Bag leak detectors (BLDs) are either a requirement or an option for compliance for companies who have to comply with many of the MACT Rules, including the hazardous waste combustor (HWC) MACT. These devices are not the same as other process monitoring parameters such as flow rates, temperatures and amp loadings. They have their own periodic QA checks and the data logging and reporting is completely different than other parameteric monitoring. Once their requirements are understood, many people, in industry and at regulatory agencies, think BLDs are one of the biggest win-win situations for all parties to come along in a long time. BLDs are filter maintenance monitors or filter performance monitors. Their purpose is to monitor a filter and provide feed-back on the performance of the filter and/or alarm when a leak occurs. They are not emission monitors. For the very reason of what they are, and are not, they fall into a category all their own. The QA/QC checks are simple and straight forward but are not what we are used to. The data recording and reporting for BLDs is even simpler. The reporting is based on event exception and not on long term recorded data (minute averages, hour average, etc.). This paper will identify the source of these requirements, based on the current documentation and B3 Systems interpretation. The paper will also provide a summary that users can compare against any existing or future programs.
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