Chemical Engineering October 2015 - 58

TABLE 2. ELEmEnTs of An idEALizEd fugiTivE Emissions REguLAToRy PLAn
1. Define the hazardous air pollutants (HAPs) to be regulated
2 Define the different types of equipment and connecting devices with the potential to leak to be
regulated
.
3. Specify methods to qualify equipment performance
Define leak levels for what is considered tight for each equipment type
Define method(s) of measuring leaks for this qualification
Require performance to be checked after initial installation
a.
b.
c.
d.
Develop a lexicon of recommended practices and equipment designs to guide users to the best
available technology
4. Define maintenance programs
a.
b.
c.
a.
Codify practices for equipment installation and maintenance
Audit to assure compliance practices are followed
Require reporting
5. Define air-pollution monitoring methods; a combination of available types can be used to assure protection
of the environment and near and remote populations. Combinations of the following could be used:
Discreet monitors
i.
ii.
b.
c.
d.
lyzers (TVA). This is the USA Method 21 approach
Discreet sensors mounted at each potential leak point of interest
Mobile IR monitoring (technicians, motor vehicles, aircraft)
i.
These could be accessed wirelessly or by wire for continuous or periodic monitoring
FLIR camera allowed by the EPA Alternative Work Practice to Method 21
1.
Stationary fence-line monitoring using IR, ultraviolet (UV), specialized laser optics
i.
environmental regions
i.
a.
Used extensively in E.U., Singapore and Thailand
6. Repair procedure code
Assure that problems found are fixed correctly and in a timely manner
7. Documentation
a.
ii.
iii.
iv.
v.
vi.
8. Enforcement
a.
b.
c.
d.
All of the above
i.
Regulated HAPs at the site
Inventory of regulated equipment
Equipment qualification certification
Maintenance program
Monitoring methods and data
Repair records
Assignment of an entity that answers to the general public and government authorities, not plant
owners
Enforcers would be allowed to audit and levy fines within a defined schedule and initiate prosecution
to bring the plant site into compliance
All enforcement actions would be published and made available to the general public and media
outlets
Private citizens would have a voice in reporting suspected pollution events
ment is weak and at the discretion of
regional authorities.
Singapore. Singapore requires monitoring
by qualified providers. like
thailand and Japan, performance is
assessed from atmospheric air monitoring
at specific locations. Sites are
encouraged to use best available
technologies (Bat), and a central
authority can inspect and demand
compliance if levels are beyond allowable
limits.
Saudi Arabia. the Kingdom of
Saudi arabia manages air pollution
by measuring air quality, and enforcement
is at the discretion of a
designated agency.
58
Taiwan. taiwan has a central enforcement
authority and regulations
defining the use of Bat. it embraces
technology to electronically report airmonitoring
data and uses computer
simulations to model air quality.
European Union. in the e.U., best
available control technology (BaCt),
flexibility and public participation are
foundational. Sites apply for permits
to emit, which are subject to authorities'
discretion, taking into account
the site's performance record, location
and local environment. equipment
must be qualified before use.
Collaboration in defining and
sharing BaCt and best practices
U.S. EPA has ordered the installation of such systems at various plant sites to develop and
validate the efficacy of the leak control technology
Ambient-air monitoring stations near population centers, schools and fragile or highly valued
is ingrained in e.U. policy directives
and is a hallmark of its basic
approach to pollution control. it
is an integrated approach that is
flexible with regard to application
and enforcement, inspections and
public participation. Bat and best
practices are developed by expert
representatives from e.U. member
countries, affected industries and
non-governmental organizations.
Flame ionization detectors (FID) or optical photo-ionization detectors (PID) toxic vapor anaLearning
from world regulations
table 1 summarizes the following
policies and practices: atmospheric
monitoring at significant locations
in regions of low and high industrial
pollution; citizens engagement; traditional
media and social media as
auxiliary enforcement; negative motivation
for regulatory compliance; reporting
to a central authority; use of
BaCt; and organization of non-governmental
experts to define, develop
and maintain BaCt and inferred
regulatory requirements that lead to
desired behavior.
For example, a site may be required
to report the amount of pollutants it
is emitting without specifically having
to monitor and quantify the sources
of emissions. implicit in the reporting
rule is some degree of monitoring
and measurement. other practices
of note include using the latest in the
acquisition and transmission of data
to responsible authorities and permitting
institutions.
Permitting takes a variety of forms.
ambient pollution data will lead enforcers
to impose emission limits
on regional polluters, but enforcers
defer to the polluters with regard to
the technologies needed to meet
these limits. a plant site can apply to
the responsible authority for permission
to emit a given amount of pollutant,
which can be accepted, rejected
or negotiated to an acceptable level.
the system of permits forces transparency
on the part of both polluters
and enforcers; polluters must publish
what they emit, and enforcers' expectations
are transparent by agreeing
to a level of performance.
Idealized emissions regulation
looking at what has already been
done, the basic elements of a fugiChemiCal
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