Hazardous Waste Management, 2nd ed.

Instructors Manual

Chapter 8: Facility Development and Operations

CHAPTER 8 FACILITY DEVELOPMENT AND OPERATIONS

Supplemental Questions The opening quote is by John Stuart Mill. Who was John Stuart Mill? John Stuart Mill, 1808-73, was a British philosopher and economist. He received a rigorous education under his father, James Mill (1773-1836), and Jeremy Bentham (1748-1832), who were close friends and together had founded utilitarianism (see textbook, page 27). John Stuart Mill's own philosophy developed into a more humanitarian doctrine than that of utilitarianism's founders: he was sympathetic to socialism, and was a strong advocate of women's rights and such political and social reforms as proportional representation, labor unions, and farm cooperatives. In logic he formulated rules for the process of induction, and he stressed the method of empiricism as the source of all knowledge. On Liberty (1859) is probably his most famous work. Mill strongly influenced modern economics, politics, and philosophy. [Adapted from The Concise Columbia Encyclopedia 1989] The opening of the Waste Technologies Industries, Inc. (WII) hazardous waste incinerator in East Liverpool Ohio was recently announced. When did the permitting process on this facility begin? 1981. [For additional background on this facility see The Hazardous Waste Consultant, July/August, 1993] How many commercial hazardous waste management treatment or disposal facilities are currently in operation in the U.S.? According to the 1994 Outlook (The Hazardous Waste Consultant, March/April 1994), the number operating is 160. It is interesting to note that of the ten "new" facilities listed as making significant progress, six are expansions (which do not require siting) and one is a cement kiln (which is not required to meet all of the requirements of a commercial incinerator). There are in this listing three new incinerator facilities: USPCI, Clive, UT; Waste-Tech, Kimball NE; and Waste Technologies Industries, Inc., East Liverpool, OH. This is contrasted to 60 facilities listed under cancellations or delays. There were only four new proposals in the 1994 Outlook: 1. landfill expansion, 2. wastewater treatment, 3. metals recycling and 4. treatment 8-1. Which types of facilities do not generate residual waste? Essentially all facilities generate residual wastes. The processing of wastes in recovery/recycling facilities produce side streams, typically containing the constituents separated from the raw waste. Treatment of waste also produces residuals (e.g., metal hydroxide sludge from a chemical precipitation step or scrubber water blow-down from an incinerator). Although it is considered the "end of the line" repository for residuals, some landfills can produce residuals (e. g., collected leachate). 8-2. What types of facilities could recover or treat the residual wastes from a solvent recovery facility? A solvent recovery facility separates contaminants from waste solvents. The constituents in the residuals vary in type and concentration dependent upon a.) the manner in which the original solvent was used in manufacturing, b.) the specific separation technology employed in recovering the waste solvent, and c.) the particular solvent. A typical residual is a still bottom (from distillation). If not too contaminated and if the solvent was non-chlorinated, it could be considered for a fuel blending or energy recovery (cement kiln) facility. It could be in the form of a sludge that would require incineration.
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Chapter 8: Facility Development and Operations

8-3. Briefly describe ten measures for ensuring the safe operation of a hazardous waste facility. 1. Pre-shipment waste analysis - Characterize waste to be managed by the facility before the waste is received to determine compatibility with facility operations and to provide a basis for verification upon receipt. 2. Waste testing upon receipt - Collect representative sample of waste upon delivery to facility and test selected parameters to verify that it is consistent with the more complete pre-shipment analyses. 3. Security - Prevent vandals as well as inadvertent intruders who could become exposed to waste, damage equipment, or cause unplanned releases. 4. Inspection and maintenance - Make scheduled. inspections of equipment and structures using a prepared checklist. 5. Incident prevention - Perform a risk analysis to identify hazards and potential incidents that could lead to a fire, explosion, spill or any other unplanned, sudden release. For major concerns, take preventive measures, provide control equipment, and train personnel in emergency procedures. 6. Emergency planning - If an incident occurs, have a plan for how best to react. The plan details actions within the facility as well as interaction with the community safety services. 7. Training - Train employees to perform routine operations as well as respond to incidents. 8. Environmental monitoring - Collect samples of the environmental media and analyze for hazardous constituents. 9. Regulatory compliance - Identify regulatory requirements and meet if not exceed them. 10. Audits - Conduct a systematic, documented, periodic and objective review of facility operations and practices. 8.4 Define five criteria for siting a hazardous waste incinerator? Should any of these be mandatory? 1. Do not locate in the 100-year floodplain (should be mandatory because of the risk involved and the likely availability of much land outside the floodplain). 2. Do not locate in wetlands (should be mandatory because of the disruption of environmentally sensitive land and the likely availability of much land in non-wetland areas). 3. Do not locate landfills in areas with high ground water flow velocity (should be discretionary because of the need to consider the interrelationship of several hydrogeologic factors before determining if a site is suitable or unsuitable). 4. Do not locate in areas with high population density (should be discretionary as otherwise this criterion would force siting in rural areas and raise the issue of why is it any safer to locate it where it exposes a small rather than a large population (assuming that in the rural area a residence or two would be located just as close as those in the city). 5. Do not locate incinerators in air quality non-attainment areas (should be discretionary as the incinerator may not emit the particular non-attainment pollutants, and besides there are regulatory procedures to allow locating new facilities in such areas although the costs of development could be higher than in attainment areas). 8-5. How could a computer prove useful in siting hazardous waste facilities? With GIS (Geologic Information System) software and data, alternative criteria and sites could be analyzed and evaluated efficiently. This would support a more comprehensive analysis particularly at the regional screening level. 8-6. Name a positive and negative way in which public concern with hazardous waste impacts the development of facilities to treat or dispose of the waste. Positive - Public concern spurred regulatory initiatives that greatly expanded the need for commercial services to manage hazardous waste in environmentally acceptable manner.

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Chapter 8: Facility Development and Operations

Negative - Public concern has prompted "not in my backyard" opposition in most cases to the development of new capacity to manage hazardous waste, delaying if not preventing new facilities and increasing developers' costs. 8-7. Name five root causes of the general reaction of the public to oppose the siting of hazardous waste facilities in its community. 1. Having not participated in site selection, the facility is perceived as being imposed (involuntarily encountered) on the community (i.e., the community had no say in its destiny). 2. The facility is perceived as having no real benefit. 3. The facility is perceived as representing an unknown but substantial risk, partly prompted by the term "hazardous". 4. There is a general climate of distrust of industry (who will operate the facility), science and technology (that attempt to explain and control the risk), and government (who will watchdog the facility), reinforced by past episodes such as Love Canal. 5. Once opposition forms, it rarely lessens, partly because of political activism. 8-8. What did the Province of Alberta do to address these root causes? Which was/were the most important? 1. The site selection was an invitational process in which the community participated in site selection to the degree of having the right to refuse the facility (i.e., not siting it anywhere). 2. A public communication and education program effectively explained and demonstrated the economic benefits of additional jobs, a diversified economy, and an increased tax base. 3. The same public communication and education program effectively explained that the risks were being managed carefully. 4. The community participated in the selection of the company that would operate the facility. The fact that the community had the right to refuse the facility helped build trust. 5. Major opposition never formed. Of these, the public communication and education program was the most important together with the initial position that the community had the right to refuse the facility (determined by referendum). 8-9. Would one expect public opposition to differ dependent upon the type of facility proposed? One should expect less opposition to those facilities that treat or recover waste without permanently disposing of residuals on site. Even so, there has been large opposition to proposed incinerators (largely because of emissions) and even to some transfer facilities. 8-10. Identify the representation one would expect to find on a public advisory committee to a statewide site selection process. Community: Citizen activists, environmentalists, local officials. Industry: Generators, operators/developers, chamber of commerce Government: Regulators (technical and legal) Science: University professors, research scientists 8-11. What are Part A and Part B permit applications, and what are their main elements? Note to Lecturer: This material is not explained in the text: however, it is readily determined from reviewing regulations. A Part A is an 8-page form listing basic data about a facility (primarily the types and quantities of waste managed and the waste management methods). A Part B is the full application and could number several hundred pages in length. Its elements are listed in Table 8-2 on p. 441. When RCRA was enacted, a number of existing facilities
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were already in operation. RCRA's first regulations required that to continue to operate under "interim status", such facilities had to submit a Part A to the U. S. EPA by a specified deadline. Later (years in some cases), the U. S. EPA would call for the Part B application from interim status facilities and that would start the more deliberate phase of permitting. The Part A and B Forms are still in use with both having to be revised if a facility is capered. 8-12. What are the implications of the term "acceptable risk" as it applies to the siting and permitting of hazardous waste facilities? Because of many complexities, exact and definitive standards can not be established to cover all facilities. In the absence of exact standards, the regulator must exercise judgment. Further, any facility will pose some risk, however small, to public health and the environment. Because zero risk can not be achieved, the regulator thus must decide what is "acceptable risk". The issue becomes "acceptable to who?". The line between acceptable and unacceptable is unclear as it depends upon one's point of view. The local community typically finds any risk, however minutely small, to be unacceptable. This conflict will necessitate that the regulator perform a highly detailed evaluation of the permit application. This usually results in the following: 1.) the evaluation will take considerable time (thus delaying the development of the facility) and 2.) the regulator will require that the developer submit an inordinate amount of supplementary information regarding items such as site characteristics (thus requiring additional time and costs). Upon completion of the evaluation, issuance of a permit may be contingent upon the facility providing additional protective measures not proposed by the developer (thus representing additional costs). Even after a thorough evaluation and the provision of supplemental information, it is possible (if not likely for controversial facility proposals) that the regulator will decide not to issue a permit. 8-13. Why is a "needs assessment" important to the development of a facility? A needs assessment would demonstrate whether a particular type of facility was needed to support proper management of hazardous waste in a region/state. A broadly representative group should have participated in the preparation of the assessment (see Problem 8-10 above). A typical citizens' complaint about a proposed facility is that it is not needed; therefore, a controversial facility would have little likelihood of being permitted if the needs assessment indicated it was not necessary. However, even a needed facility has no guarantee of approval. The needs assessment represents an initial decision point, with needed facilities still receiving the same regulatory scrutiny during permitting. There is the general objective that if a particular type of facility were needed, the regulatory agency would assure that such a facility would be located "somewhere". Experience has shown that this is not necessarily the case. Interstate commerce laws provide local generators access to operating facilities in other states. 8-14. Determine the minimum number of separate storage areas necessary to provide safe segregation of the following wastes: plating sludges containing Cd; cleaning agents containing caustics; chemical wastes (aromatic hydrocarbons); waste cresol from a wood-treating operation; sludge from plating operation containing cyanides. Referring to Fig 8-10 on page 433, the waste reactivity groups are as follows: Plating Sludge w/ Cd 24 Cleaning agents w/ caustics 10 Aromatic hydrocarbon waste 16 Cresol waste 31 Plating sludge w/ cyanide 11 According to Fig 8-10, the only adverse reactivity consequence that could occur is to mix Group 10 (caustics) with Group 24 (cadmium). Thus, a minimum of two separate storage areas are required. 8-15. Under what conditions can a surface impoundment be considered a land disposal facility? A surface impoundment should be considered a land disposal facility if it were closed with some waste left in place. As such it would require double liners and other protective measures associated with a landfill (see Section 13-9 on page 853).

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Chapter 8: Facility Development and Operations

8-16. What are two fundamental measures for preventing a deep injection well from contaminating ground water? 1. Any potable aquifer is above the receiving formation and is separated by a confining layer. 2. The injection pipe is centered within a series of concentric casings alternately containing cement and noncorrosive fluids monitored for leakage. 3. The pressure is monitored continuously (drop in pressure would indicate a leak at a higher elevation or in a less dense formation). 8-17 What is the difference between a waste profile and a waste analysis plan? A waste profile lists the results of a detailed chemical and physical analyses of a particular waste. The analyses are performed to characterize fully a waste that is being considered for management at a facility. The analyses are performed once, before the waste is first received by the facility. The purposes for performing the profile are detailed on p.431. A waste analysis plan specifies the chemical and physical analyses of all wastes received by a facility. The plan specifies also the frequency of sampling, the sampling procedures, and the analytical methods. The plan includes the waste profile (described above) as well as the representative sampling conducted when the waste is received by a facility. The representative sampling verifies that the composition of the received waste matches the profiled waste. The representative sampling is limited to only a few parameters. 8-18 Name five media/receptors that could be monitored for release of hazardous waste constituents from an incineration facility. Media: Air, soil (possibly contaminated by emission deposits as well as spills), ground water (possibly contaminated by spills and leaks), and vegetation (uptake of constituents from soil). Receptors: Facility employees, residents, livestock.

8-19. Which is more important in selecting a site for a new hazardous waste facility: applying siting criteria in a scientific fashion to select a technically superior site or involving the public in site selection? Involving the public in the site selection process is more important than applying criteria in a scientific rigorous manner, even if the latter identifies a technically superior site. Experience has shown that public participation in a meaningful manner was the key to success for siting programs that resulted in the construction of a facility. Public trust in the project must be fostered, and professing to have superior technology is not sufficient to gain trust. Even going beyond the concept of trust, public values are not necessarily captured by scientific criteria (the site selection process must allow for value judgments). Further, the selected site need only to be adequate, not superior; a enormous amount of protection can be engineered into a facility independent of most site characteristics 8-20. What is the process difference between an aqueous waste treatment facility and a municipal sewage treatment There are many differences in both scale (flow rate) and technologies utilized. The flow rate at a municipal sewage treatment plant is usually measured in millions of gallons per day versus thousands at an aqueous treatment facility. Sewage treatment is a continuous flow process while aqueous treatment is usually a batch process. A conventional municipal sewage treatment facility features gravity separation, biological degradation, sludge dewatering and chemical disinfection. A conventional aqueous treatment facility usually includes gravity separation (facilitated by chemical flocculation), sludge dewatering, and infrequently some biological treatment. However, the most frequently applied processes at an aqueous treatment facility consist of inorganic chemical treatment (neutralization, cyanide destruction and metals removal), rarely applied in sewage treatment unless the sewage contains a high portion of certain industrial wastes. In summary, an aqueous waste like sewage is mostly water; however, treatment is radically different.

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