Variability in writing and enforcing air permits
Contrary to what you might think, there is little uniformity in air emissions permits from plant to plant. While many look to the Federal Government’s standards for PM emissions (i.e. MACT and other regulations), even these are not always applied uniformly across all applications. The job of actually enforcing most regulations often falls to the State authorities, who then may even distribute the responsibility further to other smaller air control boards that serve specific regions (such as in California). State regulations must be at least as strict as the Federal regulations when there is overlap - but the states have broad discretion on their own enforcement requirements. Even then the exact requirements for each plant can be further modified depending on factors such as the exact location of the plant, the surrounding area’s pollution levels, number of employees, and process conditions among others.
That means there is a wide variety of language and terminology used on permit documentation.
For this reason, dust collector OEMs and filter manufacturers may not always provide emissions testing data that directly corresponds to the language used on your plant’s air permit. Environmental/compliance engineers often have to interpolate available test data from OEMs to determine if the use of this particular product will enable the plant to achieve compliance.
That leaves us asking....Why can’t there just be one standard method of calculating emissions data?
This is the first of two articles which will tackle that question and explain how to reconcile the two.