Professional Documents
Culture Documents
AGROCHEMICALS (Fertiliser/Pesticides)
PROCESS DESCRIPTION
Fire/Explosion Risk
The materials used in fertilizer plants are highly explosive, and are, in fact,
used to make explosives.
1
· 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.
Issues to Consider:
Odour and noise may reach or exceed nuisance/safety levels. Check regulatory
compliance and complaints records.
FINANCIAL IMPLICATIONS
2
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.
Issues to Consider:
3
Typical wastes include:
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 may need to be removed from the site which can be costly.
· 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
ENVIRONMENTAL IMPROVEMENTS
4
· 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
Fertilisers
5
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.
6
Sub-sectoral Environmental Guidelines
CHEMICALS AND ALLIED PRODUCTS
(Wholesale Distribution and Storage)
PROCESS DESCRIPTION
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.
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:
Distribution of chemicals from the warehouse will raise similar issues to those
identified for delivery to the warehouse.
1
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.
FINANCIAL IMPLICATIONS
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).
2
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
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 may need to be removed from the site which can be costly.
Odour and noise may reach or exceed nuisance/safety levels. Check regulatory
compliance and complaints records.
3
ENVIRONMENTAL IMPROVEMENTS
· 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.
Chemical Compatibility
· Building and storage design to allow both vertical and horizontal separation
of chemicals.
Public Anxiety
Solid Wastes
4
· 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.
5
Sub-sectoral Environmental Guidelines
INDUSTRIAL INORGANIC CHEMICALS
PROCESS DESCRIPTION
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
FINANCIAL IMPLICATIONS
Air Emissions
1
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.
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.
Waste Disposal
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.
2
disposal on-site. All storage facilities should be provided with appropriate
secondary containment.
ENVIRONMENTAL IMPROVEMENTS
Air Emissions
Effluent Discharges
Storage of Chemicals
Others
3
ENVIRONMENTALAL ACTION PLANS
During the initial site visit, it will be important to assess the following:
4
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.
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.
FINANCIAL IMPLICATIONS
Air Emissions
1
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.
Wastewater Discharges
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.
Waste Management
2
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
Waste Minimisation
Other
During the initial site visit, it will be important to assess the following:
3
· the operation and maintenance of the wastewater treatment plant, if present,
check discharge permits and points;
· site location/surrounding area activities.
4
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.
Product Contamination
Air Emissions
· 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
· 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.
The potential range of chemicals that may be stored is considerable. They fall
into three basics divisions:
· raw materials;
· intermediate chemicals;
· finished products.
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.
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
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.
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.
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.
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
Product Responsibility
ENVIRONMENTAL IMPROVEMENTS
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.)
During the initial site visit, it will be important to assess the following:
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.
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.
Air Emissions
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
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.
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.
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.
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.
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.
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.
ENVIRONMENTAL IMPROVEMENTS
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;
During the initial site visit, it will be important to assess the following:
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 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.
Air emissions
· 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.
· 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.
· 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.
Sludge disposal
FINANCIAL IMPLICATIONS
2
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.
· 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
3
Air Emissions
Energy Efficiency
Recycling/Recovery
Waste Minimisation
ENVIRONMENTAL MANAGEMENT
· 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.
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).
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:
Not all of these will necessarily be produced by a single refinery. Some refineries
are dedicated to particular products, e.g. lube oil refinery.
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.
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.
Atmospheric Emissions
Issues to consider:
2
· drums and containers of assorted compounds (such as lubricating oil, engine
oil, other products for domestic supply).
Issues to consider:
· 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:
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
FINANCIAL IMPLICATIONS
4
· Upgrade of storage areas may be required.
· 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:
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
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.
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
6
ENVIRONMENTAL IMPROVEMENTS
When visiting the sites of potential borrowers or during loan supervision, use the
following as practical guide to the initial due diligence process.
7
· Assess emergency response to fires, major spills, etc..
· Review historical and projected trends for environmental fees and fines.
8
Sub-sectoral Environmental Guidelines
PETROLEUM STORAGE (including PETROL
STATIONS)
PROCESS DESCRIPTION
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
FINANCIAL IMPLICATIONS
In this section medium/large petroleum storage facilities and service stations are
considered separately.
Key environmental issues associated with petroleum storage facilities such as oil
terminals include the following:
2
· semi-underground, or underground storage tanks (USTs).
Issues to consider:
· 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:
Waste Management
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.
4
· Alternatively, contaminated water may be temporarily stored and disposed off-
site by a waste management contractor.
Issues to consider:
Atmospheric Emissions
Issues to consider:
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
Noise
5
It is possible that noise may reach or exceed nuisance levels, particularly on
larger sites.
Odour
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:
Issues to consider:
Issues to consider:
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
Issues to consider:
· Water draining from car wash facilities should not pass through interceptors.
· Other issues, as for larger facilities (see above).
Issues to consider:
Asbestos
Noise
Odour
7
· costs of upgrades/compliance;
· assessment and remediation of contaminated soil and groundwater;
· roles and responsibilities, time-frame and targets.
ENVIRONMENTAL IMPROVEMENTS
When visiting the sites of potential borrowers or during loan supervision, use the
following as a practical guide to the initial due diligence process.
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:
8
· known losses of product/spillages etc.
9
Sub-sectoral Environmental Guidelines
RUBBER PRODUCTS
PROCESS DESCRIPTION
Odour
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.
1
FINANCIAL IMPLICATIONS
Odour
· 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.
· 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.
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
3
ENVIRONMENTAL ACTION PLANS
4
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).
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.
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.
1
· 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
Issues to Consider:
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.
2
· 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
Some oils, gases and chemicals are utilised in the process. Typical storage may
include the following:
Issues to Consider:
Issues to Consider:
3
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 may reach or exceed nuisance/safety levels. Check regulatory
compliance and complaints records.
ENVIRONMENTAL IMPROVEMENTS
When visiting the sites of potential borrowers, or during loan supervision, use
the following as a practical guide to due diligence.