Fabric Filter Baghouse Regulatory Assistance

Regulatory Assistance

For decades ETS has provided assistance to industrial clients in the development and implementation of strategies to gain compliance with Federal and State air regulations. These projects have run the gamut from assisting the client in developing a permit to operate; to the more complex project where we would develop a comprehensive emission inventory for the facility, compare the data with applicable regulations, then develop the required permits to operate. Other examples of ETS projects include:

• Interface with State Department of Air Quality (DEQ), review regulatory control systems, recommend improvements, provide assistance in implementation, and resolve conflicts with DEQ.

• Assist agencies in developing realistic enforceable codes.

• Provide interface with client and the DEQ, design a facility perimeter ambient monitoring network, oversee the acquisition and installation of the network, then assist in the data collection, analysis and issue quarterly reports to the agency on behalf of the client.

Example Case Details

ETS was commissioned to assist a client in violation of agency permitted limits for particulates, fluorides and NOx. The ETS work scope was to review the client’s overall compliance status and recommend a comprehensive program to gain compliance. In addition the client requested that ETS provide continued interface with the agency throughout the program.

An approach was developed along with a schedule to meet compliance and was presented to the DEQ. The plan was scrutinized by the agency and subsequently accepted. ETS was then requested to assist in implementation of the recommended approach, and providing continuing monitoring, data acquisition and reporting as required by the agency.

ETS was recently awarded a contract from a west coast DEQ to assist the agency in identifying the Best Available Retrofit Control Technologies (BARCT) suitable for installation within the 2011-2014 time frame to help the district attain PM_2.5 ambient air quality standards. The area is classified as “non-attainment” for PM_2.5 and must meet National Ambient Air Quality Standards (NAAQS) by 2015. Industries within the district of concern included several oil refineries, glass manufacturing, and cement manufacturing. The project involved visiting the facilities, acquiring and reviewing pertinent operational and emission data, evaluating suitable control technologies for each facility and predicting their impacts on SOx (a key pre-curser of sulfates and one of the principal components of PM_2.5 ) and PM_2.5. Technical and cost proposals were requested from a short list of vendors, along with their estimates for equipment delivery and installation. All information and analysis, vendor proposals and delivery schedules along with ETS conclusions and recommendations has been documented in an ETS report and utilized by the agency.

An ETS client was required to install and maintain a NOx continuous monitoring system (CEMS) as a requirement of the firms' permit to operate the facilities industrial boiler. The regulation stipulated that the client submit quarterly reports to the agency. These reports were to include average hourly NOx emission rates as well as a 30 day rolling average of these emission rates.  The client hired ETS to install and maintain the CEMs system, and conduct all necessary calibration and accuracy assessments. In addition the ETS work scope also included all data acquisition, analysis, and reporting. In this project ETS submitted the quarterly reports to the client for his subsequent submittal to the agency. The project ran for over eight years.

Additional regulatory assistance projects are presented in the case history section.