A Heuristic for Fugitive Emissions Management

Progressively more stringent emission limits and advances in regulations and enforcement have made air compliance more difficult for metallurgical facilities. This has historically required improved collection and treatment of stack sources. Fugitive emission reductions are now increasingly required to achieve compliance. Typically small in magnitude, fugitive emissions have a disproportionate impact on ground level concentrations, can be visible to the public and can influence workplace health and safety. Moreover, these emissions are complex, as they are spread over multiple sources, distance and time and are affected by various activities and conditions. As such it is difficult to find, define and monitor these emissions and their impacts. This difficulty translates to the design of emission reduction measures and operational requirements. This paper presents an overview or ‘heuristic’ of fugitive emissions management for compliance in existing operations. This includes aspects such as the impact of regulations on project scope, approaches to developing a comprehensive emission inventory, considerations for solution development and the plant’s role in sustaining compliance once achieved. Case studies are presented to demonstrate how portions of this approach have been applied.