Chemical Engineering March 2014 - 62

Environmental Manager
United States. The U.S. provides
the most stringent regulatory environment,
in terms of the required
standards and enforcement activities.
For instance, the emission
levels of certain individual components
may not exceed 100, 250 or
500 ppm, depending upon location
or special plant site regulations.
Monitoring is conducted using organic
vapor analyzers (Method 21)
or forward-looking infrared (FLIR)
cameras. U.S. regulations also dictate
repair requirements and reporting
requirements to local, state
and federal agencies.
EPA may impose Enhanced Leak
Detection and Repair (LDAR) requirements
on plants that are not carrying
out the normal LDAR requirements
properly. These requirements can
involve equipment upgrades or replacement.
Among the requirements
are use of low-leak valves and packing
technology - the latter being a
regulatory first. Also required are
written guarantees that the valve
will not leak above 100 ppm for five
years, or test reports indicating that
leak performance not exceeding
100 ppm is attainable for at least
five years.
A 2013 article by Cynthia Giles
[4], EPA Assistant Administrator
for Enforcement and Compliance
Assurance, promotes the use of current
and new technologies to motivate
compliance and optimize enforcement:
" We
are moving toward a world
References
1. Drago, J., Air Pollution Rules - World and
USA Leak Detection and Repair, AchemAsia
2013, Beijing, China, May 14, 2013.
2. Yang, T., Comparative Overview of China's
Environmental Complaint System and
the U.S. Citizen Suit System and Lessons,
" China Environmental Yearbook, " 1993-
2010.
3. Stanway, D., To Tackle Pollution, China
to Steer Local Governments Away from
Growth at All Costs, Beijing-Reuters, Published
November 18 2013 (Accessed at:
http://www.reuters.com/article/2013/11/18/
us-china-reform-environment-idUSBRE9
AH07M20131118).
4. Giles, C., Next Generation Compliance, The
Environmental Forum, September-October
2013.
in which states, EPA, citizens and
industry will have real-time electronic
information regarding environmental
conditions, emissions
and compliance, and we are using
what we have learned about compliance
to make it easier to comply
than to violate. "
Looking forward
What does the future hold? The
U.S. is increasingly becoming a
model for other countries' regulatory
frameworks. Contributing
to this trend is the fact that U.S.
multi-national companies tend to
abide by U.S. standards as part
of corporate policy, regardless of
the countries where they operate
(demonstrating that it is possible
to operate a plant competitively
and act responsibly toward the
environment). There is also growing
realization among developing nations,
such as China, that economic
development and environmental
protection can no longer be mutually
exclusive, but must be balanced
for the long-term sustainability of
both. In the final analysis, morestringent
regulations and stricter
enforcement alone cannot improve
air quality. These actions must be
accompanied by a heightened sense
of corporate responsibility on the
part of polluters and a commitment
to do the right thing to benefit their
own community, nation and ultimately
the world.
■
Edited by Suzanne Shelley
Author
Jim Drago has worked in
sealing technology for over 30
years, and is currently a principal
applications engineer
for Garlock Sealing Technologies
(Phone: 800-448-6688;
Email: jim.drago@garlock.
com). He is a licensed professional
engineer in the state of
New York. Drago's work has
focused on applications, product
engineering, engineering
management and global business development.
He has authored numerous articles and presented
papers at technical symposia on sealing to
meet fugitive emissions regulations and sealing
product selection. He also has contributed to the
industry standards of the American Petroleum
Institute (API), American Society of Mechanical
Engineers (ASME), Electric Power Research
Institute (EPRI), and Society of Tribologists and
Lubrication Engineers (STLE). Drago is a former
member of ASME BPE Standard committees on
sealing and polymers.
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