The Difficulties With Attaining Compliance With Environmental Regulations

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Courtesy of All4 Inc.

If you are an environmental compliance manager today with college age children you are probably encouraging them to become dentists or orthodontists, and not to follow in your footsteps as an environmental compliance manager.  Arguably one of the toughest positions today is being responsible for managing environmental compliance at an industrial facility.  The primary element to managing the constantly expanding litany of environmental regulatory requirements is to be sure you have identified all of them.  Only then you can set about the task of planning.

I am primarily addressing the difficulties of dealing with environmental compliance with today’s air quality rules and regulations, because that is what I have done for the past 40 plus years.  However, most environmental compliance managers do not have the luxury of only working on a single medium (e.g., air, or water, or waste).  They wear multiple hats and may even have direct health and safety responsibilities to boot.

First if your facility burns coal in any way shape or form, you are either scrambling to figure out what your control strategies need to be to comply with new air quality regulations, or you are looking for alternative employment.  If you are an environmental compliance manager at a coal-fired utility, the hot topic of discussion used to be worrying about whether it would be the Clear Air Interstate Rule (CAIR) or the Cross State Air Pollution Rule (CSAPR) or yet a third variant of the CAIR/CSAPR acronym that might shutdown your units.  Not anymore, now it’s how are you possibly going to comply with the Mercury Air Toxics Standards (MATS) rule.  Even oil-fired utilities get in on the significant challenges of the MATS rule. On top of all of that, U.S. EPA has revised and strengthened the National Ambient Air Quality Standards (NAAQS) for both nitrogen dioxide (NO2) and sulfur dioxide (SO2) which will, in all likelihood, prohibit major modifications at utility units. Combine all of this with major vacillations in fuels pricing with unconventional natural gas development, electric rate-deregulation in some areas of the country, and unprecedented numbers of facilities shutting down; we have major uncertainty for an entire industry that has been a pillar for the U.S. economy.

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