction Plan during the malfunction, explain why you took other actions:

Have you reported your actions that were not consistent with the Plant ABC Malfunction Plan to the proper authorities by telephone or FAX within 2 working days of the event and sent a letter within 7 working days of the event?

Do you believe that any excess emissions and/or parameter monitoring exceedances occurred during the malfunction? Yes � No�

Which, if any, units were shut down because of malfunction:

Do you have any suggestions for future events like the one that occurred?

Your name:Your signature:Name of Supervisor on duty during malfunction:Comments of Supervisor:

Signature of Supervisor:




Under the May 2003 amendment of Under the May 2003 amendment of §§63.6(e)(3)(v), 63.6(e)(3)(v), SSMPsSSMPs are available to are available to the public on request to the permitting the public on request to the permitting authority.authority.On July 29, 2005 EPA proposed to On July 29, 2005 EPA proposed to remove this provision and rely on local remove this provision and rely on local authority if there is a need for the public authority if there is a need for the public to review to review SSMPsSSMPs..

Public Review of Public Review of SSMPsSSMPs


Use of Standard Operating Use of Standard Operating Procedures (SOPs)Procedures (SOPs)

Use of SOPs (or other existing procedures) Use of SOPs (or other existing procedures) is allowed, instead of having a separate is allowed, instead of having a separate SSMP. (SSMP. (§§63.6(e)(3)(vi))63.6(e)(3)(vi))..While low burden, there are several While low burden, there are several downsides to using this approach that downsides to using this approach that should be considered.should be considered.


–– SOPs may not focus on minimizing excess SOPs may not focus on minimizing excess emissions and thus could be considered emissions and thus could be considered inadequate.inadequate.

–– The chance of deviating from an SOP’s The chance of deviating from an SOP’s typically detailed requirements is high.typically detailed requirements is high.

–– Recordkeeping to assure the plan is Recordkeeping to assure the plan is followed could be extensive.followed could be extensive.


A Typical SSMP OrganizationA Typical SSMP Organization

Cover page with approval signature(s) and Cover page with approval signature(s) and date.date.–– While not required, approval signatures help While not required, approval signatures help

obtain operator buyobtain operator buy--in and verify the in and verify the authenticity of the plan and management authenticity of the plan and management support of the plan.support of the plan.


Affected facility identification and Affected facility identification and identification of NESHAP(s) addressed identification of NESHAP(s) addressed by the plan.by the plan.Process overview and identification of Process overview and identification of regulated emission points and their regulated emission points and their control devices and monitors.control devices and monitors.


Description of startDescription of start--up and shutdown up and shutdown periods and tabulation of procedures periods and tabulation of procedures that will be followed.that will be followed.Description of potential malfunctions Description of potential malfunctions and tabulation of procedures that will be and tabulation of procedures that will be followed.followed.


Recordkeeping requirements and forms.Recordkeeping requirements and forms.Reporting requirements and forms.Reporting requirements and forms.Appendices:Appendices:–– Checklists (if used).Checklists (if used).–– Personnel and notification lists.Personnel and notification lists.–– Optional content itemsOptional content items


Recordkeeping and reporting information Recordkeeping and reporting information and forms are often included in and forms are often included in SSMPsSSMPs, , but can easily be put into other but can easily be put into other documents that are more clearly not documents that are more clearly not subject to the SSM plan administrative subject to the SSM plan administrative provisions.provisions.


It is also common to include lists of It is also common to include lists of responsible and contact individuals, phone responsible and contact individuals, phone lists, etc. in lists, etc. in SSMPsSSMPs–– Since changes to such lists are common, these Since changes to such lists are common, these

too, may be best contained in other documents.too, may be best contained in other documents.–– Similarly, recordkeeping and reporting associated Similarly, recordkeeping and reporting associated

with changes can be minimized by identifying with changes can be minimized by identifying positions rather than individuals. positions rather than individuals.


Recordkeeping OverviewRecordkeeping Overview

Records are required to:Records are required to:–– Identify SS&M periods.Identify SS&M periods.–– Identify exceedance periods.Identify exceedance periods.–– Confirm that the SSMP was followed.Confirm that the SSMP was followed.–– Identify cases where the SSMP was not Identify cases where the SSMP was not

followed.followed.–– Provide other required information.Provide other required information.–– Provide information for reports.Provide information for reports.


A checklist to be filled out by Operations is A checklist to be filled out by Operations is usually the starting point for meeting the usually the starting point for meeting the record requirements and serves as the record requirements and serves as the primary event record.primary event record.The checklist is often included in the SSMP The checklist is often included in the SSMP and thus its use and revision is subject to and thus its use and revision is subject to the SSMP requirements.the SSMP requirements.


Summary of Subpart A SS&M Summary of Subpart A SS&M RecordsRecords

§63.6(e)(3)(v) §63.6(e)(3)(v) –– You must keep a copy of your SSMP for as You must keep a copy of your SSMP for as

long as you continue to operate your long as you continue to operate your NESHAP process plus five years. NESHAP process plus five years.

–– If your SSMP is revised, you must also If your SSMP is revised, you must also keep the previous version(s) for five years. keep the previous version(s) for five years.


§63.6(e)(3)(iii) §63.6(e)(3)(iii) –– You must keep records for every SS&M You must keep records for every SS&M

event to demonstrate if you followed the event to demonstrate if you followed the SSMP and to record any actions not SSMP and to record any actions not consistent with the SSMP. consistent with the SSMP.

Typically a checklist is used.Typically a checklist is used.


§§63.10(b)63.10(b)–– (i) Record the occurrence and duration of (i) Record the occurrence and duration of

each SS&M of process equipment; each SS&M of process equipment; –– (ii) Record the occurrence and duration of (ii) Record the occurrence and duration of

each malfunction of required air pollution each malfunction of required air pollution control and monitoring equipment; control and monitoring equipment;


–– (iv) Record actions taken during periods of (iv) Record actions taken during periods of SS&M which are different from the SSMP SS&M which are different from the SSMP procedures;procedures;

–– (v) Record information necessary to (v) Record information necessary to demonstrate conformance with the SSMP demonstrate conformance with the SSMP when all actions taken are consistent with when all actions taken are consistent with the procedures specified in the plan.the procedures specified in the plan.


§§63.10(c) For Sources Monitored with a 63.10(c) For Sources Monitored with a Continuous Monitoring System Continuous Monitoring System –– (1) Record of all required CMS measurements (1) Record of all required CMS measurements

(including monitoring data recorded during (including monitoring data recorded during unavoidable CMS breakdowns and outunavoidable CMS breakdowns and out--ofof--control periods)control periods);;


ReportingReporting

The May 2003 subpart A amendment of The May 2003 subpart A amendment of §§63.6(e)(3)(viii) requires, that you report 63.6(e)(3)(viii) requires, that you report in your next semiin your next semi--annual report if you annual report if you have revised your SSMP.have revised your SSMP.


Also, if the revisions change the scope Also, if the revisions change the scope of activities considered to be SS&M, or of activities considered to be SS&M, or change how any emission limit, work change how any emission limit, work practice requirement, or other practice requirement, or other requirement in your NESHAP applies, requirement in your NESHAP applies, the revised SSMP is not effective until the revised SSMP is not effective until the permitting authority has received the permitting authority has received written notice from you describing the written notice from you describing the revisions.revisions.


§63.10(d)(5)(i) requires a SS&M periodic §63.10(d)(5)(i) requires a SS&M periodic report and specifies its content, schedule, report and specifies its content, schedule, etc. etc. –– For Subparts KK and JJJJ this report may be For Subparts KK and JJJJ this report may be

included with the periodic compliance report. included with the periodic compliance report. –– Where all SS&M events were handled Where all SS&M events were handled

consistent with the SSMP, the report must consistent with the SSMP, the report must include a statement to that effect.include a statement to that effect.


–– Where actions for Where actions for anyany event were not event were not consistent with the SSMP that must be consistent with the SSMP that must be reported.reported.

Whether or not there were exceedances.Whether or not there were exceedances.–– Specific information listed in Specific information listed in §§63.10(d)(5) 63.10(d)(5) is is

required for each malfunction that occurred required for each malfunction that occurred during the reporting period.during the reporting period.

–– Note: Each SS&M reportable will also need to Note: Each SS&M reportable will also need to be reviewed for possible reporting under Title be reviewed for possible reporting under Title V. V.


§§63.10(d)(5)(ii) requires 63.10(d)(5)(ii) requires ““immediateimmediate””reporting where there was an reporting where there was an exceedance exceedance andand the SSMP was not the SSMP was not followed.followed.–– Immediate reporting means a call or fax Immediate reporting means a call or fax

within 2 days, followed by a letter within 7 within 2 days, followed by a letter within 7 days.days.

Start-up, Shutdown and Malfunction Plans equipment, process equipment, or a process to operate in a...

Documents

Transcript of Start-up, Shutdown and Malfunction Plans equipment, process equipment, or a process to operate in a...