Bag Leak Detection Blog

Let's Get Real About MACT

Ask any environmental compliance engineer what their biggest worry is and they will likely mention something involving MACT (maximum achievable control technology) standards. As MACT standards come to cover more and more industries, many facilities have found achieving compliance to be a significant challenge. Frequently they find that under investment in air pollution control over a number of years substantially complicates their compliance. Some have held out for political change that they assumed would lead to a revocation of these standards. Although the MACT program is firmly established by law and not subject to any executive directives or revision like some other standards, they've built programs of minimal compliance assuming that MACT would be reversed. It hasn't. It's exceedingly unlikely that it will. 

What Are MACT Standards? 

Invention born of a mishap

Often we discuss the advantages of triboelectric dust monitoring technology over other particulate emissions monitoring methods for plants covered under MACT standards. For the most part, the majority of these advantages come from the much greater detection range and sensitivity of triboelectric technology. Triboelectric detectors can register changes in dust concentration down to 0.000002 g/dscf or 0.005 mg/m3. The next most sensitive detection device (opacity meters and other optical based monitors) can only reach down to 5 -10% opacity, which in most applications equates to about 10 - 20 times less sensitive. Even so, many industries continue to use opacity based systems despite this and other shortcomings of opacity monitoring solutions compared to triboelectric technology. 

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. 

One thing engineers in countless industries often discover when integrating dust monitoring systems in their facilities is the need for an advanced software system for managing and organizing emissions data. Many monitoring suppliers actually produce their own data management software tools, compatible with their detection systems and others, that serve just this purpose.

When evaluating dust monitoring data software options, your best bet is a system that both meets your compliance reporting needs and your company’s individual needs; similar to selecting monitoring hardware, this shouldn’t be a bottom-line, “check-the-box” compliance decision.

Everyone's favorite job....NOT

Emissions regulations can seem daunting even just to begin reading. Many standards taking up over 100+ pages in addition to basic outlines established by Title V requirements. And it will come as no surprise to readers of this blog that some of the most onerous aspects of modern emissions regulation involve emissions compliance reporting. Non-compliance with these recording and reporting requirements frequently lead to fines in excess of those related to actual emissions excursions. 

But it's a lot of work, and dreadfully monotonous. So most folks look for ways to reduce the difficulty and complexity of compliance reporting, both to improve efficiency and avoid fines over incorrect reporting. Let’s looks at one way your plant can simplify its emissions compliance reporting. 

Use Triboelectric Monitoring as the Basis for Your CAM Plan

Ignorance may not be bliss....

Environmental regulations have evolved over the decades becoming increasingly strict around emissions standards. As this occurs, many older industrial facilities find that it's not financially viable to invest in new pollution control technology. In some cases, exceptions have been granted to older facilities to facilitate the transition to stricter standards. This has meant that some facilities have received exemptions, often called “grandfather” exemptions from certain standards or specific requires of larger sets of emission standards. Often though, these exemptions are forfeited when any significant upgrades or modifications are made to the plant’s systems. 

For this reason, many plant decision-makers have developed the viewpoint that as long as they refuse to upgrade to newer systems they can continue to avoid compliance with new regulations.. This leads them to avoid at all costs any modification or upgrades to their emissions control systems in the mistaken belief that by doing so they will avoid difficulties (and costs) associated with complying with newer, stricter environmental standards.

This can be seen by some plants refusal to install a CEMS or BLDS for fear it will increase their risk of getting fined or sanctioned over emissions excursions. The reality however is the contrary...

Complying with a CEMS (continuous emissions monitoring system) mandate from the air quality board may seem like a daunting task for most plants. While many eventually install the CEMS few realize that the work does not stop there. Many plants find themselves in trouble not over a lack of the CEMS, but rather over failure to observe the reporting requirements that accompany it. 

What is a CEMS and why use one?

The CEMS class of devices includes a wide range of different monitoring systems for different pollutants including acid gases like NOx, chlorine, HDIs and particulate matter, as well as other specific hazardous compounds such as heavy metals like lead and hex chrome. For our purposes, we will focus on PM CEMS used for monitoring particulate matter emissions such as what you find placed after a dust collector. 

Regulating authorities require nearly all industrial facilities to measure dust particulate emissions in some fashion. Opacity meters were, for decades, the standard required by the EPA and under many State and Local air permits.

However, in recent years, triboelectric particulate monitors have been promoted by some as superior to opacity meters, and have begun replacing opacity meters in many applications across all industries. So why the change? Is there a reason to switch to triboelectric monitoring devices for dust/particulate monitoring?

For many environmental engineers working with dust collection equipment can be a challenge. While many other industries seem to have moved forward with advancing technology, dust collectors often seem to be stuck in the past with regards to recording and reporting of particulate monitoring data. Manually collecting data sets from various monitoring sources can take much effort and even more work is required to compile them into one unified report.

Ineffective Data Collection Equals Tedious and Time Wasteful Reporting

More than just fretting about Reportable Events

If bags in your baghouse start to leak, and your dust collector performance deteriorates, eventually particulate emissions will increase.  Often companies track the threshold that obligates them to report an event under their air permit - and once a facility’s emissions exceed these limits they are required to report the incident to the regulating authority having jurisdiction. This process is lengthy and can involve remediation, sanctions and large fines.

For this reason, we often describe the importance of preventing small issues from becoming reportable events—something that triboelectric detection systems can prevent.  For instance we suggest using more sensitive broken bag detectors that can even detect trends well below the reportable limit.  And often multiple alarm levels can provide critical early warning to allow maintenance teams to fix problems before a reportable excursion even occurs.

But besides causing reportable events, leaking filters can cause other serious problems in a factory - often leading to product and equipment damage and possible health concerns.