CSB Nine Years Later, Still No Dust Regulation – Urges OSHA To Finalize Combustible Dust Safety Standard

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A factory that has been destroyed by a Dust Explosion

Nine years after the first of a series of deadly combustible dust explosions in the U.S., the CSB (Chemical Safety Board) is imploring OSHA to take decisive action and finalize its court-ordered Combustible Dust Standard. Investments in plant dust collection systems will be vital to meeting the new proposed standards.

April 4, 2012 – Baghouse.com News | Fed. 20, 2003, CTA Acoustics plant in Corbin, Ky, 7 dead; Feb. 7, 2008 Imperial Sugar Refinery in Port Wentworth, Ga, 14 dead, 38 injured; various dates in 2011, Hoeganaes powdered iron metal manufacturing plant in Gallatin, Tn, 5 dead in 3 separate incidents in 5 months. These are just a few of the deadly industrial dust explosions to occur in the U.S. over the last decade. In each of these incidents, the lives of these workers were tragically cut short by the seemingly-innocuous dusts present in the facilities.

The Chairperson of the U.S. Chemical Safety Board (CSB) Rafael Moure-Eraso, in a recent article has called attention to the fact that despite several deadly incidents occurring in the nine years since the CTA explosions, OSHA still has yet to follow through with its pledge to issue a comprehensive combustible dust safety standard for general industry.

Chairperson Moure-Eraso  relates the progression of events that lead to the CSB calling for OSHA to implement a comprehensive standard for combustible dust.  “The safety board launched a study into the hazards of combustible dust. Our 2006 report revealed there is no national regulation that adequately addresses combustible dust explosion hazards in general industry. Although many states and localities have adopted fire codes that have provisions related to combustible dust, a CSB survey found that fire code officials rarely inspect industrial facilities to enforce the codes. The board clearly stated that American industry needs a comprehensive federal combustible dust regulation.”

While the explosion at the CTA Acoustics plant in Corbin, Ky did lead the CSB to issue a number of recommendations to both plant management, local and state regulators, it was not until the 2008 Imperial Sugar Refinery explosion in Port Wentworth, Ga, that left 14 dead and 38 injured, that the CSB made its recommendation to OSHA to issue a “comprehensive combustible dust standard for general industry”.

The CSB is an independent governmental agency charged with investigating industrial chemical accidents. And while they do have limited authority to investigate and issue recommendations, they do not have the power to enforce safety regulations.

Despite its repeated recommendations to OSHA for the urgent need for hazardous dust standards, he relents: “ Yet, nine years after the CTA catastrophe, and more than five years after our recommendation to OSHA, there is still no comprehensive OSHA standard to prevent these accidents.”

After the CSB’s recommendations, OSHA in April, 2009 announced that it planned on issuing a comprehensive dust standard for general industry. However, its recent 2012 agenda does not include any specific mention of goals or targets for the development of the standard during the course of this year.

Will There Ever Be a Comprehensive Combustible Dust Safety Standard?

While the U.S. is still struggling to prevent these kinds of incidents from occurring, the rest of the world is not immune from them either. In fact, major manufacturers such as China, which often lack extensive safety regulations, are even more prone to experience these kinds of incidents. According to recent reports, last year saw two electronics manufacturers in China that produce parts for Apple Computer products experienced dust explosions when fine particles of aluminum ignited, killing four workers and injuring dozens of others. Apple’s Supplier Responsibility documents state that the company is now requiring improved ventilation, inspections and cleaning methods for dust deposits.

Without a standard that comprehensively addresses the hazards of combustible dust, American workers will continue to be put at risk for future catastrophic explosions and fires.

“I don’t know what steps China is taking to prevent its dust explosions, but I do know what can be done here in the U.S. It’s time for OSHA to move on a comprehensive regulation to adequately address combustible dust hazards” – stated CSB Chairperson Moure-Eraso.

What Does This Mean For U.S. Manufacturers?

While the current status of combustible dust regulation is not fixed on a federal level, (i.e. OSHA) the dangers of combustible dust still present a clear and present danger to both the financial interests of U.S. manufacturers and the lives of U.S. workers.

As a result of the long history of combustible dust explosions in the U.S. many state and municipal fire codes and other regulatory agencies already have combustible dust regulations for most industries.  In addition, many insurance providers are requiring plants as part of regular safety audits to improve dust hazard protection in their facilities as a condition of maintaining their coverage.

dust collection systems

Maintaining a sufficiently-sized dust collection system is vital to prevent combustible dust explosions.

The first step to preventing these incidents is recognizing the dangers combustible dusts present in an industrial setting. Measures to control or mediate combustible dust hazards include maintaining a adequate dust collection system (i.e. a baghouse), good house-keeping practices and good facility design.

A main contributing factor in all of the above mentioned incidents was an improperly operated or maintained dust collection system. From inefficient collection pickup points, to bucket elevators that were not properly cleaned and sealed, to conveyor systems that were overloaded to baghouses of insufficient size and fire protection. A relatively minor investment in a facility’s dust collection system, such as changing to a sufficiently sized collector (i.e. larger CFM, larger baghouse with more dust collector bags) or additional baghouses will prevent the kind of massive capital loss and loss of life seen in these past incidents.

While governmental regulation will not ensure that these tragic incidents are the last of their kind, it is hoped that along with increase corporate awareness and ever-improving dust collection technology, these incidents will become rarer and rarer. Saving not only billions of dollars for companies, but safeguarding millions of workers in these industries.

Dominick DalSanto is an Author & Environmental Technologies Expert, specializing in Dust Collection Systems. With nearly a decade of hands-on working experience in the industry, Dominick’s knowledge of the industry goes beyond a mere classroom education. He is currently serving as Online Marketing Director & Content Manager at Baghouse.com. His articles have been published not only on Baghouse.com , but also on other industry related blogs and sites. In his spare time, Dominick writes about travel and life abroad for various travel sites and blogs.

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More Reasons Not To Store Dust In Your Dust Collector Hopper

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Clogged machinery,  exposure to hazardous chemicals, and disruptions in plant processes,  are just a few of the problems that come from using your dust collector hopper for dust storage. 

February 25, 2012 | Baghouse.com News – One of the most common baghouse operation practices that we find when we send a dust collector technical advisor out to various facilities is that many plants unwisely use the hopper on their dust collector for storage of the collected dust. Sometimes this is done unwittingly, as maintenance staff simply overlook emptying the hopper on a regular basis. Other times, this is more or less included (unwisely), into the design by neglecting to install a discharge system, such as a screw conveyor, or slide gate mechanism.

Dust Collector Bags

“You dust collector is NOT designed to store collected material for extended periods of time.”

However, whether this course of action is planned or not, using your dust collector hopper for storage of any collected material for an extended period of time can cause a myriad of problems. Among the various problems that can arise are damage to dust collector bags, increased emissions, increased pressure drop (i.e. increased system airflow resistance), and clogging and damage to dust discharge systems (conveyor systems, slide gates, etc.).

In addition, in some instances involving compounds that may be considered hazardous, storing collected materials in the hopper can lead to extensive fines and prosecution from governmental regulators such as OSHA or the EPA.

A Foundry Runs Afoul of OSHA and The EPA, Lands President and Company in Criminal Court

Recently, a Franklin, New Hampshire metal parts manufacturer and its president pleaded guilty to charges stemming from what OSHA found to be unlawful storage of hazardous compounds. The hazardous or toxic compounds in question were byproducts of the plants manufacturing process, that contained high levels of lead and cadmium. The plant and its president according to court records, knowingly stored the waste with the hazardous levels of lead and cadmium in unapproved containers throughout the plant for longer than the 90 days allowed by law without notifying OSHA and the EPA.

During an inspection of the plant by OSHA in 2009, the plant was found to be in violation of the Resource Conservation and Recovery Act (RCRA), which requires a permit to store hazardous waste on site for longer than 90 days. OSHA notified the EPA of their findings, and then a few months later, the EPA executed a search warrant on the plant found drums of hazardous waste being stored at the plant.

In the end, a federal grand jury indicted Wiehl and Franklin Non-Ferrous Foundry for unlawfully accumulating and storing lead and cadmium hazardous waste at the foundry site since July 2005. Wiehl faces a possible maximum sentence of two years in prison and a maximum fine of $250,000. Under the terms of a plea agreement filed with the court, the United States Attorney’s Office has agreed to recommend that he serve two years of probation, six months of house arrest, and that he publish a public apology. Franklin Non-Ferrous Foundry, Inc is facing a possible maximum fine of $500,000.

Dust collection screw conveyer

Ensure your dust collection system regularly discharges into a dust conveyor system, such as a screw conveyor.

What’s The Lesson? Store Collected Dust Properly! 

While the situation with manufacturer discussed above did not involve storing material in the dust collector, it does demonstrate that the EPA, and OSHA (and other safety organizations) do not take kindly to the storing of chemicals and compounds in inappropriate ways. You dust collector is NOT designed to store collected material for extended periods of time. 

As already mentioned, using your hopper to store dust will lead to a score of problems that adversely affect not only the efficiency of your dust collection system, but your entire plant. These problems drastically increase if the collected dusts contain hazardous materials (lead, mercury, etc.), are an explosion hazard (food products, metal powders, fertilizer, etc.) or are corrosive to machinery. In these instances it is imperative that proper dust transportation, storage and disposal methods are implemented. These include the use of continuous hopper cleaning (such as timed or sense actuated slide gates, pneumatic locks, etc.). It is also vital to regularly check these systems, specially those components most prone to wear and failure such as slide gates, seals, etc.

| Dominick DalSanto is an Author & Environmental Technologies Expert, specializing in Dust Collection Systems. With nearly a decade of hands-on working experience in the industry, Dominick’s knowledge of the industry goes beyond a mere classroom education. He is currently serving as Online Marketing Director & Content Manager at Baghouse.com. His articles have been published not only on Baghouse.com , but also on other industry related blogs and sites. In his spare time, Dominick writes about travel and life abroad for various travel sites and blogs.

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CSB Video Report On Series Of Combustible Dust Explosions At Tennessee Powdered Metals Plant

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The Chemical Safety Board issued a final report on a series of deadly combustible dust explosions in Tennessee. It highlights dust collection systems as the only way to prevent deadly combustible dust explosions. Recommends OSHA issue new comprehensive dust regulations within one year. 

January 6th, 2012 Baghouse.com News | The Chemical Safety Board has issued its final report regarding a series of deadly industrial dust explosions accidents that occurred at the Hoeganaes powdered metals plant in Gallatin, Tennessee in 2011. The main cause of these three deadly explosions and fires that claimed five lives and injured many others was determined to be negligence regarding combustible dust hazards. The CSB further noted that a main factor in these accidents was the constant neglect of the plant’s dust collection system.

All three of the incidents occurred when large amounts of accumulated highly combustible iron dust where dispersed into the air and then ignited. The plant manufactures various metal powders for industrial use, the most produced of which is iron powder.

Hoeganaes Cumbustible Dust Hazard

Picture of combustible dust accumulations near a bucket elevator that killed 2 workers when the dust was ignited by the motor.

The CSB investigation found that iron dust was present in high enough concentrations in the air to be clearly visible, and had accumulated on nearly all surfaces including elevated ledges, rafters, and other overhead spaces in amounts of 4 inches or greater. In addition the CSB clearly documented through photos and videos how dust handling equipment such as bucket elevators, conveyor belts, etc.  were not adequately sealed, regularly leaking large amounts of dust into the air when in operation, and were not connected to the plant’s dust collection system. Additionally, plant workers told investigators that the dust collection system was regularly out of service due to maintenance.

Three Combustible Dust Incidents At One Plant In Six Months

The CSB investigation begin after the first of the three incidents occurred on January 31st, 2011 when fine iron dust particles coming from a broken bucket elevator were ignited while two maintenance personnel were performing repairs. The airborne particles were ignited by a spark from the bucket elevator’s electrical motor when it engaged. The resulting explosion and fire severely burned both workers, and eventually proved fatal for both men.

Just two months later, while the CSB was still conducting an investigation into the first incident, another flash fire occurred on March 29th when a maintenance worker used a hammer while reconnecting a gas line on the side of one of the plant’s furnaces. When he struck the side of the furnace with the hammer it lofted accumulated iron dust into the air, which then ignited, severely burning him, and causing him to fall from elevated working position further injuring him.  According to CSB officials, “the build up of so much iron dust near a furnace with open flames and hot surfaces was a recipe for disaster. A fire was basically inevitable the moment the dust was dispersed into the air.”

Hoeganaes Cumbustible Dust Hazard

March 29, 2011 Combustible dust fire in Gallatin, Te Hoeganaes powdered metals plant. The second of two serious dust fires/explosions in six months at the plant

Even with two such incidents within two months of each other, Hoeganaes management and its parent company still failed to take action to address the combustible dust safety issues at the Gallatin, Tennessee plant.

This failure proved to be catastrophic as just a few months later on May 27th when the an even deadlier third incident took place. Workers were repairing a corroded furnace pipe containing extremely flammable hydrogen gas caught fire when workers used a forklift to raise a metal floorplate to access the pipe. Workers has assumed the leaking gas was non-flammable nitrogen. After the initial explosion, the leaking gas continued to burn as a continues jet fire. The force of the initial explosion shook loose largeamounts of accumulated iron dust from overhead rafters. As the large plumes of iron dust fell they were ignited by the jet fire causing massive explosions further injuring workers and damaging the plant. One worker stated that so much iron dust was lofted into air, that even with a flashlight he was only able to see two to three feet in front of him as he tried to escape.

Hoeganaes Combustible Dust Explosion

The aftermath of the third Hoeganaes combustible dust explosion in 2011. Notice the dislodged metal floor grating.

Evidence of Danger Present Well Before

All of these incidents were easily preventable. However plant management refused to take appropriate action to improve dust collection at the plant.

Even before the series of incidents, the plant had twice tested its dusts for combustibility. They ever were warned of the potential for a dust explosion after an insurance audit, which cited the potential for a such an accident due to the plant’s poor dust collection system policies, and housekeeping.

In addition to these warnings, the plant had firsthand knowledge of the combustibility hazards present in the plant, when on several occasions flash fires had occurred when workers performed maintenance using welding torches on dust covered conveyor belts. In fact the Gallatin Fire Department Hoeganaes facility in the last 12 years. These included one in June of 1999 where an iron dust fire in the baghouse lead to the hospitalization of one worker for smoke inhalation.

The CSB found that part of the core problem was that the plant, which was built over thirty years ago, was not designed according to good practice guidelines for combustible dust hazards, such as those set forth by the NFPA (National Fire Protection Association). “During its decades of operation, [the plant] was never redesigned to address the serious dust hazards” states CSB investigator Johnnie Banks.

Hoeganaes Cumbustible Dust Hazard - Accumulated Dust

Accumulated combustible iron dust on rafters at the Hoeganaes plant lead to several deaths when a series of dust fires and explosions occurred in 2011.

The plant has numerous flat elevated surfaces that easily accumulate large amounts of dust, and are difficult or impossible to clean with regularity. NFPA 484, which covers combustible metals safety, recommends that “floors elevated platforms, and gratings be designed to prevent dust accumulations and facilitate cleaning.” The same standard also requires that any machinery that emits combustible dust be connected to a dust collection system. Both of these recommendations were not followed by the Hoeganaes plant.

Many have asked how is it that these accidents were allowed to happen, even when plant management had all of these warnings and was in clear violation of best industry standards?

The city of Gallatin requires industrial facilities, including the Hoeganaes plant, to comply with the International Fire Code, which includes a brief chapter on combustible dust standards and references the more detailed NFPA standards. However the code does not require compliance with the more stringent NFPA standards. As a result the plant was not directly in violation of the International Fire Code that it was mandated to follow.

CSB Recommendations Based On Its Investigation

As a result of the CSB investigation, the CSB has proposed several actions be taken to reduce the risk of more combustible dust incidents from occurring elsewhere.

First, the CSB recommended that the International Code Counsel “revise the International Fire Code to mandate compliance with the combustible dust safety standards set forth by the NFPA.”

Secondly, in its 2006 report on the dangers of combustible dust hazards in industry, the CSB recommended that OSHA (Occupational Health and Safety Administration) issue a comprehensive combustible dust safety standard for general industry. As a result in 2007 OSHA instituted a national emphasis program for combustible dust, with the stated goal of eventually issuing a comprehensive combustible dust standard in the near future. In 2009 OSHA announced that it would begin the rule making process for combustible dust hazards. However, in 2011 at the time of these accidents, no standard had yet been proposed, or completed.

As a result, in its final report on the incidents, the CSB recommended that OSHA issue its long awaited combustible dust standards “within one year”, and that the standard include combustible iron and steel powders.  In the meantime, the CSB recommended that plants that manufacture steel and iron powders be included in the national emphasis program. for combustible dust.

 What This Means For Facilities With Combustible Dust Hazards

The continued loss of life due to combustible dust hazards is no longer being ignored by the CSB, OSHA, or other governmental agencies. The only way to prevent the loss of additional lives is for industry to begin following best industry standards as set forth by the NFPA and eventually the comprehensive standard by OSHA.

In the meantime, plant mangers and operators can educate themselves on the dangers of combustible dusts by reviewing educational articles on the subject such as those published here on Baghouse.com (http://www.baghouse.com/2011/01/19/the-potential-for-dust-explosions-in-dust-collection-systems/). They can also seek the assistance of experts in the dust collection industry to identify areas where improvement can be made, and make suggestions of ways to increase dust collection efficiency at their facilities.

For more information about the dangers of combustible dusts, please see the following links:

The CSB video reports on the Hoeganes incidents:

The following LinkedIn groups work specifically to raise awareness of combustible dust hazards, and lobby for comprehensive standards for general industry:

http://www.linkedin.com/groups?gid=1184577&goback=%2Egmp_1184577

http://www.linkedin.com/groupRegistration?gid=2076996&csrfToken=ajax%3A2562522142432018780&goback=%2Eanb_2076996_*2

 

 

About the Author

| Dominick DalSanto is an Author & Environmental Technologies Expert, specializing in Dust Collection Systems. With nearly a decade of hands-on working experience in the industry, Dominick’s knowledge of the industry goes beyond a mere classroom education. He is currently serving as Online Marketing Director & Content Manager at Baghouse.com. His articles have been published not only on Baghouse.com , but also on other industry related blogs and sites. In his spare time, Dominick writes about travel and life abroad for various travel sites and blogs.

 

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California Recycling Plant Fined Millions For Lacking Baghouse

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October 17, 2011, Baghouse.com News – A California recycling company has been accessed millions in fines by the EPA for failing to install and maintain baghouses at several of its plants. SA Recycling LLC was primarily fined for failure to repair/reinstall a baghouse dust collector at its Terminal Island, California, plant after a dust explosion there destroyed the original collector in 2007. The company continued to operate the facility, which includes industrial smelters used to recycle metals such as steel, aluminum, and lead from junkyard cars,  without a baghouse after the 2007 explosion.

Upon further investigation, the EPA ordered the company to install additional baghouses and other air pollution controls at several of its locations throughout California. All together the settlement will cost the company over $3 million, $2.9 million to upgrade the various facilities, and over $690,000 for fines and other costs.

For more information, see the article here: http://eponline.com/Blogs/Environmental-Protection-Blog/2011/10/Air-Pollution-Control-Technology-or-EPA-Fines-You-Decide.aspx

 

 

About the Author

| Dominick DalSanto is an Author & Environmental Technologies Expert, specializing in Dust Collection Systems. With nearly a decade of hands-on working experience in the industry, Dominick’s knowledge of the industry goes beyond a mere classroom education. He is currently serving as Online Marketing Director & Content Manager at Baghouse.com. His articles have been published not only on Baghouse.com , but also on other industry related blogs and sites. In his spare time, Dominick writes about travel and life abroad for various travel sites and blogs.

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5 Baghouse Safety Precautions

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Performing any kind of work on a baghouse can be hazardous work. Often set in industrial locations, dealing with baghouse systems can present a number of dangers to personnel. Thankfully, these maintenance tasks can be accomplished safety if proper safety precautions are followed.

A new article authored by Baghouse.com that has been published on a leading environmental and safety magazine EHSToday.com that offers 5 often overlooked baghouse safety proceedures for performing any type of work on dust collection systems. You can read the article here: 5 Essential Baghouse Maintenance Safety Precautions I encourage all of our readers to take a moment and read this article and consider how well are you doing regarding baghouse safety.

Direct URL: http://ehstoday.com/industrial_hygiene/news/baghouse-safety-precautions/

 

About the Author

| Dominick DalSanto is an Author & Environmental Technologies Expert, specializing in Dust Collection Systems. With nearly a decade of hands-on working experience in the industry, Dominick’s knowledge of the industry goes beyond a mere classroom education. He is currently serving as Online Marketing Director & Content Manager at Baghouse.com. His articles have been published not only on Baghouse.com , but also on other industry related blogs and sites. In his spare time, Dominick writes about travel and life abroad for various travel sites and blogs.

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Industrial Air Permits & Your Dust Collection System – Unfair & Confusing Enforcement

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Confusing regulations, conflicting methods of application, and unpredictable enforcement of industrial emissions regulations often leave many companies scratching their heads at what they did wrong. This article is part of a series about industrial air permits and their relationship with your dust collection system. See earlier article: Industrial Air Permits – Overcoming the Difficulties

(Baghouse.com – September 10th, 2011) – Governmental environmental regulations are often praised for the role they play in helping to keep our planet clean, and protecting us from hazardous by-products of our modern industrialized world. However, as these regulatory bodies increase in size, and influence, many claim that they have become inefficient, bogged down due to their overly bureaucratic organization, and even as “corrupt” as the big business polluters they are charged with protecting the public against.

We can see this in a recent article from Ethanol Producers Magazine; the article highlights the plight of a group of ethanol plant operators, and their constant struggles to understand and comply with needlessly complex environmental regulations, and permits issues by state and federal agencies. The article explains how sometimes permitting agencies require certain standards to be met in their permit proposals, that do not have any regulation behind them. These unnecessary requirements are simply confusing are not are not fair and are the result of over-regulating, states Jessica Karras-Bailey, an associate with RTP Environmental Associates Inc.

While certain states may have stricter emissions standards that others, in general the problem lies with permit issuing agencies, and officials going above and beyond what is required by federal and state legislation. In one cited example, an ethanol plant permit proposal would have required truck with grain shipments to follow a specific pattern within the site (taking a right turn, drive in a counterclockwise direction, and then leave by taking a left turn). Failure to enact this provision would have left the plant in non-compliance with the permit, leading to heavy fines and possibly forced closures. Provisions such as this obviously left management confused, wondering why such a requirement was mandated by existing regulations, as well as how they could possibly implement such a thing in a practical way.

Instances such as this highlight the almost “Mystic Elements” that these permits can sometimes require of plant operators. Often times companies are simply at a loss, not knowing what action to take, all the while fearing the repercussions that might come from not complying with these regulations.

In the instance cited above, the plant management turned to a consulting firm that specializes in helping facilities come into compliance with pollution control regulations, and with negotiating with permitting agencies. They were able to learn why the state’s permitting officials had placed this peculiar requirement in the permit (air dispersion modeling reasons). After that, the firm was able to negotiate with the agency, explaining that from a practical standpoint, it simply was not possible, and find a more flexible solution that was acceptable to both parties. “But it’s not always easy,” stated the consultant, and we tend to agree with that conclusion.

Air Permitting Compliance Help & Advice

Ordering baghouse replacement parts can be quite complicated

Do governmental pollution regulations have you feeling like this at times? EPA clean air regulations (NAAQS, NESHAP, etc…) for particulate matter (PM2.5), mercury, and other VOCs can be easily met by operating a proper dust collection system at your facility.

In researching this article, Baghouse.com contacted several consulting firms that specialize in helping facilities with the environmental permitting process, and advise them on ways to bring their sites into compliance with said regulations. We managed to speak with Brian Burdorf at Trinity Consultants, Inc. based in Dallas, Tx. about some of the more common issues that companies encounter during the permitting process, and what actions these firms can take to ensure compliance. We asked for some specific standards that among the hardest for companies to meet, and which ones can be affected by dust collection system performance the most.

Burdorf, mentioned that most difficult sections of current U.S. clean air regulations for companies to come into compliance with are the National Ambient Air Quality Standards (NAAQS), and associated U.S. EPA dispersion modeling requirements for demonstrating compliance with nitrogen dioxide (NO2), sulfur dioxide (SO2), and fine particulate matter (PM2.5). In addition, with regards to dust collection systems, he adds that the National Emission Standards for Hazardous Air Pollutants (NESHAP), Maximum Achievable Control Technologies (MACT), and New Source Performance Standards (NSPS)for industrial-commercial-institutional steam generators (boilers), electric utility steam generating units (utilities), portland cement manufacturing, and similar industrial processes are particularly challenging for companies to meet.

Theses standards, many of which have been updated, or otherwise expanded in recent years, require higher emissions standards that are increasingly complex, and difficult to achieve with existing or antiquated dust collection systems.

What Can You Do to Ensure Your Dust Collection System Reaches Compliance?

The role of dust collection systems in controlling pollution is growing more vital with each passing year. With tougher limits being proposed/adopted by regulatory bodies for particulate matter within the NAAQS, NESHAP, MACT, and NSPS, many formerly compliant sites are being forced to upgrade their existing systems, or install completely new equipment (such as replacing ESPs with Baghouse technology). With so many industries being affected by these rules, naturally the rules are complex, and often apply differently to different industries, and require different tactics for different industries and processes to reach compliance.

If you are confused and intimidated by the seemingly insurmountable challenge presented by the air permitting process for your facility, fear not for you have several options available to help you overcome these challenges. This topic will be covered in of our next article in this series here on Baghouse.com. We will discuss which exact regulations apply for different industries, what part certain technologies (Baghouse, filters, mercury capture systems etc.) will play in meeting the standards of tomorrow, and how you can plan to meet these standards not only for the present, but also for the future as well. If you have any specific questions that cannot wait until then, feel free to contact us here at Baghouse.com for assistance and we will be glad to help.

 

[author] [author_image timthumb=’on’]https://www.baghouse.com/wp-content/uploads/2011/08/DSC042141.jpg[/author_image] [author_info]

Dominick DalSanto is an Author & Environmental Technologies Expert, specializing in Dust Collection Systems. With nearly a decade of hands-on working experience in the industry, Dominick’s knowledge of the industry goes beyond a mere classroom education. He is currently serving as Online Marketing Director & Content Manager at Baghouse.com. His articles have been published not only on Baghouse.com , but also on other industry related blogs and sites. In his spare time, Dominick writes about travel and life abroad for various travel sites and blogs.

[/author_info] [/author]
References:

http://www.ethanolproducer.com/articles/7566/permitting-a-big-ticket-item

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Lead Smelter Ordered By EPA to Repair Dust Collection Systems

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A lead smelting facility has been ordered by the EPA to upgrade its existing pollution control technology, including its dust collection systems, and review operational procedures regarding environmental issues. 

Arecibo, Puerto Rico – A lead smelting facility in the Commonwealth of Puerto Rico has been served with an order from the U.S. Environmental Protection Agency to reduce air and water pollution caused by its operations. The Battery Recycling Company, Inc. from Arecibo, Puerto Rico, is being forced to upgrade its existing facilities’ pollution control technologies, including a dust collection system used for the collection of highly toxic lead dust.

The Battery Recycling Company, a secondary lead smelter, recycles used motor vehicle batteries and produces approximately 60 tons of lead per day.

Inspectors found fault with reporting policies, and operation and maintenance of the facilities dust collection system. After stressing that the company needs to improve its handling of the toxic substances it processes to protect  workers, their families, and the surrounding area, EPA Regional Administrator Judith A. Enck said: “The EPA legal action requires the Battery Recycling Company to improve its operations to protect people’s health and the environment. Our work is not done. EPA’s evaluation of the company’s compliance with federal environmental laws is active and ongoing.”

The plant which is regulated by both the Puerto Rico Environmental Quality Board (EQB), and the EPA, has been ordered to improve monitoring and reporting operations in addition to taking preventative actions and making operational improvements. The company was cited by the EPA and the EQB for having installed and tested new pollution control equipment on two of its furnaces in both 2007 and 2010 without notification. These points are significant because operational and physical changes occurred which increased the amount of pollution the facility generates. In addition, the inspectors found that the leak detection system in place to alert plant personnel of a of potentially devastating fugitive lead emissions was not fully operational. The inspectors also that the main rotary air lock on one of the dust collection system was not functioning at full capacity and was allowing lead dust to escape into the atmosphere.

Lead is a toxic metal that can cause damage to a child’s ability to learn and a range of health damage in adults.  Lead exposure can have serious, long-term health consequences in adults and children. Even at low levels, lead in children can cause I.Q. deficiencies, reading and learning disabilities, impaired hearing, reduced attention spans, hyperactivity and other behavior problems. Lead exposure can also cause health problems in pregnant women and harm fetuses.

The company has been ordered to ensure the proper operation of its leak detection system at all times to prevent fugitive lead dust emissions. Daily particulate readings must take place at each of the dust collection system’s Baghouses, and be recorded to ensure the facility is complying with all applicable air regulations concerning lead and other substances released into the air. Additionally, they must provide results from 2010 performance tests conducted to assess the efficiency of the facility’s pollution control systems on two of its furnaces to the EPA, and update its existing pollution control models and send these for review with the EPA.

 

 
About the Author

| Dominick DalSanto is an Author & Environmental Technologies Expert, specializing in Dust Collection Systems. With nearly a decade of hands-on working experience in the industry, Dominick’s knowledge of the industry goes beyond a mere classroom education. He is currently serving as Online Marketing Director & Content Manager at Baghouse.com. His articles have been published not only on Baghouse.com , but also on other industry related blogs and sites. In his spare time, Dominick writes about travel and life abroad for various travel sites and blogs.

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Baghouse Malfunction Causes Plant To Tell Workers “Stay Home!”

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A caution sign warning of a danger caused by a malfunctioning Baghouse

Bay Minette, Alabama – A Baghouse fire at a furniture manufacturing plant led to the closure of the entire site for several days. The Bay Minette, Alabama plant operated by Standard Furniture Manufacturing Co. suffered an explosion and ensuing fire in two silos that contain sawdust collected by the plant’s larger dust collection system.

While the exact cause of the explosion, and subsequent fire are not yet known, it is expected that an ignition source (such as a spark or an electric arc) may have been caused during a maintenance procedure.

The 600+ employees of the plant had to remain at home until the Baghouse was repaired and back in operation. This was further delayed when fire inspectors from the local fire department requested that the Baghouse be taken apart to aid them in their investigation of the fire.

This incident, one of many that occur each year, illustrates the importance of a site’s Baghouse, and larger dust collection system to maintaining normal operations. These often overlooked systems can when they malfunction due to maintenance neglect, improper operation, poor design, or other reasons lead to immense immediate costs for plant operators, and even larger long term ones.

Therefore this example highlights the need for constant attention to be given to dust collection systems so as to avoid these expenses, and therefore reduce overall operating costs. Only by maintaining a program of regular Baghouse maintenance, providing operators with sufficient training, ensuring all systems are adequately sized for the facility’s needs and meet all safety standards, can costly incidents like this one be avoided.

 

 
About the Author

| Dominick DalSanto is an Author & Environmental Technologies Expert, specializing in Dust Collection Systems. With nearly a decade of hands-on working experience in the industry, Dominick’s knowledge of the industry goes beyond a mere classroom education. He is currently serving as Online Marketing Director & Content Manager at Baghouse.com. His articles have been published not only on Baghouse.com , but also on other industry related blogs and sites. In his spare time, Dominick writes about travel and life abroad for various travel sites and blogs.

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Lack of Baghouse Maintenance Leads to Heavy Fines For Wood Pellet Manufacturer

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Athens, Maine, USA – Violations regarding the operation and maintenance of a Baghouse have led to heavy fines of over $30,000 being imposed to a wood processing plant in Athens, Maine. The fines were issued by the Maine Department of Environmental Protection.

The fines were issued to the plant for violating terms of their state air emissions permit. The plant was found to be operating its Baghouse without having replaced a number of Baghouse Filters that had been damaged/destroyed in a recent fire. The plant also was found to be exceeding limits for particulate matter emissions, due to improper

In addition to issues relating to the dust collection system, the plant also was cited for not maintaining an operational wet-scrubber, maintaining required logs of operating hours, and exceeding the limit for propane usage. They were also cited for failure to report the Baghouse fire indecent that had previously damaged the Baghouse and its filters, and that the wet-scrubber system had experienced a service outage.

The Maine Department of Environmental Protection is the state agency charged with enforcing Maine’s environmental laws.

According to the monthly enforcement report, issued in March 2011,  Maine Woods Pellets will pay the fine in monthly installments after it did not correctly operate its air pollution systems.

 
 
About the Author

| Dominick DalSanto is an Author & Environmental Technologies Expert, specializing in Dust Collection Systems. With nearly a decade of hands-on working experience in the industry, Dominick’s knowledge of the industry goes beyond a mere classroom education. He is currently serving as Online Marketing Director & Content Manager at Baghouse.com. His articles have been published not only on Baghouse.com , but also on other industry related blogs and sites. In his spare time, Dominick writes about travel and life abroad for various travel sites and blogs.

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Industrial Air Permits – Overcoming the Difficulties

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By Dominick DalSanto
Environmental Technologies Expert & Author
Baghouse.com

In today’s world increasing public attention is being given to environmental issues. Politicians and lawmakers are following suit by making modifications to existing pollution control legislation. The general consensus is that environmental regulations are going to be getting much tougher in the near future. Even though certain political factions are vehemently opposing many of theses actions, the trend is most assuredly heading towards tighter regulation of emissions.

This is evidenced by recent actions of the EPA (Environmental Protection Agency). Recently the agency issued new regulations regarding the emission of Mercury (Hg) and other heavy metals such arsenic, chromium, and nickel, and acidic gases, including hydrogen chloride (HCl) and hydrogen fluoride (HF), as well as other kinds of particulate matter (PM).

The agency also has assorted that it has authority under the U.S. Clean Air Act to regulate Green House Gases (GHGs) that are believed to be contributing to global warming trends. This will mean that large GHG emission sources will be subject to quotas and be required to acquire emissions permits for GHG emissions. These actions are in line with the current presidential administration’s environmental policy.

These and other developments, while still in their early stages will soon result in increased difficulty obtaining and staying in compliance with air permits. A process that already many in industry describe as overly complex and easy to get lost in. Many have a hard time sorting through the seemingly endless barrage of new and updated regulations. Often only realizing they have failed to meat their requirements after an inspection has taken place, and their facility has been assessed heavy fines.

New Series of Articles Regarding Air Permitting and Compliance

These new standards are particularly applicable to dust collection systems. The new EPA regulations covering particulate matte, along with Mercury and other heavy metals, poses many challenges for plants to reach compliance. Many facilities housing outdated dust collection systems, such as Shaker designs, and use baghouse filters made from older materials that are not as efficient as newer materials such at PTFE membrane. Additionally, due to shrinking maintenance budgets many dust collection systems are in a state of disrepair and as such are operating well below optimal efficiency. These factors will can potentially lead to achieving compliance with new and updated  air permits quite difficult for facility management.

We here at Baghouse.com are now preparing a series of articles to assist facility management with these issues. The new series will present an overview of the air permitting process. It will include case studies that highlight some of the difficulties involved in obtaining, and the implementation of air permits. We will also include helpful information from several consulting firms that work with industrial clients with the permitting process; from obtaining and negotiating air permits, to obtaining and maintaining compliance with them.

Read more about how to overcome unfair and confusing enforcement by regulatory bodies of emissions permits in the next article in the series: Industrial Air Permits & Your Dust Collection System – Unfair and Confusing Enforcement

 

 
About the Author

| Dominick DalSanto is an Author & Environmental Technologies Expert, specializing in Dust Collection Systems. With nearly a decade of hands-on working experience in the industry, Dominick’s knowledge of the industry goes beyond a mere classroom education. He is currently serving as Online Marketing Director & Content Manager at Baghouse.com. His articles have been published not only on Baghouse.com , but also on other industry related blogs and sites. In his spare time, Dominick writes about travel and life abroad for various travel sites and blogs.

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