Landfill Start-Up, Shutdown, and Malfunction Plan
Startup, Shutdown, and
Malfunction Plan for the Landfill Gas
Collection and Control System
City of Midland Landfill
Midland, Michigan
Prepared for
City of Midland Landfill
4311 East Ashman Road
Midland, Michigan 48642
July 2010
Rev 02 – June 2011
Prepared by
CTI and Associates, Inc.
51331 W. Pontiac Trail
Wixom, Michigan 48393
CITY OF MIDLAND LANDFILL
LANDFILL GAS COLLECTION AND CONTROL SYSTEM
STARTUP, SHUTDOWN, AND MALFUNCTION PLAN
TABLE OF CONTENTS
1.0 INTRODUCTION ................................................................................................ 1-1 1.1 Background ........................................................................................................ 1-1 1.2 Definitions........................................................................................................... 1-1 1.3 Excluded Components ....................................................................................... 1-2 1.4 Included Components ........................................................................................ 1-2 1.5 Regulatory Contacts ........................................................................................... 1-3 1.6 Owner/Engineering Contacts ............................................................................. 1-3 2.0 SSM SCENARIOS ............................................................................................. 2-1 2.1 Collection System............................................................................................... 2-1 2.2 Control System – Open Flare ............................................................................. 2-2 2.3 Control System – Compressor System .............................................................. 2-4 3.0 STANDARD OPERATING PROCEDURES ...................................................... 3-1 3.1 Control System Startup – Compressor System .................................................. 3-1 3.2 Control System Shutdown – Compressor System ............................................. 3-1 3.3 Control System Startup – Flare System ............................................................. 3-2 3.4 Control System Shutdown – Flare System ......................................................... 3-2 4.0 MODIFICATIONS, RECORDKEEPING, AND REPORTING ............................. 4-1 4.1 Modifications ...................................................................................................... 4-1 4.2 Recordkeeping ................................................................................................... 4-1 4.3 Reporting ............................................................................................................ 4-2 Pn-CML SSM Rev 02 - Final.docx
i
CITY OF MIDLAND LANDFILL
LANDFILL GAS COLLECTION AND CONTROL SYSTEM
STARTUP, SHUTDOWN, AND MALFUNCTION PLAN
APPENDICES
APPENDIX A:
SSM Recordkeeping Forms, including Completed Forms
APPENDIX B:
Summary of SSM Plan Revisions
Pn-CML SSM Rev 02 - Final.docx
ii
CITY OF MIDLAND LANDFILL
LANDFILL GAS COLLECTION AND CONTROL SYSTEM
STARTUP, SHUTDOWN, AND MALFUNCTION PLAN
1.0
INTRODUCTION
1.1
Background
This Startup, Shutdown, and Malfunction (SSM) Plan was prepared to satisfy the
requirements of the National Emissions Standards for Hazardous Air Pollutants
(NESHAP) for municipal solid waste (MSW) landfills (40 CFR Part 63, subparts A and
AAAA). The purpose of the NESHAP is to prevent excess emissions of hazardous air
pollutants (HAPs) during a startup, shutdown, or malfunction event of the landfill gas
collection and control system (LFGCCS) and associated monitoring equipment. This
Plan was specifically prepared for the City of Midland Landfill (CML), located at 4311
East Ashman Road, Midland, Michigan. The CML is a licensed Type II MSW landfill,
owned by the City of Midland, Michigan.
This SSM Plan should be followed during all SSM events at CML. The Plan identifies
the procedures for operating and maintaining the LFGCCS during SSM events. The
Plan identifies procedures to adequately provide corrective actions to repair the
malfunctioning equipment as soon as practicable and to minimize excess emissions of
HAPs. Recordkeeping documents and reporting requirements are also included.
1.2
Definitions
The NESHAP defines the following terms:
Startup: “the setting in operation of an affected source or portion of an affected source
for any purpose”.
Shutdown: “the cessation of operation of an affected source or portion of an affected
source for any purpose”.
Malfunction: “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
Pn-CML SSM Rev 02 - Final.docx
1-1
City of Midland Landfill
Landfill Gas System SSM Plan
June 2011
limitations in an applicable standard to be exceeded. Failures that are caused in part by
poor maintenance or careless operation are not malfunctions.”
1.3
Excluded Components
The following items are not included in the requirements of the NESHAP or this SSM
Plan:

Failure of portable analyzers used to monitor landfill gas quality or conduct
surface emissions monitoring (i.e., GEM, EAGLE, FID).

Exceedances of parameters monitored monthly at individual landfill gas (LFG)
extraction wells (temperature greater than 55 degrees Celsius, zero or positive
pressure, and either nitrogen concentration greater than 20% or oxygen
concentration greater than 5%).

Exceedances of required quarterly monitoring of methane concentration at the
landfill surface (surface emissions greater than 500 parts per million above
background concentration).
1.4
Included Components
The following items are included in the requirements of the NESHAP and this SSM Plan:

The landfill gas collection system including, but not limited to, header piping,
extraction wells, collection trenches, driplegs, condensate knockout pots, straw
drain manholes, condensate/leachate pumps, and valves.

The landfill gas control system including, but not limited to the open flare, blower
and motor, compressors, ignition and operation equipment, continuous recording
devices.

The gas treatment system, such as those used to filter, dewater and, compress
landfill gas for use as fuel in a gas to energy facility.
Pn-CML SSM Rev 02 - Final.docx
1-2
City of Midland Landfill
Landfill Gas System SSM Plan
June 2011
1.5
Regulatory Contacts
All reporting information related to the SSM Plan should be submitted to the Michigan
Department of Natural Resources and Environment (MDNRE) at the following address:
MDNRE Air Quality Division
Saginaw Bay District Office
401 Ketchum Street, Suite B
Bay City, Michigan 48708
Phone (989) 894-6214 (Ms. Kathleen Brewer, current Env. Specialist for CML)
Fax (989) 684-9799
1.6
Owner/Engineering Contacts
Owner: City of Midland, Michigan
City of Midland Landfill
4311 East Ashman Road
Midland, Michigan 48642
Scott O’Laughlin, Landfill Superintendent
Phone: 989-839-6535
Cell Phone: 989-615-6231
Engineer: CTI and Associates, Inc.
51331 West Pontiac Trail
Wixom, Michigan 48393
Phone: (248) 486-5100
Fax: (248)486-5050
Contact: Beth Benoit (248) 486-7308 or Xianda Zhao, P.E. (517) 420-7174.
Pn-CML SSM Rev 02 - Final.docx
1-3
City of Midland Landfill
Landfill Gas System SSM Plan
June 2011
2.0
SSM SCENARIOS
For SSM recordkeeping and reporting purposes, the LFGCCS has been divided into two
main components; the collection system (including wells, piping, valves, and driplegs),
and the control system (including the skid mounted flare system, the mechanical dripleg
and pumping station, and the compressor and chiller/reheater system).
Likely
malfunctions for each of these main components are listed below along with immediate
and corrective actions to be taken. For each SSM event, an SSM Recordkeeping Form,
included in Appendix A, must be completed. The person completing the Form will refer
to the list below to identify the component affected, the likely malfunction, the immediate
action, and the recommended corrective action.
2.1
Collection System
Likely Malfunction
Immediate Action
Corrective Action
No/low flow due to
pinched/damaged/settled
piping/frozen piping
Open or close control valves to
allow continued flow to the control
system and to prevent
unnecessary air intrusion.
Determine location of
damage/settling. Repair
piping by replacing damaged
pipe, regrading settled areas,
or thawing/covering frozen
pipe.
Failure of control valves
If LFG is leaking to atmosphere or
causing air intrusion, close/open
surrounding valves and/or
wellheads.
Isolate affected area and
replace valve.
Failure of an extraction well
due to: frozen or broken
flexhose, fire, high water level
If LFG is leaking to atmosphere or
causing air intrusion, close/open
surrounding valves and/or
wellheads or temporarily cap
wellhead.
Replace/repair flexhose,
isolate well/remove vacuum to
control fire, pump extraction
well or surrounding leachate
collection system. If required,
replace extraction well.
Failure of a condensate
drainage feature
(dripleg/knockout/straw drain
manhole)
Isolate drainage feature by closing
surrounding valves to prevent air
intrusion.
Refill dripleg/straw with water,
cleanout blockage, or if
necessary excavate area and
check for damage.
Collection system expansion
Isolate header line affected by the
expansion by closing surrounding
valves to prevent air intrusion.
Complete expansion of the
LGCCS using best available
engineering practices.
Pn-CML SSM Rev 02 - Final.docx
2-1
City of Midland Landfill
Landfill Gas System SSM Plan
June 2011
2.2
Control System – Open Flare
Likely Malfunction
Immediate Action
Corrective Action
Wind/storm blowing out flame
If shutdown occurs, system
automatically closes actuator
valve to prevent LFG venting.
Follow SOP for flare startup.
High water level in the
condensate knockout
If shutdown occurs, system
automatically closes actuator
valve to prevent LFG venting.
Pump condensate from knockout
into either lift station or nearby
leachate manhole. Investigate
blockage, repair, and restore
drainage.
High water level in the lift
station due to blockage,
damaged and/or frozen piping
If shutdown occurs, system
automatically closes actuator
valve to prevent LFG venting.
Pump condensate from mechanical
lift station into nearby leachate
manhole. Investigate blockage,
repair, and restore drainage.
Failure/malfunction of the lift
station pump
If shutdown occurs, system
automatically closes actuator
valve to prevent LFG venting.
Repair pump or use temporary
pump to remove condensate.
Not able to restart due to
ambient temperature, frozen
pilot
If shutdown occurs, system
automatically closes actuator
valve to prevent LFG venting.
Use override function to initiate
startup at lower temperature. Thaw
the pilot.
Failure of blower, including
bearings, belts, fan wheel, etc.
If shutdown occurs, system
automatically closes actuator
valve to prevent LFG venting.
Repair blower using appropriate
replacement parts.
Failure of motor
If shutdown occurs, system
automatically closes actuator
valve to prevent LFG venting.
Repair motor using appropriate
replacement parts.
Failure of compressor, airlines,
fittings, actuators, solenoids
If shutdown occurs, system
automatically closes actuator
valve to prevent LFG venting.
If actuator fails, close the flare
inlet valve.
Repair the failed component using
appropriate methods/replacement
parts.
Too much oxygen in the gas or If shutdown occurs, system
lack of LFG flow to the flare
automatically closes actuator
valve to prevent LFG venting.
Identify cause of oxygen or
blockage of flow and repair
according to SSM Plan. If oxygen
level is due to extraction wells that
are out of compliance, adjust
wellfield to compensate.
Pn-CML SSM Rev 02 - Final.docx
2-2
City of Midland Landfill
Landfill Gas System SSM Plan
June 2011
Likely Malfunction
Immediate Action
Corrective Action
Loss of electricity
If shutdown occurs, system
automatically closes actuator
valve to prevent LFG venting.
Either utilize back-up generator or
monitor surface emissions until
electrical supply is restored to
demonstrate compliance with air
emissions standards.
Failure of the flow and
temperature recorder and/or
meter – memory card
malfunction, electrical
malfunction
If shutdown occurs, system
automatically closes actuator
valve to prevent LFG venting.
Manually verify ongoing
operation of the control
device.
Replace affected component;
memory card, recorder, meter.
Repair electrical supply as
necessary.
Not able to restart due to lack
of pilot fuel (propane)
If shutdown occurs, system
automatically closes actuator
valve to prevent LFG venting.
Switch to existing backup fuel
supply and replenish primary
supply.
Failure of the thermocouple
If shutdown occurs, system
automatically closes actuator
valve to prevent LFG venting.
Replace thermocouple with onsite
backup unit.
Failure of the flame arrestor
(clogging, freezing, etc.)
If shutdown occurs, system
automatically closes actuator
valve to prevent LFG venting.
Clean flame arrestor or replace if
necessary.
Failure of the knockout pot,
including plugging of the filter,
high water level, etc.
If shutdown occurs, system
automatically closes actuator
valve to prevent LFG venting.
Clean the filter, remove collected
water.
Shutdown of flare due to high
water levels in flare stack
If shutdown occurs, system
automatically closes actuator
valve to prevent LFG venting.
Empty flare stack drain(s).
Accidental pressing of
emergency STOP button
If shutdown occurs, system
automatically closes actuator
valve to prevent LFG venting.
Follow SOP for flare startup.
Routine Maintenance
If shutdown occurs, system
automatically closes actuator
valve to prevent LFG venting.
Follow SOP for flare startup.
Pn-CML SSM Rev 02 - Final.docx
2-3
City of Midland Landfill
Landfill Gas System SSM Plan
June 2011
2.3
Control System – Compressor System
The following malfunctions refer to pre-programmed trips in a single compressor.
Likely Malfunction
Immediate Action
Corrective Action
Compressor oil temp/pres out
of spec
Compressor automatically
shuts down; valve to the
pipeline will automatically
close.
Repair/replace
damaged/malfunctioning parts.
Gas suction/temp/pres out of
spec
Compressor automatically
shuts down; valve to the
pipeline will automatically
close.
Repair/replace
damaged/malfunctioning parts.
Motor overheat/overload
Compressor automatically
shuts down; valve to the
pipeline will automatically
close.
Repair/replace
damaged/malfunctioning parts.
Chiller high level
Compressor automatically
shuts down; valve to the
pipeline will automatically
close.
Determine cause of high level in
chiller and address.
LEL level reached in
compressor building
Compressor automatically
shuts down; valve to the
pipeline will automatically
close.
Ventilate building and correct
cause of high gas level.
Pn-CML SSM Rev 02 - Final.docx
2-4
City of Midland Landfill
Landfill Gas System SSM Plan
June 2011
3.0
STANDARD OPERATING PROCEDURES
Following are standard operating procedures (SOP) for startup and shutdown events of
the control systems (both compressors and open flare). These SOPs must be followed
during every startup and shutdown event.
3.1
Control System Startup – Compressor System
1.
Check for unsafe conditions in the surrounding area, i.e. exposed fan belts,
leaking LFG or propane gas, etc.
2.
Turn off flare blowers.
3.
Turn on compressor at building.
4.
Start chiller/reheater system.
5.
Start flare in “manual operation” until block valve connecting FCV-3300 opens.
6.
Open FCV-3300 to minimum required for predetermined minimum LFG flow to
flare.
7.
Open FCV-3100 to pressurize pipeline.
8.
Turn on ONE compressor with VFD = 50% with slide valves in open position.
9.
If VFD exceeds 80%, turn on second compressor.
3.2
Control System Shutdown – Compressor System
1.
Check for unsafe conditions in the surrounding are, i.e. exposed fan belts,
leaking LFG or propane gas, etc.
2.
Shutdown the control system by any of the following: press the emergency stop
button; turn off the electrical supply using the main electric panel switch.
3.
Ensure that FCV-3100 is CLOSED and that FCV-3300 is OPEN.
4.
Perform “Control System Startup – Flare System” if flare is not operating at time
of compressor shutdown.
Pn-CML SSM Rev 02 - Final.docx
3-1
City of Midland Landfill
Landfill Gas System SSM Plan
June 2011
5.
Verify that the system is properly shutdown (check flow rate, temperature,
pressure).
3.3
Control System Startup – Flare System
10.
Check for unsafe conditions in the surrounding area, i.e. exposed fan belts,
leaking LFG or propane gas, etc.
11.
Check that the valves are open and in proper operating position.
12.
Reset the emergency stop button if necessary.
13.
Check the fuel supply for the spark ignition (propane gas)
14.
Check for adequate electrical supply to the control system.
Reset circuit
breakers or other controls if necessary.
15.
Start the control system by turning the “flare power” dial “on” and pressing the
“start” button.
16.
Verify that the system is operating properly (check flow rate, temperature, and
pressure).
3.4
Control System Shutdown – Flare System
6.
Check for unsafe conditions in the surrounding are, i.e. exposed fan belts,
leaking LFG or propane gas, etc.
7.
Shutdown the control system by any of the following: press the emergency stop
button; turn the “Flare Power” knob to off, turn off the electrical supply using the
main electric panel switch. In an emergency where access to the flare system
area is blocked, the LFG header pipe valves near Cell 14 and near Cells 1 – 8
can be closed, thereby stopping LFG flow to the flare.
8.
Check that the actuator valve on the flare skid is in the “closed” position
9.
Verify that the system is properly shutdown (check flow rate, temperature,
pressure).
Pn-CML SSM Rev 02 - Final.docx
3-2
City of Midland Landfill
Landfill Gas System SSM Plan
June 2011
4.0
MODIFICATIONS, RECORDKEEPING, AND REPORTING
4.1
Modifications
The SSM Plan must be periodically modified to reflect changes in the landfill equipment,
operations, or procedures. The Plan should be modified if any of the following are true:

SSM Plan does not address an SSM event that has occurred.

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.

SSM Plan does not provide adequate procedures for correcting the
malfunctioning process and/or monitoring equipment as quickly as practicable.

SSM Plan includes an event that does not meet the definition of an SSM event.

SSM Plan does not address or adequately address a malfunction event. If this is
true, the SSM Plan must be revised within 45 days after the event to include
detailed procedures for operating and maintaining the LFGCCS during similar
malfunctions. The revised Plan should include a corrective action program for
similar malfunctions.
Each revision or modification of the SSM Plan must be reported in the semi-annual SSM
report (detailed below). Revisions or modifications to the Plan do not constitute Title V
air permit revisions.
Previous versions of the SSM Plan should be available for
inspection by the US EPA or the MDEQ for five (5) years after the revisions are made.
In order to track revisions or modifications to the plan, a summary table of revisions is
included in Appendix B.
4.2
Recordkeeping
The SSM Plan should be kept as a record of all SSM events and made available to the
US EPA or MDEQ as requested.
An SSM Report Form containing the required
recordkeeping information is included in Appendix A. If an SSM event occurs, the form
should be filled out completely and placed in Appendix A of this Plan.
Pn-CML SSM Rev 02 - Final.docx
4-1
City of Midland Landfill
Landfill Gas System SSM Plan
June 2011
4.3
Reporting
4.3.1
Immediate SSM Reports
If the actions taken during an SSM event were not consistent with this SSM Plan and the
CML exceeded the applicable emission limitation in the landfill NESHAP, the CML must
report the actions by telephone or fax 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, and certifying signature of the owner or operator or other responsible
official.

Explanation of the circumstances of the event.

The reasons the CML did not follow this SSM Plan.

A description of all excess emissions and/or parameter monitoring exceedances
believed to have occurred during the SSM event.
4.3.2
Semi-Annual Reports
If an SSM event occurs during a semiannual reporting period (January 1 through June
30 and July 1 through December 31), the CML must submit a semi-annual report
containing the following information:

Name, title, and certifying signature of the owner or operator or other responsible
official.

Statement that the actions taken during the SSM event were consistent with the
SSM Plan (if that is true).

Identification of any instance where any action taken during an SSM event
(including actions taken to correct a malfunction) is not consistent with the SSM
Plan, but the Site did not exceed any applicable emission limitation in the
NESHAP.
Pn-CML SSM Rev 02 - Final.docx
4-2
City of Midland Landfill
Landfill Gas System SSM Plan
June 2011

The number, duration, and brief description of each SSM event which caused, or
may have caused, an applicable emission limit to be exceeded.

If the SSM Plan was revised during the semi-annual reporting period to reflect
changes to the MSW landfill operations or procedures, the CML must report each
revision to the SSM Plan in the semi-annual report.
The semi-annual SSM report may be combined with the NSPS report. The NSPS report
was previously required annually. However, the NESHAP now requires the NSPS report
to be submitted semi-annually.
Pn-CML SSM Rev 02 - Final.docx
4-3
APPENDIX A
CITY OF MIDLAND LANDFILL
SSM Recordkeeping Forms
Pn-CML SSM Rev 02 - Final.docx
City of Midland Landfill
SSM Recordkeeping Form
Name of Person Completing Form:
Signature:
Type of Event (Check One):
Date(s) Form Completed:
Startup
Shutdown
Malfunction
Starting Date/Time of Event:
Ending Date/Time of Event:
Event Duration:
Was SSM Plan Followed (Check One)?
Yes
No
If the SSM Plan and SOPs were not followed, initiate reporting procedures listed in SSM Plan.
System Affected (Check One):
Collection System
Open Flare
Likely Malfunction (Refer to Section 2.0):
Standard Corrective Action Procedures/Information Needed
1. List of new equipment required for repair (i.e. blower belts, bearings, valves, etc):
2. Was the repair completed?
3. Was a third party needed to diagnose the malfunction or to perform the repair?
Contact name:
4. Name of person/company that performed repair:
5. If the LFGCCS was shutdown, who completed the startup procedure?
Q:\Projects\Municipal\City Of Midland\Midland Landfill\Air Compliance\SSM\SSM Recordkeeping Form Template.doc
Date/Time
Completed
APPENDIX B
CITY OF MIDLAND LANDFILL
Summary of SSM Plan Revisions
Pn-CML SSM Rev 02 - Final.docx
APPENDIX B
Summary of SSM Plan Revisions
Date of
Revision
Page
Number(s)
Revised
Reason for Revision
Alex Bade, EIT
2/28/2011
All
Updated to include landfill gas treatment system.
Beth Benoit
6/6/2011
2–4
Updated Table
Name and Signature
of Person Revising
Plan
Pn-CML SSM Rev 02 - Final.docx
LFGTE Facility Malfunction Abatement/Preventative Maintenance Plan
CITY OF MIDLAND
GAS TO ENERGY GENERATION FACILITY
MALFUNCTION ABATEMENT &
PREVENTATIVE MAINTENANCE PLAN
PERMIT TO INSTALL NUMBER 45-10A
Prepared for
City of Midland
Utilities Department
333 West Ellsworth Street
Midland, Michigan 48640
January 1, 2011
(revised February 9, 2011)
Prepared by
CTI and Associates, Inc.
51331 W. Pontiac Trail
Wixom, Michigan 48393
248.486.5100
248.486.5050 FAX
CITY OF MIDLAND
GAS TO ENERGY GENERATION FACILITY
MALFUNCTION ABATEMENT & PREVENTATIVE MAINTENANCE PLAN
TABLE OF CONTENT
1.
BACKGROUND ............................................................................................................................. 1
2.
GENERAL INFORMATION .......................................................................................................... 3
2.1 RELATED DOCUMENTS ............................................................................................................... 3
2.2 EMERGENCY CONTACT – 24 HOURS .......................................................................................... 3
2.3 RESPONSIBLE PERSONNEL ......................................................................................................... 3
3.
AFFECTED EQUIPMENT ............................................................................................................. 4
4.
MALFUNCTION ABATEMENT AND PREVENTATIVE MAINTENANCE PLAN................. 5
4.1 DESCRIPTION OF EQUIPMENT ..................................................................................................... 5
4.2 EQUIPMENT INSPECTION ............................................................................................................ 5
4.3 REPLACEMENT PARTS ................................................................................................................ 7
4.4 CORRECTIVE PROCEDURES ........................................................................................................ 7
5.
IMPLEMENTATION OF AND UPDATE TO PLAN.................................................................... 8
5.1 IMPLEMENTATION OF PLAN ....................................................................................................... 8
5.2 UPDATE TO THE PLAN ................................................................................................................ 8
5.3 REVISION HISTORY .................................................................................................................... 8
i
SECTION 1
1. BACKGROUND
This Malfunction Abatement and Preventative Maintenance Plan (Plan) was prepared in accordance with
Condition III.2 of Permit Number 45-10A for the City of Midland, Waste Water Treatment Plant. The
condition reads as follows:
At least 60 days prior to start-up of any engine in FGICENGINES, the permittee shall submit to the
AQD District Supervisor, for review and approval, a malfunction abatement/preventative
maintenance plan for FGICENGINES. After approval of the malfunction abatement/preventative
maintenance plan by the AQD District Supervisor, the permittee shall not operate FGICENGINES
unless the malfunction abatement/preventative maintenance plan, or an alternate plan approved by the
AQD District Supervisor, is implemented and maintained. The plan shall incorporate procedures
recommended by the equipment manufacturer as well as incorporating standard industry practices.
At a minimum the plan shall include:
a.
Identification of the equipment and, if applicable, air-cleaning device, and the supervisory
personnel responsible for overseeing the inspection, maintenance, and repair.
b.
Description of the items or conditions to be inspected and frequency of the inspections or
repairs.
c.
Identification of the equipment and, if applicable, air-cleaning device, operating parameters
that shall be monitored to detect a malfunction or failure, the normal operating range of
these parameters and a description of the method of monitoring or surveillance procedures.
d.
Identification of the major replacement parts that shall be maintained in inventory for quick
replacement.
e.
A description of the corrective procedures or operational changes that shall be taken in the
event of a malfunction or failure to achieve compliance with the applicable emission limits.
If the plan fails to address or inadequately addresses an event that meets the characteristics of a
malfunction at the time the plan is initially developed, the owner or operator shall revise the plan
within 45 days after such an event occurs and submit the revised plan for approval to the AQD
District Supervisor. Should the AQD determine the malfunction abatement/preventative maintenance
plan to be inadequate, the AQD District Supervisor may request modification of the plan to address
those inadequacies. (R 336.1702(a), R 336.1910, R 336.1911, R 336.1912, R 336.2803, R 336.2804,
40 CFR 52.21(c) and (d))
Rev.01, February 9, 2011
Page 1
SECTION 1
This Plan has been developed to satisfy the above requirements. As such, it provides procedures and
elements of inspection, inspection frequencies, back up equipment inventories and general information
used to prevent, detect, and correct malfunctions.
It is important to note that the regulations anticipated that periodic shutdown of the each individual
control equipment at a landfill is anticipated. Since periodic malfunctions, unforeseen circumstances or
short duration maintenance activities are anticipated by the regulations, City of Midland believes they
have implemented a program consistent with these requirements.
City of Midland understands that AQD expects the City of Midland to address any temporary break down
of a control device or devices.
While a plan has been written suggesting parts lists, inspections,
inspection frequencies, etc. to comply with the above paragraph it is anticipated the short duration
shutdown events will continue to occur which are beyond City of Midland’s control.
Rev.01, February 9, 2011
Page 2
SECTION 3
2. GENERAL INFORMATION
2.1 RELATED DOCUMENTS
The following documents will be available for reference at the City of Midland Gas to Energy Generating
Facility:
•
Start-up, Commissioning, and Training Plan for the City of Midland Integrated Utility
Improvement Project – Landfill Gas to Energy Project, prepared by Green Companies, Inc., dated
November 19, 2010.
•
Control Strategy for the City of Midland Integrated Utility Improvement Project – Landfill Gas to
Energy Project, prepared by Green Companies, Inc., dated December 10, 2010.
•
Preventative Maintenance Plan for the City of Midland Integrated Utility Improvement Project –
Landfill Gas to Energy Project, prepared by Green Companies, Inc., dated December 30, 2010.
•
Startup, Shutdown, and Malfunction Plan for the Landfill Gas Collection and Control System at
the City of Midland Landfill, prepared by CTI and Associates, Inc., dated July 2010.
2.2 EMERGENCY CONTACT – 24 HOURS
The Waste Water Treatment Plant (WWTP) is operated 24 hours a day. The Gas to Energy Generating
Facility is monitored continuously through the WWTP SCADA system and alarms are communicated
through the existing Wonderware software. When an alarm is activated or attention is required the
WWTP Operator will follow a protocol to notify the appropriate on-call individual.
2.3 RESPONSIBLE PERSONNEL
All supervisory personnel responsible for overseeing the inspection, maintenance, and repair of the engine
plant are listed below:
Name
Title
Phone Number
Kevin Babinski
Wastewater/GTE Superintendent
989-837-3502
Scott O’Laughlin
Landfill Superintendent (GCCS)
989-839-6535
Steve Smith
Wastewater/GTE Operations Supervisor
989-615-8304
Jim Ives
Elec/Mech 2 (GTE/GCCS Operations)
989-839-9577
Rev.01, February 9, 2011
Page 3
SECTION 3
3. AFFECTED EQUIPMENT
The City of Midland plans to operate two internal combustion engines that are covered by this Plan. The
engines are used for combusting treated landfill gas and wastewater treatment plant (WWTP) digester gas
to produce electricity.
These engines are identified as Emission Units EUICEENGINE 1 and
EUICEENGINE2 in Permit No. 45-10A issued by the Michigan Department of Natural Resources and
Environment Air Quality Division.
Rev.01, February 9, 2011
Page 4
SECTION 4
4. MALFUNCTION ABATEMENT AND PREVENTATIVE MAINTENANCE PLAN
The following section of this Plan contains prevention of malfunctions, detection of malfunctions, and
correction of malfunctions for each of the engines.
4.1 DESCRIPTION OF EQUIPMENT
The City of Midland has plans to operate two internal combustion engines (both Caterpillar G3520C) for
combusting treated landfill gas and WWTP digester gas to produce electricity.
These engines are
identified as Emission Units EUICEENGINE1 and EUICEENGINE2 in Permit No. 45-10A. In addition
to these engines, the facility includes an engine heat recovery system, engine cooling system, and
electrical generation equipment.
4.2 EQUIPMENT INSPECTION
Table 1 shows the Engine Plant items or conditions that are inspected, the frequency of the inspections,
the procedures followed to aid in the prevention of a malfunctions, monitoring parameters that are used to
detect and aid in the prevention of a malfunction or equipment failure, the normal range of these
parameters, and recording/ retaining of the monitoring records.
Table 1
List of Engine Plant Prevention/Detection Items
Item or Conditions to
Be
Inspected
Frequency of Inspection
/Monitoring
Engine Air Cleaner
Element
Engine Oil
*Performance based
Assessment
*Performance based
Assessment
Engine Oil Sample
Establish Baseline for
each Engine
(Performance/Oil sample)
Weekly
Weekly
Engine Oil Level
Engine Oil
Temperature
Oil Filter Differential
Pressure
Engine Oil Filter
Fuel Metering Valve
Rev.01, February 9, 2011
Weekly
Procedures to be Followed to
Aid in the Prevention of
Malfunctions
Check Sensor (difference in pressure) Replace
when necessary
Establish baseline, use oil chemistry
and performance as a guide (Change
when necessary)
Once baseline is established verify frequency
with oil chemistry sampling results
Check float & Secondary auto-fill
Check Temperature gauge
Establish Baseline for
Check Electronic Technician (ET)
Software
Check pressure differential change
Each engine (Performance
Engine oil filter as needed
Performance based assessment
Check Codes, Clean Sensor
Page 5
SECTION 4
Item or Conditions to
Be
Inspected
Frequency of Inspection
/Monitoring
Throttle Control
Valve
(Check Elec. Valves)
Cooling System
Coolant
Level
Cooling System
Coolant
Temperature
Cooling System
Coolant
Pressure
Differential Pressure
Crankcase Vent
Generator Load
Walk-Around
Inspection
Performance based
Assessment
Battery Electrolyte
Level
Belts (Radiator)
Engine Valve
Radiator
*Every 6 months of service
Water Pump
Performance based assessment
Generator
*Performance based
Assessment (assess at
Approximately 8,000 hours
Of use)
Performance based assessment
Ignition System
Spark Plugs
Turbocharger
Overhaul – Top End
Overhaul – In-Frame
Overhaul - Major
Procedures to be Followed to
Aid in the Prevention of
Malfunctions
Check ET Software
Weekly
Check Sight glass for level and
Color
Weekly
Check ET Software
Weekly
Check ET Software
Weekly
Check Pressure, Control vacuum
(walk around)
Check load conditions (Kilowatts)
Check for any unusual conditions,
Leaks, broken gauges, pinched
Wire/Tubing etc.
Check battery electrolyte level
Weekly
Weekly
*Every 12 months
Performance based assessment
Performance based assessment
*Performance based
Assessment (assess at
Approximately 8,000 hours
Of use)
*Performance based
Assessment (assess at
Approximately 50,000 hours
Of use)
Performance based assessment
*Performance based
Assessment (assess at
Approximately 100,000
hours of use)
Inspect/Adjust/Replace
Adjust as needed
Check inlet & outlet temps, clean/
Wash exterior surfaces as needed
Inspect for leaks during walkAround inspection
Visually inspect system for lose
wires/fittings, vibration damage
etc.
Inspect/Replace
Establish baseline to use as a guide
(change when necessary)
Overhaul
Overhaul
Overhaul
*Engine performance supersedes frequency of maintenance activities. Approximately values used in this table
should only be used as a guideline in evaluation of each parameter to be inspected, maintained and replaced.
Rev.01, February 9, 2011
Page 6
SECTION 4
4.3 REPLACEMENT PARTS
To facilitate quick replacement, the spare or replacement parts necessary for proper engine operation and
routine maintenance will be located on site at the generation facility, the compressor facility, or at WWTP
central maintenance area (major components or specialty parts will be ordered as needed). Inventory may
vary from time to time.
4.4 CORRECTIVE PROCEDURES
The corrective procedures or operational changes shall be undertaken in the event of a malfunction or
failure of the generation facility.
City of Midland will expeditiously implement the appropriate
procedures to correct the event. Repair records will be maintained in an operations log.
Rev.01, February 9, 2011
Page 7
SECTION 5
5. IMPLEMENTATION OF AND UPDATE TO PLAN
5.1 IMPLEMENTATION OF PLAN
If the plan fails to address or inadequately addresses an event that meets the characteristics of a
malfunction at the time the plan is initially developed, the owner or operator shall revised the plan within
45 days after such an event occurs and submit the revised plan for approval to the AQD District
Supervisor. Should the AQD determine the malfunction abatement/preventative maintenance plan to be
inadequate, the AQD District Supervisor may request modification of the plan to address those
inadequacies.
5.2 UPDATE TO THE PLAN
This plan will be updated within 60 days of replacing or expanding the components of the Engine Plant
with components not described herein. If no components of the Engine Plant are replaced or expanded
with components described herein, the Plan will be updated at least once every 5 years or as needed.
5.3 REVISION HISTORY
Date
Rev
Description
01/01/11
00
Issue Document
02/09/11
01
Revise Section 2 to clarify the 24 Hour Emergency Notification Process.
Rev.01, February 9, 2011
Page 8
"
Il.
PM2.5,PRIMRY
LB
Generic
1.7
,o
502
LB
Generic
it.1l
II'
vae
1..6
Gooeric
5.6
i'l
11)
1I'"
~
o
z
"-
1'1
III
r1/1
"-(I)
C'I
o
<'I
!II
N
o
IU
D
"j
r
lv
~
II.
o
o
IIVASTEGAS
MMCF
lANDFILL GAS
MMCF
WASTE GAS
MMCF