Pollution Control and Monitoring
Section A
During the last years of the 20th century, environmental authorities from the most developed countries initiated a process to improve environmental protection. Several special environmental policies were consequently implemented with two main objectives which are to improve global pollution control, avoiding pollutants transfer between media (air, water, and land) and to enhance the importance of prevention as the best way to protect the environment.
Pollution control is becoming increasingly important to society in general and to the business community in particular. The traditional approach to pollution control is to clean up at the end of the process. Many corporations use the traditional pollution control approach of recycling or cleaning up at the end of the manufacturing process. However, the high costs of recycling and cleanup operations and the high amounts of pollutants produced are driving companies to look for alternative pollution control methods.
In the past, pollution management was limited to recycling or cleaning up wastes that resulted from the manufacturing process. Enlightened companies installed pollution control devices to eliminate or reduce further contamination of the environment. They introduced integrated systems that incorporated waste as a primary ingredient in another product or process. Some firms even diversified into reclamation activities that provided services to other companies similar to those used in-house (1980). These techniques are useful, but they all treat the waste after it has been made.
There are different types of pollutions. These include air pollution, water pollution, land contamination and noise pollution.
As with the UK version of Integrated Pollution Control (IPC), the permits under this directive are to contain conditions. Member states are required to make sure that the permit 'shall include all necessary measures to achieve a high level of protection for the environment as a whole.' These are to include the following: emission limit values for specific potentially polluting substances and preparations which may be emitted from the installation (based on the best available techniques); appropriate monitoring requirements (specifying measurement methodology, frequency and evaluation procedure) and an obligation to supply the competent authority with the data it requires to check compliance with the permit; conditions providing that when the installation has ceased operation all measures will be taken to ensure that no harm to the environment can occur; and any specific conditions that the member state or the competent authority thinks fit, for the purpose of the directive.
The phrase 'best available techniques' (BAT) upon which emission limit values are to be based, is obviously a crucial one. According to the definition in the draft directive, BAT 'signifies the latest stage of development of activities, processes and their methods of operation which indicate the practical suitability of particular techniques to form the basis of emission limit values for preventing, or where that is not practicable, minimizing emissions to the environment as a whole without pre-determining any specific technology or other techniques.'
'Techniques' is defined to include 'both the technology used and the way in which the installation is designed, built, maintained, operated, and decommissioned. The techniques must be industrially feasible in the relevant sector, from a technical and economic point of view' (emphasis added).
'Available' is defined as meaning developed at a scale which allows its implementation in the relevant industrial context, whether or not the techniques are used or produced inside the member state in question as long as they are reasonably accessible to the operator.
'Best' is defined as meaning effective in achieving a high level of protection for the environment as a whole, taking into account the potential benefits and costs which may result from action or lack of action. The definition does not imply that there is only one set of 'best' techniques.
In selecting BAT, special consideration must be given to the items listed in Appendix IV of the draft directive, namely: the use of low waste technology; the furthering of recovery and recycling of substances generated and used in the process, where appropriate; comparable processes, facilities or methods of operation which have recently been successfully tried out; technological advances and changes in scientific knowledge and understanding; time limits for the installation of the techniques; raw material consumption (including water) and energy used in the process and their nature; and the need to prevent or minimize the overall impact of the emissions on the environment.
In the definition of BAT, cost considerations must be taken fully into account. This could lead to cost savings and increased efficiency. In considering the environment as a whole, for example, the environmental costs of using a procedure which needs more energy than the basic process must be taken into account. BAT is not defined in terms of emissions alone: the whole concept of sustainable development is applied and the permitting authority is directed to look at the efficiency and rational use of resources. As the Commission says in its draft explanatory memorandum, 'techniques which use less, or less harmful raw materials (for example, those which use recycled materials efficiently) may be considered to be better for the environment as a whole, even though emissions from installations may be a little higher.' Account must therefore be taken of the best environmental option (BEO).
There have been integrated pollution control techniques that have been used by the industries. In addition the government has also imposed legal penalties to those industries that do not limit their wastes to the limit that has been imposed. However, these techniques treat the pollution after it has been made and usually damage has also been done.
Prevention is the key to pollution control. Just like what a quotation says, “Prevention is better than cure”. Just as firms have begun to recognize the importance of designing products and processes to ensure quality, they could have also design products and processes to reduce or eliminate their negative impact on the environment.
Product Quality Control
In the product quality control, companies prompted to investigate ways to prevent disposing, or suffering form defective products. The classic approach to quality control is to monitor the production process to ensure that quality is maintained. This process, which typically uses acceptance sampling or statistical process control procedures, is known as "on-line" quality control.
Another approach in maintaining the good quality involves the improvement of product quality throughout the design process which is referred to as "off-line" quality control.(7) By designing a product that is less sensitive to variations in the manufacturing process, firms can produce a higher quality product at a lower cost.
Product design can dictate the selection of machines and procedures in the production process. It may be possible to abandon quality control production processes that are expensive or difficult to control in favor of others that produce higher quality at lower cost.
In addition, designers can develop products that are robust to the environmental conditions to which they will be exposed. For example, redesigning a product to reduce its sensitivity to temperature changes, rough handling by the user, or wear from use ensures a higher quality product.
Environmental Pollution Control
Similar opportunities exist for environmental pollution control. Industries should consider reducing pollution by improving the efficiency of production process controls and after-the-fact pollution devices.
Generally, legislation has encouraged the use of technologies that treat the symptoms of manufacturing pollution rather than address its underlying causes. Million-dollar scrubbers that treat power companies' toxic emissions and catalytic converters are required to clean automobile exhaust systems.(9) Batelle Pacific Northwest Laboratories has assisted companies to recycle wood into synthetic gases to provide energy(10) and to transform cow manure to cattle feed.(11) The U.S. Bureau of Mines has developed a method to recover cobalt from copper ore wastes,(12) and Westinghouse has reclaimed gold.
The intent of these control measures is to use, reuse, or minimize the effects of existing manufacturing processes and designs. Costs for material that will eventually evolve into waste have been committed at the onset of the process. Those costs include raw materials, labor, energy, equipment depreciation, and capital. Added to that are the costs of cleanup after the manufacturing process is completed such as equipment, labor hours, capital investment, and technical training. The value of any recycled material can be deducted from the cost as a benefit to the company, but that value is rarely sufficient to offset the actual expenditure.
Instead of these currently more popular, legislatively-supported waste and emission treatments, companies could adopt an approach similar to "off-line" quality control for pollution abatement. Products and processes should be designed to prevent pollution, rather than clean it up after production.
Pollution Prevention
Similarly, pollution control can be controlled using the technique used by product quality improvement which is the off-line quality control for pollution abatement. An improved product design, better process selection, and easy disposal of products when their useful life ends can result in measurable cost savings and improved marketability.
There are three basic strategies are available to accomplish pollution prevention. One strategy is to design the product to eliminate production processes or reduce the use of raw materials that are environmentally undesirable. A second strategy is to eliminate environmentally undesirable materials from both the product and the production process. Eliminating these materials from the product makes it easier to either recycle or dispose of the product when its useful life is over. In the production process, it may be possible to use environmentally preferable products. The third strategy is to make it easy to recycle or dispose of the product when its useful life ends. One procedure, known as "design for disassembly," makes it easier to separate the different types of materials in a product so that they can be effectively recycled or otherwise thrown out.
Guidelines for Pollution Prevention
The following guidelines can be used to implement prevention strategies. Their use should reduce the amount of pollutants produced. Industries should ask the following questions to themselves:
1. Can manufacturing processes that are difficult to control because of anti-pollution devices be eliminated through product design?
In some cases, it may be possible to redesign the product to utilize different manufacturing processes, thereby achieving pollution abatement by eliminating undesirable processes in favor of environmentally suitable processes. In addition, this practice can reduce manufacturing costs by eliminating pollution control equipment and its associated expense.
For example, Carrier Corporation has used this approach by redesigning its air conditioner parts and changed its metal-cutting process at a cost of $500,000. The firm eliminated toxic solvents, saved $1.2 million in production costs, and improved the overall quality of the product (1990)
2. If these processes cannot be eliminated, can their use be reduced through a better design?
The best approach is to eliminate environmentally unsound processes, which is not always possible. Even if total elimination is impossible, compromises can sometimes be made to reduce the use of these undesirable processes and lessen the amount of pollution that results.
For example, Whyco Chromium developed an organic compound for coating nuts and bolts that cut the number of coats required in half. Not only was the amount of waste reduced, manufacturing costs were cut by 25 percent (1990).
3. Can environmentally undesirable materials be eliminated from the product design?
It may be possible to use different materials in a design with existing processes. If the new materials are more environmentally acceptable, the outcome is an improved manufacturing process because of anti-pollution gains. In many cases, these materials already exist.
An example of this approach is demonstrated by Reynolds Metals. The company replaced a solvent-based ink with a comparable water-based ink in packaging plants and cut emissions by 65 percent, which saved $30 million in pollution equipment (1990)
4. Can environmentally undesirable materials be eliminated from the production process?
Firms should examine the materials they use in the processes. It may be possible to change the type of coolant used in a milling process.
One example is the 3M Corporation estimates that it has saved $482 million through reduced wastes in eliminating the use of solvents within their coating process and in reducing all emissions 90 percent (1990).
Another example is AT&T which redesigned a circuit board cleaning process which has resulted in the elimination of ozone-depleting chemicals and a $3 million annual saving in cleaning costs (1990).
Moreover, the Bayer organization which has reformulated a dye intermediate referred to as H acid, changed the catalyst system and redesigned the process, has reduced starting material by 20 percent, eliminated by-product iron oxide slurry and sodium chloride, and cut wastewater by 70 percent (1991).
5. Can the product be designed to increase the interest in recycling it after its useful life is over?
Growing restrictions on the types of materials that can be deposited in landfills will increase the need to consider the disposability or recyclability of products after their useful life is over. A variety of factors should be considered here.
One method of increasing disposability is to eliminate hazardous waste from the product which makes it more acceptable to landfills and recycling centers. Another consideration is the ability to separate the various materials in a product so they may be more easily and effectively disposed of or recycled. One approach to separation of materials is to design for disassembly. The basic concept is to make products that can easily be separated or disassembled by their components, thereby reducing the expense of recycling because little effort is spent separating materials. The process also converts the nonrecyclable hazardous waste to a form that requires less space in the landfill. Therefore, disposal costs are reduced.
One example is the Polaroid Company which has eliminated toxic materials from their products. Polaroid eliminated mercury from its battery products and has created recyclable batteries (1990).
Section 2
Environmental Risk Assessment
The business community has implemented pollution prevention initiatives through what has been termed "environmental management systems" (2000) and "environmental risk management systems" (1998). Environmental management and risk systems are a series of standards that are used to develop a business model for an integrated management system to identify, control, and monitor environmental risks (1998). Both initiatives focus efforts on what has essentially been identified as life-cycle analysis. Life-cycle analysis involves the evaluation of raw materials, byproducts, wastes, and the final product into a decision matrix to reduce costs and environmental liabilities (1998). The purpose of conducting a life-cycle analysis on environmental matters is to reduce risk and liabilities predominantly through awareness (1996).
The objectives of this study were to provide direction and assistance for improving environmental risk management by:
1. More fully understanding the site-specific risks related to the interactions of certain contaminants and local geology, and
2. Translating this knowledge into the development of effective pollution prevention initiatives in a more focused and efficient manner. This sequence of objectives incorporates a key principle of risk analysis: informed decision-making. (1999).
To achieve the study objectives, a modified life-cycle analysis of a UK- based manufacturing company was performed. Instead of evaluating potential environmental impacts based on the sequential stages of production, this study analyzed company-specific data from historical contamination events with the objective of instituting management and engineering controls to eliminate or reduce future impacts and liabilities.
This approach to historical environmental impact assessment is described by (1996) and it is based on the analysis of the frequency and financial severity of a particular risk. In this application, the specific risk analyzed was the release of hazardous substances to the ground surface at 48 industrial facilities in UK. The most common sources of contamination included:
1. Leaks and spills associated with operations of underground storage tanks (USTs) and waste storage areas,
2. Surface disposal,
3. Accidental spills, and
4. Atmospheric deposition
The most common type of contaminant release was from waste storage areas and surface disposal, followed by USTs and atmospheric deposition. In many instances, the sources of contamination had gone undetected for long periods of time and were only discovered when the facility underwent a comprehensive site investigation upon facility closure.
The sites evaluated in this study consisted of heavy manufacturing facilities. The sites ranged in size from 1.8 to 80 acres and had manufacturing operations from 30 to 100 yr. Each of the facilities used a host of hazardous chemicals for purposes that were associated with raw materials, degreasing, lubricating, painting, plating, machining, metal melting, energy and packaging.
To evaluate the frequency and financial risk posed by the release of hazardous substances, records on subsurface investigations and remediation were compiled. Cost data were obtained from internal sources, outside consultants, and, in some cases, from publicly available sources. The use of multiple sources for cost data was designed to provide verification of their accuracy and to minimize the potential for underestimating true costs.
Specific chemical categories include: volatile organic compounds (VOCs), polynuclear aromatic hydrocarbons (PNAs), polychlorinated biphenyls (PCBs), and metals (including arsenic, barium, cadmium, hexavalent chromium, total chromium, copper, lead, manganese, mercury, and zinc). VOCs were further separated into two groups that included dense nonaqueous-phase liquids (DNAPL) and light-nonaqueous phase liquids (LNAPL). DNAPL compounds are VOCs that have chlorine in their atomic structure, have a specific gravity slightly greater than that of water, and are commonly used as solvents and degreasers. LNAPL compounds are VOCs without chlorine in their atomic structure, have a specific gravity that is slightly less than water, and are commonly used as solvents and in fuels, such as gasoline and diesel fuels.
After completing a subsurface investigation at a facility to determine which media were affected, the extent of contamination was directly measured using either a measuring tape or was determined using survey equipment in cases where the extent of contamination was extensive or extended beneath roadways or permanent structures. The subsurface investigations involved drilling soil borings and collecting and analyzing soil samples in a laboratory for the presence of contamination. At sites where groundwater was encountered and was impacted, the extent of groundwater contamination was evaluated by installing groundwater monitoring wells, and the groundwater samples were subsequently collected and analyzed in a laboratory for the presence of contamination. Contamination extents for organic compounds were evaluated to the corresponding analyte method detection limit listed as required by EPA (1983) In some instances, it was required to define groundwater impacts to concentrations below the maximum contaminant level (MCL). The groundwater investigation was required to continue until a concentration 10 times lower than the MCL was achieved.
Evaluating the extent of contamination for metals required a different methodology than the organic compounds, because metals naturally occur in the environment. Therefore, establishing background concentrations was required before evaluating the extent of actual metal contamination.
An accurate measurement of the recovered or remediated contaminant mass was required by the regulatory agencies at most sites. The amount of contaminant mass remediated was calculated at each facility by first collecting periodic and representative samples of the recovered contaminant waste stream. Concentrations of contaminants were then determined in the samples collected through laboratory analysis. Once the concentration in each sample had been determined and calibrated through time using multiple sample collection and analysis episodes, the recovered or remediated contaminant mass was calculated by multiplying the contaminant concentrations measured by the laboratory in the samples by the total volume of air or water removed by the remediation system or the volume of soil excavated. In some cases where in situ remedial measures were conducted, contaminant mass was determined by conducting a more detailed subsurface investigation that involved analyzing numerous samples in the area to be remediated using an in situ method.
Costs would be listed on tables which include future cost projections to obtain closure from the regulating authority, internal costs, lost property values, taxes, property carrying costs, legal fees, potential litigation settlements, court costs, regulatory oversight fees, costs associated with investigation and remediation. In addition, data and costs related to arsenic, barium, cadmium, copper, manganese, and zinc are listed in the tables.
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