INDUSTRIAL AIR EMISSIONS: A NEW REGULATORY APPROACH

In many parts of the world industrial companies are feeling the effects of tightening environmental legislation. Keeping track of the legislation that affects them is becoming a core competency.

Air emission regulation changes made recently by the Ontario provincial government are a case in point. Ontario’s Regulation 419/05 Air Pollutio – Local Air Quality (O. Reg. 419/05) puts new requirements on companies regarding air emissions and the methods used to demonstrate compliance. As a result, many entities that have been in compliance with regulations, soon won’t be. How “soon” depends on what the company does as determined by their North American Industrial Classification System (NAICS) code.

The regulation sets new standards based on human health and environmental impacts, without regard to technical or economic limitations. This approach results in significant reductions in permissible emissions for metal compounds such as lead and cadmium, and organic compounds such as trichloroethylene and acrolein. The Ministry of the Environment is continuing to consult with affected industries and the public on new standards.

O. Reg. 419/05 is an example of “rolling compliance” legislation, where various provisions are brought into effect at different stages over time. It tells companies what emission levels they will be expected to reach, by a certain date. This approach adds complexity, but it gives companies time to determine whether they are now in compliance, and then to make plans for meeting the legislation’s requirements (see Phase-In Table). For example, iron and steel mills fall under Schedule 4, which calls for ultimate compliance by February 2010.

While the legislation applies only in Ontario, the Canadian reality is that often the legislation enacted in the country’s most populous province has a way of influencing the course of legislation in other provinces and territories.

This is part of a frequently seen progression for environmental protection measures. Concerns are first raised at a scientific level, and these ideas spread world-wide through the peer-reviewed publications. Often, it is European regulators and the U. S. EPA that are among the first to take regulatory steps to deal with the issue, and regulators in other countries such as Canada tend to follow suit.

Helping clients to comply

In supporting their clients in dealing with new regulations such as O. Reg. 419/05, engineers need to understand both the technical aspects and the financial aspects of compliance. It does little good to recommend a current course of action that will not help meet compliance in the future, or which is financially unfeasible.

Experience shows that many companies are reluctant to take a close look at this issue. This reluctance is partly because of the seemingly generous schedule for compliance, and because taking action generally involves spending money that does not show up directly in improved processes and profitability. It is important to point out to clients the length of time required to do the research and to take action — and how being in compliance can help make life smoother.

As well as staying current on the rolling regulations, companies need to understand how changes in the new regulations deal with “receptors.” What has been a farmer’s field up to now may soon sprout a housing subdivision. Then a company’s “business as usual” could be disrupted by a confrontation with neighbours who have problems with its “nuisance emissions” such as noise, odour and dust. This means also staying up to date with development plans at City Hall. The time to start dealing with the problem is when the plans are still just plans that can be changed, not when surveyors’ stakes and bulldozers are appearing across the neighbouring field.

The new process

As with many engineering projects, work starts with measuring the existing situation — in this case the operation’s existing emissions.

Many companies are aware of what exits from their main process stack, but do not have a good handle on their fugitive emissions from sources such as exhaust fans and ventilation outlets. Companies also get caught up wasting effort in trying to calculate the emissions from many small negligible sources.

The Goldilocks principle

In estimating emission rates from sources, it is important to hit what we might call the Goldilocks Ideal — not too much, not too little, but “just right.”

Emission estimates need only to be sufficient to do the job, so effort must be focused on the sources that have the most effect on overall compliance, while putting less effort on other sources. Otherwise the project schedule will be delayed, wasting time (which always equals money) that could be better spent elsewhere. Using engineering principles, it is unnecessary to make the emission rates more accurate than necessary; the same level of scientific precision is not necessarily required for each source.

Many times, a “conservative emission estimate” will over-estimate the actual emission, but can be readily developed and applied quickly to document compliance with the new regulations. In this case, further refinement of the emission estimate is not necessary (see Category 1 in “Compliance Categories”). The categories, which are used by the Ministry but are not part of the regulation, serve to illustrate the steps in a process that requires an increasing level of accuracy, and therefore cost, necessary to demonstrate compliance.

Following this staged approach, if compliance cannot be demonstrated with conservative estimates then the emission calculations must be revisited with a greater level of accuracy. In many cases this is an iterative process. When is “good enough,” good enough? It depends on the situation, but a skilled engineer can balance the project’s timing requirements with the need for accuracy.

In many cases, the time to stop refining the estimating rates is when the plant operation can be demonstrated to be in compliance (Category 2) with current regulations. But it is necessary to keep an eye on the future and on how the regulations will “roll on” and new standards and dispersion modelling requirements will be phased in.

Engineering controls

Engineers are further put to the test when refined emission estimates continue to show non-compliance. O. Reg. 419/05 provides two choices: install abatement controls (Category 3), or the Alternative Standards Process (Category 4).

In developing an abatement plan, engineers must get out their “toolbox” of potential solutions that can include scrubbers, thermal oxidizers, dust collectors, changes in process and better ways to capture fugitive emissions. All are opportunities for an engineer to demonstrate her or his worth in finding effective solutions that do not interfere with production, and do not cost more than necessary.

An alternative where compliance isn’t possible

Sometimes an engineer cannot technically solve every problem and the analysis indicates that even if all possible mitigation steps were taken, compliance would not be cer- tain. In this case, the company can then consider the Alternative Standards Process.

Using this Alternative Standards Process, O. Reg. 419/05 breaks new ground by allowing companies to temporarily set site-specific criteria for their facilities based on technical and economic limitations. At the time of writing (January 2008), no-one has completed the process.

The Alternative Standards Process sets a time limit, and requires companies to explore new technologies to reduce their emissions according to the standards. The company must then reapply for compliance in five years. The process allows engineers to develop solutions that can satisfy both the regulation and the company. They can help the company link the solution with planned capital upgrades and technological improvements to its facility.

As with many engineering projects, Ontario’s regulation
provides an opportunity for engineers to move beyond technical aspects into the area of finding business solutions that work.

Sean Capstick, P. Eng., is a senior air quality specialist in the Mississauga office of Golder Associates in Mississauga, Ont. scapstick@golder.com.

With environmental concerns high on every-one’s radar these days, a growing area of practice for consulting engineers could be in performing energy audits to help homeowners cut their consumption of heating and cooling energy.

Don Fugler, P. Eng. is an example of someone who has been involved in this area of building research for 20 years. A mechanical engineer and senior researcher for sustainable housing for Canada Mortgage and Housing Corporation, he has made a significant contribution to this field in Canada.

The plastic bag approach

One of Fugler’s biggest contributions has been his ability to find a simple way of discovering where a problem exists.

An example is his simple garbage bag test to measure airflows through ducts and registers.

“If I get a call from someone who says, ‘My bedroom is cold,’ I can have them create an air flow measuring device while we are talking on the phone,” Fugler says. “I tell them to get a simple green garbage bag, seal it over the vent and time how long it takes to inflate the bag. That way you can tell if it is a distribution or an insulation problem. If the distribution is adequate, then you are dealing with a heat loss problem.”

Some testing equipment can be notoriously difficult to keep in calibration, with hygrometers used for measuring relative humidity high on the list. To test if these devices are in calibration, Fugler uses a mixture of salt and water and a sealed Ziplock bag. If the hygrometer does not read 75 per cent in that environment, it needs to be recalibrated.

At CMHC, Fugler has also tested a lot of alternative house types, like straw bale houses. The prevailing view when straw bale houses were being developed was that they did not have the same moisture problems as conventional housing. Fugler questioned that thinking and came up with an inexpensive method of testing a large number of the homes, using wood chips with a couple of screws or pins across them, and wires leading out to measuring equipment. He found that straw bale houses experience many of the same moisture problems as other types of housing.

Ice damming has been a major problem for homes in Canada. It occurs when heat escapes from a poorly insulated attic, melting the snow on the roof, which then flows down to an area of the roof where it collects and freezes. Moisture then backs up from the ice dam, getting under shingles and causing leaks in the roof.

“The easiest way to tell if you have a problem is to look at your roof after a light snow or a heavy frost,” Fugler says. “If there is a pattern where the snow or frost is melted off, that will let you know where the heat is escaping from your attic.”

Need for climate specific research

The problem of ice damming is one reason why Fugler favours retaining Canadian research institutions. There is still a strong need for climate-specific and housing-type research, he says.

“I talk at a lot of conferences about ice damming,” he says, “But once you get south of Ohio, no one has ever heard of it.”

Some materials are used differently in different climates. Take polyethylene, which we use as a vapour barrier. “In our [Canadian] houses it is on the inside surface, but if you get down close to Florida it is on the outside surface. If you mess it up you can run into big problems quickly.”

Fugler says that in the U. S. they talk about saving 10 to 20 per cent on their heating bills by sealing air-ducts. “What people don’t know about the 10 per cent savings is that the research was done on houses where the heating ducts are in the attic. With a few exceptions, no Canadian houses are built that atrociously,” Fugler says.

Recently, he carried out a study to see what would induce homeowners to improve the energy efficiency in their homes and reduce greenhouse gas emissions. He found that even with a 5 or 10 year payback, homeowners were still reluctant to do anything.

Education and voluntary programs are not enough, Fugler concludes. Regulation has to be increased to the point that conventional furnaces are no longer available and only high-efficiency appliances are on the market. Only then, will there be major improvements, he says.

Last fall, Fugler received the Beckie award from the Ontario Building Envelope Council, recognizing his efforts to improve building envelope science.

John Leckie is a freelance writer based in Toronto.