A Hassle, but an opportunity
Many air permits are outdated. Sure, they're still approved and "compliant" but they were written around technology that was available at the time. Typically that is much less accurate than what's available today, and often relies on systems which require frequent calibration, have significant labor requirements, fail to provide early warning of impending issues and involves data management and reporting burdens. But often when an air permit renewal date approaches, it's just one more hassle - and many permits are simply resubmitted with the same language time after time.
But for many plants, their compliance assurance monitoring plans (CAM Plans) are seriously out of date.Emissions standards have tightened significantly, with the latest particulate matter regulations requiring measuring of emissions down to 2.5 microns and pounds per hour in the single digits. In many jurisdictions, the implementation of newer PM regulations has been uneven, or staggered to make adoption easier. Some plants manage to keep their older air permits and monitoring methods. This has lulled many into a false sense of security, thinking that they are not/will not be subject to new regulations.
The reality is that new standards may be forced upon plants quickly and without much notice due to a number of reasons (e.g. permit renewal, change in process, permitting for new equipment, etc.)
In short, an annual air permit renewal process can be used creatively as an opportunity to review a plant's options and see which baghouse monitoring method is best for them. To guide that review, we highlight three things that plants should look to improve with their next permit renewal.
1. Improve Accuracy
Your current CAM plan may rely on an older, less accurate monitoring method like visual observations of opacity from the stack or outlet source, differential pressure readings from the primary dust collector(s), opacity meters on the primary stack or in some limited cases a limit on production levels (e.g. XX pounds per hour fed into a furnace, etc.) Switch to triboelectric monitoring with its detection range down to 0.000002 g/dscf (more than 20 times more sensitive than opacity meters). This means fewer false readings, and no more surprise stack test failings as you will have the most accurate readings in real time long BEFORE the inspectors arrive.
2. Reduce Time Spent Preparing Compliance Reports
CAM plans prepared around triboelectric monitoring are often far simpler and easier to report than others involving differential pressure or opacity observations. These older methods require technicians to physically take DP readings multiple times throughout the day and record them, or for them to conduct a EPA method 9 or 22 observation (also time spent training and certifying them for methods 9 and 22). Not only does that mean reams of clipboard sheets with hard to read handwriting and lots of wasted time and errors in transcription, but it also made reporting a manual process.
Most CAM plans with triboelectric monitoring make use of remote monitoring and data collection and greatly simplified compliance reporting. In many cases a few clicks is all that’s needed to generate a daily/weekly/monthly compliance report.
3. Improve Baghouse Operation
With their increased detection sensitivity, triboelectric monitors can detect even the slightest changes in emissions levels emanating from a baghouse. With such precise data operators and maintenance technicians can receive early warning on a host of potential problems as well as diagnose and troubleshoot multiple issues successfully. Additionally, the ability to detect leaks when they first begin, and pinpoint leaking filters down to a specific unit, compartment or even row of filters saves dozens of man hours each time leaks occur. And Auburn's ability to actually measure particle velocity ensures that air speeds are correct to eliminate drop outs that jeopardize industrial dust collection system operation and introduce safety risks.
Use the upcoming permit renewal as an opportunity to implement changes to your continuous emissions monitoring in order to take advantage of the many benefits of triboelectric detection technology.
Of course you can start immediately to improve your baghouse operations - the air permit renewal is just a convenient time to have new technologies approved.