Monthly Archives: December 2010

More on Greenhouse Gas Emission

EPA will be proposing greenhouse gas emission standards for power plants in July 2011 and for refineries in December 2011 and will issue final standards in May 2012 and November 2012, respectively.

In the absence of any possible legislative action by Congress in the upcoming term, EPA is now exercising its authority under the Clean Air Act to regulate greenhouse gases as air pollutants.

In California, the Air Resources Board is going ahead with its Cap and Trade program for GHG. It is a program that does not have immediate impact on industry in the sense that affected industry is provided with GHG allowances in the first year to meet their caps. The trading of GHG allowances does not start until 2012 and will accelerate in 2015. State law mandates that GHG be reduced to 1990 level by 2020.

California’s new Cap and Trade Program for Greenhouse Gas

The California Air Resources Board has just issued a press release on its new cap and trade rule for greenhouse gas. Here are some excerpts from it:

“The regulation will cover 360 businesses representing 600
facilities and is divided into two broad phases: an initial phase
beginning in 2012 that will include all major industrial sources
along with utilities; and, a second phase that starts in 2015 and
brings in distributors of transportation fuels, natural gas and
other fuels.

Companies are not given a specific limit on their greenhouse gas
emissions but must supply a sufficient number of allowances (each
covering the equivalent of one ton of carbon dioxide) to cover
their annual emissions.  Each year, the total number of
allowances issued in the state drops, requiring companies to find
the most cost-effective and efficient approaches to reducing
their emissions.

By the end of the program in 2020 there will be
a 15 percent reduction in greenhouse gas emissions compared to
today, reaching the same level of emissions as the state
experienced in 1990, as required under AB 32.

To ensure a gradual transition, ARB will provide significant free
allowances to all industrial sources during the initial period
(2012-2014).  Companies that need additional allowances to cover
their emissions can purchase them at regular quarterly auctions
ARB will conduct, or buy them on the market.”

Cap and Trade is not new to California. There has been a similar program for NOx and SOx for some time.

Cap and Trade law in California

As most of you know, there is ZERO chance that there will be any cap and trade law coming out of the Capitol Hill in the next two years since the Republican are in control of the House of Representatives.

However, the California Air Resource Board is poised to finalize the state’s Cap and Trade regulations before the end of this year. This was mandated by the California Global Warming Solutions Act of 2006. The finalized regulations wil go into effect January 2012.

There is a Scoping Document from the Board that outlines all the steps required by the Global Warming Act.

We will post the final cap and trade rules here as soon as they are adopted by the Board.

Beware of combustible dust at your plant

One of the most frequently neglected safety and environmental concerns is the accumulation of fine dust particles at the work place. Fine dust particles can become combustible and pose a safety and fire hazard. The National Fire Protection Association defines combustible dust as particles that are smaller than 420 microns in diameter. These are the same particles that pass through a #40 U.S. standard sieve.

However – the combustible factor also depends on various other factors such as shape, moisture and content of the particle. So you may have particles that are larger than 420 microns and still pose a fire hazard.

Combustible particles exist in many industries; food manufacturing (candy, sugar, starch, flour and feed), furniture, woodworking, metal grinding, textile, dyes, coal, etc. Most synthetic organic material can form combustible dusts.

Normally noncombustible material can be transformed into combustible dust if it undergoes a manufacturing process that turns it into finely divided state. Very often, a primary explosion near a collection of fine particles will trigger a massive secondary explosion.

Here is a short video from the Chemical Safety Board on a combustible dust explosion at Imperial Sugar that killed 14 persons. It describes the events and causes that lead to the deadly explosion:


Note that the plant management was aware of the existing danger of combustible dust explosion as evidenced by earlier internal inspection, according to the CSB. But the dust was allowed to continue ot accumulate.  This is another classic example of why you should pay attention to your own internal audit findings and act on them in a timely manner.

Our 2-day seminar discusses many cases of chemical accidents and ways on how to prevent them.