Standard Practice for PM Detector and Bag Leak Detector Manufacturers to Certify Conformance with Design and Performance Specifications for Cement Plants
5.1 EPA regulations require Portland cement plants that burn hazardous waste to use BLDs or PMDs to provide either a relative or an absolute indication of PM concentration and to alert the plant operator of the need to inspect PM control equipment or initiate corrective action. EPA and others have not established for these applications specific design and performance specifications for these instruments. The design and performance specifications and test procedures contained in this practice will help ensure that measurement systems are capable of providing reliable monitoring data.
5.2 This practice identifies relevant information and operational characteristics of BLD and PMD monitoring devices for Portland cement kiln systems. This practice will assist equipment suppliers and users in the evaluation and selection of appropriate monitoring equipment.
5.3 This practice requires that tests be conducted to verify manufacturer’s published specifications for detection limit, linearity, thermal stability, insensitivity to supply voltage variations and other factors so that purchasers can rely on the manufacturer’s published specifications. Purchasers are also assured that the specific instrument has been tested at the point of manufacture and shown to meet selected design and performance specifications prior to shipment.
5.4 This practice requires that the manufacturer develop and provide to the user written procedures for installation start-up, operation, maintenance, and quality assurance of the equipment. This practice requires that these same procedures are used for a field performance demonstration of the BLD or PMD monitoring equipment at a Portland cement plant.
5.5 The applicable test procedures and specifications of this practice are selected to address the equipment and activities that are within the control of the manufacturer.
5.6 This practice also may serve as the basis for third party independent audits of the certification procedures used by manufacturers of PMD or BLD equipment.
1.1 This practice covers the procedure for certifying particulate matter detectors (PMDs) and bag leak detectors (BLDs) that are used to monitor particulate matter (PM) emissions from kiln systems at Portland cement plants that burn hazardous waste. It includes design specifications, performance specifications, test procedures, and information requirements to ensure that these continuous monitors meet minimum requirements, necessary in part, to monitor reliably PM concentrations to indicate the need for inspection or corrective action of the types of air pollution control devices that are used at Portland cement plants that burn hazardous waste.
1.2 This practice applies specifically to the original manufacturer, or to those involved in the repair, remanufacture, or resale of PMDs or BLDs.
1.3 This practice applies to (a) wet or dry process cement kilns equipped with electrostatic precipitators, and (b) dry process kilns, including pre-heater pre-calciner kiln systems, equipped with fabric filter controls. Some types of monitoring instruments are suitable for only certain types of applications.
Note 1: This practice has been developed based on careful consideration of the nature and variability of PM concentrations, effluent conditions, and the type, configuration, and operating characteristics of air pollution control devices used at Portland cement plants that burn hazardous waste.
1.4 This practice applies to Portland cement kiln systems subject to PM emission standards contained in 40 CFR 63, Subpart EEE.
Note 2: The level of the PM emission limit is relevant to the design and selection of appropriate PMD and BLD instrumentation. The current promulgated PM emission standards (70 FR 59402, Oct. 12, 2005) are: (a) 65 mg/dscm at 7 % O2 (0.028 gr/dscf at 7 % O2) or approximately 30 mg/acm (0.013 gr/acf) for “existing sources” and (b) 5.3 mg/dscm at 7 % O2 (0.0023 gr/dscf at 7 % O2) or approximately 2.5 mg/acm (0.001 gr/acf) for “new sources.” On March 23, 2006 (71 FR 14665) EPA proposed to revise the PM standard for new cement plants to 15.9 mg/dscm at 7 % O2 (0.0069 gr/dscf at 7 % O2), or about 6-9 mg/acm (0.0026-0.0039 gr/acf). The emission standards may change in future rulemakings, so users of this practice should check the current regulations. Some types of monitoring instruments are not suitable for use over the range of emissions encountered at both new and existing sources.
1.5 The specifications and test procedures contained in this practice exceed those of the United States Environmental Protection Agency (USEPA). For each monitoring device that the manufacturer demonstrates conformance to this practice, the manufacturer may issue a certificate that states that monitoring device conforms with all of the applicable design and performance requirements of this practice and also meets all applicable requirements for PMDs or BLDs at 40 CFR 63, Subpart EEE, which apply to Portland cement plants.
Note 3: 40 CFR 63.1206 (c)(8) and (9) requires that BLDs and PMDs “be certified by the manufacturer to be capable of detecting particulate matter emissions at concentrations of 1.0 milligrams per actual cubic meter unless you demonstrate under §63.1209(g), that a higher detection limit would routinely detect particulate matter loadings during normal operations.” This practice includes specific procedures for determination and reporting of the detection limit for each PMD or BLD model.
1.6 This standard does not purport to address all of the safety concerns, if any, associated with its use. It is the responsibility of the user of this standard to establish appropriate safety and health practices and determine the applicability of regulatory limitations prior to use.
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