Guidelines On Air Pollution Control Techniques
Guidelines On Air Pollution Control Techniques
Guidelines On Air Pollution Control Techniques
Pollution Control
Techniques and
Devices
October 2008
Abbreviations
1 INTRODUCTION ___________________________________________________ 2
7 COMPLAINTS ____________________________________________________ 57
8 REFERENCES ____________________________________________________ 58
The management and control of air emissions from industrial sources is subject to the
Implementing Rules (IRR) and Regulations made under RA 8749: the Philippines Clean Air Act of
1999 (CAA). Industrial activities that discharge pollutants to air must comply with the ―National
Emission Standards for Source Specific Air Pollutants‖ (NESSAP) and ―National Ambient Air
Quality Standards for Source Specific Air Pollutants from Industrial Sources/Operations‖
(NAAQS), as prescribed in Rules XXV and XXVI of the IRR.
New or modified industrial sources that emit contaminants to air require a Permit to Operate from
the regulatory authority (EMB). The proponent of the new industrial activity (permit applicant)
may sometimes be required by EMB to undertake a study to determine the potential impact of the
emissions from their industrial sources on the surrounding air quality and/or to demonstrate the
compliance of new/modified sources with the NAAQS, especially where larger or more
environmentally significant emissions sources are involved.
Although individual sources are currently issued with permits, it is the off-site impact of all of the
emission sources in aggregate from the site on the environment that must be assessed. Therefore,
atmospheric dispersion modelling of all emission sources at the site is undertaken to demonstrate
compliance with the NAAQS. The atmospheric dispersion modelling should be carried out in
accordance with EMB‘s ―Guidelines on Dispersion Modelling‖. The emissions from all point, area
and volume sources at the site in aggregate can be assessed by the dispersion modelling process.
Although each source is subject to specific emission limits, it is the impact of all of the sources
from the site that is considered by EMB in determining the permit application.
Once a permit has been obtained, the permit holder needs to manage its site, activities and
emission sources to ensure that the NESSAP and NAAQS continue to be complied with over the
operating life of the plant. The company needs to manage and control its emissions via the
selection of appropriate combustion, process equipment, fuels and materials, the installation,
operation and maintenance of appropriate air pollution control devices, and the implementation of
site operation and management plans. The company should also ensure that fuel burning
equipment is well tuned and operating efficiently, contingency plans have been developed and
implemented to manage the effects of unexpected or abnormal discharges that may result from the
failure of control devices or other events, and have inspection and monitoring systems in place to
check and verify that these actions are occurring.
EMB also has an important monitoring role in ensuring through regular inspections that operating
facilities are complying with regulatory requirements and permit conditions. An example
inspection protocol is provided in Appendix A. EMB has also developed a ―Procedural Manual for
Multi-Media Inspections‖ and associated inspection checklists for various industry sectors.
Section 11 of the Philippines Clean Air Act requires the Department of the Environment and
Natural Resources (DENR) to revise and issue guidance on air pollution control techniques. The
section states that:
“The information shall include:
a) Best available technology and alternative methods of prevention, management and
control of air pollution;
b) Best available technology economically achievable which shall refer to the
technological basis/standards for emission limits applicable to existing, direct
industrial emitters of non-conventional and toxic pollutants; and
c) Alternative fuels, processes and operating methods which will result in the
elimination or significant reduction of emissions”
2.1 Background
There are a large range of air pollution control techniques and devices available to reduce
emissions from industrial and commercial sources. The air pollution control devices selected and
installed at a site have to be appropriate to the pollutants being discharged, the size and scale of the
activity being undertaken and the emission source.
EMB has identified that guidance on fuel burning equipment in terms of maintenance, efficiency
monitoring and tuning, and the use of cleaner fuels, are practices that if followed can reduce
emissions and achieve reductions in fuel consumption which will have immediate benefit to the air
quality in the Metro-Manila region. This guidance is provided in Section 4 of the guidelines.
Pulse-Jet Bag Filters. Pulse-jet cleaning of fabric filters can treat high dust loadings,
operate at constant pressure drop, and occupy less space than other types of fabric filters.
During pulse-jet cleaning a short burst of high pressure air is injected into the bags (about
6 bar for 0.03 to 0.1 seconds). The pulse is blown through a venturi nozzle at the top of the
bags and this generates a shock wave that continues on to the bottom of the bag. The wave
flexes the fabric, pushing it away from the cage, and then snaps it back, thus dislodging the
dust cake.
The cleaning pulse is very brief, and as a result the flow of dusty gas does not have to be
stopped during cleaning. The other bags continue to filter, taking on extra duty because of
the bags being cleaned. This enables the pulse-jet fabric filters to operate on a continuous
basis with solenoid valves as the only significant moving parts. Pulse-jet cleaning is also
more intense and occurs with greater frequency than the other fabric filter cleaning
methods. As a result, pulse-jet filters cannot rely on a dust cake to provide filtration. Felted
fabrics are used because they do not require a dust cake to achieve high collection
efficiencies. Woven fabrics are not as satisfactory with pulse-jet fabric filters because they
leak a great deal of dust after they are cleaned.
A disadvantage of pulse-jet units that use very high gas velocities is that the dust from the
cleaned bags can be drawn immediately to the other bags. If this occurs, little of the dust
falls into the hopper and the dust layers on the bags becomes too thick. To prevent this,
pulse-jet fabric filters can be designed with separate compartments that can be isolated for
cleaning.
Typically, pulse-jet filters operate at gas temperatures up to about 260°C, with surges to
about 300°C. However higher temperatures are possible with specialist fabrics. The
minimum temperature of the pollutant stream must remain above the dew point of any
condensable in the stream. The bag filter unit and associated ductwork should be insulated
and possibly heated if potential for condensation exists.
Typical inlet concentrations for bag filter units are 1 to 20 g/m3 but in extreme cases, inlet
conditions may vary between 0.1 to more than 200 g/m3.
Cartridge Collectors. Cartridge collectors have the filter media contained in completed
closed containers, or cartridges. These collectors offer high efficiency filtration combined
with a significant size reduction in the fabric filter unit. Cartridge collectors can operate at
higher gas-to-cloth ratios than bag filter systems. Cartridges can be pulse cleaned, and
some types can be washed and reused.
There are a wide variety of cartridge designs and dimensions. Typical designs include flat
panels, V-shaped packs or cylindrical packs. Cartridge filters are relatively insensitive to
fluctuations in particulate loading. Filter outlet air may be sufficiently clean to be re-
circulated within the plant in many cases (for energy conservation) but this should not be
used when collecting toxic contaminants.
Achievable emission reductions for older existing cartridge collector types are in the range
of 99 to 99.9%. Typical new devices design efficiencies are between 99.99 and 99.999+%.
In addition, commercially available designs are able to control submicron particulate with
a removal efficiency of 99.999+%. Standard cartridge collectors are factory-built, off the
shelf units. They may handle air flow rates upward of 0.10 m³/s.
Static Bag Filters. In a static bag filter the bags are suspended in an enclosure on wires or
springs and fixed to the bag filter unit structure. The filter cake collects on the inside of the
bag. Movement of the bag within the air stream and stretching due to the increase in
weight periodically contributes to the dust cake detaching from the bag and falling into the
hopper. Removal can be assisted by manually shaking or rapping the outside surface. The
bags being accessed from doors on the outside of the structure
Static bag filter unit efficiency should be better than 90% if carefully maintained. The
system is only suitable for small applications with relatively low inlet dust burdens and is
generally limited to air flows of less than 5 m³/s. They are frequently used to clean air
displaced from cement and other powder silos.
3.2.1 Suitable Applications for Fabric Filtration
Although fabric filters can be used in many different conditions, there are some factors which limit
their application.
Both the performance and application of fabric filter equipment is very dependent on the
type of filter material that is used. The fabric type must also fit the cleaning method, and
the stream and particle characteristics.
The characteristics of the dust are one factor. Some particulates are too adhesive for fabric
filters. While such particles are easily collected, they are too difficult to remove from the
bags.
Some fabrics are flammable, and some dusts and stream components may form explosive
mixtures. If a fabric filter is chosen to control explosive mixtures, care must be taken when
designing and operating the fabric filters to eliminate conditions that could ignite the dust,
the stream, and the bags.
The particle size distribution impacts on the overall performance of an ESP. In general, the most
difficult particles to collect are those with aerodynamic diameters between 0.1 and 1.0 µm.
Particles between 0.2 and 0.4 µm usually show the most penetration. This is most likely a result of
the transition region between field and diffusion charging.
Typical new equipment design efficiencies are between 99 and 99.9%. Good quality existing
equipment has a range of actual operating efficiencies of 90 to 99.9%.
3.3.1 Suitable Applications for ESPs
ESPs can be used for the collection of submicron particles such as mists, smoke and fume.
Common applications of dry wire-plate ESPs are large solid fuel-fired boilers such as coal-fired
Each of these three cyclone types has the same basic design. Different levels of collection
efficiency and operation are achieved by varying the standard cyclone dimensions.
The collection efficiency of cyclones varies as a function of particle size, density and cyclone
design. Cyclone efficiency will generally increase with increases in:
Particle size and/or density;
Inlet duct velocity;
Cyclone body length;
Number of gas revolutions in the cyclone;
Ratio of cyclone body diameter to gas exit diameter;
Inlet dust loading; and
Smoothness of the cyclone inner wall.
The cyclone efficiency will decrease with increases in the following parameters:
Gas viscosity;
Cyclone body diameter;
Fibre-Bed Scrubber. In a fibre-bed scrubber the moisture-laden gas stream passes through
mats of packing fibres, such as spun glass, fibreglass, and steel. The fibre mats are often
also wetted with the scrubbing liquid. Depending on the scrubber requirements, there may
be several fibre mats and an impingement device for particulate removal included in the
design. The final fibre mat is typically dry for the removal of any droplets that are still
entrained in the stream. Fibre-bed scrubbers are best suited for the collection of soluble
particulate material, i.e. material that dissolves in the scrubber liquid, since large amounts
of insoluble material will clog the fibre mats with time. For this reason, fibre-bed scrubbers
are more often used as mist eliminators, i.e. for the collection of liquids, rather than for
particulate control.
3.5.1 Suitable Applications for Particulate Scrubbers
Particulate scrubbers can be used in a wide range of applications, but wastewater treatment or
slurry disposal must be managed effectively, otherwise the pollutant load will be transferred to the
water environment.
Venturi scrubbers are suitable for industrial boilers fired with a range of fuels including coal, oil,
and wood. They can also be applied to control emissions from chemical, mineral products, wood,
pulp and paper, rock products, lead, aluminium, iron and steel, and grey iron production industries;
and to municipal solid waste thermal oxidisers. A particularly common application is to control
emissions from hot-mix asphalt plants.
Spray towers are comparatively uncommon and tend to be used as pre-conditioners for other
control devices or in situations where gas absorption may also be necessary, such as the
superphosphate manufacturing industry.
Orifice scrubbers are used in solid fuel combustion processes, food processing (cereal, flour, rice,
salt, sugar, etc.), pharmaceutical processing; and the manufacture of chemicals, rubber and
plastics, ceramics, and fertilizer. Orifice scrubbers can be built as high energy units, but most
devices are designed for low-energy service.
3.5.2 Recommended Performance Criteria for Particulate Scrubbers
Collection efficiencies for wet scrubbers are highly variable. Most conventional scrubbers can
achieve high collection efficiencies for particles greater than 1.0 m in diameter. However, they
are generally ineffective collection devices for sub-micron (< 1 µm) particles.
Scrubber collection efficiency is directly proportional to the inlet dust concentration. That is,
efficiency will increase with increasing dust loading. This suggests that scrubber removal
efficiency is not constant for a given scrubber design, unless it is referenced to a specific inlet dust
loading. In contrast, it has been shown that scrubber outlet dust concentration is a constant,
independent of inlet concentration, similar to fabric filters described above.
3.8 Biofiltration
The term ‗Biofiltration‘ is applied to a technology in which vapour phase compounds (generally
organic compounds) are passed through a bed of media material (‗biofilter‘) and adsorbed onto the
Bioreactors that use an inert bed material normally require the biofilm to be seeded with the most
appropriate bacteria and to provide nutrients for food.
Many biofilters in the past have failed due to inadequate design or maintenance. Where a biofilter
is used as the primary control device, the design of any associated condenser can be as critical as
the design of the actual biofilter. Pilot plants can be used to determine whether a biofilter will
provide suitable control.
3.8.1 Suitable Applications for Biofilters
Biofilters and bioreactors are suitable for many applications and the variety of processes using
them is growing. Their main uses have largely been confined to wastewater treatment, composting,
food and animal products industries including emissions from rendering plants. They have also
been used for treatment of VOCs and other contaminants from the surface treatment industry and
petrochemical industry.
3.8.2 Recommended Performance Criteria for Biofilters
The EMB‘s general design and operating criteria for conventional biofilters are:
Maximum ratio of total gas volume to bed cross sectional area of 50 m3/m2/hr. Total gas
volume includes process air and any necessary dilution air, but excludes flows during
maintenance, which will be assessed on a case-by-case basis but should not generally
exceed 75 m3/m2/hr.
The biofilter must be capable of running with parts of the bed isolated from the incoming
gas flow for maintenance purposes;
Minimum bed depth of filter media of 1.0 m;
Designed to achieve at least 95% odour removal efficiency;
Maximum inlet gas temperature of 35°C;
Humid inlet air stream to maintain the bed moisture content generally above 50%. Bed
moisture content is dependent on the media used. Too little moisture causes cracking and
decreased microbial activity while too much clogs the media, preventing adsorption and
increasing the pressure drop, and leads to undesirable anaerobic activity;
Pressure drop generally less than 100 mm water gauge;
For vent streams with low contaminant concentrations (typically below approximately
2000 ppmv for VOCs), reaction rates and maximum destruction efficiency decrease.
Relatively high destruction efficiencies may also be difficult to measure with low inlet
concentrations due to the detection limitations of measurement instruments. Performance
criteria may therefore be better expressed as a minimum emission limit, such as outlet
concentrations less than 20 ppmv VOCs.
Recuperative Thermal Oxidisers. Recuperative thermal oxidiser systems are similar to
thermal oxidisers but employ heat exchangers to preheat the waste gas stream, and if
appropriate to recover secondary heat for process heating or to generate steam or hot water.
Two general types of heat exchangers are used: shell and tube, and plate heat exchangers.
Shell and tube units are more common and have advantages when temperatures exceed
540oC. Recuperative thermal oxidisers have similar destruction efficiencies to thermal
oxidisers, but this can be limited by the need to limit temperatures in the heat exchanger to
prevent damage. Care is needed for applications with gases that are difficult to oxidise or
when very high destruction efficiencies are necessary. They are usually more economical
to operate than straight thermal oxidisers because they can recover 40 to 50% of the waste
heat from the exhaust gases, but have higher maintenance costs. To avoid fouling of heat
exchangers excessive particulate in the inlet gases must be avoided.
Suitable design and performance criteria for recuperative thermal oxidisers are similar to
those for simple thermal oxidisers discussed above.
Catalytic Thermal Oxidisers. Catalytic thermal oxidisers operate very similarly to thermal
oxidisers, with the primary difference that the gas, after passing through the flame area,
passes through a catalyst bed. The catalyst has the effect of increasing the oxidation
reaction rate, enabling conversion at lower reaction temperatures than in thermal oxidiser
units. Catalysts typically used for VOC destruction include platinum and palladium. Other
formulations include metal oxides, which are used for gas streams containing chlorinated
compounds (USEPA, 1998).
Several different types of catalyst thermal oxidisers are available, largely distinguished by
the method of contacting the contaminated gas stream with the catalyst. Both fixed bed and
fluid-bed systems are used.
Flares. Flares are a specialist category of thermal oxidiser. They are primarily safety
devices, which deal with flows of short duration (generally an upset condition or an
accidental release from a process) rather than a control device that treats a continuous
waste stream. Flares are generally categorized in two ways:
- by the height of the flare tip (i.e. ground or elevated), and
- by the method of enhancing mixing at the flare tip (i.e. steam-assisted, air-assisted,
pressure-assisted, or non-assisted).
Elevating the flare can prevent potentially dangerous conditions at ground level and this
also allows the products of combustion to be dispersed. In most flares, combustion occurs
by means of a diffusion flame. A diffusion flame is one in which air diffuses across the
boundary of the fuel/combustion product stream toward the centre of the fuel flow,
forming the envelope of a combustible gas mixture around a core of fuel gas. This mixture,
on ignition, establishes a stable flame zone around the gas core above the burner tip. This
inner gas core is heated by diffusion of hot combustion products from the flame zone.
Flares can be used to control almost any VOC stream, and can typically handle large
fluctuations in concentration, flow rate, and other characteristics. Flares find their primary
application in the petroleum and petrochemical industries but are also common for landfill
gas treatment. The majority of chemical plants and refineries have flare systems designed
to relieve emergency process upsets that require release of large volumes of gas. These
large diameter flares are designed to handle emergency releases, but can also be used to
control vent streams from various process operations.
Recommended Design
Thermal Oxidiser Type Recommended Performance Criteria
Criteria
o
Thermal 750 – 850 C, for 0.5 – 2 second 98 – 99.99 % removal or < 20ppm VOCs for
Recuperative thermal residence time low concentration inlets
Regenerative thermal
Catalytic Site-specific 95 – 99 % removal or < 20ppm VOCs for
low concentration inlets
A range of conditions are recommended because higher temperatures and residence times are
necessary for those contaminants that are difficult to burn, such as particulates and products of
Figure 15: Counter Current Chemical Scrubber and Packed Tower Scrubber
Purpose built scrubbing towers designed for a specific duty may reach efficiencies of 99.99% for
certain contaminants. Common efficiencies are in the 90 – 99% range. This is very much
dependent on there being sufficient residual scrubbing capacity of the liquor being used to remove
the gaseous contaminants. The liquor needs to be continuously monitored to ensure the minimum
liquor set point is maintained. To achieve this, the scrubbing liquor has to be continually dosed
with a concentrated form of the scrubbing chemical being used.
For a caustic scrubber using sodium hydroxide, the pH of the liquor should always be maintained
above 8 to ensure adequate chemical residual in the scrubbing liquor. Therefore a constant addition
of new solution and bleed-off of spent solution is required. As a result of the bleed off, the
discharged liquor needs to be treated prior to disposal to the sewer or re-use. This treatment, and
disposal of the spent liquor, will add significant operating costs to these units which must be
considered in their selection.
4.1 Introduction
As well as installing air pollution control devices to control and reduce emissions from industrial
sources to air, there are a number of management, maintenance and efficiency measures that can
be applied to emissions sources. This is particular relevant to small to medium-sized fuel burning
equipment operating on liquid fuels. Set out in this section are best practice guidelines on how to
reduce emissions from fuel burning equipment (external and internal) operating in the Philippines.
For fuel burning equipment the best and simplest cleaner production technique that can be applied
to reduce emissions and reduce fuel consumption is to have the combustion appliance tuned on a
regular basis. The tuning should occur on an annual basis as a minimum and EMB will include this
requirement as a condition of any permit issued for fuel burning equipment.
Before costly capital improvements are undertaken, the combustion efficiency should be
maximized. With the improved combustion efficiency there is a corresponding reduction in fuel
consumption, which is a benefit to the operator, given the increasing cost of fuel.
5.1 Introduction
Section 3 of these Guidelines covered the selection of air pollution control devices and their
operating performance criteria. This section provides guidance on how to develop an
environmental management framework under the CAA regulatory regime to ensure that installed
air pollution control devices are operated in accordance with manufacturer's instructions and well
maintained, and their performance is adequately monitored to ensure that they are operating
correctly. EMB‘s EIS and enhanced permitting systems should require significant or priority
industries to develop and implement Operation and Management Plans to achieve improved
environmental outcomes.
As part of a total environmental management system for an industrial undertaking there is a need
to develop an Operation and Management Plan and procedures to ensure that the emissions to air
remain at the levels for which the permit was granted, or which were assessed in the
Environmental Impact Statement. The Operation and Management Plan should contain procedures
and instructions developed specifically for each site in order to ensure that emission control
devices installed at the site are adequately maintained, and monitored so that they are operating
correctly. It should also contain Contingency Plans designed to manage failures of the installed
controlled devices and to reduce the impacts from these failures. The preparation of Contingency
Plans and what should be contained in them is covered in Section 6.
The Operation and Management Plan should be tailored to fit the size and scale of the industrial
activity, taking into account the level of impact from its emissions to air. EMB can set permit
conditions requiring the site to develop an Operation and Management Plan (OMP) and to operate
in accordance with the parameters set out in the Plan, in particular in relation to maintenance,
inspection and monitoring of air pollution control devices.
An OMP is a means of setting out what can be regarded as good process management and
housekeeping practices at the facility in relation to the operation and management of air pollution
control equipment. It also provides a basis for auditing in terms of its environmental management
performance. The OMP is just one of the controlled documents in a facility‘s environmental
management system.
5.7 Biofilter
Set out in this section are the recommended practices for inspecting, maintaining and monitoring
biofilter.
Set out below are the parameters are to be monitored and recorded, and records retained for
sufficient time to provide a good historical record of biofilter operation.
5.7.1 Monitoring and Maintenance
Daily
1) Biofilter Inlet Gas Temperature. The temperature of inlet gases should not exceed 50C at any
time, and preferably should be maintained at 20 - 40C. Inlet gas temperatures shall be recorded at
least once every shift and logged.
2) Biofilter Static Pressure. The static pressure (back pressure) of the biofilters determined in the inlet
duct, and whether or not significant rain fall occurred within about two hours or is occurring, to be
recorded at least once every day that processing is being carried out and logged.
3) Static pressure should not, under normal moisture conditions (four hours after significant rainfall),
exceed 100 mm water gauge (wg). High static pressure with normal media moisture indicates
excessive compaction of the media, excessive breakdown of media (excessive fines), blocked gas
distribution laterals, or blocked drainage system (water build-up in the distribution system and in
the lower section of the media). If media compaction is excessive rotary hoe the bed as deep as
practicable. If excessive fines are the cause then the media requires replacement. Excessive build-
up of biological growth in the distribution laterals can be removed by water blasting, rodding, etc
via the laterals end caps and from the header. Blocked drainage invariably results from excessive
sediment in the sediment trap/trap inlet pipe. Clean out accordingly.
4) If static pressure is less than 20 mm wg this suggests insufficient media moisture; significant
tracking (short-circuiting of gas through fissures in the media or through the media/wall interface -
generally through low media moisture causing shrinkage of media); or inspection covers, manhole
covers, and ducting end caps being dislodged. Low media moisture can be rectified by turning on
media sprinklers for 2 - 3 hours per day until media moisture increases to within specification.
Dislodged ducting covers and caps must be replaced and sealed as appropriate.
5) Biofilter Media Moisture. Media moisture should be checked daily during dry periods (weekly
during partially dry periods), with observations, and use of sprinkler system, recorded. Media
moisture content should be maintained at about 40 to 60% dry weight basis through its depth. As a
guide to satisfactory moisture content, media, when squeezed in the hand, should feel damp
without significant free water (not soggy). Upper bed moisture content is estimated by scraping a
2) Media Micro-organism content. Micro-organism total viable counts are carried out on a media core
sample every six months. Typical total micro-organism counts should be > 104. A composite
If any of these conditions exist the appropriate measures for remediation will be implemented
within eight (8) hours.
Also check internal condition of the reagent tanks, looking in particular for signs of corrosion.
Record Keeping
1) Maintain a record of all inspections and any action resulting from the inspection.
2) Keep maintenance and inspection records.
Quality Control
All instruments and control devices will be calibrated, maintained, and operated according to the
manufactures specifications.
Some industrial processes have the potential to emit contaminants in quantities which can have
serious environmental impacts if the plant or air pollution control devices fail. These failures may
develop over time, or may result from a serious failure of a process or discharge control. For
processes where such releases are possible, some minimum level of process and equipment
monitoring is required to warn of the potential for, or existence of, an accidental release. This does
not prevent the permit holder from installing more sophisticated monitoring equipment than that
required by EMB. However, in the event of air pollution control device failure, the management of
the plant needs to have put in place procedures (Contingency Plans) for managing the situation.
Contingency Plans for air pollution control device failure provide procedures as what to do in the
event of a failure. In most circumstances total failure of air pollution control devices on a process
will require that the process be shut down, but in an orderly manner.
Operators of air pollution control devices need to be trained in the procedures contained in the
Contingency Plans and on how to shut the processes they are operating down in the event of a
major failure of the installed air pollution control devices.
6.1 Contents of a Contingency Plan
A contingency plan should be developed for each type of air pollution control devices installed at
the site. The Plan should:
Be based on an environmental risk assessment. This should identify likely modes of
failure and the level of impact risk for these failure scenarios for that process and air
pollution control device. This includes the likelihood of the failure mode to occur, the
consequence of the discharge (size of the release, duration, pollutants contained in the
release and the area affected), and identification of who would be affected (on-site and off-
site) by the release by these failures. This risk assessment process allows the relative risk
of the failure of each piece of air pollution control devices to be assessed, and compared to
each other. It also allows the requirements Contingency Plans to reflect the relative level of
risk posed by each failure scenario. A typical qualitative risk assessment that can be used
to evaluate the level of risk for different failures of emission control equipment at a site is
provided in Appendix B. The scenarios can be grouped into those only have on-site
consequences and those having both on-site and off-site consequences.
For off-site consequences, contain a contact list of sites and personnel that could be
affected, and in some instances may need to be evacuated from there premises.
Develop a set of procedures that sets out the actions that must be followed in the event of
the failure of a specific piece of air pollution control devices. They usually include the
following steps:
1) Identify the scale and level of failure;
2) Advise supervisor of the failure;
3) Decide whether the failure requires to process to be shutdown or that the fault can be
fixed without having to shut the plant down;
4) Implement actions to close process/plant and if a major failure;
5) Decide in consultation with supervisor whether off-site consequences will occur and
whether evacuation is required; and
6) Complete all actions.
Assign the responsibilities and actions of key personnel who will implement the
Contingency Plan in respect to the investigating the cause of failure and the scale of the
failure, and whether shutting down the process and control devices is appropriate action.
All site that hold a Permit to Operate should as a condition of the permit be required to maintain a
Complaints Register. The complaints register should record all complaints that the plant receives
from the public in relation to their operations and in particular their emissions to air.
The Complaints Register should record the following:
1) Name and contact details of complainant (or enquirer)
2) Date and time of receipt of the complaint (or enquiry)
3) Name and designation of the person who received the complaint
4) Details of the complaint
a description of the pollution incident, event or subject matter
the place, time and duration of the incident or event
the alleged or suspected source of the pollution
the weather conditions at the time of the incident or event
the complainant‘s assessment of the seriousness of the incident or event
any other pertinent comments or information provided by the complainant
5) Results of the facility‘s investigations of the incident or event
6) Mitigation actions or measures (if any) adopted
7) Advice to complainant of the outcome (date & time advised)
8) Advice to EMB of the outcome (date & time advised)
The Complaints Register is to be retained as a part of facility operational log and should be made
available to EMB inspectors who visit the site.
1) Auckland Regional Council, Performance Criteria for Air Pollution Control Equipment, August
2000, a report prepared by Sinclair Knight Merz Limited.
2) Auckland Regional Council, Assessing Risk from Potential Air Discharges Following Industrial
Incidents, A Discussion, June 2000, a report prepared by Sinclair Knight Merz Limited.
3) Auckland Regional Council, Technical Publication 152, Assessing Discharges of Contaminants
into Air (Draft), April 2002
4) Brenman B. M., Donlan M. and Bolton E., 1996, Peat Biofiltration as an Odour Control
Technology for Sulphur Based Compounds J.CIMEM, June 1996.
5) Buonicore A. J. and Davis W. T., 1992, Air Pollution Engineering Manual AWMA, Van Nostrand
Rienhold, New York.
6) USEPA, 1996, Compilation of Air Pollutant Emission Factors AP-42 Fifth Edition, Volume 1:
Stationary and Point Sources. http//www.epa.gov/ttn/chief/
7) USEPA, 1998. U.S. EPA, Office of Air Quality Planning and Standards, Stationary Source
Control Techniques Document for Fine Particulate Matter, EPA-452/R-97-001, Research Triangle
Park, NC., October.
8) USEPA, CACT, 1998 Clean Air Technology Centre, Technology Fact Sheets.
http//www.epa.gov/ttn/catc/
9) World Bank - Low NOx Burners.htm.
Air Discharges
yn Industry complies with all current permit emission discharge conditions – if n, generate a
report details and consider enforcement action
yn All discharge sources are included in the permit? - if n, report details, draft new conditions
and amend permit
yn Industry has changed processes/operations/pollution control equipment at the site since the
last inspection? - if y require written report from permit holder and amend permit and
consider enforcement action
yn Are there odours, solid particulates, liquid droplets or mist detectable off-site? - if y report
details and amend permit
yn Are the permit monitoring conditions adequate in terms of the parameters and testing
frequency? - if n report details and amend permit
yn Is the emission control equipment installed at the site effective in controlling emissions? - if
n report details and amend permit
yn Are monitoring records held for each air pollution control device installed at the site? – if n
report and amend permit to include effective OMP conditions
yn Have corrective actions required in the OMP been carried out? - if n report and consider
enforcement action
yn Is maintenance being carried out in accordance with the OMP? – if n report and consider
enforcement action
Contingency Plans
yn Does the industry have an effective Contingency Plan with procedures to manage any
accidental or unexpected releases of emissions? - if n report and amend permit
yn Have there been accidental or unexpected releases to the environment? – if y report details of
causes and action taken/needed and amend Contingency Plan if necessary
Complaints
yn Does the industry have an up to date complaints register? - if n report and amend permit
yn Is the company‘s response to complaints appropriate? – if n report and consider enforcement
action
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Appendix B Risk Management Principles and
Procedures
B.1 Introduction
The term risk assessment can be confusing, particularly in the context of air pollution assessments.
This document describes a risk-based approach to assessing potential events or incidents in
industrial facilities.
A risk-based approach is a methodology that takes account of the probabilistic nature of
unintended events. Tools that aid the identification of accidental or unexpected events and an
understanding of the potential consequences are also discussed. The probabilistic approach of risk
assessment contrasts with the more recognised assessment methods used for air quality impacts.
These are usually deterministic in nature and do not facilitate the identification of hazards or the
resulting failure combinations or sequences.
In most circumstances, normal or expected air discharges are compared to a specific guideline or
criterion, such as an ambient air quality standard. However, many criteria used in deterministic
assessments have been developed by way of a risk-based approach that includes a probabilistic
element. For example, ambient air concentration limits for many contaminants have been
determined by health risk assessments, which deal with evaluating long-term exposures in relation
to an acceptable likelihood of illness or death.
What is Risk?
The fundamental concept of risk always involves two elements: the frequency or probability with
which a hazardous event may occur, and the consequence of that event. A risk analysis deals with
both elements, while risk assessment is the process used to determine risk management priorities
by comparing the level of risk against predetermined standards or other criteria.
Risk Analysis
As discussed above, risk analysis is the process of determining how often incidents may occur and
the severity of the associated consequences so as to establish the actual, as opposed to the
perceived, level of risk. This process can be carried out using detailed mathematically-based tools
or by a more general process involving the extensive use of judgement-based data. The first
methodology is known as ‗quantitative‘, and the latter ‗qualitative‘. An example of a qualitative
method that can be followed in presented Section B.2.
A quantitative risk analysis provides a measure of risk by using estimates of frequency or
probability of the undesired events that are based upon historical data or calculations based upon
an analysis of failure sequences. This work is then supported by the calculation of the impact of
the consequences.
Quantitative risk analysis can be very demanding and, in practice, there is a potential for a very
large range of accident scenarios. It therefore may not be feasible to undertake a detailed
frequency and consequence analysis for each one. In these circumstances it may be better to rank
the scenarios qualitatively and then concentrate on those events that are assessed as having the
highest risk. Thus, risk estimation techniques provide a useful approach for ensuring the
quantitative effort is focused on events of greatest concern.
Frequency Analysis
A frequency analysis forms part of a risk analysis described above. It involves the quantitative
determination of the likelihood or frequency of events identified at the hazard identification stage.
Consequence Analysis
Consequence analysis involves methods for calculating or estimating the impact of the incident.
This could include a study of the effects of any harm caused such as on people, property or the
environment and must relate the sensitivity of the local environment to the event.
In general terms, consequence analysis determines the effects from fires, projectiles, falling
structures etc. However, in the context of assessing air emissions, the focus is on the consequence
of the release of contaminants to air. A range of tools are available for assessing the consequence
including atmospheric dispersion modelling.
Cumulative Risk
The total risk faced by an individual or society is the sum of all individual risks. Therefore, when
considering the calculated risk from a facility, it is necessary to also consider any existing risks
posed by other nearby facilities. Even when the new facility may present a small risk relative to an
existing one, the total or cumulative risk will still be increased, possibly to a level that may be
deemed intolerable.
Uncertainty
As risk is a function of both probability and what may actually happen in the future, there will
invariably be a level of uncertainty associated with any analysis of risk. This uncertainty relates to
the inability to know exactly how and when events may occur.
The uncertainties may arise in various parts of an assessment, including failure rate estimates,
consequences, or assumptions about human error. In many cases, therefore, quantitative evaluation
criteria may have limited value and more qualitative criteria may be more appropriate. In some
cases the appropriate approach will be to consider the worst case, thereby adding an element of
precaution.
Guidelines on Air Pollution Control Techniques and Devices - 62 –
Air Quality Management
Furthermore, it may be very difficult to derive quantitative criteria for ecological risk. For
example, the environmental values being protected are often not well understood. As a result any
data derived from risk analysis must be interpreted with a full understanding of the associated
uncertainties. Those tasked with risk-based decision making need to be aware of the inherent
uncertainties associated with the information used in making a judgement or decision. Thus any
risk analysis presented as part of an application for a discharge to air, will need to, at the very
least, make comment on the level of uncertainty associated with the critical data.
In order for sites to plan for, and achieve effective management of their discharges to air and the
associated hazards and impacts, a structured risk identification and assessment approach, based on the
qualitative risk assessment methodology of Australian Standard AS/NZS 4360:2003 Risk Management
can be followed. The risk assessment process is a management tool that allows resources to be applied
to control emission sources that pose the highest level of risk.
This risk assessment approach combines (qualitative) estimates of the likelihood of a certain
hazard event or environmental impact occurring, with the consequence of that impact or hazard.
The qualitative rankings of likelihood and consequence used in this assessment are based on those
in AS4360:2003 and are described in Tables B-1 and B-2, respectively.
Likelihood
Scale Descriptor Criteria
Descriptor
Consequence
Scale Descriptor Criteria
Descriptor
Multiple fatality
Catastrophic 16 Irreversible environmental damage and prosecution
Financial loss over US $5M
Single fatality or permanent disability
Major 8 Environmental damage leading to potential prosecution
Financial loss over US $1M but less than US$5M
Serious injury or long-term illness
Non-compliance with licence/agreement conditions or
Significant 4 emission having significant adverse environmental
impact
Financial loss over US $500,000 but less than US $1M
Injury requiring medical attention and several days off
work
Community complaint or emissions having adverse
Moderate 2
offsite environmental impact
Financial loss over US $250,000 but less than US
$500,000
First aid needed
Localised on-site impact such as oil staining over a small
Minor 1
area of the site
Financial loss less than US $250,000
Almost Highly
Likely Possible Unlikely
Certain Unlikely
4 3 2
5 1
Catastrophic
80 64 48 32 16
16
Major
40 32 24 16 8
8
Significant
20 16 12 8 4
4
Moderate
10 8 6 4 2
2
Minor
5 4 3 2 1
1
The numerical risk ranking has been translated into a low, medium to high risk ranking using the
criteria provided in Table B-4.
The risk rankings, and the degree of management planning or response appropriate to each risk
ranking, are generally:
H: High risk, senior management attention required
M: Moderate risk, management responsibility must be specified
L: Low risk, management by routine procedures.
General Responsibilities
Evacuation provisions are applicable to fires and all other occurrences for which evacuation of
staff from buildings to Assembly Areas (assembly points) is appropriate, such as major plant
failure, fire, etc.
All building emergency exits are labelled with the green sign EXIT.
All personnel should familiarise themselves with the locations of ALL emergency exits from their
work area and the location of their nearest Assembly Area (assembly point).
All Safe Briefing Areas are sign posted ‗Assembly Areas‘ and are allocated a distinct letter for
identification purposes. (These tie up with marked areas on site layout maps.)
Always assemble at the designated Assembly Area closest to your point of work.
Evacuation Procedures
In the event of a fire, major plant failure, explosion, bomb threat or the need to evacuate the plant,
the actions listed below should be followed.
On the continuous sound of the alarm siren (bells), STOP all activities and vacate the building
or area without delay, by the nearest exit.
Plant Operators to initiate appropriate Emergency Operating Procedures (EOP), and where
possible, confirm plant is in safe state prior to vacating buildings.
Move quickly, but do not run.
Do not return to a work area to collect belongings.
Keep left in corridors and stairs.
Do not overtake others along the route.
Assemble in the designated Assembly Area.
At Assembly Area report to the responsible Warden.
Do not enter the building or work area under any circumstances until the all clear is given.
All new staff, as part of their induction into the company, shall be given instructions on the
evacuation procedures for the site.
All visitors and contractors are to be advised of the site‘s Evacuation Procedure and the location of
Assembly Areas when they are admitted to the site.
Specific Responsibilities
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Duties of Control Officer
Report to designated control centre area.
Await wardens to report.
Review Evacuation Control Board status.
Direct personnel accordingly.
On all clear, issue instructions to return to work.
Designated Assembly Areas are marked on site layout maps, and are displayed on noticeboards
throughout the site next to the Evacuation Procedure.
For some sites, wind socks are placed throughout the site. Observe the wind direction (sock
direction) during the evacuation. Personnel should assemble at the safe upwind Briefing Areas.
All Clear
Control Centre
The most senior staff member of the shift will be the Control Officer. All Area Wardens will
report to the Control Officer.
The Evacuation Control Board will be held at the Control Centre.
A flow diagram showing the Evacuation Procedure is presented in Figure 1. This flow diagram can
be placed on notice boards throughout the site next to the site plan showing designated Assembly
Areas.
Regular drills (once every six months) are held to ensure that staff are familiar with the Evacuation
Procedures.
Training
All personnel, visitors and contractors will be trained on how to use the emergency plans set out in
this section.
Emergency procedures will be included in induction training for all new staff and contractors to
the site.
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Appendix D Guidance on Costs of Pollution
Control Equipment
The costs contained in this section are provided for indicative purposes and are sourced
from the US EPA Air Pollution Control Technology Fact Sheets. For full details the
reader should refer to the fact sheet itself. The following costs for the various air pollution
control devices covered below are ranges in US dollars (circa 2002) and are based on
typical operating conditions found in US situations. In some instances an allowance for
duct work, etc has not been included in the estimate of costs.
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Cartridge Collectors
Capital Costs $15,000 to $28,000 per sm3/sec
Conventional Cyclones
Capital Costs $4,600 to $7,400 per sm3/sec
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Cost Effectiveness $0.47 to $40 per tonne, annually
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Cost Effectiveness $40 to $7100 per tonne, annually
Thermal Oxidiser
Capital Costs $53,000 to $190,000 per sm3/sec
Flare
Capital Costs $37,000 to $4,000,000 per sm3/sec
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