Instructional Manual For Clarification Of Startup In Source Categories Affected By New Source Performance Standards - U.s. Environmental Protection Agency - 1979 Page 15
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146 •
Hydrostatic or pressure testing of fossil fuel-fired vessels
according to specific codes, and
•
Dry operation of mechanical mixing, ·granulating, conveying,
and transporting systems.
Other aspects of plant startup which regulatory people need to be familiar
with pertain to the phenomenon of engineering scale.
Scale-up problems are
bound to occur since most new plants tend to be larger in capacity than existing
ones and also attempt to incorporate innovative designs relative to energy-
efficiency.
New facilities constructed for a known process of nominal design
production rate would likely require much less time than a new plant built for
a prototype process or a much larger plant.
The Industrial surveys conducted have resulted in several common suggestions
for definition of an initial plant startup, irrespective of the industry
involved:
1.
24-hours of continuous operation
2.
Shipment of on-grade product to the customer
3.
Product from process is used to make a profit or is
inventoried.
4.
First introduction of raw material with potential
for emis'sion of regulate.d pollutant(s)
- .5.
Mechanical acceptance of plant
6.
Completion of successful demonstration run
7.
Contractual acceptance of plant
The selection of startup for each industry has been based upon a composite
of three criteria; the theoretical position of an enforcement agency (No.4
above), the viewpoint of industrial contacts (all of the above), and the ability
of
a
source category to achieve rated capacity within 180 days of the selected
startup point.
GOOD AIR POLLUTION CONTROL PRACTICE DURING STARTUP
After the effective date of an NSPS, an applicable source must meet the
-standard except during times of startup, shutdown, or malfunction.
The source
owner or operator must at all times, including startl:lp, maintain and operate
any affected facility in a manner consistent with good air pollution control
practice (40 CFR 60.11(d».
Hence, atmospheric emissions during the startup
period must always be directed through pollution control equipment.
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