CSB Nine Years Later, Still No Dust Regulation – Urges OSHA To Finalize Combustible Dust Safety Standard

, , ,
A factory that has been destroyed by a Dust Explosion

Nine years after the first of a series of deadly combustible dust explosions in the U.S., the CSB (Chemical Safety Board) is imploring OSHA to take decisive action and finalize its court-ordered Combustible Dust Standard. Investments in plant dust collection systems will be vital to meeting the new proposed standards.

April 4, 2012 – Baghouse.com News | Fed. 20, 2003, CTA Acoustics plant in Corbin, Ky, 7 dead; Feb. 7, 2008 Imperial Sugar Refinery in Port Wentworth, Ga, 14 dead, 38 injured; various dates in 2011, Hoeganaes powdered iron metal manufacturing plant in Gallatin, Tn, 5 dead in 3 separate incidents in 5 months. These are just a few of the deadly industrial dust explosions to occur in the U.S. over the last decade. In each of these incidents, the lives of these workers were tragically cut short by the seemingly-innocuous dusts present in the facilities.

The Chairperson of the U.S. Chemical Safety Board (CSB) Rafael Moure-Eraso, in a recent article has called attention to the fact that despite several deadly incidents occurring in the nine years since the CTA explosions, OSHA still has yet to follow through with its pledge to issue a comprehensive combustible dust safety standard for general industry.

Chairperson Moure-Eraso  relates the progression of events that lead to the CSB calling for OSHA to implement a comprehensive standard for combustible dust.  “The safety board launched a study into the hazards of combustible dust. Our 2006 report revealed there is no national regulation that adequately addresses combustible dust explosion hazards in general industry. Although many states and localities have adopted fire codes that have provisions related to combustible dust, a CSB survey found that fire code officials rarely inspect industrial facilities to enforce the codes. The board clearly stated that American industry needs a comprehensive federal combustible dust regulation.”

While the explosion at the CTA Acoustics plant in Corbin, Ky did lead the CSB to issue a number of recommendations to both plant management, local and state regulators, it was not until the 2008 Imperial Sugar Refinery explosion in Port Wentworth, Ga, that left 14 dead and 38 injured, that the CSB made its recommendation to OSHA to issue a “comprehensive combustible dust standard for general industry”.

The CSB is an independent governmental agency charged with investigating industrial chemical accidents. And while they do have limited authority to investigate and issue recommendations, they do not have the power to enforce safety regulations.

Despite its repeated recommendations to OSHA for the urgent need for hazardous dust standards, he relents: “ Yet, nine years after the CTA catastrophe, and more than five years after our recommendation to OSHA, there is still no comprehensive OSHA standard to prevent these accidents.”

After the CSB’s recommendations, OSHA in April, 2009 announced that it planned on issuing a comprehensive dust standard for general industry. However, its recent 2012 agenda does not include any specific mention of goals or targets for the development of the standard during the course of this year.

Will There Ever Be a Comprehensive Combustible Dust Safety Standard?

While the U.S. is still struggling to prevent these kinds of incidents from occurring, the rest of the world is not immune from them either. In fact, major manufacturers such as China, which often lack extensive safety regulations, are even more prone to experience these kinds of incidents. According to recent reports, last year saw two electronics manufacturers in China that produce parts for Apple Computer products experienced dust explosions when fine particles of aluminum ignited, killing four workers and injuring dozens of others. Apple’s Supplier Responsibility documents state that the company is now requiring improved ventilation, inspections and cleaning methods for dust deposits.

Without a standard that comprehensively addresses the hazards of combustible dust, American workers will continue to be put at risk for future catastrophic explosions and fires.

“I don’t know what steps China is taking to prevent its dust explosions, but I do know what can be done here in the U.S. It’s time for OSHA to move on a comprehensive regulation to adequately address combustible dust hazards” – stated CSB Chairperson Moure-Eraso.

What Does This Mean For U.S. Manufacturers?

While the current status of combustible dust regulation is not fixed on a federal level, (i.e. OSHA) the dangers of combustible dust still present a clear and present danger to both the financial interests of U.S. manufacturers and the lives of U.S. workers.

As a result of the long history of combustible dust explosions in the U.S. many state and municipal fire codes and other regulatory agencies already have combustible dust regulations for most industries.  In addition, many insurance providers are requiring plants as part of regular safety audits to improve dust hazard protection in their facilities as a condition of maintaining their coverage.

dust collection systems

Maintaining a sufficiently-sized dust collection system is vital to prevent combustible dust explosions.

The first step to preventing these incidents is recognizing the dangers combustible dusts present in an industrial setting. Measures to control or mediate combustible dust hazards include maintaining a adequate dust collection system (i.e. a baghouse), good house-keeping practices and good facility design.

A main contributing factor in all of the above mentioned incidents was an improperly operated or maintained dust collection system. From inefficient collection pickup points, to bucket elevators that were not properly cleaned and sealed, to conveyor systems that were overloaded to baghouses of insufficient size and fire protection. A relatively minor investment in a facility’s dust collection system, such as changing to a sufficiently sized collector (i.e. larger CFM, larger baghouse with more dust collector bags) or additional baghouses will prevent the kind of massive capital loss and loss of life seen in these past incidents.

While governmental regulation will not ensure that these tragic incidents are the last of their kind, it is hoped that along with increase corporate awareness and ever-improving dust collection technology, these incidents will become rarer and rarer. Saving not only billions of dollars for companies, but safeguarding millions of workers in these industries.

Dominick DalSanto is an Author & Environmental Technologies Expert, specializing in Dust Collection Systems. With nearly a decade of hands-on working experience in the industry, Dominick’s knowledge of the industry goes beyond a mere classroom education. He is currently serving as Online Marketing Director & Content Manager at Baghouse.com. His articles have been published not only on Baghouse.com , but also on other industry related blogs and sites. In his spare time, Dominick writes about travel and life abroad for various travel sites and blogs.

/by

EPA Issues Revised Boiler & Incinerator Rules After Extensive Public Input

,

The EPA has issued proposed revisions to emissions standards for boilers and solid waste incinerators. These new rules once finalized will lead to increased demand for dust collection systems throughout industry. 

December 23, 2011 Baghouse.com News – The Environmental Protection Agency proposed several revisions to its emissions standards for boilers and solid waste incinerators. The EPA rules set emissions limits for several different hazardous air pollutants, including mercury, particulate matter 2.5 (PM2.5) dioxins, cadmium, nitrogen dioxide and lead among others.

The rules, The Air Toxics Standards For Industrial Commercial and Institutional Boilers (Major and Source Facilities) and New Source Performance Standards (NSPS) and Emissions Guidelines (EG) for Commercial and Industrial Solid Waste Incinerators (CISWI), were originally proposed back in March 2011. The reason for the revisions according to the EPA was to address concerns raised by the public, and owners/operators during the public comment period. According to the EPA the proposed changes will still result in significant reductions in most pollutants, and even larger reductions in some, while limiting the financial burden from implementation as much as possible.

Boiler RegulationsThe revised rules will require only a small percentage of the total boilers in the U.S. to install pollution control equipment such as dust collection systems. The vast majority (86%) of boilers will not be covered by the rules at all, others (13%) will only be required to perform regular maintenance, and tune-ups to stay in compliance (also termed “workplace practices”). The remaining less than 1% of boilers are responsible for the vast majority of air pollution in this sector. They are mainly found in chemical processing, oil refineries, and other heavy industries. By retooling the rules to focus only on the largest emitters, the EPA hopes to improve flexibility in reaching compliance for smaller institutions.

The new regulations will result in over 8,100 premature deaths, 5,100 heart attacks, and 52,000 asthma attacks being avoided each year starting by 2015. The EPA estimates that for every $1 spent complying with these new regulations, the public will see $12 to $30 in health benefits. These results will be realized by reducing emission levels of compounds like mercury and lead, which are proven to cause developmental problems in young children and nervous system damage in adults and children, as well as by reducing particulate matter i.e. dust pollution, which is a severe asthma aggravator.

Existing major source boilers will have three years to come into compliance with the new regulations, with an additional year if needed technologies cannot be installed by then. CISWI units will have five years to comply.

The estimated annualized cost of the rule, as amended based on the reconsideration proposal, would be $1.49 billion, compared with $1.40 billion for the final rule. The estimated annualized cost would increase by about $90 million due to the addition of approximately 300 affected units to the revised inventory of units. This is the case even with a decrease in the stringency of some emission limits and less stringent PM control requirements for biomass units in the proposal.

Different Regulations For “Area Source” and “Major Source” Boilers

Major and Area Source Boilers RegulationsBoilers which only produce small amounts of air pollution are classified as “area source” boilers, and are mainly found in places like churches, hospitals, and commercial buildings. The majority of these burn natural gas (1.3 million), as such they are not covered by this rule. The remaining 187,000 area source burners that do not use natural gas would be covered by the new rules, of these only approximately 2% would have emissions limits, the other 98% would only need to follow workplace practices to stay in compliance.

Boilers that create large amounts of air pollution are classified as “major source” boilers. Of these approximately 14,00 boilers, most of which are found at heavy industrial sites such as refineries, and chemical processing plants, an estimated 88% (about 12,300) would only need to follow best work place practices, while the remaining 12% (about 1,750) will be required to reduce emissions, as well as increased monitoring, and record keeping.

Revisions Based On Public Comments

After allowing several months for public and industry comments regarding the original proposal, the EPA has included several of these suggestions into its revised proposal. Many of these are in response to claims that the original proposal was to restrictive in requiring the same standards across many different types of boilers in many different locations, applications, and that use different fuel sources. Among the proposed changes to make compliance easier, and fairer are the following:

Major Source Boilers:

  • Subcategories for different types of light and heavy liquid fuels
    • To reflect the real world differences in operating standards and requirements between the fuels
  • Different limits for PM 2.5 for different fuels
    • Different limits for boilers using biomass, coal, etc.
  • Revised limits for carbon monoxide
    • Subsequent studies have been provided that show that CO emissions vary greatly between boilers, and one universal limit is not practical
  • Allow for a alternative total selective metals emissions limit for select air toxics
    • To ease compliance costs, and improve flexibility
  • Remove dioxin limits and replace with work place practice requirements
    • Based on subsequent analysis showing dioxin levels in boilers are often well below accurately detectible levels
  • Increased flexibility in compliance monitoring requirements
    • Allow for monitoring from stack or continuous monitoring, and remove continuous monitoring requirement for biomass boilers
  • Remove emissions limits for units outside continental United States
    • To deal with unique operating circumstances and requirements for these units
  • Allow “clean gas” boilers to continue to be exempt from new standards
    • To improve flexibility and ease of compliance

Area Source Boilers:

  • Alter Initial tuneup schedule
    • Change compliance timeframe to two years, instead of one, create new categories of boilers and increase overall flexibility in compliance requirements
  • Alter tuneup schedule/requirements for seasonal units
    • Change from every other year to every five years for these infrequently employed units

Revisions To Commercial and Industrial Solid Waste Incinerators (CISWI) Standards

A CISWI unit is any device that is used to burn solid waste at a commercial or industrial facility. Examples of CISWI units include incinirators used to burn solid waste (i.e. garbage), energy recovery units designed to recover heat that combust solid waste; and kilns designed to manufacture products and also combust solid waste.

The revised CISWI standards provide for stricter emissions limits on nine major air pollutants regulated by the EPA (mercury, PM 2.5, lead, etc.). In addition, the new standards provide for new definitions of what exactly qualifies as solid waste, hazardous waste, etc. Many of the revisions for the new standards requested increased clarification in these areas. The subsequently revised standards have increased clarification on what materials are categorized as, allow for certain “non-hazardous secondary materials” to not be classified as solid waste when used as a fuel (e.g. certain wood products that are used as part of biomass fuel sources) and allow for plant operators to request the EPA to clarify, and reclassify certain materials based on site specific considerations.

The EPA estimates that, for some units, it would be more cost-effective to use an alternative disposal option. If those units use alternative disposal options, and the remainder use add-on controls, the total nationwide cost would be approximately $270 million. If all 95 CISWI units currently in operation use add-on controls, the total nationwide cost for complying with the rule, as amended, would be approximately $284 million per year.

What This Means For The Future

The EPA believes these newly revised standards will provide both added health benefits, and environmental protection while still not creating an unbearable burden for operators. “With this action, EPA is applying the right standards to the right boilers,” said Gina McCarthy, assistant administrator for EPA’s Office of Air and Radiation. “Gathering the latest and best real-world information is leading to practical, affordable air pollution safeguards that will provide the vital and overdue health protection that Americans deserve.”

WIth these new standards set to take effect in the near future, dust collection systems, baghouses, baghouse filters, etc. will be in high demand as many existing plants require extensive upgrades in order to reach compliance. In addition to these standards, the EPA’s newly issued mercury rule will also in many technologies (such as activated carbon injection) require upgrades to existing dust collection systems, or at minimum investments in more efficient baghouse filters or system tuneups.

 

 
About the Author

| Dominick DalSanto is an Author & Environmental Technologies Expert, specializing in Dust Collection Systems. With nearly a decade of hands-on working experience in the industry, Dominick’s knowledge of the industry goes beyond a mere classroom education. He is currently serving as Online Marketing Director & Content Manager at Baghouse.com. His articles have been published not only on Baghouse.com , but also on other industry related blogs and sites. In his spare time, Dominick writes about travel and life abroad for various travel sites and blogs.

/by

California Recycling Plant Fined Millions For Lacking Baghouse

, ,

October 17, 2011, Baghouse.com News – A California recycling company has been accessed millions in fines by the EPA for failing to install and maintain baghouses at several of its plants. SA Recycling LLC was primarily fined for failure to repair/reinstall a baghouse dust collector at its Terminal Island, California, plant after a dust explosion there destroyed the original collector in 2007. The company continued to operate the facility, which includes industrial smelters used to recycle metals such as steel, aluminum, and lead from junkyard cars,  without a baghouse after the 2007 explosion.

Upon further investigation, the EPA ordered the company to install additional baghouses and other air pollution controls at several of its locations throughout California. All together the settlement will cost the company over $3 million, $2.9 million to upgrade the various facilities, and over $690,000 for fines and other costs.

For more information, see the article here: http://eponline.com/Blogs/Environmental-Protection-Blog/2011/10/Air-Pollution-Control-Technology-or-EPA-Fines-You-Decide.aspx

 

 

About the Author

| Dominick DalSanto is an Author & Environmental Technologies Expert, specializing in Dust Collection Systems. With nearly a decade of hands-on working experience in the industry, Dominick’s knowledge of the industry goes beyond a mere classroom education. He is currently serving as Online Marketing Director & Content Manager at Baghouse.com. His articles have been published not only on Baghouse.com , but also on other industry related blogs and sites. In his spare time, Dominick writes about travel and life abroad for various travel sites and blogs.

/by

EPA Admits Error In Mercury Rule

,

Golden Stack Testing Nuggets: The EPA Admits Error in Proposed Mercury MACT Rule. Calculation used to determine emissions limits for mercury and other toxic air substances was off by nearly 1,000. 

Here is an interesting article about the EPA’s new mercury standards from our good friend Ron McCulloch the “blue collar MBA” with Golden Specialty Inc. Ron and his firm are among the most trusted names in stack testing services in the nation.

This posts comments on a recently discovered error in the EPA Mercury MACT rule. After initially being discovered by the non-profit trade organization Utility Air Regulation Group (UARG), the EPA has finally admitted the there was indeed an error in the way they calculated the limits for the MACT (maximum achievable control technology) floor for both the mercury and air toxics standards (MATS) rules.

An EPA official admitted that the error was indeed present. But she claimed that it had not had a substantial effect on the final rule. She further stated that the EPA had corrected the mistake and apologized for the error.

The error deals with the formula used for converting measurements reported in terms of lb/GWh to lb/MWh is “incorrect by a factor of 1,000” claims the UARG.

 

About the Author

| Dominick DalSanto is an Author & Environmental Technologies Expert, specializing in Dust Collection Systems. With nearly a decade of hands-on working experience in the industry, Dominick’s knowledge of the industry goes beyond a mere classroom education. He is currently serving as Online Marketing Director & Content Manager at Baghouse.com. His articles have been published not only on Baghouse.com , but also on other industry related blogs and sites. In his spare time, Dominick writes about travel and life abroad for various travel sites and blogs.

/by

Industrial Air Permits & Your Dust Collection System – Unfair & Confusing Enforcement

,

Confusing regulations, conflicting methods of application, and unpredictable enforcement of industrial emissions regulations often leave many companies scratching their heads at what they did wrong. This article is part of a series about industrial air permits and their relationship with your dust collection system. See earlier article: Industrial Air Permits – Overcoming the Difficulties

(Baghouse.com – September 10th, 2011) – Governmental environmental regulations are often praised for the role they play in helping to keep our planet clean, and protecting us from hazardous by-products of our modern industrialized world. However, as these regulatory bodies increase in size, and influence, many claim that they have become inefficient, bogged down due to their overly bureaucratic organization, and even as “corrupt” as the big business polluters they are charged with protecting the public against.

We can see this in a recent article from Ethanol Producers Magazine; the article highlights the plight of a group of ethanol plant operators, and their constant struggles to understand and comply with needlessly complex environmental regulations, and permits issues by state and federal agencies. The article explains how sometimes permitting agencies require certain standards to be met in their permit proposals, that do not have any regulation behind them. These unnecessary requirements are simply confusing are not are not fair and are the result of over-regulating, states Jessica Karras-Bailey, an associate with RTP Environmental Associates Inc.

While certain states may have stricter emissions standards that others, in general the problem lies with permit issuing agencies, and officials going above and beyond what is required by federal and state legislation. In one cited example, an ethanol plant permit proposal would have required truck with grain shipments to follow a specific pattern within the site (taking a right turn, drive in a counterclockwise direction, and then leave by taking a left turn). Failure to enact this provision would have left the plant in non-compliance with the permit, leading to heavy fines and possibly forced closures. Provisions such as this obviously left management confused, wondering why such a requirement was mandated by existing regulations, as well as how they could possibly implement such a thing in a practical way.

Instances such as this highlight the almost “Mystic Elements” that these permits can sometimes require of plant operators. Often times companies are simply at a loss, not knowing what action to take, all the while fearing the repercussions that might come from not complying with these regulations.

In the instance cited above, the plant management turned to a consulting firm that specializes in helping facilities come into compliance with pollution control regulations, and with negotiating with permitting agencies. They were able to learn why the state’s permitting officials had placed this peculiar requirement in the permit (air dispersion modeling reasons). After that, the firm was able to negotiate with the agency, explaining that from a practical standpoint, it simply was not possible, and find a more flexible solution that was acceptable to both parties. “But it’s not always easy,” stated the consultant, and we tend to agree with that conclusion.

Air Permitting Compliance Help & Advice

Ordering baghouse replacement parts can be quite complicated

Do governmental pollution regulations have you feeling like this at times? EPA clean air regulations (NAAQS, NESHAP, etc…) for particulate matter (PM2.5), mercury, and other VOCs can be easily met by operating a proper dust collection system at your facility.

In researching this article, Baghouse.com contacted several consulting firms that specialize in helping facilities with the environmental permitting process, and advise them on ways to bring their sites into compliance with said regulations. We managed to speak with Brian Burdorf at Trinity Consultants, Inc. based in Dallas, Tx. about some of the more common issues that companies encounter during the permitting process, and what actions these firms can take to ensure compliance. We asked for some specific standards that among the hardest for companies to meet, and which ones can be affected by dust collection system performance the most.

Burdorf, mentioned that most difficult sections of current U.S. clean air regulations for companies to come into compliance with are the National Ambient Air Quality Standards (NAAQS), and associated U.S. EPA dispersion modeling requirements for demonstrating compliance with nitrogen dioxide (NO2), sulfur dioxide (SO2), and fine particulate matter (PM2.5). In addition, with regards to dust collection systems, he adds that the National Emission Standards for Hazardous Air Pollutants (NESHAP), Maximum Achievable Control Technologies (MACT), and New Source Performance Standards (NSPS)for industrial-commercial-institutional steam generators (boilers), electric utility steam generating units (utilities), portland cement manufacturing, and similar industrial processes are particularly challenging for companies to meet.

Theses standards, many of which have been updated, or otherwise expanded in recent years, require higher emissions standards that are increasingly complex, and difficult to achieve with existing or antiquated dust collection systems.

What Can You Do to Ensure Your Dust Collection System Reaches Compliance?

The role of dust collection systems in controlling pollution is growing more vital with each passing year. With tougher limits being proposed/adopted by regulatory bodies for particulate matter within the NAAQS, NESHAP, MACT, and NSPS, many formerly compliant sites are being forced to upgrade their existing systems, or install completely new equipment (such as replacing ESPs with Baghouse technology). With so many industries being affected by these rules, naturally the rules are complex, and often apply differently to different industries, and require different tactics for different industries and processes to reach compliance.

If you are confused and intimidated by the seemingly insurmountable challenge presented by the air permitting process for your facility, fear not for you have several options available to help you overcome these challenges. This topic will be covered in of our next article in this series here on Baghouse.com. We will discuss which exact regulations apply for different industries, what part certain technologies (Baghouse, filters, mercury capture systems etc.) will play in meeting the standards of tomorrow, and how you can plan to meet these standards not only for the present, but also for the future as well. If you have any specific questions that cannot wait until then, feel free to contact us here at Baghouse.com for assistance and we will be glad to help.

 

[author] [author_image timthumb=’on’]https://www.baghouse.com/wp-content/uploads/2011/08/DSC042141.jpg[/author_image] [author_info]

Dominick DalSanto is an Author & Environmental Technologies Expert, specializing in Dust Collection Systems. With nearly a decade of hands-on working experience in the industry, Dominick’s knowledge of the industry goes beyond a mere classroom education. He is currently serving as Online Marketing Director & Content Manager at Baghouse.com. His articles have been published not only on Baghouse.com , but also on other industry related blogs and sites. In his spare time, Dominick writes about travel and life abroad for various travel sites and blogs.

[/author_info] [/author]
References:

http://www.ethanolproducer.com/articles/7566/permitting-a-big-ticket-item

/by

Obama Orders EPA to Scrap Proposed Ozone Regulations Due to Economy

,

September 2nd, 2011 | Baghouse.com – Bowing to pressure from all directions, President Obama announced Friday that he was ordering the EPA (Environmental Protection Agency) to scrap plans to tighten the federal clean air regulations regarding ozone and smog. The controversial proposal has long been singled out as an unnecessary “job killer” by opposition republican law makers, and a wide range of industry groups.

In the prepared statement issued on Friday after a federal report on private sector employment show virtually no growth for August. The President said that after considering the the burdens that governmental regulations place on business, he had decided to withdraw the proposed new ozone limits. “At the same time, I have continued to underscore the importance of reducing regulatory burdens and regulatory uncertainty, particularly as our economy continues to recover. With that in mind, and after careful consideration, I have requested that Administrator Jackson withdraw the draft Ozone National Ambient Air Quality Standards at this time. Work is already underway to update a 2006 review of the science that will result in the reconsideration of the ozone standard in 2013. Ultimately, I did not support asking state and local governments to begin implementing a new standard that will soon be reconsidered,” Obama said.

Environmental Protection Agency

The EPA’s proposed tighter ground-level ozone standards were deemed to burdensome by Pres. Obama and overruled.

The proposed new standards would have lower the the acceptable amount of ground-level ozone in the National Ambient Air Quality Standards (NAAQS) from the current 75 ppb (parts per billion) to between 60 – 70 ppb. The new standards were projected to have cost between $19 billion to $90 billion in compliance costs depending how strict the amendments would be.

The announcement was applauded by many who stood in opposition to the proposed changes. “The president’s decision is good news for the economy and Americans looking for work. EPA’s proposal would have prevented the very job creation that President Obama has identified as his top priority,” said Jack Gerard, president and CEO of the American Petroleum Institute. National Association of Manufacturers President and CEO Jay Timmons said, “Manufacturers have made it very clear that this discretionary action by the EPA to revise the ozone standard would harm the economy and threaten job creation. Today the Administration took yet another step in delaying the standard and manufacturers hope this is a sign that the Administration is hearing our concerns.”

The decision to revise the standards came after years of legal challenges to the existing levels for ozone. President Bush had previously followed the same course when he overruled EPA suggestions and set the standard to the current limit of 75 ppb, stricter than the previous levels set in 1997 but below EPA scientists recommendations to protect public health.

Despite the proposed enormous costs of implementing the new regulations, the EPA says that is worth the cost, since the ground-level ozone standard is the environmental regulation most closely linked to public health. Ozone is the main contributing ingredient to smog, which is a powerful lung irritant that cause periodic public health warnings due to its role in causing and/or aggravating asthma and other lung conditions. Supporters say this would despite huge costs to industry, create billions in savings in health care, lost productivity, and other areas.

Ground-level Ozone pollution contributes to the creation of smog, a powerful lung irritant and asthma trigger

The decision while looked upon as a cop-out by many environmentalists, does not spell doom for the regulations. Currently, the standards are set to be reviewed by the EPA in 2013. The EPA when issuing standards is bound by the Clean Air Act (the federal statute that established the EPA in 1970) to not consider the cost of implementation when formulating standards. Additionally, the American Lung Association has a pending lawsuit against the EPA over the regulations that it says are contrary to scientific findings on the matter. President Obama’s recent review of the standards was given as a solution to the lawsuit. However with those plans scrapped for now, the ALA is ready to continue their legal battle to get the regulations tightened. EPA administrator Jackson had said in July that the standard would not survive a legal challenge because it did not follow the recommendations of the agency’s scientific advisers.

However, resistance to the proposed regulations continues to run deep despite calls for its passage from health groups. “We ask the President and his Administration to abandon their current reconsideration efforts until a review is required in 2013 and to carefully consider the drastic consequences this standard will have on job growth and the struggling economy,” Timmons said.

Howard Feldman, director of regulatory and scientific affairs with the American Petroleum Institute, said in August, “A Manufacturers Alliance/MAPI study found that EPA’s ozone proposal could result in 7.3 million U.S. jobs lost by 2020 and could add $1 trillion in new regulatory costs per year between 2020 and 2030.”

“The discretionary proposed ozone regulation is not workable and would impose a severe burden on manufacturers and the entire American economy at a time when workers and businesses are really struggling,” Feldman said.

“Existing emission controls have led to significant improvements in air quality and will continue to produce cleaner air,” said Feldman. “We need to allow existing regulations to work before we consider adding new ones.”

And what does this mean for U.S. industry in general? While the administration’s decision to hold of on tightening the NAAQS for now will result in lower compliance costs in the short term, facilities should not assume this means that these standards will not return in the near future. Environmental regulation most certainly will continue to increase in the near future, and companies would be wise to invest in sufficient Air Pollution Control (APC) technology in anticipation.

 

 
About the Author

| Dominick DalSanto is an Author & Environmental Technologies Expert, specializing in Dust Collection Systems. With nearly a decade of hands-on working experience in the industry, Dominick’s knowledge of the industry goes beyond a mere classroom education. He is currently serving as Online Marketing Director & Content Manager at Baghouse.com. His articles have been published not only on Baghouse.com , but also on other industry related blogs and sites. In his spare time, Dominick writes about travel and life abroad for various travel sites and blogs.

/by

Lead Smelter Ordered By EPA to Repair Dust Collection Systems

, ,

A lead smelting facility has been ordered by the EPA to upgrade its existing pollution control technology, including its dust collection systems, and review operational procedures regarding environmental issues. 

Arecibo, Puerto Rico – A lead smelting facility in the Commonwealth of Puerto Rico has been served with an order from the U.S. Environmental Protection Agency to reduce air and water pollution caused by its operations. The Battery Recycling Company, Inc. from Arecibo, Puerto Rico, is being forced to upgrade its existing facilities’ pollution control technologies, including a dust collection system used for the collection of highly toxic lead dust.

The Battery Recycling Company, a secondary lead smelter, recycles used motor vehicle batteries and produces approximately 60 tons of lead per day.

Inspectors found fault with reporting policies, and operation and maintenance of the facilities dust collection system. After stressing that the company needs to improve its handling of the toxic substances it processes to protect  workers, their families, and the surrounding area, EPA Regional Administrator Judith A. Enck said: “The EPA legal action requires the Battery Recycling Company to improve its operations to protect people’s health and the environment. Our work is not done. EPA’s evaluation of the company’s compliance with federal environmental laws is active and ongoing.”

The plant which is regulated by both the Puerto Rico Environmental Quality Board (EQB), and the EPA, has been ordered to improve monitoring and reporting operations in addition to taking preventative actions and making operational improvements. The company was cited by the EPA and the EQB for having installed and tested new pollution control equipment on two of its furnaces in both 2007 and 2010 without notification. These points are significant because operational and physical changes occurred which increased the amount of pollution the facility generates. In addition, the inspectors found that the leak detection system in place to alert plant personnel of a of potentially devastating fugitive lead emissions was not fully operational. The inspectors also that the main rotary air lock on one of the dust collection system was not functioning at full capacity and was allowing lead dust to escape into the atmosphere.

Lead is a toxic metal that can cause damage to a child’s ability to learn and a range of health damage in adults.  Lead exposure can have serious, long-term health consequences in adults and children. Even at low levels, lead in children can cause I.Q. deficiencies, reading and learning disabilities, impaired hearing, reduced attention spans, hyperactivity and other behavior problems. Lead exposure can also cause health problems in pregnant women and harm fetuses.

The company has been ordered to ensure the proper operation of its leak detection system at all times to prevent fugitive lead dust emissions. Daily particulate readings must take place at each of the dust collection system’s Baghouses, and be recorded to ensure the facility is complying with all applicable air regulations concerning lead and other substances released into the air. Additionally, they must provide results from 2010 performance tests conducted to assess the efficiency of the facility’s pollution control systems on two of its furnaces to the EPA, and update its existing pollution control models and send these for review with the EPA.

 

 
About the Author

| Dominick DalSanto is an Author & Environmental Technologies Expert, specializing in Dust Collection Systems. With nearly a decade of hands-on working experience in the industry, Dominick’s knowledge of the industry goes beyond a mere classroom education. He is currently serving as Online Marketing Director & Content Manager at Baghouse.com. His articles have been published not only on Baghouse.com , but also on other industry related blogs and sites. In his spare time, Dominick writes about travel and life abroad for various travel sites and blogs.

/by

Lack of Baghouse Maintenance Leads to Heavy Fines For Wood Pellet Manufacturer

, ,

Athens, Maine, USA – Violations regarding the operation and maintenance of a Baghouse have led to heavy fines of over $30,000 being imposed to a wood processing plant in Athens, Maine. The fines were issued by the Maine Department of Environmental Protection.

The fines were issued to the plant for violating terms of their state air emissions permit. The plant was found to be operating its Baghouse without having replaced a number of Baghouse Filters that had been damaged/destroyed in a recent fire. The plant also was found to be exceeding limits for particulate matter emissions, due to improper

In addition to issues relating to the dust collection system, the plant also was cited for not maintaining an operational wet-scrubber, maintaining required logs of operating hours, and exceeding the limit for propane usage. They were also cited for failure to report the Baghouse fire indecent that had previously damaged the Baghouse and its filters, and that the wet-scrubber system had experienced a service outage.

The Maine Department of Environmental Protection is the state agency charged with enforcing Maine’s environmental laws.

According to the monthly enforcement report, issued in March 2011,  Maine Woods Pellets will pay the fine in monthly installments after it did not correctly operate its air pollution systems.

 
 
About the Author

| Dominick DalSanto is an Author & Environmental Technologies Expert, specializing in Dust Collection Systems. With nearly a decade of hands-on working experience in the industry, Dominick’s knowledge of the industry goes beyond a mere classroom education. He is currently serving as Online Marketing Director & Content Manager at Baghouse.com. His articles have been published not only on Baghouse.com , but also on other industry related blogs and sites. In his spare time, Dominick writes about travel and life abroad for various travel sites and blogs.

/by

Industrial Air Permits – Overcoming the Difficulties

, ,

By Dominick DalSanto
Environmental Technologies Expert & Author
Baghouse.com

In today’s world increasing public attention is being given to environmental issues. Politicians and lawmakers are following suit by making modifications to existing pollution control legislation. The general consensus is that environmental regulations are going to be getting much tougher in the near future. Even though certain political factions are vehemently opposing many of theses actions, the trend is most assuredly heading towards tighter regulation of emissions.

This is evidenced by recent actions of the EPA (Environmental Protection Agency). Recently the agency issued new regulations regarding the emission of Mercury (Hg) and other heavy metals such arsenic, chromium, and nickel, and acidic gases, including hydrogen chloride (HCl) and hydrogen fluoride (HF), as well as other kinds of particulate matter (PM).

The agency also has assorted that it has authority under the U.S. Clean Air Act to regulate Green House Gases (GHGs) that are believed to be contributing to global warming trends. This will mean that large GHG emission sources will be subject to quotas and be required to acquire emissions permits for GHG emissions. These actions are in line with the current presidential administration’s environmental policy.

These and other developments, while still in their early stages will soon result in increased difficulty obtaining and staying in compliance with air permits. A process that already many in industry describe as overly complex and easy to get lost in. Many have a hard time sorting through the seemingly endless barrage of new and updated regulations. Often only realizing they have failed to meat their requirements after an inspection has taken place, and their facility has been assessed heavy fines.

New Series of Articles Regarding Air Permitting and Compliance

These new standards are particularly applicable to dust collection systems. The new EPA regulations covering particulate matte, along with Mercury and other heavy metals, poses many challenges for plants to reach compliance. Many facilities housing outdated dust collection systems, such as Shaker designs, and use baghouse filters made from older materials that are not as efficient as newer materials such at PTFE membrane. Additionally, due to shrinking maintenance budgets many dust collection systems are in a state of disrepair and as such are operating well below optimal efficiency. These factors will can potentially lead to achieving compliance with new and updated  air permits quite difficult for facility management.

We here at Baghouse.com are now preparing a series of articles to assist facility management with these issues. The new series will present an overview of the air permitting process. It will include case studies that highlight some of the difficulties involved in obtaining, and the implementation of air permits. We will also include helpful information from several consulting firms that work with industrial clients with the permitting process; from obtaining and negotiating air permits, to obtaining and maintaining compliance with them.

Read more about how to overcome unfair and confusing enforcement by regulatory bodies of emissions permits in the next article in the series: Industrial Air Permits & Your Dust Collection System – Unfair and Confusing Enforcement

 

 
About the Author

| Dominick DalSanto is an Author & Environmental Technologies Expert, specializing in Dust Collection Systems. With nearly a decade of hands-on working experience in the industry, Dominick’s knowledge of the industry goes beyond a mere classroom education. He is currently serving as Online Marketing Director & Content Manager at Baghouse.com. His articles have been published not only on Baghouse.com , but also on other industry related blogs and sites. In his spare time, Dominick writes about travel and life abroad for various travel sites and blogs.

/by

Would We Have Clean Air Without Governmental Regulation?

, ,
U.S. Environmental Legislation has come under attack from many different groups recently

Editorial By Dominick DalSanto
Environmental Technologies Expert & Author
Baghouse.com

With recent battles on Capital Hill in Washington D.C. regarding the EPA’s (Environmental Protection Agency) increasing impact on the nation’s economy, many questions are being raised as to the effectiveness of governments having a active role in environmental affairs.

One particularly interesting, and controversial question that has been raised by some is: What would our world’s air quality be without governmental environmental regulation?

Opponents of tougher emissions regulations, and environmental regulations in general, are beginning to question whether government agencies like the EPA are really needed at all.

Conservatives Weigh in on EPA Claims

Recently a conservative think tank organization named the Heritage Foundation, released a report claiming that had the U.S. Clean Air Act never been passed by the U.S. Congress in 1970, industry itself would eventually have taken steps to correct the nation’s growing environmental problems, in part due to technological advancements, and corporate ethics.

A direct quote from the report states:

It is simply preposterous to assume that air quality would worsen unabated over the course of 30 years in the absence of a particular statute. History has proven otherwise, of course. Long before the original CAA [Clean Air Act] was enacted in 1963, industrial emissions were declining as a result of technological advances and efficiency improvements. And both factors, as well as others, will continue to drive environmental improvements regardless of regulation

The paper also claims that by 1970, emissions were already declining on their own, before the first governmental clean air legislation came into effect. This they claim proves that the EPA and similar governmental regulatory bodies similar to it, are not necessary. They claim they only hurt industry and therefore the economies of their respective nations, by requiring new technologies to be installed, and issuing fines for violations.

Additionally, the Heritage Foundation claims that the estimates found in the EPA’s report to Congress are grossly inaccurate, lack any reasonable way to verify its claims, and even admits that its statistics and figures cannot be verified.

The EPA report states that in 2010 the Clean Air Act amendments of 1990 resulted in approximately $1.3 trillion in public health and environmental benefits, for a cost of only $50 billion. That’s a value worth more than 9% of GDP, for a cost of only .4% of GDP. And that in 2020  that figure will increase to approximately $2 trillion in benefits, at a cost of $65 billion. That’s a value worth more than 14% of today’s GDP, for an expenditure of only .46%. The ratio of benefits to cost is more than 30 to 1.

 

Environmentalists Strike Back

Air Pollution Trends and rates over the course of the last hundred years

Proponents of the Clean Air Act, and similar environmental regulations, point to air pollution rates such as shown here, to prove that the CCA has succeeded in reducing air pollution since then 1970s.

In short order, dozens of environmentalist organizations, and activists have attacked the conclusions of the Heritage Foundations report. One such article from Switchboard.nrdc.org which is the staff blog of the Natural Resources Defense Council, a leading environmental activist organization, alleges that the Heritage Foundations accusations are completely baseless. They counter that the conclusions of the Heritage Foundation are contradictory in nature, and the product of the industrial sector and right-wing political agenda.

For example the Heritage Foundation article comments that it believes that the EPA estimates are incorrect because the claims made in the report allegedly can not be corroborated. The NRDC article counters that the EPA report is in fact the product of extensive peer-review, and that the Heritage Foundation article’s only source is “a report from one non peer-reviewed study by the Mackinac Center for Public Policy, a free market think tank that, according to IRS data, is funded almost exclusively by corporate and conservative foundations (e.g. oil giants ExxonMobil and the Koch brothers). When asked by Detroit’s Metro Times in 1996 on funding sources, the Center’s President Lawrence Reed said: “Our funding sources are primarily foundations … with the rest coming from corporations and individuals,” but that “… revealing our contributors would be a tremendous diversion…”

Are Emissions Regulations Really Required?

The facts are undeniable that with stricter environmental/emissions standards has come cleaner air for all. To try and say that these regulations are not needed, and that companies, and industry in general will act to reduce the environmental damage they are inflicting on our earth is simply willful blindness. That conclusion ignores a fundamental truth about business and human nature in general; namely that profits come first, every time.

This is not meant to imply that seeking profits first is inherently unethical in some way. In fact the point of any business venture is to gain profit. Nor does this mean that there are not companies that do place a high value on environmental responsibility. Neither does it mean that governmental regulation and legislation are without flaws, or that they are only force that is working towards reducing pollution. However, even in today’s world with increasing attention being given to environmental issues by the public at large, the largest motivating factor for industry in general to reduce its environmental footprint remains the financial benefit.

For us in the dust collection industry, this means that sales efforts always need to remain focused on presenting how our dust collectors, Baghouses, and other pollution control technologies will result in savings/increased profits for the customer.

 

Sources:

http://www.heritage.org/government-regulation/report/coming-clean-regulatory-costs-and-benefits#_ftn1

http://switchboard.nrdc.org/blogs/ljohnson/the_heritage_foundations_criti_1.html

 

What Do You Think?

We would love to hear your comments on this subject. Please leave your comments below, and share in the discussion.

 

 
About the Author

| Dominick DalSanto is an Author & Environmental Technologies Expert, specializing in Dust Collection Systems. With nearly a decade of hands-on working experience in the industry, Dominick’s knowledge of the industry goes beyond a mere classroom education. He is currently serving as Online Marketing Director & Content Manager at Baghouse.com. His articles have been published not only on Baghouse.com , but also on other industry related blogs and sites. In his spare time, Dominick writes about travel and life abroad for various travel sites and blogs.

/by