Not Quite ISO 14001, But... The operation produces a special waste

[Luke Hannant]

Well this is not quite an ISO 14001 question, although I do need to resolve the issue inorder to continue down the road to certification.

I understand that in this particular situation, I am governed by UK legislation, for which many of you might not be familiar, but in any case, feel free to advise, if even on the legislative requirements of your country.

---------------------------- The Situation ----------------------------

The company I am working on behalf of, currently runs a cleaning operation about once a month, resulting in 8000 litres of 2% caustic cleaning solution. Before discharging to effluent, this solution is neutralised with HCL to a pH of 7. This operation has been undertaken for the last five years, without any notification to the Environment Agency.

---------------------------- The Question ----------------------------

SO what's the problem? Well what I cant decide is whether this operation is a normal process operation, and discharge to effluent, subject to their consent to discharge specifications.

OR

Since the operation produces a special waste (the caustic solution; or is it technically a waste?????), does it require

A) A waste licencing permit to neutralise the special waste?
B) A special waste contractor to remove the waste?

------------------------------------------------------------------------------

I know the correct solution to this problem is simply to approach the Environment Agency and ask. I am personally quite up for this, although my direct boss, would prefer going to the environment agency when certified, as he is worried about possiable tighting of effluent specifications on other parameters (i.e suspended solids, BOD, etc.), and afraid I may be opening a can of worms!!!

So, what do think???

 

[Luke Hannant]

bit of a hard question to answer i admit, but any thoughts are appreciated

 

[energy]

From over here

Not knowing about the UK, all I can tell you is what we do here.

Once a month, we discharge approx. 90,000 to 100,000 US gallons of waste water treated with HCL and caustic (potassium hydroxide) to a ph limit of 6.0 to 9.0. The State Department of Environmental Protection requires a full blown discharge permit with maximum allowable monthly flows and monthly reporting requirements. That required a complete operational system designed and approved by their Engineers. Spill Prevention Controls, Public Notification of the Plan to discharge to the sewers of the State and Inspection of the facility by the DEP. There are also lab analysis performed on a grab sample monthly that looks at the amount of zinc, lead, iron, copper and total suspended solids. These are reported to the DEP, also. If you can afford to haul away your 8000 liters, you would be better off. You have to make sure that that they are a reputable company with the required permits to treat your waste. You are responsible. It's really a matter of expense.
Our system has redundancy and failsafes built in due to the liability in the event of a spill that would reach outside the facility and enter the water ways. Our containment pits for the chemical storage tanks are designed to contain the contents of the tank, plus 10%. But, it was cheaper to discharge (legally) than trying to haul away the amount of waste water we generate. We are permitted to a maximum 135,000 US gallons per day. We never even get close to that. We average approx. 9,000 gals per day, based on 10 to 11 operating days per month. Your waste appears that it would require two tanker trucks per month. Look at that cost. You also have the potential of a HCL spill that I have to believe is regulated. It's not only dangerous to life, it's a no no in the environment, so think about safe storage and transfer of the acid to your plant, too. My guess is that the hauling may be the most cost effective way to go, for that amount of waste. JMHO

 

[M Greenaway]

If your boss is serious about environmental management how can he refuse you asking the environment agency ? How else will you know, I believe it is also a requirement of this standard to maintain a list of current legislation which, I guess, someone should be clued up on - surely this person would know.

 

[energy]

Homework first

M Greenaway said:

If your boss is serious about environmental management how can he refuse you asking the environment agency ? How else will you know, I believe it is also a requirement of this standard to maintain a list of current legislation which, I guess, someone should be clued up on - surely this person would know.

M.

Over here, we have access to a dozen types of permit applications that you can scrutinize prior to contacting the Department of Environmental Protection. You select the one that applies to you. Anytime you dump to a sewer treatment plant or body of water (ground water), regulation is required. 2% caustic is mild. Ours is a combination of 50% HCL and 30% Caustic. The % doesn't matter. It's part of a industrial process. For example, we also have a discharge permit for Hydrostatic Testing Wastewater Discharge. It's part of a process used to test the integrity of our system piping and pressure vessels. Because we filter the water from the city with a 5 micron filter and our piping is PVC and the tanks are lined, the water is cleaner (that we discharge) than we take in. Still, the permit ensures that what you are discharging is authorized by the DEP and requires occasional monitoring with the result submitted to the DEP. There is no doubt, in my mind, the authorities should eventually be notified.

But the boss's concern is valid. You do not let them into your facility until you have done your research and know where you are going. It would be like calling in a Registrar with no Q system in place. They will dig into every little thing.
Luke has some work to do before notifying the agency. Otherwise, they will nickel-dime you to death. They are worse than Auditors!

 

[Randy]

Going to the agency and asking for information will not tighten the standards as your boss thinks. The standards are already engraved in stone. If your boss doesn't want to check with the regulatory agency, will he allow you to go to other outside resources? Do you have a corporate environmental guru or attorney (you guys would call him a barrister or solicitor I think)?

You may already be on nasty ground if you haven't notified the gov't of discharges and there is a regulatory requirement to do so regardless of the composition of the discharge. A meeting with your "designated inmate" over the issue is advisable.

 

[Luke Hannant]

Dear All,

Many thanks for your response. Since posting my orginal question I have since learned that liquid process waste is EXCLUDED from UK waste management licensing (a contractor is required to remove it from site), IF notification from the Environment Agency is obtained for a consent to discharge.

Which the 'Desiginated Inmate' is planning to do once we either get accreditation, or sort out some other problems before calling the agency to let them run.

------------------ Now for a slighty different question... ---------------

In the event of a chemical spillage, can the spill be hosed down to effluent (provided of course it will not affect pH specifications, etc.)????

OR

Would this spill immediately be considered a waste, and as a result not be allowed to be discarged to effluent unless prior authorization (for every chemical????) is obtained????

......which leads me to yet another question (dont you love inqusitive minds) what do you guys do about chemical spillages??? Do you instruct the ABSOLUTE usage of spill kits, or do you instruct that some chemicals may get washed down to effluent (depending on volume, hazard, etc.)???? If so was it necessary to seek any kind of Environment Agency Authorization????

 

[Randy]

Here in the good 'ol US of A waste is defined as "that material which can no longer be used for its original intended purpose, or has been designated as a hazardous waste in one of 4 ways".

Most likely you have a waste of hazardous material there.

 

[energy]

Different Regs

Luke,

It is difficult to compare your environmental regulations with what we have here. But, if you are “exempt” from reporting your wastewater discharge, you would be “exempt” from the requirement to have a Spill Prevention Plan. But, good practices would address the potential of a spill and the hazards associated with it. We have to have a Spill Prevention Plan in order to obtain a Wastewater Discharge Permit. The main concern is a spill that can be released into the environment. In our particular situation, the greatest potential for a spill is when we are taking on acid or caustic from a tanker truck. 3600 gallons of caustic or 4600 gallons of HCL, each time. We have spill kits, emergency escape respirators, neutralizing agents that are spread on the spill, protective clothing, etc..It is a requirement. Our facility has several floor drains (sumps) that will capture any spill and pump it into our neutralization tanks. We barricade the chemical truck with absorbent socks, inside the facility, to prevent any accidental spill from leaving the building. If that were to happen, there are Local, State and Federal reporting requirements. The phone numbers are posted for these agencies. As long as the spill is contained inside, they do not have to be notified. (unless somebody is injured). The drivers are required to read our plan, wear the required protective clothing or we don’t do business with them. We also have to submit a water conservation plan to the state along with site maps, line drawings of our system and many other attachments. The permit actually fills a 2” binder.

Having rambled a bit, most discharges of 5000 gallons a day do not require a permit, unless it contains a substance identified as an acute hazard, (like chromium, mercury) or any hazardous material listed in a federal register. There are hundreds of them.

It sounds like you already have your answer to your original post. I would recommend you have a spill prevention/control plan as a matter of safety. As a minimum, train your people how to act in the event of a spill and clean up and disposal methods. Our neutralization powders, once used, are considered a "Hazardous Waste" as Randy has pointed out. Before we would use those agents, for a minor spill we would hose down and push the spill towards our sump pumps for nuetralization in our system. For a major spill the agents would be used if there was no other way to keep the contents of the spill in the building.

Finally, it’s a pleasure to talk to an English Gentleman for a change.

 

[Luke Hannant]

Well I say Old Chaps, jolly good thread, very informative.

It seems that UK and USA regulations are quite similiar, at least in terms of the hazardous waste definition, although not needing a license to discharge up to 5000 gals/day (provided it dosent contain certain substances), is something else.

I think I might have confused you, with the waste management license V consent to discharge. It turns out that we are not in anyway excluded from a consent to discharge (weve had one since 1963 anyway), although I was completely barking up the wrong tree when i thought i needed a waste management license just because the particluar volume of process waste was "Hazardous" (spent caustic).

So just to be sure I understand the chemical spillages, basically all spillages must be absorbed, and treated as hazardous waste,
unless I can get the Environment Agency to accept certain chemicals to be washed to effluent (provided we do not affect our consent to discharge specifications).

---------------------------- yet another question!! --------------------

Just out of curosity, what is the best medium for absorbing spillages. Sand springs to mind as being cheap and cheerfull. Is it suitable for oil and chemicals??? I obviosly need to check with my waste carrier that they can take it and treat it, but i was just wondering how efficient it is at absorbing, say oil spillages in practice.