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Technology meets new environmental challenges.

Technology Meets New Environmental Challenges

By now, almost everyone is aware of the adverse effects of the illegal dumping of hazardous materials. These wastes and byproducts are now wreaking havoc on public health and natural resources, and the cleanup operations are straining the financial resources of communities throughout the nation. A federally-sponsored cleanup operation can easily result in costs in the tens of millions of dollars. Yet, these illegal operations are not the only reason environmental remediation activities must be implemented.

Through the 1970s and 1980s, we have become a more environmentally aware society and consequently, the federal and state governments have passed a myriad of laws to protect the environment. The result has been that industry must keep on top of and comply with a growing number of regulations and bear the responsibility to the communities involved.

Many industrial practices that were once commonplace are no longer permitted under today's regulations. Currently, the only "accepted" concept of environmental practices is that it is continually changing and that risk managers, corporate environmental compliance officers and environmental consultants must now deal with the dilemma of making technically sound, regulatory responsive, cost effective decisions.

Cleanup Incentives

The ramifications of pollution incidents should be fully considered before a remediation process is selected. First, there is an alphabet of laws which regulate environmental management, including RCRA (Resource Conservation and Recovery Act), CERCLA (Comprehensive Environmental Response Compensation and Liability Act), SARA (Superfund Amendments and Reauthorization Act) and TSCA (Toxic Substance Control Act). Each law carries with it substantial civil and criminal penalties if companies do not comply.

With incidents involving hazardous or toxic materials, there is a very real potential for third-party claims. Property damage, bodily injury and natural resource damages have all been recent sources of extensive litigation and vast settlements. As a result, case law is continually being established in courts throughout the country forcing industry to pay for pollution claims.

In terms of public relations, pollution events are bad press for the industry involved, and can often put corporate reputations on the line. The names of Hooker Chemical Company and Occidental Chemical Company are perpetually linked with the environmental disaster of Love Canal in upstate New York, as is Ashland Oil's name to its catastrophic spill into the Monongahela River, Union Carbide to Bhopal, India, and most recently Exxon to the oil spill off the coast of Alaska.

Property transfers are yet one more incentive for environmental remediations of which risk managers should be aware. A growing number of states are passing regulations which require the cleanup of any past environmental impairment situation prior to the sale of a property. Not only do outstanding environmental issues reduce the value of the property, but they can prohibit the sale entirely unless addressed.

The Investigation

The first step in solving an environmental problem is to identify the type and extent of the pollutant source. This is typically accomplished through the use of an environmental site investigation. The scope of the investigation can vary considerably depending on the site's specific conditions, but will typically include groundwater investigation, surface and subsurface soils investigation, surface water, air monitoring and source characterization.

Depending upon the nature and extent of the environmental problem being faced there are a host of potential treatment alternatives. Some of the more commonly used and most effective remediation technologies include surface barriers, slurry walls, groundwater treatment, gas collection/recovery systems, air stripping and incineration.

Low permeability surface barriers, commonly referred to as "capping," are created to prevent the percolation of surface water into waste material, which would allow it to spread into clean soils and groundwater, as well as to prevent erosion. The cap is a series of layers, each having a unique function. The outermost layer is usually top soil for vegetation purposes and under the top soil is a sandy soil which protects the underlying barrier layer. The barrier can be comprised of low permeability clay or a synthetic material, and covers a filter layer of intermediate sand as well as a gas channeling layer to collect and disperse gas generated by the waste.

When it becomes necessary to contain, capture or redirect the flow of groundwater near a waste site it may be advisable to construct sunken slurry walls. In the process, deep trenches are dug and a mixture of soils and cement are poured into the trench to create an impermiable wall. Slurry walls can be placed in a variety of configurations around a site, including upgradient of the site to redirect clean groundwater, or downgradient to capture contaminated groundwater so it can be properly treated.

The process of groundwater treatment, also known as "pump and treat," entails a system of wells placed around a site. Water is pumped to the surface, treated to remove the existing contaminates, and either reinjected into the ground or discharged into a nearby stream.

If there is a danger of an offsite migration of gases generated by waste material it may become necessary to implement a gas collection/recovery system. There are two types of systems: passive and active. Passive systems allow gases to flow naturally through a series of directed paths to a controlled point of release. Active gas collection systems use mechanical means (pumps, blowers, compressors, etc.) to direct gas through the system.

In-situ biological treatment involves the direct application of biodegradable wastewater onto land for microbial decomposition. Through the action of microorganisms in the soils (they actually eat the chemicals), the contamination is broken down into less hazardous components.

In cases requiring the removal and separation of organic compounds from either wastewater or gases within a broad concentration range it may be best to implement a carbon absorption/activated carbon system. This system requires periodic monitoring, as the carbon does require replacement as it becomes saturated.

Another effective and commonly used method of groundwater treatment is air stripping. This method removes volatile organic compounds from the water by pumping contaminated water from the ground to the top of a tank column and having the water filter down through a packing material within the tank. Concurrently, air is introduced at the base of the column so the volatile organics are transferred from the water to the air and carried out of the top of the column.

As landfill space becomes increasingly regulated, expensive and scarce, the incineration of hazardous waste has become a viable alternative. Liquids, semi-solids and solids can all be incinerated and the design of the incinerator will dictate what type of waste can be handled. In turn, the type of waste will determine at what temperature and for how long the material must be burned. Incinerator facilities can either be permanent or mobile. Mobile facilities are often used when transportation costs for the waste are prohibitive.

Consistent with the EPA's policy of waste minimalization, mobile dewatering units were developed to filter out solids from contaminated liquids. Also known as filter presses, the technology produces a solid filtercake from the solids in the solution. The amount of hazardous material is thereby reduced in volume and more amenable to disposal facilities. The water portion needs only to be treated and discharged.

When evaluating a potential cleanup technology at a facility there are numerous considerations which need to be made. Probably the most fundamental is that the risk manager should be satisfied that the site has been completely characterized. Having performed a comprehensive site investigation, key aspects of reviewing recommended remedial alternatives include compliance with applicable or relevant and appropriate requirements (ARARs), long-term effectiveness and permanence, implementability, cost and community perception. By applying these fundamental considerations to the technologies in question, the risk manager is sure to make a sound investment in the remedial alternative selected for a site.

Legal Considerations

There are a multitude of laws to be considered when dealing with hazardous materials. ARARs is a term developed by the federal government to encompass any regulation or special interest which might impact a publicly-funded cleanup. However, the steps should also be applied to a privately-funded cleanup as well. ARARs can range from the assurance that the appropriate permits have been obtained to initiate the cleanup operations, to considering a potential conflict with a site of archaeological or historical value.

For example, the federal government (along with certain state governments) increasingly enforces the need for waste minimization. Through regulation, industry has been put on a schedule to reduce its waste volume and encouraged to develop new and innovative waste treatment technologies. In addition, the EPA has set up a time table for the gradual elimination of most hazardous material into landfills. Through this "landban" it has become increasingly difficult to dispose of waste materials, including those resulting from cleanup operations, and all disposal options must be reviewed carefully.

Another example would be if the treatment technology under evaluation should involve the discharge of hazardous materials into a nearby stream. This situation would require the company responsible for the discharge to obtain a permit under the National Pollutant Discharge Elimination System (NPDES). An outgrowth of the Clean Water Act (CWA), the NPDES regulates all discharge to surface water and municipal utility authorities.

A thorough review of the applicable regulations for any recommended technology is a necessity in the risk manager's screening process. A possible treatment alternative can be screened immediately if it does not meet the compliance issues associated with it. Pending regulations should also be included in the evaluation to solicit a comprehensive review of ARARs to ensure that the remedial decision made is based upon all available regulatory information.

Once the risk manager has chosen a treatment that is in compliance with ARARS he should investigate the effectiveness of the proposed remedy. Is the alternative a short-term solution requiring future attention, or a permanent solution, ensuring the continued protection of the environment? Special consideration should be given to the degree of threat posed by the hazardous substances remaining at the site, the adequacy and reliability of the controls, and the impact to the environment and public health as well as the costs if the remedy fails.

Employing the Method

While the question of implementation of the chosen method of treatment may be obvious to some, it is an area that is often overlooked in the selection process. Every community with a problem landfill would like to see the waste picked up and carted away. Yet, when the reality of extensive air emissions, increased trucking traffic and lack of disposal facilities is presented, the solution seems less attractive. There are countless limitations which can impact the start-up of a cleanup program, including seasonal influences, property access restrictions and the availability of goods and services. No matter how effective the treatment technology may be, it is useless if the equipment can not get onto the property.

The cost of a remedial action alternative can come in one of two forms; the construction cost and the operation and maintenance (O&M) cost. A low-end construction cost can often be deceptive because of its long-term O&M costs. The risk manager needs to look at both ends over five and ten year periods to effectively compare the available options. A hidden cost which should be evaluated in the O&M phase, is the required monitoring after site closure. Analytical costs can be quite extensive if a technology is chosen which requires an aggressive monitoring scheme and may make the overall program cost prohibitive.

Community Perception

Community relations is an important parameter of good business for industry. Public perception, both positive and negative, of a cleanup project can be a strong determining factor in the success of a selected technology. This is especially true with a highly visible or established contamination problem. An industry perceived as unresponsive, and with a long history of environmental fines, can be forced to prove by the courts, the media, or through regulatory actions, that its remedial action is adequate and technically sound.

Selecting the appropriate remedial technology is often a very difficult task and is best done with the assistance of a competent environmental consultant. The factors to be considered in the selection process can be overwhelming but by asking an environmental professional the right key questions, it is possible to manage the environmental remediation selection process properly with low risk to the community and bottom line.

Beth I. Muhler is senior project engineer for Consulting Services, Inc. in Downingtown, PA.
COPYRIGHT 1989 Risk Management Society Publishing, Inc.
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Author:Muhler, Beth I.
Publication:Risk Management
Date:Aug 1, 1989
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