Instructional Manual For Clarification Of Startup In Source Categories Affected By New Source Performance Standards - U.s. Environmental Protection Agency - 1979 Page 14
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146 PROJECT APPROACH
Technical information for this manual has been solicited primarily from
process engineers employed at the industries involved.
Additional data have
been obtained from trade associations, equipment suppliers or contractors, and
technical journals and publications.
ArPLICATION OF FINDINGS
The startup definitions specified for each industry have been geared
towards normal or typical circumstances in wh'ich all equipment is delivered
and tested on schedule and no major malfunctions occur during initial startup
or subsequent process'evaluation.
This manual points out several source cate-
gories where problems might be encountered in meeting the 180 day deadline.
In these instances, enforcement personnel will evaluate the situation on a
case-by-case basis.
It must be, stressed that not obtaining maximum production
rate within 180 days (as may occur with the kraft pulp mill, nitric acid plant,
or prim8.ry aluminum industry, for example) is not sufficient reason for delay
of performance tests; tests could be required during the 180 day period and
again when maximum production is reached.
SUl'fM,ARY
, Contacts with the various industries involved in each of the NSPS cate-
gories have resulted in many similar circumstances regardless of source type,
which affect new source startup.
Items which generally apply to any source
category are:
•
The desire to come on-stream as soon as possible so as to
minimize extensive startup periods which would result in
excessive capital expenditures with no immediate cash flow return.
•
Training of operating personnel can be very important if exper-
ienced people cannot be obtained from another plant location.
•
Most plants initially undergo mechanical acceptance of process
equipment which is partially carried out by the contractor or
equipment supplier and partially carried out by the source
owner or operator.
•
Following mechanical acceptance, process performance evaluation
is conducted, usually in the form of a demonstration or test
run, resulting in the acceptance of the plant from the contractor.
Some specific procedures or operations that may be carried out for par-
ticular pieces of equipment are:
•
Water batching of liquid vessels for leak detection and
instrument calibration,
•
Gradual firing and curing of equipment containing refractory
material,
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