Industrial dust collection systems are a crucial tool in ensuring workplace safety, sustainability, and environmental compliance. These systems are not just equipment needed for your processes and facilities to produce effectively; they are state-of-the-art safety measures. However, to maintain their effectiveness they require modern validation and certification methods. Regular assessments are essential, especially when process conditions change.
The Consequences of Non-compliance
Extraction systems that handle explosive dust are made up of numerous vital components. These components must work in harmony to provide the expected safety. When a system malfunctions or doesn’t perform as intended, it can lead to a host of issues:
Production Impacts: Malfunctioning extraction can disrupt the production process, resulting in downtime and decreased productivity.
Health Concerns: Operators exposed to dust due to inadequate extraction can face significant short and long-term health problems, leading to absenteeism, reduced workforce efficiency, reduced worker morale and productivity, and sickness and injury among your team. One example is silicosis, a lung disease caused by long-term exposure to fine silica dust.
Increasing Costs: Neglected preventive maintenance, monitoring, and operational tasks result in unplanned costs for repair and replacement of worn and broken equipment.
Safety Risks: Failure to ensure your equipment is up to date increases the risk of dust explosions, which can have catastrophic consequences, endangering lives and property.
Compliance and Inspections
For all ATEX equipment (equipment used in explosive atmospheres), regular inspections are mandatory. The specific intervals and requirements vary based on the manufacturer and notified bodies responsible for type approval. Compliance checks must include the following…
Explosion Isolation System Inspection Requirements:
A clear description of the intended use of the explosion isolation system.
Operational requirements.
Installation requirements.
General arrangement plans.
Commissioning requirements.
Maintenance guidelines.
Periodic Inspections
Regular inspections are crucial to ensure that the explosion isolation system maintains its capability and reacts as originally designed in case of an explosion. Procedures after an explosion are also a vital part of compliance.
Inspection Points
Specific inspection points are listed in user manuals, and in most cases, only authorized engineers can perform these inspections. Even when end users are allowed to inspect, it’s strongly recommended to engage knowledgeable companies like Baghouse.com for an annual inspection. Book Now Your Baghouse System Audit.
Inspectors can identify issues beyond the checkpoints. For instance, they can uncover dust deposits on valve seats, which, if not cleared, can render safety components ineffective in the event of an explosion. Safety is contingent on the entire system functioning correctly, not just individual components.
Documenting the Inspection
A documented inspection or maintenance, conducted by an authorized company, is the formal way to prove compliance with OSHA and NFPA standards. Documentation is essential in case of accidents or incidents to demonstrate that regular maintenance occurred. When individuals without adequate training or authorization conduct inspections, they bear full responsibility for any faults. Conversely, following instructions and maintaining proper documentation shifts responsibility away from the end user.
We can assist by providing annual safety inspections for Dust Collection Systems in various industrial applications. These inspections include a comprehensive functional test of the entire system and a summary of recommendations based on our on-site survey for each dust collector.
Training for Safety
Regular training for key personnel is crucial. This includes not only personnel directly involved with the equipment but also those responsible for emergency procedures, such as Building Management System (BMS) operators. Having an accessible emergency checklist is vital for quick, effective responses during alarms, ensuring everyone knows what to do in critical situations. Read more about our Training for Maintenance and Safety Personnel.
In conclusion, compliance with safety and environmental regulations is non-negotiable in industrial dust collection systems. Regular inspections, documentation, and expert assistance are your best allies in maintaining a safe, compliant, and efficient dust collection operation. Our experts are ready to help you evaluate, diagnose, and improve the safety and efficiency of your dust collection system, ensuring a secure and sustainable workspace for all.
If you have any questions or need assistance with your dust collection system compliance, feel free to reach out to us. Your safety and peace of mind are our top priorities!
https://www.baghouse.com/wp-content/uploads/2023/09/Audit.jpg538910Andres Biancottihttps://www.baghouse.com/wp-content/uploads/2018/03/BH-Logo-Alt-01.pngAndres Biancotti2023-09-12 23:08:492023-09-13 16:12:25Dust Collection System Compliance – Ensure Your System Will Pass an Audit
Introduction: The Importance of Dust Collection Compliance
Maintaining a safe and healthy workplace environment is a top priority for any business, and for industrial facilities, effective dust collection is a critical component. Not only does proper dust collection help protect workers from respiratory hazards and potential dust explosions, it also ensures compliance with regulatory requirements.
The Occupational Safety and Health Administration (OSHA), the Mine Safety and Health Administration (MSHA) and other government organizations set standards and guidelines to safeguard employees and minimize the risks associated with airborne particulates.
In this guide, we will explore the key aspects of dust collection compliance, covering everything from OSHA regulations to combustible dust hazards, design considerations, emissions monitoring, and more. By understanding and adhering to these essential requirements, businesses can create a safer working environment, mitigate potential hazards, and maintain regulatory compliance.
Occupational Safety and Health Administration (OSHA) Regulations
OSHA regulations apply to most private sector employers and their workers. Formed as a result of the Occupational Safety and Health Act of 1970, OSHA’s mandate is to ensure safe and healthy working conditions. If you are located in the US, it is likely that your facility is subject to OSHA standards.
OSHA provides guidance documents, fact sheets, and publications to help you understand and comply with their regulations. You can find these by searching the OSHA website. While you should be familiar with all OSHA requirements (consult your site EH&S expert), here are some key OSHA standards and regulations that are relevant for dust collection and control:
General Duty Clause: The General Duty Clause (Section 5(a)(1) of the Occupational Safety and Health Act) requires employers to provide a workplace free from recognized hazards that can cause serious harm or death. This clause serves as a broad requirement for employers to address dust hazards and implement effective dust control measures.
Respiratory Protection: OSHA’s Respiratory Protection Standard (29 CFR 1910.134) establishes requirements for the use of respiratory protection when employees are exposed to dust that exceeds permissible exposure limits. It includes guidelines for selecting, fitting, and training employees on the use of respiratory protection equipment.
Hazard Communication: OSHA’s Hazard Communication Standard (29 CFR 1910.1200) requires employers to properly identify and communicate the hazards associated with dust and ensure that employees are trained on the safe handling, storage, and disposal of hazardous substances.
Walking-Working Surfaces: OSHA’s Walking-Working Surfaces Standard (29 CFR 1910 Subpart D) includes requirements for maintaining clean and safe working surfaces, free from accumulations of dust or debris that could create slip and fall hazards.
Electrical Safety: OSHA’s Electrical Standard (29 CFR 1910 Subpart S) includes requirements for electrical equipment used in areas where combustible dust may be present. It addresses measures to prevent ignition sources and the potential for electrical hazards in dust collection systems.
Machine Guarding: OSHA’s Machine Guarding Standard (29 CFR 1910.212) establishes requirements for safeguarding machinery to protect workers from moving parts, including dust collection equipment. It ensures that appropriate guards are in place to prevent employee contact with hazardous machinery.
Combustible Dust: Although OSHA does not have a specific standard solely dedicated to combustible dust, they have issued guidelines and directives related to combustible dust hazards. OSHA’s Combustible Dust NEP (National Emphasis Program) provides guidance for inspecting facilities that handle combustible dust, emphasizing compliance with existing standards and the identification of potential hazards. See below for more information on combustible dust requirements.
It is important to note that OSHA requirements may vary depending on specific industry and location. Consult your relevant OSHA standard and your local EH&S professional to ensure compliance with all applicable regulations.
OSHA’s Combustible Dust National Emphasis Program (NEP)
OSHA’s NEP program is a directive aimed at addressing the unique hazards associated with combustible dust in various industries. The NEP provides guidance to OSHA compliance officers regarding the inspection, enforcement, and compliance activities related to facilities that handle combustible dust materials. The program aims to increase awareness, promote compliance with existing OSHA standards, and reduce the risk of dust-related incidents including fires and explosions.
The most critical Requirements of the NEP include:
Inspections: OSHA compliance officers conduct inspections of facilities that handle combustible dust. These inspections focus on identifying potential dust hazards, evaluating compliance with applicable standards, and determining the effectiveness of dust control measures.
Employee Training: Employers are required to provide adequate training to employees regarding the hazards of combustible dust, safe work practices, and emergency response procedures. Training should cover topics such as dust control measures, housekeeping practices, proper equipment operation, and the use of personal protective equipment (PPE).
Hazard Assessment: Facilities must conduct a thorough hazard assessment to identify potential sources of combustible dust, assess the severity of the hazard, and implement appropriate control measures. This assessment should consider factors such as dust generation, accumulation, dispersion, and ignition sources.
Housekeeping Practices: Proper housekeeping practices play a critical role in controlling combustible dust hazards. Facilities must establish regular cleaning procedures to minimize the accumulation of dust on surfaces, equipment, and ventilation systems. Vacuuming, sweeping, and other methods should be employed to prevent excessive dust buildup.
Ignition Source Control: Facilities must implement measures to control potential ignition sources that could ignite combustible dust. This includes proper electrical equipment selection and installation, grounding and bonding procedures, and isolation of ignition sources from dust-handling areas.
Engineering Controls: Employers are required to assess and implement appropriate engineering controls to minimize the risk of dust explosions. This may include the installation of explosion venting, deflagration suppression systems, spark detection systems, and deflagration venting ductwork.
Written Programs: Facilities must develop and maintain written programs that address combustible dust hazards, including procedures for dust control, equipment maintenance, inspections, employee training, incident reporting, and emergency response.
Understanding Combustible Dust Hazards
Combustible dust hazards pose a significant risk where fine particles of solid materials can become suspended in the air and create a potentially explosive atmosphere. Understanding the nature of these hazards is crucial for maintaining a safe working environment and implementing effective control measures. Combustible dust can arise from a wide range of materials, including organic substances like wood, grain, and food products, as well as inorganic materials such as metals, chemicals, and pharmaceuticals.
OSHA’s Dust Combustion Pentagon
The hazard potential of combustible dust arises when several factors, commonly known as the Dust Explosion Pentagon, come together. These factors include the presence of:
Combustible dust particles
An ignition source
Oxygen in the air
Dispersion of dust particles
Confinement of the dust cloud.
When these elements combine in the right proportions, they create a potentially explosive environment. Ignition sources can range from sparks, open flames, hot surfaces, electrical equipment, friction, or static electricity.
To mitigate combustible dust hazards, several preventive measures should be implemented:
Effective housekeeping practices are essential to minimize dust accumulation on surfaces, equipment, and ventilation systems, as excessive dust buildup increases the risk of ignition. Regular cleaning, including vacuuming and sweeping with appropriate equipment, can help control dust levels and prevent potential incidents.
Proper ventilation systems should be installed to control dust dispersion and maintain a safe working environment.
Potential ignition sources, such as electrical equipment, must be properly designed, installed, and maintained to minimize the risk of igniting combustible dust.
Explosion protection measures, such as explosion venting or suppression systems, can help mitigate the severity of explosions if they do occur.
Understanding combustible dust hazards is essential for identifying potential risks and implementing appropriate control measures. By conducting thorough dust hazard assessments (see below), implementing effective housekeeping practices, controlling ignition sources, and employing engineering controls, employers can significantly reduce the risk of dust-related incidents as well as fines and violations, and ensure the safety of their workers and facilities.
National Fire Protection Association (NFPA) Standards
The NFPA (link to NFPA site) is a non-profit organization dedicated to eliminating death, injury, property, and economic loss due to fire, electrical, and related hazards. You should familiarize yourself with all requirements applicable to your site, but here are the most commonly referenced NFPA standards related to dust collection and control:
NFPA 654: Standard for the Prevention of Fire and Dust Explosions from the Manufacturing, Processing, and Handling of Combustible Particulate Solids: NFPA 654 provides guidelines for preventing fire and dust explosions in facilities that handle combustible particulate solids. It covers various aspects of dust control, including hazard identification, assessment, and mitigation measures. The standard emphasizes the importance of conducting a Dust Hazard Analysis (DHA) to identify potential hazards, implementing effective housekeeping practices, and using appropriate explosion protection systems.
NFPA 68: Standard on Explosion Protection by Deflagration Venting: NFPA 68 focuses on the design, installation, operation, and maintenance of deflagration venting systems. It provides guidelines for venting combustible dust explosions to minimize damage and protect personnel and equipment. The standard outlines requirements for calculating vent areas, selecting venting devices, and establishing proper vent duct designs.
NFPA 69: Standard on Explosion Prevention Systems: NFPA 69 addresses explosion prevention systems used to protect industrial processes and equipment. It covers various protection methods, including deflagration venting, flameless venting, explosion suppression, and explosion isolation. The standard provides requirements for designing and installing these systems to mitigate the risk of dust explosions.
NFPA 70: National Electrical Code (NEC): While not specific to dust collection, the NEC provides guidelines for electrical installations, including those in areas where combustible dust may be present. It covers proper electrical equipment selection, wiring methods, grounding, and bonding to prevent ignition sources in dust-handling environments.
NFPA 91: Standard for Exhaust Systems for Air Conveying of Vapors, Gases, Mists, and Noncombustible Particulate Solids: NFPA 91 focuses on exhaust systems used to convey air, vapors, gases, mists, and noncombustible particulate solids. While primarily addressing general ventilation systems, it includes provisions for dust collection systems, including requirements for ductwork, air velocity, explosion venting, and spark detection systems.
NFPA 664: Standard for the Prevention of Fires and Explosions in Wood Processing and Woodworking Facilities: This standard is applicable to wood shops and wood processing facilities.
These are just a few of the many NFPA standards related to dust collection and control. Consult the specific NFPA standards applicable to your industry and operations to ensure compliance with best practices and industry guidelines for preventing dust-related hazards.
Contact us to consult with a baghouse expert and receive guidance on how to comply with NFPA requirements.
Dust Hazard Analysis (DHA): Identifying and Mitigating Risks
NFPA 652 (Standard on the Fundamentals of Combustible Dust) provides details on conducting a DHA in accordance with the NFPA requirements. However, hear is a summary of the process:
Scope and Team Formation: Determine the scope of the DHA, identifying the areas, processes, and materials to be included in the analysis. Form a multidisciplinary team that includes individuals with expertise in engineering, safety, operations, and maintenance.
Hazard Identification: Identify potential sources of combustible dust and assess the likelihood and severity of a dust explosion or fire. This includes reviewing material safety data sheets (MSDS), conducting facility walkthroughs, and analyzing historical incident data.
Dust Hazard Assessment: Evaluate the characteristics of the dust, such as particle size, particle shape, combustibility, and explosibility. Consider the dust’s ignition sensitivity, explosion severity, and any potential secondary hazards. Assess the effectiveness of existing control measures and housekeeping practices.
Risk Evaluation: Determine the level of risk associated with identified hazards. Evaluate the likelihood and potential consequences of a dust-related incident, considering factors such as ignition sources, dust concentrations, ventilation systems, and equipment design.
Control Measures and Recommendations: Develop recommendations to mitigate identified hazards and reduce the risk of dust explosions or fires. This may include implementing engineering controls, such as improved ventilation or explosion protection systems, enhancing housekeeping practices, modifying equipment or processes, or providing training and personal protective equipment (PPE) for employees.
Documentation and Review: Document the findings, recommendations, and actions taken during the DHA process. Maintain clear records of the assessment, including the scope, team members, hazard identification, risk evaluation, and control measures. Regularly review and update the DHA to reflect any changes in processes, materials, or regulations.
Training and Communication: Ensure that employees and relevant stakeholders are trained on the hazards associated with combustible dust, the control measures in place, and the actions to take in the event of an incident. Promote a culture of safety and provide ongoing communication and education regarding dust hazards and prevention strategies.
Designing Dust Collection Systems for Compliance
It is critical that your dust collector system is designed in accordance with all applicable regulations. We strongly recommend you consult with a dust collection expert before and during your system design and installation to avoid costly rework, mitigation, or safety and health incidents at your site. Here are some general considerations when specifying system requirements or designing a dust collection system:
Identify Applicable Regulations: Understand the specific regulations and standards that apply to your industry and location. This may include Occupational Safety and Health Administration (OSHA) regulations, National Fire Protection Association (NFPA) standards, local building codes, and environmental regulations.
Conduct a Dust Hazard Analysis (DHA): Perform a comprehensive analysis of the dust hazards present in your facility. Identify the types of dust generated, their explosibility characteristics, and potential ignition sources. Use the DHA findings to inform the design of the dust collection system and control measures.
Determine Airflow and Capture Velocity: Calculate the required airflow and capture velocity based on the dust generation rate, size and weight of dust particles, and the proximity of dust sources to the collection hood. Ensure that the system is designed to effectively capture and contain the dust at the source.
Select Proper Collection Equipment: Choose appropriate dust collection equipment that meets regulatory requirements and is suitable for the specific application. Consider factors such as filtration efficiency, dust handling capacity, explosion protection features, and compatibility with the type of dust being collected.
Ensure Adequate Ventilation: Design the ventilation system to maintain a safe and healthy working environment. Provide sufficient air exchange rates, taking into account the size of the facility, the number of dust sources, and the type of operations being conducted. Ventilation should effectively control dust dispersion and maintain breathable air quality.
Implement Explosion Protection Measures: If handling combustible dust, incorporate explosion protection measures as required by regulations. This may include explosion vents, flameless venting, explosion and fire suppression, or deflagration containment systems. Ensure that the design of the dust collection system integrates these measures effectively.
Consider Noise Control: Dust collection systems can generate significant noise levels. Take measures to minimize noise through proper equipment selection, ductwork design, and the use of noise-reducing features like silencers or sound dampening materials.
Provide Easy Maintenance and Access: Design the system with accessibility in mind, allowing for easy maintenance, inspection, and cleaning of components. Incorporate features such as access doors, cleanout ports, and quick-release mechanisms for filters or collection containers.
Labeling and Signage: Ensure that the dust collection system is properly labeled and includes appropriate warning signs to indicate potential hazards, emergency shutdown procedures, and any necessary precautions for personnel.
Documentation and Record Keeping: Maintain thorough documentation of the dust collection system design, including equipment specifications, airflow calculations, hazard analysis reports, maintenance records, and inspection logs. Regularly review and update documentation to ensure compliance with changing regulations.
It is crucial to consult with industry experts, compliance professionals, and relevant regulatory agencies to ensure that your dust collection system design meets all applicable regulatory requirements – YOU are responsible for ensuring that your site is in compliance.
Emissions Monitoring and Reporting Requirements
Emissions requirements are another topic that many industrial professionals need to understand and comply with to avoid fines, mitigation actions, and potential health issues.
Understand Applicable Regulations: Familiarize yourself with the specific regulations and reporting requirements related to dust emissions monitoring in your industry and location. This may include local, state, and federal environmental regulations, air quality standards, and permit conditions. Also review your equipment permits to understand what requirements each piece of equipment is subject to.
Determine Monitoring Frequency: Determine the frequency at which dust emissions monitoring should be conducted based on regulatory requirements and any specific conditions outlined in permits or compliance agreements. This may include continuous monitoring, periodic sampling, or a combination of both.
Select Monitoring Methods: Choose appropriate monitoring methods that are approved and recognized by regulatory authorities. Common methods include stack sampling, opacity monitoring, gravimetric sampling, and real-time particulate matter monitoring. Ensure that the selected methods are suitable for the type of dust being emitted and provide accurate and reliable data.
Establish Monitoring Locations: Determine the appropriate locations for dust emissions monitoring. This may involve identifying critical emission points, such as stacks, vents, or process equipment, where emissions are expected to be generated. Consider factors such as representative sampling, accessibility, and compliance with monitoring requirements.
Calibrate and Maintain Monitoring Equipment: Regularly calibrate and maintain the monitoring equipment to ensure accurate and reliable measurements. Follow manufacturer recommendations and any specific calibration protocols specified by regulatory authorities. Keep detailed records of calibration dates, results, and maintenance activities.
Record and Report Monitoring Data: Maintain comprehensive records of all monitoring data, including measurement dates, locations, sampling methods, and results. Ensure that the records are accurate, well-documented, and readily accessible. Prepare and submit reports in accordance with regulatory requirements, including specified timeframes and data formats.
Compliance with Emission Limits: Regularly compare the monitoring data with the applicable emission limits or standards established by regulatory authorities. Take prompt action if emissions exceed permitted levels, and implement corrective measures to bring emissions back into compliance.
Stay Updated on Changes in Regulations: Stay informed about any changes or updates to regulations related to dust emissions monitoring and reporting. Monitor updates from regulatory agencies and industry organizations to ensure ongoing compliance with the latest requirements.
Retain Records: Retain monitoring records, reports, and documentation for the specified duration as required by regulations. This may vary depending on the jurisdiction, but it is generally advisable to keep records for a minimum of several years to demonstrate compliance and facilitate future audits or inspections.
Seek Professional Guidance: If needed, consult with a professional to ensure compliance with regulations, proper sampling techniques, and accurate reporting.
Compliance Audits and Inspections
Compliance audits and inspections are important processes to ensure that dust collection systems meet regulatory requirements and operate in a safe and environmentally responsible manner. Here is a summary of compliance audits and inspections that dust collection systems could be subject to:
Regulatory Compliance Audits: Regulatory agencies such as the OSHA and MSHA may conduct compliance audits to assess whether the dust collection system meets the relevant regulatory requirements. These audits may involve a review of permits, records, operational procedures, maintenance logs, and emissions monitoring data.
Safety Inspections: Safety inspections focus on identifying potential hazards and ensuring that appropriate safety measures are in place. Inspectors may check for proper installation and maintenance of equipment, compliance with electrical and fire safety codes, adherence to lockout/tagout procedures, and the presence of proper safety signage and personal protective equipment. These audits may be conducted by your site EH&S team or by external authorities (your local fire marshal, etc.)
Emissions Testing: Emissions testing is performed to measure the level of pollutants emitted by the dust collection system. This may involve the use of sampling equipment to collect dust samples, which are then analyzed to determine the concentration of specific contaminants. The results are compared against regulatory emission limits to assess compliance. The permits for your equipment may specify your emissions testing requirements.
Operational Audits: Operational audits evaluate the performance and efficiency of the dust collection system. They may include assessing the system’s airflow, pressure drop, filter cleaning efficiency, and energy consumption. These audits aim to identify any operational issues or opportunities for improvement. com conducts thorough audits of your dust collection system equipment.
Internal Audits: In addition to external audits and inspections, organizations may conduct internal audits to assess their own compliance and identify areas for improvement. These audits can be valuable for ensuring that all aspects of the dust collection system are operating effectively and in compliance with internal policies and procedures.
Training and Employee Awareness
Training is a critical component of operating dust collection systems, both to ensure your systems operate efficiently and for ensuring you stay compliant to all environmental, health, and safety requirements. Training should be conducted regularly for your maintenance, operations, engineering, EH&S, and management staff that are involved with dust collection.
Baghouse.com offers a comprehensive training program geared toward educating your entire staff on dust collection principals including system design and selection, operation, maintenance and troubleshooting, special considerations for combustible dust, and other relevant topics. We offer this training both on-site and remotely (via Zoom, etc.) and it can be tailored to your specific site requirements.
Specific maintenance and housekeeping practices may vary depending on your situation (if you handle combustible or toxic dust, etc.) but there are some general best practices to ensure your site stays clean and safe when dust is present:
Regular Equipment Inspections: Conduct regular inspections of your dust collection systems to identify any signs of wear, damage, or malfunction. This includes inspecting filters for leaks, ductwork, fans, valves, and other components. Address any issues promptly to maintain system efficiency and prevent potential safety hazards including dust emissions or dust buildup in your system.
Scheduled Maintenance: Establish a daily, weekly, and monthly preventative maintenance schedule for routine tasks such as filter replacement, replacement of pulse valve diaphragms, door seals, fan belts, and other items that wear out. Adhere to manufacturer guidelines and recommendations for maintenance activities to maximize the system’s effectiveness. Contact Baghouse.com for a useful maintenance checklist that you can tailor for your site.
Cleaning Procedures: Develop and implement proper cleaning procedures for the dust collection system and surrounding areas. This includes regular cleaning of ductwork, hoods, and equipment surfaces to prevent dust accumulation and potential hazards. Use approved cleaning methods and equipment that minimize the release of dust into the environment.
Training and Education: Provide comprehensive training to personnel involved in operating and maintaining the dust collection system (see above). Ensure they understand the importance of compliance with environmental, health, and safety regulations, as well as the proper procedures for maintenance, cleaning, and safe handling of materials.
Housekeeping Practices: Implement effective housekeeping practices to minimize the generation and accumulation of dust. This includes regular sweeping, vacuuming, and dampening surfaces to prevent dust from becoming airborne. Dispose of collected dust properly according to applicable regulations. Generally, visible dust in the air or on surfaces in your facility is a sign that housekeeping is needed, or that your system requires inspection and maintenance.
Hazardous Material Handling: If your dust contains hazardous materials, ensure proper handling, storage, and disposal procedures are followed in compliance with relevant regulations. Label containers appropriately, store hazardous materials in designated areas, and work with certified disposal contractors as necessary.
Record-Keeping: Maintain accurate records of maintenance activities, inspections, cleaning schedules, and any incidents or corrective actions taken. These records demonstrate compliance efforts and can be useful during audits or inspections.
Employee Engagement: Foster a culture of environmental, health, and safety awareness among employees. Encourage reporting of any concerns, near misses, or incidents related to the dust collection system. Regularly communicate updates, provide training refreshers, and involve employees in safety committees or initiatives.
Industry-Specific Compliance Considerations
Every industry and site has its own particular considerations for dust collection and control. Here are a few points to consider for some specific industries:
Manufacturing and Industrial Facilities: These facilities often generate dust from processes such as metalworking, woodworking, or chemical manufacturing. Compliance considerations may include proper containment of dust, selection of appropriate dust collection equipment, compliance with hazardous material handling and disposal regulations, and adherence to specific industry standards or guidelines.
Construction Sites: Construction sites can generate dust from activities such as concrete cutting, grinding, and demolition. Compliance considerations may include implementing dust control measures such as wetting down surfaces, using dust collection systems for equipment, proper storage and handling of construction materials, and compliance with local air quality regulations.
Pharmaceutical and Food Processing Industries: These industries require strict adherence to cleanliness and hygiene standards. Compliance considerations may include utilizing dust collection systems designed for sanitary applications, ensuring the use of appropriate filter materials to prevent cross-contamination, compliance with Good Manufacturing Practices (GMP), and adherence to industry-specific regulations and guidelines.
Mining and Quarrying Operations: Mining and quarrying activities often generate significant amounts of dust. Compliance considerations may include implementing effective dust control measures such as water spraying or dust suppression systems, proper ventilation and exhaust systems, regular monitoring of air quality, and compliance with mining-specific regulations and guidelines. MSHA has specific requirements aimed at preventing and controlling exposure to hazardous levels of respirable dust that cause lung disease, including coal workers’ pneumoconiosis (CWP) or silicosis. MSHA regulates dust collection systems and has a process for equipment approval for use in mining operations, and conduct regular inspections of mining operations.
Energy and Power Generation: Power plants, including coal-fired facilities, face specific compliance considerations for dust collection and control. Compliance measures may include the use of high-efficiency particulate air (HEPA) filters, compliance with emission limits for particulate matter, proper handling and disposal of fly ash or other byproducts, and adherence to industry-specific regulations and guidelines.
There are multiple government agencies (federal, state, and local) that likely have regulations that apply to your site and your dust collection systems. It is critical that you understand and comply with all regulations to avoid costly fines, mitigation actions, and most importantly, environmental or safety incidents caused by a failure to comply. Baghouse.com has many years of experience working with customers in multiple industries, and provides consulting for customers to help ensure your systems are compliant.
British Columbia’s workplace regulatory body, WorkSafeBC, fined West Fraser Mills, a wood product firm that operates in both the United States and in Canada, $115,000 for having combustible dust present at several of their locations. Inspectors noticed the potentially combustible wood dust around several electrical fixtures, appliances, motors, and moving machinery parts. The flammable dust is supposed to be collected and cleaned up in the locations in which it’s produced. Places with heat and electricity become safety hazards quickly when the dust is not taken care of properly.
Key Takeaways:
West Fraser Mills was issued a hefty fine for letting wood dust accumulate in their warehouses.
Fine wood dust comes from milling different wood products and can build up in several places.
Fine would dust is susceptible to catching on fire and would not need much to get it started.
“British Columbia’s occupational safety regulator, WorkSafeBC, issued a CAD$150,000 (about $114,000) fine to wood products firm West Fraser Mills this November for accumulations of combustible dust in several buildings at its Quesnel, BC manufacturing site.”
In July of 2016, the mismanagement of a heat exchanger led to an extensive series of explosions that resulted in damaging forest fires in Mississippi. The mismanagement was a result of Enterprise Products Pascagoula Gas Plant allowing the equipment to experience too much thermal fatigue. If there had been more extensive safety measures and inspection protocols set in place, these disastrous results may not have occurred, saving a plethora of vegetation and clean up funds.
Key Takeaways:
As regards a Mississippi gas leak explosion, a February 12 report points to thermal fatigue as the culprit.
Thermal fatigue refers to the weakening of materials over time, due to the stress of heating and cooling.
Upon inspection, it was clear that small cracks had arisen over time, due to temperature fluctuations.
“The plant – which had repaired four heat exchangers nine times in 17 years, CSB found – was shut down for nearly six months.”
https://www.baghouse.com/wp-content/uploads/2019/02/Pascagoula-Gas-Plant.jpg492768Jeremyhttps://www.baghouse.com/wp-content/uploads/2018/03/BH-Logo-Alt-01.pngJeremy2019-02-25 13:00:052020-01-29 18:42:30Safety gaps led to explosions at Mississippi gas plant: CSB
Quickly finding and replacing leaking filters is crucial for keeping a baghouse operating at peak efficiency. The longer you take to replace the leaking filter the more likely you will have to report the event to your air quality control regulatory agency (reportable event) and the more abatement costs you will incur.
How Broken Bag Detectors Work
How triboelectric bag leak detection systems work – Courtesy of http://auburnsys.com/
Triboelectric broken bag detectors measure the amount of static electricity generated by dust particles in an airstream. Dust particles generate an electrical current when they encounter the insulated metal probe in the ductwork. A dust particle directly impacting the probe creates a DC signal while a particle passing near to the probe generates an AC signal. The latest generation of triboelectric detectors (such as the Auburn Systems’ TRIBO series) unify both signals and then output a measurement of particle concentration to a nearby control panel or transmit it to a PLC.
Using a Triboelectric Broken Bag Detector as Early Warning
Most leaking baghouse filters begin as small holes or rips that overtime become worse and worse. Catching a leak quickly is crucial. The longer a leak persists the worse it becomes, often quickly causing a plant to exceed its maximum PM 2.5 emissions limits set out in its air permit. Additionally, abatement requirements quickly increase as a leak continues over time.
Older optical emissions monitors (i.e. opacity meters) and optical bag leak detectors can only detect a filter leaking so badly damaged that the increase in emissions exceeds 10% opacity (often greater than the maximum permissible levels for many air permits).
Triboelectric systems are sensitive enough to detect even the smallest of increases in dust emissions such as when a bag first begins leaking. Operators can then examine the realtime trending emissions data to see whether it was a sudden spike indicates a damaged bag (such as from quickly worn hole) or slow rise indicating wearing filters.
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Using Broken Bag Detector to Pinpoint Which Filters Are Leaking
An added advantage of triboelectric bag leak detectors is they can enable operators and maintenance technicians to pinpoint exactly which bags are leaking and need to be replaced.
Personnel should carefully monitoring emissions while cleaning system runs. When emissions spike during one cleaning cycle it means that leaking filters are present. Using this method, maintenance personnel can trace the leaking filters down to a specific baghouse, compartment and even row (pulse jet only) of bags. This saves time and money over traditional dye leak testing.
However, on older units, or when first beginning to troubleshoot a unit dye leak testing should still form part of your maintenance schedule. Dye leak testing can pinpoint multiple leaks at once, and in structural components as well as filters.
By quickly pinpointing leaking filters maintenance staff also reduce the amount of abatement required after the leak is fixed.
Below is the sample data from a test conducted to determine the differences in performance between a triboelectric leak detection system and a typical optical system (opacity meter). Notice the huge difference in response time and abatement required.
When a baghouse goes down it often brings much down with it, from specific equipment to entire production lines to even entire plants due to emissions or health and safety issues. Preventing unscheduled baghouse shutdowns directly impacts the bottom line. In some facilities, losses from just one down day can add up to tens of thousands of dollars in lost production, fines and other costs. Therefore, investing in the maintenance and upkeep of these baghouse systems is well worth the initial capital costs.
Triboelectric dust monitoring system often prove one of the most cost-effect ways to improve dust collector maintenance and operation. With the ability to monitor emissions in realtime and trends over time, operators can better assess the condition and operation of their baghouses than those who rely solely on differential pressure.
For example, by carefully analyzing the triboelectric data trends maintenance planners can accurately predict when filters will no longer achieve their require collection efficiency and need a changeout. Further, they can begin preparations for the changeout in advance, sourcing filters and cages, obtaining contract labor for the changeout and scheduling the changeout for the next most convenient time (e.g. yearly maintenance shutdown). Compare this with the added costs and stress involved when a changeout is done at the last minute!
Additionally, as mentioned above, triboelectric bag leak detectors also prevent downtime by quickly alerting plant personnel to any leaks as soon as they begin to form. By catching leaks before they become serious plants can avoid stoppages for abatement, repair and any possible fines or sanctions from air quality regulators.
Recap of the Key Points
Triboelectric bag leak detectors directly impact the bottom line of your baghouse by improving maintenance efficiency, reducing downtime
Increased detection range means finding leaks quicker, before they become reportable events
See when filters first begin to fail allows predictive maintenance planning to reduce inconvenient shutdowns
Find leaking filter bags quicker, pinpoint down to specific unit, compartment and row without a dye leak test
Comply with MACT standards that require triboelectric broken bag detectors over opacity meters
Interested in a Triboelectric Broken Bag Detection System?
If you would like to know more about our line of triboelectric broken bag detectors and how they can benefit your facility contact us today for a free consultation and quote!
https://www.baghouse.com/wp-content/uploads/2018/03/TRIBO_dsp_U3200-2.jpg600749dominickdalsantohttps://www.baghouse.com/wp-content/uploads/2018/03/BH-Logo-Alt-01.pngdominickdalsanto2016-02-01 16:04:332019-05-06 23:03:51Find Leaking Baghouse Filters Faster with a Triboelectric Broken Bag Detector
Slag processing facility recently agreed to pay over $325,000 in fines for a violation of their air permit. What major infraction lead to such an immense fine? A broken differential pressure gauge on their baghouse!
By Dominick DalSanto Dust Collection Expert Baghouse.com
Portage, Indiana – On September 18th, 2014 a manufacturing plant agreed to pay $325,000 in fines over a broken dust collector differential pressure gauge and falsified reports.
Calumite Company LLC manufactures an additive for the glass industry made from recycled slag from nearby steel mills. As part of its air permit with the state of Indiana, the company is require to operate dust collection systems throughout the plant and to record and report their operation efficiency to state regulators.
Over a period of at least 16 months this particular unit did not have a working differential pressure gauge (also called a magnehelic gauge). Rather than replace the broken gauge, workers regularly estimated DP readings for their reports and then submitted them to state and federal regulators as required. The dust collector in question controlled emissions from the loading and unloading of the company’s product onto railcars and truck trailers. During the course of the investigation, several workers admitted to falsifying reports, and supervisors even admitted to knowing about the broken gauge, but signed-off on the readings and submitted the reports anyway.
A broken baghouse differential pressure gauge resulted in massive fines for one facility
What is Differential Pressure on a Baghouse?
State and federal regulators often use differential pressure readings to determine how efficiently a dust collector operates and thus use it as a standard for controlling emissions. Differential pressure is the difference in pressure between the clean and dirty air sides of a dust collector. As dirty air passes through the filters in a dust collector it encounters resistance from the fabric and any buildup dirty on the filters. When the filters are clean there is less resistance and thus a lower drop in pressure between the two compartments inside the dust collector. For this reason, differential pressure readings tell operators the current condition of the filters and the unit in general. If the DP is high, it can signify high dust loading, filter blinding (i.e. clogged filters) which in turn lead to high emissions. A abnormally low reading can also mean that the filters have holes in them or have come lose…also resulting in high emissions.
Lessons Learned? – Do Not Neglect The Dust Collectors
The company was fined for operating one of its dust collectors without taking accurate differential pressure readings. While most dust collection related penalties and fines are related to failure to replace blinded or torn dust collector filters (often due exceeded service life, lower efficiency media, or pushing too much airflow through the filters) this fine comes solely from a failure to accurately monitor the dust collector operation and to record and report it accurately.
The take away here is to never neglect dust collection system maintenance, operation, and especially as this case highlights, reporting. While keeping up with the many regulations, regulations, standards, and requirements imposed on facility managers for dust collection systems might pose a challenge, forgoing the needed maintenance to change something seemingly small and unimportant (in this case a DP gauge) will eventually cost far more in fines, lost productivity, system downtime, and repair costs than maintaining the system properly ever will.
https://www.baghouse.com/wp-content/uploads/2018/03/Dust-Collector-Magnehelic-Gauge.jpg397400dominickdalsantohttps://www.baghouse.com/wp-content/uploads/2018/03/BH-Logo-Alt-01.pngdominickdalsanto2015-01-23 12:24:232019-05-06 23:47:36Broken Dust Collector DP Gauge Leads to $325,000 in Fines
Massive steel mill looks to revise its air permit to allow for proportionally huge increases in its emissions, particularly PM10, VOCs, lead and manganese from its industrial dust collection system. Neighbors say its already emits far too much while the company says it is only a correct to reflect the actual state of the plant and will not result in increased emissions.
Controversy has surrounded a recent application to modify the air permits for a Severstal Steel Mill. Last week, the plant submitted an application to revise its current air permits with the Michigan Department of Environmental Quality for its operations at the Dearbourn, Michigan facility. Specifically, the revisions will allow for large increase in particulate emissions for the plants industrial dust collection systems, i.e. its baghouses. The company says that the revision is not an application for an increase, but rather a modification of the old permit which was inaccurate. The company claims that no increase in emissions will occur, only that the air permit will now accurate detail the existing emissions at the plant.
Neighbors and environmentalists in the area are not buying it. “Just to make a profit, you are going to expose these kids to pollution,” said Haidar Abdallah “That’s wrong.” Given that the area surrounding the massive plant, which produces over 5 million metric tones of rolled sheet and another 1.5 galvanized and galvannealed sheet in 2012, is already one of the most heavily polluted in the country. The EPA estimated the area’s toxicity score as 45 times that of the statewide average.
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Dust Emissions Increase or Revision to Accurate Levels?
The majority of the debate revolves around differing views on the increases in the plant’s application for the revised limits. According to the plant, “the permit Severstal is seeking from the MDEQ does not authorize us to emit more pollutants. The permit is a technical correction that is based upon the results of stringent testing rather than upon estimates. With this permit correction, Severstal will continue to meet all applicable state and Federal air regulations for the protection of the public health.”
Severstal bought the plant in 2004, when the Rouge Steel (the previous owner) declared bankruptcy. Since then, the company claims to have poured over $1.7 billion into the plant, largely in the form on new pollution controls such as improved dust collection systems. The plant recently upgrading several of its lines with “two state-of-the-art air pollution control baghouses” to control PM, lead and manganese emissions. According to the company, when they acquired the nearly 100 year old plant, it had not and could not provide accurate measurements of its emissions to the state regulatory board. They claim they followed a plan approved by state regulators to “plan, do, check, and act”. They invested in the new control technology, then they proceeded to check the emissions, and now they are simply submitting a now accurate report on the plant’s emissions levels.
While the company’s story does have merit, it is still hard to swallow the large increases bourn out by the numbers released from the application. In some cases, the plant is asking for a revision of over 5,500% of its lead emissions. On average, the company is asking for an increase for emissions of about 725 times the amounts previously allowed for. It should be noted that many of these increases are proportional, the real amounts here are still very small on many categories. (see chart below)
Residents and workers have cause for concern. The dangers from particulate (i.e. dust) pollution are well established and very real. Particulate matter exposure is linked to respiratory health problems and is proven to be an aggravating cause of several cancers and other respiratory aliments. Even more so the other contaminates involved here, namely lead and manganese pose a health risk. According to the American Lung Association, lead dust exposure ” can harm every system in the body, particularly targeting the nervous system.” It also can cause severe brain and kidney damage, especially in young children. Additionally, manganese is known to cause severe damage to the central nervous system.
In any case, the company will still have to win over the state regulatory boards to its side to gain approval for its plan. A public hearing on the issue has been scheduled for March 19th at Henry Ford Community College. Information portion starts at 6 p.m. and the public hearing begins at 7 p.m. The company has already invested a large amount of capital into bringing the plant into compliance with state and federal air pollution regulations for particulate matter, lead and other pollutants. Whether or not it has been enough may depend on how severe the public backlash over the dirty nature of its plant and more importantly its response.
| Dominick DalSanto is an author & dust collection 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 sales director 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.
Environmental groups claim the 1625 MW coal-fired plant in La Grange, Texas is exceeding PM2.5 emissions limits due to outdated dust collectors and poor operating practices.
July 20, 2012 Baghouse.com News | Environmental groups in Texas are suing one of the largest coal-fire power plants in the state, alleging the plant is violating its air pollution permits and emitting excess dust pollution. The Fayette Power Project located in La Grange, Texas, a 1,625 megawatt power plant located about 60 miles west of the state capital of Austin was served a notice of intent by the Environmental Integrity Project (EIP).
Excessive emissions often occur when plant operators fail to stay within require operating parameters (e.g. running the system to hot thus causing damage to the filter bags, placing too large of a load on the baghouse, etc.) or when they are using out-of-date equipment that is well past its recommended service life.
The EIP alleges LCRA (Lower Colorado River Authority the majority owner and operator of the plant) is in violation of its air pollution permits from the Texas Commission on Environmental Quality (TCEQ), specifically the limits on particulate matter (PM2.5), claiming that the plant uses antiquated electrostatic precipitators for dust collection instead of newer, more efficient baghouse filters.
The EIP, which is representing the Texas Campaign for the Environment and other environmental groups, previously filed six claims against LCRA, two were withdrawn, three others were dismissed by the courts, leaving only this issue to continue to the discovery phase in a Houston federal court. LCRA says that claim “involves unfounded allegations” and the costs of the suit “will eventually be passed on to ratepayers.”
“We’ve discovered what we believe are egregious violations of the air pollution permit for the power plant and that harms public health, pollutes the air that we all breath,” said Ilan Levin, the Associate Director of Environmental Integrity Project.
LCRA General Manager Becky Motal flatly denied the charges, and claims the environmental groups are harassing them despite being “one of cleanest coal-fired plants in Texas”. “This notice of intent to file yet another lawsuit with similar allegations as in a previous suit is completely unwarranted and harassing,” Motal said in a press release after they learned of the suit. “FPP [Fayette Power Project] is one of the cleanest and most efficiently operated coal plants in Texas, and I am proud of the conscientious, environmentally responsible work our employees do providing electricity to more than a million people in Central Texas.”
Texas Vs. The EPA – The Origins of the Battle
Currently, the Fayette plant operates under what is known as a “flexible permit”. meaning it allows for exceeding emissions levels in certain areas if they are made up for by better than required performance in other areas. The flexible permits are issued by the Texas Commission on Environmental Quality, the state agency charged with regulating and enforcing environmental laws in Texas. The EPA (the federal agency with ultimate authority over environmental law in the US) ruled several years ago that the flexible permits did not meet federal standards and were illegal. The situation between the EPA and the TCEQ plays a part in the case against LCRA.
Environmental groups are suing the Fayette Power Project located in LaGrange, Texas saying it violates its air permits, and needs to install new air pollution control equipment, including new more efficient baghouse filter systems to replace older, less efficient ESPs.
According to Ilan Levin the Associate Director of Environmental Integrity Project, the LCRA is in the process of obtaining a new permit to increase levels for particulate matter emissions from the state board. “We are trying to enforce the permit that is currently on the books,” he says. “Now EPA has already ruled that those flexible permits are illegal — that they don’t meet federal standards. And we agree with that. But nonetheless that’s the permit they have. And what we’ve found is that they’re not even meeting the limits in that awful flexible permit.”
In response Motal of LCRA said “FPP complies with all permit limits, and in most cases emissions are well below levels set by federal and state authorities. The authority says that the plant “has long been recognized as one of the cleanest coal-burning power plants in the state.”
ESPs vs. Baghouses – “Outdated ESPs not working very well”
In March 2011, the plant installed air scrubbers on Unites 1 and 2 at a cost of about $400 million. LCRA and its partner Austin Energy (which jointly owns Unites 1 and 2 with LCRA) says the air scrubbers now remove more than 95% of sulfur dioxide emissions. Prior to this local farmers accused the plant of contributing to the degradation of their surrounding farm land due to acid rain caused by the plant’s SO2 emissions. *
While environmentalists welcome the installation of the SO2 scrubbers, they believe the plant needs to do more regarding particulate matter (PM2.5 dust particles 2.5 microns in size and larger) emissions, which are linked to asthma, heart disease, premature death, and other respiratory conditions. The core of the current lawsuit claims the plant exceeded federal limits for PM2.5.
They say the plant needs to replace its outdated ESPs with newer, more efficient baghouse filter systems. “The LCRA Fayette Power Plant doesn’t have baghouses,” Levin says. “Instead they’ve got thirty-year old electrostatic precipitators or ESPs and those aren’t working very well. In fact, what we’ve found is that the really high levels of particulate matter pollution are happening when they start those coal-fired boilers up. And they are often in start-up mode for hundreds of hours per year.” Levins says that the LCRA doesn’t turn on their pollution controls that would capture particulate matter during those start-ups. “And so during start-up, the public is exposed to excessive and very dangerous levels of soot or particle pollution,” he says.
Today, filters (commonly known as baghouses or fabric filters) are used by plants to prevent the escape of particulate matter from their stacks. these are help in most opinions to be more efficiency than ESPs, which use electrodes to charge incoming dirty air that then passes by large electromagnetic plates that collect the charged dirt particles.
No Amicable Settlement in Sight
While both sides claim to be working to ensure a clean source of electricity for the surrounding area, it does not seem likely that the two parties will work things out by themselves. “The answer to the question ‘Why now?’ is that we feel like we have no choice. We’ve been talking to LCRA or trying to talk to LCRA for a couple of years,” Levin says. “We haven’t made any headway. We’re only bringing this lawsuit because the state regulators and the federal regulators, that is to say the Texas Commission on Environmental Quality and the EPA, are not enforcing the law.”
About The Author:
| Dominick DalSanto is an Author & Environmental Technologies Expert, specializing in baghouse filter 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. Born in San Bernardino county California, raised in Chicago Illinois, he currently resides in Buenos Aires, Argentina.
October 3, 2012 – Baghouse.com | Recently, the EPA has been busy issuing new air pollution regulations (Cross-State Air Pollution Rule, Cement MACT, Mercury MACT, etc.) and tightened several exiting ones (NESHAPs, NAAQs, etc). With the new standards, and revisions to existing ones, many formerly compliant facilities may not find themselves no longer able to meet their existing air permits. In addition, some facilities will need to complete the application process again for new permits based on the new standards. This process can be exceedingly difficult, due to the complexity of the regulations. Many facilities end up getting lost along the way, potentially costing them millions of dollars in the process.
A while back Baghouse.com had the opportunity to speak with Trinity Consultants, an international firm that specializes in assisting industrial companies with air quality regulatory compliance challenges, about the coming changes in the regulatory scene and how companies can avoid getting lost in the process. The following are some excerpts from that interview that we feel will be helpful for our readers.
Interview with Trinity Consultants
What would you say is the most difficult section of current clean air regulation for industry to come into compliance with?
“At present, the new 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) are the most difficult provisions of the clean air act regulations for new or modified facilities. U.S. EPA has also promulgated additional challenging requirements that affect specific industries or specific source types including 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 others.”
What problems do you encounter with regards to dust collection/particulate matter (PM2.5)emissions?
“Dust collection, capture, and control is an important consideration for compliance with the PM2.5 NAAQS as well as compliance with the new NESHAP, MACT, and NSPS noted above. ”
One of the “scariest” new regulations is the Mercury MACT; what role will baghouses play in meeting these new standards?
“Most technologies for collecting mercury emissions involve the use of a baghouse. The most common include injecting a material to absorb the mercury in the airstream, usually activated carbon or a proprietary sorbent compound, which then needs to be collected from the airstream just like any other particulate matter would be, by the baghouse. In some cases the only way to handle this increased particulate load is to upgrade the baghouse. This could mean replacing the bags with more efficient PTFE membrane bags, expanding the baghouse (either by added more compartments, using a larger baghouse, or by switching to pleated baghouse filter elements).”
What problems do you encounter frequently with the regulatory process that are the most frustrating?
“We have clients that have had to cancel proposed capital expansion projects due to the economic and/or operational infeasibility of complying with the new NAAQS provisions for PM2.5, SO2, & NO2.”
What can companies do when they feel overwhelmed by the often complex permitting process to make sense of the situation?
“Our clients frequently request staff from Trinity Consultants to train, advise, or develop strategic guidance for their environmental, management, operations, and/or legal staff on the complex environmental topics or have Trinity Consultants directly assist with their permitting and compliance needs.”
What do you feel is the most important thing for companies to keep in mind with regards to compliance issues?
“Stay up to date (fresh, timely) on the regulatory rule changes affecting their industry. Participate in industry associations or work groups that focus on environmental requirements for your industry. Companies can also find timely updates, regulatory notices, and training courses at www.trinityconsultants.com. We also suggest that companies subscribe to Trinity Consultants’ periodic publications which include Environmental Quarterly and eNews at www.trinityconsultants.com/subscribe”
How do these previously mentioned regulations come into play with regards to dust collection? (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 others)
“For existing utility sources, the 0.03 lb/MMBtu limit should easily be met with a good ESP, and does not force you into a baghouse – our understanding is the crossover point may be about 0.005 lb/MMBtu filterable. For new utility sources, the limit is very low and could only potentially be met with a baghouse. For cement plants, ESPs are likely a thing of the past and existing baghouses will likely need new filter media or polishing baghouses. There are many retrofit projects currently being pursued. With the new NSPS, lower than 0.002 gr/dscf bags are being evaluated. Getting suppliers to guarantee PM emissions limits on new units that meet the standards will be very challenging. In some places, two bags may be needed in series, one for lime injection providing some scrubbing effect and then a final bag house. Meeting the PM limit is very challenging for the cement industry, requiring periodic maintenance program improvements, even a single bag leak can take you out of compliance. Industrial-commercial-institutional boiler considerations: For solid fuel-fired boilers, it appears that fabric filters will be required (whenever the rule becomes effective). At this time, it’s impossible to tell what the reconsideration will do as many companies are looking to expand it. For liquid fuel-fired boilers, fabric filter may be an option. We expect companies that installed a new baghouse would have used a BLDS since it appears to be preferred over a COMS. We expect some companies will convert to natural gas instead of upgrading their solid and liquid-fired emissions controls.”
What specific problems do you find that companies have gaining compliance with regards to their baghouse?
“Opacity limits with short-averaging periods are a big problem for ESPs – almost any ESP on a solid fuel unit cannot run 100% compliance, though 99%+ is possible. A baghouse can run essentially 100% compliance. Since they all have COMS you record every hour. PM CEMS are a big problem as their accuracy is suspect – back-to-back testing with Method 5 and a PM CEMS can give very different answers.
For the cement industry, the greatest challenge in meeting the new PM limits, other than the limits being low, is the related requirement to meet the limits with a PM CEM. There is virtually no data of this type in the industry and the monitoring equipment is complex. Therefore, there is significant uncertainty at to whether the limit is achievable, day in, day out. According to the Council of Industrial Boiler Owners (CIBO) the level of emission reduction for industrial-commercial-institutional boilers has not been demonstrated to be achievable by industrial applications, and may only be achievable on a consistent basis with the use of new technology not commonly used in industrial applications. Electrostatic precipitator suppliers and bag house suppliers both indicate that this new standard is not achievable with the exception that the type of exotic filters used for clean rooms in food production and some pharmaceuticals may be applicable but at exorbitant cost.”
What aspect (or specific regulation or set of regulations) do you feel needs to be revised or reformed the most to make the regulatory process more conducive to industrial growth, while still providing protection for our environment?
“I believe EPA and state agencies need to revise or reform their dispersion modeling methodologies and/or tools to more realistically assess compliance with the new 1-hr NAAQS.”
Would you say that current regulation is hampering companies’ efforts to expand their operation?
“Yes.”
Advice for Companies
When working with a client to achieve overall compliance of their facility with applicable regulations, what advice or warnings do you give to them regarding the proper operation, and maintenance of their baghouse system?
How important is it for plants to make sure their dust collection system is functioning properly?
“It will be very important to demonstrate continuous compliance with the more stringent regulatory requirements.”
Do you believe that it is in a facilities best interest to upgrade outdated and undersized dust collection equipment? In your experience (expert opinion) do you feel that it is worth the investment in capital for the potential benefits?
“Upgrade decisions will be required on a facility by facility basis but in many instances, upgrading of equipment will be necessary / required.”
What percentage of your clients would you say are having problems with their baghouse system that are causing them to be out of compliance with clean air regulations?
“By and large, our clients are in compliance with clean air regulations (continuous compliance is not an option for business risk mitigation). However, the recent stringent regulations presents significant challenges and our clients are actively pursuing and developing solutions to implement in the next year or two.”
About Trinity Consultants: Founded in 1974, Trinity Consultants is an international firm that specializes in assisting industrial companies with air quality regulatory compliance challenges. Trinity also provides professional training, environmental modeling software, EH&S information management solutions, and EH&S staffing services. Environmental professionals can subscribe to Trinity’s free Environmental Quarterly publication at trinityconsultants.com/subscribe.
| 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 Marketing Director 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. Follow Meon
https://www.baghouse.com/wp-content/uploads/2018/03/BH-Logo-Alt-01.png00dominickdalsantohttps://www.baghouse.com/wp-content/uploads/2018/03/BH-Logo-Alt-01.pngdominickdalsanto2012-05-28 13:47:462018-06-21 20:59:02Industrial Air Permits – New Clean Air Regulations and Baghouses
EPA chief resigns after outrage over comments saying EPA should figuratively “crucify” EPA offenders to set an example.
April 30 2012 – Baghouse.com News | A top EPA regional administrator resigned today over controversial comments regarding his views of how the EPA (Environmental Protection Agency) should enforce its environmental regulations, saying that the EPA should do like the ancient Romans who would crucify conquered villagers to set an example. Al Armendariz, the administrator for the EPA’s 6th region tendered his resignation after his remarks draw the ire of various members of Congress and the media.
In his letter of resignation to EPA Administrator Lisa Jackson, he expressed his regret over his statements, and claimed they did not reflect his work as an EPA administrator, or the EPA’s views general. However, he acknowledged that with the controversy his continued work at the EPA cause an undue distraction, and therefore he felt it necessary to resign.
At a local government meeting in Texas in 2010, Armendariz liked his “philosophy of enforcement” of EPA policy to how the Romans would use crucifixion to intimidate recently conquered lands. “It was kind of like how the Romans used to, you know, conquer villages in the Mediterranean,” he said. “They’d go in to a little Turkish town somewhere, they’d find the first five guys they saw, and they’d crucify them. And then, you know, that town was really easy to manage for the next few years,” he added.
Armendariz went on to related that “you make examples out of people who are in this case not complying with the law … and you hit them as hard as you can” — to act as a “deterrent” to others. He went on to say that the oil and gas industry needed to be an “enforcement priority” for the agency. The oil and gas industry along with the power generation industry have been coming under increased pressure from new and tougher environmental regulations such as the Cross-State rule, Mercury MACT, NESHAPs, and more. Many companies will need to make extensive investments in pollution control technologies such as dust collection systems, air scrubbers and mercury capture systems to comply with the new rules.
In accepting his resignation, EPA Administrator Jackson reiterated earlier sentiments that the EPA did not agree with Armendariz comments or views as expressed in his speech. “I respect the difficult decision he made and his wish to avoid distracting from the important work of the agency,” she said, thanking him for his service.
Critics Claim Remarks Are Evidence of Obama-EPA’s “Assault On Energy”
Critics of the EPA have taken the controversy as the latest proof that the “Obama-EPA” is playing partisan politics and is acting in bad faith to further the Administration’s alleged vendetta against the U.S. energy industry.
The controversy began earlier this week when Sen. James Inhofe (R-Okla.), a vehement critic of the Obama Administration (particularly on environmental issues) referenced the remarks in a speech on the Senate floor. Sen. Inhofe then proposed to launch an investigation into alleged politically-motivated bias on the part of the “Obama-EPA”.
Sen. Inhofe was not the only member of Congress to weigh in on the controversy. Several Republican lawmakers also expressed outrage and called for Armendariz to be fired including Reps. Steve Scalise (R-La.) and Pete Olson (R-Texas).
Rep. John Fleming (R-La.), called the comments “enviro-fascism at its worst.” The EPA’s Region 6 includes Louisiana, Texas, New Mexico, Arkansas, and Oklahoma.
House Speaker John Boehner (R-Ohio) reached out on Twitter, stating that the “Obama admin admits ‘crucify’ strategy for energy job creators.”
And Texas Gov. and recent Republican Presidential Primary candidate Rick Perry took the comments as “another reason to all-but-eliminate EPA” called the comments “unacceptable & offensive”.
Another top Republican, House Oversight and Government Reform Committee Chairman Darrell Issa (R-Calif.), plans to question EPA about the remarks. “He’s writing to EPA to seek clarification and express outrage with comments that are clearly at odds with the president’s prior comments on domestic energy production and that are clearly anathema to the cause of job creation,” a spokesman for Issa said.
In addition to lawmakers, several business and trade organizations are taking aim at the EPA over the controversy. Energy in Depth, an oil-and-gas industry group, is also highlighting the comments over Twitter and on its website, providing updates on the controversy including the calls for GOP members for his resignation. Other groups including the Business Roundtable and the Institute for Energy Research also took to Twitter to vent their feelings on the matter, criticizing the EPA and the Obama Administration.
The White House Denies Link To Armendariz Controversy – Cites Record As Proof
White House Press Secretary Jay Carney on Thursday called the comments at odds with the administration’s record of promoting oil-and-gas development and EPA’s approach. He pointed to increased oil and natural gas production in recent years as proof.
“The president’s approach, his all-of-the-above approach to our energy needs, I think documents and proves that those comments do not reflect his policy or the approach that the EPA has taken,” Carney said.
Carney also reiterated that the regional EPA official has apologized for the remarks. “What he said is clearly not representative of either this president’s belief in the way that we should approach these matters, or in the way that he has approached these matters, either from this office here in the White House or at the EPA,” Carney said at a press briefing.
While the ousting of Armendariz from his position is likely to be sufficient to reassure most, it is not likely to be the end of the matter. Given the serious implications of these words from a top level EPA administrator (one of the most important regions, the oil-rich South and Southwest), the Obama Administration’s tough stance on environmental issues, and role the booming U.S. oil fracking industry has in the nation’s future, ensure this issue will not go away. Republicans are likely to use this experience as a part of a continuing rally against Obama’s energy and environmental agenda…a fight that does not have a clear victor in sight.
| 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. Follow Meon
A clear description of the intended use of the explosion isolation system.
A clear description of the intended use of the explosion isolation system.
