The overall evaluation also considered fugitive emissions. A research and development team assisted in creating a series of analytical tests around the facility to determine if something was missed in closing the mass balance.
In certain areas of the facility, particularly around rotating equipment such as compressors and near the reactors and loading areas, air monitoring instruments recorded fugitive emissions (Figure 1). Checking that compressors were leak-tight became a part of routine maintenance, as did monitoring piping around the machinery for vibration, which could result in additional leak points at certain piping-to-equipment connections.
"It is important to note that when you are trying to detect process leaks at these extraordinarily low values, even wind direction can be an important factor. The tests were repeated over a range of different environmental conditions, including time of day and various ventilation conditions," Kourpas adds.
Today, the Hometown plant reviews NF3 emissions monthly to ensure its GHG target is achieved. In addition, periodic fugitive emission testing will occur — perhaps annually at first, with data collected determining the frequency going forward.
The Ulsan facility has started a similar GHG reduction program in the past fiscal year, particularly to help prevent venting losses.
On a broader level, Air Products has implemented LDAR programs at multiple locations in the U.S. to comply with several different regulatory requirements. "In almost all cases, we partner with outside LDAR service contractors who are typically selected locally at the site level. We believe this to be the most successful approach in terms of performing the actual monitoring activities themselves, maintenance of leak inspection records in suitable databases, and preparation of necessary reports," says a spokesman.
ANOTHER CORPORATE INITIATIVE
Meanwhile, Solvay, Brussels, Belgium, has integrated its own emissions control strategies with those inherited from Rhodia following its 2011 takeover of that company.
"Sites located in countries where leak detection is regulated such as the U.S. and Europe and most of the big sites handling volatile compounds already report solid quantitative data regarding their fugitive emissions. The plan is to bring all sites to the same standards is terms of leakage rate assessment," says Solvay environmental expert Laurent Sapet.
The company has identified valve stems, flange and reactor gaskets, relief valves, rupture disks and loading/unloading arms as areas for specific focus.
"The strategy is to promote leak detection and repair on all sites and, in particular, those handling volatile and dangerous product such as substances of very high concern as defined in the European REACH directive. Our industrial department is already providing support to those sites willing to start an initiative in this field. It is planned to build a corporate policy supported by group guidance within the next two years," Sapet notes. The initiative could involve a global contract with specific suppliers for leak detection and repair, he adds.
Moves by the EPA are prompting other companies to act. Most recently, in a June 27 consent decree, EPA got BASF, Florham Park, N.J., to revise the emissions strategy for its Wyandotte, Mich., plant.