Chemical Engineering October 2015 - 57

gitive emissions plan. Six general
concepts to assure a balanced approach
are discussed, including:
clear regulatory objectives; equipment
qualification; preventive and
sustaining maintenance; documentation
useful to meeting objectives;
use of best available control technology;
and a three-pronged approach
to leak detection.
Regulatory overview in U.S.
in the 1990s, the U.S. environmental
Protection agency (ePa) concluded
that ldaR programs at petroleum
refineries existed in name only, or
were minimally managed and implemented.
as a result, the ePa
mounted a full enforcement effort,
and by 2010 petroleum refineries
under consent decrees far outnumbered
those that were not. the mandate
evolved from compliance with
the regulations for leak detection and
repair to leak prevention today. Regulators
now want chemical process
industries (CPi) plants to use the best
available low-emission technologies
to stop leaks from occurring in the
first place. this approach is termed,
" enhanced ldaR. " although not
formally part of U.S. regulations, it
is mandated via consent decrees
whenever the ePa finds deficiencies
in ldaR programs.
in the U.S., leaks are monitored
using flame or photo-ionization detection
equipment and quantified in
parts per million by volume (ppmv).
this measure is the concentration of
a volatile organic compound (voC)
categorized as a hazardous air pollutant
(HaP) at the point of the equipment
being monitored. these data
are put into equations that approximate
the rate of mass loss in pounds
or kilograms per hour [6]. the method
of gathering leak data as ppmv in the
field is given in method 21 [7].
in december 2008, another
method of monitoring leaks was
allowed - the " alternative work
Practice to detect leaks from
equipment " (awP) [8] uses forwardlooking
infrared (FliR) instruments
resembling handheld video cameras.
Specialized infrared (iR) sources are
tuned to make hydrocarbon gases
visible. this monitoring method inFugitive-emission
control
technology
TABLE 1. Emissions REguLATions of sELEcTEd counTRiEs
Country
Thailand
Motivation to control fugitive emissions
* Corporate social responsibility, media and
public pressure
* Future regulations will impose more
formal rules
India
People's Republic
of China
None specified. Plant sites are expected
to use best practices
Singapore
Kingdom of
Saudi Arabia
Taiwan
Uses accepted technical practices
Best available control techniques are
published and expected to be used
LDAR programs are minutely defined
and regulated. Low emission packing
and valves and their performance
requirements are specified
Japan
E.U.
U.S.
* Access to bank guarantees
* Citizen complaints leading to litigation
* Financial penalties, risk of shut down,
media and citizen pressure
* Unique law objective: recognition of environment
and economic needs
* Corporate social responsibility, media and
public pressure
* Risk of shut-down of operations
* Violators face fines or imprisonment
* Prosecution by government agencies
and suspension of operations
* Corporate social responsibility, media and
public pressure
* Action by local authorities, media and
citizen pressure
* Fines and prosecution leading to
consent decrees requiring special
projects, equipment installation, extra
rules and fines
dicates only the presence of a leak,
but not the quantity. it is commonly
accepted that FliR-type devices
can detect leaks of 5,000 to 10,000
ppmv and above.
the U.S. is notorious for rigorous,
detailed regulations. the administering
agency, the ePa, has fostered a
culture of doing only what is necessary
to comply, no more or less. in
recent years, enforcers have promoted
prevention via the latest technology,
expressed as " next generation
Compliance " [9].
a december 2012 workshop [10]
attended by regulators, policy makers
and environmental law academics
presented ways to more effectively
enforce existing regulations
via technology, increased citizen
involvement, traditional and social
media, more efficient rules and increased
transparency.
Worldwide regulations
a survey of selected, industrialized
regions of the world provides insight
into different ways of mitigating and
minimizing air pollution.
Thailand. thailand, for example,
extensively monitors ambient air
in areas of concentrated industrial
activity, such as Rayong Province.
ChemiCal engineering www.Chemengonline.Com oCtober 2015
while there is no strong central enforcement
authority, social pressure
motivates polluters to comply.
Japan. Japan has a similar approach,
but with stronger enforcement.
the country assigns maximum
emission levels to each site
based on atmospheric air monitoring.
each site is responsible for
self-monitoring and using the best
technologies to limit emissions.
Corporate responsibility motivates
plant sites to do the right thing, and
media attention and popular indignation
are effective motivators.
India. in india, plant sites are motivated
by high litigation costs and
financial sanctions, which take the
form of limiting or denying access to
bank loan guarantees and subsidies.
while monitoring is not mandated, it
must be done as a consequence of
the requirement to report each year's
emission quantities.
China. China has a tradition of citizen
action via a system of letters and
visits for making complaints about
polluters. Chinese pollution laws
seek to balance environmental protection,
public health and economic
development. in other countries this
concept is understood in practice,
but not codified. at present, enforce57
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