Author: Henri Azibert
When news comes of a new regulation being promulgated, the first reaction is often to view it with fear or disdain. Yet in many cases, the long-term effects are quite beneficial, and the original, most fervent opponents end up benefiting from its effect. This has been the case for emission regulations where product performance has significantly improved, and life cycle costs have been reduced.
Although we have not seen much activity from the Environmental Protection Agency in the U.S. recently, our neighbors have been quite busy. This past year, Canada issued “Regulations Respecting Reduction in the Release of Methane and Certain Volatile Organic Compounds” and Mexico issued “Administrative Provisions for the integral control and prevention of methane emissions in the hydrocarbon sector”. While we have yet to see the final effect that these regulations will have on the industry, we have had experience in the United States with similar regulations.
It is not unusual for an industry sector to oppose a regulation; citing increased costs or even the inability to conform. Indeed, there are times when meeting a new regulation seems impossible. Starting with an inventory of current practice, and then looking at having to improve performance by one or two orders of magnitude, the target appears to be unattainable. Looking forward, the argument must be made that the regulation should be repealed as unreasonable and unduly burdensome.
Yet, looking backwards, the results often prove that, if anything, the regulation was too lax and did not go far enough. When the Clean Air act was enacted in the 1990’s there was much concern in the processing industry that the emission goals could not be met. Many centered around the need to seal hazardous and toxic chemicals more effectively and to significantly reduce fugitive emissions. Meeting the new limits seemed impossible. So, one study was conducted by the Chemical Manufacturers Association and the Society of Tribology and Lubrication Engineers (1) to examine how the National Standard for Hazardous Air Pollutants could be met. It concluded that the existing maximum achievable control technology together with effective maintenance practices could easily achieve the standard requirements.
With the proper selection of material and designs, pump seals could easily attain the required emission levels. Some common mechanical seal designs and material were also identified as being problematic and needed to be avoided. This was how it was discovered that polymeric secondary seals created hysteresis in the seal face tracking, and this, in turn, led to increased emission levels. Using other existing configurations did not have this limitation and therefore could be used to meet the regulation limits. The performance of single and dual seals of various designs and face material was also catalogued to provide a guide on what would be the best available control technology. Not only were the goals of the regulation easily met, but they could be surpassed. The side effects turned out to be increased reliability, higher product yields, and reduced costs.
An argument is often made that the emphasis should be on voluntary programs. It allows all involved to go at their own pace. Yet the results of these programs tend to be disappointing. When developing a program alone, it can be financially difficult to justify making capital improvements, as well as difficult to find the required technological innovations. It can increase costs, result in failures and potential safety issues. Following the old adage “if it isn’t broke, don’t fix it”, doing business as usual is a cautious course of action, especially when other competitors implement short term cost cutting measures.
With a regulation or legislation, on the other hand, everyone is involved in the process: users, suppliers, engineering firms, equipment manufacturers – all have an interest in meeting the regulation. It is this unorganized but resulting cooperation and collaboration which makes it straightforward to achieve the goal. Information is shared though platforms such as the EU Best Available Techniques reference documents (BREFs), (https://www.eea.europa.eu/themes/air/links/guidance-and-tools/eu-best-available-technology-reference) that is used in Europe to document the best available technology to meet the Industrial Equipment Directive, or Industry forums where research results and the latest product designs are presented.
Everyone has an incentive to invest so there is no competitive disadvantage for early adopters. New control methods and practices are embraced. As better materials, designs and products are developed and used, reliability and performance improve. The ancillary results are increased efficiency and profitability. It turns out to be easy to meet what at first appeared to be impossible. When everyone works together to achieve a common goal, there is no limit as to what can be achieved.
So, the next time a new regulation comes into effect, do not worry about how difficult it will be to meet the challenges, look at how you have conquered them in the past. Do not look forward, look backwards.
References
CMA/STLE Pump Seal Mass Emissions Study, Kittleman, Thomas; Pope, Michael; Adams, William (Turbomachinery Laboratories, Department of Mechanical Engineering, Texas A&M University, 1994) https://oaktrust.library.tamu.edu/handle/1969.1/164204.
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