15 Environmental Concerns Elliott Goldberg and Maung K Min 1.0 ENVIRONMENTAL REGULATIONS AND TECHNOLOGY 1.1 gulatory Concerns Environmental laws and regulations including permits are reviewed in this chapter. Included are the Federal Clean Air Act Amendment(CAAA the Federal Clean Water Act(CWA)regulations, the Resource Conservation and Recovery Act(RCra)or, as it is also known, the Solid Waste Disposal Act. Also discussed along with the regulations under osHAre the National Institute for Occupational Safety and Health(NIOSH)and the Hazardous Waste Operations and Emergency Response(HAzWOPER The environmental regulations covered here are not intended to be all inclusive but to provide a basic understanding of the important environmental laws and regulations 1. 2 Technology The environmental technology section includes reviews of waste water reatment and air and waste minimization/pollution prevention. Waste water treatment procedures discussed include biological treatment, activated car bon adsorption, air and steam stripping chemical precipitation, ion ex- change, and membrane separation 635
Environmental Concerns Elliott Goldberg and Maung K. Min 1.0 ENVIRONMENTAL REGULATIONS AND TECHNOLOGY 1.1 Regulatory Concerns Environmental laws and regulations including permits are reviewed in this chapter. Included are the Federal Clean Air Act Amendment (CAAA), the Federal Clean Water Act (CWA) regulations, the Resource Conservation and Recovery Act (RCRA) or, as it is also known, the Solid Waste Disposal Act. Also discussed along with the regulations under OSHAare the National Institute for Occupational Safety and Health (NIOSH) and the Hazardous Waste Operations and Emergency Response (HAZWOPER). The environmental regulations covered here are not intended to be allinclusive but to provide a basic understanding ofthe important environmental laws and regulations. 1.2 Technology The environmental technology section includes reviews of waste water treatment and air and waste minimization/pollution prevention. Waste water treatment procedures discussed include biological treatment, activated carbon adsorption, air and steam stripping, chemical precipitation, ion exchange, and membrane separation. 635
636 Fermentation and Biochemical Engineering Handbook Air pollution control technology includes thermal incineration, cata lytic incineration, carbon adsorption, absorption, condensation, baghouse filtration, wet scrubbing, and electrostatic precipitation The range of technology will provide the engineer with a sufficient ackground to understand the important air control measures 2.0 LAWS REGULATIONS AND PERMITS 2.1 Air The Federal Clean Air Act Amendments( CAa)were initially enacted in 1963 and modified in 1970 and 1977. The Clean air Act Amendments of 1990 involved major changes to environmental regulations. These included a national permitting system to regulate air pollution Its was to protect the public health and environment by indicating how and when the various industries involved must control a list of air toxics. The regulatory authority was given to the states and local governments. Congress, through the CAA, authorized the epa to develop the necessary regulations to carry out the provisions of the act The EPA established the National Ambient Air Quality Standards (NAAQS), which included allowable ceilings for specific pollutants. How- ever, the states have the option to make any or all parts of the Clean Air Act requirements more stringent than the minimums set by EPA. The EPA is required to regularly evaluate the compliance status of all geographic areas with respect to pollutants, that is, whether the NAAQS is being met for each criteria pollutant. An area where NAAQS is not met is designated as a non- attainment area(NA )for that pollutant Areas where the Federal Ambient Air Quality Standards are being met are designated attainment and are subject to Prevention of Significant Deterioration(PSD)requirements and are required to identify those areas that are attaining or not attaining the standards Compliance and noncompliance can be costly. It has been estimated that the installed cost of equipment and systems to control emissions could range from $20 to $50 billion or higher. The technologies expected to be used include wet scrubbing, thermal incineration, catalytic incineration, carbon absorption, and solvent recovery. New sources and modifications of existing sources of air pollution in an attainment area are regulated under the
636 Fermentation and Biochemical Engineering Handbook Air pollution control technology includes thermal incineration, catalytic incineration, carbon adsorption, absorption, condensation, baghouse filtration, wet scrubbing, and electrostatic precipitation. The range of technology will provide the engineer with a sufficient background to understand the important air control measures. 2.0 LAWS, REGULATIONS AND PERMITS 2.1 Air The Federal Clean Air Act Amendments (CAA) were initially enacted in 1963 and modified in 1970 and 1977. The Clean Air Act Amendments of 1990 involved major changes to environmental regulations. These included a national permitting system to regulate air pollution emissions. Its purpose was to protect the public health and environment by indicating how and when the various industries involved must control a list of air toxics. The regulatory authority was given to the states and local governments. Congress, through the CAA, authorized the EPA to develop the necessary regulations to carry out the provisions of the act. The EPA established the National Ambient Air Quality Standards (NAAQS), which included allowable ceilings for specific pollutants. However, the states have the option to make any or all parts of the Clean Air Act requirements more stringent than the minimums set by EPA. The EPA is required to regularly evaluate the compliance status of all geographic areas with respect to pollutants, that is, whether the NAAQS is being met for each criteria pollutant. An area where NAAQS is not met is designated as a nonattainment area (N.A.) for that pollutant. Areas where the Federal Ambient Air Quality Standards are being met are designated attainment and are subject to Prevention of Significant Deterioration (PSD) requirements and are required to identify those areas that are attaining or not attaining the standards. Compliance and noncompliance can be costly. It has been estimated that the installed cost of equipment and systems to control emissions could range from $20 to $50 billion or higher. The technologies expected to be used include wet scrubbing, thermal incineration, catalytic incineration, carbon absorption, and solvent recovery. New sources and modifications ofexisting sources of air pollution in an attainment area are regulated under the
Environmental Concerns 637 Prevention of Significant Deterioration Program(PSD). PSD review is required if the new source or modifications result in a net emission increase above specified levels he specific pollutants referred to include carbon monoxide, nitrogen dioxide, lead, ozone, inhalable particulates, and sulfur dioxide Primary and secondary standards also were set by EPA, with second ary standards reflecting levels necessary to protect welfare in addition to health An area may be in an attainment status for one pollutant and in a non- attainment status for another pollutant. In most areas, PSD authority has been assigned to either the state or local jurisdiction. The use of the best Available Control Technology(BACT) is required for each pollutant and is based on the emission level and capital and operating costs. Regulations in on-attainment areas are required to meet the EPa s New Source review (NSR) regulations The Clean Air Act of 1990 included a list of 189 toxic chemicals to be controlled and such emissions are to be reduced 90% by the year 2000. It also included the phasing out of chlorinated fluorocarbons( CFC's)and carbon tetrachloroflurocarbons(HCFC s)by 2030 All new and modified emission sources must meet the New Source Performance Standards(NSPS). These standards are generally less strin gent than either the Best Available Control Technology(BAct) or the Lowest Available Emission Rate(LaeR) The National Emission Standards for Hazardous Air Pollutants (NESHAPS) specify emission standards for various hazardous air pollut ants and cover asbestos, arsenic, benzene, beryllium, mercury, vinyl chlo- ride. Pvc. etc The CAaa was promulgated to strengthen the federal air protection program and concerns about air toxics by including an expanded National Emission Standards for Hazardous Air Pollutants(NESHAP) program Concerns over the effects of hazardous air pollutants(HAP)or air toxics resulted in the Title Operating permit program. The relationship ofthe Title V program to other CAa titles is shown in Fig
Environmental Concerns 637 Prevention of Significant Deterioration Program (PSD). PSD review is required if the new source or modifications result in a net emission increase above specified levels. The specific pollutants referred to include carbon monoxide, nitrogen dioxide, lead, ozone, inhalable particulates, and sulfur dioxide. Primary and secondary standards also were set by EPA, with secondary standards reflecting levels necessary to protect welfare in addition to health. An area may be in an attainment status for one pollutant and in a nonattainment status for another pollutant. In most areas, PSD authority has been assigned to either the state or local jurisdiction. The use of the Best Available Control Technology (BACT) is required for each pollutant and is based on the emission level and capital and operating costs. Regulations in non-attainment areas are required to meet the EPA’s New Source Review (NSR) regulations. The Clean Air Act of 1990 included a list of 189 toxic chemicals to be controlled and such emissions are to be reduced 90% by theyear 2000. It also included the phasing out of chlorinated fluorocarbons (CFC’s) and carbon tetrachloroflurocarbons (HCFC’s) by 2030. All new and modified emission sources must meet the New Source Performance Standards (NSPS). These standards are generally less stringent than either the Best Available Control Technology (BACT) or the Lowest Available Emission Rate (LAER). The National Emission Standards for Hazardous Air Pollutants (NESHAPS) specie emission standards for various hazardous air pollutants and cover asbestos, arsenic, benzene, beryllium, mercury, vinyl chloride, PVC, etc. The CAAA was promulgated to strengthen the federal air protection program and concerns about air toxics by including an expanded National Emission Standards for Hazardous Air Pollutants (NESHAP) program. Concerns over the effects of hazardous air pollutants (HAP) or air toxics resulted in the Title Voperating permit program. The relationship ofthe Title V program to other CA4 titles is shown in Fig. 1
638 Fermentation and Biochemical Engineering Handbook Title Il Air Toxics Acid rain Title I Title v Title VII Nonattainment pErmit Program Enforcement Existing SIP Permit Program Program Figure 1. The relationship of the Title V program to other CAA titles 2.2 Water In 1972 Congress enacted the Federal Water Pollution Control Act known as the clean water Act (CWA). In 1977 further amendments were enacted which strengthened the provisions of the Clean Water Act. Further refinements were enacted by Congress with the Water Quality Act Amend ments of 1987. The purpose of the CWa was to restore and maintain the chemical, physical, and biological integrity of our countrys waters. It set up specific effluent guidelines for SIC industry categories and BOD and suspended solids continued to serve as the primary parameters. The National Pollutant Discharge Elimination System(NPDES)was set up and authorized EPa to establish and enforce effluent limitations on waste water discharges Designated priority pollutants were introduced with a permit program and aquatic toxicity also became a permit requirement. Volatile Organic Compounds (voC) emissions from waste water treatment plants were severely restricted and control of nutrients such as nitrogen and phosphorous The Clean water Actestablished standards that area-wide waste water treatment plants be developed and implemented to assume adequate control
638 Fermentation and Biochemical Engineering Handbook Air Toxics Acid Rain i-xq Permit Program - Program I Figure 1. The relationship of the Title V program to other CAA titles. 2.2 Water In 1972 Congress enacted the Federal Water Pollution Control Act known as the Clean Water Act (CWA). In 1977 further amendments were enacted which strengthened the provisions of the Clean Water Act. Further refinements were enacted by Congress with the Water Quality Act Amendments of 1987. The purpose of the CWA was to restore and maintain the chemical, physical, and biological integrity ofour country's waters. It set up specific effluent guidelines for SIC industry categories and BOD and suspended solids continued to serve as the primary parameters. The National Pollutant Discharge Elimination System (NPDES) was set up and authorized EPA to establish and enforce effluent limitations on waste water discharges. Designated priority pollutants were introduced with a permit program and aquatic toxicity also became a permit requirement. Volatile Organic Compounds (VOC) emissions from waste water treatment plants were severely restricted and control of nutrients such as nitrogen and phosphorous were required. The Clean Water Act established standards that area-wide waste water treatment plants be developed and implemented to assume adequate control
Environmental Concerns 639 of the quality of the effluent for industrial discharges of toxic pollutants into Publicly Owned Treatment Works(POTw). It also stated that federal financial assistance would be provided to construct publicly owned waste water treatment works It also established that the federal agencies, the state water pollution control agencies, interstate agencies, and the municipalities and industries involved, prepare or develop comprehensive programs for preventing, reduc ing or eliminating the pollution of navigable waters and ground waters and improving the sanitary condition of surface and underground waters. Due regard shall be given improvements which are necessary to conserve such waters for the protection and propagation of fish and aquatic life The Clean Water Act lays the basis for technology based effluent standards of conventional pollutants such as Biochemical Oxygen Demand (BOD), Total Suspended Solids (tss), fecal coliform, oil and grease, pH toxic pollutants, and non-conventional pollutants such as active pesticides ingredients used in the pesticide manufacturing industry, etc A complete list of toxic pollutants can be found in the Code of Federal Regulations, 40 CFR, Part 401.15 The CWA established requirements for setting standards for dis charges from new sources for specific industries. It also lists requirements for preventing and responding to accidental discharges of oil or hazardous substances into navigable waters with notification requirements for releases removal requirements, liability standards and civil penalties. Furthermore the CWa established permitting programs to control discharges and severe civil and criminal enforcement provisions for failure to comply with the law Compliance with the Cwa must be incorporated into the design and operation of every chemical process plant To summarize, the focus of the Cwa is the control of pollutants in effluent discharged from a facility through any conveyance to virtually any stream or significant body of water. These discharges are primarily controlled through the National Pollution Discharge Elimination System (NPDES) If the discharge is to a Publicly Owned Treatment Works, the plant needs to meet pretreatment standards to limit pollutants that cannot be readily removed by the POTW Discharges from the POTW are required to be in accordance with the ffluent limitations contained in the npdeS permit for the POtw. If the facility discharges directly into receiving waters, the facility must file for and obtain its own NPDES permit
Environmental Concerns 639 of the quality of the effluent for industrial discharges of toxic pollutants into Publicly Owned Treatment Works (POTW). It also stated that federal financial assistance would be provided to construct publicly owned waste water treatment works. It also established that the federal agencies, the state water pollution control agencies, interstate agencies, and the municipalities and industries involved, prepare or develop comprehensive programs for preventing, reducing or eliminating the pollution of navigable waters and ground waters and improving the sanitary condition of surface and underground waters. Due regard shall be given improvements which are necessary to conserve such waters for the protection and propagation of fish and aquatic life. The Clean Water Act lays the basis for technology based effluent standards of conventional pollutants such as Biochemical Oxygen Demand (BOD), Total Suspended Solids (TSS), fecal coliform, oil and grease, pH, toxic pollutants, and non-conventional pollutants such as active pesticides, ingredients used in the pesticide manufacturing industry, etc. A complete list of toxic pollutants can be found in the Code of Federal Regulations, 40 CFR, Part 40 1.15. The CWA established requirements for setting standards for discharges from new sources for specific industries. It also lists requirements for preventing and responding to accidental discharges of oil or hazardous substances into navigable waters with notification requirements for releases, removal requirements, liability standards and civil penalties. Furthermore, the CWA established permitting programs to control discharges and severe civil and criminal enforcement provisions for failure to comply with the law. Compliance with the CWA must be incorporated into the design and operation of every chemical process plant. To summarize, the focus of the CWA is the control of pollutants in effluent discharged from a facility through any conveyance to virtually any stream or significant body of water. These discharges are primarily controlled through the National Pollution Discharge Elimination System (NPDES). If the discharge is to a Publicly Owned Treatment Works, the plant needs to meet pretreatment standards to limit pollutants that cannot be readily removed by the POTW. Discharges from the POTW are required to be in accordance with the effluent limitations contained in the NPDES permit for the POW. If the facility discharges directly into receiving waters, the facility must file for and obtain its own NPDES permit
640 Fermentation and Biochemical Engineering Handbook 2.3 Solid Waste Resource Conservation and Recovery Act(RCRA)(Solid Waste Disposal Act) was originally enacted by Congress in 1976 and amended several times subsequently. The 1984 amendments set deadlines for enforc- ing the regulations. They also placed restrictions on disposal of wastes on andand forced tighter regulation of hazardous wastes Ineffect, Congress gave EPA the authority to control hazardous wastes from their generation to their ultimate disposal Congress also sought to encourage the recycling of recoverable material. The RCra included the statements that Millions oftons of recoverable material which could be used are needlessly buried each year Methods are available to separate usable materials from solid waste The recovery and conservation of such materials can reduce the dependence of the United States on foreign resources and reduce the deficit in its balance of payments Principally, however, Congress aimed at the environment and health Disposal of solid waste and hazardous waste in or on the land without careful planning and management can present a danger to human health and the environment As a result of the Clean Air Act. the Water Pollution Control Act, and other federal and state laws respecting public health and the environment, greater amounts of solid waste in the form of sludge and other pollution treatment residues have been created. Similarly, inadequate and environmen tally unsound practices for the disposal or use of solid waste have created increased amounts of air and water pollution and other problems for the environment and health Open dumping is particularly harmful to health since it can contaminate drinking water from underground and surface supplies and pollutes the air and land
640 Fermentation and Biochemical Engineering Handbook 2.3 Solid Waste Resource Conservation and Recovery Act (RCRA) (Solid Waste Disposal Act) was originally enacted by Congress in 1976 and amended several times subsequently. The 1984 amendments set deadlines for enforcing the regulations. They also placed restrictions on disposal of wastes on land and forced tighter regulation of hazardous wastes. In effect, Congress gave EPA the authority to control hazardous wastes from their generation to their ultimate disposal. Congress also sought to encourage the recycling of recoverable material. The RCRA included the statements that: Millions oftons of recoverablematerial which could be used are needlessly buried each year. Methods are available to separate usable materials from solid waste. The recovery and conservation of such materials can reduce the dependence ofthe United States on foreign resources and reduce the deficit in its balance of payments. Principally, however, Congress aimed at the environment and Disposal of solid waste and hazardous waste in or on the land without carehl planning and management can present a danger to human health and the environment. As aresult ofthe Clean Air Act, the Water Pollution Control Act, and other federal and state laws respecting public health and the environment, greater amounts of solid waste, in the form of sludge and other pollution treatment residues, have been created. Similarly, inadequate and environmentally unsound practices for the disposal or use of solid waste have created increased amounts of air and water pollution and other problems for the environment and health. Open dumping is particularly harmful to health since it can contaminate drinking water from underground and surface supplies and pollutes the air and land. health:
Environmental Concerns 641 Alternatives to existing methods of land disposal must be developed, since many of the cities in the United States will be running out of suitable solid waste disposal sites within five years, unless immediate action is taken. Objectives of the Act are to promote the protection of health and the environment and to conserve valuable material and energy resources by providing technical and financial support t development of solid waste management plans:Cs2 state and local governments and interstate agencies for the resource recovery and resource conservation systems Furthermore the act proposed to prohibit future open dumping on the land and required the conversion of existing open dumps to facilities which do not pose a danger to the environment or health. The act requires that hazardous waste be properly managed, thereby reducing the need for corrective action at a future date. An important consideration of rCra was that it required the promulgation of guidelines for solid waste collection, ransport, separation, recovery, and disposal practices and systems The Act set up specific procedures forestablishing standards. Enforce ment of job safety and health standards were also written into the Act 2.4 Occupational Safety and Health Act (OSHA) In 1970, Congress enacted the Occupational Safety and Health Act, which requires employers to provide safe and healthful working conditions for their employees. It authorized the Secretary of Labor to set mandatory occupational safety and health standards to protect employees As a result, the Occupational Safety and Health Review Commission was created to review the enforcement actions taken by osha. The National Institute for Occupational Safety and Health(NIOSH) was set up to research work place safety and health and to recommend standards to OSHA for controlling exposure to harmful and toxic substances The OSHA act of 1970 is comprehensive in scope and covers enforce- ment of standards, penalties, research activities, state programs, financial assistance, employees duties and rights, and OSHAs effect on other The Hazardous Waste Operations and Emergency Response Stan (HAZWOPER; 29 CFR 1910. 120) was issued by OSHA in March 1990 These regulations serve as a guide to a safety and health plan for hazardous waste operations
Environmental Concerns 641 Alternatives to existing methods of land disposal must be developed, since many of the cities in the United States will be running out of suitable solid waste disposal sites within five years, unless immediate action is taken. Objectives of the Act are to promote the protection of health and the environment and to conserve valuable material and energy resources by providing technical and financial support to state and local governments and interstate agencies for the development of solid waste management plans, including resource recovery and resource conservation systems. Furthermore the act proposed to prohibit future open dumping on the land and required the conversion of existing open dumps to facilities which do not pose a danger to the environment or health. The Act requires that hazardous waste be properly managed, thereby reducing the need for corrective action at a future date. An important consideration of RCRA was that it required the promulgation of guidelines for solid waste collection, transport, separation, recovery, and disposal practices and systems. The Act set up specific procedures for establishing standards. Enforcement of job safety and health standards were also written into the Act. 2.4 Occupational Safety and Health Act (OSHA) In 1970, Congress enacted the Occupational Safety and Health Act, which requires employers to provide safe and healthful working conditions for their employees. It authorized the Secretary of Labor to set mandatory occupational safety and health standards to protect employees. As a result, the Occupational Safety and Health Review Commission was created to review the enforcement actions taken by OSHA. The National Institute for Occupational Safety and Health (NIOSH) was set up to research work place safety and health and to recommend standards to OSHA for controlling exposure to harmful and toxic substances. The OSHA act of 1970 is comprehensive in scope and covers enforcement of standards, penalties, research activities, state programs, financial assistance, employees duties and rights, and OSHA’s effect on other laws. The Hazardous Waste Operations and Emergency Response Standard (HAZWOPER; 29 CFR 1910.120) was issued by OSHA in March 1990. These regulations serve as a guide to a safety and health plan for hazardous waste operations
642 Fermentation and Biochemical Engineering Handbook The HAZWOPER regulations includes the following RCRA Corrective Actions Clean up operations for uncontrolled hazardous waste sites luding voluntary operations, and routine operations Emergency responses where there is a release of hazardous substances or a potential release of hazardous substances The formulation of safety and health plans for hazardous waste operations, which include the following a preliminary site characterization analysis and hazard as signment before entering a site known to be contaminated A site specific safety and health program to control safety and health hazards a training program for all employees and contractors em ployed on the site who may be involved in hazardous waste A medical surveillance program Proper work practices, including appropriate personnel prc A site control system to prevent contamination of personnel and equipment A monitoring program to establish the appropriate levels of personnel protective equipment Decontamination procedures before entering a site Observation of applicable regulations issued by the Depart ment of Transportation, Environmental Protection Agency and the Occupational Safety and Health Act, in handling, labelling, moving and disposing of containers containing An emergency response plan for emergencies which may occur on site The preliminary site plan characteristic analysis and hazard assess- ment should be performed by an experienced and trained technician before entering the site. a more detailed site evaluation and analysis must be done to establish the necessary engineering controls and personnel protectiv equipment. All potential hazards must be identified and evaluated and an air
642 Fermentation and Biochemical Engineering Handbook The HAZWOPER regulations includes the following: RCRA Corrective Actions Clean up operations for uncontrolled hazardous waste sites, including voluntary operations, and routine operations Emergency responses where there is a release of hazardous substances or a potential release of hazardous substances exists The formulation of safety and health plans for hazardous waste A preliminary site characterization analysis and hazard assignment before entering a site known to be contaminated A site specific safety and health program to control safety and health hazards A training program for all employees and contractors employed on the site who may be involved in hazardous waste activities operations, which include the following: A medical surveillance program Proper work practices, including appropriate personnel A site control system to prevent contamination of personnel A monitoring program to establish the appropriate levels of Decontamination procedures before entering a site Observation of applicable regulations issued by the Department of Transportation, Environmental Protection Agency, and the Occupational Safety and Health Act, in handling, labelling, moving and disposing of containers containing contaminated material An emergency response plan for emergencies which may occur on site The preliminary site plan characteristic analysis and hazard assessment should be performed by an experienced and trained technician before entering the site. A more detailed site evaluation and analysis must be done to establish the necessary engineering controls and personnel protective equipment. All potential hazards must be identified and evaluated and an air protective equipment. and equipment personnel protective equipment
Environmental Concerns 643 monitoring programmust be set up to ascertain that it is safe for work to beg and proceed. In summary, the hazards must be identified, a health risk assessment performed, a medical surveillance program instituted, potential sources of fire and explosion identified, and other possible risks and hazards evaluated. Site specific safety and health rules must be set up, distributed and posted. Such a plan should include the applicable items from the following list. Workers at the site must be informed of the potential hazards and must be cognizant of the site specific safety and health plan Safety and Health plan Safety and Health Procedures Training Requirements Hazards Identification Personnel Protective Equipment Hazardous and Toxic Materials On Site Medical Surveillance Hospital Location rgency Response Personnel 2.5 Environmental Auditing Environmental auditing can cover a wide range of objectives. The approach can focus on how well a manufacturing facility is complying with the various environmental regulations, such as the Clean Air Act Amend- ments(CAAA), the Clean Water Act(CWA), the Resource Conservation and Recovery Act(RCra), Title Illof the Superfund Amendments and Reautho- rization Act(SARA), the Comprehensive Environmental Response, Com- pensation and Liability Act(CERCLA), the Toxic Substances Control Act TSCA), various aspects of the Occupational Safety and Health Act(OSHA) d can also cover property acquisition. It can also cover the various State regulations, for instance, in New Jersey an environmental audit can cover the Toxic Catastrophe Prevention Act(TCPA), the Spill Act, and the state
Environmental Concerns 643 monitoring program must be set up to ascertain that it is safe for work to begin and proceed. In summary, the hazards must be identified, a health risk assessment performed, a medical surveillance program instituted, potential sources of fire and explosion identified, and other possible risks and hazards evaluated. Site specific safety and health rules must be set up, distributed and posted. Such a plan should include the applicable items from the following list. Workers at the site must be informed of the potential hazards and must be cognizant of the site specific safety and health plan. Safe@ and Health Plan: Safety and Health Procedures Personnel Responsibilities Decontamination Procedures Required Monitoring Training Requirements Hazards Identification Personnel Protective Equipment Emergency Procedures Hazardous and Toxic Materials On Site Medical Surveillance Hospital Location Emergency Response Personnel 2.5 Environmental Auditing Environmental auditing can cover a wide range of objectives. The approach can focus on how well a manufacturing facility is complying with the various environmental regulations, such as the Clean Air Act Amendments (CAAA), the Clean Water Act (CWA), the Resource Conservation and Recovery Act (RCRA), Title I11 of the Supehnd Amendments and Reauthorization Act (SARA), the Comprehensive Environmental Response, Compensation and Liability Act (CERCLA), the Toxic Substances Control Act (TSCA), various aspects ofthe Occupational Safety andHealth Act (OSHA), and can also cover property acquisition. It can also cover the various State regulations, for instance, in New Jersey an environmental audit can cover the Toxic Catastrophe Prevention Act (TCPA), the Spill Act, and the State
644 Fermentation and Biochemical Engineering Handbook Permit Compliance. If desired, it can also cover waste minimization and pollution prevention The environmental audit offers a comprehensive assessment of facilitys compliance with applicable federal, state and local regulations. It also can identify problems before the local or state regulator can be made aware of them and allows time to correct the inadequacies Other advantages of the environmental audit is to allow time to properly assess the problem, plan its solution and allow for funding the capital cost required. There are potential problems in having an environmental audi performed. Theresults ofrecent court decisions indicate that theenvironmen- tal audit results may not beable to bekept in confidence and furthermore, they may be used as evidence of noncompliance in civil or criminal court actions It is conceivable that an audit can increase the potential liabilities. Conse- quently, management should be prepared to commit to satisfy any negative findings before the audit is undertaken The Department of Justice has developed guidelines for compliance and reporting that will be taken into consideration before assessing penalties for environmental regulations. Consequently, the scope and purpose of the audit should be fully understood and agreed to by both management and the consultant prior to undertaking the audit, and questions such as who does the consultant report, who will be given copies of the environmental audit, who will be in charge of document control, who should meet with the consultant, etc. should be decided Audit--Environmental auditing consultants have developed forms for collecting/developing information on various aspects of the site. The more important of these will include the following Site information data Types of adjacent land use · Primary site use Buildings on site, number and size or manufacturing on site ates Waste materials disposal Liquid
644 Fermentation and Biochemical Engineering Handbook Permit Compliance. If desired, it can also cover waste minimization and pollution prevention. The environmental audit offers a comprehensive assessment of a facility’s compliance with applicable federal, state and local regulations. It also can identify problems before the local or state regulator can be made aware of them and allows time to correct the inadequacies. Other advantages of the environmental audit is to allow time to properly assess the problem, plan its solution and allow for funding the capital cost required. There are potential problems in having an environmental audit performed. The results of recent court decisions indicate that the environmental audit results may not be able to be kept in confidence and furthermore, they may be used as evidence of noncompliance in civil or criminal court actions. It is conceivable that an audit can increase the potential liabilities. Consequently, management should be prepared to commit to satisfy any negative findings before the audit is undertaken. The Department of Justice has developed guidelines for compliance and reporting that will be taken into consideration before assessing penalties for environmental regulations. Consequently, the scope and purpose of the audit should be filly understood and agreed to by both management and the consultant prior to undertaking the audit, and questions such as who does the consultant report, who will be given copies of the environmental audit, who will be in charge of document control, who should meet with the consultant, etc., should be decided. Audit-Environmental auditing consultants have developed forms for collectingldeveloping information on various aspects of the site. The more important of these will include the following: Site information data Types of adjacent land use Primary site use Site configuration Buildings on site, number and size For manufacturing on site: - Products - Intermediates - Waste materials disposal Solid Liquid Gaseous
