New Equipment and Upgrades? Remember Any and All Requirements for Careful Emissions Adjustment
According to a recent interview by The Dispatch, Columbus, Mississippi, of a VP/mill manager of a mill in East Mississippi under state government scrutiny explained how he takes all penalties seriously even though, along with other high recent numbers in the state for other industry, many seem questionable. All are expensive. His take on this is that many of these new penalties stem from the constant changes in equipment happening in the industry combined with the fact enforcement is relentless in applying a "one strike" rule to the paper industry. In these industries there is no chance to quick the problem and avoid penalty beyond citing, such as with restaurants who fail health department inspections, to be re-examined and avoid any further punishment beyond the publication of their failure in the great majority of U.S. states. This requires extra attention to adhering to constant adherence to proper operation and standards.
"The mill is constantly investing capital and people resources to meet new and existing state and federal regulations," the mill manager told The Dispatch via email. "As part of that investment, monitoring new and existing equipment for compliance is an on-going, daily process. So, when an equipment test fails, we identify the problem, put steps in place to resolve the issue and don't wait until a fine is imposed to make changes."
The majority of penalties have risen from issues with particulate matter, the sum of all solid and liquid particles in the air, many of which are hazardous.
"The fact that the fines tend to focus on particulate matter are the result of the circumstances. Any change to our system, whether upgrading equipment, new regulations, testing methodology or during periods of shut-down, technical adjustments have to made to the operations airflow and pollution control devices - this takes testing. If you fail a test for any reason, you've exceeded the permit and a fine is imposed regardless if your next test is in compliance."
"Our operations utilize environmental management systems, certifiable to ISO standards to meet regulatory requirements and reduce our environmental impact. We audit compliance with environmental laws and regulations routinely at all our operations. The company tracks and reports publicly its environmental performance... a leader in environmental performance among pulp mills in North America and has invested considerable capital to improving environmental performance. These investments have resulted in significant reductions in air emissions, chemical use, water use and solid waste generation..."
Indeed numerous modern players in the paper industry have made exceptional progress, in a progressing number of regions around the globe, in commissioning the design of and the consistent investment in more and better emissions control systems. However, it should be noted that they will only work as well as they are programmed to, and furthermore only with exact mixtures that are understood both by sensors as well as staffers who mind the environmental system. A lot of emphasis of new product specification is highlighted in enhanced product capability and durability to attract sales, but companies can always be wise to make sure to take into proper consideration any changes as far as waste discharge properties that come with new, often cleaner and newer, but also often more powerful machinery, or machinery which simply creates a new type of discharge the mill's systems are not programmed yet to know they need to be broken down or catalyzed. Most of these problems can be resolved by simply adjusting systems accordingly between programming and possibly small but affordable component additions or alterations in the environmental section. But what is needed is also the the proper understanding beforehand what changes, if any in a project, will be made to site waste processing systems by alternating components. As explains this new report, only one failure is required to levy a heavy fine. There is no second chance in many cases to make compliance to avoid this burden to a mill group's bottom line.
TAPPI
http://www.tappi.org/