Air Permit Compliance is Confusing
Often facilities have a difficult time identifying exactly what local, state and federal regulators require of them regarding their dust collection systems. This is not unreasonable as the myriad of overlapping environmental, and health and safety requirements that affect dust collection systems can be quite the twisted knot to untangle. And stack monitoring requirements are just one more confusing twist in the knot. Many wonder if these monitoring requirements apply to them since their dust collection system is relatively simple and small scale.
Do I Even Need an Air Permit For My Dust Collector?
In nearly all cases you need an air permit from your local permitting authority. The Federal Government, through the EPA, sets basic emissions standards but then leaves it to the State and Local authorities to determine how best to meet those standards in their jurisdiction. This means that the exact requirements of your air permit may differ from one place to the next. In general, as the national standards have tightened significantly in recent years, nearly all air permits for dust collectors require continuous monitoring of the stack (i.e. outlet emissions).
What Kind of Stack Monitoring Does My Air Permit Require - General
Generally if your system falls under an air permit than it will also include a provision for operational monitoring of the dust collection system. Over the years there have been several different monitoring strategies to ensure proper operation of the collectors. Before the advent of advanced particulate detecting technology, indirect methods of measuring collection efficiency were used such as visual observations of opacity from the stack (EPA Method 9 and 22) as well as differential pressure on the dust collector. Later, evolving regulations called for continuous emissions monitoring systems or CEMS to be installed on all permitted dust collectors. These include opacity meters, which came to be widely used as they provided a continuous monitoring method with relative accuracy. In recent years triboelectric dust detection systems have started replacing opacity meters as the preferred CEMS for particulate emissions monitoring. (Auburn Systems actually first presented this concept to the EPA - our infographic on the evolution of tribo technology shows key dates.)
Beyond the normal NESHAP standards, some facilities fall under special regulations. These include industry specific MACT standards (Maximum Achievable Control Technology) that require some facilities to meet specific emissions limits that are based on the emissions levels already achieved by the best-performing similar facilities. MACT standards exist for industries such as lead smelting, cement kilns, powdered metals, and others. These MACT standards in particular often require continuous emissions monitoring in order to quickly detect leaks before they cause large exceedances. (The greater sensitivity, accuracy and multiple alarm capabilities of triboelectric allow facilities to react proactively to developing problems.) EPA regulators accept triboelectric bag leak detectors as suitable for meeting the requirement for broken bag detection provisions of these newer MACT standards.
Any installation of a CEMS system will also likely include some kind of record keeping requirements for regular submissions to the local regulating authority having jurisdiction. In many cases, triboelectric systems can be integrated with specialized computer software to compile the required data and format it for quick filing.
Satisfying these stack monitoring requirements requires a careful examination of your plant’s unique air permit and a reading of the specific statutes that apply. Many times this is best achieved by supporting busy in house staff with external resources. For this reason, many plants feel it best to hire an outside consultant to assist them in developing a strategy for complying with their air permit. In other cases, a bit of advice from an experienced vendor might suffice to point in house personnel on the correct path.
Are you not sure whether your facility needs to monitor its stack emissions? Let an Auburn Systems representative help you identify what your local air board may require for your system and help you get on the path to compliance today! Just contact us here for a consultation or call us today Toll Free: 1-800-255-5008