CONTINUOUS OPACITY MONITOR
OPERATION AT A
PRESSURIZED BAGHOUSE
-------
CONTINUOUS OPACITY MONITOR
OPERATION AT A
PRESSURIZED BAGHOUSE
Field Evaluation Report
Contract 68-02-3541
Work Assignment 4
Submitted to
U.S. Environmental Protection Agency
Office of Air Quality Planning and Standards
Research Triangle Park, North Carolina 27711
Work Assignment Manager
Peter Westlin
October 1981
9122.00/25
Prepared by
Engineering-Science
7903 Westpark Drive
McLean, Virginia 22102
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TABLE OF CONTENTS
CHAPTER 1 INTRODUCTION 1-1
CHAPTER 2 DISCUSSION OF RESULTS 2-1
CHAPTER 3 DESCRIPTION OF TEST FACILITY 3-1
CHAPTER 4 EVALUATION PROCEDURES 4-1
APPENDIX FIELD DATA
ii
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LIST OF FIGURES
1.1 Baghouse General Arrangement 1-3
2.1 Transmissometer vs. RM9 Opacity Measurements
(6/3/81, 9:28-10:28 am) 2-6
2.2 Transmissometer vs. RM9 Opacity Measurements
(6/10/81, 9:52-10:52 am) 2-7
2.3 Transmissometer vs. RM9 Opacity Measurements
(6/11/81, 1:41-2:45 pm) 2-8
2.4 Transmissometer vs. RM9 Opacity Measurements
(6/12/81, 10:16-11:10 am) 2-9
2.5 COM Measurements During Cleaning System Mal-
function (above) Normal Operation (below) 2-10
2.6 COM Recording During Normal Furnace and
Baghouse Operation (6/12/81) 2-11
3.1 Electric Arc Furnace Process Schematic 3-4
3.2 Baghouse - Side View 3-5
4.1 Plan View of Baghouse with RM9 Observer Posi-
tions/ Sun Positions and Wind Directions 4-3
LIST OF TABLES
2.1 RM9 and COM System Opacity Measurements 2-5
2.2 Smoke Release Tests 2-6
111
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CHAPTER 1
INTRODUCTION
Engineering-Science (ES) conducted a long-term evaluation of the
operation of a continuous opacity monitoring (COM) system measuring the
opacity of emissions from a pressurized baghouse controlling the discharge
from two electric arc furnaces at a steel mill located in the southeast.
Drawings of the baghouse discharge and COM transceiver are shown in
Figure 1.1. This work was performed under contract to the U.S. Environ-
mental Protection Agency (EPA), Office of Air Quality Planning and Stan-
dards, Emission Standards and Engineering Division, Emission Measurement
Branch (Contract 68-02-3541, Work Assignment 4). The purpose of this
evaluation was to:
o Determine the ability of the COM system to record accurate,
representative measurements of emissions opacity for a 30-day
period.
o Determine the extent to which this data could be used to in-
dicate the need for baghouse maintenance by detecting increases
in emissions opacity resulting from baghouse malfunctions.
o Compare COM system measurements to Reference Method 9 measure-
ments.
The evaluation consisted of visible emissions measurements (Refer-
ence Method 9) and simultaneous recording of opacity monitor measurements
on an auxiliary recorder installed by ES. Visible emissions measurements
were made during normal furnace and baghouse operation, during high opa-
city events simulated by smoke generators located within the baghouse,
during, actual baghouse malfunctions (cleaning system, hopper removal sys-
tem not operational), and during simulations of baghouse malfunctions
(torn bags installed by ES). Continuous recordings of opacity were made
by the auxiliary recorder to document the actual operation of the opacity
monitoring system installed on the subject baghouse.
Furnace operation was observed and documented during this period us-
ing plant operating records. Baghouse operation and maintenance was do-
cumented using plant records and daily interviews with mill operators re-
sponsible for baghouse operation and maintenance. Opacity monitor opera-
tion was monitored through daily inspections of automatic calibration and
weekly optical alignment checks. Upscale and zero calibrations were per-
formed manually each week by ES during furnace shutdown. "Zero stack"
conditions allowed these weekly calibrations to be conducted with the
monitor in an operating mode when all system components (electronic and
optical) were operating.
1-1
-------
The results of this evaluation indicate that:
o The opacity monitor system measurements varied significantly with
visible emissions observations during the entire evaluation even
though both measurements were made using the same pathlength.
Method 9 measurements were 33% to 50% lower than monitor measure-
ments during normal operation and baghouse malfunctions (cleaning
system shutdown, a torn bag).
o Method 9 measurements ranged from 120% to 600% higher than COM
measurements during smoke release tests. In these tests, the
degree of discrepency between the two measurement methods varied
directly with the smoke generate position.
o The opacity monitor system does not measure a representative por-
tion of discharge flow for all conditions. Opacity emissions from
broken bags can exit the baghouse undetected by the COM. Monitor
response varied with the location of smoke generators within the
baghouse. When emissions are caused by dust penetration in a
small area within a compartment, the particles may not pass
through the measurement path. The apparent reversal of relative
measurements by the COM system and Method 9 observation during
smoke release tests compared to other measurement conditions is
caused by the fact that not all, if any, of the smoke generated
passed through the measurement path of the COM system, while it
was quite visible at the observer's view point.
o The opacity monitor system can detect most baghouse malfunctions
which effect the entire baghouse such as cleaning system malfunc-
tions.
o During normal operation, periods of increased opacity emissions
due to process changes can be detected by the opacity monitor
system. These measurements were recorded during portions of
furnace cycles known to generate higher than normal dust concen-
trations in baghouse inlet flow.
o A general increase in opacity measured by the COM and Method 9
with increasing tear size was observed. The opacity monitoring
system did detect emissions penetrating a single torn bag with
tears ranging in size from 1 inch to 9 inches. The torn bas was
located in a position in which the monitor and RM9 measurements
compared closely during the smoke release tests.
o The absolute difference between opacity measured by the COM sys-
tem and Method 9 increased with opacity. The difference is par-
ticularly noticeable for measurements from 7% to 18% (the highest
opacity measured) when COM measurements where 13% to 400% higher
than Method 9 measurements.
o The COM system operated for thirty days with no malfunctions or
zero calibration drift.
1-2
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FIGURE 1.1
Baghouse General Arrangement
MONITOR.^
PEAK OF
- ROOF-
.OUTLET
\/
SMOKE RELEASE POSITIONS
• • (3) •
3 II 1
-TORN BAG
POSITION
INLET MW9 OBSERVER LOCATION
PLENUM
-MONITOR-
INLET
PLENUM
SMOKE
RELEASE
POSITIONS
1-3
ENGINEERING-SCIENCE
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CHAPTER 2
DISCUSSION OF RESULTS
The field evaluation of the operation of the COM system measuring
pressurized baghouse emissions opacity was designed to determine if:
o COM system measurements correlate to Reference Method 9 (RM9)
measurements.
o COM system measured a portion of baghouse discharge flow which
exhibited opacity representative of the opacity of overall flow.
o COM system measurements could identify the increase in opacity
of emissions caused by baghouse malfunctions or furnace opera-
tion.
COM SYSTEM MEASUREMENTS VS FM9 MEASUREMENTS
Table 2.1 presents a comparsion of opacity measurements made by the
COM system and RM9 observations conducted during: (1) normal baghouse
operation (Figures 2.1 through 2.4), (2) a baghouse hopper removal system
malfunction which required shutdown of baghouse cleaning operations, and
(3) torn bag emissions penetrating tears installed by ES.
The comparsion of RM9 measurement averages to integrated COM measure-
ments shows different relative measurements between the two depending on
the comparison conditions. The higher RM9 measurements for the represen-
tative flow test measurements (Table 2.2) can be expected. It is shown
later in this chapter that the COM system does not measure a representa-
tive portion of overall flow.
The remaining' measurement comparison variations during normal and
malfunction operation (Table 2.1) can be attributed to: the limited
availability of RM9 locations which duplicated the measurement path of the
COM system; cyclical variations in peak opacity during cleaning cycles
which occur during the 15 second interval between FM9 observations (RM9
measurements are averaged during the same period as COM measurement inte-
gration); and, any inherent discrepency between TO*9 and actual opacity,
at the low opacity observed. Since RM9 measurements are made in multiples
of 5 percent opacity, a six minute average opacity of 2.9 percent, for
example, may be determined from several 0 percent and 5 percent opacity
measurements, none of which accurately depict the actual opacity dur-
ing measurement. A 0 percent recording represents no visible emissions
2-1
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which may have an actual opacity of up to 3 percent while a 5 percent
recording would represent barely visible emissions which could have an
actual opacity of 3 percent to 7 percent.
The COM/RM9 comparison showed relative measurement of opacity within
from .1 percent to 8 percent opacity for comparative measurements made
during normal and malfunction operation as shown in Table 2.1. During
normal conditions the COM system recorded an average opacity of 3.6
percent while the average of RM9 recordings was 2.4 percent. During
malfunction operation, the COM system average was 9.5 percent and the
RM9 average was 4.8 percent opacity.
EVALUATION OF THE REPRESENTATIVENESS OF COM MEASUREMENTS
The relative measurements made during representative flow tests
varied considerably more (Table 2.2), although this was anticipated. Dur-
ing these tests the smoke generators where located in four positions with-
in baghouse compartment D for six tests each. The relationship between
the relative COM/RM9 measurements and smoke generator position is illus-
trated in Table 2.2.
ES expected much higher RM9 opacity measurements than COM system mea-
surements because the COM system measurement path was not capable of
"seeing" all smoke generated from locations 3 and 4 as shown in Figure
1.1. Measurements by the RM9 observer were higher by an average of 1.5
percent for smoke released opacity in position 1, 3.6 percent opacity in
position 2, 6.5 percent opacity in position 3 and 15.6 percent in position
4 than the opacity measured by the COM system. This shows that the closer
the source of emissions penetration is to the exhaust vent, the less likely
they are to pass through the COM measurement path.
The comparisons demonstrate the correlation of COM opacity measure-
ments to the location of smoke generators during these tests. The emis-
sions penetrating torn bags in the vicinity of positions 3 and 4 during
normal malfunctions can be expected to exhibit similar flow characteris-
tics bypassing the COM system measurement path. Emissions from half the
bags with a compartment could exit the baghouse largely undetected.
OPACITY MEASUREMENT DURING BAGHOUSE MALFUNCTIONS
Normal baghouse and furnace operation was maintained during the
majority of the test period. The baghouse hopper dust removal system
malfunctioned from June 15, 1981 to June 19, 1981 which also required
shutdown of bag cleaning system operation. Baghouse pressure drop and
emissions opacity increased. Baghouse emission measurements during this
period are compared to COM measurements during normal baghouse operation
in Figure 2.5. Note the absence of cleaning cycle emissions opacity
peaks as well as the overall reduction in integrated opacity measurements
when the baghouse cleaning system is not operating. The reduction in
integrated opacity during this malfunction is due to the absence of clean-
ing cycle peak opacities which tend to raise the integrated measurements
above the typical non-cleaning measurements recorded during COM integration
2-2
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period. Penetration by emissions through seepage can be expected during
a cleaning system shutdown. Increased pressure drop across the thicker
filter cake stretches the fabric filter and plugs of the filter cake
penetrate the fabric leaving additional paths through the fabric for
particulate penetration. Observe the relative increase in real time
recordings (excluding cleaning cycle recordings of opacity) during this
malfunction over normal operations. For further discussion of the rela-
tionship between baghouse pressure drop and emissions refer to "An
Investigation of Fabric Filter Emissions Correlation (Contract €8-01-4146;
Task Order 69; Bob King, Task Manager).
During torn bag tests conducted by ES, bag tears were artificially
introduced in 1-inch, 3-inch, 6-inch, and 9-inch lengths at a single bag
position within compartment D which approximated the average of measure-
ments during representative flow measurements. As can be observed in
Table 2.1, a general correlation between bag tear size and COM measurement
exists. COM system measurements increased from 7.3 percent opacity for a
one inch tear to 15 percent for a 9 inch tear while EM9 measurements
ranged from 4.9 to 10.8 percent opacity respectively.
OPACITY MEASUREMENT DURING NORMAL OPERATION
Opacity measurements exceeding the 3 percent standard for this source
classification (Electric Arc Furnaces - 40 CFR 60, Subpart AA), were re-
corded for periods of six minutes by the COM system recorder and the aux-
iliary recorder installed by ES and by RM9. In many cases the high inte-
grated recordings and averaged RM9 measurements were caused by cleaning
cycle emissions. In many other cases, the real time COM recordings ex-
ceeded 3 percent excluding the cleaning cycle peaks. The real time mea-
surements occurred during specific furnace operations such as oxygen lanc-
ing and immediately following charging when the electrodes are lowered
into the furnace bucket and charge melting begins. It is at this time
that rust, paint, oil and other impurities are removed and exit with fur-
nace discharge gas flow. The excess opacity measurements usually lasted
for 15 to 30 minutes. Figure 2.6 correlates the high opacity events to
furnace melting (as denoted in plant records as "power on") operation.
CONCLUSIONS
The following conclusions, relative to the goals of this evaluation
as presented at the beginning of this chapter, can be drawn from the
results of this evaluation:
o The COM system measurements were consistently higher than
RM9 measurements during normal and malfunction conditions.
o The COM system does not always measure a representative portion
of overall baghouse exhaust flow.
o Increases in emissions due to baghouse malfunction and changes
furnace operation were detected by the COM system as increases
in opacity.
2-3
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TABLE 2.1
RM9 AND COM SYSTEM OPACITY MEASUREMENTS
Date
6-3-81
6-10-81
6-11-81
6-12-81
6-16-81
6-17-81
6-23-81
6-24-81
6-24-81
6-24-81
6-25-81
6-25-81
Time
1341-1435
0928-1028
0952-1052
1016-1110
1043-1143
1331-1425
1718-1818
0943-1037
1125-1219
1301-1355
0913-1007
1025-1125
Test Conditions
Normal
Operation
Normal
Operation
Normal
Operation
Normal
Operation
Baghouse cleaning
system not in
operation
1-inch tear in bag,
C- 1 7 , Compartment D
3-inch tear in bag,
C-17, Compartment D
3-inch tear in bag, •
C-17, Compartment D
6-inch tear in bag,
C-17, Compartment D
6-inch tear in bag,
C-17, Compartment D
9-inch tear in bag,
C-17, Compartment D
9-inch tear in bag,
C-17, Compartment D
COM System
Measurements
( average of
six minute
integrations )
3.1
2.9
4.2
4.1
3.1
7.3
12.6
8.2
5.8
11.5
12.4
15.0
RM9
Measurements
( average of
six minute
averages)
2.2
2.8
1.9
2.8
0.1
4.9
2.7
3.0
2.1
5.2
9.6
10.8
2-4
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TABLE 2.2
SMOKE RELEASE TESTS
NJ
I
(Jl
Test
1
2
9
10
18
19
3
4
11
12
20
22
5
6
13
14
23
24
7
8
15a
16
17
25
26
Date
6-B-81
6-8-81
6-8-81
6-8-81
6-9-81
6-9-81
6/8/81
6/8/81
6/8/81
6/8/81
6/9/81
6/9/81
6/8/81
6/8/B1
6/8/81
6/8/81
6/9/81
6/9/81
6/8/81
6/8/81
6/9/81
6/9/81
6/9/81
6/9/81
6/9/81
Time
10:05-10:11
10.17-10:23
1:35—1:41
2:05--2:11
8:59—9:05
9:05—9:11
10:29-10:35
10:41-10:47
2:17—2:23
2:29—2:35
9:11 — 9: 17
9:23 — 9:29
12:05-12:11
12: 11-12:17
2:41—2:47
2:53—2:59
9:29—9:35
9:35—9:41
10:23-12:29
12:29-12:35
8:35—8:41
8:47 — 8:53
8:53 — 8:59
9:41—9:47
9:47—9:53
Smoke
Release
Location
Average
2
2
2
2
2
2
Average
3
3
3
3
3
3
Average
4
4
4
4
4
4
4
% Opacity
(Monitor)
(six minute
integration)
7.0
4.5
7.3
7.8
10.0
10.4
7.8
6.5
9.2
5.8
6.4
7.5
10.9
7.7
8. 1
3.9
3.8
3.5
13.5
15.3
8.0
2.2
1.9
3.7
2.1
2.2
4.6
2.1
% Opacity
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FIGURE 2.1
Transmissometer vs. RM9 Opacity Measurements
C6/3/81, 9:28-10:283170
7-
> 6
•o
"9
01
-------
FIGURED. 2
Transmissometer vs. RM9 Opacity Measurements
(6/10/81, 952-10:52am)
7-
o -
OJ
cn»
QJ
5.--
c
O)
3
C
f 4
a.
O
UJ
cc.
UJ 0
o. 2
i i i !i i i i r
0 6 12 13 24 30 36 42 48 54 60
TIME, minutes
TRANSMISSOMETER -
RM9
2-7
ENGINEERING-SCIENCE
-------
FIGURE 2.3
Transmissometer vs. RM9 Opacity Measurements
. C6/11/81, t:41-2:45pm)
7-
03
> 6
•O
(U
CD*
CU
5---
f 4
VO
o
Q_
O
Of.
UJ /,
a. 2
i i i i r r i
6 12 18 24 30 36 42
TIME, minutes
TRANSMISSOMETER
RM9
2-8
ENGINEERING-SCIENCE
-------
FIGURE 2.4
Transmissometer vs. RM9 Opacity Measurements
.(6/12/81; 10:16-11:1 Oam)
7-
to
Ol
3
6-
•o
41
S-
o>
01
5',-
CL>
4->
3
f 4
U
«C ,
O. 3
O
Of.
LU 0
Q. 2
1 -
0^
-0^^
0
r i i i r r i i i
Q 6 12 18 24 30 36 42 48 54 60
TIME, minutes
TRANSMISSOMETER
RM9
2-9
ENGINEERING-SCIENCE
-------
FIGURE 2.5k-
Measurements During
Cfeaning Sy stenrtj/faif unction Cabo ve)
Normal Operation Cbetow]|j
15.
10
o
«c
ui.
S 5
••'Uil 'If 'III
.:;:i-,'i: -iir
BII»l!!52!K!r:S'SiHil II Mil 11- IH 111 IV i
HiimnniiiBiniB :nni;ntinii LI • in-n r-i
0015
oooa
1115,
1100
0300
0745
2-10
ENGINEERING-SCIENCE
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FIGURE 2.6
COM Recording
During Normal Furnace and Baghouse Operation
C6/t2/8t} "
o
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CHAPTER 3
DESCRIPTION OF TEST FACILITY
The COM system evaluated during this investigation is installed on
a pressurized baghouse which controls particulate emissions discharged
by two electric arc furnaces melting scrap to produce steel for the mill.
These are direct evacuation systems. The particulate concentration of
exhaust discharged by the furnaces varies with the operation of the
furnaces during each operating cycle consisting of several individual
operations. The discharge is drawn through a duct which connects to the
furnace when the cap is in place/ and through a roof duct which collects
fugitive emissions when the cap is removed for charging and pouring.
Figure 3-1 shows a schematic of the process.
Fugitive or shop emissions are most evident during the first opera-
tion of a furnace cycle which is the charging of scrap metal by dumping
it into the furnace with an overhead crane. The electrodes are then
slowly lowered into the furnace, melting the scrap and volatilizing and
combusting paint grease, oil, rust, and other impurities. This operation
produces significant dust emissions in the shop, some of which are
collected by the roof exhaust duct which is connected to induced draft
(ID) fans. Other fugitive emissions escape through roof vents to the
atmosphere.
Once the cap is completely lowered, the furnace exhaust duct, also
connected to ID fans, collects all furnace emissions. The inlet concen-
tration of particulate is highest during the first 10 to 30 minutes of
each melt after which they decrease significantly. A second charge is
added after the first charge is melted down. Fugitive emissions are again
present in the shop, and continue until the cap is lowered. Baghouse in-
let particulate loading increases for another 10 to 30 minute period.
Figure 2.6 presents the COM system opacity measurements during furnace #4
charge and melt operations. The melt operation is denoted in mill records
by "power on", referencing the electrical power drawn during this opera-
tion.
One further operation called oxygen lancing is performed which results in
high baghouse inlet particulate concentrations. Pure oxygen is added to
the molten steel through a removeable probe under high pressure. This
oxidizes carbon and other impurities and forms aerosols which enter the
cap exhaust duct.
3-1
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Baghouse Description
The baghouse evaluated during this investigation consisted of two
parallel rows of baghouse compartments receiving flow from the ID fans
through ductwork at the bottom. There are eight compartments per row,
each containing 88 30-foot long bag filters. A reverse pulse cleaning
system removes filter cake which drops to the hoppers below, where dust
is removed by a screw conveyor system. The baghouse is illustrated in
Figures 3.1 and 3.2.
Continuous Opacity Monitoring System
The COM system used at this facility consists of two Dynatron Model
1100 emission monitoring systems. One instrument was mounted on each row
of baghouse compartments near the bottom center of the discharge vent.
Transceiver output is integrated over six-minute periods and recorded on
a 0 to 100 percent opacity scale strip chart, which is located in the bag-
house operating room along with the monitor control unit and all baghouse
and ID fan controls. The double pass measurement is converted to a single
pass output for the actual measurement path width. No exit diameter cor-
rection is necessary since the monitor pathlength spans the entire length
of the exhaust vent (Figures 3.1 and 3.2). The system uses a 30 percent
opacity internal filter for span calibration. An internal electronic cal-
ibration system does not check absolute zero calibration, but provides a
12 percent opacity low scale calibration..
Baghouse Operation and Maintenance
Baghouse O&M is conducted during the day shift. One operator is
permanently assigned to baghouse maintenance. Daily inspection of the
cleaning system pneumatic controls is performed. The dust removal system
required most of the operators' attention since a new dust pelletizor was
undergoing initial operation. Baghouse compartment internal inspections
were conducted by ES each weekend to locate any torn or loose bags. The
baghouse appeared to be in good condition during the entire test evalua-
tion. It is assumed that all normal emissions resulted from penetration
mechanisms such as pinhole plug, seepage, and straight through penetra-
tion. Compartment pressure drop is measured and compartment cleaning is
performed on four-minute intervals on each row. Individual pressure drop
normally ranges from 6 to 8 inches f^O. Each weekend the furnaces are
shutdown for maintenance, and baghouse reverse flow fans are operated
continuously to clean filter bags.
Baghouse maintenance is recorded in a baghouse maintenance log which
documents any malfunctions, repairs, and bag replacements. ID fan failure
is alarmed in the furnace control room. Baghouse operation during this
investigation was normal except during the dust removal system malfunction
which required shutdown of the bag cleaning system. Compartment pressure
drop increased to 13 inches f^O. Visual observations of baghouse compart-
ment opacity are conducted daily.
ES site personnel observed the reduction in COM system integrated
opacity measurements and an absence of cleaning cycle peaks on June 15,
1981 and notified baghouse and COM system operators. Compartment
3-2
-------
pressure drop had increased from 6 to 8 inches H20 during normal operation
to 13 inches H20. Hopper level and cleaning system fault alarms were
operating in the baghouse control room along with COM system recording and
alarm. Plant personnel had disrupted cleaning operations to avoid filling
the dust hopper in responsse to the high level alarm. Repairs the hopper
removal systems were performed and once the hopper dust level was lowered,
the bag cleaning system was reactivated.
Continuous Opacity Monitoring System Operation and Maintenance
Prior to initiating this investigation the COM system had experienced
intermittent difficulty in making accurate measurements. Opacity record-
ings would inexplicably increase by 30 to 60 percent for several hours,
sometimes days, with no actual change in opacity, or baghouse and furnace
operation. This problem was corrected by a manufacturer representative
prior to the beginning of this investigation. The power supply was mal-
functioning because higher current was thought to be needed for the source
lamp to compensate for the path length. The lamp current was reduced and
the power supply replaced.
Monitor operation and maintenance is performed by an instrument
technician. The purge air blower and calibration is checked daily. COM
system recordings and control unit fault indicators are observed several
times daily by the technician. Any maintenance is recorded in a monitor
log book. No monitor maintenance was performed during this investigation
because no malfunctions occurred.
3-3
-------
Electric Arc Furnace'Process Schematic
^FURNACE EXHAUST DUCT
:ROOOXHAUST PUCT,
FURNACE CAP
ELECTRODES-
PILE
RAILROAD CAR
BAGHOUSE
._... SLAG--1
.MOLTEN STEEL',.
TO ROLLING MILL:-1
ID FANS.. SPARK .
ARRESTER
-------
PTGORE. 3>2*
Baghouse - Side View __;
BAGHOUSE: EXHAUST VENTS.;
- COW TRANSCEIVER?
22
- Denotes smoke release position
3-5
ENGINEERING-SCIENCE
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CHAPTER 4
EVALUATION PROCEDURES
Visible Emissions Observations
Visible emissions were observed by following RM9 procedures as
closely as possible. It can be seen from Figure 4.1, that the position
from which FM9 measurements were taken is not consistent with the three
stack height distance recommended by the method. This was the only loca-
tion available which positioned the sun at the back of the observer and
which allowed the observer a measurement path which approximately dupli-
cated the COM system measurement pathlength. ?M9 measurements could be
made only when wind was from the southwest, west or northwest or when
wind velocity was below 5 to 10 mph. This was because strong easterly
winds blew through the exhaust vent and all emissions exited through the
west side undetected by the observer.
Emissions from individual compartments could be recognized during
their respective cleaning cycles because the opacity of these emissions
was significantly higher than the opacity of emissions from other com-
partments .
Several IM9 measurements were conducted during normal baghouse and
furnace operations. These were correlated to furnace operation (Table
2.1). RM9 measurements were also conducted during a baghouse cleaning
system shutdown, smoke releases (representative flow tests), and torn
bag tests to evaluate COM system sensitivity.
COM System Calibration
The auxiliary recorder installed by ES was connected to the real
time and six minute integrated outputs of single pass opacity from the
COM system control unit. A 20.5 percent opacity span filter was used by
ES and the full scale output of the recorder was set at 50 percent opa-
city to maximize recording sensitivity. During the furnace shutdown of
the weekend of June 2, zero emissions were measured by the COM system.
The 20.5 percent filter was manually inserted into the measurement beam
using a manual calibration jig which allows the filter to be inserted
into the transceiver. This was performed while the COM system was in
measurement mode when actual calibration drift and alignment can be de-
termined with all measurement components (optical and electronic) in op-
eration. This procedure was conducted during each weekend maintenance
shutdown of mill and furnace operations. No alignment or calibration
problems were identified during the evaluation period. The COM system
4-1
-------
had an internal span calibration filter of 45% opacity and a low calibra-
tion filter of 15% opacity. The system automatically performed daily
internal calibration checks at 7:00 a.m.
Manual calibration could not be performed during the weekend of June
20 because of the noise in the COM system control unit output resulting
from reverse flow fan operation. Reverse flow fan operation is conducted
during the weekend shutdowns to further clean filter bags. During this
weekend, furnace shutdown occurred earlier than usual, reverse flow
operation began ahead of schedule, and zero calibration during COM mea-
surement mode operation was not possible.
Representative Flow Evaluation
This test was designed to determine if emissions penetrating a com-
partment from different bag positions could be detected by the COM system.
Refering to Figure 3.2, the four smoke release positions in compartment
D were selected to demonstrate the relationship between emissions pene-
tration location and COM system measurements. The smoke candles used
were Superior Signal Corp Type D, which have a smoke generating capacity
of 200,000 cubic feet in duration of four to six minutes. The flow and
duration of smoke from these candles varied and six tests were conducted
at each smoke release location and measurements were averaged to allow
for the inconsistent candle characteristics. The tests were scheduled
to avoid interference with compartment D cleaning cycles. Melting op-
erations causing high background opacity measurements by the COM system
were excluded from the test conditions. These measurements of furnace
melting emissions were excluded to eliminate extraneous measurements
from the representative flow tests. The results of this test are pre-
sented in Table 2.2.
Torn Bag Evaluation
This evaluation was performed to determine if the COM system was
effective in detecting emissions from broken or torn fabric filter bags.
A 1-inch tear was installed in bag C-17 of compartment D. This loca-
tion was selected because it was known from earlier smoke generation
tests that measurements of emissions originating there could be made by
the COM system which compared closely with RM9. RM9 measurements were
conducted for one hour during seven separate tests. Three-inch, 6-inch,
and 9-inch tears were sequentially introduced at the original location.
Normal furnace operations were performed during the RM9 measurements
taken while torn bags were in compartment D.
4-2
-------
FIGURE 4.1
Plan View of Baghouse with RM9 Observer Positions,
Sun Positions and Wind Directions
POSITION 2
NW
W
SW
BAGHOUSE CQM TRANScEivER. BAGHOUSE
RM9 POSITION 2
A
B
C
D
E
F
G
H
X
COM PATHLENGTH,
COM RETROFLECTOR
—
^
I
J
K
L
M
N
0
P
in
RM9 POSITION 1
WIND DIRECTIONS
DURING RM9
POSITION T
4-3
ENGINEERING-SCIENCE
-------
APPENDIX
FIELD DATA
-------
/£-„
/5V
- !
..!_
-------
SUMMARY
LOCATION
SUMMARY OF AVERAGE OPACITY
HOURS OF OBSERVATION }\^1^2\
OBSERVER
TEST NUMBER
DATE
TYPE FACILITY
CONTROL DEVICE
OBSERVER CERTIFICATION DATE
OBSERVER AFFILIATION £ J
POINT OF EMISSIONS
HEIGHT OF DISCHARGE POINT
Set
Number
Time
Start— End
//://* -2 :/?:/r
rr*—
Opacity
Sum Average
40
50
40
35
Readings ranged from
I- 7
/.r
to % opacity
The source was/was not In compliance with
at the time evaluation was made.
-------
SUMMARY
SUMMARY OF AVERAGE OPACITY
HOURS OF OBSERVATION
LOCATION
TEST NUMBER
DATE
TYPE FACILITY_
CONTROL DEVICE
OBSERVER
OBSERVER CERTIFICATION DATE
OBSERVER AFFILIATION e_
POINT OF EMISSIONS
4/^r/
HEIGHT OF DISCHARGE POINT
Set
Number
Time
Start— End
10 '
- 10 -.
Ji
It:?
lr.ll
Opacity
Sum Average
\oo
3,7
u
Readings ranged from
to % opacity
The source was/was not In compliance with
at the time evaluation was made.
-------
SUMMARY OF AVERAGE OPACITY
SUMMARY
LOCATION //c
TEST NUMBER_^
DATE
TYPE FACILITY
CONTROL DEVICE
HOURS OF OBSERVATION
OBSERVER
OBSERVER CERTIFICATION DATE
OBSERVER AFFILIATION
POINT OF EMISSIONS
HEIGHT OF DISCHARGE POINT
Set
Number
Time
Start— End
Opacity
Sum Average
\o-.o5--
\0«.
2-20
ID'.
Readings ranged from
to % opacity
The source was/was not In compliance with
at the time evaluation was made.
-------
SUMMARY OF AVERAGE OPACITY
SUMMARY
LOCATION
TEST NUMBER
DATE
TYPE FACILITY
CONTROL
HOURS OF OBSERVATION
OBSERVER D'.
OBSERVER CERTIFICATION DATE
OBSERVER AFFILIATION
POINT OF EMISSIONS
HEIGHT OF DISCHARGE POINT
Set
Number
Time
Start— End
a:o5" - \l\\i
\1'.i\^ \is.\1
ii/.n - \z\-&
\L\l* - (Z\ 11
12. -^ - if. *$"
ii\ *>*r -iz: *'
u'. +l-iZ'.<*1
Opacity
Sum
^50
vK
406
r^o
Average
\o.4-
\4,
Readings ranged from
to % opacity
The source was/was not 1n compliance with
at the time evaluation was made.
-------
SUMMARY OF AVERAGE OPACITY
SUMMARY
LOCATION
TEST NUMBER
DATE ^'
TYPE FACILITY
CONTROL DEVICE
tf
HOURS OF OBSERVATION
OBSERVER
OBSERVER CERTIFICATION DATE
OBSERVER AFFILIATION
POINT OF EMISSIONS
HEIGHT OF DISCHARGE POINT
Set
Number
Time
Start—End
Sum
opacity
Average
260
2.+0
ID
xfr
\\.d
2-.
Readings ranged from
to % opacity
The source was/was not In compliance with
at the time evaluation was made.
-------
SUMMARY
SUMMARY OF AVERAGE OPACITY
HOURS OF OBSERVATION
LOCATION
TEST NUMBER
DATE
TYPE FACILITY
CONTROL DEVICE
OBSERVER
OBSERVER CERTIFICATION DATE
OBSERVER AFFILIATION
POINT OF EMISSIONS
HEIGHT OF DISCHARGE POINT
Set
Number
Time
Start— End
3;&r -*>'.{/
Opacity
Sum
2^
Average
)\.a
Readings ranged from
to % opacity
The source was/was not In compliance with
at the time evaluation was made.
-------
SUMMARY OF AVERAGE OPACITY
SUMMARY
LOG AT I ON
3. £•
TEST NUMBER
DATE
TYPE FACILITY
CONTROL DEVICE
HOURS OF OBSERVATION
OBSERVER
OBSERVER CERTIFICATION DATE
OBSERVER AFFILIATION
POINT OF EMISSIONS
HEIGHT OF DISCHARGE POINT
Set
Number
Time
Start— End
Opacity
Sum
Average
?'.«(-
I3./
JO.O
\o- L
II. 4-
Readings ranged from
to % opacity
The source was/was not In compliance with
at the time evaluation was made.
-------
SUMMARY OF AVERAGE OPACITY
SUMMARY
LOG AT I ON jJuCcHs
TEST NUMBER
DATE
TYPE FACILITY
CONTROL DEVICE
*?
HOURS OF OBSERVATION
OBSERVER
OBSERVER CERTIFICATION DATE
OBSERVER AFFILIATION
POINT OF EMISSIONS
HEIGHT OF DISCHARGE POINT
Set
Number
Time
Start— End
Opacity
Sum Average
370
-^
±
-H
I O'. n <•—fo! |1
t-»H^-
Readings ranged from
to % opacity
The source was/was not In compliance with
at the time evaluation was made.
-------
SUMMARY
SUMMARY OF^pjiAGE OPACITY
•M|^:-V,£f *.'. HOURS OF OBSERVATION
LOC AT I ON
9.C.
TEST NUMBER
DATE /* '/
TYPE FACILITY fiAf
CONTROL
OBSERVER
OBSERVER CERTIFICATION DATE
OBSERVER AFFILIATION
POINT OF EMISSIONS
HEIGHT OF DISCHARGE POINT
3
-------
SUMMARY
SUMMARY OF AVERAGE OPACITY
HOURS OF OBSERVATION
LOC AT I ON /UMC0V $. C.
OBSERVER
TEST NUMBER
DATE
TYPE FACILITY
CONTROL
OBSERVER CERTIFICATION DATE
OBSERVER AFFILIATION
POINT OF EMISSIONS
HEIGHT OF DISCHARGE POINT
Set
Number
Time
Start-End
Sum
Opacity
/r
vof
Vb
Average
0.*
0,4
4,0
Readings ranged from
to % opacity
The source was/was not In compliance with
at the time evaluation was made.
-------
SUMMARY
LOCATI m
TEST NUMBER
DATE ^
TYPE FACILITY
CONTROL DEVICE
*
-------
SUMMARY OF AVERAGE OPACITY
SUMMARY
TEST NUMBER
DATE
TYPE FACILITY
CONTROL DEVICE
U
HOURS OF OBSERVATION
OBSERVER
OBSERVER CERTIFICATION DATE
OBSERVER AFFILIATION
POINT OF EMISSIONS
HEIGHT OF DISCHARGE POINT
Set
Number
Time
Start— End
Opacity
Sum Average
o
l/.'/^n-T-
O
Readings ranged from
to % opacity
The source was/was not In compliance with
at the time evaluation was made.
-------
SUMMARY
LOCATION
TEST NUMBER
DATE &
TYPE FACILITY
CONTROL
SUMMARY OF AVERAGE OPACITY
S.C.
J
HOURS OF OBSERVATION
OBSERVER
OBSERVER CERTIFICATION DATE
OBSERVER AFFILIATION
POINT OF EMISSIONS
HEIGHT OF DISCHARGE POINT
Set
Number
Time
Start— End
Opacity
Sum
Average
0
14-6
7-1
r.
XI
' 2 \61\\*?
I?
Readings ranged from
to % opacity
The source was/was not In compliance with
at the time evaluation was made.
-------
SUMMARY
SUMMARY OF AVERAGE OPACITY
HOURS OF OBSERVATION
LOC AT I W(KJi,
TEST NUMBER
TYPE FACILITY,
CONTROL
U
OBSERVER
OBSERVER CERTIFICATION DATE
OBSERVER AFFILIATION
POINT OF EMISSIONS
HEIGHT OF DISCHARGE POINT
Set
Number
Time
Start—End
Opacity
Sum I Average
*4
1*
-24-
- 6 '.I?.
I--?
Readings ranged from
to % opacity
The source was/was not In compliance with
at the time evaluation was made.
-------
SUMMARY
LOCATI m
TEST NUMBER
PATE,£
TYPE FACILITY
CONTROL DEVICE/^
SUMMARY OF AVERAGE OPACITY
HOURS OF 0
OBSERVER
!VAIION
OBSERVER CERTIFICATION DATE
OBSERVER AFFILIATION
POINT OF EMISSIONS
HEIGHT OF DISCHARGE POINT
Set
Number
Time
Start — End
Opacity
Sum
Average
- f 2*7
I*
9'.
f.f
|o'.i> - /a: 11
1.1
:5< - 10:5
Readings ranged from
to % opacity
The source was/was not In compliance with
at the time evaluation was made.
-------
SUMMARY
LOCAT I ON
TEST NUMBER
DATE
TYPE FACILITY
CONTROL DEVICE
SUMMARY OF AVERAGE OPACITY
HOURS OF OBSERVATION
OBSERVER CERTIFICATION DATE
OBSERVER AFFILIATION
POINT OF EMISSIONS
HEIGHT OF DISCHARGE POINT
Set
Number
Time
Start— End
I!'?? "
Jr.
f 2.10/-I
Opacity
Sum
Average
1-1
0.4,
Readings ranged from
to % opacity
The source was/was not In compliance with
at the time evaluation was made.
-------
SUMMARY
SUMMARY OF AVERAGE OPACITY
HOURS OF OBSERVATION
LOCATION
TEST NUMBER
DATE &
TYPE FACILITY
CONTROL
OBSERVER
OBSERVER CERTIFICATION DATE
OBSERVER AFFILIATION
POINT OF EMISSIONS
HEIGHT OF DISCHARGE POINT
Set
Number
Time
Start— End
Readings ranged from
Opacity
Sum Average
11 0
3,6
to % opacity
The source was/was not 1n compliance with
at the time evaluation was made.
-------
SUMMARY OF AVERAGE OPACITY
SUMMARY
LOCATION
TEST NUMBER
DATE
TYPE FACILITY
CONTROL DEVICE
J
HOURS OF 0
OBSERVER^
EfiVATION
OBSERVER CERTIFICATION DATE
OBSERVER AFFILIATION
POINT OF EMISSIONS
HEIGHT OF DISCHARGE POINT
Set
Number
Time
Start—End
Sum
Opacity
Average
Ho
/t>:o"7-
Readings ranged from
to % opacity
The source was/was not In compliance with
at the time evaluation was made.
-------
SUMMARY OF AVERAGE OPACITY
SUMMARY
TEST NUMBER
DATE
TYPE FACILITY
CONTROL
HOURS OF OBSERVATION
OBSERVER
OBSERVER CERTIFICATION DATE
OBSERVER AFFILIATION
POINT OF EMISSIONS
HEIGHT OF DISCHARGE POINT
Set
Number
Time
Start— End
Opacity
Sum
Average
Kr
12,1
£36
U-1
15.3
- tt'.IJ,
A35"
Readings ranged from
to % opacity
The source was/was not In compliance with
at the time evaluation was made.
------- |