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FEM 2024 - Air Emissions Level 2

  • Updated

Table of Contents

  1. Airpollutanttrack
  2. Airpollutanttrack Verification And Scoring
  3. Airproduction
  4. Airproduction Verification And Scoring
  5. Airreduce
  6. Airreduce Verification And Scoring
  7. Airimplementation
  8. Airimplementation Verification And Scoring
  9. Airmonitorscore
  10. Airmonitorscore Verification And Scoring
  11. Airindustryreq
  12. Airindustryreq Verification And Scoring
  13. Airreplace
  14. Airreplace Verification And Scoring
  15. Airpolicies
  16. Airpolicies Verification And Scoring

Airpollutanttrack

8. Does your facility track the total annual emissions quantities of key pollutants from all point source emissions from facility operations? (Ref ID: airpollutanttrack)

Answer Yes if:  Your facility has calculated the annual emission quantity of all the applicable key pollutants listed in the FEM from all point source emission sources from facility operations.

Note: If your facility only conducts emission testing and has not calculated annualized air emission quantities of all the applicable pollutants listed in the FEM, you should select No for this question.

If you select Yes, you will need to complete a table with the following questions to provide details on your air emissions from all point source emissions from facility operations during the reporting year.

  • Pollutant – Reportable pollutants for facility operations include:
    • Particulate Matter (PM) – This must be reported as the total quantity of PM including all fractions (e.g., PM2.5, PM10).
    • Nitrogen Oxides (NOx)
    • Sulfur Oxides (SOx)
    • Carbon Monoxide (CO)
    • Volatile Organic Compounds (VOC) or Total Organic Carbon (TOC) – This must be reported as total quantity of VOC.
    • Hazardous or Toxic Air Pollutants (HAP/TAP) – This must be reported as total quantity of HAP/TAP
  • Please select operations related pollutants emitted by your facility
  • Is this pollutant regulated by a government agency?
  • Was the total annual emission quantity of this pollutant from all point sources calculated for the reporting year?
  • What is your annual emission quantity (in kg) of the pollutant?
  • Describe the methodology used to determine the annual emissions quantity of this pollutant.

Suggested Uploads:

  • Documentation that supports emission reporting calculations and methodology which may include:
    • Annual emission inventory with quantities of applicable pollutants
    • Emission source operational data (i.e., operating time, flow/emission rates)
    • Records of fuel consumption
    • Emission factors or assumptions used in emissions calculations.

What is the intent of the question?

The intent of this question is for facilities to track the total quantity of key pollutants emitted from point sources related to facility operations in the FEM reporting year (e.g., boilers, generators, combustion heating, etc) to be able to demonstrate reductions in the amount of pollutants emitted to the environment.

Technical Guidance

Calculating the annual emission quantities of pollutants emitted from operations allows facilities to have a baseline of emission quantities that can be used to identify opportunities to reduce the amount of pollutants emitted to the air and quantify these improvements.  

Reporting Air Emissions from Operations in the FEM:

Before reporting air emissions data in the FEM, data quality checks should be performed to ensure that the data and the methodologies used to calculate emissions quantities are effective at producing accurate air emissions data.

The reported quantity of each pollutant must be facility-wide and include emissions from all point sources from facility operations. For example, in the FEM reporting year, if a facility has a natural gas boiler that emitted 450kg of PM and a diesel generator that emitted 650kg of PM, the reported emission quantity would be 1,100kg (450kg + 650kg) of PM for the reporting year. 

For the FEM, this methodology of reporting the combined total of the pollutant/pollutant group from all point sources is applied to all reported pollutants (e.g., VOC are reported as the total quantity of all VOC from all point sources of emissions from facility operations)

Volatile Organic Compounds (VOC)

VOC are defined as organic chemical compounds that under normal conditions are gaseous or can vaporise and enter the atmosphere. The general criteria for determining whether a pollutant is considered a VOC is provided below:

  • It contains carbon. 
  • Vapor Pressure is > or = 0.01 kPa (~0.075 mmHg) at 20C
  • Boiling point is < or = 250C at standard pressure of 101.3 kPa

Hazardous or Toxic Air Pollutants (HAP/TAP)

Are defined as compounds that are known or suspected to cause significant harmful impacts to human health or the environment.  

Country-specific regulation may define which air pollutants are designated as HAPs/TAPs within a specific jurisdiction. Where country-specific definitions or regulations do not define HAPs/TAPs, recognized lists from other jurisdictions may be referenced when determining if pollutants from facility operations should be included in the reported quantity for HAPs/TAPs.  For example, information on HAPs from the US EPA can be found here https://www.epa.gov/haps. A current list of HAPs (as defined by the US EPA can be found here: https://www.epa.gov/haps/initial-list-hazardous-air-pollutants-modifications 

Calculating Annual Air Emissions Quantities from Operations:

Note: The methodology used to calculate emissions from each source should be selected and applied by qualified individuals such as a process or environmental engineer who understand the technical principles and methodologies for determining emissions from operations sources (e.g., boilers, generators, combustion heating equipment, etc).

There are several methodologies and techniques that can be used to calculate emission quantities of pollutants from operations. These can include:

  • Direct Measurement or Sampling – Through the use of continuous emission monitoring systems (CEMS) or testing results that are used to calculate annual emission quantities based on the sources operating parameters (e.g., operating time, flow rate, pollutant emission rates, etc).
  • Engineering Calculations – That utilizes established emission factors for specific fuel types, equipment or processes. 
  • Fuels Analysis/Mass Balance – That uses the known or estimated content of pollutants in the fuel source and fuel consumption data to calculate emission quantities for specific pollutants.

To calculate the annual emissions from a source, there are several critical pieces of information that must be known. This can depend on the specific methodology used to calculate emissions, however these typically include the following for each point source:

  • Air flow rate of the source (e.g., m3/hr)
  • Operating time in the reporting year (e.g., hrs)
  • Emission concentration - from direct measurements or emission factors (e.g., kg/m3)

Once these are known the basic equation is as follows:

  • Emission Quantity = emission concentration x air flow x operating time 

If sources have control technologies installed (e.g., scrubbers, catalytic reduction systems, electrostatic precipitator, etc), the pollutant destruction or removal efficiency of the control can be factored into the emissions calculations. For example, if 1,000 kg of NOx was emitted from a source and the exhaust stack was fitted with a catalytic reduction system which has a 90% removal/destruction efficiency, the calculated quantity of NOx emitted would be 100kg (1,000kg x 10%).

Do:

  • Review source data (e.g., records of fuel consumption, emission factors, operating time, flow/emission rates, etc.) to ensure calculated emission total are accurate.
  • Ensure the most recent and updated versions of data tracking spreadsheets are being used and that all automated calculations/formulas are correct.
  • Ensure the proper units are reported and verify any unit conversions from source data to reported data.
  • Review any assumption or estimation methodology/calculations to ensure accuracy.
  • Report the proper tracking method in the FEM (e.g., Estimated if annual emissions are calculated using emission factors, or measured if using continuous emission monitoring systems (CEMS)).

Do Not:

  • Report data that is not accurate (e.g., the data source is unknown or has not been verified).
  • Report estimated data if it is not supported by verifiable and reasonably accurate estimation methodology and data (e.g., emission factors, fuel consumption, or other engineering calculations).

Resources:

Several publicly available resources that contain examples of the methodologies and information required to calculate emission from point sources are provided below. 

Note:  The emissions calculation methods and information (e.g., emission factors) in these resources are provided for reference and may contain regulatory requirements that do not apply to your facility. If country specific calculation methodologies (e.g., emission factors, fuel composition data, etc) are available, they should be used when calculating your facility’s emissions. 

Airpollutanttrack Verification And Scoring

How This Will Be Verified:

When verifying a facility’s air emissions data, Verifiers must review all aspects of the facility’s emissions tracking and reporting program that could produce inaccuracies including:

  • Emissions data sources (e.g., testing reports, emission factors, emissions calculation methodology or other engineering estimates); and
  • The process and tools used to aggregate the data (e.g., spreadsheet calculations, unit conversions, etc.)

If any inconsistencies or errors are noted, the reported information must be corrected where possible and detailed comments should be included in the Verification Data field.

Full Points:

Documentation Required:

  • Documentation that supports emission reporting calculations and methodology for each point source from facility operations and the applicable pollutant(s). This may include:
    • Annual emission inventory with quantities of applicable pollutants
    • Spreadsheets or other documentation showing emission calculations including:
      • Emission source operational data (i.e., operating time, air flow rates). 
      • List of emission factors and/or other assumptions used in emissions calculations.
      • Records of fuel consumption used in emissions calculations.
      • Emission testing results used to determine emission rates from sources.

Note: If the facility utilizes a third-party service provider to calculate emission quantities, documentation to support the data and methodology used should be made available for verification.

Interview Questions to Ask:

  • Staff responsible for reporting the facility’s emission data is knowledgeable and can explain how source data (e.g., pollutants, operating time, emission source flow rate, etc) is identified and collected and the methodology used to calculate emissions.

Inspection - Things to Physically Look For: 

  • All point source emission sources and potential pollutants from facility operations source are properly identified and this is consistent with onsite observations of the facility’s operational emission sources.

Partial Points: N/A

Airproduction

9. Does your facility track the total annual emissions quantities of key pollutants from all emissions from production?   (Ref ID: airproduction)

Answer Yes if: Your facility has calculated the annual emission quantity of all the applicable key pollutants listed in the FEM from all emission sources (point source and fugitive sources) from facility production.

Note: If your facility only conducts emission testing and has not calculated annualized air emission quantities of all the applicable pollutants listed in the FEM, you should select No for this question.

If you select Yes, you will need to complete a table with the following questions to provide details on your air emissions from all point source emissions from production during the reporting year.

  • Pollutant - Reportable pollutants for facility production include:
    • Particulate Matter (PM) – This must be reported as the total quantity of PM including all fractions (e.g., PM2.5, PM10).
    • Nitrogen Oxides (NOx)
    • Sulfur Oxides (SOx)
    • Carbon Monoxide (CO)
    • Volatile Organic Compounds (VOC) or Total Organic Carbon (TOC) – This must be reported as total quantity of VOC.
    • Hazardous or Toxic Air Pollutants (HAP/TAP) – This must be reported as total quantity of HAP/TAP
    • Ammonia (NH3)
    • Ozone (O3)
    • Ozone Depleting Substances (other than refrigerants reported in Question 6)
    • Carbon disulfide (CS2) – Applicable only to facilities that produce Man-made Cellulose Fibre (MMCF).
    • Hydrogen Sulfide (H2S) - Applicable only to facilities that produce Man-made Cellulose Fibre (MMCF).
  • Please select production related pollutants emitted by your facility
  • Is this pollutant regulated by a government agency?
  • Was the total annual emission quantity of this pollutant from all point sources calculated for the reporting year?
  • What is your annual emission quantity (in kg) of the pollutant?
  • Describe the methodology used to determine the annual emissions quantity of this pollutant.

Suggested Uploads:

  • Documentation that supports emission reporting calculations and methodology which may include:
    • Annual emission inventory with quantities of applicable pollutants
    • Emission source operational data (i.e., operating time, flow/emission rates)
    • Records of raw material/chemical consumption
    • Emission factors or assumptions used in emissions calculations.

What is the intent of the question?

The intent of this question is for facilities to track the total quantity of key pollutants emitted from all sources (point source and fugitive sources) related to facility production processes in the FEM reporting year to be able to demonstrate reductions in the amount of pollutants emitted to the environment.

Technical Guidance

Calculating the annual emission quantities of pollutants emitted from production allows facilities to have a baseline of emission quantities that can be used to identify opportunities to reduce the amount of pollutants emitted to the air and quantify these improvements.  

Reporting Air Emissions from Production in the FEM:

Before reporting air emissions data in the FEM, data quality checks should be performed to ensure that the data and the methodologies used to calculate emissions quantities are effective at producing accurate air emissions data. 

The reported quantity of each pollutant must be facility-wide and include emissions from all point sources and fugitive sources from production. For example, in the FEM reporting year, if a facility emitted 750kg of VOC from screen printing and 250kg of VOC from spot cleaning operations, the reported emission quantity would be 1,000kg (750kg + 250kg) of VOC for the reporting year. 

For the FEM, this methodology of reporting the combined total of the pollutant/pollutant group from all point sources is applied to all reported pollutants (e.g., VOC are reported as the total quantity of all VOC from all sources of emissions from production)

Volatile Organic Compounds (VOC)

VOC are defined as organic chemical compounds that under normal conditions are gaseous or can vaporise and enter the atmosphere. The general criteria for determining whether a pollutant is considered a VOC is provided below:

  • It contains carbon. 
  • Vapor Pressure is > or = 0.01 kPa (~0.075 mmHg) at 20C
  • Boiling point is < or = 250C at standard pressure of 101.3 kPa

Hazardous or Toxic Air Pollutants (HAP/TAP)

Are defined as compounds that are known or suspected to cause significant harmful impacts to human health or the environment.  

Country-specific regulation may define which air pollutants are designated as HAPs/TAPs within a specific jurisdiction. Where country-specific definitions or regulations do not define HAPs/TAPs, recognized lists from other jurisdictions may be referenced when determining if pollutants from production should be included in the reported quantity for HAPs/TAPs.  For example, information on HAPs from the US EPA can be found here https://www.epa.gov/haps. A current list of HAPs (as defined by the US EPA can be found here: https://www.epa.gov/haps/initial-list-hazardous-air-pollutants-modifications 

Calculating Annual Air Emissions Quantities from Production:

Note: The methodology used to calculate emissions from each source should be selected and applied by qualified individuals such as a process or environmental engineer who understand the technical principles and methodologies for determining emissions from production sources including point source and fugitive emissions sources.

There are several methodologies and techniques that can be used to calculate emission quantities of pollutants from production. These can include:

  • Direct Measurement or Sampling – Through the use of continuous emission monitoring systems (CEMS) or testing results that are used to calculate annual emission quantities based on the sources operating parameters (e.g., operating time, flow rate, pollutant emission rates, etc).
  • Engineering Calculations – That utilizes established emission factors for specific chemicals/pollutants, equipment, or processes. 
  • Mass Balance/Potential to emit (PTE) – That uses the known or estimated content of pollutants in the chemicals used and the consumption data or purchased volume of the chemicals to calculate emission quantities for specific pollutants.

To calculate the annual emissions from point sources, there are several critical pieces of information that must be known. This can depend on the specific methodology used to calculate emissions, however these typically include the following for each point source:

  • Air flow rate of the source (e.g., m3/hr)
  • Operating time in the reporting year (e.g., hrs)
  • Emission concentration - from direct measurements or emission factors (e.g., kg/m3)

Once these are known the basic equation is as follows:

  • Emission Quantity = emission concentration x air flow x operating time 

If sources have control technologies installed (e.g., scrubbers, activated carbon filtration, dust collectors, regenerative thermal oxidizers, etc), the pollutant destruction or removal efficiency of the control technology can be factored into the emissions calculations. For example, if 1,000 kg of VOC was emitted from a source and the exhaust stack was fitted with a thermal oxidizer which has a 90% removal/destruction efficiency, the calculated quantity of VOC emitted would be 100kg (1,000kg x 10%).

To calculate the annual emissions from fugitive emissions (e.g., emissions that are not emitted through a fixed exhaust stack), different methodologies are often required. Some examples of how emissions can be determined from fugitive sources are provided below:

  • Potential to Emit (PTE)
    • Potential to Emit calculation uses the inventory of process chemistry purchased to calculate the maximum amount of pollutants that could be emitted from that facility.  
    • For example, if 500kg of IPA was purchased, 500kg of IPA could potentially be emitted to the air.  This is generally a very conservative assumption and gives the maximum potential emissions for the pollutant from the facility.
  • Mass Balance
    • Emissions may be calculated based on the amount of a particular chemical used annually and the chemicals composition (i.e., percentage of VOC content or individual pollutant of that chemical).
    • For example, if a total of 0.5m3 of acetone is used for spot cleaning on an annual basis and the density of acetone is 784 kg/m3.  The annual emission quantity of acetone would be 392 kg (0.5m3 x 784 kg/m3). 
    • Another example, if the VOC content in a chemical was 5g/L and the facility used 2,500L annually, the annual emission quantity of VOC for this chemical would be 12,500g (or 12.5kg) (2,500L x 5g/L)

Note: To provide a conservative estimate when calculating emissions quantities from uncontrolled fugitive sources, it is often estimated that 100% of the volatile pollutants will be emitted to the environment. If a percent composition range is provided (i.e., on and SDS) the upper part of the range should be used.

Do:

  • Review source data (e.g., records of chemical consumption, emission factors, operating time, flow/emission rates, etc.) to ensure calculated emission total are accurate.
  • Ensure the most recent and updated versions of data tracking spreadsheets are being used and that all automated calculations/formulas are correct.
  • Ensure the proper units are reported and verify any unit conversions from source data to reported data.
  • Review any assumption or estimation methodology/calculations to ensure accuracy.
  • Report the proper tracking method in the FEM (e.g., Estimated if annual emissions are calculated using emission factors, or measured if using continuous emission monitoring systems (CEMS)).

Do Not:

  • Report data that is not accurate (e.g., the data source is unknown or has not been verified).
  • Report estimated data if it is not supported by verifiable and reasonably accurate estimation methodology and data (e.g., emission factors, fuel consumption, or other engineering calculations).

Resources:

Several publicly available resources that contain examples of the methodologies and information required to calculate emission sources are provided below. 

Note:  The emissions calculation methods and information (e.g., emission factors) in these resources are provided for reference and may contain regulatory requirements that do not apply to your facility. If country specific calculation methodologies (e.g., emission factors, fuel composition data, etc) are available, they should be used when calculating your facility’s emissions. 

Airproduction Verification And Scoring

How This Will Be Verified:

When verifying a facility’s air emissions data, Verifiers must review all aspects of the facility’s emissions tracking and reporting program that could produce inaccuracies including:

  • Emissions data sources (e.g., testing reports, emission factors, emissions calculation methodology or other engineering estimates); and
  • The process and tools used to aggregate the data (e.g., spreadsheet calculations, unit conversions, etc.)

If any inconsistencies or errors are noted, the reported information must be corrected where possible and detailed comments should be included in the Verification Data field.

Full Points:

Documentation Required:

  • Documentation that supports emission reporting calculations and methodology for all emission sources from production (point source and fugitive sources) and the applicable pollutant(s). This may include:
    • Annual emission inventory with quantities of applicable pollutants
    • Spreadsheets or other documentation showing emission calculations including:
      • Emission source operational data (i.e., operating time, air flow rates). 
      • List of emission factors and/or other assumptions used in emissions calculations.
      • Records of chemical consumption and composition used for emissions calculations.
      • Emission testing results used to determine emission rates from sources.

Note: If the facility utilizes a third-party service provider to calculate emission quantities, documentation to support the data and methodology used should be made available for verification.

Interview Questions to Ask:

  • Staff responsible for reporting the facility’s emission data is knowledgeable and can explain how source data (e.g., pollutants, operating time, emission source flow rate, etc) is identified and collected and the methodology used to calculate emissions.

Inspection - Things to Physically Look For: 

  • All emission sources and potential pollutants from production are properly identified and this is consistent with onsite observations of the facility’s production emission sources.

Partial Points: N/A

Airreduce

10. Has your facility established an implementation plan to reduce air emissions from facility operations? (Ref ID: airreduce)

Answer Yes if: Your facility has a current documented plan with defined actions that your facility is planning to implement to reduce the quantity of pollutants emitted from emissions sources related to facility operations (e.g., boilers, generators, combustion heating, etc) 

If you answer Yes, you will be asked the following sub questions:

  • What control devices, process modifications, or raw material/fuel/equipment substitutions will be implemented to reduce air emissions?
  • Which pollutants are targeted for reduction?
  • Please upload your plan.

Suggested Uploads

  • A copy of the implementation plan that includes details of the specific actions the facility plans to take to reduce air emissions from facility operations equipment (e.g., boilers, generators, etc) with implementation timelines.
  • Emissions specifications or calculated emissions reduction estimates from proposed new equipment or alternative fuel sources included in the implementation plan.
  • Specifications (e.g., pollutant destruction/removal efficiency) of control devices that are included in the implementation plan.

What is the intent of the question?

The intent of this question is for facilities to demonstrate that they have identified and evaluated emission reduction opportunities and have established formal plans with defined actions to reduce air emission from facility operations.  

Technical Guidance

Creating an implementation plan includes the process of reviewing and evaluating available options to reduce air emissions. The key steps of creating an implementation plan should include the following:

  • Identify emission reduction opportunities through internal assessment by qualified personnel or third-party experts.
  • Evaluate reduction options to determine the most suitable options (e.g., feasibility studies, cost benefit analyses) 
  • Approve funds/budget for chosen options.
  • Create a timeline and define the actions needed to implement the solution and realize reductions.
  • Conduct regular reviews of the implementation plan check on progress.

Emissions from facility operations can be reduced in several ways including the following:

  • Installation of control equipment (e.g., scrubbers or catalytic reduction systems on exhaust stacks etc)
  • New technology or equipment modifications (e.g., upgrading to a new boiler that produces cleaner emissions) 
  • Alternative fuel inputs (e.g., switching to a natural gas boiler from a coal-fired boiler)

When evaluating options to reduce emissions, priority should be given to utilizing the Best Available Technology (BAT), which may include any, or a combination of the above listed methods depending on the emission source.   For the definition of BAT in the FEM, please refer to the introduction section of this guidance.

Resources:

Several publicly available resources that contain examples and guidance on emission control techniques and an implementation plan template are provided below. 

  • Best Available Techniques (BAT) Reference Document for Large Combustion Plants

https://publications.jrc.ec.europa.eu/repository/bitstream/JRC107769/jrc107769_lcp_bref2017(1).pdf 

Airreduce Verification And Scoring

How This Will Be Verified:

Full Points:

Documentation Required:

  • An implementation plan that includes details of the specific actions the facility plans to take to reduce air emission from facility operations equipment (e.g., boilers, generators, etc) which may include including: 
    • Documentation of the emissions specifications or calculated emissions estimates from proposed new equipment or alternative fuel sources included in the implementation plan that show the expected emissions reductions.
    • Specifications (e.g., pollutant destruction/removal efficiency) of control devices included in the implementation plan.
    • Implementation timelines (i.e., the planned start and completion dates for actions listed in the plan). 

Notes: 

  • Actions to reduce pollutant quantities should not consider emission reductions due to reductions in production volume or equipment operating time as these factors will not result in sustainable improvements. 
  • If the facility has completed all actions in the plan prior to reporting year and does not have an implementation plan for reductions the reporting year and beyond, a No response should be selected (i.e., points are not awarded for historical plans that were implemented prior to the reporting year).

Interview Questions to Ask:

  • Staff responsible for the implementation plan can explain the facility’s process for evaluating emission reduction opportunities and the facility’s implementation plans and actions to reduce air emissions.

Inspection - Things to Physically Look For: 

  • The actions listed in the implementation plans directly relate to the observed facility operations sources onsite.

Partial Points: N/A

Airimplementation

11. Has your facility established an implementation plan to reduce air emissions from production processes? (Ref ID: airimplementation)

Answer Yes if: Your facility has a current documented plan with defined actions that your facility is planning to implement to reduce the quantity of pollutants emitted from emissions sources related to production processes (e.g., solvent/adhesive use, printing, dyeing, etc.) 

If you answer Yes, you will be asked the following sub questions:

  • What control devices, process modifications, or raw material/fuel/equipment substitutions will be implemented to reduce air emissions?
  • Which pollutants are targeted for reduction?
  • Please upload your plan.

Suggested Uploads

  • A copy of the implementation plan that includes details of the specific actions the facility plans to take to reduce air emissions from production emissions with implementation timelines.
  • Emissions specifications or calculated emissions reduction estimates from proposed new equipment, process modifications, raw materials substitutions or control devices included in the implementation plan.
  • Specifications (e.g., pollutant destruction/removal efficiency) of control devices included in the implementation plan.

What is the intent of the question?

The intent of this question is for facilities to demonstrate that they have identified and evaluated emission reduction opportunities and have established formal plans with defined actions to reduce air emission from facility production.  

Technical Guidance

Creating an implementation plan includes the process of reviewing and evaluating available options to reduce air emissions. The key steps of creating an implementation plan should include the following:

  • Identify emission reduction opportunities through internal assessment by qualified personnel or third-party experts.
  • Evaluate reduction options to determine the most suitable options (e.g., feasibility studies, cost benefit analyses) 
  • Approve funds/budget for chosen options.
  • Create a timeline and define the actions needed to implement the solution and realize reductions.
  • Conduct regular reviews of the implementation plan check on progress.

Emissions from facility operations can be reduced in several ways including the following:

  • Installation of control equipment (e.g., dust collectors/baghouse filtration systems, wet scrubbers, activated carbon filtration, regenerative thermal oxidizers (RTO), etc.). 
  • New technology or equipment modifications (e.g., alternative dyeing/printing technologies, installation of local ventilation systems equipped with additional controls to capture and treat emissions).
  • Alternative raw material inputs (e.g., chemicals substitutions for less hazardous alternatives, using water-based chemistries or chemicals with a lower VOC content)

When evaluating options to reduce emissions, priority should be given to utilizing the Best Available Technology (BAT), which may include any, or a combination of the above listed methods depending on the emission source and process.   For the definition of BAT in the FEM, please refer to the introduction section of this guidance. 

Resources:

Several publicly available resources that contain examples and guidance on emission control techniques and an implementation plan template are provided below. 

Airimplementation Verification And Scoring

How This Will Be Verified:

Full Points:

Documentation Required:

  • An implementation plan that includes details of the specific actions the facility plans to take to reduce air emission from production emissions (e.g., printing/dyeing or other finishing processes, application of chemicals such as solvent or adhesives, etc.) which may include including: 
    • Documentation of the emissions specifications or calculated emissions estimates from proposed new equipment or alternative raw materials included in the implementation plan that show the expected emissions reductions.
    • Specifications (e.g., pollutant destruction/removal efficiency) of control devices included in the implementation plan.
    • Implementation timelines (i.e., the planned start and completion dates for actions listed in the plan). 

Notes: 

  • Actions to reduce pollutant quantities should not consider emission reductions due to reductions in production volume or equipment operating time as these factors will not result in sustainable improvements. 
  • If the facility has completed all actions in the plan prior to reporting year and does not have an implementation plan for reductions the reporting year and beyond, a No response should be selected (i.e., points are not awarded for historical plans that were implemented prior to the reporting year).

Interview Questions to Ask:

  • Staff responsible for the implementation plan can explain the facility’s process for evaluating emission reduction opportunities and the facility’s implementation plans and actions to reduce air emissions.

Inspection - Things to Physically Look For: 

  • The actions listed in the implementation plans directly relate to the observed production emission sources onsite.

Partial Points: N/A

Airmonitorscore

Are you monitoring or reporting against any industry guidelines or tools for air emissions (additional to the legal requirement)? (Ref ID: airmonitorscore)

Note:  This response to this Level 2 question will be pre-populated based on the response to this question in Level 1. The Level 1 question is unscored, and scoring will be applied in Level 2 as follows:

  • Full Points will be awarded for a Yes response.
  • No Points will be awarded for a No response.

Airmonitorscore Verification And Scoring

How This Will Be Verified:

This question will be verified in accordance with the criteria set forth in the Level 1 question (Question 7).

Airindustryreq

12. Are you meeting / conforming to the requirements of the industry guideline(s) on air emissions?   (Ref ID: airindustryreq)

Note:  This question will only be applicable to facilities that have a Yes response to the question: Are you monitoring or reporting against any industry guidelines or tools for air emissions (additional to the legal requirement)? 

Answer Yes if: Your facility is meeting all the requirements of the industry guideline you are reporting against. This must include all testing and emission limit criteria.

If you answer Yes and are reporting against a ZDHC guideline, you will be asked the following sub question:

  • which level of air performance have you achieved:
    • Level 1: Foundational
    • Level 2: Progressive
    • Level 3: Aspirational

Suggested Uploads

  • Copies of emissions calculations or reporting, and any emission testing that demonstrates the facility is meeting the requirements of the guideline.
  • ZDHC Supplier Platform- MMCF Module certificate

What is the intent of the question?

The intent of this question is for facilities to demonstrate that they are meeting all of the requirements of industry developed guidance or tools that go beyond basic legal compliance monitoring and reporting.

Technical Guidance

Different guidelines or tools may have different requirements for monitoring and reporting of air emissions (e.g., the type and frequency of emission reporting, types of pollutants that must be monitored/reported, emission calculation or testing methodologies and frequencies, etc.) To demonstrate a facility is meeting these requirements, facilities should have procedures in place to determine the monitoring and reporting requirements that apply to their operations and meet the required monitoring and reporting requirements. 

Supporting documentation that shows the facility is meeting these requirements such as emissions calculations/reports, testing results should be maintained.  

Examples of industry guidance/tools for air emissions are the ZDHC Air Position Paper/Guidelines and the ZDHC MMCF Air Emissions Guidelines of the ZDHC MMCF Guidelines.  Both of these guidance documents can be found and downloaded here https://www.roadmaptozero.com/output

Airindustryreq Verification And Scoring

How This Will Be Verified:

Full Points:

Documentation Required:

  • Documentation that demonstrates the facility is monitoring and reporting air emissions in accordance with the applicable guidelines/tools. This may include:
    • Air emissions inventory or report with reported emission quantities or emission rates that show compliance with the limits in the guideline.
    • Air emissions calculation methodology and supporting documentation (e.g., facility operating data, consumption quantities of chemicals and/or fuels emission factors or assumptions used for determining the emitted quantity of specific pollutants, etc)
    • ZDHC Supplier Platform- MMCF Module certificate

Note – Required documentation may vary by guideline or tool being reported against. All air emission reporting documentation required by the standard should be available for verification. 

Interview Questions to Ask:

  • Staff responsible for managing air emissions understand and can describe the monitoring and reporting requirements of the guidelines/tools the facility is reporting emissions against and be able to explain the facility’s procedures for meeting the requirements of the guideline/tool.

Inspection - Things to Physically Look For: 

  • The relevant emission sources observed at the facility are included in the facility’s emissions monitoring/reporting procedures as required by the guideline or tool used to report emissions.

Partial Points:

  • Partial Points will be awarded for facilities who are reporting against a ZDHC Guideline and meeting the Foundational Limits.

Airreplace

13. Do you have a plan to or have you already replaced your current refrigerant with low ODP / low GWP refrigerant gasses that goes beyond current legal requirements? (Ref ID: airreplace)

Answer Yes if: Your facility has replaced or has an established plan to replace one (1) or more refrigerants with refrigerants/coolants with a lower Ozone Depletion Potential (ODP) and Global Warming Potential (GWP) that is not currently required by local law. 

Notes: 

  • The intent of this question is that both ODP and GWP of the refrigerant/coolant are reduced. If the alternative refrigerant/coolant has a higher ODP or GWP, you should answer No to this question.
  • If your plan is to only comply with legal requirements with regard to the phase out or substitution of refrigerants, you should answer No this question.

Suggested Uploads

  • Documentation that shows refrigerants have been replaced with alternative refrigerant gases that have a lower ODP and GWP (e.g., refrigerant purchase receipts, maintenance logs)
  • The documented replacement plan with timelines for replacement of current refrigerants.
  • The referenced ODP and GWP data that was used to determine that the alternative refrigerants used, or planned to be used, have lower ODP and GWP values.

What is the intent of the question?

The intent of this question is for facilities to go beyond current legal requirements to replace refrigerant gases used onsite with alternative refrigerant/coolants that have a reduced impact on the environment.

Technical Guidance

Country specific regulations may be implemented to support national commitments to international treaties (e.g., the Montreal Protocol) on the phase out of ozone depleting substances (ODS) such as those commonly found in refrigerants used for cooling devices or air conditioning equipment. To proactively support this, facilities should have a clear understanding of the refrigerants used onsite and any current applicable regulatory requirements with regards to their phase out. Facilities should also be taking steps to eliminate the use of these in advance of any regulatory requirements to do so.

When planning to proactively phase out refrigerants, facilities can do the following:

  • Establish procedures to stay current on applicable regulatory requirements for the   phase out of ODS/refrigerants.
  • Identify which refrigerant(s) are used onsite that are targeted for future phase out.
  • Establish plans with defined actions to phase out targeted refrigerants before the onset of regulatory requirements for phase out.  

Where it is not required by local regulations or not possible to discontinue the use of harmful refrigerants completely, environmental impact can be reduced by switching to alternative refrigerants that have lower Ozone Depletion Potential (ODP) and Global Warming Potential (GWP) or alternative coolants. For example, HCFC-22, commonly known as R-22 (ODP0.05, GWP 1,810) can be replaced with a refrigerant gas with a lower ODP and GWP such as R-134a (ODP 0, GWP 1,430) or R134a can be replaced with R-32 (ODP 0, GWP 675).

In some cases, alternative refrigerant gases can be directly used in equipment, and in other cases the equipment may need to be retrofitted to be able to operate with different refrigerant gases. When evaluating an alternative refrigerant for use or retrofitting a system, facilities should follow the manufacturer’s suggested handling and installation guidelines and also consider possible impacts on the system’s energy consumption. 

Resources:

Several publicly available resources that contain information on replacing refrigerants with preferred alternatives are provided below. 

Note:  Information in these resources is provided for reference and may contain regulatory requirements that do not apply to your facility (e.g., country specific phase out requirements or approved alternatives). If country specific requirements or information are available, it should be referenced when considering the phase out or substitution of refrigerants.

EU Climate-friendly alternatives to HFCs https://climate.ec.europa.eu/eu-action/fluorinated-greenhouse-gases/climate-friendly-alternatives-hfcs_en

Airreplace Verification And Scoring

How This Will Be Verified:

Full Points

Documentation Required: 

  • Documentation that shows one (1) or more refrigerants have been phased out or replaced with alternative refrigerant gases that have a lower ODP and GWP (e.g., refrigerant purchase receipts, maintenance logs) that are not already required to be phased out/replaced per local regulatory requirements.
  • The referenced ODP and GWP data that was used to determine that the alternative refrigerants used, or planned to be used, have lower ODP and GWP values.
  • If the facility has not replaced current refrigerants used onsite, but has an established plan to replace one (1) or more refrigerants, the plan should include:
    •   List of refrigerants to be phased out/replaced with a list of the alternative refrigerants to be used, where applicable. 
    • A defined timeline for phase out/replacement of current refrigerants that shows the facility is planning to phase out/replace the refrigerant before they are legally required to do so.

Interview Questions to Ask: 

  • Staff responsible for managing refrigerant use at the site should be able to explain any refrigerant replacement that has taken place or the facility’s plan for refrigerant replacement.  

Inspection - Things to Physically Look For: 

  • All reported refrigerant replacements or replacement plans are consistent with observations of the refrigerant containing equipment onsite.

Partial Points:  N/A

Airpolicies

14. Does the facility have business policies or procedures in effect that ensure that all Best Available Technologies (BAT) for air emissions reductions are considered in the long-term environmental plans of the facility? (Ref ID: airpolicies)

Answer Yes if: Your facility has documented business policies or procedures in place to evaluate and plan for the implementation of BAT to reduce air emission from the facility. This must cover all emission sources (e.g., facility operations and production sources).

Suggested Uploads

  • Copies of your business policies or procedures to evaluate and plan for the implementation of BAT to reduce air emission.
  • If available, documentation to show that the policies/procedures are being followed (e.g., records of evaluation of BAT, proposals/quotations or equipment specifications for technologies being considered, proposed emission reductions resulting from the evaluated technologies, etc)

What is the intent of the question?

The intent of this question is to encourage facilities to establish business practices to evaluate and plan for the implementation of BAT to reduce air emissions from the facility.

Technical Guidance

In the FEM, the concept of Best Available Technology (BAT) is defined as the most effective and advanced technology including materials, processes, and equipment that is currently available that will result in reduction of pollutants emitted and minimizing impacts to the environment. This is further defined as follows:

  • Best in relation to technology means the most effective method in achieving a high level of protection of the environment. 
  • Available means technology that is developed on a scale that allows for economically and technically viable implementation taking into consideration the costs and benefit and that the technology reasonably accessible to the business carrying on the activity regardless of whether the technology is developed or widely implemented locally.
  • Technology refers to materials, processes, and equipment, and the way it is designed, built, maintained, operated.

Procedures for evaluating BAT should be incorporated into the facility’s environmental management system which focuses on reducing impacts on the environment and be included as part of the ongoing review of environmental impacts and technology to reduce them.

The adoption of BAT often requires actions such as process/equipment modifications, the installation of control equipment, research into alternative raw material/chemical inputs that requires long term planning and capital allocation.   Facilities should have processes in place to stay up to date with emerging technologies and regularly review these to determine viable options for both new and existing emission sources to determine the most effective means to reduce the emissions to the air. These evaluations should be included in the long-term planning to reduce emissions.

Additionally, the adoption of BAT often depends on the specific operations, emission source and pollutant characteristics at a facility. For example:

  • In some cases, the most effective current solution for reducing particulate emission may be an Electrostatic precipitator (ESP) and in other cases a form of wet scrubbing or cyclone filtration may be more effective. 
  • In some cases, the most effective current solution for reducing emission of organic compounds (e.g., formaldehyde) may be substitution for an alternative chemical input or the use of a control technology such as thermal oxidation.

Evaluation of BAT must be conducted by qualified professionals such as process or environmental engineers who understand the facility’s emissions and pollutant characteristics (e.g., pollutant loading, emission source operational parameters such as temperature and moisture content, etc) and the design and operational characteristics of any controls or alternative technologies being evaluated in order to determine potential air emission reductions through engineering estimates or other air emission calculation methodology.

Note: In some countries, requirements to adopt BAT or procedures to determine BAT may be defined by local regulations or directives, which should be complied with, however facilities should strive to conduct a detailed evaluation of all available technologies to reduce environmental impacts to the lowest achievable level. 

Resources:

Resources that include guidance on the determination of selection of BAT as well as examples of BAT are provided below.

Note - The resources below are provided for reference only. Facilities are expected to understand and comply with any applicable local regulations related to the determination of BAT for control of emission to air.

Airpolicies Verification And Scoring

How This Will Be Verified:

Full Points:

Documentation Required:

  • Business policies or procedures to evaluate and plan for the implementation of BAT to reduce air emissions including all facility operations and production sources of emissions. These processes must be considered and included in the facility’s long term environmental plans (e.g., 3–5-year environmental strategy)
    • Procedures should include processes for environmental reviews of existing or any new operations at the facility (e.g., new production processes or equipment, new raw material/chemical inputs, etc.) and include an evaluation of BAT with regards to reducing emission to air 
    • Procedures must define the timeline and scope for these reviews. Note that the frequency and scope can be established by the facility but should not exceed three years and should cover all significant emission sources at the facility (i.e., both operational sources (e.g., boilers, generators) and production related emission sources) 
  • Supporting documentation to show that the policies/procedures are being followed (e.g., records of evaluation of BAT for new or existing operations, proposals/quotations or equipment specifications for technologies being considered, proposed emission reductions resulting from the evaluated technologies, etc)

Interview Questions to Ask:

  • Staff responsible for the facility’s environmental management system and other relevant staff involved in the implementation of procedures related to environmental planning and evaluation of BAT can explain the facility’s planning and review process for evaluating BAT to reduce air emissions.

Inspection - Things to Physically Look For: 

  • Emissions sources observed onsite are included in the facility’s procedures to review and plan for the adoption of BAT. 

Partial Points: N/A

 

 

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