Industrial Dust Powder

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.”

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Gas Plant Explosion

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.”

Read more:

A entry level triboelectric broken bag detection system - Courtesy of

By Dominick DalSanto

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 Dust Detection Systems Work

How triboelectric bag leak detection systems work – Courtesy of

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.


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.

Leak Test ResultsTriboelectric Bag Leak DetectorOptical System
Estimated Time to:
Detect LeakLess than 1 Hour2-3 days
Locate Leaking Filter(s)Less than 1 Minute2-3 Man Hours (dye leak test)
Clean Up LeakLess than 1 Man-Hour8-10 Man Hours
Estimated Size of:
Hole Detected1/4”8”
Dust Accumulation2.6 cubic feet60 cubic feet
Dust Clean Up ToolShopvacShovels


Reduce Baghouse System Downtime

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!

Magnehelic gauge for reading differential pressure in a baghouse

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

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.

Magnehelic gauge for baghouse dust collection system

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.

Link to official case record:


Saverstal Steel Dearborn industrial dust collection system

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. 


By Dominick DalSanto
Baghouse Technology Expert and Sales Director

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.


Looking for baghouse filters? Contact us today for a free quote! Now providing free on-site visits in Las Vegas, Houston and San Diego Areas!

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.

Pollutant Location within Severstal plant Currently allowed Proposed revised % increase
PM10 (fine-particle dust) B Blast Furnace Casthouse Baghouse 2.85 lbs/hr. 7.6 lbs/hr 167%
PM10 C Blast Furnace Casthouse Baghouse 5.70 lbs/hr. 18.24 lbs/hr 220%
PM10 Relading fugitives 3.22 tpy (12-month rolling average) 3.6 tpy (12-month rolling average) 12%
PM10 Desulfurization – baghouse 1.55 lbs/hr. 3.6 lbs/hr. 132%
PM10 Desulfurization – roof 6.88 tpy (12-month rolling average) 24.38 tpy (12-month rolling average) 254%
PM10 BOF electrostatic precipitator 37.7 lbs/hr. 47.5 lbs/hr. 26%
PM10 BOF fugitives 7.25 tpy (12-month rolling average) 28.3 tpy (12-month rolling average) 290%
PM10 Combined B/C blast furnace casthouse fugitives 10.16 tpy 15.04 tpy 48%
PM10 Combined B and C stoves 14.16 lbs/hr. 27.84 lbs/hr. 97%
PM10 BOF baghouse 3.35 lbs/hr. 17.71 lbs/hr. 429%
CO (Carbon Monoxide) BOF electrostatic precipitator 3,057.4 lbs/hr. 7,048 lbs/hr. 131%
VOC (volatile organic compounds) C Blast Furnace Casthouse Baghouse 6.77 lbs/hr. 9.92 lbs/hr. 47%
VOC Combined B/C blast furnace casthouse baghouses 27.0 tpy 49.42 tpy 83%
Lead (Pb) C Blast Furnace Casthouse Baghouse 0.00015 lbs/hr. 0.0077 lbs/hr. 5033%
Lead (Pb) Desulfurization – baghouse 0.000278 lbs/hr. 0.0016 lbs/hr. 476%
Lead (Pb) Combined B/C blast furnace casthouse fugitives 0.000087 lbs/hr. 0.0064 lbs/hr. 7256%
Lead (Pb) Combined B/C blast furnace casthouse baghouse 0.000223 lbs/hr. 0.00753 lbs/hr. 3277%
Manganese (Mn) C Blast Furnace Casthouse Baghouses 0.00256 lbs/hr. 0.042 lbs/hr. 1541%
Manganese (Mn) Desulfurization baghouse 0.00064 lbs/hr. 0.013 lbs/hr. 1931%
Manganese (Mn) Combined B/C blast furnace casthouse fugitives 0.006 lbs/hr. 0.0448 lbs/hr. 647%
Manganese (Mn) Combined B/C blast furnace casthouse baghouses 0.00385 lbs/hr. 0.0597 lbs/hr. 1451%


Severstal Official Website

News article with full text of company’s statement regarding the revised emissions application.


| 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 His articles have been published not only on , 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.

By Dominick DalSanto

July 20, 2012 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 His articles have been published not only on , 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.


See Article Pecan Growers Blame Coal-Fired Plant For Killing Crops

Previous Articles on Air Permitting:

By Dominick DalSanto

October 3, 2012 – | 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 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  We also suggest that companies subscribe to Trinity Consultants’ periodic publications which include Environmental Quarterly and eNews at

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?


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?

“Periodic baghouse maintenance programs for many plants will need to be improved. There is a lot facility operators can do to make their baghouses run more efficiently.”

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


| 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 His articles have been published not only on , 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.

Al Armendariz EPA

EPA chief resigns after outrage over comments saying EPA should figuratively “crucify” EPA offenders to set an example.

April 30 2012 – 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 His articles have been published not only on , 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.

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 – 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 His articles have been published not only on , 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.

The EPA has issued proposed revisions to emissions standards for boilers and solid waste incinerators. These new rules once finalized will lead to increased demand for dust collection systems throughout industry. 

December 23, 2011 News – The Environmental Protection Agency proposed several revisions to its emissions standards for boilers and solid waste incinerators. The EPA rules set emissions limits for several different hazardous air pollutants, including mercury, particulate matter 2.5 (PM2.5) dioxins, cadmium, nitrogen dioxide and lead among others.

The rules, The Air Toxics Standards For Industrial Commercial and Institutional Boilers (Major and Source Facilities) and New Source Performance Standards (NSPS) and Emissions Guidelines (EG) for Commercial and Industrial Solid Waste Incinerators (CISWI), were originally proposed back in March 2011. The reason for the revisions according to the EPA was to address concerns raised by the public, and owners/operators during the public comment period. According to the EPA the proposed changes will still result in significant reductions in most pollutants, and even larger reductions in some, while limiting the financial burden from implementation as much as possible.

Boiler RegulationsThe revised rules will require only a small percentage of the total boilers in the U.S. to install pollution control equipment such as dust collection systems. The vast majority (86%) of boilers will not be covered by the rules at all, others (13%) will only be required to perform regular maintenance, and tune-ups to stay in compliance (also termed “workplace practices”). The remaining less than 1% of boilers are responsible for the vast majority of air pollution in this sector. They are mainly found in chemical processing, oil refineries, and other heavy industries. By retooling the rules to focus only on the largest emitters, the EPA hopes to improve flexibility in reaching compliance for smaller institutions.

The new regulations will result in over 8,100 premature deaths, 5,100 heart attacks, and 52,000 asthma attacks being avoided each year starting by 2015. The EPA estimates that for every $1 spent complying with these new regulations, the public will see $12 to $30 in health benefits. These results will be realized by reducing emission levels of compounds like mercury and lead, which are proven to cause developmental problems in young children and nervous system damage in adults and children, as well as by reducing particulate matter i.e. dust pollution, which is a severe asthma aggravator.

Existing major source boilers will have three years to come into compliance with the new regulations, with an additional year if needed technologies cannot be installed by then. CISWI units will have five years to comply.

The estimated annualized cost of the rule, as amended based on the reconsideration proposal, would be $1.49 billion, compared with $1.40 billion for the final rule. The estimated annualized cost would increase by about $90 million due to the addition of approximately 300 affected units to the revised inventory of units. This is the case even with a decrease in the stringency of some emission limits and less stringent PM control requirements for biomass units in the proposal.

Different Regulations For “Area Source” and “Major Source” Boilers

Major and Area Source Boilers RegulationsBoilers which only produce small amounts of air pollution are classified as “area source” boilers, and are mainly found in places like churches, hospitals, and commercial buildings. The majority of these burn natural gas (1.3 million), as such they are not covered by this rule. The remaining 187,000 area source burners that do not use natural gas would be covered by the new rules, of these only approximately 2% would have emissions limits, the other 98% would only need to follow workplace practices to stay in compliance.

Boilers that create large amounts of air pollution are classified as “major source” boilers. Of these approximately 14,00 boilers, most of which are found at heavy industrial sites such as refineries, and chemical processing plants, an estimated 88% (about 12,300) would only need to follow best work place practices, while the remaining 12% (about 1,750) will be required to reduce emissions, as well as increased monitoring, and record keeping.

Revisions Based On Public Comments

After allowing several months for public and industry comments regarding the original proposal, the EPA has included several of these suggestions into its revised proposal. Many of these are in response to claims that the original proposal was to restrictive in requiring the same standards across many different types of boilers in many different locations, applications, and that use different fuel sources. Among the proposed changes to make compliance easier, and fairer are the following:

Major Source Boilers:

  • Subcategories for different types of light and heavy liquid fuels
    • To reflect the real world differences in operating standards and requirements between the fuels
  • Different limits for PM 2.5 for different fuels
    • Different limits for boilers using biomass, coal, etc.
  • Revised limits for carbon monoxide
    • Subsequent studies have been provided that show that CO emissions vary greatly between boilers, and one universal limit is not practical
  • Allow for a alternative total selective metals emissions limit for select air toxics
    • To ease compliance costs, and improve flexibility
  • Remove dioxin limits and replace with work place practice requirements
    • Based on subsequent analysis showing dioxin levels in boilers are often well below accurately detectible levels
  • Increased flexibility in compliance monitoring requirements
    • Allow for monitoring from stack or continuous monitoring, and remove continuous monitoring requirement for biomass boilers
  • Remove emissions limits for units outside continental United States
    • To deal with unique operating circumstances and requirements for these units
  • Allow “clean gas” boilers to continue to be exempt from new standards
    • To improve flexibility and ease of compliance

Area Source Boilers:

  • Alter Initial tuneup schedule
    • Change compliance timeframe to two years, instead of one, create new categories of boilers and increase overall flexibility in compliance requirements
  • Alter tuneup schedule/requirements for seasonal units
    • Change from every other year to every five years for these infrequently employed units

Revisions To Commercial and Industrial Solid Waste Incinerators (CISWI) Standards

A CISWI unit is any device that is used to burn solid waste at a commercial or industrial facility. Examples of CISWI units include incinirators used to burn solid waste (i.e. garbage), energy recovery units designed to recover heat that combust solid waste; and kilns designed to manufacture products and also combust solid waste.

The revised CISWI standards provide for stricter emissions limits on nine major air pollutants regulated by the EPA (mercury, PM 2.5, lead, etc.). In addition, the new standards provide for new definitions of what exactly qualifies as solid waste, hazardous waste, etc. Many of the revisions for the new standards requested increased clarification in these areas. The subsequently revised standards have increased clarification on what materials are categorized as, allow for certain “non-hazardous secondary materials” to not be classified as solid waste when used as a fuel (e.g. certain wood products that are used as part of biomass fuel sources) and allow for plant operators to request the EPA to clarify, and reclassify certain materials based on site specific considerations.

The EPA estimates that, for some units, it would be more cost-effective to use an alternative disposal option. If those units use alternative disposal options, and the remainder use add-on controls, the total nationwide cost would be approximately $270 million. If all 95 CISWI units currently in operation use add-on controls, the total nationwide cost for complying with the rule, as amended, would be approximately $284 million per year.

What This Means For The Future

The EPA believes these newly revised standards will provide both added health benefits, and environmental protection while still not creating an unbearable burden for operators. “With this action, EPA is applying the right standards to the right boilers,” said Gina McCarthy, assistant administrator for EPA’s Office of Air and Radiation. “Gathering the latest and best real-world information is leading to practical, affordable air pollution safeguards that will provide the vital and overdue health protection that Americans deserve.”

WIth these new standards set to take effect in the near future, dust collection systems, baghouses, baghouse filters, etc. will be in high demand as many existing plants require extensive upgrades in order to reach compliance. In addition to these standards, the EPA’s newly issued mercury rule will also in many technologies (such as activated carbon injection) require upgrades to existing dust collection systems, or at minimum investments in more efficient baghouse filters or system tuneups.


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 His articles have been published not only on , 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.