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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)).
                                              10

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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.
                                             11

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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.
                                           12

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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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