Issues Involving the Development and Implementation of Operation and Maintenance Plans and Startup, Shutdown, and Malfunction Plans to Comply with the Integrated Iron and Steel MACT Rule

摘要

Operation and Maintenance (O & M) Plans and Startup, Shutdown, and Malfunction(SSM) Plans must be prepared and implemented for affected sources under the IntegratedIron & Steel (II&S) Maximum Achievable Control Technology (MACT) rule ("therule"). For most applicable facilities, these requirements became effective on May 22,2006.The requirements for O & M Plans include monthly inspections of equipment importantto the performance of the capture system; specific baghouse inspections under varyingfrequencies; preventative maintenance requirements for venturi scrubbers andelectrostatic precipitators (ESP's); selection and justification of operating limits forcertain capture systems; corrective action procedures for baghouses equipped with bagleak detection systems or continuous opacity monitors (COMS); corrective actionprocedures for venturi scrubbers equipped with continuous parameter monitoring systems(CPMS); and corrective action procedures for ESP's equipped with COMS.SSM Plans must be prepared in accordance with the provisions in §63.6(e)(3). Theseplans must address a program of corrective action for malfunctioning process and airpollution control and monitoring equipment used to comply with the relevant standard.The paper addresses several issues involved in the development and implementation of O& M Plans and SSM Plans for several iron and steel industrial clients. For example,some rulemaking language is not amendable to how certain iron and steelmakingprocesses actually operate, and decisions must then be made to how best address theseissues. Recommendations are provided to how best address these issues from either aregulatory basis or engineering solution approach.