HWC MACT Plan Templates
Prepared By Elizabeth M. Drake and Gerald J. Drake
Compliance Strategies & Solutions, Inc.
1301 Regents Park Drive, Suite 203
Houston, Texas 77058
Phone (281) 286-1861
Fax (281) 286-0325
ABSTRACT
The compliance date for the Phase I Hazardous Waste Combustor Maximum Achievable Control Technology (HWC MACT) regulation is September 30, 2003. As this date approaches, affected sources will be developing and implementing required plans and programs for complying with the HWC MACT regulations. The following are two of the required plans that must be developed and implemented by the compliance date:
The requirements for each of these plans are contained in various locations throughout the Title 40 Code of Federal Regulations (CFR) Subpart A and Subpart EEE regulations. The authors have dissected these regulations and compiled the applicable requirements for each of these plans into separate documents. These documents have been organized into templates that can be used to develop the specific plan. The templates can also be used as a basis for assessing the completeness of existing plans.
The procedure used to develop the templates will be presented in this paper. In addition, a general outline for each template will be presented along with a summary of the required information. The methodology presented can be used to develop templates for the remaining required HWC MACT plans.
INTRODUCTION
The compliance date for the Phase I Hazardous Waste Combustor Maximum Achievable Control Technology (HWC MACT) regulation is September 30, 2003. Sources affected by the HWC MACT regulations are required to develop and implement certain plans and programs by the compliance date. The HWC MACT plans can be developed by the facility, by a contractor, or a joint effort between the facility and contractor. Regardless of the entity that develops the specific plan, each plan must satisfy all the regulatory requirements, must be complete, and must be appropriately documented.
This paper will describe a methodology that was used to develop a template for an Operation and Maintenance Plan (O&M Plan) and a Feedstream Analysis Plan (FAP). The methodology employed to develop the templates can be applied to other HWC MACT required plans and programs. The developed templates are designed to ensure that all requirements are addressed. Therefore, when properly implemented, the templates will produce complete plans that can provide the appropriate documentation for demonstrating compliance with the HWC MACT requirements.
DEVELOPING THE TEMPLATES
When developing any plan that is used to document compliance with a set of requirements, the first step is to ensure that you have the most recent set of requirements and to document the version of regulations used in developing the template. For the purposes of template development, an electronic version of the requirements is preferred. One location for obtaining an electronic version of the HWC MACT regulations is the electronic Code of Federal Regulations (e-CFR) maintained by the National Archives and Records Administration at the following website: http://www.access.gpo.gov/ecfr/. Other sources of electronic regulations are available, but the e-CFR version is free-of-charge. Note that the authors have found errors in the e-CFR regulations, and recommend that the accuracy of the source be verified prior to use.
Electronic versions of the 40 CFR Part 63 Subpart A and Subpart EEE regulations were obtained and used for developing the template. The electronic regulations were reviewed, and the provisions associated with the templates being developed were copied and pasted into separate files for the individual templates. Each reference contained in the regulations was followed in order to obtain all the applicable requirements for each template. It was important to follow all references to their conclusion in order to facilitate the development of complete and accurate plans. The regulatory citations were maintained with each provision that was copied and pasted to serve as documentation that all applicable provisions were addressed by the templates and the plans. Once all regulatory provisions were added to the appropriate template file, the authors saved these files as documentation and used copies to actually generate the templates.
The template files containing all of the applicable regulations were then reviewed to determine the major sections for the templates and plans. Examples of major sections include engineering description, inspection procedures, frequency of analysis, etc. In all cases, an introductory section containing the purpose and scope of the plan was warranted. Also, plans typically contained a cover page, table of contents, lists of tables and figures, acronym list, and appendices, as appropriate. The remaining sections of the template were primarily dictated by the requirements.
After the major sections of the templates were determined, the regulations were cut and pasted into their associated section of the template. It should be noted that some regulatory provisions addressed multiple sections of the template and were pasted into all applicable sections. Once the applicable requirements were incorporated into the appropriate sections, each section was reviewed, organized, and condensed into the final version. The template was then ready to be used to develop the site-specific plan or review an existing plan to ensure that it meets the requirements.
OPERATION AND MAINTENANCE PLAN TEMPLATE
The following template was developed using the above methodology and summarizes the HWC MACT requirement related to Operation and Maintenance Plans.
1.0 Introduction
This section should introduce the reader to the facility by providing general facility information, e.g., name, address, contact, EPA ID number, etc., and a description, e.g., products produced, type of unit, location, etc. The general regulations related to O&M Plans should be referenced as 40 CFR 63.6(e) and 63.1206(c)(7).
2.0 Facility Description
This section should describe the specific units and components required to be addressed by the O&M Plan. Pursuant to 40 CFR 63.1206(c)(7)(i)(A), the O&M Plan is required to address “all components of the combustor, including associated pollution control equipment, that could affect emissions of regulated hazardous air pollutants.” This section should list and briefly describe the components of the combustor unit that the facility considers affecting emissions of HAPs. For incinerators and lightweight aggregate kilns (LWAKs) with baghouses, the regulations in 40 CFR 63.1206(c)(7)(ii) require specific information on the bag leak detection system to be included in the O&M Plan. Specific bag leak detection system information that can be included in this section include the manufacturer’s certification of performance (capable of measuring 1.0 milligram particulate matter per actual cubic meter), system output, system alarms, and installation location.
3.0 Operating Procedures
40 CFR 63.1206(c)(7) requires the O&M Plan to include “detailed procedures for operation” of the combustor and air pollution control equipment (APCE) and that operations be “consistent with good air pollution control practices”. 40 CFR 63.6(e) requires the facility to operate the affected source and associated APCE and monitoring equipment “consistent with safety and good air pollution control practices”. Also, 40 CFR 63.1206(c)(7)(ii)(A)(4) requires the bag leak detection system to be operated consistent with available written EPA guidance or, if not available, the manufacturer’s written specifications. An available EPA guidance is the Fabric Filter Bag Leak Detection Guidance1. This section should include the procedures for operating the affected components listed in Section 2.0, including the combustor, APCE, and bag leak detection system. Alternatively, this section should reference the location of the procedures associated with operating the affected components.
4.0 Inspection Procedures
40 CFR 63.1206(c)(7) requires the O&M Plan to include “detailed procedures for… inspection” of the combustor and APCE. This section should include the procedures for inspecting the affected components listed in Section 2.0. Alternatively, this section should reference the location of the procedures associated with inspecting the affected components.
5.0 Maintenance Procedures
40 CFR 63.1206(c)(7) requires the O&M Plan to include “detailed procedures for… maintenance” of the combustor and APCE. This section should include the procedures for maintaining the affected components listed in Section 2.0. Alternatively, this section should reference the location of the procedures associated with maintaining the affected components. In addition, 40 CFR 63.1206(c)(7)(ii)(A)(6) states that after the initial adjustment of the bag leak detection system, the facility cannot “adjust the sensitivity or range, averaging period, alarm set points, or alarm delay time, except as detailed in the operation and maintenance plan.” Therefore, for incinerators and LWAKs with baghouses that are required to install a bag leak detection system, the O&M Plan must include information on adjusting the system.
6.0 Corrective Measures
40 CFR 63.1206(c)(7) requires the O&M Plan to include “detailed procedures for… corrective measures” for the combustor and APCE. This section should include the corrective measure procedures for the affected components listed in Section 2.0. Alternatively, this section should reference the location of the corrective measure procedures associated with the affected components. In addition, 40 CFR 63.1206(c)(7)(ii)(B) states that the corrective measures plan included in the O&M Plan must specify the procedures that will be followed when a bag leak detection system alarm occurs. Therefore, for incinerators and LWAKs with baghouses that are required to install a bag leak detection system, the O&M Plan must include the procedures that will be followed when a bag leak detection system alarm occurs.
7.0 Pumpable Waste Feed Ramp Down Procedure
40 CFR 63.1206(c)(3)(viii) allows facilities that feed pumpable waste to ramp down the waste feed for a period of time not to exceed one minute when an automatic waste feed cut-off (AWFCO) occurs. This provision does not apply if the AWFCO was related to the minimum combustion chamber temperature, maximum hazardous waste feed rate, or the hazardous waste firing system operating limits. If a facility elects to ramp down the waste feed, they are required to document the procedures in the O&M Plan. Therefore, the O&M Plan must include the procedures for those facilities that elect to ramp down the waste feed.
8.0 Recordkeeping
Pursuant to 40 CFR 63.1206(c)(7)(i)(D), the O&M Plan is required to be placed in the facility operating record. Also, pursuant to 63.6(e)(1)(i) the Agency may review the facility operation and maintenance records in order to determine that the operation and maintenance procedures are being used. Therefore, this section should describe the records that the facility will maintain as part of the operation and maintenance program for the affected units. Such records can include inspection logs, operating logs, maintenance work requests, preventive maintenance documents, etc. In addition, 40 CFR 63.10(b) requires the facility to maintain the necessary information that can be used to demonstrate compliance with any of the HWC MACT requirements. Records are required to be retained for at least 5 years with the most recent 2 years retained onsite. The required records can be maintained on microfilm, computer, floppy discs, magnetic tape, or microfiche. The type of records and their locations should be discussed in this section.
FEEDSTREAM ANALYSIS PLAN TEMPLATE
The following template was developed using the methodology discussed and summarizes the HWC MACT requirements related to Feedstream Analysis Plans.
1.0 Introduction
This section should introduce the reader to the facility by providing general facility information, e.g., name, address, contact, EPA ID number, etc., and a description, e.g., products produced, type of unit, location, etc. The general regulations related to a FAP should be referenced as 40 CFR 63.1209(c)(2).
2.0 Feedstream Description
Pursuant to 40 CFR 63.1209(c)(1), an analysis of each feedstream that is sufficient to document compliance with the applicable feed rate limits must be performed. Feedstream is defined as “any material fed into a hazardous waste combustor, including, but not limited to, any pumpable or nonpumpable solid, liquid, or gas.” Based on this definition, affected feedstreams can include auxiliary fuels, e.g., natural gas, fuel oil, diesel fuel, coal, etc., hazardous wastes, non-hazardous wastes, raw material, and other streams, e.g., atomization air, combustion air, vent streams, etc., that are fed to the combustor. This section should discuss the different types of feedstreams that can be fed to the unit.
3.0 Feedstream Analysis Parameters
40 CFR 63.1209(c)(2)(i) requires the FAP to include the parameters that each feedstream will be analyzed to ensure compliance with the operating parameter limits. If a method other than direct analysis of the feedstream is used, e.g., results supplied by others, published data, documented data, etc., these methods must also be described in the FAP. Therefore, this section should discuss the source of the data that will be used for each feedstream to ensure compliance with the operating parameter limits for the combustor.
4.0 Methods for Documenting Compliance
Pursuant to 40 CFR 63.1209(c)(2)(iii), the FAP must discuss how the analysis results will be used to document compliance with the applicable feed rate limits. Typically, this is done by knowing the concentration of the constituent in each feedstream, monitoring the flow rate by use of a continuous monitoring system (CMS), and summing over all the feedstreams. However, many other methods can be used when determining compliance with the feed rate limits. An example included in the regulations is analyzing materials prior to blending and not after blending, in which case the FAP must describe how compliance will be demonstrated for the blended materials. In addition, statistical methods may be used for determining the concentration of a constituent in a feedstream. If the Maximum Theoretical Emission Calculation (MTEC) method is used for compliance with the mercury, semivolatile metal, low volatile metal, and/or hydrochloric acid/chlorine gas emission limits (see 40 CFR 63.1206(b)(9), (10), (14), and (15)), this method should be discussed. The method for handling non-detectable quantities should also be discussed. Furthermore, if you are waiving the monitoring of metals or chlorine in certain feedstreams, e.g., natural gas, combustion air, vapor recovery streams, etc. (see 40 CFR 63.1209(c)(5)), the expected level of each constituent in these feedstreams and how that will be used to determine compliance should be discussed.
5.0 Analytical Methods
Pursuant to 40 CFR 63.1209(c)(2)(iv), the analytical test methods to be used must be identified in the FAP. In addition, 40 CFR 63.1208(b)(8) states that any reliable analytical method can be used to determine the feedstream concentrations of metals, chlorine, and other constituents if the method will produce unbiased, precise, and representative results for the feedstream.
6.0 Sampling Methods
Pursuant to 40 CFR 63.1209(c)(2)(v), the feedstream sampling methods to be used to obtain representative samples must be identified in the FAP. In addition, 40 CFR 63.1208(b)(8) states that any reliable sampling method can be used to determine the feedstream concentrations of metals, chlorine, and other constituents if the method will produce unbiased, precise, and representative results for the feedstream.
7.0 Sample Handling and Preservation
Although not specifically identified in the HWC MACT regulations, sample handling and preservation procedures should be included in the FAP. This section should include discussions on sample preservation, sample containers, holding times, chain-of-custody procedures, packaging, shipping, etc. It should be noted that the HWC MACT regulations reference the SW-846 sampling and analysis methods, many of which include sample handling and preservation criteria.
8.0 QA/QC Objectives and Procedures
Although not specifically identified in the HWC MACT regulations, quality assurance and quality control (QA/QC) objectives and procedures should be included in the FAP. The objectives and procedures should include targeted precision and accuracy limits and how they will be demonstrated. It should be noted that the HWC MACT regulations reference the SW-846 sampling and analysis methods, many of which include QA/QC objectives and criteria.
9.0 Frequency of Analysis
40 CFR 63.1209(c)(2)(vi) requires the FAP to include the frequency that the initial analyses will be reviewed or repeated to ensure that the results being used to demonstrate compliance are accurate and up-to-date.
10.0 Recordkeeping
The FAP is required to be placed into the facility operating record pursuant to 40 CFR 63.1209(c)(2). In addition, 40 CFR 63.10(b) requires the facility to maintain the necessary information that can be used to demonstrate compliance with any of the HWC MACT requirements. Records are required to be retained for at least 5 years with the most recent 2 years retained onsite. The required records can be maintained on microfilm, computer, floppy discs, magnetic tape, or microfiche. The type of records and their locations should be discussed in this section.
CONCLUSIONS
A methodology was presented for developing templates using an electronic version of the requirements to produce complete and accurate plans for complying with the regulations. Templates were developed and summarized for the HWC MACT Operation and Maintenance Plan and Feedstream Analysis Plan. The presented methodology may be used to develop templates for other HWC MACT plans and programs. The developed templates may be used to develop the actual plans and programs, or to review existing plans to ensure that they meet all HWC MACT requirements.
REFERENCES
1. Office of Air Quality Planning and Standards (OAQPA) Fabric Filter Bag Leak Detection Guidance, U.S. EPA, EPA-454/R-98-015, September 1997.
Feedstream Analysis Plan
Hazardous Waste Combustor MACT
HWC MACT Plans
Operation and Maintenance Plan
Templates