Waste Management

In this article, a number of references are made to laws and procedures that have been formulated in the United States with respect to waste management. An engineer handling waste-management problems in another country would well be advised to know the specific laws and regulations of that country. Nevertheless, the treatment given here is believed to be useful as a general guide.

Multimedia Approach to Environmental Regulations in the United States Among the most complex problems to be faced by industry during the 1990s is the proper control and use of the natural environment. In the 1970s the engineering profession became acutely aware of its responsibility to society, particularly for the protection of public health and welfare. The decade saw the formation and rapid growth of the U.S. Environmental Protection Agency (EPA) and the passage of federal and state laws governing virtually every aspect of the environment. The end of the decade, however, brought a realization that only the more simplistic problems had been addressed. A limited number of large sources had removed substantial percentages of a few readily definable air pollutants from their emissions. The incremental costs to improve the removal percentages would be significant and would involve increasing numbers of smaller sources, and the health hazards of a host of additional toxic pollutants remained to be quantified and control techniques developed.

Moreover, in the 1970s, air, water, and waste were treated as separate problem areas to be governed by their own statutes and regulations. Toward the latter part of the decade, however, it became obvious that environmental problems were closely interwoven and should be treated in concert. The traditional type of regulation—command and control—had severely restricted compliance options.

The 1980s began with EPA efforts redirected to take advantage of the case-specific knowledge, technical expertise, and imagination of those being regulated. Providing plant engineers with an incentive to find more efficient ways of abating pollution would greatly stimulate innovation in control technology. This is a principal objective, for example, of EPA's "controlled trading" air pollution program, established in the Offsets Policy Interpretative Ruling issued by the EPA in 1976, with statutory foundation given by the Clean Air Act Amendments of 1977. The Clean Air Act Amendments of 1990 expanded the program even more to the control of sulfur oxides under Title IV. In effect, a commodities market on "clean air" was developed.

The rapidly expanding body of federal regulation presents an awesome challenge to traditional practices of corporate decision-making, management, and long-range planning. Those responsible for new plants must take stock of the emerging requirements and construct a fresh approach.

The full impact of the Clean Air Act Amendments of 1990, the Clean Water Act, the Safe Drinking Water Act, the Resource Conservation and Recovery Act, the Comprehensive Environmental Responsibility, Compensation and Liability (Superfund) Act, and the Toxic Substances Control Act is still not generally appreciated. The combination of all these requirements, sometimes imposing conflicting demands or establishing differing time schedules, makes the task of obtaining all regulatory approvals extremely complex.

One of the dominant impacts of environmental regulations is that the lead time required for the planning and construction of new plants is substantially increased. When new plants generate major environmental complexities, the implications can be profound. Of course, the exact extent of additions to lead time will vary widely from one case to another, depending on which permit requirements apply and on what difficulties are encountered. For major expansions in any field of heavy industry, however, the delay resulting from federal requirements could conceivably add 2 to 3 years to total lead time. Moreover, there is always the possibility that regulatory approval will be denied. So, contingency plans for fulfilling production needs must be developed.

Any company planning a major expansion must concentrate on environmental factors from the outset. Since many environmental approvals require a public hearing, the views of local elected officials and the com-munity at large are extremely important. To an unprecedented degree, the political acceptability of a project can now be crucial.

Plant Strategies At the plant level, a number of things can be done to minimize the impact of environmental quality requirements.

These include:

1. Maintaining an accurate source-emission inventory
2. Continually evaluating process operations to identify potential modifications that might reduce or eliminate environmental impacts
3. Ensuring that good housekeeping and strong preventive maintenance programs exist and are followed
4. Investigating available and emerging pollution-control technologies
5. Keeping well informed of the regulations and the directions in which they are moving
6. Working closely with the appropriate regulatory agencies and maintaining open communications to discuss the effects that new regulations may have
7. Keeping the public informed through a good public-relations program.
   

It is unrealistic to expect that at any point in the fore seeable future Congress will reverse direction, reduce the effect of regulatory controls, or reestablish the preexisting legal situation in which private companies are free to construct major industrial facilities with little or no restraint by federal regulation.