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How to Prepare a Startup, Shutdown,
Malfunction Plan
for Collection and Control Systems at
Municipal Solid Waste Landfills
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EPA-456/R-03-006
December 2003
How to Prepare a Startup, Shutdown, Malfunction Plan
for
Collection and Control Systems at
Municipal Solid Waste Landfills
By:
Joe Fanjoy
Eastern Research Group, Inc.
Morrisville, North Carolina
Prepared for:
Mary Ann Warner, Project Officer
Information Transfer and Program Integration Division
Contract No. 68-D-02-0079
Work Assignment Numbers 1-03 and 2-04
U.S. Environmental Protection Agency
Office of Air Quality Planning and Standards
Information Transfer and Program Integration Division
Research Triangle Park, North Carolina
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HOW TO PREPARE A
STARTUP, SHUTDOWN, MALFUNCTION PLAN
FOR
COLLECTION AND CONTROL SYSTEMS AT
MUNICIPAL SOLID WASTE LANDFILLS
Purpose: This document explains how to prepare a startup, shutdown, malfunction plan for municipal
solid waste (MSW) landfills. This document is provided for guidance only and should not be used for
regulatory interpretation or enforcement purposes. See 40 CFR part 63, subparts A and AAAA for the
regulatory requirements for MSW landfills to control hazardous air pollutants.
Intended users: Owners and operators of municipal solid waste landfills should use this document to
help determine what to include in their startup, shutdown, malfunction plan. Landfill owners who are
required to install a landfill gas collection and control system must prepare a startup, shutdown,
malfunction plan for that collection and control system.
NOTE
This guidance is based on the landfills NESHAP (40 CFR part 63, subpart
AAAA) as promulgated on January 16, 2003. It is also based on the Part 63
General Provisions (subpart A) as amended on May 30, 2003 (68 FR 32586).
These amendments include provisions governing Startup, Shutdown,
Malfunction plans and the changes made are reflected in this document. For
landfills, the primary concern is with malfunction of the landfill gas collection
and control system and associated monitoring equipment, because the landfill
itself is not a typical "process" that can be started up or shut down.
The EPA is considering how these May 30, 2003 amendments to the part 63
General Provisions affect SSM Plans for landfills. We plan to amend this
SSM Plan guidance document in the future if any clarifications are made to
the landfills NSPS and NESHAP that would affect the contents of the SSM
Plan. To obtain the latest regulatory information on the landfills NSPS and
NESHAP, see www.epa.gov/ttn/atw/landfill/landflpg.html.
53
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TABLE OF CONTENTS
BACKGROUNDS
What requires me to write a startup, shutdown, malfunction plan?3
What is meant by startup, shutdown, and malfunction?3
How does startup, shutdown, and malfunction apply to landfills?3
What is the purpose of a startup, shutdown, malfunction plan?3
When must I develop my startup, shutdown, and malfunction plan?4
DEVELOPING YOUR LANDFILLS SSM PLAN4
What information should my SSM plan contain?4
To which operations at my MSW landfill does the SSM plan apply?5
Should I develop tools for meeting the SSM recordkeeping provisions??
IMPLEMENTING YOUR LANDFILLS SSM PLANS
When am I required to use the SSM plan?8
Who sees the SSM plan and how long should I keep it?8
When do I need to modify my SSM plan?8
Do I have to submit any SSM reports?9
Can I combine my SSM reports with other reports?10
APPENDIX A. EXAMPLE ELEMENTS OF AN SSM PL AN A-1
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BACKGROUND
What requires me to write a startup, shutdown, malfunction plan?
Sections 63.1955(b) and 63.1960 of subpart AAAA and §63.6(e)(3)(i) of subpart A, General Provisions,
require owners or operators of landfills who are required by 40 CFR 60.752(b)(2) of subpart WWW, the
landfills Federal plan, or an EPA approved and effective State or Tribal plan to install a collection and
control system to develop and implement a written startup, shutdown, and malfunction plan (SSM Plan).
What is meant by startup, shutdown, and malfunction?
Section 63.2 of the General Provisions defines these terms as follows:
•Startup is defined as "the setting in operation of an affected source or portion of an affected source for
any purpose."
•Shutdown is defined as "the cessation of operation of an affected source or portion of an affected
source for any purpose."
•Malfunction is defined as "any sudden, infrequent, and not reasonably preventable failure of air
pollution control and monitoring equipment, process equipment, or a process to operate in a normal or
usual manner which causes, or has the potential to cause, the emission limitations in an applicable
standard to be exceeded. Failures that are caused in part by poor maintenance or careless operation are
not malfunctions."
How does startup, shutdown, and malfunction apply to landfills?
The Part 63 General Provisions, which define startup, shutdown, and malfunction, were written for
typical industrial or manufacturing sources and associated processes. Many of these sources and
processes may, at times, shutdown entirely for clean-out, maintenance, or repairs, then restart the
operation. The requirement to prepare an SSM plan is intended to prevent excess emissions when the
source or process malfunctions, ceases operation, or commences operation.
A landfill, however, is not a typical affected source that can be started up or shut down. Landfill
emissions are produced by a continuous biological process that cannot be stopped or shut down. For the
landfills SSM plan, the primary concern is with malfunction of the landfill gas collection and control
system and associated monitoring equipment, not with the startup, shutdown, or malfunction of the
entire source. Therefore, this guidance and the example elements of an SSM plan (Appendix A) focus
primarily on malfunction of the gas collection system, gas control system, and gas treatment system.
What is the purpose of a startup, shutdown, malfunction plan?
The purpose of the plan is to ensure that you:
•Operate and maintain your affected landfill collection and control system during a startup, shutdown,
and malfunction event in a manner consistent with safety and good air pollution control practices for
minimizing emissions to the levels required by the relevant standards (§63.6(e)(3)(i)(A)).
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•Are prepared to correct malfunctions as soon as practicable after their occurrence to minimize excess
emissions (§63.6(e)(3)(i)(B)).
•Reduce the reporting burden associated with periods of startup, shutdown, malfunction and the
corrective actions taken to restore the malfunctioning equipment to its normal or usual manner of
operation (§63.6(e)(3)(i)(C)).
When must I develop my startup, shutdown, and malfunction plan?
•New landfills must develop an SSM Plan by the date the landfill is required to install a collection and
control system under the NSPS (§63.1945(c)).
•Existing landfills must develop an SSM Plan by the date the landfill is required to install a collection
and control system by the emission guidelines, the landfills Federal plan, or the EPA approved and
effective State or Tribal plan that applies to the landfill. If an existing landfill is already required to
have a collection and control system, then the SSM Plan must be developed by 1 year after the NESHAP
promulgation date, i.e., by January 16, 2004 (§63.1945(d), (f)).
DEVELOPING YOUR LANDFILLS SSM PLAN
What information should my SSM plan contain?
For the purposes of subpart AAAA, the SSM Plan should address the landfill gas collection system and
the control system, as well as the required continuous parameter monitoring systems related to the
control system (§§63.6(e)(3), 63.1960).
The SSM Plan should describe in detail the following (§63.6(e)(3)):
•Procedures for operating and maintaining the collection and control equipment during startup,
shutdown, and malfunction events.
•Program to adequately provide corrective actions to repair the malfunctioning equipment as soon as
practicable and to minimize excess emissions of hazardous air pollutants.
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NOTE
The Solid Waste Association of North America submitted a letter to EPA
inquiring whether time frames for shutdown of landfill gas control devices to
conduct routine inspection and maintenance activities, as well as to address
malfunctions, could be included in the SSM Plan. The EPA entered the
SWANA letter into the public docket (OAR-2003-0215) and is considering rule
changes to address the issues raised. We plan to amend this SSM Plan
guidance document in the future if any clarifications are made to the landfills
NSPS and NESHAP regarding contents of the SSM Plan. To obtain the latest
regulatory information on the landfills NSPS and NESHAP, see
www.epa.gov/ttn/atw/landfill/landflpg.html.
To which operations at my MSW landfill does the SSM plan apply?
Your SSM Plan applies to the landfill gas collection system and the landfill gas control system and their
respective components. The SSM Plan must address the monitoring equipment associated with the
control system. As described below, if you treat landfill gas, you must include the system to treat the
landfill gas in your SSM Plan.
Gas collection system
Equipment that is used to collect the landfill gas must be included in your SSM Plan. The collection
system components include equipment such as the landfill gas lines, landfill gas collection wells, landfill
gas collection trenches, the field valves, and the blower. The SSM Plan applies to a malfunction of any
part of the landfill gas collection system. Your SSM Plan needs to address procedures you would follow
in the event of a malfunction of any collection system equipment, for example, if a blower stops
working, a collection well is flooded with water or a collection trench is pinched. See Appendix A for
an example showing information you should include in your SSM Plan.
To ensure proper operation of the gas collection system, the landfills NESHAP and NSPS require
monthly monitoring of temperature, pressure, and either nitrogen concentration (Method 2A) or oxygen
concentration (Method 2C) at each gas collection well and quarterly monitoring of methane
concentration at the landfill surface (Method 21). Your SSM plan does not need to address potential
failure of portable monitoring equipment that is used to collect these discrete measurements once per
month or once per quarter. Failure to conduct a required monthly or quarterly measurement using the
specified methods would be a violation of the monitoring requirements of the landfills NESHAP and
NSPS. The SSM plan is intended to address malfunctions, not problems caused by poor maintenance.
It is a maintenance and operational responsibility of the landfill to have working portable analyzers to
conduct these measurements, and to either have a spare analyzer or quickly repair or replace a broken
analyzer. The analyzers are off-the-shelf instruments that are readily available and can be quickly
replaced. Therefore, a landfill could not realistically claim that a failure of one or these gauges or
analyzers was a "malfunction" that caused them to be unable to take a monthly or quarterly
measurement. It would serve no purpose to include potential failure of this portable monitoring
equipment in SSM plans for the landfills NESHAP.
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Similarly, the SSM Plan does not have to describe the actions you would take if the surface monitoring
shows an exceedance of the 500 parts per million (ppm) methane level or if the temperature, pressure,
nitrogen, or oxygen monitoring at a well head indicates a problem. The NSPS (§60.755) already
specifies the corrective actions to be taken in such situations and the length of time allowed to correct
the exceedance. Therefore, it is not necessary to include corrective procedures in your SSM Plan.
Gas control system
The gas control system must be included in your SSM Plan. The following control systems, or any
approved alternative control system in use at the landfill, must be included in your SSM Plan.
•flare
•engine
•boiler
•turbine
Gas treatment system
The SSM Plan applies to your gas treatment system. Landfill owners and operators have the option of
treating landfill gas for subsequent sale or use instead of combusting it. You must include all equipment
used to treat the landfill gas prior to sale or use as a fuel, such as equipment used to filter, de-water, and
compress the gas. Note that if you choose to treat the landfill gas, you must reduce NMOC emissions
from any atmospheric vent from the gas treatment system by 98 weight percent or to less than 20 parts
per million by volume (40 CFR 60.752(b)(2)(iii)(C)).
If you combust treated landfill gas, and the treated landfill gas meets the requirements of the regulation,
then the combustion device does not have to meet any emission limits or monitoring requirements and
you do not have to include the combustion device in your SSM Plan.
Note
The EPA proposed clarifications regarding what constitutes treated landfill
gas and the corresponding compliance obligations on May 23, 2002 (67 FR
36476). To view the latest changes to the landfills regulations, visit
www.epa.gov/ttn/atw/landfill/landflpg.html.
The following equipment may be used to fulfill the monitoring tasks for the gas control system, as
prescribed by rule. You must include monitoring equipment in your SSM Plan.
•Flow recorder. Record gas flow from collection system to the open flare or enclosed combustion
device at least once every 15 minutes.
•Temperature monitor with continuous recorder. Monitor the combustion temperature of the enclosed
combustion device. The monitor must be equipped with a continuous recorder. (Not required for
boilers or process heaters >44 megawatts.)
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»Heat sensing device such as UV beam sensor or thermocouple. Monitor continuously the presence of a
pilot flame or the flare flame for an open flare
Your SSM Plan must include procedures you will take to correct a malfunction of either the control
system or the required continuous monitoring equipment. For example, it must address malfunctions
that could cause your control device to shut down or to operate outside the required control device
operating conditions. The NESHAP (§§63.1960 and 63.1965) andNSPS (§§60.758(c)(l)) establish the
acceptable operating parameter ranges for each type of control device (e.g., the allowable temperature
range for an enclosed combustion device).
NOTE
See Appendix A of this document for example information you should include
in your SSM Plan. The table in Appendix A does not constitute an entire SSM
Plan. Read this entire document and the General Provisions (40 CFR 63.6(e))
to leam what information your SSM Plan should contain.
Should I develop tools for meeting the SSM recordkeeping provisions?
The SSM Plan should also describe procedures for recording the information listed below (§§63.6(e)(3)
and 63.10(b)). The records may take the form of a "checklist" or other effective form of recordkeeping
(§§63.6(e)(3X»0 and 63.10(b)(2)(v)).
•The occurrence and duration of each startup, shutdown, malfunction at your MSW landfill (i.e.,
collection and control equipment).
•The occurrence and duration of each malfunction of your landfill gas collection and control and
monitoring equipment.
•The actions taken to correct the malfunctioning equipment.
•Information to demonstrate that the SSM Plan has been followed.
•Any deviations from the SSM Plan.
You may use a standard operating procedures (SOP) manual, an Occupational Safety and Health
Administration (OSHA) plan, or other plan to satisfy the requirements for writing an SSM Plan as long
as the other plan meets all the requirements of an SSM Plan, as described in the General Provisions
(§63.6(e)(3)(vi)).
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IMPLEMENTING YOUR SSM PLAN
When am I required to use the SSM plan?
You should use the SSM Plan during all SSM events of your MSW landfill operations, and operate and
maintain your MSW landfill gas collection and control system operations in accordance with the
procedures specified in the SSM Plan (§§63.6(e)(3)(ii) and 63.1960).
Who sees the SSM plan and how long should I keep it?
•Your SSM Plan should he kept as a record and made available for inspection and submitted upon
request to the Administrator (i.e., EPA or a State that has been delegated authority to enforce the
NESHAP program) (§§63.6(e)(3)(v) and 63.1980(b)).
•If your SSM Plan is revised, the previous versions should be available for inspection or copying by the
Administrator for five (5) years after the revisions are made (§63.6(e)(3)(v)).
When do I need to modify my SSM plan?
You may periodically revise your SSM Plan to reflect changes to your MSW landfill equipment,
operations, or procedures (§63.6(e)(viii)). Revise your SSM Plan if any of the following are true:
•SSM Plan does not address an SSM event that has occurred (§63.6(e)(3)(vii)(A)).
•SSM Plan fails to provide for the operation of the air pollution control and monitoring equipment
during an SSM event in a manner consistent with safety and good air pollution control practices to
minimize emissions (§63.6(e)(3)(vii)(B)).
•SSM Plan does not provide adequate procedures for correcting the malfunctioning process and/or air
pollution and monitoring equipment as quickly as practicable (§63.6(e)(3)(vii)(C)).
•SSM Plan includes an event that does not meet the definition of an SSM event listed in §63.2
(§63.6(e)(3)(vii)(D)).
If your SSM Plan fails to address or inadequately addresses an event that meets the definition of a
malfunction, you must revise the SSM Plan within 45 days after the event to include detailed procedures
for operating and maintaining your MSW landfill operations during similar malfunction events
(§63.6(e)(3)(viii)). The revised SSM Plan should include a program of corrective action for similar
malfunctions of monitoring or air pollution control equipment. Each revision to the SSM Plan must be
reported in your semiannual SSM report (§63.10(d)(5)(i)).
Any revisions made to your SSM Plan as required by Subpart AAAA do not constitute Title V permit
revisions. Also, none of the procedures in the SSM Plan fall within the "permit shield" provision in
section 504(f) of the Clean Air Act (§63.6(e)(3)(ix)).
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NOTE
If the revisions to your SSM Plan alter the scope of SSM activities at your MSW
landfill operation or otherwise modify the applicability of any emission limit, work
practice requirement, or other requirement in 40 CFR part 60, subpart AAAA,
the revised SSM Plan is not effective until you have provided written notice to
your permitting authority describing the SSM Plan revision (§63.6(e)(3)(viii)).
Do / have to submit any SSM reports?
Periodic SSM Reports. If an SSM event occurs during a semiannual reporting period, you must submit
a semi-annual SSM report (§63.10(d)(5)(i)) with the following information included (§§63.6(e)(3)(iii),
63.10(d)(5)(i), and 63.1980(b)):
•Name, title, and certifying signature of the owner or operator or other responsible official.
•Statement that your actions taken during the SSM event were consistent with the SSM Plan (if this is
the case)
•Identification of any instance where any action taken during an SSM event (including actions taken to
correct a malfunction) is not consistent with your SSM Plan, but your landfill did not exceed any
applicable emission limitation in the landfills NESHAP (63.10(d)(5)(i)).
•The number, duration, and brief description of each SSM event, which caused, or may have caused an
applicable emission limit to be exceeded (63.10(d)(5)(i)).
If you revise your SSM Plan to reflect changes to your MSW landfill operations or procedures, you must
report each revision to the SSM Plan in your semiannual compliance report (§§63.6(e)(3)(viii) and
Immediate SSM Reports. If your actions taken during an SSM event were not consistent with your
SSM Plan and your landfill exceeded the applicable emission limitation in the landfills NESHAP, you
must report such actions by telephone or facsimile (fax) transmission within two (2) working days after
commencing actions inconsistent with the plan. Also, a letter must be sent within seven (7) working
days after the end of the SSM event. The letter should include the following information
•Name, title, certifying signature of the owner/operator or other responsible official.
•Explanation of the circumstances of the event.
•The reasons you did not follow the SSM Plan.
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•Describe all excess emissions and/or parameter monitoring exceedances that you believe occurred
during the SSM event.
Can I combine my SSM reports with other reports?
If you must submit a semiannual SSM report under 40 CFR 63.lO(d)(5) of the general provisions
because you had an SSM event during the reporting period, you may combine that report with the
semiannual report required by the NESHAP. Per 40 CFR 63.1980(a) of the NESHAP, you must submit
the NSPS annual report per 40 CFR 60.757(f) semiannually, not annually. The reports required by
§63.1980(a) of the NESHAP and §60.757(f) of the NSPS summarize the collection and control system
exceedances. These two semiannual reports contain similar information and may be combined as
allowed by §63.10(d)(5)(i) of the General Provisions.
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APPENDIX A. EXAMPLE ELEMENTS OF AN SSM PLAN
This appendix contains a table identifying the types of information you should include in your SSM
Plan. Information in this appendix serves as only a tool to identify the information you will need to
develop and does not address every piece of equipment or situation possible. We do not attempt to
prescribe appropriate procedures and actions to follow in the event of a malfunction. The appropriate
actions will vary depending on the site-specific design of the landfill gas collection and control system,
and on site-specific safety and environmental considerations. You should refer to the landfills NESHAP
(40 CFR part 63, subpart AAAA) and the general provisions (40 CFR part 63, subpart A) that are
referenced by Table 1 of subpart AAAA for the requirements that apply to your landfill.
Table A identifies important elements of your SSM Plan. Although each cell is not complete, the table
illustrates the types of information you should include in your SSM Plan. Basically, identify your
equipment, anticipate likely malfunction events, and describe corrective action procedures. You may
present the information in the most appropriate format for your landfill. We completed the final row of
the table to illustrate appropriate information for a failure of the flare.
EQUIPMENT AND PURPOSE. Table A identifies typical equipment located at a MSW landfill that
has installed a collection and control system. Specific equipment may vary, but certain equipment is
required to fulfill the monitoring requirements of the NESHAP, which requires you to comply with the
monitoring requirements in the NSPS/emission guidelines. In the table, the NSPS/emission guidelines
monitoring requirements are noted in parentheses.
Include in your SSM Plan, each type of gas collection and control system equipment and control system
operating parameter monitoring equipment present at your landfill. For each piece of collection,
control, or monitoring equipment, your SSM Plan must show how you will minimize excess emissions
of HAP during an SSM event and how you will repair or replace malfunctioning equipment as soon as
practicable.
LIKELY MALFUNCTIONS. Include the potential malfunction events and causes for each type of gas
collection, control, and control system monitoring equipment present at your landfill. Your SSM Plan
will need to describe plans to correct potential malfunctions.
IMMEDIATE ACTION. Your SSM Plan shows how you will minimize emissions should any part of
your landfill's collection, control, or monitoring equipment malfunction. To fulfill this requirement, for
example, information in the IMMEDIATE ACTION column could be part of your program to
minimize excess emissions of hazardous air pollutants upon an SSM event.
Immediate actions may include notifying the appropriate landfill staff and initiating immediate actions
such as shutoff the flow of landfill gas to the malfunctioning control device or routing landfill gas to a
backup control device, if available.
CORRECTIVE ACTION. You must outline your procedures for operating and maintaining the
collection and control equipment during an SSM event. In addition to these procedures, you must
provide in your SSM Plan a program to repair the malfunctioning equipment as soon as practicable to
minimize excess emissions. For example, the CORRECTIVE ACTION column could be part of your
program to provide corrective actions to repair the malfunctioning equipment as soon as practicable.
A-1
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A-2
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Table A. Example Elements of SSM Plans.
As examples to help you identify the types of scenarios to include in your SSM plan, we list below some
potential malfunctions and a few possible corrective actions. This table is not comprehensive and does
not constitute an entire SSM Flan. You will need to develop procedures for each type of equipment and
malfunction scenario appropriate to your landfill. Read this entire document and the General Provisions
(40 CFR 63.6(e)) to learn what information your SSM Plan should contain. We have completed the last
row in the table as an example.
EQUIPMENT
PURPOSE
LIKELY
MALFUNCTION
IMMEDIATE
ACTION
CORRECTIVE
ACTION
Collection system
LFG lines
LFG collection
well
LFG collection
trenches
LFG header
pipes
field valves
blower
collect LFG
collect LFG
collect LFG
collect LFG
control flow of LFG
move LFG through lines
Control system
flow recorder
Record gas flow from
collection system to
enclosed combustion
device (every 15
minutes), unless bypass
lines are secured in a
closed position
(§60.756(b)(2))
A-3
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Table A. Example Elements of SSM Plans. (Continued)
EQUIPMENT
flow recorder
temperature
monitoring
device
UV scanner or
thermocouple
approved
alternative
control device
engine
PURPOSE
Record gas flow from
collection system to open
flare (every 15 minutes),
unless bypass lines are
secured in a closed
position (§60.756(c)(2))
Monitor and
continuously record
temperature of enclosed
combustion device
continuous recorder
(§60.756(b)(l))
Monitor the continuous
presence of a pilot flame
or the flare flame for an
open flare
(§60.756000))
Owner or operator must
submit appropriate
monitoring requirements
for alternative control
device (§60.756(d))
Combust LFG
LIKELY
MALFUNCTION
Power failure
Cleanup system
failure
Compressor failure
Instrumentation
failure
Filter failure
Chiller failure
Spark plugs
Valves
Sensors
Cooling system
Oil system
IMMEDIATE
ACTION
Notify
engineering or
maintenance
office. •
LFG
automatically
redirected to
flare.
CORRECTIVE
ACTION
A-4
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Table A. Example Elements of SSM Plans. (Continued)
£QUIPMENT
turbine
boiler
flare
gas treatment
system
PURPOSE
Combust LFG
Combust LFG
combust LFG
treat gas prior to sale or
use as fuel
LIKELY
MALFUNCTION
Power failure
Cleanup system
failure
Compressor failure
Instrumentation
failure
Filter failure
Chiller failure
Oil system
Sensors
Power failure
Condensate system
Cleanup system
failure
Compressor failure
Instrumentation
failure
Filter failure
Chiller failure
Malfunction of
sensors
Power failure
failure of condensate
management system
Blower failure
Blowout of flare due
to flow interruption,
high wind, or drop in
Btu content
Blowout of flare due
to loss of utility air
used to operate
instruments and
valves
IMMEDIATE
ACTION
Notify
engineering or
maintenance
office.
LFG
automatically
redirected to
flare.
Notify
engineering or
maintenance
office.
LFG
automatically
redirected to
flare.
Notify
engineering or
maintenance
office.
Automatic
shutoffofLFG
to the flare.
CORRECTIVE
ACTION
Restart flare:
purge combustible
gases from flare,
light pilot flame,
verify pilot
operation,
begin flow of LFG
See "To which operations at my MSW landfill does the SSM plan apply?" section of this document for
discussion of applicability of SSM plans to monitoring equipment.
A-5
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TECHNICAL REPORT DATA
(Please read Instructions on reverse before completing)
I REPORT NO
EPA-456/R-03-006
3 RECIPIENTS ACCESSION NO
4 TITLE AND SUBTITLE
How to Prepare a Startup, Shutdown, Malfunction Plan for
Collection and Control Systems at
Municipal Solid Waste Landfills
S REPORT DATE
December 2003
6 PERFORMING ORGANIZATION CODE
7 AUTHOR(S)
Joe Fanjoy
Eastern Research Group, Inc.
g PERFORMING ORGANIZATION REPORT NO
9 PERFORMING ORGANIZATION NAME AND ADDRESS
Office of Air Quality Planning and Standards
Mail Drop E143-02
Research Triangle Park, NC 27711
10 PROGRAM ELEMENT NO
II CONTRACT/GRANT NO
68-D-02-0079
12 SPONSORING AGENCY NAME AND ADDRESS
13 TYPE OF REPORT AND PERIOD COVERED
U.S. Environmental Protection Agency
Office of Air Quality Planning and Standards
Research Triangle Park, NC 27711
Final Report
14 SPONSORING AGENCY CODE
EPA/200/04
15 SUPPLEMENTARY NOTES
To be published at http://www.epa.gov/ttn/atw/landfiH/landflpg.html
16 ABSTRACT
This document explains how to prepare a startup, shutdown, malfunction plan for municipal solid waste
landfills. Landfill owners and operators who are affected by the National Emission Standards for Hazardous
Air Pollutants for Municipal Solid Waste Landfills (landfills NESHAP) and who must install a collection and
control system must prepare a startup, shutdown, malfunction plan (SSM plan). For the landfills SSM plan,
the primary concern is with malfunction of the landfill gas collection and controls system, not with the
startup and shutdown of the entire source. Therefore, the guidance focuses primarily on the malfunction of
the gas collection system, gas control system, and gas treatment system. The document describes what
information the SSM plan should contain, to which operations the SSM plan applies, and explains how to
keep records and reports. Also included is an appendix with example elements of an SSM plan for MSW
landfills.
KEY WORDS AND DOCUMENT ANALYSIS
DESCRIPTORS
b IDENTIFIERS/OPEN ENDED TERMS
c COSATI Field/Group
Municipal solid waste landfill
Air pollution
Clean Air Act
NESHAP
Startup, shutdown, malfunction plan
Air Pollution control
Nonmethane organic compounds
Methane
18 DISTRIBUTION STATEMENT
Release Unlimited
19 SECURITY CLASS (Report)
Unclassified
21 NO OF PAGES
17
20 SECURITY CLASS (Page)
Unclassified
22 PRICE
EPA Form 2220-1 (Rev. 4-77) PREVIOUS EDITION IS OBSOLETE
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United States Office of Air Quality Planning and Standards Publication No. EPA-456/R-03-006
Environmental Protection Air Quality Strategies and Standards Division December 2003
Agency Research Triangle Park, NC
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