Meeting the information requirements of NESHAPs at Ash Grove Cement's Chanute plant

Ash Grove Cement Company's (Ash Grove's) Chanute, KS facility manufactures portland cement and recovers thermal energy from solid and liquid hazardous waste derived fuel. As a result, the facility is subject to six different National Emission Standards for Hazardous Air Pollutants (NESHAPs). These NESHAPs regulate air pollutant emissions from nearly all equipment at the facility including valves, flanges, storage tanks, storage bins, conveying systems, mills, kilns, etc. The facility is required to demonstrate continual compliance with these requirements through extensive recordkeeping, monitoring and reporting that is often unique to each individual piece of equipment and that cannot efficiently be achieved through historically used methods of notebook and pencil. Consequently, the facility was forced to develop an overall program for ensuring that all information would be generated, collected, processed, stored, and, if necessary, be made available for reporting. An overriding goal of the program development was to utilize existing systems whenever possible and practical. Consequently, all existing data collection and management systems in place at the facility were reviewed, including plant maintenance systems, plant operating systems, control systems, accounting systems, etc. to determine if the systems already possessed required information, or if they could be utilized to collect the information. Where gaps in information collection were identified, systems were modified or developed such that all information necessary could be collected and processed in an efficient manner. This paper will review the various information requirements of these regulations with a focus on how existing plant systems were utilized to collect and process the information required by these NESHAPs.