An Upcoming Industrial Air Permit Renewal Offers a Fresh Start

Posted by Justin Dechene on Nov 24, 2015 1:30:00 PM

Renewing an industrial air permit can be a stressful event, not just for environmental engineers but also the entire management team. Really, the terms of a facility’s air permit can have a direct impact on its viability as a business. This is why so many plants have been forced to retire older equipment or shutdown entirely in recent years. 

For others the renewal process presents an opportunity for a new start. Older plants may have retained various portions of their older air permits when they operated less efficient equipment, or had different procedures. Now they may have modified their processes, installed newer equipment or made other changes that affect their operation and these older provisions are now burdensome and unnecessary. 

While the tendency is to resist changing something that is not broken, there are compelling reasons to consider revising the CAM at your facility to include triboelectric monitoring. 

Modifying a Compliance Assurance Monitoring Plan (CAM)

Facilities operating under Title V air permits must draft and submit a Compliance Assurance Monitoring (or CAM) plan as required by EPA. Essentially, CAM plans detail how a plant will monitor its pollution control devices and what metrics it will use to determine when they are operating within acceptable limits. Interestingly, the CAM plans are drafted by plant personnel and can be customized to fit the circumstances of each plant. Afterwards, they are submitted to regulators for approval. 

Many older plants continue to use CAM plans drafted with older, less accurate monitoring technologies. For example, many CAM plans rely on optical detection (i.e. opacity meters) or visual testing (EPA methods 9 and 22). Other plants must monitor dust collector differential pressure and stay within a preset  range (using DP as an indicator of collection efficiency). 

Triboelectric Systems Required – Either Explicitly or Implicitly

Some might say they are worried about revising their CAM plans to include triboelectric monitoring. They reason that if they do so they will in effect make their jobs harder and force their facility to meet stricter limits than their legacy permit currently requires. This line of reasoning is incorrect, as either implicitly or explicitly this level of monitoring is required for modern day operations. 

Many EPA standards require the use of a Bag Leak Detection System when monitoring fabric filter dust collectors. Triboelectric BLDS have been specified when industry requirements can't rely on other less sensitive monitoring methods (i.e. 1995 Secondary Lead MACT), in addition to other industry-specific standards. 

Even if not explicitly required under applicable standards, today's permits are dealing with lower and lower levels of particulate, other less sensitive methods will not alarm until  they have exceeded limits. On a practical level this means that whenever an problem arises, operators using non-triboelectric CAM will only receive an alert once an exceedance has occurred, which then requires reporting, possible fines or even compulsory shutdowns.

And adding insult to injury in the event of excursions, factories without sensitive monitoring devices will have much less data available to defend themselves.  With accurate recording they can identify precisely when limits were exceeded and for how long.  Without that data they'll be exposed to claims and assumptions...and be unable to refute them.

Additional Benefits of Revising CAMs to Include Triboelectric Detectiontriboelectric dust detectors save time and money

CAM plans built around triboelectric monitoring systems are simpler and provide additional benefits beyond compliance. With greater sensitivity, operators can see in real-time when emissions start to rise (indicating a leak, set of bags beginning to fail). This means catching leaks within hours, not days like other methods. This allows for remediation to take place immediately, avoiding fines and abatement costs

It also allows for predictive maintenance by providing trending emissions data on bags as they begin to fail. This means scheduling bag changeouts for the most convenient time and no more emergency shutdowns. 

Additionally, triboelectric detectors can easily be set up to transmit data remotely 24/7. This eliminates the needs for tedious labor involved in manually recording DP readings at each unit. It also eliminates the time consuming visual inspections (Method 9 or 22), which can only take place during the day and in good weather. 

Conclusion

In our experience, saving time and eliminating the need for personnel do manual inspections have been the biggest reasons for revising CAM plans to include triboelectric monitoring. Beyond compliance, the use of triboelectric monitoring brings additional maintenance and operational advantages that other methods simply cannot provide. 

Want to learn more about the benefits of switching to triboelectric monitoring? Feel free to contact Auburn for more information on how to successfully revise your air permit or see for yourself the benefits by viewing our archived webinar: Predictive Monitoring Webinar - Turning Bag Leak Detection from Hassle to Asset

Or if renewal is a bit further out, we'll keep track and contact you.  Just drop your details into this form and we'll do the rest.  

 

Topics: Air Permits