An Opportunity Not a Hassle
Do you dread the task of managing you air permit renewal? Sure there's a process - but it's one that also provides a great opportunity to look at how your plant can improve operation while reducing costs.
The key is to take a different approach than simply copying the last permit application as many folks do. Certainly this involves more work, and requires an earlier start. (Want a reminder so that time doesn't slip away? We provide that service at no charge with a simple registration here.) By taking a fresh look, you'll often find opportunities to break the shackles of inefficiency that were built into your permit based on the best available technology at the time it was first written...which is often a decade or more ago. Imagine running today's plant with '90s computers!
Here are 3 tips to help you make your next air permit renewal a success and not just a refiling of paperwork.
Tip #1 - Quit Taking Manual Readings and Automate Data Collection
For too many plants, continuous monitoring involves taking manual readings of differential pressure on each unit everyday, or making visual observations of the stack. This “clipboard” data then needs to go to an office somewhere and make its way from paper to computer. Often, it then needs to make its way once more from the spreadsheet to the compliance report that gets filed weekly, monthly or quarterly. The entire process is tedious and wastes valuable time - at a time when many plants operate with thin personnel levels. It also creates multiple opportunities for error in transcription, and it introduces opportunities for lost data. Where is it stored? Who's responsible? How's it backed up?
Ditch the clipboards and switch to fully automated triboelectric dust monitoring systems. Tribo.dsp systems from Auburn can be fully automated to collect emissions data in real time. Further, integrated emissions monitoring software such as Auburn’s TRIBO.vision systems can collect, store and process all the required data (emissions, diff press, temp, etc.) for your emissions report with just a few clicks (no copy and pasting from endless spreadsheets).
Tip #2 - Lose the Outdated Monitoring Metrics and Move into 21st Century
Many plants continue to use outdated methods and technologies to monitor their baghouses. Differential pressure is great for monitoring and diagnosing problems in your baghouse, and absolutely should be monitored carefully. However, monitoring only DP for emissions control is not wise as it leaves open the way for false readings that could fail to alert operators to emissions exceedances. When that happens, air quality inspectors will not accept the "DP looked fine so we didn’t think anything was wrong!”
Adding triboelectric emissions monitoring to the mix can provide a wealth of benefits. Besides better operational data to base your decisions on, it also provides more data for when things do go wrong. Better advance warning of when filters begin to leak lets your people fix small issues before they become major incidents.
And something you don't normally associate with regulatory compliance...it can actually reduce costs. Rather than replacing bags on a set schedule, you'll observe in real time as performance deteriorates - and replace bags when it's time. That reduces bag cost as well as unscheduled downtime.
Tip #3 - Quit Fooling Yourself Thinking You Can Keep Your Grandfathered Permit Forever
So many plants tell us how they think they can avoid new regulations by staying under their old grandfathered air permits. They think the key is to simply never update anything as that in of itself will trigger the need for a new permit application. Thus, they do whatever they can to avoid investing in ANYTHING related to their dust collection system. The fact is that despite the best wishes of many, tighter regulations are inevitable. Even with the recent change in political leadership in the US, no party or agency has suggested to lighten the standards for PM 2.5 emissions, MACT standards or other similar EPA standards that impact baghouse operation. As such, trying to delay the inevitable is only a waste of time and will leave your facility on its back foot when new regulatory changes take full effect.
It's also not as secure a position as many assume in the case of an incident. Some companies figure they're better off not having data that demonstrates the details of an excursion. Conversely, regulators tend to assume the worst, and data can be valuable to demonstrate not only that the event may not have been severe, but that it was detected and addressed quickly.
Switching to triboelectric dust emissions technology for your plants CAM (Compliance Assurance Monitoring) plan provides a host of benefits. Most importantly, it puts your plant on the path to compliance for the foreseeable future.
Air permit renewal for your industrial dust collection system can be a time to review the available options for improving baghouse operation and efficiency while also improving compliance and reducing environmental. Start looking at the options for better baghouse monitoring today!