General Introduction
Air emissions from industrial processes and manufacturing operations have the potential to emit pollutants into the air that impact the environment, human health and contribute to climate change. As governments and industry stakeholders continue to focus on reducing environmental impacts, more stringent requirements and regulations may be imposed. By proactively managing and working to reduce impacts of your facility’s air emissions, you can reduce your exposure to regulatory risks or new requirements from business partners. In general, the Higg FEM Air Emissions section encourages you to:- Identify and understand the types of emission sources and pollutants that are emitted from your facility.
- Understand and comply with all applicable legal requirements relating to air emissions including all permitting, reporting, and testing requirements.
- Track and report emissions of key pollutants associated with facility operations and production.
- Evaluate, plan for, and adopt best available technologies (BAT) including materials, processes, and equipment to minimize emissions to air.
Air Emissions At Your Facility
Pollutants are typically emitting from the one of the following types of emission sources:
- Point Source: air flow which is actively controlled and directed (e.g., by fan and exhaust ducting) into the atmosphere from a single stationary fixed source such as stack or vent. Examples include boiler exhaust stack, the exhaust stack of a local ventilation system used to capture emissions from processes that emit volatile organic compounds (VOCs).
- Fugitive Emissions Source: for the Higg FEM, fugitive emission sources are those that are passively released into the outdoor environment and are not actively directed through a single exhaust point (e.g., stack or vent). Examples include screen printing, spot cleaning or dyeing areas with only general ventilation (e.g. passive sidewall ventilation or windows).
- Mobile Emissions Source: for the Higg FEM, mobile emission sources are those that are non-stationary sources of emission. Examples include powered motor vehicles (e.g., forklifts, trucks, passenger vehicles), heavy machinery (e.g., mobile cranes or lifts), small engines (e.g., landscaping equipment).
The Higg FEM also further categorizes emissions based on the nature of the emission source as follows:
- Emission from Facility Operations: for the Higg FEM, these include emissions from sources that support facility operations and are not the direct result of production processes. Emissions from facility operations are typically emitted through point source or mobile emissions sources. Examples include boilers, generators, heating and cooling systems (e.g., combustion heating, refrigerant-containing cooling equipment), and combustion engines.
Emissions from Production: for the Higg FEM, these include emissions from sources that are related to production processes. Emissions from production are typically emitted through point sources or as fugitive emissions. Examples include production processes that use chemicals (e.g., solvents, adhesives, printing, dyeing) processes that emit dust/particulates, products of combustion, or other hazardous or toxic air pollutants.
Reportable Pollutants in the FEM
The Higg FEM requires that facilities track and report emission data for refrigerants used onsite and several key pollutants listed below. Additional details on reporting pollutant quantities in the FEM are provided in the relevant questions.
| Pollutants Emitted from Operations | Pollutants Emitted from Production Processes |
| Particulate Matter Nitrogen Oxides (NOx) Sulfur Oxides (SOx) Carbon Monoxide (CO) Volatile Organic Compounds (VOC) or Total Organic Carbon (TOC) Hazardous or Toxic Air Pollutants (HAP/TAP) Ammonia (NH3) Ozone (O3) Ozone Depleting Substances (ODS) Carbon disulfide (CS2) Hydrogen sulfide (H2S) |
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
Best Available Technology (BAT)
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.
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.
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 planning and evaluation of available solutions 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.
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.
Air Emissions Data Quality
Accurately tracking and reporting air emissions data over time provides facilities and stakeholders with detailed insight into opportunities for improvement. If data is not accurate, this limits the ability to understand the facility’s air emissions and identify the specific actions that will help reduce environmental impacts.
When establishing an air emissions tracking and reporting program, the following principles should be applied:
- Completeness – The tracking and reporting program should include all emission sources.
- Accuracy – Ensure that the data input into the air emissions tracking program is accurate and is derived from credible sources (e.g., emissions testing/monitoring or emissions calculations are based on established scientific measurement principles or established emissions estimation methodologies, etc.)
- Consistency – Use consistent methodologies to track air emissions data that allows for comparisons of emissions over time. If there are any changes in the tracking methods, sources, or other operations that impact air emissions data, this should be documented.
- Transparency – All data sources (e.g., testing reports), assumptions used (e.g., estimation techniques), and calculation methodologies should be disclosed in data inventories and be readily verifiable via documented records and supporting evidence.
- Data Quality Management – Quality assurance activities (internal or external) should be defined and performed on air emissions data as well as the processes used to collect and track data to ensure reported data is accurate.
Applicability Questions
To determine which questions you will need to complete in the Air Emissions section, you will need to complete the applicability questions listed below. You will be asked to select which air-emitting equipment, processes, and potential pollutants you have on-site. Your selections will direct you to complete the questions that are most applicable for your facility. If you don’t have any facility air emissions from operations or production, you will not need to answer any additional questions in this section.
Notes:
- If you have air emissions from facility operations (e.g., boilers, generators), you will answer relevant questions about emissions to air from facility operations sources.
- If you have air emissions from production processes (e.g., solvents or adhesives), you will answer relevant questions about emissions to air from production sources.
1. Does your facility contain any of the following operations equipment?
- Boiler
- Generators
- Combustion Engines (e.g., gasoline powered pumps)
- Industrial Ovens (for heating/drying/curing)
- Heating and Ventilation (Combustion Heating (Furnace))
- Refrigerant containing device (other than air conditioning system)
- Air conditioning (Cooling)
- Other sources of known air emissions from facility operations
- Other sources of volatile organic compounds (VOCs)
2. Does your facility conduct any of the following processes or use any of the following substances?
- Yarn spinning or synthetic fiber manufacturing
- Finishes (i.e. any mechanical or chemical process that occurs after dying to affect the look, performance, or feel of the product)
- Solvents
- Adhesives/ cementing
- Printing
- Dyeing
- Tenterframes or other heating processes
- Spot cleaners (*Spot cleaners are chemicals used to remove contaminated spots from final products such as garments, bed covers, shoes etc. In many cases, acetone-based chemicals are used as spot cleaners. Spot cleaning activity may be done onsite during production processes, or a facility may have a dedicated room for spot cleaning.)
- Sprayed chemicals or paints
- Other sources of ozone depleting substances (ODSs)
- Other sources of particulate matter (PM)
- Other sources of volatile organic compounds (VOCs)
- Hazardous or Toxic Air Pollutants (HAPs/ TAPs)
3. Does your facility produce Man-made Cellulose Fibre (MMCF)?
- Yes should be selected only if your facility manufactures MMCF. Facilities that use MMCF to make final products should select No.
Air Emissions – Level 1
Answer Yes if: Your facility has a documented inventory of all point source emission sources at your facility including point sources from facility operations and production emission sources.
If you select Yes, you will be asked the following sub question(s):
- Does your facility’s point source air emissions inventory include the following information? Select all that apply.
- Unique source identifier (emission point name or number)
- Process or Equipment the source is linked to
- List of pollutants emitted from the source
- Legal or other emissions, testing or reporting requirements (ie. testing parameters and frequency), if applicable
- Control devices installed on the source, if applicable
- Note: The intent of this inventory item is to indicate the presence or absence of a control device for the source. If there is no control device for this source and this is indicated on the inventory, this option should be selected.
- Please upload a copy of the inventory
Suggested Uploads:
- A copy of the facilities inventory of point source air emission sources.
What is the intent of the question?
The intent of this question is for facilities to establish an inventory (i.e. a list) of all possible point sources of emissions to air on-site. This includes point sources from facility operations and production emissions. The intent is also for facilities to understand which pollutants are emitted or have the potential to be emitted from each point source.
Technical Guidance
An air emission source inventory is needed for facilities to identify, track, and manage emission sources onsite. To prepare a comprehensive inventory, all point sources of facility emissions from operations and production should be included. Regular review should be carried out to make sure the inventory is up-to-date and accurate. This inventory should include emissions sources regulated by permits as well as those not currently regulated.
Emission source inventories can contain varying levels of detail and information, however the following basic information should be included in the inventory
- Unique source identifier (emission point name or number)
- Process or Equipment the source is linked to.
- List of pollutants emitted from the source.
- Legal or other emissions, testing or reporting requirements (ie. testing parameters and frequency), if applicable
- Control devices installed on the source, if applicable
- Note: The intent of this inventory item is to indicate the presence or absence of a control device for the source. If there is no control device for this source and this is indicated on the inventory, this option should be selected.
An example inventory can be downloaded here: https://www.sumerra.com/wp-content/uploads/Air-Emissions-Inventory.xlsx
Examples of common sources of emission sources and pollutants that can be emitted through point sources are provided below. Note that this is not an exhaustive list and facilities may require the support of qualified environmental experts to identify air emission point sources and all potential pollutants emitted.
- Particulate Matter (PM) – e.g., from fuel combustion, yarn spinning, slashing, weaving, synthetic fiber manufacturing, casting
- Oxides of Sulphur and Nitrogen (SOx and NOx) – typically associated with fuel combustion.
- Volatile organic compounds (VOCs) – e.g., from fabric finishes, solvents, adhesives, fabric printing, tenterframes, degreasing operations.
- Ozone depleting substances (ODS) – commonly found in refrigerants, many apparel spot cleaners, and some adhesives and solvents.
- Ammonia (NH3) – e.g., from fabric finishing, tanning processes.
- Ozone (O3) – e.g., from denim finishing
- Carbon disulfide (CS2) – from Man-Made Cellulosic Fibres (MMCF) Production
- Hydrogen Sulfide (H2S) – from Man-Made Cellulosic Fibres (MMCF) Production
- Hazardous or toxic air pollutants (HAPs/TAPs) – e.g., from fuel combustion, solvents, adhesives, and finishing processes (e.g., printing, potassium permanganate spray), anti-fungal/bacterial agents, metal plating, injection moulding, etc.
- 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 operation are considered 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
How This Will Be Verified:
Full Points:
Documentation Required:
- An up-to-date inventory of all point source emission sources from the facility including operational and production emission sources.
- The inventory contains all the basic information listed in the sub-question and this information is accurate and complete.
Note: This information may be maintained in several different documents. For example, if the facility has a list of all point sources and pollutants emitted from each source but maintains a separate legal register with all emission related regulatory requirements that can be linked to the inventory, this would be acceptable.
Interview Questions to Ask:
- Staff responsible for managing air emissions are able to explain the information in the inventory and how emission sources and pollutants are identified.
Inspection – Things to Physically Look For:
- All point source emission sources and potential pollutants from each source are properly identified and this is consistent with onsite observations.
Partial Points:
- Partial points will be awarded if all the requirements above are met, however the facility’s inventory does not contain all the basic inventory information listed in the sub question “Does your facility’s point source air emissions inventory include the following information? Select all that apply”.
Answer
Answer
Answer
Answer Yes if: Your facility has a documented inventory of all mobile and fugitive emission sources at your facility including mobile and fugitive sources from facility operations and production sources.
Answer Not Applicable if: Your facility does not have any mobile or fugitive emission sources at your facility.
Note: Mobile and fugitive sources may be included in a facility wide emissions source inventory that includes all emissions sources (i.e., point source, mobile and fugitive emission sources) or this can be maintained separately. For example, if the facility has a list of all mobile and fugitive sources and pollutants emitted from each source but maintains this information in separate documentation that can be linked to the inventory, this would be acceptable.
If you select Yes, you will be asked the following sub question(s):
- Does your facility’s mobile and fugitive air emissions inventory include the following information? Select all that apply.
- Unique source identifier (emission point name or number)
- Process or Equipment the source is linked to.
- List of pollutants emitted from the source.
- Legal or other emissions, testing or reporting requirements (ie. testing parameters and frequency), if applicable
- Abatement process for the source, if applicable
- Note: The intent of this inventory item is to indicate the presence or absence of an abatement process for the source. If there is no abatement process for this source and this is indicated on the inventory, this option should be selected.
- Please upload a copy of the inventory
Suggested Uploads:
- A copy of the facilities inventory of mobile and fugitive air emission sources.
What is the intent of the question?
The intent of this question is for facilities to establish an inventory (i.e., a list) of all possible mobile and fugitive sources of emissions to air on-site. This includes mobile and fugitive sources from facility operations and production sources. The intent is also for facilities to understand which pollutants are emitted or have the potential to be emitted from each mobile and fugitive source.
Technical Guidance
An air emission source inventory is needed for facilities to identify, track, and manage emission sources onsite. To prepare a comprehensive inventory, all mobile and fugitive sources of emissions from operations and production should be included. Regular review should be carried out to make sure the inventory is up-to-date and accurate. This inventory should include emissions sources regulated by permits as well as those not currently regulated.
Emission Inventories can contain varying levels of detail and information, however the following basic information should be included in the inventory
- Unique source identifier (emission point name or number)
- Process or Equipment the source is linked to.
- List of pollutants emitted from the source.
- Legal or other emissions, testing or reporting requirements (ie. testing parameters and frequency), if applicable
- Abatement processes for the source, if applicable
- Note: The intent of this inventory item is to indicate the presence or absence of an abatement process for the source. If there is no abatement process for this source and this is indicated on the inventory, this option should be selected.
Mobile and fugitive emission sources are defined in the introduction of the air emissions guidance. Common examples of emission sources and pollutants that can be emitted from mobile and fugitive sources are provided below. Note that this is not an exhaustive list and facilities may require the support of qualified environmental experts to identify air emission sources and all potential pollutants emitted.
Mobile Sources:
- Powered motor vehicles (e.g., forklifts, trucks, passenger vehicles), heavy machinery (e.g., mobile cranes or lifts) small engines (lawnmowers or other landscaping equipment) can emit particulate matter (PM) and oxides of sulphur and nitrogen (SOx and NOx) from fuel combustion.
Fugitive Sources:
- Printing, solvent/adhesive application, spot cleaning or dyeing areas with only general ventilation systems or no ventilation systems at all can emit volatile organic compounds (VOCs) and/or HAPs/TAPs from chemicals applied or used in the process.
How This Will Be Verified:
Full Points:
Documentation Required:
- An up-to-date inventory of mobile and fugitive emission sources from the facility including operational and production emission sources.
- The inventory contains all the basic information listed in the sub-question and this information is accurate and complete.
Note: Mobile and fugitive sources may be included in a facility wide emissions source inventory that includes all emissions sources (i.e., point source, mobile and fugitive emission sources) or this can be maintained separately. For example, if the facility has a list of all mobile and fugitive sources and pollutants emitted from each source but maintains this information in separate documentation that can be linked to the inventory, this would be acceptable.
Interview Questions to Ask:
Staff responsible for managing air emissions are able to explain the information in the inventory and how emission sources and pollutants are identified and managed.
Inspection – Things to Physically Look For:
All mobile and fugitive emission sources and potential pollutants from each source are properly identified and this is consistent with onsite observations.
Partial Points:
- Partial points will be awarded if all the requirements above are met, however the facility’s inventory does not contain all the basic inventory information listed in the sub question “Does your facility’s mobile and fugitive air emissions inventory include the following information? Select all that apply”.
Answer
Answer
Answer Yes if: Your facility is in compliance with all applicable legal requirements relating to air emissions including all permitting, reporting and testing requirements.
Note: If your facility does not have one or more of the legally required permits noted in the Permits Section of the FEM, you should select No for this question.
If you answer No, you will be asked the following sub questions:
- Does your facility have an action plan to address the non-compliance?
- Please upload the action plan to correct the non-compliance.
- If you cannot upload a copy, please describe the action plan.
Suggested Uploads
- Action plan to address the non-compliance. If no, is selected to the main question.
What is the intent of the question?
The intent of this question is to ensure that facilities are operating in compliance with all applicable legal requirements relating to air emissions including any permitting, reporting, and testing requirements.
Technical Guidance
Aspects related to air emissions at facilities may be regulated in multiple ways depending on several factors such as the type(s) of emission sources, pollutants, industry category, or the jurisdiction in which the facility operates.
Requirements may include:
- Discharge permits or approvals for facility emissions to air or specific facility operations or equipment.
- Source testing (also known as stack testing) of specific sources at frequencies defined by local law(s) to determine compliance with in-stack or emission rate concentrations of specific pollutants (e.g., ppm or mg/m3)
- Calculating or measuring annualized mass emission quantities of specific pollutants to demonstrate compliance with permits or other regulatory requirements (e.g., tons or kg per year)
- Calculating the offsite concentration of specific pollutants using air dispersion modelling to demonstrate compliance with ambient air quality guidelines or standards.
- Legally mandated control devices for emission sources.
Being in compliance means that all legally required permits are valid and up to date and any testing and/or reporting are performed in accordance with all applicable legal requirements.
How This Will Be Verified:
Full Points:
Documentation Required:
- Documentation that demonstrates the facility is meeting all applicable legal requirements relating to air emissions including all permitting, reporting and testing. This may include, but is not limited to the following:
- Permits, licenses, or other approval documentation.
- Testing reports
- Legally required emissions and/or pollutant reporting documentation
Note – Required documentation may vary by facility as this will depend on the specific legal requirements that apply to each facility.
Interview Questions to Ask:
- Staff responsible for managing air emissions understand and can describe legal requirements relating to the facility’s air emissions and the processes in place to ensure compliance.
Inspection – Things to Physically Look For:
- All legally required permits are valid and up to date and any testing and/or reporting are performed in accordance with all applicable legal requirements.
Partial Points:
- Partial points will be awarded if your facility is not currently in compliance with one or more legal requirements and you have established an action plan to address the non-compliance(s).
- The action plan must contain the following information:
- The specific action that the facility is taking to address the non-compliance.
- The responsible person(s), role or department that is responsible for implementing the actions.
- The expected timeline to achieve compliance.
Answer
Answer
Answer
Answer Yes if: Your facility knows which specific refrigerants are used at your facility.
If you answer Yes, you will be asked the following sub questions:
- What type of refrigerant do you use in your facility? (Select all that apply)
- Answer Options: CFC, CFO, HCFC, HCFO, HFC, HFO, HCC, HCO, HC, HO, PFC, PFO, PCC, PCO, H.
- Which specific refrigerant do you use in your facility?
- Answer Options: A list of specific refrigerants will be available for you to select based on the types of refrigerants selected in the sub question above.
Suggested Uploads
- An inventory or list of refrigerants used onsite.
What is the intent of the question?
The intent of this question is to ensure that facilities understand which refrigerants are used at their facilities.
Technical Guidance
Refrigerants such as CFCs and HCFCs commonly used in air conditioning, cooling and refrigeration equipment can contain ODS that are contributors to GHG emissions and climate change due to their relatively high global warming potentials (GWPs). Refrigerants are often emitted to the air through equipment leaks or during servicing or disposal of refrigerant containing equipment.
Knowing which refrigerants are used onsite will help facilities plan for phasing out the use of ozone depleting substances (ODS) at their facility in accordance with good environmental practices and current or future regulatory requirements. More information on phasing out Ozone Depleting Substances can be found here: https://www.epa.gov/ods-phaseout
How This Will Be Verified:
Full Points:
Documentation Required:
- An inventory or list of refrigerants used onsite with supporting evidence such as:
- Equipment specifications or technical manuals that show which refrigerants the equipment contains.
- Records of refrigerant purchases or equipment service or maintenance that shows which refrigerants are used in equipment onsite.
Interview Questions to Ask:
- Staff responsible for managing environmental matters or refrigerant containing equipment understand and can explain which refrigerants are used onsite and how refrigerant use is identified and managed at the facility.
Inspection – Things to Physically Look For:
- All refrigerant use has been properly identified and this is consistent with onsite observations.
Partial Points: N/A
Answer
Answer
Answer Yes if: Your facility has a documented preventative maintenance program that covers all refrigerant containing equipment at your facility.
If you answer Yes, you will be asked the following sub questions:
- Please upload your preventative maintenance procedures.
- If you can’t upload your procedures, please describe them here.
Suggested Uploads
- Copies of your preventative maintenance plan or program documentation that covers all refrigerant containing equipment at your facility (e.g., preventative maintenance schedules or procedures, completed inspection checklists or service records, etc.)
What is the intent of the question?
The intent of this question is to ensure that facilities have preventive maintenance procedures in place to proactively identify and minimize the release of refrigerant gases to the environment.
Technical Guidance
Preventative maintenance is maintenance that is regularly scheduled and performed on equipment to reduce the chances of equipment failure and identify potential problems before they result in breakdowns or leaks. Preventive maintenance should be planned and scheduled based on available information for each piece of equipment (e.g., manufacturer’s recommendations, past breakdowns or leaks from equipment, operating conditions, etc.)
Refrigerants are commonly emitted to the air through equipment leaks and although leaks do occur, preventative maintenance can help facilities prevent or detect leaks early and minimize releases to the environment. Preventative maintenance actions may include:
- Inspecting compressor operation
- Checking refrigerant levels
- Refrigerant leak testing
- Inspecting motor operation and motor mounts
- Checking electrical connections
- Inspecting all pipes and fittings
- Examining all other parts for wear and tear
- Testing and recalibrate temperature settings and thermometers.
- Cleaning the equipment (e.g., motors, fans, cooling coils, drain lines, etc.)
- Note – Inspection and maintenance of refrigerant containing devices should only be conducted by trained and qualified individuals.
Resources:
Additional resources for inspecting, maintaining, and managing refrigerant containing equipment are provided below.
Note – The resources are provided for reference only and may contain legal references that do not apply to your facility. Facilities are expected to understand and comply with any applicable local regulations related to the use and management of refrigerants.
- California Air Resources Board Leak/Inspection checklist – https://ww2.arb.ca.gov/sites/default/files/2020-08/rmp_leak_inspection_flyer.pdf
- US EPA Stationary Refrigeration – Resources for Businesses https://www.epa.gov/section608/stationary-refrigeration-resources-businesses
How This Will Be Verified:
Full Points:
Documentation Required:
- Preventative maintenance plan that covers all refrigerant containing equipment at the facility. This may include:
- Preventative maintenance schedule or procedures
- Completed inspection checklists.
- Service records or maintenance logs
Note: If the facilities equipment is maintained by third-party service providers, copies of relevant preventive maintenance documentation such as those listed above should be made available for verification.
Interview Questions to Ask:
- Staff responsible for the maintenance and/or inspection of refrigerant containing equipment understand and can explain the facility’s preventive maintenance procedures.
Inspection – Things to Physically Look For:
- All refrigerant containing equipment is in good working repair and observations indicate that preventive maintenance is conducted as per the facility’s plan.
Partial Points: N/A
Answer
Answer
Answer Yes if: Your facility tracks the quantity of all refrigerants used in all equipment onsite.
Answer Partial Yes if your facility tracks the usage of at least one (1) refrigerant but does not yet track all refrigerants used onsite.
Note: Refrigerants used within owned and operated vehicles will be in scope of the Higg FEM from Higg FEM 2024 onwards. Facilities are encouraged to account and report these sources and emissions in FEM 2023. If these are not tracked in FEM2023, a “Yes” response can be input for Question 6 “Does your facility track refrigerant usage?”. However, if these sources are not tracked from FEM2024 onwards, facilities should select “Partial Yes” or “No”to this question in accordance with FEM Guidance for this question.
If you answer Yes or Partial Yes, you will be asked the following sub questions:
- Refrigerant (list of refrigerants will pre-populate based on refrigerants used)
- Did you add this refrigerant to existing equipment in the reporting year?
- Quantity of refrigerant added to existing equipment during the reporting year
- Unit of measure
- What method was used to track refrigerant use?
- Did you fix the leak associated with this refrigerant?
- How did you fix the leak/ What is your plan for fixing this leak?
- Please upload your action plan or methods fixing the leak that you had fixed the leak
Suggested Uploads
- An inventory of refrigerants used onsite with the quantity of each refrigerant added to existing equipment for the reporting year.
- Documentation of the methodology used to track refrigerant use (e.g., leakage rate or consumption calculation methodology)
- Documented plans or actions taken to fix refrigerant leaks, if applicable.
What is the intent of the question?
The intent of this question is for facilities to enter quantitative data that shows how much refrigerant(s) your facility emitted in the reporting year.
Note: This question will contribute to your GHG-emissions calculation so it’s important for you to enter accurate data about refrigerant use onsite.
Technical Guidance
Refrigerants are often emitted through equipment leaks and servicing. Most modern equipment is designed to minimize leaks however over time, leaks do occur. Having to add refrigerants to existing equipment generally indicates the system has a leak.
Tracking refrigerant use is an important part of managing refrigerants use onsite. Tracking refrigerant use allows facilities to monitor how much refrigerant has been released to the environment as well as identify problematic or leaking equipment.
It is also important to have an action plan to fix the leaks and/or upgrade equipment to eliminate refrigerant leakage.
When establishing your tracking and reporting program, start by doing the following:
- Map out all facility equipment (production and operational equipment) to identify equipment that contain refrigerants.
- This should include identifying the specific refrigerant type that is used in the equipment (e.g., R-22).
- Establish procedures to determine how much refrigerant is released (e.g., through leaks, disposal, etc) from each piece of equipment.
- In general, the amount of refrigerant released is equal to the amount of refrigerant that is added to the equipment (see Calculating Leak Rate below)
- Refrigerant purchase invoices, or service records may also be helpful in determining quantities released.
- If estimation techniques are used, the calculation methodology should be clearly defined and be supported by verifiable data.
- Record tracking data (e.g., monthly, annual leakage or top-up records) in a format that is easy to review [e.g., spreadsheet or similar data analytics program that allows export of data in a human readable format (e.g., Microsoft Excel)] and maintain relevant supporting evidence for review during verification.
Calculating a Leakage Rate
When determining the quantity of refrigerants emitted from a piece of equipment, it is generally considered that the amount of refrigerant emitted is equal to the amount that was added to the equipment after a period of time to return the equipment back to a full charge.
- For example, if you recharge the refrigerant in a Chiller unit to a full charge, then after one year of operation you need to add 0.5kg to fully recharge the unit, then it is assumed that the 0.5kg was emitted due to leaks or servicing throughout the year.
When tracking refrigerant emissions, a facility can directly measure and record the amount of refrigerant added to a piece of equipment in the reporting year or a leakage rate can be determined and used to estimate emissions.
The leakage rate is typically expressed as the percentage of a full charge that would be lost in a 12-month period. The example below is one way to calculate a leak rate.
- Take the kilograms (kg) of refrigerant you added to recharge the system to a full charge and divide it by the kg of refrigerant in the normal full charge for the system.
- Determine the number of days that have passed between charges (e.g., how many days between the last time refrigerant was added and this time refrigerant was added), then divide by 365 (the number of days in a year).
- Take the kg of refrigerant determined in step 1 and divide it by the number of days determined in step 2.
- Lastly, multiply by 100% (to determine a percentage).
For example:
Chiller #1
- Refrigerant Added = 1kg
- Full charge = 5kg
- Days between charges = 275
Leakage rate = (1kg ÷ 5kg) ÷ (275 ÷ 365) x 100% = 26.5%
Therefore, this Chiller unit loses/emits 1.33kg (26.5% of a full charge) of refrigerant in a year.
Note: Leakage rates may also be used to determine preventative maintenance schedules or when equipment may need additional service or replacement.
Reporting Refrigerant Data in the FEM:
Before reporting refrigerant data in the FEM, data quality checks should be performed to ensure that the data AND the processes used to collect and record the data are effective at producing accurate energy data.
Do:
- Review source data (e.g., equipment maintenance records, servicing logs, refrigerant purchase invoices, etc.) against aggregated totals to ensure it is 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., measured, leakage rate, estimate)
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., leakage rate or other engineering calculations).
How This Will Be Verified:
When verifying a facility’s refrigerant data, Verifiers must review all aspects of the facility’s tracking program that could produce inaccuracies including:
- The initial data collection processes and data sources (e.g., equipment maintenance records, servicing logs, refrigerant purchase invoices, etc.); and
- The process and tools used to aggregate the data (e.g., spreadsheet calculations, leakage rate calculations, 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:
- All refrigerant containing equipment has a log of equipment servicing including refrigerant replacement that is kept up to date (e.g., monthly, annual leakage rates or top-up records)
- Records of the quantity of each refrigerant added to existing equipment for the reporting year.
- Documentation of the methodology used to track refrigerant use (e.g., leakage rate or other consumption calculations and methodology)
- Documented plans or actions taken to fix refrigerant leaks, if applicable.
Note: If the facilities equipment is maintained by third-party service providers, copies of relevant documentation (e.g., service records, maintenance logs, quantities of refrigerants added) should be made available for verification.
Interview Questions to Ask:
- Staff responsible for maintaining the refrigeration equipment and tracking usage should understand and be able to describe the process and frequency for tracking refrigerant and the methodology to determine refrigerant usage.
Inspection – Things to Physically Look For:
- Evidence the facility is tracking refrigerant use and this is consistent with onsite observations (e.g. service tags or record on equipment that match maintenance records)
Partial Points:
- Partial points will be awarded if your facility tracks the usage of at least one (1) refrigerant but does not yet track all refrigerants used onsite.
Answer
Answer Yes if: You are monitoring or reporting your facility’s air emissions against industry guidelines or tools for air emissions. The standard must be in addition to any local law monitoring or reporting requirements.
Answer Not Applicable if your facility does not have any relevant emission from operational or production sources that are covered under inquiry guidelines or tools (i.e., if your facility only has refrigerant emissions)
Note: If your facility is only monitoring, reporting, or testing your facility emissions in accordance with local law requirements, you should select No for this question.
If you answer Yes, you will be asked the following sub questions:
- Please indicate which Air standard you are reporting against:
- ZDHC Air Position Paper/Guideline
- ZDHC MMCF Air Guidelines
- Other
- If other, please describe.
Suggested Uploads
- Copies of emissions calculations or reporting that demonstrate facility emissions are being monitored or reported against the selected standards.
Note: This question is unscored in Level 1. Scoring will be applied in Level 2 and will result in additional scored questions on industry air emission guidelines/tools in Level 2.
What is the intent of the question?
The intent of this question is to encourage facilities to monitor and report their air emissions against industry developed guidance or tools that go beyond basic legal compliance monitoring and reporting.
Technical Guidance
Industry guidance and tools are developed to support facilities in the proper management and reduction of emissions to the environment. These tools intend to provide consistent methodologies to identify, monitor and report emissions of hazardous pollutants. They also strive to support facilities in managing and reducing emissions by establishing progressive emission thresholds that go beyond basic compliance.
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, etc.) When adopting an industry standard, facilities should review the guideline to determine the monitoring and reporting requirements that apply to their operations and put in place procedures to meet the required monitoring and reporting requirements.
Examples of industry guidance/tools for air emissions are the ZDHC Air Position Paper/Guidelines and the ZDHC MMCF Air Guidelines – Air Emissions of the ZDHC MMCF Guidelines. Both of these guidance documents can be found and downloaded here https://www.roadmaptozero.com/output
How This Will Be Verified:
Full Points (applied in Level 2):
Documentation Required:
- Documentation that demonstrates the facility is monitoring and reporting air emissions in accordance with the applicable guideline(s)/tool(s) selected. This may include:
- Air emissions inventory or report with reported emission quantities or emission rates.
- 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.
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: N/A
Air Emissions – Level 2
Higg FEM Level Progression
If your facility did not achieve Level 1 in this section, you will have the option to complete Level 2 and 3 questions and will be asked the following question:
Your facility has not achieved Level 1 within this section, the maximum score for this section will be limited to your answers in Level 1, You now have the option to answer Level 2 and Level 3 questions, would you prefer to proceed answering these additional questions?
If you Answer Yes: Level 2 and 3 questions will be available to answer in this section.
If you Answer No: Level 2 and 3 questions will not be available in this section.
Notes:
- If your facility did not achieve Level 1 in this section, answering Level 2 and 3 questions will not result in additional score beyond what you have already achieved in Level 1
- It is recommended that facilities consult with their business partners on whether they require responses to Level 2 and Level 3 questions, even though you have not achieved Level 1 in this specific section.
- Facilities are encouraged to complete Level 2 and Level 3 questions when possible as these can provide valuable insights on your facilities environmental performance and opportunities for improvement with the advanced Higg FEM aspects in Level 2 and 3
Answer
Answer
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.
- Estimating Emissions from Boilers https://www.dcceew.gov.au/sites/default/files/documents/boilers.pdf https://www.epa.gov/sites/default/files/2015-08/documents/ii02.pdf
- National Pollutant Inventory (NPI) Emission Estimation Technique Manual for Textile and Clothing Industry https://www.dcceew.gov.au/sites/default/files/documents/ftextile.pdf
- US EPA air Emission factors and quantification main page: https://www.epa.gov/air-emissions-factors-and-quantification
- US EPA AP42 Compilation of Air Emissions Factors: https://www.epa.gov/air-emissions-factors-and-quantification/ap-42-compilation-air-emissions-factors
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
Answer
Answer
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. Forexample, 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.
- National Pollutant Inventory (NPI) Emission Estimation Technique Manual for Textile and Clothing Industry: https://www.dcceew.gov.au/sites/default/files/documents/ftextile.pdf
- US EPA air Emission factors and quantification main page: https://www.epa.gov/air-emissions-factors-and-quantification
- US EPA Emission Modelling: https://www.epa.gov/air-emissions-modeling
- Clearinghouse for Inventories and Emissions Factors (CHIEF): https://www.epa.gov/chief
- US EPA AP42 Compilation of Air Emissions Factors: https://www.epa.gov/air-emissions-factors-and-quantification/ap-42-compilation-air-emissions-factors
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
Answer
Answer
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
- US EPA Clean Air Technology Center https://www.epa.gov/catc/clean-air-technology-center-products
- Implementation plan template: https://howtohigg.org/resources/resources-library/#templates
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
Answer
Answer
Answer
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.
- US EPA – Clean Air Technology Center https://www.epa.gov/catc/clean-air-technology-center-products
- Industrial Emissions Directive 2010/75/EU (Integrated Pollution Prevention and Control) – Best Available Techniques (BAT) Reference Document for the Textiles Industry https://publications.jrc.ec.europa.eu/repository/handle/JRC131874
- Implementation plan template: https://howtohigg.org/resources/resources-library/#templates
- Best available techniques (BAT) reference document on surface treatment using organic solvents including preservation of wood and wood products with chemicals https://publications.jrc.ec.europa.eu/repository/handle/JRC122816
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
Answer
Answer
Answer
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.
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)?
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
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.
Answer
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.
- US EPA Significant New Alternatives Policy (SNAP) Program https://www.epa.gov/snap
- US EPA Significant New Alternatives Policy (SNAP) Program – Substitutes in Refrigeration and Air Conditioning https://www.epa.gov/snap/substitutes-refrigeration-and-air-conditioning
- EU Climate-friendly alternatives to HFCs https://climate.ec.europa.eu/eu-action/fluorinated-greenhouse-gases/climate-friendly-alternatives-hfcs_en
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
Answer
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.
- US EPA – Technology Transfer Network – Clean Air Technology Center – RACT/BACT/LAER Clearinghouse RACT/BACT/LAER Clearinghouse (RBLC) https://cfpub.epa.gov/rblc/index.cfm?action=Home.Home&lang=en
- EU – Establishing the best available techniques (BAT) conclusions, under Directive 2010/75/EU on industrial emissions, for the textiles industry. https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A32022D2508&qid=1671517820694
- Industrial Emissions Directive 2010/75/EU (Integrated Pollution Prevention and Control) – Best Available Techniques (BAT) Reference Document for the Textiles Industry https://publications.jrc.ec.europa.eu/repository/handle/JRC131874
- Best available techniques (BAT) reference document on surface treatment using organic solvents including preservation of wood and wood products with chemicals https://publications.jrc.ec.europa.eu/repository/handle/JRC122816
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
Air Emissions – Level 3
Answer
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.
- Best Available Techniques (BAT) Reference Document for Large Combustion Plants
- https://publications.jrc.ec.europa.eu/repository/bitstream/JRC107769/jrc107769_lcp_bref2017(1).pdf
- US EPA Clean Air Technology Center https://www.epa.gov/catc/clean-air-technology-center-products
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
Answer
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.
- US EPA – Technology Transfer Network – Clean Air Technology Center – RACT/BACT/LAER Clearinghouse RACT/BACT/LAER Clearinghouse (RBLC) https://cfpub.epa.gov/rblc/index.cfm?action=Home.Home&lang=en
- EU – Establishing the best available techniques (BAT) conclusions, under Directive 2010/75/EU on industrial emissions, for the textiles industry.
- https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A32022D2508&qid=1671517820694
- Industrial Emissions Directive 2010/75/EU (Integrated Pollution Prevention and Control) – Best Available Techniques (BAT) Reference Document for the Textiles Industry https://publications.jrc.ec.europa.eu/repository/handle/JRC131874
- Best available techniques (BAT) reference document on surface treatment using organic solvents including preservation of wood and wood products with chemicals https://publications.jrc.ec.europa.eu/repository/handle/JRC122816
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
Answer
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.
- US EPA Significant New Alternatives Policy (SNAP) Program https://www.epa.gov/snap
- US EPA Significant New Alternatives Policy (SNAP) Program – Substitutes in Refrigeration and Air Conditioning https://www.epa.gov/snap/substitutes-refrigeration-and-air-conditioning
- EU Climate-friendly alternatives to HFCs https://climate.ec.europa.eu/eu-action/fluorinated-greenhouse-gases/climate-friendly-alternatives-hfcs_en
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
Answer
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.
- US EPA – Technology Transfer Network – Clean Air Technology Center – RACT/BACT/LAER Clearinghouse RACT/BACT/LAER Clearinghouse (RBLC) https://cfpub.epa.gov/rblc/index.cfm?action=Home.Home&lang=en
- EU – Establishing the best available techniques (BAT) conclusions, under Directive 2010/75/EU on industrial emissions, for the textiles industry. https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A32022D2508&qid=1671517820694
- Industrial Emissions Directive 2010/75/EU (Integrated Pollution Prevention and Control) – Best Available Techniques (BAT) Reference Document for the Textiles Industry https://publications.jrc.ec.europa.eu/repository/handle/JRC131874
- Best available techniques (BAT) reference document on surface treatment using organic solvents including preservation of wood and wood products with chemicals https://publications.jrc.ec.europa.eu/repository/handle/JRC122816
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
Answer
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