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FEM 2024 - Air Emissions Level 3

  • Updated

Table of Contents

  1. Airplan
  2. Airplan Verification And Scoring
  3. Airprogress
  4. Airprogress Verification And Scoring
  5. Airreplacelegal
  6. Airreplacelegal Verification And Scoring
  7. Airtech
  8. Airtech Verification And Scoring

Airplan

15. Has your facility made progress on your implementation plan to reduce air emissions from facility operations in the reporting year? (Ref ID: airplan)

Answer Yes if: Your facility has an established implementation plan to reduce air emissions from facility operations sources (e.g., boilers, generators, etc) and has completed one (1) or more actions on the plan to reduce air emissions in the reporting year.

Note: A Yes response can be provided for this question if the facility is able to demonstrate that they have implemented the best available control technologies (BAT) for all significant source of emission to air from facility operations and the facility is:

  • Operating/maintaining equipment and control devices, where applicable in accordance with manufacturers recommendations.
  • Consistently implementing the BAT in daily operations.

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

  • Describe the actions completed in the reporting year.

Suggested Uploads

  • Supporting evidence to demonstrate the actions implemented which may include:
    • Emissions specifications (e.g., pollutant destruction/removal efficiency) of control devices or new/modified equipment installations. 
    • Evidence of fuel substitutions (e.g., purchase or consumption records)
    • Emissions specifications or calculated emissions reduction estimates from actions or alternative fuel sources that show emissions have been reduced.
  • Supporting evidence to demonstrate BAT adopted at the facility for facility operations is being operated/maintained in accordance with manufacturers recommendations (e.g., maintenance schedules/inspection records, operating parameter monitoring, manufacturers specifications for operation and maintenance)

What is the intent of the question?

The intent of this question is for facilities to demonstrate that they have made progress (i.e., implemented actions) on their implementation plans to reduce air emission in the reporting year OR that the facility has implemented BAT for facility operations emission sources and are operating/ maintaining these appropriately. 

Technical Guidance

In the FEM, making progress on your implementation plan means that the facility has completed one (1) or more of the actions listed in their implementation plan to reduce the amount of pollutants emitted to the air in the reporting year. 

The FEM does not specify the types of actions that need to be completed as these can vary by facility and emission source type, however the actions should result in demonstrable reductions in air emissions. This should be demonstrated through emissions calculations or engineering estimates that demonstrate the implemented actions have or will result in the reduction of pollutants emitted to the air from facility operations sources at the facility.

Note: 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. 

Facilities that have implemented BAT should ensure that the technologies implemented are properly maintained and monitored. For example, if a facility has determined the use of a natural gas boiler with flue gas recirculation or low NOx burners is the BAT for reducing NOx emissions, there should be processes in place to maintain and monitor these controls to ensure that the equipment is operating effectively. Typically recommended operation conditions and maintenance requirements will be provided in the equipment manufacturers specifications. Similarly, if a facility is operating a coal fired boiler and has determined that a wet limestone scrubber to reduce SO2, particulate and acid gases is the BAT, the same monitoring and maintenance procedures outlined above should be applied. 

Resources:

Several publicly available resources that contain examples and guidance on emission control techniques and BAT are provided below. 

Airplan Verification And Scoring

How This Will Be Verified:

Full Points:

Documentation Required:

  • Supporting documentation that demonstrates that one (1) or more actions were implemented which may include:
    • Emissions specifications (e.g., pollutant destruction/removal efficiency) of control devices or new/modified equipment installations. 
    • Evidence of fuel substitutions (e.g., purchase or consumption records)
    • Calculated emissions reduction estimates from actions or alternative fuel sources that show emissions have been reduced.
  • Supporting documentation to demonstrate BAT implemented at the facility for facility operations is being operated/maintained in accordance with manufacturers recommendations (e.g., maintenance schedules/inspection records, operating parameter monitoring, manufacturers specifications for operation and maintenance)

Note: Full points will be provided for this question if the facility is able to demonstrate that they have implemented the best available control technologies (BAT) for all significant source of emission to air from facility operations and the facility is:

  • Operating/maintaining equipment and control devices, where applicable in accordance with manufacturers recommendations.
  • Consistently implementing the BAT in daily operations.

Interview Questions to Ask:

  • Staff responsible for implementing the action(s) to reduce emissions to air or operating/maintaining BAT are able to describe the action(s) taken. 

Inspection - Things to Physically Look For: 

  • The actions reported directly relate to the observed facility operations sources onsite.

Partial Points: N/A

Airprogress

16. Has your facility made progress on your implementation plan to reduce air emissions from production processes in the reporting year? (Ref ID:airprogress)

Answer Yes if: Your facility has an established implementation plan to reduce air emissions from production sources and has completed one (1) or more actions on the plan to reduce air emissions in the reporting year.

Note: A Yes response can be provided for this question if the facility is able to demonstrate that they have implemented the best available control technologies (BAT) for all significant source of emission to air from production processes and the facility is:

  • Operating/maintaining equipment and control devices, where applicable in accordance with manufacturers recommendations.
  • Consistently implementing the BAT in daily operations.

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

  • Describe the actions completed in the reporting year.

Suggested Uploads

  • Supporting evidence to demonstrate the actions implemented which may include:
    • Emissions specifications (e.g., pollutant destruction/removal efficiency) of control devices or new/modified equipment installations. 
    • Evidence of raw material or chemical substitutions (e.g., purchase or consumption records)
    • Emissions specifications or calculated emissions reduction estimates from actions or alternative raw materials/chemicals that show emissions have been reduced.
  • Supporting evidence to demonstrate BAT adopted at the facility for production process is being operated/maintained in accordance with manufacturers recommendations (e.g., maintenance schedules/inspection records, operating parameter monitoring, manufacturers specifications for operation and maintenance)

What is the intent of the question?

The intent of this question is for facilities to demonstrate that they have made progress (i.e., implemented actions) on their implementation plans to reduce air emission in the reporting year OR that the facility has implemented BAT for facility production sources and are operating/maintaining these appropriately. 

Technical Guidance

In the FEM, making progress on your implementation plan means that the facility has completed one (1) or more of the actions listed in their implementation plan to reduce the amount of pollutants emitted to the air in the reporting year.

The FEM does not specify the types of actions that need to be completed as these can vary by facility and emission source type, however the actions should result in demonstrable reductions in air emissions. This should be demonstrated through emissions calculations or engineering estimates that demonstrate the implemented actions have or will result in the reduction of pollutants emitted to the air from production processes sources at the facility.

Note: 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. 

Facilities that have implemented BAT should ensure that the technologies implemented are properly maintained and monitored. For example, if a facility has determined the BAT for reducing VOC emission from the screen-printing process is channelling all emission through a local ventilation system that is fitted with activated carbon adsorption, there should be processes in place to maintain and monitor these controls to ensure that the equipment is operating effectively (e.g., ventilation capture/flow rates, carbon change out schedules, etc). Typically recommended operating conditions and maintenance requirements will be provided in the equipment manufacturers specifications.  Similarly, if a facility has determined a wet scrubber to reduce Ammonia (NH3) from coating or finishing emissions is the BAT, the same monitoring and maintenance procedures outlined above should be applied. 

Resources:

Several publicly available resources that contain examples and guidance on emission control techniques and BAT are provided below. 

Airprogress Verification And Scoring

How This Will Be Verified:

Full Points:

Documentation Required:

  • Supporting documentation that demonstrates that one (1) or more actions were implemented which may include:
    • Emissions specifications (e.g., pollutant destruction/removal efficiency) of control devices or new/modified equipment installations. 
    • Evidence of raw material or chemical substitutions (e.g., purchase or consumption records)
    • Calculated emissions reduction estimates from actions or alternative raw materials/chemicals that show emissions have been reduced.
  • Supporting documentation to demonstrate BAT implemented at the facility for production emissions is being operated/maintained in accordance with manufacturers recommendations (e.g., maintenance schedules/inspection records, operating parameter monitoring, manufacturers specifications for operation and maintenance)

Note: Will be provided for this question if the facility is able to demonstrate that they have implemented the best available control technologies (BAT) for all significant source of emission to air from production processes and the facility is:

  • Operating/maintaining equipment and control devices, where applicable in accordance with manufacturers recommendations.
  • Consistently implementing the BAT in daily operations.

Interview Questions to Ask:

  • Staff responsible for implementing the action(s) to reduce emissions to air or operating/maintaining BAT are able to describe the action(s) taken. 

Inspection - Things to Physically Look For: 

  • The actions reported directly relate to the observed production emission sources onsite.

Partial Points: N/A

Airreplacelegal

17. Have you replaced your current refrigerant with low ODP / low GWP refrigerant gasses that goes beyond current legal requirements?  (Ref ID: airreplacelegal)

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

Notes: 

  • If you have answered Yes to question 14 on the basis that you have already replaced one (1) or more refrigerants with alternative refrigerants/coolants, you should select Yes.
  • The intent of this question is that both ODP and GWP of the refrigerant/coolant are reduced. If the replacement 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 select No.

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 referenced ODP and GWP data that was used to determine that the alternative refrigerants 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 refrigerants/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.

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.

Airreplacelegal 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.

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.  

Inspection - Things to Physically Look For: 

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

Partial Points:  N/A

Airtech

18. Have you utilized the best available technology (BAT) for the major air emissions from your facility?  (Ref ID: airtech)

Answer Yes if: Your facility has conducted a review of the best available control technology (BAT) and implemented the BAT for all significant emission sources at the facility. This must cover all of the facility’s major emission sources from both facility operations and production sources.

Note: Significant emissions sources are defined as the sources at the facility that are determined to be the most significant contributors to facility emissions as determined by a formal evaluation and review of facility emissions/sources by a qualified individual.

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

  • Describe the technology currently being utilized.
  • Please upload supporting documentation if available.

Suggested Uploads

  • Documentation of the BAT evaluations for each source that identifies the BAT for each emission source which may include:
    • Equipment/emission specifications for technologies considered.
    • Alternative raw material/fuel/chemical inputs evaluated.
    • The estimated/calculated emissions of the evaluated technologies used to determine BAT. 
  • Supporting evidence to demonstrate that the BAT has been implemented for all emission sources which may include: 
    • Photos of control technologies or new/modified equipment installations, 
    • evidence of raw material or chemical substitutions (e.g., purchase or consumption records)
    • Calculated emissions after BAT implementation to confirm emission reductions have been achieved.
    • Documentation to demonstrate BAT implemented at the facility is being operated/maintained in accordance with manufacturers recommendations (e.g., maintenance schedules/inspection records, operating parameter monitoring, manufacturers specifications for operation and maintenance)

What is the intent of the question?

The intent of this question is for facilities to demonstrate that they have implemented BAT to minimize emissions to air from all significant emissions sources at 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.

Evaluation of BAT to determine the most effective solutions 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.

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.

BAT is also something that can evolve overtime. To ensure BAT is currently being used, facilities should have processes to conduct regular reviews of emerging technologies (e.g., alternative raw material/fuel/chemical inputs, process or emission control equipment) to ensure that current BAT is being used.

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.

Airtech Verification And Scoring

How This Will Be Verified:

Full Points:

Documentation Required:

  • Documented BAT evaluations that identify the BAT for each emission source which may include:
    • Equipment/emission specifications for technologies considered.
    • Alternative raw material/fuel/chemical inputs evaluated.
    • The estimated/calculated emissions of the evaluated technologies used to determine BAT. 
    • Note: BAT evaluations must be conducted at least every 3 years for each source. 
  • Supporting evidence to demonstrate that the BAT has been implemented for all emission sources which may include: 
    • Photos of control technologies or new/modified equipment installations, 
    • evidence of raw material or chemical substitutions (e.g., purchase or consumption records)
    • Calculated emissions after BAT implementation to confirm emission reductions have been achieved.
    • Documentation to demonstrate BAT implemented at the facility is being operated/maintained in accordance with manufacturers recommendations (e.g., maintenance schedules/inspection records, operating parameter monitoring, manufacturers specifications for operation and maintenance)

Interview Questions to Ask:

  • Staff responsible for implementing, operating, or maintaining BAT are able to describe the facility’s processes to ensure BAT is consistently used and all associated equipment is operated appropriately.  

Inspection - Things to Physically Look For: 

  • BAT implemented at the facility is consistently used and all associated equipment is operated appropriately.

Partial Points: N/A

 

 

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