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REFERENCES 1. Chemical and Engineering News, vol. 77, no. 17, p. 10, April 26, 1999. 2. Independent Technical Review of Three Waste Minimization and Management Programs, p. 3-2. Albuquerque, NM: U.S. Department of Energy, Albuquerque and Oakland Office, August 1995. 3. EPA Pollution Prevention Policy Statement: New Directions for Environmental Protection, June 15, 1993. 4. EPA Pollution Prevention Solutions During Permitting, Inspections and Enforcement. EPA/745-F-99-001, p. 29, June 1999. 5. Characterization of Municipal Solid Waste in the United States: 1996 Update, U.S. EPA, Office of Solid Waste, EPA530-R-97-015, p. 10. Prepared by Franklin Associ- ates, Prarie Village, KS, June 1997. 6. EPA Federal Facility Pollution Prevention: Tools for Compliance, EPA/600/R-94/154, p. 54, September 1994. 7. U.S. Department of Energy, Pollution Prevention Program Plan. DOE/S-01/8, p. 4. Washington, DC, 1996. 8. Los Alamos National Laboratory, Applicability of Waste Minimization to Environ- mental Restoration, LA-UR-96-17-21, Los Alamos, NM, pp. 9–15, June 1996. 9. EPA Environmental Management Systems Bulletin 1, EPA 744-F-98-004, July 1998. 10. U.S. EPA Waste Minimization EPA Assessment Manual, PEA/625/7-88/003, pp. 6– 10. Cincinnati, OH: Hazardous Waste Engineering Research Lab, July 1988. 11. U.S. EPA Facility Pollution Prevention Guide, EPA/600/R-92/088, Washington, DC, May 1992. 12. Characterization of Municipal Solid Waste in the United States: 1996 Update, U.S. EPA, Office of Solid Waste, EPA530-R-97-015, p. 89. Prepared by Franklin Associ- ates, Prarie Village, KS, June 1997. 13. Guidance for ROI Submissions. Albuquerque, NM: U.S. Department of Energy, 1996. 14. Environmental Protection Agency, U.S. Office of Research and Development, Guid- ance for the Data Quality Objectives Process, EPA/600/R-96/055, Washington, DC, September 1994. 15. U.S. EPA Facility Pollution Prevention Guide, EPA/600/R-92/088, Washington, DC, May 1992. ABBREVIATIONS A annual costs after implementation of P2 project B annual costs before implementation of P2 project C capital investment for the P2 project CAA Clean Air Act CERCLA Comprehensive Environmental Response, Compensation, and Liability Act C&D construction and demolition debris D estimated project termination/disassembly cost Copyright 2002 by Marcel Dekker, Inc. All Rights Reserved. D&D decontamination and decommissioning DfE design for environment DQO Data quality objective E installation operating expenses EMS environmental management system EPCRA Emergency Planning and Community Right-to-Know Act ER environmental restoration ISO 14000 International Organization for Standardization 14000 L number of useful years of a project MSW municipal solid waste NOV Notice of Violation NPL National Priorities List PA preliminary assessment PPE personal protective equipment PPOA Pollution Prevention Opportunity Assessment RCRA Resource Conservation and Recovery Act RI/FS remedial investigation/feasibility study ROI return on investment SI site investigation SWMU solid waste management unit TRI toxic release inventory WM waste management WMin/P2 waste minimization/pollution prevention GLOSSARY Construction and demolition debris (C&D) The waste building materi- als, packaging, and rubble resulting from construction, remodeling, repair, and demolition operations on pavement, houses, commercial buildings, plants, and other structures. Data quality objective (DQO) Qualitative and quantitative statements derived from the DQO process that clarify study objectives, define the appropriate type of data, and specify the tolerable levels of potential decision errors that will be used as the basis for establishing the quality and quantity of data needed to support decisions. It provides a systematic procedure for defining the criteria that a data collection design should satisfy, including when to collect samples, where to collect samples, the tolerable level of decision errors for the study, and how many samples to collect. Decontamination and decommissioning (D&D) The process of reduc- ing or eliminating and removing from operation of the process harmful substances, such as infectious agents, so as to reduce the likelihood of Copyright 2002 by Marcel Dekker, Inc. All Rights Reserved. disease transmission from those substances. After the D&D operation, the process is no longer usable. Demolition The wrecking or taking out of any load supporting structural member and any related razing, removing, or stripping of a structure. Also called deconstruction. Design for environment (DfE) The systematic consideration of pollution prevention/waste minimization options during the design consideration of any process associated with environmental safety and health over the product life cycle. Environmental assessment (EA) A document that briefly provides suf- ficient evidence and analysis for determining whether to prepare an environmental impact statement or a finding of no significant impact. This document will include a brief discussion of the need for the proposal, of alternatives as required by EPA regulations, of the environ- mental impacts of the proposed action and alternatives, and a listing of agencies and persons consulted. Environmental management system (EMS) A systematic approach to ensuring that environmental activities are well managed in any organiza- tion. It is very similar to ISO 14000. Environmental restoration (ER) Cleaning up and restoration of sites contaminated with hazardous substances during past production or dis- posal activities. ISO 14000 International Standardization of Environmental Management System Standard which is “that part of the overall management system which includes organizational structure, planning activities, responsibil- ities, practices, procedures, processes and resources for developing, implementing, achieving, reviewing and maintaining the environmental policy.” Municipal solid waste (MSW) Residential and commercial solid wastes generated within a community. Pollution prevention opportunity assessment (PPOA) A tool for a company to identify the nature and amount of wastes and energy usage, stimulate the generation of pollution prevention and energy conservation opportunities, and evaluate those opportunities for implementation. Recycling of materials The use or reuse of a waste as an effective substitute for a commercial product, as an ingredient, or as feedstock in an industrial or energy-producing process; the reclamation of useful constituent fractions in a waste material; or removal of contaminants from a waste to allow it to be reused. This includes recovery for recycling, including composting. Return on investment (ROI) The calculation of time within which the process would save the initial investment amount if the suggested Copyright 2002 by Marcel Dekker, Inc. All Rights Reserved. changes were incorporated into it. In this calculation, depreciation, project cost, as well as useful life are taken into account. Source reduction Any practice which: (a) reduces the amount of any hazardous substance, pollutant, or contaminant entering any waste stream or otherwise released into the environment prior to recycling, treatment, or disposal; and (b) reduces the hazards to public health and the environment associated with the release of such substances, pollu- tants, or contaminants. Thermal destruction Destroying of waste (generally hazardous) in a device which uses elevated temperatures as the primary means to change the chemical, physical, or biological character or composition of the waste. Examples include incineration, calcination, oxidation, and micro- wave discharge. Commonly used for medical waste. Toxic release inventory (TRI) Required by the EPCRA, a TRI contains information on approximately 600 listed toxic chemicals that the facili- ties release directly to air, water, or land or transportation of waste off-site. Vitrification A process of immobilizing waste that produces a glasslike solid that permanently captures radioactive materials. Waste combustion Combustion of waste through elevated temperature and disposal of the residue so generated in the process. It also may include recovery of heat for use. Waste management (WM) Activities associated with the disposition of waste products after they have been generated, as well as actions to minimize the production of wastes. This may include storage, treatment, and disposal. Copyright 2002 by Marcel Dekker, Inc. All Rights Reserved. 3 The Waste Management Hierarchy W. David Constant Louisiana State University and A&M College, Baton Rouge, Louisiana 1 INTRODUCTION The management of waste can be approached from several venues, including regulations, history, technical methods, and interpretations of past management practices and our current methods to manage waste in what is considered the proper approach today. This chapter will explore the above approaches to waste management, present the Natural Laws (1) for the reader’s consideration, and then describe a simple hierarchy for waste management based on these laws. The im- pact of the “implementation” of natural attenuation in many remediation schemes of today is also discussed. The objective is to raise awareness of both the capabilities and limitations that are placed on society in the management of waste. 2 HISTORICAL PERSPECTIVE While we have recently increased our awareness of environmental problems and waste management, these issues have been in effect to some degree since society began to reach beyond simple existence. Humankind for centuries has developed and exploited available resources in useful and necessary ways, along with wasteful approaches. However, significant problems arose once communities, towns and cities developed into urban centers wherein contamination of water Copyright 2002 by Marcel Dekker, Inc. All Rights Reserved. supplies from waste and animals caused significant deaths to occur. Further industrialization and heavy dependence on fossil fuels has in the past century greatly increased pressure on the environment to cope with the anthropogenic materials and methods of humankind’s development. The development of regu- lations in the United States, described below, best illustrates the interactions for such a heavily industrialized nation. In earlier history the best examples of industrial pollution are found in England (2), where factories contaminated nearby rivers and raised awareness about the limitations of drinking water sources. Air pollution resulted from use of coal for fuel, but it was only after many years, in the mid-1800s and later in the 1900s, that regulations and cause-and-effect mechanisms led to control of pollu- tant levels. Most unfortunate was the episode occurring in London during December 1952 due to stagnant conditions over the city, wherein pollutant concentrations resulted in death of about 4000 people from particulates and SO 2 buildup. This event was followed by the passage of the Clean Air Act by the government of England, which laid the basis for pollution control in that country. In the United States, the historical perspective can be best represented through actions and activities in the United States and resulting regulations, to tie two perspectives together. Initial efforts were focused on water pollution by the River and Harbor Act of 1899, the Public Health Service Act of 1912, and the Oil Pollution Act of 1924, all being fairly localized in action. Only after World War II did the U.S. government take significant action to control pollution problems with the Water Pollution Control Act of 1948 and the following Federal Water Pollution Control Act (FWPCA) of 1956, which set funds for research and assisted in state pollution control with construction of wastewater treatment facilities. In 1965, the Water Quality Act provided national policy for control of water pollution. Focusing on drinking water, the Safe Drinking Water Act (SDWA) of 1974 directed the U.S. Environmental Protection Agency (EPA) to establish drinking water standards, which occurred in 1975. In 1980, Congress placed controls on underground injection of waste, requiring permits for the method. Finally, the SDWA amendments of 1986 led to interim and permanent drinking water standards. It was not until the 1972 amendments were made to the FWPCA that the nation implemented major restrictions on effluents to restore and maintain water bodies in the United States. The Clean Water Act of 1977 added to this focus with consideration of toxins being 65 substances or classes as a basis to reduce and control water pollution. This action led to the initial priority pollutants list, which included benzene, chlorinated compounds, pesticides, metals, etc. In combina- tion, then, the FWPCA and CWA provided the National Pollution Discharge Elimination System (NPDES) permit system in place today. These regulatory activities, while focused on water media and abatement of problems in rivers and other water bodies, did not directly address the other Copyright 2002 by Marcel Dekker, Inc. All Rights Reserved. media in our ecosystem—soil (land) and air. As industry responded to the water regulations, unengineered disposal of waste on land (unengineered pits) became an acceptable and legal method for waste management in many industrial streams, including petroleum wastes, petrochemical wastes and off-spec products, and solid waste disposal (old garbage dumps). These activities led to numerous acts to control and mitigate pollution from dumping, etc. Initial efforts involved control of the transportation of solid food wastes for swine, for control of trichinosis. Modern regulations began with the Solid Waste Disposal Act (SWDA) of 1965 and the National Environmental Policy Act of 1969, which required environmental impact statements. The Resource Recovery Act of 1970 amended the SWDA about the time that the Environmental Protection Agency was formed. True regulation for solid waste management did not come into effect until the Resource Conservation and Recovery Act (RCRA) of 1976, with guidelines for solid waste management and a legal basis for implementation of treatment, storage, and disposal regulations. Also, hazardous wastes and solid wastes were defined by the RCRA. With numerous amendments, the RCRA was followed by the Comprehensive Environmental Response, Compensation and Liability Act (CERCLA) in 1980 to deal with abandoned sites and provide the funds and regulations to perform cleanups. CERCLA, or Superfund, has been through numerous revisions, and its effectiveness has come under question due to the great deal of litigation involving cleanup of old sites. Air quality needs became apparent in the 1950s due to the Donora, Pennsylvania, accident, and the linkage shown between automobile emissions and photochemical smog, but it was not until the Clean Air Act of 1963, and amendments in the 1960s, 1970s, and 1990s that true national programs were established for pollution control in the air medium. These regulations were focused on motor vehicle emissions, and on emissions from industrial sources. Thus, the United States has “chased” waste management and pollution in all media, and while regulations are now complex, they do provide for control, management, and abatement of pollution from recognized sources to water, land and air. Two points develop from this brief historical–regulatory review. First, waste is tied directly to population, and population is growing at a rapid rate, so these growth centers must manage and direct waste properly to avoid release and contamination problems. Second, while many countries have significant controls in place as in the United States, many Third World countries and underdeveloped regions are “behind the curve” in regulatory and technical development to manage waste. Many are still dealing with “end-of-pipe” technologies while the United States and others are dealing with remediation, mitigation, and pollution prevention. Still others lack the fundamentals of basic treatment technologies and have significant population growth. Thus our history, in the United States and England, has the potential to continue to repeat itself, unless proper technology Copyright 2002 by Marcel Dekker, Inc. All Rights Reserved. is brought to these developing population areas. While the United States and England had time to deal with waste issues, our continued use and development of agricultural land has diminished our resources, and places high stress on those agricultural lands to provide food for the expanding of society. Hopefully, balance will be achieved on a global scale in time to meet the population demand with managed resources and sufficient waste management to protect all media and humankind. 3 TECHNICAL APPROACH In order to manage waste properly, we must explore the geography of a process so that appropriate engineering (and the constraints of different areas of geogra- phy) can be applied to solve a waste management issue or problem. Let us focus now on a chemical manufacturing process, wherein raw materials are taken to manufacture products, such as petroleum to petrochemicals for containers. There are three distinct areas—the process itself, the facility boundary (fence line), and “nature” outside the fence line. Historical sites such as those covered in Super- fund regulations also include a boundary and “nature.” Nature is defined here as everything except humankind or society. In order to properly apply a sound technical approach to the waste management of such a manufacturing facility, each of these three areas must be considered from an engineering perspective. First, in the process itself, classical chemical engineering is applied, including reactor design, thermodynamics, unit operations, mass transfer, etc., which are well established methods in the chemical process industry (CPI). The focus here is on the process, products, and profit. The second area, the boundary of the facility, is where the bulk of waste management is located, including recycle, reuse, treatment, source control, etc. Lines of these two areas are blurred today with optimization of processes, recycle, and substitution of chemicals to minimize pollution. However, both of these geographic areas are engineered and controlled in terms of materials handling, processing, and safety, as would be found in any chemical process. The third geographic area brings us to nature—the area around the facility or waste site, where the fate and transport of contaminants released from the first two regions now takes control. In the realm of environmental chemodynamics (3), the controlling factors are the transport of chemicals in the environment, governed by the physical-chemical relationship to reaction, trans- port, etc. Waste management in this region now involves sorption, sediment oxygen demand, groundwater modeling, biodegradation, partition coefficients, and other multimedia processes. The shift in understanding in this region is significant. We no longer have a reactor vessel, a temperature controller, or a homogeneous catalyst bed. The systems are heterogeneous, are difficult to scale, and may not provide consistent or reproducible results when management meth- ods or technologies are applied to a waste problem. In addition to our lack of Copyright 2002 by Marcel Dekker, Inc. All Rights Reserved. control over these systems, problems faced are usually dealing with low levels of contamination, which are difficult to model, predict, or treat. However, as risk assessment and exposure assessment methods improve in accuracy and realism, these problems are being tackled with growing frequency. It is important to recognize in the natural environment that our efforts are usually secondary to existing natural forces. An excellent basis to approach management of waste, both in the CPI model and beyond, in nature, is found in the Natural Laws, as illustrated below. Also, a significant contrast develops when we look at the Natural Laws, especially if one compares them to the five elements in the federal approach to management of hazardous wastes, as listed below: 1. Classification of hazardous waste 2. Cradle-to-grave manifest system 3. Federal standards for treatment, storage, and disposal (TSD) facilities 4. Enforcement with permits 5. Authorization of state programs 4 THE NATURAL LAWS Dealing with waste falls under the Natural Laws (1,4) and it is from these laws that the waste management hierarchy is formed: 1. I am, therefore I pollute. 2. Complete waste recycling is impossible. 3. Proper disposal entails conversion of offensive substances into environ- mentally compatible earthenlike materials. 4. Small waste leaks are unavoidable and acceptable. 5. Nature sets the standards for what is compatible and for what are small leaks. Briefly, these laws state the rules we must follow to properly manage waste in the future. Since we exist, we generate waste, and thereby pollute. This is due to the second law, which makes complete recycling impossible, as in thermodynam- ics, wherein no real process is completely reversible—some loss occurs. With some waste therefore being generated, the third law requires that the material be returned to the environment (nature) in a compatible format—that is, earth- enlike—in either a solid, liquid, or gaseous state. When returned, small leaks will occur, as with minor auto emissions, and these are unavoidable and acceptable, provided we observe nature’s standards as to what is compatible and how small (or large) the leaks can be. A logical flow of management choices follows from these laws. Copyright 2002 by Marcel Dekker, Inc. All Rights Reserved. 5 WASTE MANAGEMENT CHOICES The following list incorporates all options available and is similar to lists developed by the EPA and others (5). The management list also supports the relationship presented by Reible (2) in that environmental impact is proportional to population times per-capita resource usage divided by environmental effi- ciency. In words, then, the environmental impact is minimized for a given standard of living when the environmental efficiency is high or improved. Reible’s relationship supports the third law, to minimize impact via high environ- mental efficiency, returning material (and energy) in compatible forms. It is important to note here that much of the waste discussion focuses on material, and that energy pollution should not be neglected, due to problems found in changing river temperatures due to discharge, global warming, etc. To answer the old question, “How clean is clean?,” a material is clean when it is returned in a form, amount, and concentration which is acceptable to that found in nature. In other words, a material is “clean” when its concentration does not exceed the natural limits of that material in the space established by the balances (material) that assimilate it (6). Clearly, then, minimization is the first choice and the optimal one from an environmental standpoint. However, society demands a certain standard of living, so for those wastes remaining from minimization, destruction becomes the best alternative. Why destruction, as such a choice would support technologies such as incineration? Because it is the molecular structure, among other things, that provides the toxicity of the compound, and if it can be broken down (hopefully not yielding a more toxic compound), toxicity can be reduced or eliminated in efficient and correct incineration processes. However, not all wastes causing toxicity problems can be destroyed, such as heavy metals passing through an incinerator. Thus, these materials must be properly treated prior to release, changing their chemical states or bonding for a less toxic or hazardous form. Finally, one notes that in all processes such as those above and others, some residuals always remain, and lead to the final option, disposal. Disposal requires compliance with the Natural Laws—earthenlike materials acceptable to nature’s standards for assimilation. Thus, the hierarchy for waste management is simply: 1. Minimization 2. Destruction 3. Treatment 4. Disposal While technologies may overlap these steps, all are contained within, which brings us to an important concept: how does natural attenuation fit into the waste management scheme above? Natural attenuation, or monitored natural attenuation Copyright 2002 by Marcel Dekker, Inc. All Rights Reserved. [...]... storage, and disposal of hazardous waste In 1984 and 1986, Congress passed major amendments to the RCRA The 1984 amendments were known as the Hazardous and Solid Waste Amendments (HSWA) The HSWA required phasing out land disposal of untreated hazardous wastes The HSWA also added increased enforcement authority for the EPA, provided for more stringent hazardous waste management standards, and provided for. .. requires solid and hazardous waste generators to concentrate on fundamental process changes to prevent waste (particularly hazardous waste) from being generated in the first place, rather than regarding hazardous waste streams as a necessary concomitant to industrial production and focusing on the treatment and disposal of that waste Pollution prevention, as opposed to hazardous waste treatment and disposal,... tank program The HSWA also provided for corrective action for releases from solid and hazardous waste management units (both active and inactive) at operational solid and hazardous waste management facilities 2.4 The Pollution Prevention Act of 1990 and a New Way of Managing Hazardous/Toxic Waste Streams In response to many commentators, who noted that the existing RCRA and CERCLA regulatory frameworks... and emergency preparedness and response (contingency planning) Corrective action: The company must establish and maintain documented procedures to monitor and measure operations and activities that impact on the environment, and must have documented procedures for investigating nonconformances and implementing appropriate corrective action Procedures must be in place for identifying, maintaining, and. .. electricity was to be used, rendered Love’s plans for the canal uneconomic, and Love’s dream for the canal was never realized The abandoned canal filled with rainwater and was used as a swimming hole and for winter ice skating by the local community In the 1940s, Hooker Chemical Company obtained rights to the canal, and began to use the old canal as a dump for chemical wastes from Hooker’s chemical manufacturing... chemicals in their processes Unlike the RCRA and CERCLA, which provide at best indirect liabilitydriven disincentives to the use and production of toxic and hazardous substances and wastes, the Pollution Prevention Act attempts to focus public, governmental, and industry attention on reducing the amount of pollution produced, by encouraging cost-effective changes in production, operation, and raw materials... the community and are prepared to respond if there is a release, spill, or leak from such facilities 2.3 Solid and Hazardous Waste Management and the Resource Conservation and Recovery Act In contrast to legislation enacted as a reaction to environmental crises or catastrophes, the regulation of facilities and activities related to solid wastes (and of hazardous wastes as a subset of solid wastes), is... strategy for addressing wastes, particularly hazardous or toxic wastes, is a “command -and -control system imposed upon the regulated community from the top down By contrast, many pollution prevention initiatives are voluntary efforts initiated by companies that seek to improve the “bottom line,” rather than requirements imposed by a regulatory agency To understand the current emphasis on pollution. .. including pollution prevention versus “end-of-pipe” controls The EPA now provides Web-based information and tools for companies or entities that wish to pursue pollution prevention or environmental management systems initiatives (6) The EPA’s Office of Enforcement and Compliance Assistance has produced “Sector Notebooks” for the following industry sectors: Agricultural Chemical, Pesticide and Fertilizer... initiated a regulatory reform effort that allowed regulated companies to propose multimedia projects meeting certain criteria to allow trade-offs between media and to enable better environmental performance overall within a facility This regulatory reform effort, denominated “Project XL,” allowed companies and other entities to propose projects that substitute performance based standards for the prescriptive, . Bulletin 1, EPA 744-F-98-004, July 19 98. 10 . U.S. EPA Waste Minimization EPA Assessment Manual, PEA/625/7-88/003, pp. 6– 10 . Cincinnati, OH: Hazardous Waste Engineering Research Lab, July 19 88. 11 problems with the Water Pollution Control Act of 19 48 and the following Federal Water Pollution Control Act (FWPCA) of 19 56, which set funds for research and assisted in state pollution control with construction. REFERENCES 1. Chemical and Engineering News, vol. 77, no. 17 , p. 10 , April 26, 19 99. 2. Independent Technical Review of Three Waste Minimization and Management Programs, p.

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