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

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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.

 

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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.

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References:

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

Obama Orders EPA to Scrap Proposed Ozone Regulations Due to Economy

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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.

Lead Smelter Ordered By EPA to Repair Dust Collection Systems

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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.

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

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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.

Industrial Air Permits – Overcoming the Difficulties

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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.

Would We Have Clean Air Without Governmental Regulation?

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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.

22 Months More of Life, and 31.5 Billion Euros Saved by Reducing Air Pollution in Europe’s Cites

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Reducing air pollution in major European cities could add 22 months to local life expectancy and save 31.5 billion euros ($43.4 billion) in health costs and work absenteeism, concludes a European Commission-funded study released Wednesday.

One of the largest sources of persistent, air pollution is particulate matter emitted during the burning of fossil fuels such as coal for power generation.  Current dust collection technology, if fully implemented can remove nearly all particulate matter from power plant emissions. As this study shows, the cost of implementing these, and other pollution control technologies pales in comparison with the public health benefits, and savings.

Read the full article here: http://content.usatoday.com/communities/greenhouse/post/2011/03/air-pollution-life-expectancy/1

 

 
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.

EPA sets new Clean Air Act Regulations for Boilers and Incinerators

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Revised standards will bring dramatic benefits to public health, and cost nearly 50% less than initial proposals

By Dominick DalSanto
Environmental Technology Expert & Author
Baghouse.com

The Environmental Protection Agency (EPA) has issued its final set of Clean Air Act standards for boilers and incinerators. The new standards will lead to a reduction of harmful emissions including mercury, and soot from this equipment. Recently federal court orders had charge the agency with the task of issuing final standards ahead of its proposed date. The new set of standards are expected to cost approximately 50 percent less to implement than the original proposal.

The court’s directive from September 2009 led to the EPA issuing a proposal of new standards in April 2010. The court case struck down a set of industry standards that had been proposed and adopted during the Bush administration. After receiving much public input, the EPA made substantial changes and was granted an additional 30 days by the court in December 2010 to implement as much as the public’s input as possible.

The proposed public health benefits for this plan are quite extensive. Exposure to emissions of mercury, soot and several other harmful compounds are very damaging to humans. These pollutants aggravate preexisting conditions such as cancer, heart disease, and asthma, and are especially hard on children, even causing developmental disabilities in some. The EPA estimates that between 2,600 to 6,600 premature deaths will be avoided along with 4,100 heart attacks, and 42,000 asthma attacks.

Much of the public comment on the proposed set of regulations involved the initially high cost of implementation. However, the newly revised standards represent a dramatic cut in the cost of implementation, while maintaining maximum public health benefits. As a result, EPA estimates that for every dollar spent to cut these pollutants, the public will see between $10 to $24 in health benefits, including fewer premature deaths.

Over 4,800 comments were received from both industry, and communities throughout the United States. This included a substantial amount of new information from industrial sources that had previously not been considered. In addition, President Obama recently issued an executive order that called on the EPA to reform its regulatory review process to ensure maximum protection for public health, while not unattainable burdens upon industry. Based on these factors, the EPA revised the proposed, standards, to provide addition flexibility and cost effective techniques – achieving significant pollution reduction and important health benefits, while lowering the cost of pollution control installation and maintenance by about 50 percent, or $1.8 billion.

Details of the new EPA Clean Air Act Standards for Incinerators, and Boilers

Industrial Boiler emissions are include mercury, soot, and ozone.

Emissions from industrial boilers now must conform to EPA emission standards. This includes installing pollution control technologies such as Dust Collectors, and Air Scrubbers to remove harmful compounds from the air.

Several different kinds of boiler and incinerator equipment are covered by the new EPA regulations, including:

  • Boilers used at heavy emissions sources: The approximately 13,800 boilers located at large sources of harmful emissions including chemical manufacturing plants, oil refineries, and similar industrial locations. These standards will reduce the emissions of harmful pollutants at these sources including: mercury, organic air toxins, and dioxins. Estimates for the cost of implementing these new standards in this sector are now $1.5 billion lower than the initial projected cost. Health benefits associated with reduced exposure to these harmful compounds, fine particles, and ozone are projected to save between $22 billion to $54 billion in 2014.
  • Boilers at light emissions sources: There are about 187,000 boilers located at small sources of air pollutants, including universities, hospitals, hotels and commercial buildings that may be covered by these standards. Due to the small amount of emissions these sources are responsible for, EPA has limited the impact of the final rule making on small entities. The original standards for these have been dramatically refined and updated to ensure maximum flexibility for these sources, including for some sources, revising the requirement from maximum achievable control technology to generally available control technology. The cost reduction from the proposed standard to the final is estimated to be $209 million.
  • Solid waste incinerators: There are approximately 88 solid waste incinerators are employed in commercial or industrial settings. These include those used in cement manufacturing facilities. These standards, which facilities will need to meet by 2016 at the latest, will reduce emissions of harmful pollutants including mercury, lead, cadmium, nitrogen dioxide and particle pollution. The cost reduction from the proposed standard to the final is estimated to be $12 million.

In separate but related actions, EPA is finalizing emission standards for sewage sludge incinerators. While there are more than 200 sewage sludge incinerators across the country, EPA expects that over 150 are already in compliance. These standards will reduce emissions of harmful pollutants including mercury, lead, cadmium, and hydrogen chloride from the remaining 50 that may need to leverage existing technologies to meet the new standards.

2,600 to 6,600 premature deaths will be avoided along with 4,100 heart attacks, and 42,000 asthma attacks.

EPA has also identified which non-hazardous secondary materials are considered solid waste when burned in combustion units. This distinction determines which Clean Air Act standard is applied when the material is burned. The non-hazardous secondary materials that can be burned as non-waste fuel include scrap tires managed under established tire collection programs. This step simplifies the rules and provides additional clarity and direction for facilities. To determine that materials are non-hazardous secondary materials when burned under today’s rule, materials must not have been discarded and must be legitimately used as a fuel.

The agency recognizes that secondary materials are widely used today as raw materials, as products, and as fuels in industrial processes. EPA believes that the final rule helps set protective emissions standards under the Clean Air Act.

The emissions standards for sewage sludge incinerators and the definition of solid waste are not part of today’s reconsideration.

About 200,000 boilers are located at small and large sources of air toxic emissions across the country. The final standards require many types of boilers to follow practical, cost-effective work practice standards to reduce emissions. To ensure smooth implementation, EPA is working with the departments of Energy (DOE) and Agriculture (USDA) to provide the diverse set of facilities impacted by the standards with technical assistance that will help boilers burn cleaner and more efficiently. DOE will work with large coal and oil-burning sources to help them identify clean energy strategies that will reduce harmful emissions and make boilers run more efficiently and cost-effectively. In addition, USDA will reach out to small sources to help owners and operators understand the standards and their cost and energy saving features.

 

 
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.

Biomass Power Plants Fined $835,000 For Excess Particulate Matter Emissions

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By Dominick DalSanto
Environmental Technologies Expert & Author
Baghouse.com

Two Biomass power plants in California’s central valley were fined $835,000 by the U.S. Environmental Protection Agency (EPA) for exceeding emission limits of nitrogen oxides (which lead to the formation of Ozone), and fine particulate matter. Ampersand Chowchilla Biomass, LLC, (ACB), and Merced Power, LLC, (MP), are located within 12 miles of each other in California’s San Joaquin Valley. An additional fine of $15,000 was issued to ACB by the San Joaquin Valley Air Pollution Control District for violation of a district only statute.

The two plants which began operating in 2008 after nearly 2 years of refurbishments, are additionally required to install new pollution control technologies, and monitoring systems. As a result of this action, the plants have installed equipment that will reduce nitrogen oxide emissions by up to 180 tons per year, and carbon monoxide by up to 365 tons per year. The EPA and The District have placed the plants under supervision for the next years years to ensure compliance.

Failure to maintain a fully functionally dust collection system often leads to heavy governmental fines, and sanctions. In the end, the cost of properly maintaining your dust collection system is much lower than the costs associated with operating a faulty, inefficient, and inadequate system.

This action is part of the EPA’s larger efforts for improve the air quality across the nation, specifically in some of the nations largest urban areas. The San Joaquin Valley suffers from one of the worst air quality situations in the country. With heavy industry, a strong reliance on personal automobiles (lack of public transportation), and geographical characteristics all combining to create large amounts of smog, ozone and particulate matter pollution. The area often consistently exceeds national health standards for ozone and particulate matter.

“EPA is committed to doing our part to tackle the worst air quality in the nation. Today’s enforcement actions are a victory for human health,” said Jared Blumenfeld, EPA’s Regional Administrator for the Pacific Southwest. “San Joaquin Valley communities can now breathe easier as a result of the significant pollution controls won in these settlements.”

Nitrogen oxides react with other chemicals to form ozone and small particles, both harmful to the public’s health. Ozone and particulate matter affect the human respiratory system, and are linked to a variety of significant health problems ranging from aggravated asthma to premature death in people with heart and lung disease.

Biomass power plants use green waste from farms and other operations that would otherwise be subject to open burning, and construction debris that might have gone to a landfill, to generate power. A key piece of equipment needed to control emissions from this process, is an suitable dust collection system. As this case demonstrates, failure to maintain a fully functionally dust collection system often leads to heavy governmental fines, and sanctions. In the end, the cost of properly maintaining your dust collection system is much lower than the costs associated with operating a faulty, inefficient, and inadequate system.

After refurbishing the plants in 2007-2008, ACB and MP initiated operations in 2008. A joint investigation by the EPA and District found that ACB and MP violated the air permits issued to them by the District by:

· Emitting air pollutants including nitrogen oxides, sulfur dioxide, and carbon monoxide in excess of the permit limits;

· Failing to perform timely source testing to measure emissions of various air pollutants;

· Failing to properly install and operate emissions control systems for nitrogen oxides, a precursor to ozone; and

· Failing to certify the continuous emissions monitoring systems.

The plants also violated various District rules including requirements for emissions control plans.

Do you know of any real-life examples where plants chose not to invest in a adequate dust collection system (or failed to maintain it properly, install a larger system to keep up with production needs, etc…) and in the end it ended up costing them much more later on? If you do, we would love to hear from you in the comments section below.

 

 
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.

Israeli Clean Air Act Sets New Standards for Pollution Controls

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By Dominick DalSanto
Environmental Expert & Author
Baghouse.com

The first sweeping legislation governing air pollution in the state of Israel recently went into effect on Jan 1st, 2011, nearly 2 and a half years after it passage through the Israeli legislature.

Industrial plants that previously had no set emissions standards to operate under will now be required to have emissions permit. This is the culmination of nearly a decade of legislative efforts on the part of Israeli policy makers, and environmental activists to bring Israel up to par with other industrialized nations’ stance on harmful emissions. For example, the initial Clean Air Act in the United States was passed in 1970.

While the wait may have been long, the effect of the act is not a mere formality. The new legislation sets new limits for emissions, requires permits to be obtained, and establishes fines for violations of the those statues and permits. Incorporation under the Act will be gradual over the next four years with factories in the metal production and processing sector required to apply for permits by March.

The Environmental Protection Ministry said an expert committee was expected to return its recommendations by mid-January. Following which, the ministry, with the help of an international consultant, would determine the appropriate tools and develop a national plan.

The Act also merges all air monitors into one national network while increasing the number of substances monitored. The ministry will also be increasing the number of portable testers for vehicles from six presently to 11.

A database of emissions data will also shortly be available on the ministry’s website in Hebrew.

The original version of the Act was first drafted by experts on behalf of the Environmental Protection Ministry but failed to pass through the legislative process. A private member’s bill submitted by various MKs, drafted in part by the Israel Union for Environmental Defense, and championed by Omri Sharon when he was an MK, ground its way through the legislative process over a three year period, finally being passed into law in 2008. However, implementation was delayed until January 1, 2011 at the request of then minister Gideon Ezra so that the ministry could hire the requisite manpower.

 
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.