How Can I Accurately Account For The Variable Opacity Of Particulate Matter Emissions From A Newly Installed Fabric Filter System At A Cement Manufacturing Facility, Given The System's Unique Pulse-jet Cleaning Mechanism And The Potential For Condensational Nucleation Of Submicron Particles, In Order To Ensure Compliance With The National Emission Standards For Hazardous Air Pollutants (NESHAP) Subpart LLL?
To ensure compliance with NESHAP subpart LLL for a cement manufacturing facility's fabric filter system, follow this structured approach:
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Understand Opacity and System Dynamics:
- Recognize that opacity measures light blockage by particulates, affected by pulse-jet cleaning and condensational nucleation of submicron particles.
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Performance Testing:
- Conduct baseline testing to measure particulate matter and opacity under various operating conditions, including during pulse-jet cleaning cycles.
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Continuous Emission Monitoring:
- Use certified opacity monitors, accounting for particle size and composition variability. Consider supplementing with Particulate Matter (PM) CEMS for accuracy.
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Pulse-Jet Cleaning Management:
- Schedule cleaning cycles to avoid interference with opacity measurements. If unavoidable, average opacity readings over periods including cleaning phases.
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Condensational Nucleation Mitigation:
- Model the system to predict nucleation conditions. Adjust exhaust gas temperature or use conditioning to minimize particle formation.
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Operating Parameter Monitoring:
- Track fabric filter parameters (differential pressure, cleaning frequency) to predict and manage opacity variations.
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Record Keeping and Reporting:
- Maintain detailed logs of opacity readings, maintenance, and system issues for compliance audits.
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Quality Assurance and Training:
- Implement regular audits and staff training to ensure reliable monitoring and system maintenance.
By integrating these strategies, the facility can effectively manage variable opacity and ensure NESHAP compliance.