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Sub-sectoral Environmental Guidelines

AGROCHEMICALS (Fertiliser/Pesticides)

PROCESS DESCRIPTION

Primary pesticide manufacturing conventionally entails several process steps to


build up a biologically active chemical entity from raw materials and/or
specific chemical intermediates. It should be recognised that as opposed to
fertiliser manufacture the manufacture of these biologically active molecules
poses a much higher degree of risk to the environment. Evidence of this is that
of the 19 'red' (i.e. hazardous materials) list substances for water, 12 are
pesticides. Some pesticides are manufactured from extremely hazardous raw
materials such as organophosphorus compounds (OPs). Such materials are
recognised nerve agents and must be handled with great integrity. The final
products are persistent in the environment and thus extra care must be taken
when handling these materials.

Secondary processing involves the formulation of the pesticide in a marketable


form. This normally only involves physical operations such as vessel charging,
mixing, milling, warming, cooling, product transfers, granulation, drying,
sieving and packaging. No chemical reactions should take place during
secondary processing. Pesticides are formulated in a number of forms, for
example, as emulsifiable concentrates, oil in water emulsions, flowable
concentrates, granules, water dispersible granules and wettable powders,
depending upon the product.

There are three main types of fertilisers. Ammonium nitrate is produced


through the neutralisation of nitric acid using ammonia, the ammonium nitrate
is evaporated and the resulting solution converted to solid particles of a
particular size range, as specified by the market. Ammonium phosphate is
produced by the exothermic reaction of phosphoric acid and ammonia. Water
or contaminated condensate is added to control the reactor temperature and a
slurry product results. Single superphosphate (SSP) is produced by the reaction
of phosphate rock with sulphuric acid, converting insoluble calcium phosphate
to a soluble form with the release of large amounts of steam.

SUMMARY OF KEY ENVIRONMENTAL RISK/LIABILITY FACTORS

Fire/Explosion Risk

The materials used in fertilizer plants are highly explosive, and are, in fact,
used to make explosives.

Air Emission Management

· Dust and fugitive emissions arising from vessel charging in pesticide


formulation.
· Leakages and fugitive releases form seals, gaskets and valves in pipework.

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· Releases could contain dusts, particulates, volatile organics, possibly
pesticides, ammonia, urea.
· From fertiliser plants gaseous emissions may include compounds of sulphur,
nitrogen and fluorine, and also particulates.
· Requires control, LEV, bag filters for pesticides this may include off-gas
incineration with complex monitoring and backups.

Issues to Consider:

· Inventories of OPs.
· Abatement technology required to remove fluorine gases produced in
process, potential for adverse human health effects.
· Used filters can contain catalysts containing heavy metals which require
careful disposal.
· Abatement technology for handling of OPs.

Water Supply and Wastewater Management

· Sources of process and potable water - municipal, abstraction wells,


boreholes (quality of water is critical: check ion content, hardness,
microbiology, organics, heavy metals).
· Final wastewater from fertiliser plants is likely to arise from by-product
streams, scrubber effluents, liquid spills, washing liquors and condensate
liquids.
· Permits and charges are usually required for water abstraction.
· High potential for recycling and reuse of water and heat.
· Contaminated wastewater with products and by products of the production
process.
· Fate of all wastewater leaving the site.
· Releases could contain organic and inorganic wastes, ammonia. In the case
of pesticide manufacture, these will include red list substances.
· Releases of wastewater with a high nutrient content can have an adverse
effect upon receiving waters (eutrophication).
· Contents of effluent from fertiliser waste pond can contain arsenic and
vanadium which are poisonous to aquatic and human life.

Issues to Consider:

· Integrity of drainage system. Check surface/fouldrains, soakaways,


underground drainage system, interceptors etc.
· Quality of wastewater treatment plant (facility/municipal) - check type,
effectiveness, monitoring, final effluent disposal.
· Regulatory compliance - discharge consents, enforcement, costs.

Odour and Noise

Odour and noise may reach or exceed nuisance/safety levels. Check regulatory
compliance and complaints records.

FINANCIAL IMPLICATIONS

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Note if pesticides are manufactured, then risk/liability factors will be much
greater.

· Fees and penalties (air emissions, effluent discharges, solid and sludge
disposal).
· Risk of major spills resulting in substantial liability claims.
· Runoff/storm water drainage from raw material, finished product and waste
holding areas.
· Contamination of soil and groundwater from leaking storage tanks/loading
areas.
· Public/environmental health and nuisance (smell etc.) issues associated with
vented fumes.
· Potential releases of fluorine in superphosphate manufacture for fertilisers.
· Site location, especially if pesticides are being manufactured.
· Pollution abatement can be expensive.
· Relatively high potential for soil and groundwater contamination - can be
very costly to remediate.
· Phase out/reduced usage of fertilisers and pesticides because of tighter
legislation may have a significant effect on the market for these products.
· Long term investment in operation and maintenance costs could increase if
there is a trend towards a more stringent regulatory environment.
· Exposure of workforce to pesticides (eg., OPs). Personnel should be
monitored.

OTHER POTENTIAL ENVIRONMENTAL ISSUES

Storage of Oils, Gases and Chemicals

Considerable quantities of oils, gases and chemicals may be utilised in the


process. Typical storage includes the following:

· underground storage tanks (UST);


· bulk storage oil tanks;
· underground phosphoric acid tanks;
· fuel oil tanks;
· tank farm (multiple tanks) containing finished product;
· drums of assorted additives, caustics, disinfectants, detergents, solvents.

Issues to Consider:

· Secondary containment of tanks (bunds etc.) to prevent spills reaching the


wider environment.
· Licensing of pressurised tanks.
· Regular integrity testing of UST and bulk storage tanks.
· Accident/fire precautions and emergency procedures.
· Venting of tanks containing OPs.
· Handling procedures for OPs.

Solid and Hazardous Waste Management

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Typical wastes include:

· waste raw materials;


· waste oils;
· sludges (often caustic);
· solid wastes (drums, cartons, packaging, domestic);
· waste catalyst;
· off-spec product;
· pesticide waste.

Issues to Consider:

· Regulatory requirements.
· Means of hazardous waste disposal.
· Means of solid waste management.
· Disposal permits.
· Waste disposal contractors (approved? licensed?).
· Ownership of waste disposal sites.
· Pollution of soil and groundwater.
· Solid waste from fertiliser plant can be stored in ponds, where leaching can
cause serious water quality problems. Waste is often highly acidic and some
sludges may be toxic.
· Safe disposal of pesticide substances.

Asbestos and PCBs

Asbestos and PCBs may need to be removed from the site which can be costly.

· Asbestos is found in building materials, pipework, insulation etc.


· PCBs can be found in transformer/hydraulic equipment oil, capacitors etc.

Site Setting and Security

· Dust emissions may affect residents and other industries located in the area.
· Wastes from fertiliser plants may be of use to nearby chemical works.
· The security of fertilizer production plants is an issue of concern, as
products may be stolen and used to make incendiary devices.

Personnel

Pesticide manufacture usually entails an assessment and routine monitoring of


personnel health, especially associated with OPs.

ENVIRONMENTAL IMPROVEMENTS

· Re-use heated wastewater to warm cold water supply.


· Pipe insulation etc.
· Change to cleaner fuel sources.
· Re-use of waste products in the process, e.g. process wastewater.

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· Recovery of raw materials, products, useful light fractions e.g. from heavy
residues and spent catalyst slurries, also nitrogen, super phosphates.
· Great potential for reuse of wastewater within fertiliser plants, thus
minimising final wastewater volumes.
· Compact waste packaging material sent for landfill.
· Minimise leakages and fugitive release from pipework through use of
appropriate corrosive resistant materials and leak proof valve and pump
design.
· Minimise dust production through extraction systems, management and
procedures for transfer of dry materials.
· NOx can be reduced 90-95% by catalytic conversion with ammonia to
reduce NOx to N2 also discharges of SO2 .

Pesticides

· Disposal of process waste is often very difficult.


· Issues mainly associated with efficient handling and storage throughout
the process.

Fertilisers

· Urea fumes can be wet-scrubbed and resultant wastewater used as low


grade fertiliser.
· Fumes and dust from ammonium nitrate manufacture can contain
nitrogen compounds which can be reused after minor treatment.
· Ammonia in process condensates, boiler blowdown or cooling tower
blowdown can be removed by stripping with air or steam.
· Phosphogypsum can be reused in building industry as plaster and in the
manufacture of building blocks once rendered a safe by-product.

GUIDE TO INITIAL DUE DILIGENCE SITE VISITS

Determine if the site is manufacturing pesticides or fertilisers. If pesticide


manufacture then look in more detail into any area where any materials may be
released into any medium.

· Perform a complete tour of the site compound if possible, include settlement


ponds if present, check discharge points.
· Determine nature of air emission abatement equipment.
· Observe for signs of bad housekeeping, dust accumulation, and poor
security.
· Note nature of disposal packaging materials.
· Note method of wastewater treatment for washdowns.
· Look for localised spills, leaking pipes etc.
· Check age of process equipment.
· Check use of personal protective equipment.
· Assess emergency response to fires, major spills etc.
· Site location.

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It is also suggested that contact is made with local regulatory agencies to
determine compliance record and whether complaints have been made by the
public.

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Sub-sectoral Environmental Guidelines
CHEMICALS AND ALLIED PRODUCTS
(Wholesale Distribution and Storage)

PROCESS DESCRIPTION

This guideline covers the following activities:

· transportation of chemicals to a warehouse;


· storage of chemicals at warehouses;
· repackaging or loading of chemicals prior to distribution from the
warehouse.

It does not cover the production of chemicals or the transportation and storage
of petroleum products. Both of these issues are covered in separate guideline
documents.

Subsequent to manufacture, chemicals and allied products are typically stored


in:

· fixed bulk storage tanks (gases and liquids) or silos (powders);


· transportable containers such as cylinders (gases), drums (liquids, solids)
and bags (solids).

Transfer from the site of manufacture to the warehouse will therefore typically
involve bulk tanker delivery or off-loading of individual, or group packaged
containers. Receiving warehouses therefore require:

· suitable off-loading equipment, such as pumps, hoses and forklifts;


· bulk storage facilities;
· adequate storage space for transportable containers;
· a thorough knowledge of the properties of the chemicals being transported
and stored. This information should be available on Material Safety Data
Sheets (MSDS) which accompany the transfer

Distribution of chemicals from the warehouse will raise similar issues to those
identified for delivery to the warehouse.

SUMMARY OF KEY ENVIRONMENTAL RISK/LIABILITY FACTORS

Accidental Release of Hazardous Chemicals

Accidental release of hazardous chemicals on site and in transit may result in


explosions, air pollution and significant environmental impacts in relation to
soil, groundwater and surface water contamination. Releases of hazardous
substances to the air could impact the local environment including human
receptors, potentially leading to large compensation claims. Remediation costs

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could be high, particularly if the site is in an area of high environmental
sensitivity, for example, if located on a drinking water aquifer. Additional
costs may include criminal or civil fines, ecosystem rehabilitation (e.g. fish
restocking) and claims from third parties such as nearby landowners or
residents.

Explosion and Fire Risk

Major explosions or fires at chemical storage facilities have resulted in


widespread contamination and destruction, impacting not only the immediate
site but surrounding land, rivers and communities. The release of hazardous
gases which may travel many kilometres from the site, is of particular concern.
Compensation costs for such incidents are high and widespread remediation
and rebuilding may be necessary.

FINANCIAL IMPLICATIONS

· Fees and penalties.


· Risk of accidental release of chemicals to air or surface water.
· Risk of explosion and fire risk.
· Contamination of soil and groundwater from leaking storage tanks/loading
areas.
· Outstanding claims (health and safety).
· Product liability issues.

OTHER POTENTIAL ENVIRONMENTAL ISSUES

Ecological and Exposure Hazards of Chemicals

Due to the wide ranging properties of specific chemicals and allied products, a
variety of hazards are associated with their storage and distribution. Significant
hazardous properties relating to individual chemicals include flammability,
combustion potential, toxicity, corrosive potential and oxidising potential.
Chemicals with such properties are typically labelled with the appropriate (and
internationally recognised) diamond shaped hazard symbol. Inadequate control
of hazardous chemicals can therefore elevate the risk of explosion or major fire
risk and lethal or sub-lethal impact on human and ecological receptors
(elements of the biological environment which could be affected).

Some chemicals may only possess a hazard potential if they have the
opportunity to react with other compounds. These incompatible chemicals may
therefore create any of the ecological and exposure hazards listed above if
stored together. In general, chemicals with different hazard symbols should not
be stored together - clear guidance on the compatibility of different chemicals
can be sought from the MSDS (which should be readily available from the
manufacturer).

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Soil, Groundwater and Surface Water Contamination

Contamination of soil, groundwater and surface waters (on site and in transit)
can occur through acute incidents and accidents such as a major spillage or via
gradual or repeated leakage. Surface waters are particularly vulnerable to
chemical contamination. Chronic, undetected leakages on site can occur as a
result of fractured vessels, seals, valves and pipelines.

Air Emissions

Emissions to air will result from the storage, transfer and handling of gases
volatile compounds and powders. This is a potential source of nuisance (e.g.
odour or dust emissions) and can present an environmental risk. Emissions to
air can be controlled by operational practices (e.g., conveyors rather than
manual handling to reduce dust emissions) or abatement techniques such as
vapour recovery lines or carbon absorption for organic compounds.

Public Anxiety

Public anxiety, particularly from neighbouring residents, can be caused by a


lack of knowledge regarding the nature of the chemicals being stored on the
site, odours from the site, the potential for fires and explosions and the action
that will be taken in the case of an accidental release. This public anxiety can
result in significant planning constraints being imposed on this type of facility.

Disposal of Solid Wastes

The main solid wastes of concern are damaged product and contaminated
packaging. Damaged product, particularly if hazardous in nature, will require
appropriate storage and disposal techniques. Primary packaging (e.g. plastic
liners within drums) and secondary packaging (e.g. distribution pallets, shrink
wrap) may be contaminated with hazardous chemicals. Both damaged product
and packaging may generate significant volumes of solid waste. The site
should comply with the regulatory requirements for the storage and disposal of
solid and hazardous wastes and use authorised waste transport and disposal
contractors.

Asbestos and PCBs

Asbestos and PCBs may need to be removed from the site which can be costly.

· Asbestos is found in building materials, pipework, insulation etc.


· PCBs can be found in transformer/hydraulic equipment oil, capacitors etc.

Odour and Noise

Odour and noise may reach or exceed nuisance/safety levels. Check regulatory
compliance and complaints records.

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ENVIRONMENTAL IMPROVEMENTS

Soil, Groundwater and Surface Water Contamination

· The potential for soil, groundwater and surface water contamination can be
minimised by regular inspections and preventative maintenance
programmes, pressure/integrity testing of underground storage tanks, the
provision of impermeable hard standing in storage areas, use of modern and
regularly checked tankers and trucks, adequate secondary containment and
the use of catchment pits, sumps or interceptors to prevent any potential
spillages reaching surface water drainage systems.

Explosion and Fire Risks

· Additional fire control systems (fire ring mains, reservoirs, sprinkler


systems, alternative fire fighting equipment where use of water use
inappropriate).
· The provision of a fire water holding reservoir.
· The installation of low and high level tank alarms.

Chemical Compatibility

· Building and storage design to allow both vertical and horizontal separation
of chemicals.

Public Anxiety

· Improvement in the quantity and/or quality of information provided to local


communities by the site - in some countries this is a legal requirement
depending on the volume and properties of the chemicals being stored.
· Vehicle management to and from the site, including total number of
movements, vehicle route and timing of vehicle movements (e.g. daytime
only).
· Location and timing of loading and off-loading areas.
· Minimisation of visual impact through appropriate landscaping.

Solid Wastes

· Manufacturer 'take-back' opportunities for damaged products.


· Reuse schemes for packaging (pallets, drums).

Develop an Environmental Action Plan (EAP) to focus on the prevention of


soil and groundwater contamination and the minimisation of explosion risks or
releases to air are essential in reducing the environmental risks posed by
chemical storage and distribution facilities. Key environmental management
measures should include:

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· regulatory compliance measures;
· clear labelling of hazardous chemicals in both vessels and pipes;
· maintenance of chemical inventories;
· posting of information around the site with regard to appropriate storage
techniques, segregation of incompatible chemicals and loading/off-loading
techniques;
· development and implementation of spill response plans;
· development and implementation (through regular practice drills) of on site
emergency plans;
· development of off site emergency plans and distribution of appropriate
information to nearby residents;
· procedures to assess validity of storage and transportation licenses with fire
· authorities and other agencies.
· removal of outdated chemicals or chemicals no longer used on site;
· roles and responsibilities, time frame and benchmarks.

GUIDE TO INITIAL DUE DILIGENCE SITE VISITS

· Perform a complete tour of the facility.


· Note the age and condition of the tankers and trucks used.
· Inspect the drainage systems, including nature, extent and types (e.g. foul,
storm), integrity, discharge points, locations of sumps, catchment pits,
interceptors and soakaways.
· Check containment measures for storage, including bunding (which should
be able to contain 110% of the volume of the largest enclosed tank).
· Look for evidence of spillage during loading and off-loading operations.
· Look for evidence of leakage from tanks or containers.
· Use of appropriate hard standing in chemical storage areas.
· Note levels of odour and dust around storage areas which might indicate
poor handling or storage practises.
· Review historical and projected environmental fees and fines.

Contact should also be made with local regulatory agencies to determine


compliance record and whether complaints have been made by the public
regarding the facility.

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Sub-sectoral Environmental Guidelines
INDUSTRIAL INORGANIC CHEMICALS

PROCESS DESCRIPTION

This guideline covers the production of a large range of non-carbon compounds


and cyanides and carbonates. Production of this wide range of chemicals
basically involves the conversion of simple raw materials, or specific chemical
intermediates, to an active chemical substance through several stages of
synthetic chemistry.

Ancillary activities may include boilers, refrigeration equipment, effluent


treatment plant and storage facilities for raw materials and finished products.

SUMMARY OF KEY ENVIRONMENTAL RISK/LIABILITY FACTORS

Air Emissions

Possible sources of air emissions include vapours or dusts from raw materials
and final products, combustion products (sulphur oxides, nitrogen oxides and
carbon oxides) and odours. Many of these emissions may be harmful to the
environment. Facilities may be required to obtain a permit from local
regulators. The permit comprises a series of conditions that may include
specific limits for pollutants and the installation of pollution control equipment.

Effluent Discharges

Effluent discharges to sewer and surface waters normally require discharge


permits from the regulatory authorities. The parameters in the permit will
depend on the nature of the operation, content, final destination and treatment
of the effluent. In many instances it is illegal to discharge effluent to a sewer or
surface waters without a valid discharge permit. The facility may be required
to install an effluent treatment plant, or contribute to the costs for off-site
treatment, by the regulatory authorities. Inorganic pollutants such as heavy
metals can be difficult to treat and can cause damage to the environment as they
accumulate in living organisms.

Soil and Groundwater Contamination

Sources of soil contamination include spillages or leaks from underground and


above ground storage tanks and waste disposal activities. Contamination of
surface and groundwaters may occur if pollutants enter the drainage systems or
filtrate through the soil. This is of particular concern where heavy metals and
other persistent inorganic chemicals, including cyanide, are released.

FINANCIAL IMPLICATIONS

Air Emissions

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The air emission permit may require routine and/or continuous monitoring of
specific emissions. Some of these emissions may require pollution control
equipment. Specific requirements will depend on local legislation and the
individual requirements of the regulatory authorities. Fines may be incurred if
the conditions of the permit are breached.

Effluent Discharges

Charges for wastewater are based on the quality and quantity of the effluent
discharged, but may also involve costs for special treatment. When the quality
of the wastewater consistently complies with the discharge permit, charges are
set at an agreed rate. However, if the permit limits are exceeded, the charges
will increase sustainability and fines may be imposed. The facility may face
pressures from the regulatory authorities to install an on-site effluent treatment
plant. This can involve significant expenditure.

Soil and Groundwater Contamination

If a facility identifies contamination on its site the actions required will depend
upon the regulatory authorities, the local regulations and the exact
circumstances of the site. The main cost of contamination is clean up, which
varies upon the nature and extent of the contamination and the local geological
and hydrogeological conditions. Costs for clean up of contaminated
groundwater are generally higher than those for soil. In general, older facilities
with a long history of chemical production and storage are more likely to be
contaminated.

OTHER POTENTIAL ENVIRONMENTAL ISSUES

Waste Disposal

Wastes arising from inorganic chemical production have the potential to be


hazardous. Disposal should be carried out in the correct manner, with no direct
dumping on the site. Normally, non-hazardous wastes are buried in landfill
sites and hazardous wastes are destroyed in large commercial waste
incinerators or specially licensed landfills.

The costs of waste disposal vary according to the final disposal method, the
hazards associated with a particular waste and the location and availability of
suitable disposal sites.

Storage and Spillage of Chemicals

Considerable quantities of chemicals are likely to be stored on-site. Storage


facilities may include above or below ground tanks, tank farms or large drum
storage compounds. Adequate measures must be taken to prevent the
chemicals contaminating the soil, groundwater and surface water in the
surrounding area. Chemicals can enter watercourses as a result of accidental
releases from storage vessels and production processes, or from deliberate

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disposal on-site. All storage facilities should be provided with appropriate
secondary containment.

Gases should be stored in bulk pressurised vessels and appropriate safety


measures should be installed to prevent accidental releases and also explosions.

Nuisance Related Issues

Local nuisance complaints can arise in response to emissions of noise and


odour. The measures to reduce noise and odour emissions range from simple
actions such as the installation of noise baffles to complex and expensive
abatement technologies for specific odours.

ENVIRONMENTAL IMPROVEMENTS

Potential environmental improvements may include:

Air Emissions

· Install abatement equipment.


· Identify and minimise leakages and fugitive emissions from seals, gaskets;
and valves in pipework and process vessels.
· Heat transfer and pipe insulation.

Effluent Discharges

· Minimise the volume of effluent through the potential to re-use wastewater


within the process.
· Minimise leakages and water loss in the system.
· Minimise use of water during washdowns.
· Install or upgrade on-site effluent treatment plant.

Storage of Chemicals

· Upgrading of storage areas to ensure proper containment of accidental spills


and leakages.
· Minimise the risk of accidental discharge to surface and groundwater by:
· provision of secondary containment and bunds for bulk and drummed
storage of chemicals;
· regular integrity testing of underground storage tanks and bulk storage
tanks;
· develop written procedures for tank filling, spill response and bund
drainage.

Others

· upgrade refrigerant in chilling/refrigerant system to non-CFC coolants, and


minimise leakages.

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ENVIRONMENTALAL ACTION PLANS

Environmental action plans should focus on the minimisation of air and


effluent emissions and the correct storage of chemicals as well as:

· the maintenance of legislative compliance at the facility;


· minimisation of emissions to the environment;
· procedures for the handling and storage of liquid chemicals;
· disposal procedures for waste raw materials, product intermediaries and
waste finished product leaving the site;
· preventative maintenance programmes for pollution control and abatement
equipment;
· storage of raw materials, finished goods and process chemicals;
· spill control and prevention measures.

GUIDE TO INITIAL DUE DILIGENCE SITE VISITS

During the initial site visit, it will be important to assess the following:

· compliance with air emission permits and presence of visible/odorous


emissions;
· presence and efficiency of emission abatement technology;
· the wastewater treatment plant if present and the discharge points:
· the operation and maintenance of the wastewater treatment plant;
· compliance with wastewater permit;
· methods of disposal and destination of solid waste;
· condition and adequacy of chemical storage areas, both bulk tanks and
drummed chemicals and the presence of secondary containment;
· visible evidence of staining or spillages;
· evidence of dead or distressed vegetation on-site;
· cooling systems, if present, and type of refrigerant used;
· site location/surrounding area activities.

Contact should be made with the local regulatory agencies to determine


compliance record and whether complaints have been made by the public.

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Sub-sectoral Environmental Guidelines
PLASTICS AND SYNTHETICS

PROCESS DESCRIPTION

The activities covered in this guidance note include the manufacture (linkage
reactions of organic monomers) of plastic and synthetic materials. Auxiliary
operations may include the production and recovery of monomers, production
(blending and mixing of chemicals and the fabrication) of plastic and other
synthetic items as intermediate or finished goods and printing operations. If
heat is required for chemical reactions, facilities may also maintain large boiler
plant for the production of steam.

SUMMARY OF KEY ENVIRONMENTAL RISK/LIABILITY FACTORS

Air Emissions

A very large range of organic and inorganic chemicals may be released as raw
materials or by-products of the production processes. Where monomers are
being produced, recovered or polymerised, or where the polymers are being
processed, highly reactive (and hazardous) monomers are likely to be emitted.
Air emissions are normally prescribed in air emission permits which set
emission limits for specific, named chemicals.

Some or all of the emissions may require continuous monitoring and pollution
control/abatement equipment in order to maintain emission levels within the
parameters of the air emission permits. Production facilities may also be
required either to eliminate emissions or, where this is impractical, render them
harmless.

In order to maintain safe and healthy working conditions within production


facilities, free monomers and dusts are extracted using local exhaust ventilation
(LEV). These sources of emission, whilst relatively minor, may also require
appropriate pollution control measures.

FINANCIAL IMPLICATIONS

Air Emissions

Continuous monitoring and pollution control/abatement devices may be a very


significant cost. Specific requirements would depend on local legislation and
the individual requirements of local regulators. Abatement controls may
include thermal incineration or condensation of volatile compounds, scrubbing
water soluble compounds (particularly acids and bases), and the arrestment of
dusts, using electrostatic or cyclone precipitators.

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As with all large commercial boiler plant, a tightening of air emission
parameters may, dependent on the fuel currently being used, require
considerable investment in either abatement technologies or in the purchase of
new boilers which burn a cleaner fuel. The cost of purchase of such plant may
be very significant.

OTHER POTENTIAL ENVIRONMENTAL ISSUES

Wastewater Discharges

Discharges to water will arise from wastewater discharges to sewers and


surface waters. A permit with specific discharge parameters may be required.
There are likely to be costs associated with achieving compliance with the
discharge consent.

Many facilities operate wastewater treatment plants to perform primary


treatment to effluent prior to discharge to the sewerage system. In some cases,
wastewater treatment plant may be a full mechanical and/or bio-treatment
facility to treat effluent prior to discharge to surface waters, where no further
treatment will be performed. Variations to wastewater discharge consents may
require changes in the operation of the treatment plant, in order to maintain
compliance.

Storage and Spillage of Chemicals

Where significant volumes of chemicals are stored, for example in tank farms
and large drum storage compounds, adequate measures must be taken to
prevent accidental releases from entering the soil and polluting the ground
water or nearby surface waters. Chemicals can enter water courses as a result
of accidental releases, such as spillages or leakages from storage vessels or
from accidents during the production processes.

The prevention of spillages is mostly a management and procedural issue,


however, all storage facilities should be provided with appropriate secondary
containment.

Waste Management

All chemical processes produce varying quantities of hazardous waste, ranging


from acids and solvents, to biologically active chemicals. The disposal of
hazardous wastes requires that adequate measures are taken to identify the
waste and adopt the most appropriate route for disposal. In some cases, trans-
frontier shipments are necessary and from time to time, overseas transport is
required. In such cases, the producers must endeavour to make sure that the
wastes are adequately labelled and packaged securely and that the waste are
properly disposed of at the final disposal facility. The disposal/destruction of
some waste streams (usually biologically active chemicals) requires official
witnesses to be present.

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The disposal of hazardous wastes is expensive, especially where specialist
disposal methods are required and when the waste have to be transported across
frontiers.

ENVIRONMENTAL IMPROVEMENTS

Potential environmental improvements may include:

Waste Minimisation

· The recovery and re-use of raw materials where practicable.


· The elimination of certain waste streams from processes or product lines.
· Heat transfer and pipe insulation.

Other

· Improvements in chemical bulk storage to minimise the risk of accidental


discharge to surface and groundwater.
· Establish opportunities to recycle waste plastic where practicable.
· Improvements in housekeeping to minimise unnecessary discharge of other
materials to the environment.

ENVIRONMENTAL ACTION PLANS

Environmental action plans should focus on the following:

· maintaining legislative compliance at the facility;


· adherence to written procedures;
· minimising emissions to the atmosphere;
· proper disposal of wastes, particularly hazardous/chemical waste.
· preventative maintenance programmes for pollution control and abatement
equipment;
· materials storage;
· spill control and prevention measures;
· tracking changes in legislation;
· companies with relevant health and safety legal requirements.

GUIDE TO INITIAL DUE DILIGENCE SITE VISITS

During the initial site visit, it will be important to assess the following:

· compliance with air emission permits;


· housekeeping, the general manner in which wastes are handled and the
overall appearance of the site;
· cooling systems, if present, and type of refrigerant used;
· disposal of solid waste, off site waste disposal facilities;

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· the operation and maintenance of the wastewater treatment plant, if present,
check discharge permits and points;
· site location/surrounding area activities.

Contact should be made with the local regulatory agencies to determine


compliance record and whether any complaints have been made by the public.

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Sub-sectoral Environmental Guidelines
PRODUCTION OF DRUGS AND
PHARMACEUTICALS

PROCESS DESCRIPTION

The activities included in this guidance note include the manufacture of natural
and synthetic drugs and pharmaceuticals. This note, however, does not include
"down stream" activities, such as wholesale, distribution and retail of products.

Many of the processes involve chemical reactions, and may require the input of
energy (in the form of heat and pressure etc.). Auxiliary operations may
include the production of heat, steam, compressed air and cooling equipment.
Other processes may comprise milling and/or blending of products. Synthetic
pharmaceutical production processes may be part of much larger manufacturing
complex, using the products or by-products of one process as a raw material for
another. Production plants may share common site-derived services such as
power, effluent treatment etc., which may be managed by site personnel, not
directly involved with the pharmaceuticals production.

Research and development activities require almost as many employees as


production, so the number of staff at risk at any given time may reach several
thousands.

SUMMARY OF KEY ENVIRONMENTAL RISK/LIABILITY FACTORS

Product Contamination

Drugs and pharmaceutical products usually need to be manufactured in a sterile


environment. There are a considerable number of industry guidelines which
relate to clean air systems, hygiene procedures, clean room requirements which
must be adherred to if the product is to stay free of contamination. The
ventillation system, part production activities, the age of the production
building and manufacturing practices all influence the potential risk of product
contamination and cross contamination.

Air Emissions

Air emissions may include the following:

· toxic gases;
· volatile organic compounds;
· dusts;
· odours;
· combustion products (oxides of sulphur, nitrogen and carbon).

Points source emissions will often require air emission permits, which may
stipulate limits for specific, named pollutants. In order to control these

1
emissions, the facility is likely to be required to monitor emissions and submit
the results to the authorities. Depending on the nature or size of the process,
pollution control equipment or abatement devices may be required in order to
bring emissions within permitted limits. In many instances it may be illegal to
operate and emit pollutant to the atmosphere without a valid permit.

Wastewater Discharges

Discharges to water may include:

· active ingredients;
· organic compounds;
· inorganic salts, acids, alkaline solutions;
· sludges.

In many instances, due to the nature and volume of the effluent, facilities will
require on site effluent treatment plant. Such plant may be auxiliary to existing
municipal effluent treatment plant currently treating the facilities' discharges, or
may provide full treatment, independent of a third party.

Industrial effluent discharges to sewer and surface waters are likely to require
discharge permits from the regulatory authorities. Depending on the nature of
the operation and the final destination of the discharge (whether it undergoes
secondary treatment, for example at a municipal sewage treatment works, or
discharged untreated) the permitted parameters within the consent may vary. In
many instances it may be illegal to operate and discharge wastewater to a sewer
or surface waters without a valid discharge permit. The facility may be
required by regulatory pressures to install/upgrade on-site effluent treatment
facilities or face rising costs for off-site treatment. Some organic effluents may
require specific treatment technology requiring stream segregation.

Storage and Spillage of Chemicals

The potential range of chemicals that may be stored is considerable. They fall
into three basics divisions:

· raw materials;
· intermediate chemicals;
· finished products.

In general, intermediates and raw materials tend to be chemically reactive,


whereas, active ingredients present in finished products may have
biochemically hazardous properties.

Where significant volumes of chemicals are stored, for example in tank farms
and drum storage compounds, adequate measures must be taken to prevent
accidental releases from entering the soil and polluting the groundwater or
nearby surface waters. Chemicals can enter water courses as a result of
accidental releases, such as spillages or leakages from storage vessels or
associated pipework, or from accidents during the production processes.

2
Spillages and pollution incidents, often occur in the event of poor management
and maintenance of storage areas. All storage facilities should be provided
with appropriate secondary containment.

Soil and Groundwater Contamination

There are a number of situations where contaminants could be spilled and enter
the soil or surface waters. Contamination of the soil could occur from a
spillage or seepage from underground and above ground storage tanks,
associated pipework or from waste disposal activities. Surface and
groundwaters may become contaminated if pollutants enter the drainage
systems, or seep through the soil. Certain organic chemicals are capable of
degrading plastic pipework, permeating concrete or asphalt and entering the
groundmass where they may be highly mobile. Organic solvents (toluene,
xylene, chlorobenzene, etc.) may be highly toxic, endangering drinking water
resources.

FINANCIAL IMPLICATIONS

Product Contamination

Significant expenditure may be required in upgrading clean rooms, ventillation


systems, manufacturing processes in order to comply with accepted industry
standards of practice for product hygiene. In some cases this may mean
relocating the production processes to a purpose-built building.

Air Emissions

The air emission permit may require analysis of air emissions and frequent or
continuous monitoring for specified pollutants. Some emissions, such as
volatile organic compounds and dusts, may require pollution control devices or
abatement measures. Volatile organic compounds are not allowed to be
released into the atmosphere. Catalytic burners or other cleaning equipment
may need to be installed, with extensive cost implications. Specific
requirements would depend on local legislation and the individual requirements
of the regulatory authorities.

Effluent Discharges

Charges for wastewater usually are based on the quality and quantity of the
discharge, but may also be influenced by subsequent treatment. Where the
quality of the wastewater remains within the parameters set out in the discharge
consent, the charges would be set at an agreed rate. However, if the consent
limits are exceeded, the charges will increase or, alternatively, fines may be
imposed for persistent breaches. The unscheduled release of some compounds,
particularly those which may be very hazardous and could provoke the
authorities to implement a prohibition order on the plant until the problem is
rectified. The facility may face pressures from the regulatory authorities to
install an on-site effluent treatment plant which may involve significant cost.

3
In order to determine the quality of wastewater, many discharge consents
require facilities to carry out sampling and analysis of the discharges which in
turn may require investment in monitoring equipment or use of contractors.

Soil and Groundwater Contamination

Where contamination has been identified on-site the actions required (which
may include clean-up of the site), will depend upon the regulatory authorities,
the local regulations and the exact circumstances of the site. Certain organic
compounds may permeate concrete, plastic and asphalt and may be highly
mobile in the soil able to migrate to surface or groundwaters. The cost of the
clean-up will vary depending upon the nature and extent of the contamination
and the local geological and hydrogeological conditions. In general, costs for
clean-up of contaminated sites are significant. In many instances, older works
with a long history of chemical production and storage are most likely to be
contaminated.

Waste Disposal

The cost of waste disposal can in some instances be significant. The reuse of
by-products is desirable to as great an extent as possible. The reactive nature of
the waste may require that special precautions are required for transport,
particularly if waste is transported across national frontiers or overseas.
National and international drugs and medicine regulatory authorities, may
require that the destruction of certain active ingredients are officially witnessed.

OTHER POTENTIAL ENVIRONMENTAL ISSUES

Storage and Spillage of Chemicals

Considerable quantities of chemicals are likely to be stored on-site. They may


be stored in, above or below ground tanks, tank farms or large drum storage
compounds. Adequate measures must be taken to prevent the chemicals (some
of which may be highly mobile) from entering the soil and polluting the
groundwater or nearby surface waters. Chemicals can enter watercourses as a
result of accidental releases, such as spillages or leakages from storage vessels,
from accidents during the production processes or from deliberate disposal on-
site. All storage facilities should be provided with appropriate secondary
containment. Where gases are being produced these may be stored in bulk
pressurised vessels, and appropriate safety measures should be installed to
prevent accidental releases and also explosions.

Where there are significant or very long pipe runs, and a regular visual check is
impracticable, it may be necessary to install remote loss detectors. These can
monitor flow continuously and raise alarms when loss of pressure or volume is
detected.

For reasons of safety and security it may be necessary to erect fencing around
pipelines and storage areas in order to limit access of non-authorised personnel.
In addition, some storage areas may require specific and independent fire
prevention measures.

4
Nuisance Related Issues

The emissions of noise and odour are most commonly associated with
nuisance. However, nuisance can be described as any operation which
interferes with a third party. The location of the facility and its neighbours may
influence the perception of nuisance.

A number of actions can be taken by most facilities to minimise nuisance,


which include:

· provision of noise attenuation screens and devices;


· provision of odour control devices;
· minimisation of vehicle movement and related noise at night;
· minimise intrusive night-time lighting.

Hazardous Materials (PCBs Asbestos)

Asbestos and PCB-containing material may need to be identified, covered,


labelled and properly managed with a view to removal in anticipation of future.
Removal of these items can be costly.

Animal Testing

Animal testing of products may be carried out on site. There could be issues
relating to public opposition to such tests, animal welfare, and the disposal of
infected animal carcasses and animal wastes.

Public Consultation

Pharmaceutical companies may be the subject of considerable public scrutiny,


and should be prepared to respond to inquiries and complaints.

Product Responsibility

Companies may have outstanding or pending liability issues caused by previous


or current products.

Worker Health and Safety Issues

Companies should be aware of their responsibilities towards workers, and may


be liable for damages caused by occupational hazards.

ENVIRONMENTAL IMPROVEMENTS

Potential environmental improvements may include:

· recovery and secondary use of raw materials where practicable;


· elimination of certain waste streams from processes or product lines;

5
· energy conservation through heat transfer, pipe insulation, and better control
systems;
· utilisation of heat from exothermic reactions;
· comprehensive preventative maintenance programmes;
· the elimination of fugitive emissions;
· establishing the optimum efficiency of effluent treatment plant;
· chemical bulk storage, to minimise the risk of accidental discharge to
surface and groundwater;
· establish opportunities to recycle waste where practicable;
· good housekeeping, to minimise unnecessary discharge of other materials to
the environment;
· improved worker health and safety (training, better safety equipment etc.)

ENVIRONMENTAL ACTION PLAN

Environmental management measures should focus on the following:

· maintaining high standards of hygiene in production areas;


· maintaining legislative compliance at the facility;
· strict adherence to written procedures;
· labelling of containers, drums, pipes etc.;
· efficient emergency response procedures, including clear signs, instructions
and drills;
· an accident prevention policy;
· minimising emissions to the atmosphere;
· management of the site's aqueous discharges and of the effluent treatment
plant, if present;
· management of the site's solid and liquid waste streams;
· preventative maintenance programmes for pollution control and abatement
equipment;
· materials storage;
· spill control and prevention measures.

GUIDE TO INITIAL DUE DILIGENCE SITE VISITS

During the initial site visit, it will be important to assess the following:

· product hygiene standards throughout the process (including packaging and


transport);
· compliance with air emission permits and minimise the occurrence of
visible emissions;
· fugitive emissions - check the means of identifying and quantifying
unauthorised releases;
· compliance with effluent discharge consents - check discharge points;
· the operation and maintenance of the wastewater treatment plant, if present;
· disposal of solid and liquid waste - check final disposal routes, methods and
documentation;

6
· housekeeping, the general manner in which wastes are handled and the
overall appearance of the site;
· condition and adequacy of storage facilities;
· evidence of spillage or surface staining;
· the status and nature of complaints and the manner in which they are
processed;
· site location/surrounding area activities;
· site security and the safety of all site personnel, contractors and visitors.

Contact should be made with the local regulatory agencies to determine


compliance record and whether complaints have been made by the public.

7
Sub-sectoral Environmental Guidelines
PRODUCTION OF BULK ORGANIC
CHEMICALS

PROCESS DESCRIPTION

The activities in this guidance note incorporate the manufacture of bulk organic
chemicals. This note, however, does not include the production of derived
organic chemicals, such as pharmaceuticals, plastics, paints agrochemicals, etc.

The majority of organic chemicals are initially derived from the petrochemicals
industry, through the cracking of oil. The resulting fractions then undergo
various secondary and tertiary reactions.

Many of the processes require significant input of energy, and auxiliary


operations may include production of heat, steam and compressed air to drive
the reactions. Very often, organic chemicals plants may be a part of much
larger chemical manufacturing works and may share common site-derived
services, such as power, effluent treatment and which may be managed by site
personnel not directly involved with the production of organic chemicals.

SUMMARY OF KEY ENVIRONMENTAL RISK/LIABILITY FACTORS

Air Emissions

Air emissions may include organic compounds (including olefins and


aromatics)and odours.

In many cases point source emissions will require air emission permits, which
may stipulate limits for specific, named pollutants. In order to control these
emissions, the facility is usually required to monitor emissions and submit
findings to the authorities. Depending on the nature or size of the process,
pollution control equipment or abatement devices may be required. In many
instances it may be illegal to operate and emit pollutants to the atmosphere
without a valid permit.

Wastewater Discharges

Discharges to water may include olefins and aromatics (including phenol),


alcohols, oil fractions, salts, acids and suspended solids (catalysts, by-products
etc.).

Depending on the nature and volume of effluent and local regulations, facilities
may require an on-site effluent treatment plant or face rising costs for off-site
treatment.

1
Trade effluent discharges to sewer and surface waters are likely to require
discharge consents from the regulatory authorities. Depending on the nature of
the operation and the final destination of the discharge (whether it undergoes
secondary treatment, for example at a municipal sewage treatment works, or is
discharged untreated) the permitted parameters within the consent may vary. In
many instances it may be illegal to operate and discharge wastewater to a sewer
or surface waters without a valid discharge consent.

Storage and Handling of Chemicals

Raw materials and finished products are often put in or discharged from rail
and road tankers. The risk of spillages and leakages during these operations is
very high and air emissions due to evaporation of volatile spilled product are an
added risk.

Where significant volumes of chemicals are stored, for example in tank farms
and drum storage compounds, adequate measures must be taken to prevent
accidental releases from entering the soil and polluting the groundwater or
nearby surface waters. Chemicals can enter water courses as a result of
accidental releases, such as spillages or leakages from storage vessels or
pipework or from accidents during the production processes.

Spillages and pollution incidents often occur in the event of poor management
and maintenance of storage areas. Storage facilities should be provided with
appropriate secondary containment. For new installations, double walled tanks
are required. Regular checking of volumes and strict log keeping is required for
the early detection of any spillages.

Soil and Groundwater Contamination

There are a number of situations where contaminants, such as oil and other
organic compounds could be spilled and enter the soil or surface waters.
Contamination of the soil could occur from a spillage or seepage from
underground and above ground storage tanks, associated pipework, or from
waste disposal activities. Surface and groundwaters may become contaminated
if pollutants enter the drainage systems, or seep through the soil. This is of
particular concern where certain organic chemicals may degrade plastic pipes
or rubber seals and enter the ground, or for chemicals which may be
particularly mobile or persistent in the soil.

FINANCIAL IMPLICATIONS

Air Emissions

The air emission permit may require analysis of air emissions and frequent or
continuous monitoring for specified pollutants. Some emissions, such as
organic compounds and dusts, may require pollution control devices or
abatement measures, the costs of which may be significant. Specific
requirements (eg., thermal oxidation, adsorption or electrostatic precipitation)
depend on local legislation and the requirements of the regulatory authorities.
Automatic monitoring equipment for measuring concentrations of organic

2
compounds may be required, as may personal concentration detectors. Fire
fighting equipment and alarm systems should be installed and regularly
maintained, and staff thoroughly trained in emergency response procedures.

Effluent Discharges

Charges for wastewater are based on the quality and quantity of the discharge,
but may also be influenced by subsequent treatment. Where the quality of the
wastewater remains within the parameters prescribed in the discharge consent,
the charges are set at an agreed rate. However, if the consent limits are
exceeded, the charges will increase or, alternatively, fines may be imposed for
persistent breaches. The facility may face pressures from the regulatory
authorities to install an on-site effluent treatment plant. On-site effluent
treatment (primary, secondary or tertiary) usually involves significant capital
expenditure.

In order to determine the quality of the wastewater, many discharge consents


require facilities to carry out sampling and analysis of the discharges requiring
investment in sampling equipment or contract services.

Soil and Groundwater Contamination

Where contamination has been identified on-site remediative actions may be


required (which could include clean up of the site). This will depend upon the
regulatory authorities, the local regulations and the specific site circumstances.
Certain organic compounds can permeate concrete, plastic and asphalt and
may be highly mobile in the soil, being able to migrate to surface or
groundwaters.

The cost of clean up will vary depending chiefly upon the nature and extent of
contamination and the local geological/hydrogeological conditions. In general,
costs for clean up are significant, remediation of groundwater generally being
more costly than for soil. In many instances, older works with a long history of
chemical/industrial production and storage are more likely to be contaminated.

OTHER POTENTIAL ENVIRONMENTAL ISSUES

Storage and Spillage of Chemicals

Considerable quantities of chemicals are likely to be stored on-site. They may


be stored in above or below ground tanks, tank farms or large drum storage
compounds. Adequate measures must be taken to prevent the chemicals (some
of which may be highly mobile) from entering the soil and polluting the ground
water or nearby surface waters. Chemicals can enter watercourses as a result of
accidental releases, such as spillages or leakages from storage vessels, from
accidents during the production processes or from deliberate disposal on-site.
All storage facilities should be provided with appropriate secondary
containment and be constructed of appropriate material. Where gases are being
produced these may be stored in bulk pressurised vessels, and appropriate
safety measures should be installed to prevent accidental releases and also
explosions.

3
Where there are significant or very long pipe runs, and a regular visual check is
impracticable, it may be necessary to install remote loss detectors. These can
monitor flow continuously and raise alarms when loss of pressure or volume is
detected.

For reasons of safety and security it may be necessary to erect fencing around
pipelines and storage areas in order to limit access to authorised personnel. In
addition, some storage areas may require specific and independent fire
prevention measures.

Waste Disposal

Waste arising from an operation can either be reused in the operation, recycled
for use in another or secondary operation, or disposed of. Most wastes are
either buried in landfill sites or are destroyed in large commercial waste
incinerators. Generally, non-hazardous wastes, are landfilled and hazardous
wastes, such as chemicals are incinerated. Chemical wastes can arise from
contaminated or out-of-specification product, intermediate materials and raw
materials.

The costs of waste disposal vary according to the final disposal method, the
hazards associated with the particular waste stream, and the abundance or
scarcity of suitable disposal sites.

Nuisance Related Issues

The emissions of noise and odour are most commonly associated with
nuisance. However, nuisance can be described as any operation which
interferes with a third party. The location of the facility and its neighbours may
influence the perception of nuisance.

A number of actions can be taken by most facilities to minimise nuisance,


which include:

· provision of noise attenuation screens and devices;


· provision of odour control devices;
· minimisation of vehicle movement and related noise at night;
· minimise intrusive night-time lighting.

Hazardous Materials (PCBs Asbestos)

Asbestos and PCB containing material may need to be identified, covered,


labelled and properly managed with a view to removal in anticipation of future.
Removal of these items can be costly.

ENVIRONMENTAL IMPROVEMENTS

Potential environmental improvements may include:

· recovery and re-use of raw materials where practicable;

4
· elimination of certain waste streams from processes or product lines;
· heat transfer and pipe insulation;
· comprehensive preventative maintenance programmes;
· the elimination of fugitive emissions;
· establishing the optimum efficiency of effluent treatment plant;
· chemical bulk storage, to minimise the risk of accidental discharge to
surface and groundwater;
· establish opportunities to recycle waste where practicable;
· good housekeeping, to minimise unnecessary discharge of other materials to
the environment;

ENVIRONMENTAL ACTION PLANS

Environmental action plans should focus on the following:

· maintaining legislative compliance at the facility;


· strict adherence to procedures;
· minimising emissions to the atmosphere;
· management of the site's aqueous discharges and of the effluent treatment
plant, if present;
· preventative maintenance programmes for pollution control and abatement
equipment;
· materials storage;
· spill control and prevention measures.

GUIDE TO INITIAL DUE DILIGENCE SITE VISITS

During the initial site visit, it will be important to assess the following:

· compliance with air emission permits and minimise the occurrence of


visible emissions;
· fugitive emissions - check the means of identifying and quantifying
unauthorised releases;
· compliance with effluent discharge consents - check discharge points;
· the operation and maintenance of the wastewater treatment plant, if present;
· disposal of solid waste - check final disposal routes and methods and
documentation;
· housekeeping, the general manner in which wastes are handled and the
overall appearance of the site;
· condition and adequacy of chemical storage facilities/compounds;
· evidence of spillage or surface staining;
· the status and nature of complaints and the manner in which they are
processed;
· site location/surrounding area activities
· site security and the safety of all site personnel, contractors and visitors;
· fire fighting equipment, emergency response time, alarm systems, staff
training.

5
Contact should be made with the local regulatory agencies to determine
compliance record and whether complaints have been made by the public.

6
Sub-sectoral Environmental Guidelines
PAINT AND ALLIED PRODUCTS

PROCESS DESCRIPTION

The production of paints involves the polymerisation of raw materials, the


dispersion of the pigments and mixing of other ingredients such as additives
and solvents to give the final properties of the finished product. Pigments are
fine coloured powders (many pigments contain lead, cadmium, chromium),
while the film formers (binders, resins and polymers) bind the pigment
particles together and to the surface to which it is to be applied. Binders used
without pigment give a film of clear varnish. Thinners, commonly a blend of
solvents, are used to produce different consistencies of product. Additives can
include antifreeze, dispersing agents, wetting agents, thickeners, biocides,
ammonia and antifoaming agents.

The key processes involved in paint production start with the dispersion of the
pigment, breaking down aggregates of pigment particles resulting in a
concentrated pigment dispersion called a millbase. Millbases are converted to
paint by mixing with film former (resin), extra solvents and additives before
being filtered and pumped to the filling line prior to distribution.

The film former (resin) may be brought to the site or manufactured on site.
The raw materials are heated for a certain period at set temperatures to produce
polyester (or copolymer, depending upon the raw materials and process) before
being cooled, filtered and stored.

SUMMARY OF KEY ENVIRONMENTAL RISK/LIABILITY FACTORS

Air emissions

The principal environmental risk factors associated with paint production is


emissions to atmosphere from the following sources:

· Emissions from mixing process include solvents which give rise to volatile
organic compounds (VOCs) which are of environmental concern because of
the harmful properties which they exhibit, including human health risks,
destruction to atmospheric ozone, contribution to global warming and to
photochemical ozone creation at ground level.

· Odour associated with solvents can give rise to nuisance affecting


neighbouring properties. The significance of the risk associated with this
varies according to the location of the site and its surroundings. In the most
serious cases odour control equipment may be required.

· Fugitive emissions can arise from raw material storage silos, reactor and
vessel cleaning and filtration activities as well as leakages releases from

1
seals, gaskets and valves in pipework and process vessels. Emissions could
contain volatile organic compounds and pigment particulates.

· Particulate emissions may cause a nuisance to neighbours and may also


contain elevated concentrations of lead and cadmium or other heavy metals,
depending on the pigments used.

· Emissions from the fuel used to heat the process vessels may also be
significant depending upon the fuel type used (coal, oil or gas).

Effluent discharge

The main concern relates to the effluent discharges arising from the
wastewaters generated from the cleaning of process mixing equipment and
pipework, which occurs frequently, between paint colours. Once cleaned they
are washed, either with water or solvent, depending upon the type of paint.
This generates an effluent contaminated with solvent and high levels of
suspended solids, often coloured, which requires treatment.

The quality of the effluent from the whole site should be reviewed as final
wastewater may arise from by-product streams and liquid spills. Wastewater
may also be contaminated with products and by products of the production
process.

The wastewater may discharge to an effluent treatment plant on-site, settlement


tanks or to the sewer (and subsequently to a municipal treatment plant).

Health and Safety

Many solvents are carcinogenic. Adequate ventilation, fume extraction and


safety equipment is required. Long-term health related liabilities may arise if
procedures are inadequate.

Sludge disposal

Residual batch sludges are hazardous and must be disposed of at approved


landfill sites. Inadequate on-site dumping may lead to significant groundwater
pollution.

Fire and Explosions

Paint production typically utilises a range of extremely flammable products.


There will often be large quantities of solvent vapours within the production
areas, which can explode if ignited.

FINANCIAL IMPLICATIONS

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Air emissions

Depending upon the nature of emissions (in particular the type of solvent -
which is likely to vary with different paints) and the scale of operations,
additional air emission abatement equipment may need to be installed on the
mixing vessels and spray booths. Emission control equipment which may be
required includes hoods, scrubbers and incinerators.

Effluent discharges

Settlement may remove much of the contamination from the effluent prior to
release to sewer. The destination and fate of sludges arising from any treatment
should be checked. In addition it may be important to check the integrity of the
drainage system and any interceptors. To verify that the site is within the limits
set in the discharge permit sampling and analysis of effluent from the site may
be required.

Fire and explosions

A fire or major explosion could clearly prove financially ruinous. Additional


fire protection equipment may need to be installed. Emergency procedures in
the event such an occurrence should be in place.

OTHER POTENTIAL ENVIRONMENTAL ISSUES

Storage or Oils, Gases and Solvents

Considerable quantities of oils, gases and chemicals may be utilised in paint


production. Typical storage vessels include the following:

· Storage of solvent
· Bulk storage fuel tanks
· Tank farm (multiple tanks) containing finished product
· Drums of assorted additives, caustics, disinfectants, detergents

Secondary containment (bunds etc.) should be installed from all bulk storage
tanks to reduce the risk of ground contamination and pollution of surface
waters. Further measures include regular integrity testing of underground
storage tanks and bulk storage tanks, accident/fire/explosion precautions and
emergency procedures and records of the testing pressurised vessels.

ENVIRONMENTAL IMPROVEMENTS

Potential environmental improvements include:

3
Air Emissions

· Convert to using water-based paints or low solvent content paints.


· Avoid using pigments containing lead and cadmium.

Energy Efficiency

· Re-use heated wastewater to warm cold water supply.


· Pipe insulation, for process vessels, both heating and cooling systems, etc.
· Change to cleaner fuel sources.
· Recirculate cooling water in a closed non contact system.

Recycling/Recovery

· Reconditioning and reuse of solvents (distillation on site or off site).

Waste Minimisation

· Minimise leakages and fugitive release from pipework through use of


appropriate corrosive resistant materials and leak proof valve and pump
design.
· Minimise product loss through timing and method of vessel and pipework
cleaning.
· Minimise dust production through extraction systems, management and
procedures for transfer of dry materials.

Most measures to achieve regulatory compliance and improve hazards are


expensive, and involve relatively high levels of technology.

ENVIRONMENTAL MANAGEMENT

Recommended environmental management measures include:

· emission monitoring for all point and fugitive emission sources in order to
endure compliance with relevant regulations;
· wastewater monitoring and control where appropriate;
· maintenance and efficiency of any on site emission abatement equipment
and treatment plant;
· development of water based powder paints.

GUIDE TO INITIAL DUE DILIGENCE SITE VISITS

During the initial site visit it is important to assess the following:

4
· all point sources of air emissions through questioning site management and
through existing emissions inventories;
· effluent discharge practices and treatment;
· containment of bulk storage (in particular, for solvents) and waste storage
areas;
· age of process equipment and presence of emission abatement equipment;
· health and safety issues (in particular, solvent exposure).

Contact should be made with local regulatory agencies to determine


compliance record and whether complaints have been made by the public.

5
Sub-sectoral Environmental Guidelines
PETROLEUM REFINERIES

PROCESS DESCRIPTION

This guidance note covers the refining of crude petroleum to produce gases,
liquids, greases and tars which are either used as products in their own right or as
the precursors of petrochemicals for further industrial processes. Typical refinery
products include:

· natural gas and liquefied petroleum gas (LPG);


· solvent naphthas;
· jet fuel;
· kerosene;
· diesel oils;
· lubricating oils;
· various fuel oils;
· waxes;
· bitumen.

Not all of these will necessarily be produced by a single refinery. Some refineries
are dedicated to particular products, e.g. lube oil refinery.

Petroleum refining involves two basic processes: separation and conversion.


Crude petroleum enters the refinery and is separated into various fractions by
distillation in stills. Each still typically consists of heat exchangers, a furnace, a
fractionating tower, steam strippers, condensers, coolers and auxiliaries.
Separation processes also include absorption, adsorption, filtration, crystallisation
and extraction.

Conversion processes include a number of chemical reactions. The most


important of these are:

· Polymerization - the conversion of gases produced in cracking, into liquid


fuels;
· Alkylation - the production of isoparaffins (used in gasoline) using hydrogen
fluoride and sulphuric acid as catalysts;
· Isomerization - changing the arrangement of the atoms in a molecule, e.g.
butane to isobutane;
· Reforming - a high temperature catalytic treatment converting the
constituents into similar sized modules but with higher octane ("anti-knock")
ratings.

In addition to separation and cracking, together with blending and mixing


processes, various other chemical treatments take place involving:

· removal of various constituents, primarily sulphur, but also resins and


asphaltic materials;
· improvement of colour;

1
· improvement of odour;
· improvement of stability;
· addition of various constituents such as antioxidants to prevent gum
formation.

Waste treatment processes also account for a significant area of the refinery,
particularly sulphur compounds in gaseous emissions together with various solid
and liquid extracts and wastes generated during the refining process.

The refinery is therefore composed of a complex system of stills, crackers,


processing and blending units and vessels in which the various reactions take
place, as well as packaging units for products for immediate distribution to the
retailer, e.g. lubricating oils. Bulk storage tanks usually grouped together in
bunded tank farms are used for storage of both crude and refined products.

Other tanks are used in the processes outlined, e.g. treating, blending and mixing
whilst others are used for spill and fire control systems. A boiler and electrical
generating system usually operate for the refinery as a whole.

SUMMARY OF KEY ENVIRONMENTAL RISK/LIABILITY FACTORS

Atmospheric Emissions

Principal sources of releases to air from refineries include:

· combustion plants, emitting sulphur dioxide, oxides of nitrogen and


particulates;
· refining operations, emitting sulphur dioxide, oxides of nitrogen, carbon
monoxide, particulates, volatile organic compounds, hydrogen sulphide,
mercaptans and other sulphurous compounds;
· bulk storage operations and handling of volatile organic compounds (various
hydrocarbons).

Issues to consider:

· Regulatory requirements - air emission permits stipulating limits for specific


pollutants, and possibly health and hygiene permit requirements.
· Requirement for monitoring programme.
· Fees and penalties.
· Requirements to upgrade pollution abatement equipment.

Storage and Handling of Petroleum Products

Large quantities of environmentally-sensitive petroleum products are stored in:

· tank farms (multiple tanks);


· single above-ground storage tanks (ASTs);
· semi-underground, or underground storage tanks (USTs).

Smaller quantities of materials may be stored in:

2
· drums and containers of assorted compounds (such as lubricating oil, engine
oil, other products for domestic supply).

Issues to consider:

· Secondary containment of tanks and other storage areas (with adequate


bunding etc.) and integrity of hardstanding (without cracks, impervious
surface) to prevent spills reaching the wider environment: also secondary
containment of pipelines where appropriate.
· Licensing of storage facilities.
· Age, construction details and testing programme of tanks.
· Labelling and environmentally secure storage of drums (including waste
storage).
· Accident/fire precautions, emergency procedures.
· Disposal/recycling of waste or "out of spec" oils and other materials.

Soil and Groundwater Contamination

There is a potential for significant soil and groundwater contamination to have


arisen at petroleum refineries. Such contamination consists of:

· Petroleum hydrocarbons including:


· lighter, very mobile fractions (paraffins, cycloparaffins and volatile
aromatics such as benzene, toluene, ethylbenzene and xylenes)
typically associated with gasoline and lighter distillates;
· middle distillate fractions (paraffins, cycloparaffins and some
polyaromatics) associated with diesel, kerosene, some of the lighter
fuel oils, which are also of significant mobility;
· heavier distillates (long-chain paraffins, cycloparaffins and
polyaromatics) associated with lubricating oils and heavy fuel oils;

· Various organic compounds associated with petroleum hydrocarbons or


produced during the refining process, e.g. phenols, amines, amides, alcohols,
organic acids, nitrogen and sulphur containing compounds.
· Other organic additives, e.g. anti-freeze (glycols), alcohols, detergents and
various proprietary compounds.
· Organic lead, associated with leaded gasoline and other heavy metals.

Key sources of such contamination at petroleum refineries are:

· transfer and distribution points in tankage and process areas, also general
loading and unloading areas;
· landfarm areas;
· tank farms,
· individual ASTs and particularly USTs;
· interceptors;
· additive compounds;
· pipeline runs;
· drainage runs;
· pump raft/pipe manifold areas;

3
· vehicle washing facilities;
· maintenance workshops;
· on-site waste treatment facilities, impounding basins, lagoons, especially if
unlined.

Issues to consider:

· Whilst contamination may be associated with specific facilities the


contaminants are relatively highly mobile in nature and have the potential to
migrate significant distances from the source in soil and groundwater.
· Petroleum hydrocarbon contamination can take several forms: free-phase
product, dissolved-phase, emulsified phase or vapour phase. Each form will
require different methods of remediation so that clean-up may be complex
and expensive.
· Petroleum hydrocarbons include a number of compounds of significant
toxicity, e.g. benzene and some polyaromatics are known carcinogens.
· Vapour phase contamination can be of significance in terms of odour issues
etc.

Fire Risks

Due to the obvious risk of fire, refineries are equipped with sprinkler or spray
systems which may draw upon the mains supply of water, or water held in
lagoons, or from reservoirs or neighbouring water courses. Fire water so
produced will be polluting and require containment.

Asbestos

Asbestos may be a significant issue at petroleum refinery sites particularly as


insulating material/lagging associated with furnaces, combustion areas etc., and
in a range of structures including building materials. Removal from the site can
be costly.

FINANCIAL IMPLICATIONS

· Risk of major spills resulting in substantial liability claims or regulatory


enforcement action.

· Contamination of soil, groundwater and surface water bodies due to historical


and/or present use of petroleum products. Soil and groundwater
contamination relating to petroleum products is extremely costly to remediate
and could be severely disruptive to site operations.

· Fees and penalties (particularly relating to air emissions and effluent


discharges).

· Run-off/stormwater drainage from storage areas on refinery.

· Outstanding claims (health and safety).

4
· Upgrade of storage areas may be required.

· Upgrade of pollution abatement equipment particularly relating to air


emissions and site infrastructure (sewers, drainage, interceptors) may be
required.

· Major fires and spills could be financially ruinous.

OTHER POTENTIAL ENVIRONMENTAL ISSUES

Water Supply/Wastewater Management

· Facilities will require significant volumes of water for on-site processes (e.g.
coolants, blow-downs etc.) as well as for sanitary and potable use;.
· Wastewater will derive from these sources (process water) and from
stormwater run-off. The latter could contain significant concentrations of
petroleum product.
· Petroleum hydrocarbons, either dissolved, emulsified or occurring as free-
phase will be the key constituents although wastewater may also contain
significant concentrations of phenols, amines, amides, alcohols, ammonia,
sulphide, heavy metals and suspended solids.
· Wastewaters may be collected in separate drainage systems (for process,
sanitary and stormwater) although industrial and stormwater systems may in
some cases be combined.
· In addition, ballast water from bulk crude tankers may be pumped to
receiving facilities at the refinery site prior to removal of floating oil in an
interceptor and treatment as for other wastewater streams.
· On-site treatment facilities may exist for wastewater or treatment may take
place at a public wastewater treatment plant.
· Stormwater/process water is generally passed to a separator or interceptor
prior to leaving the site which takes out free-phase oil (i.e. floating product)
from the water prior to discharge, or prior to further treatment, e.g. in settling
lagoons).
· Discharge from wastewater treatment plants is usually passed to a nearby
water course.

Issues to consider:

· Source of process, potable and sanitary water (municipal, on-site, abstraction,


surface water etc.).
· Permits and charges for water use.
· Ability of industrial sewer system to capture all process effluents and also
stormwater run-off.
· Separation of sanitary from industrial/stormwater systems where required,
and separation of water from any on-site vehicle washing facilities from
interceptors.
· Integrity of drainage system critical requirements for regular inspection and
monitoring of drainage system, also lining of drainage ditches, impounding
basins and lagoons.

5
· Possibility of accidental releases of petroleum products reaching local water
courses or entering sanitary sewage system.
· Efficiency of wastewater treatment system and interceptors/separators
critical, check type, effectiveness, monitoring, final effluent and sludge
disposal.
· Regulatory compliance discharge consents, enforcement, requirements for
ongoing effluent monitoring costs.
· Requirements and costs for potential upgrade of wastewater treatment plant
and interceptors/separators.

Waste Management

Typical wastes include:

· waste oils, process chemicals, still resides;


· "out of spec." materials;
· waste alkali (sodium hydroxide);
· waste oil sludge (from interceptors, tanks, lagoons etc.);
· solid wastes (cartons, rags, etc.).

Issues to consider:

· Regulatory requirements.
· Means of solid waste disposal management.
· Storage of waste on-site prior to disposal.
· Disposal permits.
· Fees and penalties.
· Use of approved disposal routes (and contractors).
· Ownership of waste disposal site.
· Potential pollution of soil and groundwater related to on-site and off-site
storage and disposal.

Polychlorinated Biphenyls (PCBs)

Where transformers and capacitors are present, it is possible that these may
contain PCBs, requiring removal from site, or at the very least provided with
adequate containment and proper fire hazard prevention measures.

Noise

It is possible that noise may reach or exceed nuisance levels, particularly on sites
close to the residential areas.

Odour

Odour may be a nuisance in sensitive areas and provision of odour control


devices may be necessary.

6
ENVIRONMENTAL IMPROVEMENTS

· Upgrade material storage areas, especially underground storage facilities.


Minimise underground storage or underground pipelines in favour of above-
ground structures. Provide secondary containment facilities for all pipelines,
tanks and drum storage areas;
· Upgrade air emissions control, particularly fugitive emissions;
· Installation of loss detectors on long pipe runs;
· Improve heat transfer and pipe insulation;
· Introduction of good environmental engineering practice;
· Improvements of wastewater treatment facilities and interceptors to achieve
lower discharge;
· Improvements of integrity of all waste or wastewater containment facilities
(ditches, lagoons etc.);
· Separation of wastewater streams where appropriate.

ENVIRONMENTAL ACTION PLAN

Develop an Environmental Action Plan (EAP) to include:

· regulatory compliance measures;


· waste management plan (waste minimisation, re-use, recycling, monitoring);
· health and safety improvements;
· costs of upgrades/compliance;
· assessment and remediation of contaminated soil and groundwater;
· roles and responsibilities, time-frame and benchmarks.

GUIDE TO INITIAL DUE DILIGENCE SITE VISITS

When visiting the sites of potential borrowers or during loan supervision, use the
following as practical guide to the initial due diligence process.

· Perform a complete tour of the site compound if possible.


· Note quantities and characteristics of atmospheric emissions, wastewater
discharges and solid and hazardous waste arising.
· Note signs of poor housekeeping, inadequate/untidy storage areas, poor drum
labelling.
· Review current status of pollution abatement technology.
· Evaluate potential for spillages and leakages to enter soil or stormwater
drainage system.
· Check drainage systems.
· Note nature of solid waste disposal.
· Look for localised spills, leaking tanks, pipes etc..
· Check for distressed flora/vegetation zones near storage sites.
· Check personal protective equipment.
· Review machinery guarding.

7
· Assess emergency response to fires, major spills, etc..
· Review historical and projected trends for environmental fees and fines.

It is also suggested that contact is made with local regulatory agencies to


determine compliance and whether complaints have been made by the public.

8
Sub-sectoral Environmental Guidelines
PETROLEUM STORAGE (including PETROL
STATIONS)

PROCESS DESCRIPTION

Facilities involved in the storage of petroleum range from small to large-scale


distribution terminals typically occupying between 1 and 15 ha with a storage
capacity in the 10,000 to >100,000m3 range, as well as petrol filling stations
which typically occupy less than 0.1 ha and with a storage capacity below 200m3.

Petroleum distribution terminals commonly receive their products from the


refinery by pipeline, although in some cases road, rail or ship delivery may occur.

Bulk storage tanks (with capacities ranging from several hundred to several
thousand cubic metres) receive the products, which can include gasoline,
naphtha, middle distillates (gas oil (diesel or heating oil), kerosene, aviation fuels
lighter fuel oils), heavy fuel and lubricating oil. The various products are often
divided into "white oils" consisting of gasoline and lighter spirits and the "black
oils" consisting of heavier oils such as fuel oils. The storage tanks are generally
above ground, large cylindrical vessels usually set in bunded tank farms, although
some underground, semi-buried and mounded tanks may also be present.
Tetramethyl lead, marker dyes and various additives may also be stored on-site.

The various petroleum products are then transferred by pipeline from the bulk
storage tanks to loading gantries via the additives compound, where proprietary
additives may be added. The loading gantries can either be bottom loading
stands or top loading stands in the case of heavier fuel oils. Road tankers are
filled at these locations and then distribute their products regionally. More
modern terminals are equipped with systems which collect the petroleum fumes
generated during the filling of the tankers and transfer these via above-ground
pipes to a Vapour Recovery Unit.

Other activities at oil terminal sites include vehicle re-fuelling facilities, vehicle
maintenance workshops, tanker washing facilities and in some cases small
sewage treatment units. For some petroleum products, drumming operations may
take place on-site, where the product is dispensed into containers of various sizes,
e.g. for lubricating oil, motor engine oil etc.

When the road tanker arrives at a petrol filling station it discharges its products
into a series of underground storage tanks. Typically, there are several of these
corresponding to the type of fuel, e.g. leaded, unleaded, premium, diesel. A
typical capacity of tank may be in the 5 to 50m3 range. Suction pipes then
transfer the product to the corresponding petrol or diesel pump as required.

1
SUMMARY OF KEY ENVIRONMENTAL RISK/LIABILITY FACTORS

· Risk of major spills resulting in substantial liability claims or regulatory


enforcement action (service stations and terminals).
· Contamination of soil and groundwater due to historical and/or present use of
petroleum products (service stations and terminals).
· Fees and penalties (particularly effluent discharges).
· Long-term the terminal may become non-compliant if regulatory environment
becomes more stringent.
· Run-off/stormwater drainage from storage areas on terminal.
· Outstanding claims (health and safety).

FINANCIAL IMPLICATIONS

The following are applicable to both terminals and filling stations.

· Soil and groundwater contamination relating to petroleum products is


extremely costly to remediate and could be severely disruptive to site
operations.
· Upgrade of storage areas may be required.
· Upgrade of pollution abatement equipment or site infrastructure (sewers,
drainage, interceptors) may be required.
· Major fires and spills could be financially ruinous.

OTHER POTENTIAL ENVIRONMENTAL ISSUES

In this section medium/large petroleum storage facilities and service stations are
considered separately.

Medium/Large Size Petroleum Storage Facilities

Key environmental issues associated with petroleum storage facilities such as oil
terminals include the following:

· storage and handling of petroleum products;


· soil and groundwater contamination;
· waste management;
· atmospheric emission;
· fire risks.

Storage and Handling of Petroleum Products

Large quantities of hazardous petroleum products, typically in the 104 - 105m3


range are stored in:

· tank farms (multiple tanks);


· single above-ground storage tanks (ASTs);

2
· semi-underground, or underground storage tanks (USTs).

Smaller quantities of materials may be stored in drums and containers of assorted


compounds (such as lubricating oil, engine oil, other products for domestic
supply).

Issues to consider:

· Secondary containment of tanks and other storage areas (with adequate


bunding etc.) and integrity of hardstanding (without cracks, impervious
surface) to prevent spills reaching the wider environment: also secondary
containment of pipelines where appropriate.
· Licensing of storage facilities.
· Age, construction details and testing programme of tanks.
· Labelling and environmentally secure storage of drums (including waste
storage).
· Accident/fire precautions, emergency procedures.
· Disposal/recycling of waste oils and other materials.

Soil and Groundwater Contamination

There is a potential for significant soil and groundwater contamination to have


arisen at large petroleum storage facilities. Such contamination consists of:

· petroleum hydrocarbons including:


· lighter, very mobile fractions (paraffins, cycloparaffins and volatile
aromatics such as benzene, toluene, ethylbenzene and xylenes)
typically associated with gasoline and lighter distillates;
· middle distillate fractions (paraffins, cycloparaffins and some
polyaromatics) associated with diesel, kerosene, some of the lighter
fuel oils, which are also of significant mobility;
· heavier distillates (long-chain paraffins, cycloparaffins and
polyaromatics) associated with lubricating oils and heavy fuel oils;

· organic lead, associated with leaded gasoline;


· other organic additives, e.g. anti-freeze (glycols), alcohols, detergents and
various proprietary compounds.

Key sources of such contamination at petroleum storage terminals are:

· loading gantries;
· tank farms,
· individual ASTs and particularly USTs;
· interceptors;
· additive compounds;
· pipeline runs;
· drainage runs;
· pump raft/pipe manifold areas;
· vehicle washing facilities;
· maintenance workshops.

3
Issues to consider:

· Whilst contamination may be associated with specific facilities the


contaminants are relatively highly mobile in nature and have the potential to
migrate significant distances from the source in soil and groundwater.
· Petroleum hydrocarbon contamination can take several forms: free-phase
product, dissolved-phase, emulsified phase or vapour phase. Each form will
require different methods of remediation so that clean-up may be complex and
expensive.
· Petroleum hydrocarbons include a number of compounds of significant
toxicity, e.g. benzene and some polyaromatics are known carcinogens.
· Vapour phase contamination can be of significance in terms of odour issues,
e.g. houses, food and retail outlets.

Waste Management

Typical wastes include:

· waste oils and "out of spec." materials;


· waste oil sludge (from interceptors/tanks);
· solid wastes (cartons, rags, etc.).

Issues to consider:

· Regulatory requirements.
· Means of solid waste disposal management.
· Disposal permits.
· Fees and penalties.
· Use of approved disposal routes (and contractors).
· Ownership of waste disposal site.
· Potential pollution of soil and groundwater related to on-site and off-site
storage and disposal.

Water Supply/Wastewater Management

· Facilities will require significant volumes of water for on-site processes


(especially tanker washing facilities) as well as for sanitary and potable use.
· Wastewater will derive from these sources and from stormwater run-off. The
latter could contain significant concentrations of petroleum product.
· Wastewaters are generally collected in separate drainage systems (industrial,
sanitary and stormwater) although industrial and stormwater systems may in
some cases be combined.
· On-site treatment facilities may exist for wastewater or treatment takes place
at a public wastewater treatment plant.
· Discharge from wastewater plants or from stormwater run-off is usually
passed to a nearby water course.
· Stormwater/industrial water generally passed to a separator or interceptor prior
to leaving the site which takes out free-phase oil (i.e. floating product) from
the water prior to discharge.

4
· Alternatively, contaminated water may be temporarily stored and disposed off-
site by a waste management contractor.

Issues to consider:

· Source of process, potable and sanitary water (municipal, on-site, abstraction,


surface water etc.).
· Permits and charges for water use.
· Ability of industrial sewer system to capture all process effluents.
· Separation of sanitary from industrial/stormwater systems where required, and
separation of water from tanker washing facilities from interceptors.
· Integrity of drainage system is critical.
· Possibility of accidental releases of petroleum products reaching local water
courses or entering sanitary sewage system.
· Efficiency of wastewater treatment system and interceptors/separators critical,
check type, effectiveness, monitoring, final effluent and sludge disposal.
· Regulatory compliance discharge consents, enforcement, costs.
· Requirements and costs for potential upgrade of wastewater treatment plant
and interceptors/separators.

Atmospheric Emissions

Atmospheric emissions from specific processes on-site are likely to be limited in


extent although fugitive emissions may be of concern in terms of:

· lighter distillates, if benzene is present;


· odour issues in terms of neighbours or sensitive receptors.

Issues to consider:

· Any regulatory requirements (including health and hygiene permit


requirements).
· Fees and penalties.
· Requirements to upgrade pollution abatement equipment and vapour recovery
systems.

Fire Risks

Due to the obvious risk of fire terminals are equipped with sprinkler or spray
systems which may draw upon the mains supply of water, or water held in
lagoons, or from neighbouring water courses. Fire water so produced will be
polluting and require containment.

Asbestos

Asbestos is unlikely to be a major issue at petroleum storage sites although as it is


often found in a range of structures including building materials, pipework,
insulation, it may need to be removed from the site which can be costly.

Noise

5
It is possible that noise may reach or exceed nuisance levels, particularly on
larger sites.

Odour

Odour may be a nuisance in sensitive areas and provision of odour control


devices may be necessary.

Service Stations

Although the scale of operation at a petrol filling station is much less than at a
petroleum storage terminal, many of the above environmental issues are
pertinent:

Storage and Handling of Petroleum Products

· Storage in USTs, also some storage in ASTs.

Issues to consider:

· Age, construction details and testing programme of tanks, especially USTs,


pipelines and fittings.
· Condition of surface of facilities (degree of impermeability, integrity (presence
of cracks) especially in pump area and area where spillages are likely.
· Licensing of storage facilities.
· Accident/fire precautions and emergency procedures.

Soil and Groundwater Contamination

Key hazards at service stations include:

· potential for gasoline contamination (volatile paraffins and aromatics,


including benzene);
· potential for diesel contamination (middle distillate range hydrocarbons).

Key sources of contamination at service stations are:

· leakage from USTs;


· spillages around fill point of UST;
· spillage from pump area (where integrity of surface compromised);
· leakages from underground pipelines, drains and interceptor.

Issues to consider:

· Highly mobile nature of contaminants (lighter fractions of significant


solubility).
· Likely presence of potentially significant migration pathways from cracks in
the hardstanding and from in-ground USTs.

6
· Volatile nature of contaminants (potential for migration of vapours into
basements, wine cellars, etc, of neighbouring houses).
· Toxic nature of gasoline constituents, especially benzene, and MTBE
(additive in unleaded fuel).

Waste Management

· Waste includes petrol/diesel contaminated rags, paper, sand or other material


used for clearing or containing leaks or spills.

Issues to consider:

· As for larger petroleum storage sites (see above).

Water Supply/Wastewater Management

· Water draining from car wash facilities should not pass through interceptors.
· Other issues, as for larger facilities (see above).

Issues to consider:

As for larger petroleum storage sites (see above) noting particularly:

· integrity and layout of drainage system;


· adequacy and maintenance of interceptors (should contain maximum contents
of a compartment of a petrol tanker);
· requirement for separation of car wash drainage from interceptor.

Asbestos

As for medium to large size petroleum storage areas.

Noise

As for medium to large size petroleum storage areas.

Odour

As for medium to large size petroleum storage areas.

ENVIRONMENTAL ACTION PLANS

Develop an Environmental Action Plan (EAP) to include:

· regulatory compliance measures;


· waste management plan (waste minimisation, re-use, recycling, monitoring);
· health and safety improvements;

7
· costs of upgrades/compliance;
· assessment and remediation of contaminated soil and groundwater;
· roles and responsibilities, time-frame and targets.

Most measures to achieve regulatory compliance and minimise hazards involve


low to moderate or intermediate levels of technology.

ENVIRONMENTAL IMPROVEMENTS

· Upgrade material storage areas, especially underground storage facilities.


Minimise underground storage or underground pipelines in favour of above-
ground structures. Provide secondary containment facilities for all pipelines,
tanks and drum storage areas.
· Installation of loss detectors on long pipe runs.
· Introduction of good environmental engineering practice.
· Improvements on wastewater facilities and interceptors to achieve lower
discharge.
· Separation of wastewater streams where appropriate.

GUIDE TO INITIAL DUE DILIGENCE SITE VISITS

When visiting the sites of potential borrowers or during loan supervision, use the
following as a practical guide to the initial due diligence process.

· Perform a complete tour of the site compound if possible.


· Quantities and characteristics of atmospheric emissions, wastewater
discharges and solid and hazardous waste arising.
· Note signs of poor housekeeping, inadequate/untidy storage areas, poor drum
labelling.
· Review current status of pollution abatement technology.
· Evaluate potential for spillages and leakages to enter soil or stormwater
drainage system.
· Check drainage systems.
· Note nature of solid waste disposal.
· Look for localised spills, leaking tanks, pipes etc..
· Check for distressed flora/vegetation zones near storage sites.
· Check personal protective equipment.
· Review machinery guarding.
· Assess emergency response to fires, major spills, etc.
· Review historical and projected trends for environmental fees and fines.

Not all of the above may be applicable to retail filling stations. However, in the
case of the latter, particular attention should be paid to:

· integrity of surface, presence of cracks, vegetation within hardstanding;


· age and condition of USTs;
· monitoring programmes undertaken;
· state of drainage systems and interceptors;

8
· known losses of product/spillages etc.

It is also suggested that contact is made with local regulatory agencies to


determine compliance and whether complaints have been made by the public.

9
Sub-sectoral Environmental Guidelines
RUBBER PRODUCTS

PROCESS DESCRIPTION

Both natural and synthetic rubber is used to manufacture a number of products,


for example tyres, carpet underlay and clothing/footware. Natural rubber
originates from the sap of the rubber tree, which is extracted and solidified by
acidification. Synthetic rubber is manufactured from a product of petroleum
cracking. To produce rubber products, synthetic and natural rubbers are mixed
with a number of chemicals and oils to produce a rubber compound which is
extruded and milled. Then, depending on the final product, curing takes place
under high pressure and temperature prior to, or following, assembly.

SUMMARY OF KEY ENVIRONMENTAL RISK/LIABILITY FACTORS

Odour

One of the main environmental problems associated with the manufacture of


rubber products is odour generation. The odour is mainly produced by natural
rubber breakdown during the initial mixing process and can be a significant
nuisance issue for neighbouring facilities and residential areas. Facilities
producing rubber are usually issued with an air permit from the local regulatory
authority which specifies that no offensive odour should be detectable at the
site boundary. The measurement of odour is subjective and there are no
definitive methods of measuring the offensiveness of an odour. Therefore it is
usually the local authority inspector who decides whether an odour is offensive.

Particulate Air Emissions

Many of the chemicals which are mixed together with rubber to produce a
rubber compound are powders. Powders used include vulcanising agents such
as sulphur and zinc, but the main constituent is carbon black. Carbon black is
a very fine, greasy particulate substance. All of these powders require care
during handling due to the potential respiratory risks to workers. The release of
all particulates is again controlled through air permits issued by local regulatory
authorities, with limits set at a lower level for carbon black than other
particulates. Worker health protection measures are required since many
materials used can cause respiratory illnesses.

Volatile Organic Compounds (VOCs)

Many rubber product manufacturers use an organic solvent based rubber


cement to adhere the components of the product together, e.g. octane can be
used in tyre and air mattress production. VOCs are a result of the evaporation
of organic solvents and are regulated through air permits. Methods for
reducing VOC emissions include the replacement of organic solvents with
water based alternatives.

1
FINANCIAL IMPLICATIONS

Odour

· The installation of odour control equipment may incur significant


expenditure depending upon the location of nearest neighbours.
· There may be a need to pay fines for the release of an offensive odour
beyond the site boundary.

Particulate Air Emissions

· Capital cost may be required for the design and installation of abatement
equipment (electrostatic precipitation and dust cyclones).
· There may be a need to pay fines for the release of emissions over the limit
specified in the air permit.

Volatile Organic Compounds (VOCs)

· Significant cost may be incurred for the design and installation of abatement
equipment (VOC incineration).
· There may be a need to pay fines for emissions over the limit specified in
the air permit.
· Costs may be incurred for the technological changes that might be required
for the alternative use of water based compounds.

OTHER POTENTIAL ENVIRONMENTAL ISSUES

Other potential environmental issues to be considered are:

· rubber fume emissions;


· emissions from boilers;
· effluent contamination with carbon black, oil and vulcanising agents such as
sulphurous powders and zinc;
· on site burning of waste.

Rubber Fumes

During the curing process of a rubber product the high temperature and
pressure produces rubber fumes. Rubber fume is a very complex mixture of
substances, the main constituents being volatile organic compounds (VOCs),
particulates and certain carcinogenic compounds. Exposure to rubber fume can
result in asthma and certain cancers such as bladder cancer. Incidence of such
medical conditions should be assessed together with any outstanding worker
health compensation claims. The environmental effects are usually minimal
due to the condensation of the fume on the factory ceiling before release to the
environment.

2
Air Emissions from Boilers

The curing of rubber requires significant heat and pressure generation capacity.
Many rubber manufacturing sites have large on site boilers to meet these high
temperature and pressure requirements. The emissions from the boilers will be
dependent on the fuel used (coal, oil or gas). Large coal fired boilers may emit
high concentrations of sulphur dioxide, nitrogen oxides, carbon dioxide, carbon
monoxide and particulates. If these exceed the emission limits of the facilities'
air permit, the boilers may need to be replaced or converted to use a different
fuel type.

Effluent Contamination

The risk of effluent contamination from carbon black, vulcanising agents such
as zinc and sulphur and oil is high. In addition, during the LCH salt bath
process a high salt content arises in the effluent. Most rubber production
facilities will have been issued with an effluent permit from the local regulatory
authorities which specifies limits for various contaminants. These discharge
consents may apply to effluent discharges to sewer and to surface water (in
many countries the authorities responsible for the sewer differ from those
responsible for surface water courses). If discharge limits are exceeded an on
site effluent treatment plant may be required and fines may be issued.

On Site Burning

Waste may be burnt on site as a means of disposal. This practice is not usually
allowed under local legislation as dark smoke may be emitted. Particular care
should be taken if rubber products are burnt due to the hazardous composition
of the smoke emitted.

ENVIRONMENTAL IMPROVEMENTS

Potential environmental improvements may include:

· Re-use of cooling waters; cooling requires large volumes of water;


· Raw material management to reduce sources of odour;
· Management of air emissions by using dust suppressed raw materials and
effective abatement technology;
· Solvent management through reduction and replacement with water based
substitutes;
· Bunding of bulk storage containers;
· Energy efficiency and heat recovery measures can be introduced.

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ENVIRONMENTAL ACTION PLANS

Recommended environmental action plans should include developing


procedures which:

· ensure regular inspections of air emission abatement equipment;


· regular sampling of air emissions from the facility;
· regular maintenance of all on site air emission abatement equipment.

GUIDE TO INITIAL DUE DILIGENCE SITE VISITS

During the site tour it is important to investigate the following:

· conduct a tour of the whole site;


· note methods of air emission abatement;
· discuss permitting requirements paying particular attention to regulations on
air emissions;
· observe for signs of bad housekeeping of raw materials during handling and
storage;
· discuss air monitoring data (odour, VOC and particulate) and any breaches
of the air permit;
· discuss water quality data and any breaches to the effluent permit;
· note methods of effluent discharge abatement;
· contact should be made with local regulatory agencies to determine
compliance record and whether complaints have been made by the public;
· note health and safety record and discuss occupational exposure statistics.

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Sub-sectoral Environmental Guidelines
GLASS / GLASS WOOL

PROCESS DESCRIPTION

Flat glass is produced by melting sand together with other inorganic ingredients
and then forming the molten material into a flat sheet. The techniques most
frequently used are the float, plate, sheet, and rolled processes. Although the
raw materials and melting operations are basically the same, each process uses
a different method for forming flat sheets from the molten glass. The most
common type of flat glass produced uses the soda-lime method with the main
ingredient being sand (silica) and other constituents including soda ash,
limestone, dolomite and cullet (broken glass, recycled in the process).

The manufacturing steps include batching (the mixing of raw materials);


melting; forming; annealing (to remove internal stresses); grinding and
polishing (to achieve flat and parallel surface); washing; and cooling.

Glass wool is produced from molten glass and subsequently converted into
glass fibre. The melting process includes cross and end-fired furnaces using
fossil fuel, electrically heated furnaces and coke fired cupolas, etc.
Fibre forming can be continuous where molten glass flows through bushings as
filaments which are coiled by water sprays and coated with a sizing compound
which are then wound into spools and dried in an oven. With rotary forming
glass flows through a single bushing and primary fibreising occurs by
centrifugal action which is then sprayed with a binder (often a phenolic
compound), formed into a mat, heated, cured and cut to size.

SUMMARY OF KEY ENVIRONMENTAL RISK/LIABILITY FACTORS

Air Emissions

· Furnaces for glass melting can be coal, natural gas, heavy fuel oil, oil etc.
The choice of fuel affects the pollutants (primarily NOx, SOx, CO and
hydrocarbons).
· Raw materials vaporise during manufacturing process, producing mainly
particulates, which condense at lower temperatures in the furnace. The
chemical composition of particulates depends upon formulation used, and
can include metals (lead, arsenic), salts and oxides.
· Glass wool emissions from curing process can contain organics (odour
implications).
· Fluoride emissions depend upon type of raw material used (fluorspar,
cryolite).
· Gaseous emissions from final steps of glass making, (the forming and
finishing) operations are generally not significant enough to be of concern.
· Fugitive emissions from storage of chemicals, raw materials, spillages from
lorries and storage areas.

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· Glass fiberisation produces particulate matter, range of volatiles, release
depend on type of process.

Issues to Consider:

Emission control equipment is usually required for furnace emissions, dust and
particulates abatement (electrostatic prepitates). Check stack height with regard
to legislation and dispersion of pollutants

Water Supply and Wastewater Management

· Sources of process and potable water - municipal, abstraction wells,


boreholes (quality of water is important, pre-treatment may be required
depending upon initial quality and intended use).
· Large volumes of water needed for cooling and production purposes.
· Main wastewater sources from glass finishing processes - washing,
quenching, grinding, polishing, direct contact with glass. Some processes
may include machine cutting, alkali washing, acid polishing, acid etching.
· Major pollutants of concern: suspended solids, oil, pH, BOD5, total
phosphorus, temperature. Also fluorides, and lead.
· Main wastewater sources from glass wool fibreising: heating and curing
· Major pollutants of concern: suspended solids, organics, binders, lubricants,
coupling agents, pH control agents: pollution abatement if wet scrubbing
devices used.
· Coloured glass production may produce wastewater streams contaminated
with heavy metals, e.g., vanadium, chromium and barium/lead etc.

Issues to Consider:

· Permits and charges are usually required for water abstraction.


· Potential for recycling and reuse of water and heat.
· Integrity of drainage system is important. Check surface/foul drains,
soakaways, underground drainage system, interceptors etc.
· Quality of wastewater treatment plant (facility/municipal) - check type,
effectiveness, monitoring, final effluent disposal.
· Regulatory compliance - discharge consents, enforcement, costs.
· Sheet and rolled glass manufacture produce no significant process
wastewater.

FINANCIAL IMPLICATIONS

· Fees and penalties (air emissions, effluent discharges, solid waste and sludge
disposal).
· Wastewater containing a variety of pollutants must be disposed of carefully
and may need treatment prior to release. The cost of on-site treatment may
be high.
· Runoff/storm water drainage from raw material, finished product and waste
holding areas. Upgrades to the drainage system may be required.
· Contamination of soil and groundwater from leaking storage tanks/loading
areas. Clean-up may be costly.

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· Health and safety issues associated with the use of lead in the glass
production process.
· Outstanding claims (health and safety).
· Installation of abatement technology may involve significant costs.
· Widespread use of alternative products (e.g. plastics may affect the market
for glass products)
· Long term investment and operation and maintenance costs could increase if
there is a trend towards a more stringent regulatory environment

OTHER POTENTIAL ENVIRONMENTAL ISSUES

Storage of Oils, Gases and Chemicals

Some oils, gases and chemicals are utilised in the process. Typical storage may
include the following:

· underground storage tanks (UST);


· bulk storage oil tanks;
· fuel oil tanks;
· drums of assorted additives, caustics, disinfectants, detergents.

Issues to Consider:

· Secondary containment of tanks (bunds etc.) to prevent spills reaching the


wider environment
· Potential for contamination of surface water by oil, grease, process materials
· Regular integrity testing of UST and bulk storage tanks
· Accident/fire precautions and emergency procedures
· Integrity of chemical store, floor and drainage arrangements
· Chemicals stored in the past, e.g. hydrofluoric acid for glass etching and
lead.

Solid and Hazardous Waste Management

Typical wastes include:

· waste or broken glass (cullet, usually recycled in process);


· sludges (often caustic);
· solid wastes (cartons, packaging, domestic);
· filters from arrestment/abatement plant;
· waste oil from oil/water separator;
· waste acid/caustic solutions;
· furnace/stack bricks containing chromium.

Issues to Consider:

· Waste disposal contractors (approved? licensed?)


· Ownership of waste disposal sites
· Pollution of soil and groundwater

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Asbestos and PCBs

Asbestos and PCBs may need to be removed from the site which can be costly.
Asbestos might be found as an insulation material in walls and ceilings, while
PCB's could be found in transformers and hydraulic machinery.

Odour and Noise

Odour and noise may reach or exceed nuisance/safety levels. Check regulatory
compliance and complaints records.

ENVIRONMENTAL IMPROVEMENTS

· Change to cleaner fuel sources.


· Increase fraction of recycled glass in furnace fuel.
· Lagoon treatment effective for removal of high levels of suspended solids
from plate glass manufacturing wastewaters.
· Some plants able to recycle non-contact and cullet quench waters.
· Re-use of cullet in process.
· Re-use heated wastewater to warm cold water supply, use recuperative
methods to preheat combustion air.
· Pipe insulation etc.
· Oxygen enrichment in combustion can result in fuel savings and increased
productivity (but also increased NOx).

GUIDE TO INITIAL DUE DILIGENCE SITE VISITS

When visiting the sites of potential borrowers, or during loan supervision, use
the following as a practical guide to due diligence.

· Perform a complete tour of the site compound if possible.


· Note signs of poor housekeeping.
· Note nature of solid waste disposal, check if lagoons, incinerators.
· Look for localised spills, leaking pipes etc.
· Check use of personal protective equipment.
· Review age of process equipment.
· Check source of electricity, heat and water supply.
· Assess emergency response to fires, major spills etc.
· Review historical and projected environmental fees and fines.

It is also suggested that contact is made with local regulatory agencies to


determine compliance record and whether complaints have been made by the
public.

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