326 IAC 20-13.1-9 Bag leak detection system requirements

Sec. 9. (a) The owner or operator of a secondary lead smelter shall install and continuously operate a bag leak detection system for all baghouses controlling process vents and process fugitive emissions sources unless a system meeting the requirements of section 10(g) of this rule for a CEMS is installed for monitoring the concentration of lead. Baghouses equipped with HEPA filters or baghouses followed by wet electrostatic precipitators used as secondary control devices are exempt from this requirement. The owner or operator of a secondary lead smelter shall maintain and operate each baghouse controlling process vents and process fugitive emissions sources to meet the following conditions: (1) The alarm on the system does not activate for more than five percent (5%) of the total operating time in a six (6) month reporting period. (2) The owner or operator of a secondary lead smelter shall include a corrective action plan in its standard operating procedures manual required in subsection (c) that specifies the procedures that will be used to determine and record the time and cause of the alarm in addition to necessary corrective actions taken to minimize emissions as follows: (A) The procedures used to determine the cause of the alarm shall be initiated within thirty (30) minutes of the alarm. (B) Procedures to determine and correct the cause of the alarm may include, but are not limited to, the following standard operating procedures: (i) Inspecting the baghouse for air leaks, torn or broken filter elements, or any other malfunction that may cause an increase in emissions. (ii) Sealing off defective bags or filter media. (iii) Replacing defective bags or filter media, or otherwise repairing the control device. (iv) Sealing off a defective baghouse compartment. (v) Cleaning the bag leak detection system probe, or otherwise repairing the bag leak detection system. (vi) Shutting down the process producing the particulate emissions. (b) The owner or operator of a secondary lead smelter shall demonstrate compliance with the bag leak detection system requirements by submitting reports showing that the alarm on the system does not activate for more than five percent (5%) of the total operating time in a six (6) month period or two hundred nineteen (219) hours, if operated for four thousand three hundred eighty (4,380) hours in the six (6) month period, whichever is less. (c) The owner or operator of a secondary lead smelter shall calculate the percentage of total operating time the alarm on the bag leak detection system activates as the ratio of the sum of alarm times to the total operating time multiplied by one hundred (100). (d) The owner or operator of a secondary lead smelter shall prepare and at all times operate in accordance with a standard operating procedures manual that describes in detail procedures for inspection, maintenance, and bag leak detection, and corrective action plans for all baghouses (fabric filters or cartridge filters) that are used to control process vents, process fugitive, or fugitive dust emissions from any source subject to the lead emission standards in sections 3, 4, 5, 6, and 8 of this rule, including those used to control emissions from building ventilation. (e) The owner or operator of a secondary lead smelter shall submit the standard operating procedures manual for baghouses required by subsection (d) to the department for review and approval in accordance with section 13(b) of this rule. (f) The procedures that the owner or operator of a secondary lead smelter specifies in the standard operating procedures manual for inspections and routine maintenance must, at a minimum, include the following requirements: (1) Daily monitoring of pressure drop across each baghouse cell. (2) Weekly confirmation that dust is being removed from hoppers through visual inspection, or equivalent means of ensuring the proper functioning of removal mechanisms. (3) Daily check of compressed air supply for pulse-jet baghouses. (4) An appropriate methodology for monitoring cleaning cycles to ensure proper operation. (5) Monthly check of bag cleaning mechanisms for proper functioning through visual inspection or equivalent means. (6) Monthly check of bag tension on reverse air and shaker-type baghouses. The checks are not required for shaker-type baghouses using self-tensioning or spring loaded devices. (7) Quarterly confirmation of the physical integrity of the baghouse through visual inspection of the baghouse interior for air leaks. (8) Quarterly inspection of fans for wear, material buildup, and corrosion through visual inspection, vibration detectors, or equivalent means. (9) Except as provided in subsection (a), continuous operation of a bag leak detection system, unless a system meeting the requirements of section 10(g) of this rule for a CEMS is installed for monitoring the concentration of lead. (g) The procedures specified in the standard operating procedures manual for baghouse maintenance shall include, at a minimum, a preventative maintenance schedule that is consistent with the baghouse manufacturer's instructions for routine and long-term maintenance. (h) The owner or operator of a secondary lead smelter shall operate a bag leak detection system that meets the following requirements: (1) The bag leak detection system must be certified by the manufacturer to be capable of detecting particulate matter emissions at concentrations of one (1) milligram per actual cubic meter (forty-four hundred-thousandths (0.00044) grains per actual cubic foot) or less. (2) The bag leak detection system sensor must provide output of relative particulate matter loadings, and the owner or operator of a secondary lead smelter shall continuously record the output from the bag leak detection system. (3) The bag leak detection system must be equipped with an alarm system that will alert appropriate plant personnel when an increase in relative particulate loadings is detected over a preset level. The alarm must be located where it can be heard by the appropriate plant personnel. (4) Each bag leak detection system must be installed, calibrated, operated, and maintained consistent with the U.S. EPA guidance document "Fabric Filter Bag Leak Detection Guidance" (EPA-454/R-98-015, September 1997)* and with the manufacturer's written specifications and recommendations. (5) The initial adjustment of the system must, at a minimum, consist of establishing the following: (A) The baseline output by adjusting the sensitivity (range). (B) The averaging period of the device. (C) The alarm set points. (D) The alarm delay time. (6) Following initial adjustment and except as detailed in the standard operating procedures and maintenance plan required under subsection (f), the owner or operator of a secondary lead smelter shall not adjust the system's: (A) sensitivity or range; (B) averaging period; (C) alarm set points; or (D) alarm delay time. The owner or operator of a secondary lead smelter shall not increase the sensitivity of the system by more than one hundred percent (100%) or decrease the sensitivity by more than fifty percent (50%) over a three hundred sixty-five (365) day period unless the adjustment follows a complete baghouse inspection that demonstrates that the baghouse is in good operating condition. (7) For negative pressure, induced air baghouses, and positive pressure baghouses that are discharged to the atmosphere through a stack, the owner or operator of a secondary lead smelter shall install the bag leak detector downstream of the baghouse and upstream of any wet acid gas scrubber. (8) Where multiple detectors are required, the system's instrumentation and alarm may be shared among detectors. (i) In addition to the record keeping and reporting requirements under section 14 of this rule, the owner or operator of a secondary lead smelter shall comply with the following: (1) Submit a report within thirty (30) days after the end of each preceding six (6) month period ending June 30 and December 31 of each year that includes the following: (A) A description of the actions taken following each bag leak detection system alarm pursuant to subsection (a). (B) Calculations of the percentage of total operating time, or the total operating time in hours and minutes the alarm on the bag leak detection system was activated during the reporting period. (2) Records for bag leak detection systems shall be maintained on site for a period of three (3) years and be available for an additional two (2) years and shall include the following information: (A) Records of bag leak detection system output. (B) Identification of the date and time of all bag leak detection system alarms. (C) The time that procedures to determine the cause of the alarm were initiated. (D) The cause of the alarm. (E) An explanation of the corrective actions taken. (F) The date and time the cause of the alarm was corrected. (G) Records of total operating time of an affected source during smelting operations for each six (6) month period. *This document is incorporated by reference. Copies may be obtained from the Government Printing Office, 732 North Capitol Street NW, Washington, D.C. 20401 or are available for review and copying at the Indiana Department of Environmental Management, Office of Air Quality, Indiana Government Center North, Tenth Floor, 100 North Senate Avenue, Indianapolis, Indiana 46204.