Codified in 40 CFR 63, Subpart LLL, the portland cement maximum achievable control technology (PC MACT) standard poses a significant regulatory hurdle to the cement industry. Facilities subject to its requirements had to complete initial performance testing and develop the first substantial semi-annual monitoring report by Jan. 31, 2003. Promulgated on June 14, 1999, the final PC MACT rule requires portland cement manufacturing plants to meet emissions standards reflecting the application of MACT. The standards were proposed in the Federal Register on March 24, 1998 (63FR14182).

The PC MACT rule applies to all portland cement manufacturing plants at any facility that is classified as either a hazardous air pollutant (HAP) major source (i.e., has the potential to emit more than 10 tpy of any single HAP or more than 25 tpy of any combination of HAPs) or HAP area source (i.e., nonmajor). Exempted from the PC MACT standards, however, are portland cement kilns and in-line kiln/raw mills subject to NESHAP for hazardous waste combustors (HWC); yet, other affected sources at portland cement plants where hazardous waste is burned in the kiln remain subject to PC MACT. Compliance with PC MACT standards requires rigorous operating procedures, monitoring, recordkeeping, and reporting.

Following is a review of the major-source PC MACT compliance program developed for a large, modern, single-line plant. With a relatively simple plant design incorporating abundant electronic data management capabilities, the facility provides the basis for a program representing the base case for PC MACT compliance. For older or more complex major sources, compliance measures are essentially identical, though more extensive and more difficult to execute. Despite EPA's recent clarifications of PC MACT, the rule still contains ambiguities that must be negotiated by plant managers. The facility in question decided to develop its compliance program according to the most stringent, but practicable, interpretation of PC MACT.

Existing procedures at the plant were modified as required to accommodate PC MACT monitoring and recordkeeping requirements. Because many plant personnel must be involved in PC MACT compliance, a team approach was implemented by Trinity Consultants and its client to develop the compliance program. In addition to Trinity staff, the team included the client's operating, maintenance, and environmental staff personnel. Ultimately, every employee in the plant received an appropriate level of training regarding PC MACT compliance, and the compliance program is now included in new employee orientation.

Developing required plans

For each affected source, PC MACT requires administrator approval of an operating and maintenance plan (OMP) prepared and submitted by the facility. Similarly, 40 CFR 63, Subpart A and the PC MACT require preparation of a startup, shutdown and malfunction plan (SSMP) for the same affected sources. Presently, the SSMP must be maintained at the facility, but need not be submitted for approval with the OMP. However, a proposed change to Subpart A could require submission of the SSMP.

The PC MACT rule identifies potentially affected sources at a cement plant; however, all the affected sources are not present at every facility. The plant under consideration included the following sources:

• In-line kiln/raw mill;
• Clinker cooler;
• Finish mill;
• Raw material, clinker, and finished product storage bins;
• Conveying system transfer points (CSTP);
• Bulk loading systems.

Determining Affected Sources

Utilizing detailed process flow diagrams, an equipment identification system, and field inspections, the project team identified more than 800 affected sources at the facility. The most numerous affected sources were the CSTPs, followed by storage bins. Because developing detailed OMPs and SSMPs for each of these affected sources would be impractical, plant operations were divided into fewer than 20 process systems, forming the basis of more manageable OMPs, SSMPs, and support documentation. Consistent with the operation of the plant, the process systems as defined generally began and ended at points in the sequence where material was at rest. All affected sources were included in at least one process system, while transfer points in multiple-use conveying systems appeared in more than one.

Complete, accurate identification of the equipment in each process group, essential to all subsequent work, was the most time-consuming task. To streamline development of OMPs and SSMPs as well as manage copious equipment data, the project team developed standardized guidelines for creating the plans. For example, the team established a procedure for consistently naming affected sources, such as CSTPs, based on adjacent equipment numbers and process flow.

Developing OMPs

After identifying the affected sources and associated equipment, the project team developed an OMP for each source. The OMPs included the following information:

• Procedures for proper operation and maintenance of the process system.
• Procedures for proper operation and maintenance of air pollution control devices (APCD) serving the process system.
• Procedures to be used to periodically monitor affected sources subject to opacity standards.
• Corrective actions to be taken when visible emissions were observed (for the finish mill process system only).

Developing SSMPs

The terms “startup” and “shutdown,” respectively, are defined in Subpart A as “the setting in operation of an affected source” and “the cessation of operation of an affected source” for any purpose. Continuously recording the startup and shutdown of individual affected sources could have been a forbidding task requiring an expanded electronic data acquisition system or dedicated staff members to manually record these events. The project team simplified the task by grouping affected sources and other equipment into rational process systems for which “group starts and stops” of interlocked equipment already existed or could be developed. The SSMPs for each affected source were related to “group starts and stops” and contained the following information:

• Procedures for operating and maintaining the process system during periods of startup, shutdown, and malfunction.
• Corrective actions for malfunctioning process and air-pollution-control equipment in the process system.
• All routine or otherwise predictable continuous monitoring system malfunctions.

If the SSMP has been followed, the PC MACT provides for enforcement relief during periods of startup and shutdown. Thus, it was to the client's advantage to clearly define the commencement and completion of startups and shutdowns and to extend this time period for as long as possible. Some systems started and stopped almost immediately, but others, such as the in-line kiln/raw mill, took several hours to start and stop.

Preparing for optimal Title V permitting

The OMPs and SSMPs for this facility were incorporated by reference into its Title V operating permit. Consequently, any changes to these plans would require the regulatory delays and uncertainty associated with permit modification procedures. In order to minimize these delays, the project team prepared the OMPs and SSMPs in a format containing all information required by the PC MACT and Subpart A, but excluding specific details about how the process systems would start up, operate, shut down, and be maintained. Using this approach, the OMPs and SSMPs will seldom change. The plans reference other documents, including Standard Operating Procedures (SOPs) and Standard Maintenance Procedures (SMPs), that contain appropriate details not referenced in the Title V permit and, furthermore, not subject to initial or subsequent regulatory review and approval. However, the client recognized that the SOPs, SMPs, and other support documentation must be maintained at all times to reflect current conditions in the plant. An inspector has every right to view these documents and expect compliance with the PC MACT requirements.

Standard operating and maintenance

The SOPs contained detailed procedures for startup, operation, shutdown, and malfunction abatement for each process system. Included in the SOPs was a list of all equipment within each system, identification of the affected sources, and a description of the events that defined system startup and shutdown. The project team prepared a separate SMP for each process system, providing the schedule for preventive and routine maintenance for all system equipment. The plant derived additional benefit from the SOPs and SMPs by developing them to serve as personnel training aids.

The project team also developed specialized SOPs for several activities:

• Visible emissions monitoring for the in-line kiln/raw mill and the clinker cooler.
• Continuous opacity monitoring for the in-line kiln/raw mill and the clinker cooler.
• Continuous inlet gas temperature monitoring for the main and bypass particulate matter control devices on the kiln.

To enhance the serviceability of the various plans and procedures, they were separated into regulatory documents (OMPs and SSMPs) and plant documents (SOPs, SMPs, and specialized SOPs). The regulatory documents were further divided into those documents requiring approval (OMPs) and those for which approval was not currently mandated (SSMPs). Facilitating preparation of numerous similarly structured OMPs and SSMPs, the project team used Microsoft Access to complete and electronically store these documents. The team used Microsoft Word to prepare and electronically store all other documents in order to maintain the original and subsequent revisions for the required record retention period.

Recordkeeping and reporting

The PC MACT requires a significant number of recordkeeping activities associated with the startup, shutdown, and malfunction of affected sources, including the following:

• Records of the occurrence and duration of each startup, shutdown, and malfunction of process equipment.
• Records of the occurrence and duration of each malfunction of air-pollution-control equipment.
• Records indicating that malfunctions were corrected as soon as practicable in accordance with the SSMP.
• Records indicating that during periods of startup, shutdown, and malfunction the source operated in accordance with the procedures of the SSMP.
• Records demonstrating that procedures specified in the SSMP were followed.
• Records of actions taken that did not follow the procedures specified in the SSMP.

In developing a PC MACT-compliant recordkeeping process, the project team took advantage of the facility's existing electronic data acquisition systems. These consisted of a computerized process control system, a computerized maintenance management system, and a continuous monitoring system (CMS) data acquisition program.

The team utilized the process-control system to electronically record the date and time of start-up and shutdown for each process and to send an alarm to the system operator if a predefined start-up or shutdown sequence was not followed. This system was also employed to ensure that required monitoring data were recorded and stored for the particulate-matter control devices' inlet thermocouples and the continuous opacity monitoring systems.

Originally, the facility used the maintenance management system solely to generate and track work orders for preventive and routine maintenance activities. The project team altered the system such that work orders would be used to schedule and track PC MACT activities, like CMS calibrations, and to ensure proper maintenance of compliance records. In addition, the team established methods for electronically creating periodic reports and revising plans. Examples of required documentation includes:

• Reporting any actions taken during a startup, shutdown, or malfunction that are not consistent with the SSMP — Subpart A is less stringent than Subpart LLL insofar as it requires reporting only if an emission or parametric exceedance occurs along with an inconsistent action. The actions taken during these events must be reported within two working days, followed by a letter to the appropriate agency within seven working days.
• Reporting malfunctions or other events that affect CMSs and are not addressed by the SSMP — These events must be reported within 24 hours and a follow-up report submitted within two weeks to the appropriate agency.
• Revising the SSMP if it fails to address an event that meets the characteristics of a malfunction and was not included in the SSMP — In this case, the SSMP must be revised within 45 days after the event.

The team created an electronic compliance calendar to ensure that all required initial notifications and periodic reports would be submitted on time, including:

• Notification of initial performance testing for all affected sources.
• Periodic SSM reports.
• CMS performance reports.

Visible emission monitoring

The facility faced an overwhelming data management task in its efforts to fulfill visible emissions monitoring requirements. In order to reduce this burden and optimize environmental staff, the project team designed a system using hand-held electronic devices to streamline and automate the process. Following the electronic assignment of a visible-emissions test to a handheld device by the maintenance management system, plant personnel used these devices to direct and record required visible-emissions test results.

Upon completion of the assigned tests, the results were uploaded into the plant's maintenance management database. As a result, visible-emissions monitoring records are stored for on-demand retrieval and report generation. Additionally, when visible-emissions tests identify a need for corrective action, the maintenance management system automatically generates and tracks a work order.

Conclusion

In its PC MACT compliance efforts, this facility chose to organize and format the OMPs, SSMPs, and supporting documentation to fully meet regulatory requirements and to benefit plant personnel. This facility's systematic approach to PC MACT compliance aims to ensure that none of the regulation's many requirements are overlooked. Thoughtful compliance with PC MACT has resulted in a cleaner and more efficient plant and a more engaged workforce.

Walter L. Greer is Senior Technical Associate and Curtis D. Lesslie is Project Manager for Trinity Consultants, (+1) 972-661-8100.

Maximum Achievable Control Technology (MACT) standards are industry-specific, technology-based standards designed to reduce hazardous air pollutant (HAP) emissions. These standards can require facility owners/operators to meet emission limits, install emission control technologies, monitor emissions and/or operating parameters, and use specified work practices. In addition, the standards typically include recordkeeping and reporting provisions. MACT standards are codified in 40 CFR Part 63.