Gasket Sealing Part 2: Mitigating BWON Emissions
Among the various environmental concerns, the management of hazardous substances like Benzene, Toluene, Ethylbenzene, and Xylene (collectively known as BWON compounds) holds significant importance due to their potential adverse effects on human health and the environment. Achieving compliance with regulations regarding the management of BWON is not only a legal obligation but also a moral imperative for sustainable industrial practices.
In recent years, regulatory agencies in the United States have intensified their focus on BWON emissions from industrial facilities. As a result, companies are increasingly turning to gaskets and sealing technologies to mitigate the release of harmful contaminants.
By Angelica Pajkovic, Client Specialist – Teadit
Emission Control Options
Once the TAB is determined, the facility will fall within one of the three control options:
1. Facilities with a TAB greater than 10Mg/yr. These facilities are required to install environmental controls on their waste streams and WMU and submit quarterly and annual reports
[§ 61.355(a)(3)].
2. Facilities with a TAB less than 10 Mg/ yr but greater than 1 Mg/yr. These facilities are not required to install controls but must submit an annual TAB report and an updated report if the TAB goes above 10 Mg/yr [§61.355(a)(4)].
3. Facilities with a TAB of less than 1 Mg/yr. These facilities are required to submit an initial TAB report and update the report if the TAB goes above 1 Mg/yr [§61.355(a)(5)].
It is important to note that most facilities will have a TAB greater than 10 Mg/yr and will require environmental controls on the equipment transporting process wastewater including the WMUs. This equipment is subject to no detectable emissions threshold and no detectable emissions monitoring standards as noted in §61.343 through §61.347 and §61.349. Un-fortunately, current inspections continue to find sources emitting significantly higher emissions than 500 ppmv. It is therefore important to mitigate any risk of NDE with the appropriate assets.
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Achieving Compliance
There are currently two primary methods used to improve compliance with the NDE control standards for WMUs. The first is to use reliable, low-emission gaskets. The second is to use an optical gas imaging camera to identify detect-able emissions around all seams, seals, covers, and openings on WMUs.
Low-emission gaskets and packing offer several advantages over traditional materials. They are specifically formulated to withstand environments commonly found in industrial processes, ensuring long-term performance and reliability. Additionally, these materials are compliant with environmental regulations and standards, providing peace of mind for facility operators and regulators alike.
In addition to their environmental benefits, low-emission gaskets can lead to cost savings for industrial facilities. By reducing the frequency and severity of leaks, these materials help minimize downtime, maintenance costs, and potential fines associated with regulatory non-compliance. Furthermore, the long service life of low-emission gaskets translates to lower overall lifecycle costs for facilities.
Implementing low-emission sealing products as part of an integrated emissions reduction strategy can help industrial facilities achieve and maintain compliance with BWON and NSPS regulations. However, companies need to consider other factors, such as proper installation, maintenance, and monitoring practices, to ensure the effectiveness of these materials in reducing emissions.
Moving Forward
Recent legal actions, such as consent decrees against industrial facilities, underscore the intricacies of emissions management and emphasize the necessity of proactive measures to mitigate environmental impacts. These consent decrees represent significant mile-stones in environmental enforcement, requiring companies to implement comprehensive measures to reduce emissions and enhance compliance.
Key components of these decrees typically include upgrading pollution control equipment, adopting advanced monitoring technologies, and investing in community outreach and education initiatives. Proactive emissions management, including real-time monitoring and rigorous leak detection protocols, is a cornerstone of consent decrees, emphasizing the importance of identifying and mitigating sources of emissions promptly.
Low-emission gaskets, packing, and sealing solutions play a critical role in reducing benzene emissions and ensuring compliance with BWON and NSPS regulations. By investing in these specialized materials and adopting best practices in emissions management, industrial facilities can protect public health, minimize environmental impact, and achieve long-term sustainability. Additionally, embracing lessons from consent decrees against industrial facil-ities can provide valuable insights into proactive emissions management and community engagement, ultimately contributing to a cleaner, healthier en-vironment for all.