Appendix G

Technical Support Provided by Martin Marietta

Magnesia Specialties, Inc. for the New Exemptions

in GAC Rule 3745-17-07
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APRIL R. BOTT

CHESTERWILLCOX & SAXBE LLP

~rundC(f~cd 5Zaw

DIRECT DIAL (614) 334-6134

abott@cwslaw.com

October 14,2005

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VIA FACSIMILE AND HAND DELIVERY

Jim Orlemann

Manager

Division ofAir Pollution Control

Ohio EPA

P.O. Box 1049

Columbus, OR 43216

RE: Request for SIP Modification--Chapter 3745-17:

Inclusion of Exemption for Martin Marietta Magnesia SpeCialties

Dear Jim:

As we discussed during a recent telephone conversation, Ohio EPA is currently undertaking its

five year statutory rule review of Ohio Administrative Code ("O.A.C.") Chapter 3745-17. As

part ofthis process, Martin Marietta Magnesia Specialties ('~Martin Marietta") would like to

request a rule exemption from the requirements of O.A.C. §3745-17-07(A) during start-up and

shutdown ofkilns at Martin Marietta's Woodville, Ohio facility ("Woodville facility").

O.A.C. §3745-17-07(A)(3) currently exempts visible emission requirements for fuel burning

equipment equipped with baghouses or electrostatic precipitators ("ESP") during start-up and

shutdown.1 While kilns do not fit the sta~tory definition of "fuel burning equipment" found in

O.A.C. §3745-17-01, Ohio EPA has ackIlpwledged that kilns equipped with baghouses or ESPs

have issues analogous to fuel burning equipment during start-up and shutdown. Therefore, Ohio

1 At start-up, visible particulate emissions are not measured until the exhaust gases reach 250 degrees F at the inlet

to the control equipment. A higher start-up temperature may be incorporated ifthe facility demonstrates that the

higher temperature is needed for safety considerations or to prevent damage to the control equipment. O.A.C.

§3745-17-07(3)(a)(i). At shutdown, visible particulate emissions are not measured once the exhaust gases have

dropped below 250 degrees F at the inlet to the control equipment. A higher shutdown temperature may be

incorporated ifthe facility demonstrates that the higher temperature is needed for safety considerations or to prevent

damage to the control equipment. a.A.C. §3745-17-07(3)(b)(i).

Tel.ephone(614) 221-4000 65 East State Street Suite 1000, Columbus OH 43215-4213 Facsimile (614) 221- 4012
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Jim Orlemann

October 14, 2005

Page 2

EPA has expressed its willingness to exempt Martin Mariettta's kilns from the requirements of

O.A.C. §3745-17-07(A) during start-up and shutdown ifMartin Marietta demonstrates that

operating its control equipment during periods ofstart-up and shutdown is either: (1) unsafe or

(2) would cause damage to the control equipment. As set forth below, Martin Marietta can

demonstrate both.

By way of background, Martin Marietta operates five rotary lime kilns at the Woodville facility.

Three ofthe kilns, #4, #5 and #6, share a common baghouse. These three kilns are known as the

North Kilns. The two remaining kilns are known as the South Kilns. South Kiln #1 is controlled

by an ESP and South Kiln #2 is controlled by a dedicated baghouse. Martin Marietta believes,

based on technical guidance and first-hand knowledge, that operation ofthe kilns' baghouses at

temperatures lower than dew point is likely to cause failure ofthe bags in the baghouses and

damage to the control equipment itself. Likewise, operation of South Kiln #1's ESP outside of

steady-state parameters will likely result in dangerous operational conditions and ineffective

control of particulate. This assertion is supported by technical materials used by control

equipment vendors, U.S. EPA and testimony from Martin Marietta's own personnel. See,

Attachments A-E.

Baghouse Control Equipment:

The Woodville facility maintains two baghouses-one common baghouse which serves the three

North Kilns and one baghouse dedicated to South Kiln #2. As generally acknowledged in the

industry, with regulators and control equipment vendors, improper start-up and shutdown of a

baghouse can severely damage the equipment.

BHAIGeneral Electric, Martin Marietta's vendor for baghouse supplies, considers start-up and

shutdown critical periods of operation. BRA's Baghouse Troubleshooting, Attachment B. At

Woodville, operators face an extra level of concern because, unlike other manufacturing/process

operations which can increase temperatures quickly, the kilns at Woodville must be brought online slowly to protect replaced kiln refractories. Williams Mfidavit at 8. Refractories must be

cured slowly in order to assure operational integrity. Bringing kiln temperatures up too quickly

can result in improperly cured refractories, which could lead to serious and dangerous kiln

conditions at high temperatures. Williams Affidavit at 8.

During this slow start-up period, operation ofthe baghouses is detrimental to the life of

baghouses' bags and the control equipment itself Specifically, at ambient temperatures to

approximately dew point, the gases and particulate filtered to the baghouses are moist. See, U.S.

EPA's Fabric Filter Operation and Maintenance Training Guide, Lesson 6, U.S. EPA's Air

Pollution Training Institute, March 1995, page 6-6, Attachment c.2 At shut-down, gases and

particulate become moist once temperatures drop below the dew point.

2http://yosemite.epa.gOY/oaqpsfEOGtrain.nsf/fabbfcfe2fc93dac8525 6afe00483cc4/66645b5aa21 e381 c85256b6d004f

a335/$F1LE/si412a lesson6.pdf. This lesson is part ofEPA training course SI 412A, Fabric Filter Operation

ReYiew:http://yosemite.epa.goY/oaqpsfEOGtrain.nsf/DisplayView/S1_412A_0-5?Open Document
Jim Orlemann

October 14,2005

Page 3

When moisture is captured by the bags and mixes with captured dust and/or previously wetted

dust is captured, a very tenacious cake is formed on the surface ofthe filter bags. Cake formed

in this manner cannot be removed during the cleaning cycle ofthe collector, so the bags are

rendered useless and must be replaced. Failure to replace bags will create higher flow rates

through the rest ofthe bags in the collector causing increased dust abrasion leading to particle

penetration and failure of additional bags. Williams Affidavit at 14. In addition, when this

moisture condenses on the metal structure ofthe baghouse (walls, tubesheet, etc.) severe

corrosion results, thereby greatly reducing the operational life ofthe collector. Williams

Affidavit at 13.

Simply put, operation of any ofthe Woodville facility's kiln baghouses at a temperature under·

the dew point could cause failure ofthe bags and corrosion of.the equipment. In order to prevent

this situation from occurring, each kiln system should be stabilized at a temperature above the

dew point in order to rapidly raise the temperature ofthe baghouse through the dew point

temperature as it is brought into operation. At start-up, a temperature in the range of 350 degrees

Fahrenheit at each baghouse inlet will likely prevent the problems described above. For shutdown, once each baghouse inlet temperature drops below 350 degrees F, the same problems

detailed above could occur.

ESP Control Equipment:

South Kiln # I utilizes an ESP, installed in 1972, to control particulate. The kiln can be fired

using petroleum coke or coal, with natural gas serving as a start-up and stabilizing fuel. Buell

Engineering Company, the ESP's vendor, designed the ESP to treat kiln gas once the

temperature in the kiln exhaust reaches 600 degrees F. See, Buell ESP Summary, Attachment D.

Operation ofthe ESP at lower temperatures is very dangerous and ineffective to control

particulate.

U.S. EPA has issued a training document which advises that ESPs should generally not be turned

on until the accompanying process reaches steady-state condi\ions. Steady-state condition is

particularly important for ESPs using solid fuels like coal because internal arcing can cause a fire

or an explosion. See, U.S. EPA's ESP Operation and Maintenance Training Manual, Lesson 6,

U.S. EPA's Air Pollution Training Institute, Feb. 1998, page 6-5, Attachment E.3

At Woodville, this operational steady-state is reached at South Kiln #1 once a stable flame is

safely established and maintained using solid fuel. Williams Mfidavit at 17. Prior to that, there

is incomplete combustion and raw fuel is present. When raw fuel, new air and ESP sparking

combine, all the elements for a catastrophic event exist within the ESP. To protect workers and

equipment, the Woodville facility utilizes an alarm to signal the introduction ofsolid fuel to the

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30/$FfLEI12bles6.pdf. This lesson is part ofEPA training course SI 412B, Electrostatic Precipitator Plan

ReYiew:http://yosemite.epa.goY/oaqpslEOGtrain.nsf/DisplayView/SI_412A_0-5?Open Document
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Jim Orlemann

October 14,2005

Page 4

kiln. Once the alarm is sounded, employees must leave the kiln area until a steady-state flame

condition has been reached.

Unfortunately, both Martin Marietta and the Woodville facility's Process Engineering Manager

George E. Williams have seen the disastrous results of an unstable ESP. The Woodville facility

lost a second ESP, associated with South Kiln #2, to an explosion in 1990. In addition, Williams

witnessed an ESP explosion while working at an oil company. Williams Affidavit at 19.

Also, as with the North Kilns, the temperature of South Kiln #1 cannot be raised too quickly

because kiln refractories must be cured slowly in order to assure the integrity ofthe refractories.

In addition to being dangerous, the use of an ESP at lower temperatures is not effective for

control purposes since the resistivity oflime dust at the lower temperatures does not allow

enough particle charge to appropriately capture the emissions. Williams Affidavit at 20.

Other Region V Rules:

While Martin Marietta has some unique operating conditions, many ofthe baghouse and ESP

issues raised above are common to various industrial sectors. Numerous states, including Region

V states, specifically address start-up and shutdown in state regulations, without regard to

whether or not fuel burning equipment is involved.

For instance, Michigan requires "good air pollution control practices" to be utilized during startup and shutdown, without a requirement to operate control equipment. See, Mich. Admin. Code

Rule §336.1912. Indiana addresses start-up and shutdown emissions in operating permits on a

case-by-case basis, taking into account available technologies, safety, cost and ,other relevant

factors. See, 326 Indiana Admin. Code Rule §2-8-4. Minnesota requires that equipment be

operated in a manner specified by the equipment's design and consistent with good operating

practice. See, Minn. Admin. Code Rule §7011.0010 Subp. 4(A). \

Request for Exemption:

For the reasons set forth above, the operation of either the baghouses or ESP at the Woodville

facility during start-up and shutdown conditions is both dangerous and potentially damaging to

the control equipment and/or the associated kilns. Therefore, Martin Marietta respectfully

requests the addition ofthe following language to O.A.C. §3745-17-07(A)(3):

G) The start-up and shutdown of any kiln at Martin Marietta's Woodville facility:

(i) For any kiln equipped with a baghouse, until the exhaust gases have

achieved a temperature of 350 degrees Fahrenheit at the inlet ofthe

baghouse or after the temperature ofthe exhaust gases has dropped below

350 degrees Fahrenheit at the inlet ofthe baghouse.
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Jim OrIemann

October 14,2005

Page 5

(ii) For any kiln equipped with an electrostatic precipitator, until the kiln is

operating in a steady-state condition using solid fuel. Steady-state is

present when a stable flame has been established after solid fuel has been

introduced into the kiln.

Martin Marietta understands that Ohio EPA will present its modified version of O.A.C. §3745-17

for interested party comment within the next sixty days. As such, we will follow-up with you

shortly to schedule a technical meeting to discuss the specifics of our request. In the meantime,

please do not hesitate to contact either the Woodville facility's environmental engineer Joe

Green at 419-849-4258 or me if you have any questions regarding this submittal.

We look forward to working with Ohio EPA on this critical matter.

Respectfully,

jh~Oj(8utr

~;::.;~tt

ARB/ric

Enclosures

cc: Lee Burkleca, Ohio EPA-DAPC

Yvonne Bailey Esq.

Joe Green
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STATE OF OHIO

COUNTY OF SANDUSKY, ss:

AFFIDAVIT OF GEORGE E. WILLIAMS

The undersigned, George E. Williams, in his capacity as Process Engineering

Manager for Martin Marietta Magnesia Specialties, LLC ("Martin Marietta"), being fIrst

duly sworn on oath, states as follows:

1. I am employed by Martin Marietta as the Process Engineering Manager at Martin

Marietta's Woodville, Ohio lime facility.

2. I have been employed as a Process Engineer for Martin Marietta since 1979 and

have worked at Woodville since 1988.

3. Prior to working at Woodville, I worked in a Martin Marietta corporate office in

Baltimore, Maryland. At that time, I had primary responsibilIty for the

Woodville, Ohio and Manistee, Michigan facilities.

4. I received my B.S. in Chemical Engineering from the University ofFlorida in

1969, and I am a Professional Engineer licensed in Florida since 1978.

5. I have taken numerous environmental, health & safety and technical courses and

seminars relevant to my job as Process Engineering Manager.

6. As the Process Engineer Manager at Woodville, it is my responsibility to maintain

the safe operation and integrity ofprocess equipment, including pollution control

equipment.

7. There are fIve lime kilns at the Woodville facility, three kilns in the North Plant

and two kilns in the South Plant. These kilns must be brought on and offline

occasionally for maintenance, replacement ofrefractories and other operational

reasons.

8. Once a kiln is off-line, it must be brought back on-line slowly to assure the kiln

refractories have enough time to properly cure or dry out. Ifrefractories are

improperly cured, dangerous conditions in and around the kiln could result.

9. We use coal and petroleum coke as the primary fuels for the kilns, and natural gas

is used for start-up and to stabilize the flame as required under normal operation.

ATTACHMENT A
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10. Particulate emissions from the North Kilns are controlled through the use of a

shared baghouse.

11. Particulate emissions from South Kiln #2 are controlled through the use of a

dedicated baghouse.

12. Ifthe temperature ofthe exhaust gas from the kilns is less than the dew point,

moisture will condense from these gases as liquid droplets. These droplets can

combine with dust particles in the gas stream or be deposited on surfaces in the

baghouse, either the actual structure ofthe baghouse or the bags.

13. When this moisture condenses on the metal structure ofthe baghouse (walls,

tubesheet, etc.) severe corrosion results thereby greatly reducillg the operational

life ofthe collector.

14. When this moisture is captured by the bags and mixes with captured dust and/or

previously wetted dust is captured, a very tenacious cake is formed on the surface

ofthe filter bags. Cake formed in this manner cannot be removed during the

cleaning cycle ofthe collector. These bags are rendered useless and must be

replaced. Failure to replace these bags will create higher flow rates through the

rest ofthe bags in the collector causing increased dust abrasion leading to particle

penetration and failure of additional bags.

15. In my opinion, operation of any ofthe Woodville kiln baghouses at a temperature

under the dew point could cause failure ofthe bags and corrosion ofthe

equipment. In order to prevent this situation, the kiln system should be stabilized

at a temperature above the dew point in order to rapidly raise the temperature of

the baghouse through the dew point temperature as it is brought into operation. I

believe that a temperature in the range of300 - 350 degrees Fahrenheit at the

baghouse inlet will prevent the problems described above.

16. Particulate emissions from South Kiln #1 are controlled through the use of an

electrostatic precipitator ("ESP").

17. It has been my experience that the ESP cannot be safely utilized until the kiln

reaches steady-state conditions (i.e. stable temperature and safely established

solid fuel firing).

18. Ifthe ESP is turned on during an unstable transition period either start-up or

shutdown, there could be serious consequences.

19. It is possible for an explosion or fire to occur due to the likelihood ofsparks from

the ESP combining with raw, uncombusted fuel and air in the collector. I have

personally witnessed the results of an ESP explosion while employed with a

major oil company and again in 1990, after an ESP located on the Woodville

South Kiln #2 exploded.
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20. Further, utilizing this ESP at lower temperatures is not effective control since the

resistivity oflime dust at the lower temperature does not allow enough particle

charge to appropriately capture the emissions.

21. In my opinion, operation of South Kiln #1 's ESP during periods ofunstable

operating conditions such as start-up and shutdown could cause dangerous

conditions and equipment damage. Also, operation at lower temperatures gives

ineffective control.

Further affiant sayeth not.

George E. Williams

Affirmed to before me and signed in my presences this Lday of t9~:itf)oS

~Q.t:I~

Notary Public 0

BRENDA J. ElMER!, NorAR\' PUBlIC

State of Ohio

'" CommisIIoA Expires MatC1123. 2008
'," ""'I~f J•••• ;,'.11 .: II."~ I flf' ~\.. \ 1'1 "I til! 1\111' Ql;OIJ':

r .....

ATTACHMENT 0

11V ......... '

. ? ~I

•• r'~. • I I / , .

±15

600

440 Volts I Phase pO Cycle

Do 10m i te Lime I< i In

64,984

600

,0268

14

.02

99.7

BT.JEl,L'ENOINEERI~G('OMPAN"Y, l~C.

Mr. Virgil Tadsen, Vice President

Dolomitic Lime Kiln Precipitator Buell Reference 70M-18l85

1!00)ly ,,'

/IUI:I I "r't1H~H;·I"(' \ II ,',

App I i ca t i on

Quan t i ty .. ACFM

"'Fa~'" COLJ( 717 Z7Z-Z001 C~al..E: a~IE:l..tNC. l..E:ElANON .....

2153 NORTh r-OURTH STREET \.E:SANON. PENNSYLVANIA I"r)~<!

Temperature - OF

Gas Density - #/CF at Conditions

Grains/CF - Inlet at Conditions - Outlet at Conditions

Desired Efficiency, %

Mechanical Design Conditions

Pressure Inches W.G.

Temperature - QF

Required Power Supply

Atten t ion;

Gentlemen:

In accordance with discW5sions, the BUELL ENGINEERING COMPANY, INC.

proposes to furnish, in accordance with the conditions outl ined under NORMAL OPERATING CONDITIONS, dust col lection equipment and certain specific auxiliaries as hereinafter itemized and described.

The items qf equipment and services are listed. Details will be in

accordance with reference'd drawings, specifications, data sheets,

and conditions. Numbered items constitute the I imits of this pro- posal. '

NORMAL OPERATING CONDITIONS

June IS I 1970

Woodville Lime &, Chemical Company

p. 0. Box 218

Woodville, Ohio 43469

Subject~
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Lesson 6

ESP Operation and Maintenance

Goal

To familiarize you with typical operation and maintenance problems associated with ESPs.

Objectives

At the end ofthis lesson, you will be able to do the following:

1. Identify typical ESP components which require inspection prior to startup

2. Identify the major steps in ESP startup and shutdown procedures

3. Explain the importance ofmonitoring each ofthe following parameters:

Voltage/current

Opacity

Gas temperature

Gas flow rate and distribution

Gas composition and moisture

4. Describe the function of air-load and gas-load voltage-current curves

5. Identify typical maintenance steps that ensure proper ESP functioning

6. Identify and describe seven common problems that affect ESP performance

7. Describe how evaluating the current, voltage, and spark\rate trends from inlet to outlet fields

provides information about general resistivity conditions

8. Identify important safety precautions to take when operating ESPs

Introduction

As with any air pollution control system, an ESP must be operated and maintained according

to the manufacturer's recommendations. Plant personnel must be properly trained to perform

these activities with confidence and efficiency. This lesson reviews some ofthe key functions

that must be completed to keep the ESP operating as it was intended including installation,

startup and shutdown procedures, performance monitoring, routine maintenance and recordkeeping and problem evaluation.

2.0·2198 6-1

ATTACHMENT E
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Lesson 6

6-2

ESP Installation

Depending on the electrostatic precipitator chosen, production, installation and operation startup may take from a few months to one or two years. In any case, proper installation procedures will save time and money, and will also help in future operation and maintenance

(O&M) ofthe ESP.

Good coordination between the ESP designer (vendor) and the installation and maintenance

crews will help keep the ESP running smoothly for years. Occasionally this coordination is

overlooked. Because they are so large, ESPs are usually installed by skilled craftsmen who do

not work for the ESP vendor, and, therefore, may not be informed ofspecific installation

instructions. Since all design tolerances are critical (especially those affecting discharge and

collection electrode alignment), it is imperative that information about the proper installation

. procedures be transferred from designers to installers.

Some key considerations during installation are:

Easy access to all potential maintenance areas-fans, motors, hoppers, discharge devices,

dampers, flue gas flow rate and temperature monitors, insulators, rappers, T-R sets, and

discharge and collection electrodes

Easy access to all inspection and test areas-stack testing ports and continuous emission

monitors (opacity monitors)

Weather conditions-the ESP must be able to withstand inclement weather such as rain or

snow

During installation, the customer purchasing the ESP should be responsible for checking the

criteria presented below. The regulatory agency review engineer also should review the process on which the ESP will be installed and verify that these items are being addressed.

1. Uniform flue gas distribution across the entire unit. Ductwork, turning vanes, baffle

plates, and inlets with perforated diffuser plates all affect flue gas distribution. These items

are usually installed in the field and should be checked visually. Ifimproperly installed,

they induce high airflow regions that decrease collection efficiency and cause reentrainment of collected dust, especially during rapping cycles.

2. Complete seal ofESP systemfrom dust pickup to stack outlet. Air inleakage or outleakage

at flanges or collector access points either adds additional airflow to be processed or forces

the process gases to bypass the collector. Inleakage to a high-temperature system (hot-side

ESP) is extremely damaging, as it creates cold spots which can lead to moisture or acid

condensation and possible corrosion. Ifsevere, it can cause the entire process gas temperature to fall below the gas dew point, causing moisture or acid to condense on the hopper

walls, the discharge electrode, or collection plates. In addition, air inleakage and moisture

condensation can cause caking offly ash in the hopper, making normal dust removal by

the discharge device very difficult. The best way to check for leaks is an inspection ofthe

walls from inside the system during daylight. Light penetration from outside helps to isolate the problem areas.

3. Proper installation ofdischarge electrodes and collection plates. Collection electrodes are

usually installed first, and the discharge wires or rigid frames are positioned relative to

them. Check each section of electrodes to ensure that the electrodes are plumb, level, and

properly aligned.

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2.0-2198

ESP Operation and Maintenance

4. Proper installation ofrappers. Collection-plate rappers and discharge-electrode rappers

should be installed and aligned according to vendor specifications. Check magneticimpulse rappers to see ifthey strike the support frame on the collection plates. Check hammer and anvil rappers to see ifthe hammers strike the anvils squarely. Check vibrator rappers installed on discharge wires to make sure they operate when activated. Rapper

frequency and intensity can be adjusted later when the unit is brought on-line.

5. Proper insulation. Most ESPs use some type ofinsulation to keep the flue gas temperature

high. This prevents any moisture or acids present in the flue gas from condensing on the

hoppers, electrodes, or duct surfaces. Because most ESPs are installed in the field, check

that all surfaces and areas ofpotential heat loss are adequately covered.

6. Proper installation and operation ofdischarge devices. It is important to check the operation ofthe discharge devices before bringing the ESP on-line to see ifthey are properly

installed. Make sure that the discharge devices are moving in the right direction so they

can remove the dust freely from the hopper. A backward-moving screw conveyor can pack

dust so tightly that it can bend the screw.

Overfilled hoppers are common operating problems that can be avoided by proper installation and maintenance of discharge devices. Installed as maintenance tools, dust-level

detectors in the hoppers can help alert ESP operators that hoppers are nearly full.

7. Smoothly runningfans. Check fans for proper rotation, drive component alignments, and

vibration. Fans should be securely mounted to a component ofsufficient mass to eliminate

excessive vibration.

In addition to the 'above items, each ESP installation should have its own checklist reflecting the unique construction features ofthat unit. The installation crew should prepare a

checklist before beginning final inspection and initial startup. A prestartup .checklist for

the initial startup suggested by Peter Bibbo (1982) is shown in Table 6-1.

6-3
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Lesson 6

6-4

Col/ecting plates

1. Free of longitudinal and horizontal bows

2. Free of burrs and sharp edges

3. Support system square and level

4. Spacer bars and corner guides free

5. Free of excessive dust buildup

6. Gas leakage baffles in place and not binding

Discharge electrodes

1. No breaks or slack wires

2. Wires free in guides and suspension weight free on pin

3. Rigid frames square and level

4. Rigid electrodes plumb and straight

5. Free of excessive dust buildup and grounds

6. Alignment within design specifications

Hoppers

1. Scaffolding removed

2. Discharge throat and poke holes clear

3. Level detector unobstructed

4. Baffle door and access door closed

5. Heaters, vibrators, and alarms operational

Top housing orinsulator compartments

1. Insulators and bushing clear and dry with no carbon tracks

2. All grounding chains in storage brackets

3. Heaters intact, seal-air system controls, alarms, dampers, and filters

in place and operational

4. Seal-air fan motor rotation correct, or vent pipes free

5. All access doors closed

Rappers

1. All swing hammers or drop rods in place and free

2. Guide sleeves and bearings intact

3. Control and field wiring properly terminated

4. Indicating lights and instrumentation operational

5. All debris removed from precipitator

6. All personnel out of unit and off clearances

7. All interlocks operational and locked out

a. No broken or missing keys

b. Covers on all locks

Transformer-rectifier sets

1. Surge arrestor not cracked or chipped and gap set

2. Liquid level satisfactory

3. High-voltage connections properly made

4. Grounds on: precipitator, output bushings, bus ducts, conduits

Rectifier control units

1. Controls grounded

2. Power supply and alarm wiring properly completed

3. Interlock key in transfer block

Source: Bibbo 1982.

ESP Startup and Shutdown

A specific startup and shutdown procedure should be supplied by the ESP vendor. Improper

startup and shutdown can damage the collector. It is imperative for the operator (source) to

have a copy ofthese procedures. Review agency engineers may want to assure that these pro2.0-2198
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2.0·2198

ESP Operation and Maintenance

cedures exist at the sites and that the operators follow the procedures or document reasons for

deviations.

Startup

Startup of an electrostatic precipitator is generally a routine operation. It involves heating

a number of components such as support insulators and hoppers. Ifpossible, the ESP

should not be turned on until the process reaches steady-state conditions. As described in

Lesson 5, this is particularly important for ESPs used on cement kilns burning coal as fuel.

The internal arcing ofthe ESP could cause a flre or an explosion. When ESPs are used on

oil-burning boilers, the boiler should be started with gas or #2 fuel oil. Heavy oil (#6 fuel

oil) is not a good fuel for startup because tarry particulate emissions can coat collection

plates and be difficult to remove. Ifan ESP is used on a coal-flred boiler, the ESP should

not be started until coal firing can be verified. This will help prevent combustible gases

from accumulating in the unit and causing explosive conditions. A typical startup procedure for an ESP used on a boiler is given in Table 6-2 (Bibbo 1982).

Startup (preoperational checks - at least 2 hours prior to gas load):

1. Complete all maintenance/inspection items.

2. Remove all debris from ESP.

3. Safety interlocks should be operational and all keys accounted for.

4. No personnel should be in ESP.

5. Lock out ESP and insert keys in transfer blocks.

Prestart (at least one hour prior to gas load):

6. Check hoppers.

a. Level-indicating system should be operational.

b. Ash-handling system operating and sequence check - leave in

operational mode.

c. Hopper heaters should be on.

l. Check top housing seal-air system.

a. Check operation of seal-air fan-leave running.

b. Bushing heaters should be on. \

8. Check rappers.

a. Energize control, run rapid sequence, ensure that all rappers are

operational.

b. Set cycle time and intensity adjustments, using installed

instrumentation-leave rappers operating.

9. Check T-R sets.

a. Check half-wave/full-wave operation (half-wave operation is

recommended for filtering fly ash when lignite is burned and a

cold-side ESP is used.)

b. Keys should be in all breakers.

c. Test-energize all T-R sets and check local control alarm functions

d. Set power levels and de-energize all T·R controls.

e. Lamp and function-test all local and remote alarms.

Continued on next page

6-5
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Lesson 6

6-6

Gas load:

10. After gas at temperature of 200°F has entered ESP for 2 hoursa. Energize T-R sets.

b. Check for normal operation of T-R control.

c. Check all alarm functions in local and remote.

d. Within 2 hours, check proper operation of ash removal system.

e. De-energize bushing heaters after 2 hours (hopper heaters

optional).

Cold start (when it is not possible to admit flue gas at 200°F for 2 hours prior

to energizing controls), proceed as follows:

1. Perform steps 1-9 above. Increase rapping intensity 50%.

2. Energize T-R sets, starting with inlet field, setting Powertrac voltage

to a point just below sparking.

3. Successively energize successive field as load picks up to maintain

opacity, keeping voltage below normal sparking (less than 10

flashes/min on spark indicator).

4. Perform step 10d above.

5. After flue gas at 200°F has entered ESP for 2 hours, perform steps

10b, c, d, and e above.

Set normal rapping.

Source: Bibbo 1982.

Shutdown

When an industrial process is shut down temporarily, the ESP system should be de-energized to save energy. The shutdown ofthe ESP is usually done by reversing the order of

the startup steps. Begin with de-energizing the ESP fields starting with the inlet field to

maintain appropriate opacity levels from the stack. The rappers should be run for a short

time after the ESP is de-energized so that accumulated dust from the collection plates and

discharge wires can be removed. All hoppers should be emptied completely before bringing the unit back on line. A typical shutdown and emergency shutdown procedure for

ESPs used on industrial sources is given in Table 6-3 (Bibbo 1982).

2.0-2198
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Lesson 6

Fabric Filter Operation and Maintenance

Goal

To familiarize you with typical baghouse operation and maintenance problems.

Objectives

At the end ofthis lesson, you will be able to do the following:

1. Identify typical steps for baghouse inspection prior to starting up

2. Identify typical parameters that a facility operator should monitor while operating the baghouse

3. Describe typical operating problems associated with shaker, reverse-air, and pulse-jet

baghouses

Introduction

This lesson provides a general overview of common operating problems and maintenance

practices for fabric filter systems. The text is written as a general guide for both baghouse

operators and air pollution regulatory agency inspectors and permit reviewers. For the baghouse system operators, there are checklists and general guidelines on what to look for or to

avoid during the installation phases, instrumentation and recordkeeping suggestions for evaluating the operating systems, and examples ofsome common operating problems that can

occur.

For the agency inspectors and permit reviewers, this lesson provides information that will be

useful for performing field inspections, or for reviewing operation and maintenance (O&M)

plans that many state agencies require as part of air permit applications for air pollution control systems. The lesson is intended to provide a general compilation oftypical baghouse operating problems and typical checklists used during installation, startup, and operation. The

lesson also provides agency permit review engineers with sufficient technical information to

determine ifthe facility baghouse operators have adequate O&M plans in place to assure

proper operation ofthe baghouse and subsequent compliance with the regulations and/or permit limits.

A number ofsections ofthis lesson were extracted from the sources listed in the Suggested

Readings section at the end ofthis lesson. These sources provide much greater detail on fabric

filter system O&M procedures.

2.0·3/95 6-1

ATTACHMENT C
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Lesson 6

6-2

Installation

Depending on the baghouse chosen, installation and initial operation startup may take from a

few days to a few months. In any case, proper installation procedures will save time and

money and will also help in future operation and maintenance ofthe baghouse.

Good coordination between the baghouse designer and the installation and maintenance personnel will help keep the baghouse running smoothly for years. Occasionally this coordination

is overlooked. The baghouse is installed, turned on, and forgotten about until it stops working

completely. By then it may be too late to keep the unit going, and the baghouse may have to be

rebuilt or even scrapped. Some key features for the facility operator to evaluate during the

installation period are listed here:

Easy access to all potential maintenance areas - fans, motors, conveyors, discharge valves,

dampers, pressure and temperature monitors, and bags

Easy access to all inspection and test areas - stack testing ports and continuous emission

monitors (opacity monitors)

Weather conditions - the baghouse must be able to withstand inclement weather such as

rain or snow

The following features have been suggested for a properly designed and installed baghouse

(McKenna and Greiner 1982):

1. Uniform air and dust distribution to allfilters. Duct design, turning vanes, and deflection

plates all contribute to uniform gas distribution. Often, this equipment arrives loose and is

field-installed. Ifimproperly installed, it can induce high airflow regions that will abrade

the duct or bag filters or cause reentrainment and induce high-dust-concentration regions

that can produce uneven hopper loading and uneven fJlter bag dust cake.

2. Total seal ofsystemfrom dust pickup to stack outlet. Inleakage of air at flanges or collector access points either adds additional airflow to be processed or short-circuitsthe process

gases. Inleakage to a high-temperature system is extremely damaging, as it creates cold

spots and can lead to dew point excursions (gas temperature falls below the dew point) and

corrosion. Ifsevere, it can cause the entire process gas temperature to pass through the

dew point and result in condensate on the bags. E!ttly bag failure and high pressure drop

will generally result. The best check for leaks is for the installation technician to inspect

the walls from inside the system during daylight. Light penetration from outside isolates

the problem areas. It is particularly important to seal the dust discharge points in negative

systems. Inleakage here will result in incomplete or no discharge, which can lead to reentrainment problems, yielding high pressure drop and hopper fires.

3. Effective coatings andpaint. Most systems are painted on the exterior surfaces only.

Extra care should be taken to touch up damaged areas with a good primer and if equipment

is not delivered fmish-painted, apply it as soon as possible following erection. Unprotected primers allow corrosion to occur and require sandblasting and costly repairs for the

facility operators. Ifthe system has been internally protected with a coating, it should be

thoroughly inspected for cracks and chips, particularly in comers, and repaired before

operation begins. A poor interior coating can be worse than none at all because it will trap

corrosive elements between the coating and the surface it was intended to protect.

2.Q-3/95
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2.0·3/95

Fabric Filter Operation and Maintenance

4. Properly installedjilter bags. The fl1ter bags are the heart of any fabric fl1ter collection

system. Improper installation can result in early bag failure, loss ofcleaning effectiveness,

and thus high pressure drop and operating costs or increased stack emission. Each manufacturer provides instructions on the proper filter bag installation and tensioning (where

required). These must be explicitly followed. Very often, early bag failures can be traced

to improper installation. It is much easier for the installation technicians to check and

recheck bag connections, tensioning, locations, and so on, in a clean, cool, dry collector

than it will be one day after startup. Bag maintenance usually accounts for 70% ofannual

maintenance time and money. Extra efforts in this area during installation can have a significant effect.

5. Proper insulation installation. Insulation is typically used to prevent O&M problems on

high-temperature collector systems. When handling high-temperature gases, it is important to maintain the temperature ofthe gas and all collector components coming in contact

with it above the gas dew point. Much ofthe time, all or a part ofthe insulation is fieldinstalled. The installers should check to see that all surfaces and areas ofpotential heat

loss are adequately covered. In particular, they should check to see that field flashing also

has insulation beneath it Cold spots cause local corrosion. Gross heat loss may cause

excessive warm-up time or lower the gas temperature below the dew point.

6. Total seal between dirty side and clean side ofcollector. Remember, the primary purpose

ofthe dust collector is to separate the particulate matter from the gas by means offabric

fl1tration. This means that all the gas must pass through the fabric. Any leaks bypassing

the fabric filters will directly emit dust to the stack and therefore reduce the collection efficiency ofthe system. The time to inspect "bypass leaks" is before startup, when everything

is clean and accessible. The best technique is to use a bright light on one side ofthe plenum and visually observe for light penetration on the other. This is the most effective in

total darkness. The installers should take extra time to check this important area. Tracking

down stack emissions not associated with bag failures can be extremely difficult after

startup.

7. Properly installed and operating dampers. Most systems employ several dampers to isolate areas ofthe system or control the volume of air flow. Proper alignment ofboth internal blades and the operating linkage is important. In high-temperature applications, special

care must be taken to allow for proper operation arid sealing at the operating temperatures.

Some dampers may require readjusting after reaching high-temperature operation. In

modular systems, single modules are normally isolated for bag cleaning and maintenance.

Leakage through these isolation dampers can cause improper bag cleaning. It will also create a very poor ambient condition for maintenance workers to work in. This, in some

applications, can pose a health hazard, and in all applications results in lower-quality

workmanship or incomplete maintenance.

8. Properly operating mechanical components. Most mechanical components are designed

with a normal operating direction. Cylinder rod location, motor rotation, and so on, must

be checked. Remember, when hooking up an AC motor, the installer has a 50% chance of

being correct on the first try. Not only will a backward-moving conveyor produce no discharge, but it can pack material so tightly that it bends the screw. Left uncorrected, a

reversed screw conveyor will result in a full hopper. The industry abounds with horror stories where full hoppers have led to burned bags, or dust that has set up, requiring jackhammers to remove it.

6-3
(

Lesson 6

6-4

9. Smoothly runningjans. Fans must be checked for proper rotation, drive component alignments, and vibration. Fans should be securely mounted to a sufficient mass to prevent

excessive vibration.

10. Clean, dry compressed air. Most systems employ compressed air to operate dampers, controls, instruments, and so on. Probably more systems suffer shutdowns and maintenance

problems due to poor-quality compressed air than for any other reason. Clean, dry air is

necessary to maintain proper operation ofthe pneumatic components. In installations

where the ambient temperature drops below 32°F, a desiccant dryer system is generally

employed. Sometimes, insulation of air lines and pneumatic components will be required.

Often, these considerations are not included in the dust collector system, with "clean, dry

compressed air to be supplied by the owner." Remember the air must be clean and dry

when it reaches the pneumatic component.

Each baghouse installation should have its own checklist reflecting the unique construction

components ofthe unit. The installation crew should prepare a checklist before beginning the

final inspection and initial startup. Table 6-1 shows an example of a typical inspection and

startup checklist This checklist would be useful for the facility engineer to make sure that the

baghouse is properly installed.

Visually inspect:

Structural connections for tightness

Duct flanges for proper seal

Filter bags for proper seating in tube sheet

Dampers for operation and sequence

System fan, reverse-air fan, and conveyors - check for proper rotation

Electrical controls for proper operation

Rotary valves or slide gates for operation

2. Remove inspection door and check conveyor for loose items or obstructions.

3. Adjust ductwork dampers - open or at proper setting.

4. Remove any temporary baffles.

5. Test horn alarm system, if included, by jumping connected sensors.

6. Start screw conveyors and check for proper operatio'n.

7. Start reverse-air fan, if included.

8. Start system fan.

9. Log manometer and temperature (if appropriate) readings at 15-minute intervals; log readings.

10. Check to see that reverse-air dampers are cycling.

11. Adjust pressure drop cleaning initiation switch, if included.

12. Determine system air volume and adjust dampers, as required.

13. Check cell plates for dust leaks.

14. Check to see that dust is being discharged from hopper.

Source: McKenna and Greiner 1982.

Reproduced by permission of ETS. Inc.

Installation errors can have a disastrous effect on the operation and maintenance ofthe baghouse. Typical installation errors and their effect on O&M are given in Table 6-2.

2.0·3/95
(

Fabric Filter Operation and Maintenance

(

Item

Baffle plates and turning vanes - improper

installation or left out

Poor seal of flanges and access areas

Poor seal at dust discharge flanges

Cracked or chipped paint and coatings

Improper bag tensioning

(reverse-air bags)

Improper bag seating

Incomplete insulation

Seal between dirty and clean air

compartments

Duct damper alignment

Screw conveyor direction reversed

Fan mount

Fan belt alignment

Exposed compressed-air lines without drier

Lack of inspection access

Lack of maintenance access

Source: McKenna and Greiner 1982.

Reproduced by permission of ETS. Inc.

Immediate potential effect

Uneven dust distribution;

uneven hopper loading;

higher pressure loss

Inleakage resulting in:

reduced inlet volume

higher fan volume

higher operating costs

lower baghouse temperature

Incomplete discharge,

reentrainment; hopper fires

Aesthetics

Ineffective cleaning; bag

collapse .

Stack emission

Cold spots

Stack emission; dirtying of

clean side of plenum

Loss of flow control

No discharge

Noise - vibration

Noise - improper fan volume

Freeze-up - condensation

Lack of early warning signs

Lack of regular preventive

maintenance

Long term effect

Bag wear, duct wear,

hopper fires

Localized cold spots

resulting in:

component corrosion

bag degradation

Reentrainment; creeping

pressure drop

Corrosion

Bag wear; high pressure

drop

Compliance failure; bag

wear; high pressure drop

Corrosion

Compliance failure

Poor maintenance/ambient

air inleakage

Bent screw(s); full hopper;

fires

Broken components

Broken belts

Damaged downstream

components

Major problems

Major breakdowns

2.0-3/95

Operation and Maintenance Training

Before starting up the baghouse, the plant engineer should schedule training sessions for plant

employees that operate and maintain the baghouse. In these training sessions the following

subjects should be covered: systems design, system controls, critical limits of equipment,

function of each baghouse component, operating parameters that should be monitored, good

operating practices, preventive maintenance, startup and shutdown procedures, emergency

shutdown procedures, and safety considerations.

Supervisors, operators, and maintenance people should attend O&M training sessions. The

training could be provided by the baghouse vendoror by a consulting company specializing in

baghouses. Many companies have in-house expertise to provide training. The length oftraining would vary depending on the complexity ofthe system design. Average training will ordinarily take at least 40 hours for full-time maintenance people.

6-5
Lesson 6

6-6

Baghouse Startup and Shutdown

A specific startup and shutdown procedure should be supplied by the baghouse vendor.

Improper startup and shutdown can damage the equipment. Ifhot moist gases are to be filtered, the baghouse must be preheated to raise the interior temperature in the baghouse above

the dew point to prevent condensation and potential corrosion problems. This can be done by

using heaters in each compartment or by burning a clean fuel such as natural gas before filtering gases from a coal-fired boiler.

The baghouse must also be brought on-line slowly to avoid permanent damage to the fabric.

Clean filters do not have a protective dust cake on them and are sensitive to dust abrasion and

penetration by fine particles. Penetration can lead to permanent residual pressure drop. In

some applications, bags are precoated with a protective dust layer prior to bringing the unit online. This protective dust can be the same dust from the process or other material such as pul~ .

verized limestone. In all cases, the filter velocity should always be kept low until a sufficient

dust cake is built up on the bags. This is indicated by a pressure drop of 1to 2 inches H20. The

gas flow can then be slowly increased to the designed rate (McKenna and Greiner 1982).

A suggested startup and shutdown list for baghouse system operators is given below.

Startup

1. Make sure all collector components are in working order and in proper mode.

2. Do not allow higher-than-design filtering velocities or air flow.

3. Avoid passing through (below) the dew point within the baghouse when dirty gases

are present. The system should be preheated to above the dew point with clean, hot air

before the introduction offlue gas. During normal operation, maintain the temperature

approximately 25 degrees above the dew point level. The gas dew point level can be

obtained by making process exhaust gas measurements (acid concentration, moisture,

and gas temperature) and appropriate calculations or by looking it up in literature such

as The Handbook a/Chemistry and Physics.

4. Operate the bypass system to assure its readiness in an emergency situation.

5. Check all indicating and monitoring devices for proper operation.

Shutdown

1. Purge the collector with clean (hot when necessary) dry air before allowing the gas

temperature to descend below the dew point. This is imperative when bringing a unit

off-line.

2. Do not store dust in the collector. Many maintenance workers have resigned after

spending a day with pick and shovel mside a dust collector hopper.

3. The bags should be "cleaned down" after dust flow ends, but not overcleaned. The

operator should allow for one or two cleaning cycles then stop the cleaning process.

2.0-3195
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2.0·3/95

Fabric Filter Operation and Maintenance

4. Finally, the operator should check to see that all components are in the proper shutdown mode.

To test your knowledge ofthe preceding section, answer the questions in Part 1 ofthe

Review Exercise.

Performance Monitoring

To determine if a baghouse is operating properly and to aid in troubleshooting when failures

occur, the operator must monitor certain operating parameters. Routine monitoring of key

parameters, either on a continuous or periodic basis, is imperative for performance evaluation

and problem diagnosis. An adequate baseline must be developed to determine when future

changes in performance occur. Some typical parameters that are monitored are: inlet and outlet

gas temperature (only on units operated above ambient temperature), pressure drop, opacity,

and gas velocity. In addition to these parameters that can be routinely measured, it can be

important to periodically evaluate the chemical composition ofthe gas stream, including moisture, acid dew point, and particle loading and size distribution. The following describes how

the above parameters affect performance and the techniques used to measure each. In addition,

there is also some common auxiliary equipment that should be monitored or periodically

checked. These include receiver air pressure, bag tension, fan amperage, and high hopper

level.

Gas Temperature

Gas temperature is important because fabrics are designed to operate within a given range.

(See Lesson 4 for details on fabric operating conditions.) Exceedances ofthese fabric temperature limits, even for short periods oftime, can weaken or damage the bags. Exposure

ofthe fabric to temperatures above the maximum limits can cause immediate failure due

to loss ofstrength or elongation from melting. Minimum temperatures are related to the

dew point temperature ofthe gas stream. Operation ofthe baghouse below these dew point

temperatures can result in moisture or acid condensation and cause bag blinding or chemical attack ofthe fabric. Condensation problems are one ofthe major causes ofbag failures.

Temperature measurements are also used to indicate inleakage into the gas stream. Temperature drops across baghouses can range from 1 tQ 2 degrees on small units to up to 25

degrees on large baghouses (EPA 1984). The facility must establish an acceptable or normal operating range. Ifthis range is exceeded, it indicates that a problem is occurring and

needs to be addressed.

To measure temperature, a thermocouple with digital, analog, or strip-chart display is

used. The temperature signals are often tied to an alann limit indicator to notify the operator oftrouble. Temperature measurements are generally made at the inlet and outlet ofthe

unit with the inlet being the primary focus.

Pressure Drop

Baghouses are designed to operate within a certain pressure drop range, based on a specific gas volumetric flow rate. Within this range during nonnal operation, the pressure

drop fluctuates with the cyclic cleaning process. The average baghouse pressure drop

gradually increases as the filter cake builds on the bags and then takes a step decrease

immediately after the compartment has been cleaned. The pressure drop across the bag6-7
ATTACHMENT B
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!

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I

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GENERAL TROUBLESHOOTING

• Operate the bypass ~ystem, if available, 'to

assure its readiness in emergency sil'uations.

• Check monitoring devices for proper operation

and calibration.

Additional information on specific start-up and shut~

down p110cedures for baghouses serving Combus~

tion Ope~ations and Hot Mix Asphalt Plants ,is outlined ili the Industry Specific Tl'o-uble-shooting sections.

r--' ...... ··-·-AiA,"iN'LEAKAGE.-.-._-...."... U"1

'"S~:ill' ~i; le~ks ·~-;;;~~-YOlt~-;y;t~-;. fu 'a-~~~tiJ;::-'

tion system, tIle fan is sized to overcome ~ll of the

design static resistanc.e in the system. The suction

pull is greater at leaks located closer 'to the fan, and

the volume of inleal<age increases. To cfllculate the

vohune of inleal<:age, use the following forml.tla:

CPM =2,402 x Area of leak (ff)

SP = static pressure in inches w.e.

CPM = airflOW in jlNmin.

: SHUTDOWN:

• Purge the col1ecto~ with clean (hotJ when necessary) dry air before allowing the temperature to

descend below the dew point. As the collecto,r

cools, moisture may condense on the bags once

dew point is reached. TIle inlet and outlet temperat'Ures should be consistent and below dew

point.

• Do not store dust in the hopper. The presence of

any moisture can Ca1.lSe it to harden, maku1g it

very difficult to remove,

,i • Allow bags to clean down after dust has stopped

entering the hopper and remove this materIal

from the hopper, but do not overclean the filters.

• Check to see tb,~t all componeI1ts are in the

proper shutdown mode.

.........-.. • ._- _••.._._". _"•• _,,,..... H'~ ._•.,

GUIDELINES FQR UNIT ' I

•••STARTUP •• • • , __ •• __ •AND -'-"0 __ ••SHUTDOWN _ __ • _:J

STARTUP:

• Ensure all collector components are in good

worldng order and in proper operating mode. .

• Do not allow higher than design filtering

velocities or airflow.

• Avoid pas9~g below the dew point when dirtY

gases are'presel,t. The system should be pre

heated to above the dQW point with clean hot ah .

before the introduction of particulate lad~ri gas.

The baghouse must be brought on-line slowly to

avoid permanent damage to the filtration media. .

Without a protective dustcake, clean filters a~e sen9i~

tive to dust alJrasion and penetration of fine parti- ;

cles. D"lSt penetration can lead to permanently .

red1.1Ced permeability. The velocity should always be

l<:ept low until a sufficient dustcake is built on the :

bags. This is indicated by a pressure differential of

1-2 in. W.e. (25-50 mm). The gas flow can then be

slowly increased to the design rate.

_._-_ ,,~_••__•• _ ~.:..._-~ I' -~~..

BAG~PJJ:SE'~~6" ,.'~ ·:!f:I,. '. '" '. I

,

1_.__ •••_ M' ". AND ..... S~UTPQ:' \0'" ... '~f" ,I ....1_. ....,I

Specific starl:up and shutdown prQcedul:es should .

be pl'Ovided by the baghouse manufacturer. Pay

close attention to these critical periods of operation !

to prevent damage to the equipment. Proper startup:

~d shutdown procedures sho"l1d be incorporated

into overall preventive maintenance programs.

If hot moist gases are to be filtered, the baghouse

must be preheated to raise ~he inte,t'ior temperat"UIe

above !:he dew point in order to pl'event condensation and potential,corrosion problems. This can be

done by using heaters in each compartment or by

burning a clean fuel such as natural gas pefol'e filtering gases from a dirty fuel (coal, oil, hazardous

waste, etc.).

, J,

, (

J

j

, 't

! I

I

I I

I I

(

\

\

I

I

:~

~:}:,~
( DUST CHEMISTRY

I, I I

.--/-To

STEP I

, , (D QIIG 70

ResistitJity tests can be extremely helpfuL In determining if

process problems rue affecting precipitator operation.

'i,. 'I' I' "! i " I 1 'II ,

1Q·~m;'·I-~-~~~'IIEt~~~~m ---'.'

_. r-I'+ ..J..!, ••' : : I.

I I I .... .-,.,. ,I--..,..o!.~.j.."'-1.'.J.,;\\:..-~.I--+l--.-H

III:: " '., I '., ,;11 ,I' ll-HI·~~-:.-_.~- f+--·,I---j..LLJ+tJ4--f-+-:-+--1-1 ,

" I" I 1,1 I , " II I', :",

'0' .L.l--4~---I-'L-...:..I---l--I"':""':41...l.-+---i+-"':"':';1--J "G 'G' lI40 ~gQ iDO IQ. 110 IQD

Flue (0 as Tell1peralure C'P)

•••••..1.0 IlPm S03 e."",.r,.r# &0, Crtn~II""""fI"'" Gllr 4.2l'Pn" •••- • 10.0 IlPII1 S03

Resistivity va. Flua Gaa Tamperature

I'rt;!pllalGr upal'llde Speclfl.d Ca61 IIl111lDro ,.21~L8~'IllIIMM8TU

Cala~"'I.d Aald Pow palp, c a7Q'F

10":.~ __ ._.~.l ...,.... I ~.~..

A small leal, in the outerflashing on thi9 corner res~dted in

tl7.e heavy corrosion. seen i1/ this photo. Repair lealcs as soon as

possible to avoid tl1is type ofdamage.

i I i/ " ',,: '"

e. "CAIf/tll:7 l !

Gw,. ~., I I

.; 10' a .1

Ui ' , .. - lit .Ol

'J ~" ,ill :-

DUST CHEMISTRY AND RESISTIVITY

Once all mechalucal and electrical systems are in

good repair and functioning properly, the process

characteristics and resistivity of the dustshould be

evaluated, Dust collectibillty changes when temperature fluctuates. If your proces/! is s'l-able, the dust

resistivily should be checked at the no.rmal operating point. If your process changes regularly, or

ope1'ates at varying temperatures, it would pIS: wise

to have l'esistivity c.hecl<:ed at several different

points, BliA. performs labora.tory resistivity tests.

Send us a sample of a.sh from one hOJ?pel' in each

field in the direction o,f gas flow, and we'll report:

• ResistiVity in ascending/descending modes.

• Electric field strength at cl~:r:acteristictenlpera~

tures and moisture levels.

• Ash layer porosity can be calculated if th,e true

density of the dust is known.

l.ndependent consultants performs our resistivity

tests in tightly controlled test envixonments where

moisture, sulf\.U'ic acid content a.nd ammonia. vapol'

content can be strictly regulated. Res~stivity tests

can pb.1POint performance problems that can't be

found in any other way.

THERMAL INSULATION AND LAGGING

Retaining heat in the precipitator casing is the best

way to prevent corr.osion. If cold spots can be eliminated, tb.en acidic condensation should not OCCUl'/

cmd cOl-rosion damage will he mhu.rruzed. Thermal

insulation is used to keep heat from !:he process in

the unit, and lagging over the insulation protects it

and keeps it dry. Keeping tlte insulation in good

shape is one way to prolong the life of any prec.ipitatOl'. Routine mspections of the flashing, rain gut~

tel'S and dOWJ:\.9pouts and the siding and roofing of

the unit will reveal any damaged areas tha.t should

be repail·ed.as soon as they appear. Failure to keep

the sidi.ng and i.nsulation in good repair can lead to

corrosion of the casi11g in a very short time.

(
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Martin Marietta

Magnesia Specialties, LLC

755 Lime Road, Woo(hdlle,OH 43469 USA

Te.lephone: (419)8494200 Fa.x: (419) 849-4246

December 15, 2005

Jim Orlemann, Manager

Division ofAir Pollution Control

Ohio Environmental Protection Agency

Lazarus Govt. Center

P.O. Box 1049

Columbus,OH 43216-1049

RE: SIP Exemption Request for Martin Marietta:

Response to Ohio EPA·s November 17,2005 Questions

Dear Mr. Orlemann:

On October 14,2005, Martin Marietta Magnesia Specialties, LLC ("Martin Marietta") submitted

a letter and supporting documentation to request a rule exemption from the requirements of

O.A.C. §3745-17-07(A) during start-up and shutdown oflime producing kilns at Martin

Marietta's Woodville, Ohio facility ("Woodville facility"). On November 17, 2005, you

responded to this letter and requested additional information from Martin Marietta. This

submittal sets forth the questions you raised, along with Martin Marietta's responses.

OEPA Question 1:

What are the current, specific procedures used by MM for the start-up and shutdown ofthe kilns

served by the baghouses and the kiln served by the ESP? In outlining these procedures, please

clearly indicate what fuels are fired while the procedures are implemented. I am particularly

interested in the extent to which natural gas is used during the start-up ofthe kilns.

Martin Marietta Answer 1:

Martin Marietta does have specific procedures for start-up and shutdown ofthe kilns. While

these procedures are standard, the time required to implement each specific step will vary

depending on how long the kilns have been down and whether or not new refractories must be

cured. Generally, the Woodville facility has the following procedures for starting-up kilns:

• Light torch to serve as a pilot light for gas firing and activate flame detection system;

• Start ID fan to produce a draft and close the regulating damper;

• Ignite main gas burner and gradually heat the kiln, making changes as required;

• Start stone feed when the kiln temperature reaches about 800 to 8500

F;

• BEFORE starting solid fuel, personne.l are warned to vacate the kiln area;

• Start the coal mill when stone'is in firi"ng zone, -2 hours after starting the stone feed;

• Once solid fuel and kiln operations are stable, activate emissions control equipment.
(

(

Jim Orlemann

December 15, 2005

Page 2 of4

Typically, shutdowns occur more quickly, depending on the nature ofthe disruption. For

instance, a small operating problem, such as the balancing ofa coal fan, would require stopping

the solid fuel supply and keeping the kiln warm with the fIring ofnatural gas. As indicated by

recent malfunction reports that the Woodville facility has submitted to Ohio EPA's Northwest

District Office ("NWDO"), the ESP usually must be immediately shut offbecause ofsafety

concerns when the fuel supply becomes unstable. A longer interruption ofseveral hours, such as

that experienced with the failure ofcontrol equipment, could allow the kiln process equipment to

cool to a point that signifIcant reheating with natural gas will be necessary. Finally, a complete

shutdown for any substantial kiln or control equipment repairs will necessitate a full restart.

OEPA Question 2:

Has MM performed any emission tests to determine the level of S03 emissions from the kilns

during normal operation, startup, and/or shutdown? Is MM aware of any other information,

other than the results ofemission tests performed by MM, which would indicate the level of S03

emissions from the kilns during normal operation, startup, and/or shutdown?

Martin Marietta Answer 2:

Martin Marietta has not performed S03 emission tests on lime kilns. We are not aware of any

such testing on lime kilns and would not expect to fInd signifIcant S03 emissions levels.

OEPA Question 3:

Please provide temperature vs. time data for the kilns, for both startup and shutdown, to show

how long it takesthe temperature ofthe exhaust gases to reach a level of250 degrees F and 350

degreesF.

Martin Marietta Answer 3:

As stated above, there is no "typical" time allocated to start-up ofthe kilns. Rather, the length of

time is dependent on the reason the kilns were taken off-line, the length oftime the kilns were

down, the addition ofnew refractories and other factors. Martin Marietta has included kiln

operating log sheets for two full start-ups oftypical kilns, Attachments A and B.

The first start-up began on April 27,2005, at South Kiln #1. See, Attachment A This was a cold

start-up ofthe kiln, which had been off-line for eleven days during planned routine maintenance

activities. The operator ignited the pilot flame at 5: 10 pm on April 27th and began to dry out the

kiln. At 8:00 am the next morning, the operator began adding natural gas to increase kiln

temperature approximately 50 degrees F per hour. Solid fuel was introduced starting at 6:00 am

on April 29th, and the ESP was energized at 8:00 am that same day. Thus, start-up took

approximately thirty'-seven hours, all on natural gas except for the last two hours.

The second start-up began on October 25, 2005, at South Kiln #2. See, Attachment B. This kiln

had been taken off-line eleven days earlier, so a cold start took place. At 4:00 pm, the natural

gas pilot flame was ignited, and the kiln began its warming process. Stone feed was added to the
(

(

Jim Orlemann

December 15,2005

Page 3 of4

kiln at 1:15 pm on October 26th, and solid fuel was introduced starting at 3:45 pm. The baghouse

was turned on shortly thereafter, about twenty-eight hours after starting the process equipment.

OEPA Question 4:

What specifically caused the explosion ofthe ESP in 1990?

Martin Marietta Answer 4:

Martin Marietta determined that the explosion was caused by the presence of a significant

amount ofunburned solid fuel in the presence ofan ignition source and oxygen.

OERA. Question 5:

The exemption temperature for baghouses and ESPs serving coal-fired boilers is 250 degrees F,

and one would expect that coal-fired boilers operate at much higher levels of S03 in the exhaust

gases than lime kilns. Why isn't MM proposing any exemption temperature level for the ESP?

Why wouldn't 250 degrees F be an acceptable exemption temperature level for baghouses and

ESPs serving lime kilns?

Martin Marietta Answer 5:

Martin Marietta did not propose a temperature level for the ESP because steady-state kiln

conditions do not correlate directly to a certain temperature. As stated in our earlier letter,

steady-state conditions must be reached in the kiln prior to utilizing the ESP to assure that

unburned fuel is not exposed to an ignition source. Steady-state is reached once a stable flame is

safely established and maintained using solid fuel (i.e. minimizing/eliminating combustibles).

Therefore, there is no "set" temperature that can be deemed to be automatically safe.

Martin Marietta's experience has indicated the initial startup firing on natural gas produces a

very high moisture loading in the exhaust gases, which will be harmful to baghouse equipment

(as previously noted). Operating baghouses at 250 degrees F is not safe for the equipment, since

the temperature ofthe relatively small volume ofexhaust gases may not be sufficient to offset

the residual heat content ofthe baghouse structure, so that it will not be damaged. Operating a

baghouse at temperatures too close to the dew point may cause failure ofbags and corrosion of

the control equipment itself Achieving a steady-state feed ofsolid fuel provides an increased

volume of hot exhaust gases that allow a baghouse to rapidly reach suitable operating conditions.

OEPA Question 6:

Apparently, MM has been able to comply with the opacity limitations in OAC rule 3745-17-07

without an exemption for startup and shutdown. How has MM been able to maintain compliance

in the past, without the exemption? Why does the company need an exemption for the startup

and shutdown ofthe lime kilns at this time?

Martin Marietta Answer 6:

As evidenced in files maintained by Ohio EPA's NWDO, Martin Marietta has diligently reported

deviations and malfunctions, some ofwhich relate to opacity during start-up and shutdown
(

(

(

\.

Jim Orlemann

December 15, 2005

Page 4 of4

scenarios. On May 18, 2005, the NWDO sent a letter to Martin Marietta advising that Ohio EPA

may have received an excessive number ofmalfunction reports. See, Attachment C.

Martin Marietta has investigated and identified potential solutions to address Ohio EPA's

concern. However, many incidents seemingly cannot be addressed by any means other than a

rule exemption. During a meeting earlier this year, we discussed a potential O.A.C. §3745-17-07

rule exemption with the Ohio EPA and were encouraged to move forward with this request.

Martin Marietta hopes this letter has adequately answered your questionsregarding this matter.

To that end, Martin Marietta would like to propose a meeting to discuss any remaining items. I

will call you shortly to schedule such a meeting. Until then, contact me at 419-849-4258 ifyou

have questions. Martin Marietta appreciates Ohio EPA's willingness to consider this request.

Respeetfully,

Joe L. Green

Environmental Engineer

Au. -(a): A& B

cc: Lee Burkleca, Ohio EPA-DAPC

Tom Kalman, Ohio EPA-DAPC

Don Waltermeyer, Ohio EPA-NWDO

Joe Reilly, MMMS Woodville

Tim Tawney, MMMS Woodville

Yvonne Bailey, Esq., MMM Raleigh

April Bott, Esq., Chester, Willcox & Saxbe LLP
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K'LNf/.:_I__ DATE. 7' t:L?tD5"-

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LAB DATA

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SUGGESTIONS \

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ATTACHMENT B

2 of 2 PAGES
Page 1 of2

Joe Green

From: Joe Green

)' :t: Tuesday, March 21, 2006 8:37 PM

To: 'Jim Orlemann'

Cc: abott@cwsfaw.com; Don Waltermeyer; Lee BurkJeca; Tom Kalman; Joe Reilly; Tim Tawney; Yvonne Bailey

Subject: Re: Martin Marietta Magnesia Specialties' [MMMS] SIP Proposal Responses for revising OAC rule 3745-17-07

Importance: High

Sensitivity: Confidential

Jim, as discussed today, I hope that the enclosed responses will address your 2/22 questions. If you need additional details, let's

schedule a conference call, or perhaps a meeting, later this month to review any remaining technical matters. Thanks. .

Joe L. Green

Environmental Engineer

Martin Marietta Magnesia Specialties, LLC

755 Lime Road, Woodville, OH 43469

Phone: 419-849-4258 (direct)

Main: 419-849-4200

FAX: 419-849-4213

Cell: 419-410-6043 (new)

,(_ .ks Joe for the responses to my November 17 e-mail. We have reviewed your responses and have the following additional

questions:

1. Regarding Answer 1:

When coal firing is initiated, does all gas firing cease? Or, does coal firing begin at a low rate and the gas firing rate decreases as

the coal firing rate increases? Natural gas firing must be continued after introducing the solid fuel, presently "petroleum coke", in

order to sustain the combustion process -- because of a relatively low percentage of volatiles in this solid "coke" fuel. Thus, as is

shown on our Attachment "A" and "B" kiln logs, natural gas rates are reduced somewhat after the introduction of solid fuel.

How exactly do you define "stable" operation ofthe kiln, and how do you determine whether or not you have achieved that

condition? Kiln operators will determine that steady-state "stable" operations have been achieved when fueling rates and process

conditions are at constant levels, and firing can be maintained without an excess of "combustibles" in the exhaust gases.

For the baghouses. in light ofthe response to question 2 concerning S03 emission levels, it appears the company's primary

concern is the blinding ofthe bags dUring start-ups and shutdowns. However, the start-up procedure shows that the stone feed

doesn't begin until the kiln temperature is well above the dew point [800 to 850 degrees Fl, while only gas firing is occurring.

During a shutdown we assume the stone feed would stop at about the same temperature, after the coal firing has already

stopped. Is itthe company's contention that the firing of only natural gas, at kiln exhaust gas temperatures of less than 250

degrees F and with, no stone feed, will cause blinding ofthe bags? Does MM currently bypass the baghouse at these lower

temperatures? As was indicated by Answer #5 of our 12/15/05 submittal, the low temperatures of the baghouse mass must be

increased quickly enough to prevent condensation of the exhaust gases and corresponding equipment damage dUring startups.

The bypasses needed at lower operating temperatures don't seem to be exempted, thus we report such events as deviations.

2. Regarding Answer 3:

I~'",ach of the start~up examples, what was the temperature of the exhaust gases when the ESP was energized? The #1 ESP

5/1112007
Page2of2

was activated at ·~8 AM during the 4/29/05 startup, with an inlet temperature of -683 F as shown on page 3 of Attachment "A".

The #2 baghouse was brought online at -8 PM on 10/26/05 with an inlet of -491 F as indicated on page 2 of Attachment "B".

Also, in each case, were there opacity excursions prior to the start-up of the ESP? If so, when did they begin and how long did

th7~'last? In the 4/29/05 startup, stone feed and solid fuel (coke) were started at -6 AM and the ESP was started at -8 AM. In,

th,\ /26/05 example, stone feed began at -1 PM, and solid fuel was started at -4 PM, with the baghouse startup at -8 PM. As

previously stated, the lack of an exemption for such startup (and shutdown) activities is the reason for proposing this revision. It

should be noted that heavier natural gas firing during the kiln warming and startup phases adds moisture to the exhaust plume.

If companies are able to achieve "stable" coal combustion conditions in large utility boilers before the exhaust gas temperatures

reach 250 degrees F, Why is that not possible for a lime kiln? We do not have first-hand knowledge related to the operation of a

large utility boiler; however, we believe that kilns and utility boilers are not comparable emissions units. Warming up a lime kiln

with gas firing is a slow gradual process, intended to preserve the useful life of refractories and equipment. If the lime kiln is

warmed too quickly, refractories would crack and equipment can be damaged, thus compromising the integrity of the kiln itself.

The subsequent introduction of large quantities of process material could cause the blinding of baghouse equipment due to

excess moisture, low temperatures, and the baghouse mass. By comparison, utility boilers are usually being brought up to

operating temperature quickly for load purposes. Moreover, these utility boilers already have an OAC 3745-17-07(A)(3)(a-b)

exemption for opacity during startups and shutdowns, which recognizes safety and equipment damage concerns.

Finally, in your December 15 letter you referred to Attachment C, but that wasn't attached to the letter. Could you send us a copy

of that Attachment? Yes, I'm sorry that we did not provide the referenced Attachment C -- which is enclosed.

======================================================================================

»> "Joe Green" <Joe.Green@martinmarietta.com> 12115/20056:04:19 PM

»>

Jim, as requested, we are submitting the enclosed responses to your questions.

( forward a copy by U.S. Man. Please advise if you need more information.

Thank you.

Joe L. Green

Environmental Engineer

Martin Marietta Magnesia Specialties, LLC

755 Ume Road, Woodville, OH 43469

Phone: 419-8494258 (direct)

Main: 419-8494200

FAX: 419-8494213

Cell: 419-308-8320

(

511112007
State of Ohio Environmental Protection Agency

( 347North~~

Bowling Green. 0Hl 4MOO-!nSB

Northwest DistrictOffice

TELE: (419) 352-8461 FAX: (419) 352-8468

www.epa.stale.oh.us

Bob Taft, Governor

Bruce Johnson, Lieutenant Governor

Joseph P. Koncelik, Director

Re: Sandusky County

Martin Marietta Magnesia Specialties

Premise #0372000127

Inspection

(

Mr. TrrmTav..'l1l.Y

Martin Marietta I\It:agnesia Specialties

755 Lime Road.

Wood\<iUe, Ohio 43469

This letter :shall :serve as follow-up to the inspection conducted On May 17, 2005 of the abovereferenced bciHty by this writer and MelanieRay. The purpose ofthis inspection was to detennine the

compliance :s.tatus ofaU air contaminant emissions units located there.

Based on Olll( discussions, my obsen-ations during the inspection, and a review ofthe company's files,

my lfindings are :as follows:

POlS (#1 Kiln) and P019 (#2 Kiln): Since June 25,2004, Ohio EPA has received (11)

malfunction reports for POlS and (5) malfunction reports for P019. In April 2005, the

company replaced a fan on PO I5 to try and help reduce the number of malfunctions.

If Ohio EPA continues to receive an excessive number of malfunction reports, the

company will be required to submit a Preventative Maintenance and Malfunction

Abatement Plan (PMMAP)_

AU otbe!remissions units appear to be in compliance with the air pollution control emission limitations

and regulatioM ofOhio EPA at this time.

Th'lU"Jt y")u f''Or the courtesy extended during my visit. If the company has any questions andior

comments concerning this letter, please contact me at the above address or call (419) 373-3129.

Sincerely,

.~L. Chapman

Division ofAir Pollution Control

fesl

pc: Samnlf Araj, Ohio EPA, DAPC-NWDO

Patrick Montgomery, Martin Marietta Magnesia Specialties

NWDOfnle

Ohio EPA is an Equal Opportunity Employer