Section of APCD/Stationary Sources Program
INTER-OFFICE COMMUNICATION
PS Memo 99-1
TO:
CP Permit Engineers
FROM:
Dennis M. Myers and Aaron Frame
DATE:
February 24, 1999
SUBJECT:
Operating parameters for common control devices
In order to standardize final approval permits for true minor sources with control devices, standard permit condition #12
(WP6.1) requires further examination. In certain situations it is necessary to include this condition in the permit when the
control efficiency is questionable. Please continue to check with your unit supervisor before including this condition in a
permit. The condition currently states:
This source shall be equipped with _____ capable of reducing uncontrolled emissions of _____ by at least _____%.
Operating parameters of the control equipment shall be identified prior to final approval of this permit. The
identified operating parameters will replace the control efficiency requirement on the final permit. (Reference:
Regulation 3B.IV.E.)
As more and more final approval permits are processed, the Construction Permit Unit should adopt common operating
parameter requirements for simple, common control devices. If common requirements are not implemented, similar sources
could end up with different operating parameters for the same type of control device. By using common parameters, final
approval processing can be expedited and provide equitable treatment for sources.
Several points should be made about the operating parameters listed below. First, for true minor sources both the initial
approval version and the final approval version of standard condition #12 will normally be used. For synthetic minor sources
normally only the initial approval version will be used, since the final approval permit should contain a separate permit
condition stating that the operating and maintenance plan approved by the Division shall be followed. It would be redundant
to specify control device operating parameters in a synthetic minor permit condition when the same information will be
included in the operating and maintenance (compliance) plan. Second, the intent here is to provide common operating
parameters for common control devices only. Engineers should work with enforcement staff to develop appropriate operating
parameters for control devices which are not referenced here. Third, these operating parameters should also be applied to
sources requiring one of the following control devices to satisfy RACT. RACT sources using control devices do not
necessarily require special treatment by adding operating parameters beyond those proposed here, but parameters can be
added as deemed necessary.
A list of common control devices and their proposed corresponding operating parameters are listed below. This data was
compiled by Scott Mason and Aaron Frame.
CONTROL DEVICE
OPERATING PARAMETERS
FREQUENCY
All cyclones
Manufacturers recommended pressure drop across the
cyclone
Weekly record keeping February 5, 1999
Page 2
Operating parameters for common control devices
Shaker baghouses
Manufacturers recommended pressure drop across the
baghouse
Weekly record keeping
Jetpulse baghouses
1. Manufacturers recommended pressure drop across the
baghouse
2. Manufacturers recommended jetpulse header pressure
Weekly record keeping for both
parameters
Wet scrubbers for particulate
1. Manufacturers recommended pressure drop across the
scrubber
2. Manufacturers recommended spray nozzle header pressure
Weekly record keeping for both
parameters
Wet scrubbers for acids/bases 1. Manufacturers recommended pressure drop across the
scrubber
2. Manufacturers recommended spray nozzle header pressure
3. Scrubbing liquor pH shall be:
7.0 < pH < 9.0 (for acids)
5.0 < pH < 7.0 (for bases)
Weekly record keeping for
all parameters
Engines with any catalytic
controls (selective or non-
selective)
1. Manufacturers recommended replacement schedule for the
O
2
sensor, based on cumulative hours of operation
2. Manufacturers recommended cleaning and regeneration
schedule(s) for the catalyst, based on cumulative hours of
operation
Record keeping of
hours of operation
(A frequency is not specified here
since many engines are
unmanned.)
An example of the same standard condition in an initial approval and a final approval permit are as follows:
Initial approval version:
This source shall be equipped with a jetpulse baghouse capable of reducing uncontrolled emissions of particulate
matter by at least 99.0%. Operating parameters of the control equipment shall be identified prior to final approval
of this permit. The identified operating parameters will replace the control efficiency requirement on the final
permit. (Reference: Regulation 3B.IV.E.)
Final approval version:
This source shall be equipped with a jetpulse baghouse. The pressure drop across the baghouse shall read 3-5
inches water column. The jetpulse header pressure shall read 90-100 psig. Records of the pressure drop across the
baghouse and jetpulse header pressure shall be maintained weekly by the applicant and made available to the
Division for inspection upon request. (Reference: Regulation 3B.IV.E.)