Example Baghouse Agency Operation & Maintenance Plan

The key element of the material outlined below is the facility's willingness to use no
visible emissions as an action level for taking corrective measures. If this had not been
the case, further monitoring techniques would have been requested. Examples of
monitoring techniques which are used to evaluate baghouse performance may be found in
the "Baghouse Periodic Monitoring Literature Review" following this O&M plan. The
literature review is a compilation of guidance from APTI training courses and other
sources on ways to monitor baghouse performance.
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The following baghouse parameters should be considered by the permit reviewer when
determining what is monitored and the frequency.

Baghouse Parameters
Baghouse type: Pulse Jet Reverse Air Shaker
Material handled:
Moisture problems possible: Yes No
Material corrosive: Yes No
If yes, are acid resistant bags in use: Yes No
Operating temperature (°F):
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Monitoring Guidelines
The facility makes a commitment to take timely corrective action during periods of
excursion where the indicators are out of range. A corrective action may include an
investigation of the reason for the excursion, evaluation of the situation and necessary
follow-up action to return operation within the indicator range. An excursion is
determined by the averaged discrete data point over a period of time. An excursion does
not necessarily indicate a violation of an applicable requirement. If the corrective action
measures fail to return the indicators to the appropriate range, the facility will report the
exceedance to the department and conduct source testing within 90 days of the
exceedance to demonstrate compliance with applicable requirements. If the test
demonstrates compliance with emission limits then new indicator ranges must be set for
monitoring and the new ranges must be incorporated in the operating permit. If the test
demonstrates noncompliance with emission limits, then the facility, within 60 days,
proposes a schedule to implement corrective action to bring the source into compliance
and demonstrate compliance.

General
Periodic Monitoring is not required during periods of time greater than one day in which
the source does not operate.

Example Baghouse Agency O&M Plan

2/19/2001
Weekly
• Visible emissions shall be observed on a weekly basis to ensure no visible emissions
during the material handling operation of the unit. If visible emissions are observed
this would be an exceedance not a violation and action will be taken as soon as
possible, but no later than 8 hours. If weather conditions prevent the observer from
conducting an opacity observation, the observer shall note such conditions on the data
observation sheet. At least three attempts shall be made to retake opacity readings at
approximately 2 hour intervals throughout the day. If unsuccessful that day due to
weather, an observation shall be made the following day.
• Check and document the baghouse pressure drop. If the pressure drop falls out of the
normal operating range, specified by the manufacturer, corrective action will be taken
within 8 hours to return the pressure drop to normal.

Maintain a written record of the observation and any action resulting from the inspection.

Monthly
• Check the cleaning sequence of the baghouse.
• Pulse jet baghouse - check the air delivery system
• Check the hopper functions and performance.
If leaks or abnormal conditions are detected the appropriate measures for remediation will
be implemented within eight (8) hours. Maintain a written record of the inspection and
any action resulting from the inspection.

Quarterly
• Thoroughly inspect bags for leaks and wear. (Look for obvious holes or tears in the
bags.)
If leaks or abnormal conditions are detected the appropriate measures for remediation will
be implemented within eight (8) hours. Bag replacement should be documented by
identifying the date, time and location of the bag in relationship to the other bags. The
location should be identified on an overhead drawing of the bag layout in the baghouse.
Maintain a written record of the inspection and any action resulting from the inspection.

Semiannual
• Inspect every 6 months all components that are not subject to wear or plugging,
including structural components, housing, ducts and hoods.

If leaks or abnormal conditions are detected the appropriate measures for remediation will
be implemented within eight (8) hours. Maintain a written record of the inspection and
any action resulting from the inspection.

Record Keeping and Reporting

Maintenance and inspection records will be kept for five years and available upon
request.

Quality Control

Example Baghouse Agency O&M Plan

2/19/2001
• The filter equipment will be operated and maintained according to the manufacturers
recommendations.
• An adequate inventory of spare parts shall be kept.

Authority for Requirement: 567 IAC 22.108(3)"b"

Example Baghouse Agency O&M Plan

2/19/2001
 Baghouse Periodic Monitoring Literature Review

Typical baghouse monitoring and indicating devices. APTI - SI:412A

Pilot Lights To show motors operating, compartments on- or off-line,

row of bags being pulsed

Opacity monitor To measure continuous opacity of stack

Manometer or magnehelic To determine pressure drop a various points in the

gauges baghouse. Recorders are useful to give permanent pressure
drop readings

Temperature indicators To determine temperature at critical points in baghouse

Gas flow meters To measure actual gas flow rate through the baghouse

Fan current, fan bearing To identify early warning signs indicating maintenance to
temperature and fan the fan
vibrator indicators

Routine maintenance APTI - SI:412A

Daily Maintenance
1. Check pressure drop.(Cite manufacturer maximum pressure drop and normal operating
range.)
2. Monitor gas flow rate.
3. Observe stack outlet; visually or with a continuous monitor, during material handling.
4. Monitor cleaning cycle; pilot lights or meters on control panel.
5. Check compressed air on pulse jet baghouses.
6. Monitor discharge system; make sure dust is removed as needed.
7. Walk through baghouse to check for normal or abnormal visual and audible
conditions.

Weekly Maintenance
1. Check all moving parts on the discharge system; screw-conveyor bearings
2. Check damper operation; bypass, isolation, etc.
3. Spot check bag tensioning; reverse air and shake bags.
4. Check compressed air lines including oilers and filters.
5. Blow out manometer lines.
6. Verify temperature-indicating equipment.
7. Check bag-cleaning sequence to see that all valves are seating properly.
8. Check drive components on fan.

Example Baghouse Agency O&M Plan

2/19/2001
Monthly Maintenance
1. Spot check bag-seating condition.
2. Check all moving parts on shaker baghouses.
3. Check fan for corrosion and blade wear.
4. Check all hoses and clamps.
5. Spot check for bag leaks and holes.
6. Inspect baghouse housing for corrosion.

Quarterly Maintenance
1. Thoroughly inspect bags.
2. Check duct for dust buildup.
3. Observe damper valves for proper seating.
4. Check gaskets on all doors.
5. Inspect paint on baghouse.
6. Calibrate opacity monitor.
7. Inspect baffle plate for wear.

Annual Maintenance
1. Check all welds and bolts.
2. Check hopper for wear.
3. Replace high-wear parts on cleaning system.

Example Baghouse Agency O&M Plan

2/19/2001
Minnesota Pollution Control Agency O & M Guidance for Baghouses

Inspect annually all components that are not subject to wear or plugging, including
structural components, housing, ducts and hoods. Maintain a written record of the
inspection and any action resulting from the inspection.

Inspect quarterly all components that are subject to wear or plugging. Maintain a written
record of the inspection and any action resulting from the inspection.

Check differential pressure once per week. Verify that it is within acceptable range.
Record the results.

Check visible emissions from the unit once per week. If visible emissions exist, inspect
equipment for evidence of malfunction, including broken bags. Record the results of the
inspection and any corrective action taken.

Calibrate mercury pressure switch annually and maintain a written record of the
calibration and any action resulting from the calibration.

Maintain pressure switch alarms with both horn and light in control room if pressure loss
to the bag puffer is detected.

Example Baghouse Agency O&M Plan

2/19/2001
Air Pollution Engineering Manual O & M Guidelines for Baghouses

Why Keep Records

1. Records permit the operator to be aware of continuing normal operation.

2. Records permit the operator to be aware of abnormal operation, such as sudden
failures or slowly changing parameters (e.g., slow rise in residual pressure that, if
allowed to continue, would limit the ability of the process to reach full load).
3. Records provide a historical record that is useful when troubleshooting problems.

What Records to Keep

1. Pressure drop.
2. Flow rate. Pressure-drop information cannot be interpreted properly unless the flow
rate is known. A record of flow rate may be useful in identifying a developing leak in
the ducting or in the baghouse itself.
3. Opacity. If a continuous opacity monitor is incorporated into the system, its output
should be recorded. If such opacity instrumentation is not available, visual opacity
readings recorded manually should still prove useful. The cause of any change in
opacity should be pursued and understood.
4. Temperature. The baghouse outlet temperature should certainly be monitored, even if
other temperature records are not kept.
5. Dust removal. At least one parameter related to the quantity of dust removed from
each baghouse compartment should be monitored and recorded. A change in dust
quantity may be indicative of baghouse failure or of process changes.

Example Baghouse Agency O&M Plan

2/19/2001
Baghouse Compliance Assurance Monitoring Guidance
(AWMA 89th Annual Meeting, 1996)

When evaluating a monitoring plan one should look for specification of:

• Monitoring location and frequency,

• Analytical device,
• Description of data acquisition / measurement with reporting units and recording
process,
• Basis for corrective action trigger levels,
• Separate corrective action time periods for diagnosing and remedying problems and
• Specific quality assurance / control procedures for proper monitoring operation.

Operational parameters monitored to demonstrate compliance are the following:

1. Visible emissions,
2. Pressure drop,
3. Opacity, Triboelectric effect or Light scattering effect,
4. Inlet and / or outlet gas temperature
5. Cleaning system operation,
6. Ash collection system operation and
7. Isolation damper operation.

The Secondary Lead Smelting NESHAP monitoring requirements are the following:

1. Daily monitoring of pressure drop of each compartment,

2. Daily visual inspection of stack emissions,
3. Daily visual inspection for adequate dust removal from hoppers,
4. Daily check of compressed air supply for pulse-jet baghouses,
5. Daily inspection of proper isolation damper operation,
6. Daily monitoring of bag cleaning cycle,
7. Weekly inspection of bag cleaning mechanisms,
8. Weekly check of bag tension on shake or reverse-air units,
9. Monthly internal inspection for air leaks,
10. Monthly inspection of bag condition and connections,
11. Monthly inspection of fan condition and operation, and
12. Continuous operation of a bag leak detection system based on triboelectric or light
scattering effects.

Example Baghouse Agency O&M Plan

2/19/2001