Keith Barnett/RTP/USEPA/US 

10/14/2006 12:30 PM	To

"O'Hare, Andy" <aohare@cement.org>

cc

Steve Fruh/RTP/USEPA/US@EPA

bcc

Subject

Good combustion practices

	

		

		Dear Andy:

		

		This is what we have developed concerning the definition of good 

combustion practices.  I would assume that all facilities are already 

doing this - but we need to codify the practice.  The only impact I see 

will be the necessity of a written training program and keeping records.
 

It is my understanding that all kilns already have a CO process monitor,


and a CO process monitor is not the same  thing as a CO CEMS.

		

		

		

		Good combustion practices (GCP) include installation, operation and 

maintenance of a computerized network of process control, including a 

process monitor for CO, combined with a comprehensive employee training 

program.  Each person working in the capacity of a production manager, 

production supervisor, process engineer, shift supervisor or control
room 

operator shall successfully complete a GCP training program which shall
be 

administered by qualified instructors.  The training program will cover 

the following topics:  machine specific safety awareness; materials
safety 

data sheet awareness; air pollutant monitoring requirements; compliance 

with GCP requirements; and GCP record keeping requirements.  Employees 

will be tested on their understanding of the contents of the GCP
program.  

Written records shall be maintained for each of the personnel listed
above 

as long as they are operating in that capacity to document the
successful 

completion of the GCP training program.  

		

		Please feel free to provide any comments.

		

		Keith W. Barnett

USEPA/OAQPS/SPPD/MMG

Mail Code D243-02

Research Triangle Park, NC  27711

919-541-5605

barnett.keith@epa.gov

