Water, water everywhere ...
Environmental regulations are certainly concentrating (or is that 'confusing'?) the minds of those in the coatings industry. Apart from the issue of volatile solvent emissions to air that we are already striving to come to terms with, there is the thorny issue of discharges to watercourses and sewers. In the last few years there has also been a raft of regulations on waste minimisation and disposal, including the control of aqueous wastes.
The legislators most directly concerned with environmental issues are the European Union and the Department for the Environment, Food and Rural Affairs (DEFRA). The enforcement bodies are the Local Authorities and the Environment Agency. They are both guided by two main principals: (a) 'the Precautionary principle'--i.e. a policy of intervention on environmental issues, whenever there is doubt and (b) 'the polluter pays'.
We use water in a number of ways in our industrial processes, almost without thinking of it as a consumable or raw material in its own right. For example, it is used for cooling or heating, capturing overspray particles in water-backed spray booths and as a suspension medium for operations such linishing, de-burring and polishing with abrasion media. We also use a wide variety of aqueous chemical solutions such as in acid pickling, phosphate conversion coatings and degreasing.
As many of you well know, there is great pressure to reduce the amount of solvent used in degreasing processes. Anyone who has ever used a vapour degreaser based on one of the chlorinated hydrocarbon solvents, such as trichlorethylene, will realise how difficult it is going to be to replace it. (Even in the last week, one client has told me that they intend to revert back to solvent vapour from their recently installed aqueous degreaser!) The physical properties of such solvents--heavy vapour; non-flammable; an excellent solvent for grease--belied the hazards of ozone depletion, toxicity and carcinogenicity. Their removal from the workplace is ongoing and will be accelerated by the Solvent Emission Directive, which calls for substances with Risk Phrase R45, R46, R49, R60 and R61, connected with cancer-causing and repro-toxic materials, to be replaced or adequately controlled as soon as possible.
The options for alternatives boil down to (a) pay for a fully enclosed vapour control system to prevent emissions to atmosphere; (b) search for a "safe" and practical alternative solvent or (c) consider aqueous degreasers instead. Anyone carrying out a risk assessment should really look at those options in reverse order; safety, health and environmental guidance often refers to a hierarchy for risk reduction with the abbreviation 'ERIC', which stands for Eliminate; Reduce; Isolate; Control. In practice such decisions are never that straightforward.
All of the options have their own peculiar advantages and disadvantages. Those opting to continue using 'Trike' may one day find that still more prohibitive legislation is introduced and the product is to be phased out altogether, because of its R45--may cause cancer--classification. Or it could become prohibitively expensive.
Alternatives such as n-propyl bromide have been put forward. However, these alternative solvents could easily end up categorised in a similar way to the chlorinated compounds, by having similar safety and environmental concerns levied against them in due course. The HSE are taking an active interest in the labelling of certain of those alternatives, which may be incorrectly labelled as R20--harmful by inhalation--when they should be R60--May impair fertility and R61--May cause harm to the unborn child. The REACH Directive (Registration, Evaluation and Authorisation of Chemicals) is certain to raise more queries against many substances and their applications. Naturally, using the Precautionary Principle, it is even more certain that the Environmental Regulators will then apply strong intervention.
Coming back to the case in point, the water residues from the various aqueous processes mentioned are potential sources of pollution. The Water Act 2003 covers all aspects of water usage by setting up the overseeing body, Ofwat; controlling and defining water abstraction; supply; quality standards for drinking water; its efficient use; setting of discharge consents for possible pollutants etc. Companies using water in their processes are required to obtain discharge consent for trade effluent. This will set out the control levels for certain substances in waste water before it can be discharged to sewer. The Authorities can also specify factors such as pH, amount of silt / particulates, temperature, Biological and Chemical Oxygen Demands (BOD & COD) for a given site.
The Groundwater Regulations 1998 allow enforcement agencies to control discharges of defined hazardous pollutants into the subsoil or watercourses. If you have a car park or forecourt, for example, where does the water drain to when it rains? After all, it could carry fallout from factory emissions to air, oil and petrol spills from vehicles, spilt raw materials from unloading operations etc. Make sure that you have a well-rehearsed and effective procedure for dealing with spillages.
The company using the land will certainly be the ones held responsible for any runoff that might end up in local streams rivers or lakes. Remember: the polluter pays! And, if it doesn't quite reach the stream but soaks into the ground, it will cause long term contamination of land and possibly the aquifers too. The Company may again suffer the consequences of a fine and ground remediation costs.
Suppose that, instead, we decide to pay someone to come along and suck it all up and take it away in a tanker for treatment. Are we sure we really know where it is going and how it will be handled? Are we certain that the driver won't take it to the nearest stream and just pump it out? That has happened. The Company producing the waste will still have a responsibility for that waste and any pollution it may cause--the regulations make it clear that there is a responsibility--a duty of care--from 'cradle to grave'.
Considering the amount of it that has fallen from the sky recently, it is odd to think that good quality water is actually a limited resource. At a recent symposium I learnt that it is possible to buy water for approximately 7p per cubic metre but, interestingly, it can cost as much as 10p per litre for waste water, classified as hazardous, to be taken away for disposal. That is equivalent to [pounds sterling]100 per tonne -a "mark up" of over 140,000%! And, incredibly, it could get a whole lot worse, if you dispose of it in the wrong way--as I hope you will see.
Any method of removing the contaminants or concentrating solutions is to be recommended. Sedimentation, precipitation and filtration are all used as means of controlling water discharge. All add cost but having aqueous waste taken away for treatment and disposal by a third party is perhaps the most expensive option. So I was interested when another option, which is apparently already widely used on the Continent, came to my attention.
Effectively, it involves distillation of the contaminated materials under slight vacuum, so that clean water could be recycled within a process. It is reported that running costs are low. It also reduces the bulk of hazardous waste for disposal to a minimum.
Whichever way you decide to deal with you process waste and aqueous emissions, ignoring or failing to abide by the rules can also be very costly. Breaching a Duty of Care can lead to a fine of up to [pounds sterling]5,000 for summary conviction (i.e. in a Magistrates court) but causing pollution can lead to a fine of up to [pounds sterling]20,000 per offence and 6 months in prison, for summary conviction but an unlimited fine and up to two years in prison, if indicted in Crown Court. There are numerous examples of hefty fines being imposed on companies.
These days, many of your customers will have environmental policies that could eliminate you from their suppliers list, should you fail to meet their standards. Obtaining the Environmental Management Standard ISO 14001 or the Eco-Management Audit Scheme (EMAS) is cited as proof of adequate controls. In any event, environmental breaches will lower your Operator Performance and Risk Appraisal (OPRA) and Operator Monitoring Assessment (OMA) scores, bringing you under increasing scrutiny from the enforcement bodies in future.
As a schoolboy in the 50's, travelling across Birmingham, I suppose I thought that it was normal for rivers to have pink or yellow foam on them and that canals were always fluorescent green or had lovely rainbow patterns from oil-slicks on the surface. But things are changing. The local environment is certainly improving.
However, there are a few potential and actual paradoxes that have become apparent due to the sudden rush to "greenness". Anyone forced to change their technology suddenly should check carefully that the process still gives them a product of acceptable quality. We need to keep ahead of the game. Always try to look for alternative solutions to keep in your back pocket for emergencies.
Finally, the Environment Agency website http://www.environmentagency.gov.uk/?lang=_e has a great deal of downloadable material. The site is VERY slow to react but with patience you can usually get what you want. There's also a great deal of very good information on the HSE website, http://www.hse.gov.uk/index.htm which excellent and extremely easy to use.
Oh! And by the way--Good Luck!
Oil spill leaking to groundwater drain = Fine + Remediation costs
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|Date:||Jul 1, 2007|
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