The Portland Cement Maximum Achievable Control Technology (PC MACT) rule requires cement producers to develop and maintain an Operations and Maintenance (O&M) plan for those portions of their operation covered by the regulation (40 CFR 63.1350(a)). The O&M plan is supposed to cover both the source and the air pollution control device specifically. Operations, inspections, maintenance, and corrective actions are all mentioned in the regulatory description of the O&M plan.

Beyond the regulation and the preamble, there is no U.S. Environmental Protection Agency guidance currently available on O&M-plan development or design. Facilities are generally free to develop the O&M plan in any form they desire, as long as it contains the critical elements that an inspector will be looking for. Different levels of compliance (or stages of development) are possible for a facility's O&M plan.

Level1 Compilation Cement plants generally have a variety of documentation covering O&M issues scattered throughout any number of departments and locations in a plant. This documentation can include everything from a hand-written procedure from a supervisor to equipment manufacturer-supplied operating manuals.

By reviewing the regulatory requirements and existing documentation, Level 1 of compliance can be achieved by gathering these documents together. It may not look pretty or be particularly useful, but as long as there are no glaring gaps, this approach stands a chance of meeting the regulatory requirements at minimum cost.

Level2 Plug the gaps A Level 1 compilation-no matter how complete-is still likely to have gaps, possibly large ones relative to a reasonable interpretation of the rule. The Level 2 approach would then follow with a thorough review of the regulations relative to the compiled information.

As specific additional missing information is obtained from, for example, equipment manufacturers or employees writing from scratch, any gaps in the Level 1 O&M plan would be filled in. The cost of the Level 2 approach could be as much as double that of Level 1, but the chance of a violation would be much lessened. In addition, the less up-to-date and organized records are at a given facility, the more difficult achieving Level 1 and 2 will be.

Level3 Standardization The next level of an O&M plan is to fully standardize the format of all material throughout the documentation. This standardized format will vary considerably from plant to plant, but one of the best approaches is to use standard operating procedures (SOP) since many plants already have such a program in place, particularly in the operations or maintenance areas.

By standardizing the format and ensuring that all regulated areas are covered, the facility will produce a document that is functional as well as compliant. Once standardization is complete, maintaining an up-to-date O&M plan will be easier as departments and supervisors grow accustomed to the format. While this level of compliance will clearly cost more to implement, it could provide considerable payback thanks to improved management and control.

Level4 Comprehensive standardization This level goes beyond the regulatory requirement by standardizing all operations and maintenance procedures throughout the plant whether they are covered by regulation or not. As a natural extension of Level 3, it can be implemented over time.

Additional strategic issues While a Level 1 or 2 effort is the most cost-effective, short-term approach, Levels 3 or 4 may be more appropriate under many circumstances. In addition to the compliance benefits, there are a number of other useful features of such a program.

The Level 3 approach could become the core of an ISO 14000-certification program. By extending the approach to Level 4, ISO 9000 certification would also be within reach. Either Level 3 or 4 lends itself to development in an Intranet database format, which can ease updating and communication issues.

In plants without computer terminal access, laminated hard copies of relevant SOPs can be posted for quick reference. The development of an SOP-based O&M plan also can be tied directly to personnel training programs with management and MSHA-compliance benefits.

Conclusion Circumstances for each plant and each company will be different. Nevertheless, a Level 3 or 4 O&M development effort may be warranted based on benefits that extend well beyond basic regulatory compliance. Development of the O&M plan through each level with an evaluation at each step is also a possible implementation strategy that can help to control costs.