The Nevada Division of Environmental Protection (NDEP) - Bureau of Air Pollution Control (BAPC) is developing a new system for determining the frequency of testing requirements for baghouses associated with non-combustion emissions at facilities of all sizes. The testing determination system (TDS) was developed using data collected from emission inventories, source tests, and permit applications from facilities under the jurisdiction of NDEP. To determine the testing required on a baghouse, NDEP will consider the following three categories and associated subcategories:
Potential to Emit (PTE)
- Uncontrolled PTE (PM10)
- Controlled PTE (PM10)
- Grain Loading Factor (gr/dscf)
- Exhaust Flow Rate (dscfm)/li>
- NVAAQS Model Contribution (%)
- Throughput (tons/hr)
- Fuel Flow (scf/hr)
- Heat Input (MMBtu/hr)
- Failed Source Test (System)
- Throughput Exceedances (System)
- Lack of Records (Facility)
- Failed Opacity (System)
- Failure to Test (System)
- Control Equipment Issues (Facility)
Using a box and whisker plot developed from the collected data, each PTE and operating parameters subcategory may be assigned a ranking value from zero to five. The compliance history subcategories will be ranked by looking at a rolling 60-month period of history without the use of a box and whisker plot. The PTE category is the most heavily weighted category followed by the compliance history category which will be used to reward compliant facilities and scrutinize those that have difficulties maintaining compliance. Based on the cumulative result of the subcategory rankings, the baghouse will be assigned one or more of the following testing frequencies:
- Initial Testing: Non-reoccurring initial performance testing.
- Anniversary Testing: Performance testing conducted one year after initial testing or test failure (conditionally reoccurring).
- Renewal Testing: Performance testing required no earlier than 365 days and no later than 90 days before date of permit expiration.
- Mid-Point Testing: Performance testing required no earlier than two years and no later than three years from initial test or renewal test.
- Annual Testing: Reoccurring performance testing required at anniversary of previous test.
NDEP views the proposed TDS of baghouses as a method of standardizing testing requirements and providing the opportunity for facilities to reduce testing requirements by maintaining compliance with their permits. Roll out of the TDS is planned for April 1, 2020. Please view the draft TDS for baghouses guidance document for more information and contact Trinity Consultants at (916) 444-6666 with any questions.