# Appendix G
Technical Support Provided by Martin Marietta Magnesia Specialties, Inc. for the New Exemptions in GAC Rule 3745-17-07( \.

APRIL R. BOTT 

# CHESTERWILLCOX 

# & SAXBE LLP

## ~rundC(f~cd 

# 5Zaw

DIRECT DIAL (614) 334-6134 abott@cwslaw.com



### October 14,2005



# (

(' 

### VIA FACSIMILEAND 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 ofExemption for Martin Marietta Magnesia SpeCialties DearJim: As we discussed during a recent telephone conversation, Ohio EPA is currently undertaking its five year statutory rule review ofOhio 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 ofO.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 highertemperature is needed for safety considerations orto 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 StreetSuite 1000, Columbus OH 43215-4213 Facsimile (614) 221-4012

## ( 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 ofbackground, 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 Mariettabelieves, 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 ofSouth Kiln #1's ESP outside of steady-state parameters will likely result in dangerous operational conditions and ineffective control ofparticulate. 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 ofa baghouse can severely damage the equipment. BHAIGeneral Electric, Martin Marietta's vendor for baghouse supplies, considers start-up and shutdown critical periods ofoperation. BRA's Baghouse Troubleshooting, Attachment B. At Woodville, operators face an extra level ofconcern 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 mustbe 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/orpreviously 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 ofadditional 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 ofany 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 of350 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

3http://yosemite.epa.gOY/oagps/EOGtrain.nsf/fabbfcfe2fc93dac8525afe00483cc41b6c72f7

### e09cff3b185256b66004f35 30/$FfLEI12bles6.pdf. This lesson is part ofEPA training course SI 412B, Electrostatic PrecipitatorPlan ReYiew:http://yosemite.epa.goY/oaqpslEOGtrain.nsf/DisplayView/SI_ 412A

_0-5?Open Document

# ( 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 ofan 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 ofSouth 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 ofanESP 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 airpollution 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 ofeither 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 ofany kiln at Martin Marietta's Woodville facility: (i) For any kiln equipped with a baghouse, until the exhaust gases have achieved a temperature of350 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.

## ( 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 ofO.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 ofourrequest. In the meantime, please do not hesitate to contact either the Woodville facility's environmental engineerJoe Green at 419-849-4258 or me ifyou 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

## (



## (

( 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 myjob 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 akiln is off-line, it mustbe 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 undernormal operation.

ATTACHMENT A

## (



# ( 10. Particulate emissions from the North Kilns are controlled through the use ofa shared baghouse. 11. Particulate emissions from South Kiln #2 are controlled through the use ofa 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 orbe 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 cannotbe 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 ofadditional bags. 15. In my opinion, operation ofany 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 atemperature above the dew point in order to rapidly raise the temperature of thebaghouse 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 ofan electrostatic precipitator ("ESP"). 17. It

### has been my experience that the ESP cannotbe 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 couldbe 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 airin the collector. I have personally witnessed the results ofan ESP explosion while employed with a major oil company and again in 1990, after an ESP located on the Woodville South Kiln #2 exploded.

## (



# (



# ( 20. Further, utilizing this ESP at lowertemperatures is not effective control since the resistivity oflime dust at the lowertemperature does notallow enoughparticle charge to appropriately capture the emissions. 21. In 

### my opinion, operation ofSouth 

### 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 lowertemperatures gives ineffective control. Further affiant sayeth not.

George E. Williams

Affirmed to before me and signed in mypresences this Lday of

# t9~:itf)oS

# ~Q.t:I~ Notary Public 

# 0

BRENDA

### J. ElMER!, NorAR\'PUBlIC 

### State ofOhio


### '" CommisIIoA Expires 

### MatC1123.2008',"**""'I~f** J •••• ;,'.11 .:**II."~** I flf'**~\..** \ 1'1 "I til! 1\111' Ql;OIJ': r
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## 440 Volts I Phase pO Cycle Do 10m 

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## 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

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## App I i 

## ca t 

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## on Quan t i 

## ty
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..... 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~**

## (



# (

( 

# Lesson 6 ESP Operation andMaintenance

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 priorto 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 ofair-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 outletfields provides information about general resistivity conditions 8. Identify important safety precautions to take when operating ESPs 

### Introduction As with any airpollution control system, an ESP mustbe operated and maintained according to the manufacturer's recommendations. Plant personnel mustbe properly trained to perform these activities with confidence and efficiency. This lesson reviews some ofthe key functions that mustbe completed to keep the ESP operating as it was intended including installation, startup and shutdown procedures, performance monitoring, routine maintenance and recordkeeping andproblem evaluation.

2.0·2198 6-1

ATTACHMENT E

# (



# (

( 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 installedby skilled craftsmenwho 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 andtest areas-stack testing ports and continuous emission monitors (opacity monitors) Weather conditions-the ESP mustbe able to withstand inclementweather such as rain or snow During installation, the customerpurchasing the ESP shouldbe responsible for checking the criteriapresented 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. Uniformflue gas distribution across the entire unit. Ductwork, turning vanes, baffle plates, and inlets withperforateddiffuserplates 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 ofcollected dust, especially during rapping cycles. 

### 2. Complete sealof ESPsystem from dustpickup to stackoutlet. Air inleakage or outleakage at flanges or collector access points eitheradds additional airflow to be processed orforces the process gases to bypass the collector. Inleakage to ahigh-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. Lightpenetration from outside helps to isolate the problem areas. 

### 3. Proper installation of discharge electrodes andcollectionplates. Collection electrodes are usually installed first, and the discharge wires orrigid frames are positioned relative to them. Check each section ofelectrodes to ensure that the electrodes are plumb, level, and properly aligned.

2.Q.2198/ \.



# (

(

2.0-2198 ESP Operation andMaintenance



### 4. Proper installation of rappers. Collection-plate rappers and discharge-electrode rappers should be installed and aligned according to vendor specifications. Checkmagneticimpulserappers to see ifthey strike the supportframe on the collectionplates. Checkhammer and anvil rappers to see ifthe hammers strike the anvils squarely. Check vibratorrappers 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. MostESPs use some type ofinsulationto 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 andoperation of discharge devices. It is important to checkthe 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 canremove the dust freely from the hopper. A backward-moving screw conveyorcan pack dust so tightly that it can bend the screw. Overfilledhoppers are common operating problems that canbe avoided byproperinstallation and maintenance ofdischarge 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 forproperrotation, drive component alignments, and vibration. Fans shouldbe securely mountedto a component ofsufficientmass to eliminate excessive vibration. In addition to the'above items, each ESP installation should have its own checklistreflecting the unique construction features ofthat unit. The installation crew should prepare a checklistbefore beginning final inspection and initial startup. A prestartup .checklistfor the initial startup suggested by Peter Bibbo (1982) is shown in Table 6-1.

6-3

### (



# ( Lesson 6

6-4 Col/ectingplates 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 orinsulatorcompartments 1. Insulators and bushing clear and dry with no carbon tracks 2. All grounding chains in storage brackets 3. Heaters intact, seal-airsystem controls, alarms, dampers, and filters in place and operational 4. Seal-airfan motor rotation correct, orvent pipes free 5. All access doors closed Rappers 1. All swing hammers ordrop 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-rectifiersets 1. Surge arrestor not cracked orchipped and gap set 2. Liquid level satisfactory 3. High-voltage connections properly made 4. Grounds on: precipitator, output bushings, bus ducts, conduits Rectifiercontrol units 1. Controls grounded 2. Power supply and alarm wiring properly completed 3. Interlock key in transfer block Source: Bibbo 1982. 

### ESP Startup andShutdown 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

## (



# (

(

2.0·2198 ESP Operation and Maintenance

cedures exist at the sites and that the operators follow the procedures or documentreasons for deviations. 

### Startup Startup ofan electrostatic precipitator is generally a routine operation. It involves heating a number ofcomponents such as supportinsulators 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 importantforESPs used on cementkilns 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 shouldbe 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 priorto 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. CheckT-R sets. a. Check half-wave/full-wave operation (half-wave operation is recommended forfiltering 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 nextpage

6-5

# (



# ( 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 ofT-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). Coldstart(when it is not possible to admitflue 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 Powertracvoltage 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. Afterflue 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 shouldbe 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 shouldbe run for a short time afterthe 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 andMaintenance

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, andpulse-jet baghouses 

### Introduction This lesson provides a general overview ofcommon 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. Forthe 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 ofairpermit applications for airpollution control systems. The lesson is intendedto provide a general compilation oftypical baghouse operating problems and typical checklists used during installation, startup, and operation. The lesson also provides agency permitreview engineers with sufficienttechnical 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/orpermit limits. A number ofsections ofthis lesson were extracted from the sources listed in the Suggested Readings section atthe end ofthis lesson. These sources provide much greater detail on fabric filter system O&M procedures.

2.0·3/95 6-1

ATTACHMENT C

## (



## ( ( 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, properinstallation procedures will save time and money and will also help in future operation and maintenance ofthe baghouse. Good coordinationbetween the baghouse designer and the installation and maintenance personnel will help keep the baghouse running smoothly foryears. Occasionally this coordination is overlooked. The baghouse is installed, turned on, and forgotten about until it stops working completely. Bythen itmay be too late to keep the unit going, andthebaghouse 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 - stacktesting ports and continuous emission monitors (opacity monitors) Weather conditions

- the baghouse mustbe able to withstand inclement weather such as rain or snow The following features have been suggested for aproperly designed and installed baghouse (McKenna and Greiner 1982): 1. 

### Uniform airanddust 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 thatwill abrade the duct orbag filters or cause reentrainment and induce high-dust-concentration regions that can produce uneven hopper loading and uneven fJlter bag dust cake. 

### 2. Totalsealof system from dustpickup to stackoutlet. Inleakage ofair 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 canleadto 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 andhigh pressure drop will generally result. The best check for leaks is for the installationtechnician to inspect the walls from inside the system during daylight. Lightpenetration 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 orno discharge, which can lead to reentrainment problems, yielding high pressure drop and hopper fires. 

### 3. Effective coatings and paint. Most systems are painted on the exterior surfaces only. Extra care shouldbe taken to touch up damaged areas with agoodprimer and ifequipment is not delivered fmish-painted, apply it as soon as possible following erection. Unprotectedprimers allow corrosion to occur and require sandblasting and costly repairs for the facility operators. 

### Ifthe system has been internally protected with a coating, it shouldbe thoroughly inspected for cracks and chips, particularly in comers, and repairedbefore operation begins. A poor interior coating canbe worse than none at all because itwill trap corrosive elements between the coating and the surface it was intended to protect.

2.Q-3/95

# (



# (

2.0·3/95 Fabric Filter Operation andMaintenance



### 4. Properly installed jilter bags. The fl1ter bags are the heart ofany fabric fl1ter collection system. Improper installation canresult 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 properfilter bag installation and tensioning (where required). These mustbe explicitly followed. Very often, early bag failures can be traced to improperinstallation. It is much easierfor the installation technicians to check and recheckbag 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 checkto 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. Totalsealbetween dirty side andclean side of collector. 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 dustto 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 besttechnique is to use a bright light on one side ofthe plenum and visually observe for lightpenetration on the other. This is the most effective in total darkness. The installers shouldtake extra time to checkthis important area. Tracking down stack emissions not associated with bag failures can be extremely difficult after startup. 

### 7. Properly installedandoperating dampers. Most systems employ several dampers to isolate areas ofthe system or control the volume ofair flow. Proper alignment ofboth internalblades andthe operating linkage is important. In high-temperature applications, special care mustbe 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 forbag cleaning and maintenance. Leakage through these isolation dampers can cause improperbag cleaning. Itwill 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. Cylinderrod location, motor rotation, and so on, must be checked. Remember, when hooking up an AC motor, the installerhas a 50% chance of being correct on the first try. Not only will a backward-moving conveyorproduce no discharge, butit can packmaterial so tightly that itbends the screw. Left uncorrected, a reversed screw conveyorwill result in a full hopper. The industry abounds withhorror stories where full hoppers have ledto burnedbags, or dust thathas setup, requiringjackhammers to remove it.



### 6-3

# ( Lesson 6

6-4 

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

### 10. Clean, dry compressedair. Most systems employ compressed airto 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 ofair 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 airmust be clean and dry when it reaches the pneumatic component. Each baghouse installation shouldhave its own checklistreflecting the unique construction components ofthe unit. The installation crew shouldprepare a checklist before beginning the final inspection and initial startup. Table 6-1 shows an example ofa typical inspection and startup checklist This checklist wouldbe 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, byjumping 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 airvolume 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 andMaintenance



# ( 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
- improperfan 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
Poormaintenance/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 andMaintenance Training Before starting up the baghouse, the plant engineer should schedule training sessions forplant employees that operate and maintain the baghouse. In these training sessions the following subjects should be covered: systems design, system controls, critical limits ofequipment, function ofeachbaghouse 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 couldbe provided by the baghouse vendororby 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.



### 6-5Lesson 6

6-6 

### Baghouse Startup and Shutdown A specific startup and shutdownprocedure shouldbe suppliedby the baghouse vendor. Improper startup and shutdown can damage the equipment. Ifhotmoist gases are to be filtered, the baghouse mustbe preheated to raise the interiortemperature in the baghouse above the dew pointto prevent condensation and potential corrosion problems. This canbe done by using heaters in each compartment orby burning a clean fuel such as natural gas before filtering gases from a coal-firedboiler. The baghouse must also be brought on-line slowly to avoid permanent damage to the fabric. Clean filters do not have aprotective dust cake on them and are sensitive to dust abrasion and penetration by fine particles. Penetration can lead to permanentresidual pressure drop. In some applications, bags are precoatedwith aprotective dust layerpriorto bringing the unit online. This protective dust canbe the same dust from the process or othermaterial such as**pul~** 

### . verized limestone. In all cases, the filter velocity should always be keptlow until a sufficient dust cake is builtup on the bags. This is indicatedby apressure drop of 1 to 2 inches H 2

### 0. The gas flow can then be slowly increasedto the designedrate (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 propermode. 2. 

### Do not allow higher-than-design filtering velocities or airflow. 

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

### gases are present. The system should be preheatedto above the dew point with clean, hot air before the introduction offlue gas. During normal operation, maintainthetemperature approximately 25 degrees above the dew point level. The gas dew point level can be obtainedby making process exhaustgas measurements (acid concentration, moisture, and gas temperature) and appropriate calculations orby looking itup in literature such as The Handbooka/Chemistry andPhysics. 

### 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 

### airbefore allowing the gas temperature 

### to descend below the dew point. This is imperative when bringing aunit off-line. 2. Do not store dustin the collector. Many maintenance workers have resigned after spending a day with pick and shovel mside a dust collectorhopper. 3. The bags shouldbe "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

# (

(

2.0·3/95 Fabric Filter Operation andMaintenance

4. Finally, the operator should check to see that all components are in the proper shutdown mode. To testyourknowledge of thepreceding section, answer the questions in Part 

### 1 of the ReviewExercise. 

### Performance Monitoring To determine ifa baghouse is operating properly and to aid in troubleshooting when failures occur, the operator must monitor certain operating parameters. Routine monitoring ofkey parameters, either on a continuous orperiodic basis, is imperative forperformance evaluation and problem diagnosis. An adequate baseline must be developed to determine when future changes inperformance occur. Some typicalparameters 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 canbe importantto 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 affectperformance and the techniques used to measure each. In addition, there is also some common auxiliary equipmentthat shouldbe monitored orperiodically checked. These include receiver airpressure, bag tension, fan amperage, and high hopper level. 

### Gas Temperature Gas temperature is importantbecause fabrics are designed

### to operate within a givenrange. (See Lesson 4 for details on fabric operating conditions.) Exceedances ofthese fabric temperature limits, even for shortperiods 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 dewpointtemperature ofthe gas stream. Operation ofthebaghousebelow these dewpoint temperatures can result in moisture or acid condensation and cause bag blinding or chemical attack ofthe fabric. Condensationproblems are one ofthe majorcauses ofbag failures. Temperature measurements are also usedto indicate inleakage into the gas stream. Temperature drops across baghouses can range from 1 tQ 2 degrees on smallunits 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 inletbeing 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 compartmenthas been cleaned. The pressure drop across the bag6-7ATTACHMENT B-( ! ",. I, 

# GENERAL TROUBLESHOOTING

• Operate the bypass**~ystem,** 

### if available, 'to assure its readiness in emergency sil'uations.

• Checkmonitoring 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 

### MixAsphaltPlants 

### ,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** 

### ofthe design static resistanc.e in the system. The suction pull is greater at leaks located closer 'to the fan, 

### and the volume ofinleal<age increases. To cfllculate 

### the vohune ofinleal<:age, use the following forml.tla: 

### CPM 

# =2,402 x Area 

### ofleak 

### (ff) 

### SP 

# = staticpressure 

## in inches w.e. 

### CPM 

# = airflOW in

## jlNmin. : SHUTDOWN:

• Purge the**col1ecto~** 

### with clean 

### (hotJ 

### when necessary) dry airbefore allowing the temperature to descend below the dew point. As 

### the collecto,r cools, moisture may condense on the bags once dew pointis 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 itto harden, maku1g it 

### very difficult to remove,
,i • 

### Allow

### bags to 

### clean down after dusthas 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 

# SHUTDOWN 

# :J

••• •• • • , __ ••

__ • -'-"0

__ ••

_ __ • _ 

### 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 pointwith cleanhot ah

. before the introduction ofparticulate**lad~ri** 

### gas. The baghouse mustbe 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 offine parti- ; cles. 

### D"lStpenetration can lead to permanently

. red1.1Ced permeability. The velocity should always be l<:eptlow 

### 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 thenbe slowly increased to the design rate. _._-_**,,~_** ••

__••

_**~.:..._-~** I'**-~~** ..

# BAG~PJJ:SE**'~~6" ,.'~** 

# ·:!f: I

,. '. '" '. I



# , AND

# S~UTPQ:'**'~f"** ,I 1 

# I 1_.

__ •••

_ M' ".

.....\0'"

... .... _. ...., 

### Specific starl:up and shutdownprQcedul:es should

. be pl'Ovided by 

### the baghouse manufacturer. 

### Pay close attention to these critical periods ofoperation ! 

### to prevent damage to the equipment. Proper startup:**~d** 

### shutdown procedures sho"l1d be incorporated into overall preventive maintenance programs. 

### Ifhot moist gases are to be filtered, the baghouse mustbe preheated to raise**~he** 

### inte,t'ior temperat"UIe above 

### !:he dew point in order to pl'eventcondensation and potential,corrosion problems. This 

### can be done 

### by

### using heaters 

### in each compartment orby 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 extremelyhelpfuLIn determining 

### if processproblems rue affectingprecipitatoroperation. '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 (0as Tell1peralure C'P)

•••••
.. 1.0 IlPm S03 e."",.r,.r#&0,**Crtn~II""""fI"'"** Gllr 4.2l'Pn"
•••- • 10.0IlPII1 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 outer flashing on thi9 corner**res~dted** 

### in tl7.e heavy 

### corrosion. seen 

### i1/ this photo. Repair lealcs as soon as possible to avoid tl1is type of damage.



# 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 ofthe dust 

### should 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, 

### itwould

### pIS: wise to have l'esistivity 

### c.hecl<:ed at several 

### different points, BliA. 

### performs lab

### ora.tory

### resistivity tests. Send us a sample ofa.sh from one hOJ?pel' in 

### each field in the direction 

### o,fgas flow, 

### and we'll report:



### • ResistiVity in 

### ascending/descendingmodes.

• Electric field 

### strength at**cl~:r:acteristic tenlpera~** 



### tures and moisture 

### levels.

• Ash 

### layer porosity can

### be calculated if

### th,e true density ofthe dust is known. l.ndependent consultants performs ourresistivity 

### tests in 

### tightly controlled test 

### envixonments where moisture, 

### sulf\.U'ic acid content a.nd ammonia. vapol' contentcanbe 

### strictlyregulated.**Res~stivity** 

### tests can

### pb.1POintperformance problems 

### that 

### can'tbe 

### 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 canbe elimi

### nated, tb.en acidic condensation should not OCCUl'/ 

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

### insulationis used to keep heat

### from !:heprocess in 

### the unit, 

### andlagging over the insulation protects 

### it and keeps 

### it dry. Keeping 

### tlte insulation 

### in good 

### shape is 

### one way to prolongthe life 

### ofanyprec.ipitatOl'. 

### Routine mspections 

### ofthe 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 

### canlead to corrosion

### ofthe 

### casi11g in 

### a 

### very short

### time. 

# (I i



# ( 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 of

### Air 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
DearMr. Orlemann: On October 14,2005, Martin Marietta Magnesia Specialties, LLC ("Martin Marietta") submitted a letter and supportingdocumentation 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 tothis letter and requested additional information from Martin Marietta. This submittal sets forth the questions you raised, along withMartinMarietta'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 Mariettadoes 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 ornot 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 heatthe 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;

• Startthe 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 

### indicatedby recent malfunction reports thatthe 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 equipmentto 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 ofS03 emissions from the kilns during normal operation, startup, and/or shutdown? Is MM aware ofany other information, otherthan the results ofemission tests performed by MM, which would indicatethe level ofS03 emissions from the kilns during normal operation, startup, and/or shutdown? 

### Martin Marietta Answer 2: Martin Mariettahas not performed S03 emission tests on lime kilns. We are not aware ofany such testing on lime kilns and would not expectto 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 takes the 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 otherfactors. Martin Mariettahas included kiln operating log sheets fortwo 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 operatorignited the pilotflame at 5: 10 pm on April 27th 

### and beganto dry 

### outthe 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 starttookplace. 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 October26th

, 

### and solid fuel was introduced starting at 3:45 pm. Thebaghouse 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: MartinMarietta determined that the explosion was caused by the presence ofa 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 onewould expect that coal-fired boilers operate at much higher levels ofS03 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 assurethat 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 sufficientto offset the residual heat content ofthe baghouse structure, sothat 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 ofhot 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 letterto Martin Marietta advising that Ohio EPA may have received an excessive number ofmalfunction reports. 

### See, Attachment C. Martin Mariettahas investigated and identified potential solutions to address Ohio EPA's concern. However, many incidents seemingly cannotbe addressed by any means otherthan a rule exemption. During a meeting earlierthis 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. MartinMariettahopes this letterhas adequately answered yourquestionsregarding 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 considerthis request. Respeetfully,

Joe L. Green Environmental Engineer



### Au. -(a): 

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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. Ifyou 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 orderto sustain the combustion process -- because of a relatively low percentage ofvolatiles 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. Forthe 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 ofonly 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 ofthe baghouse mass must be increased quickly enough to prevent condensation ofthe 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 ofthe

# start~up examples, what was the temperature ofthe 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 ofAttachment "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 ofAttachment "B". Also, in each case, were there opacity excursions prior to the start-up ofthe ESP? Ifso, 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. Ifthe lime kiln is warmed too quickly, refractories would crack and equipment can be damaged, thus compromising the integrity ofthe 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 letteryou referred to Attachment C, but that wasn't attached to the letter. Could you send us a copy ofthat 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 ifyou 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 

## (

511112007State 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 MariettaI\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 ofthe abovereferenced 

### bciHty

### bythis writerandMelanieRay. Thepurpose ofthis inspectionwas to detenninethe compliance

### :s.tatus ofaU air contaminant emissions units located there. Basedon Olll(

### discussions, myobsen-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) 

### malfunctionreports forPOlS and (5) malfunction reports for P019. In April 2005, the company replaced a fan on PO

### I5 to try and help reduce the number ofmalfunctions. IfOhio EPA continues to receive an excessive number ofmalfunction reports, the company will 

### be required to submit a Preventative Maintenance and Malfunction Abatement Plan (PMMAP)_ AU otbe!remissions units 

### appearto be incompliancewith the airpollutioncontrol emissionlimitations 

### andregulatioM 

### ofOhio EPA 

### at this time.
Th'lU"Jt 

### y")u f''Or the courtesy 

### extended during my 

### visit. Ifthe 

### company has 

### any questions andior comments concerning 

### this letter, please contact me 

### at the 

### above address or call (419) 

### 373-3129. Sincerely,**.~** 

### L. Chapman DivisionofAirPollution Control
fesl 

### pc: Samnlf

### Araj, Ohio EPA, DAPC-NWDO PatrickMontgomery, Martin MariettaMagnesia Specialties NWDOfnle

Ohio EPA is an Equal Opportunity Employer