ENVIRONMENTAL ENGINEERING:COMPLYING WITH ENVIRONMENTAL LAWS

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COMPLYING WITH ENVIRONMENTAL LAWS
Overview

In the early 1970s, compliance with environmental regulations by most industrial entities was not a top priority. Indeed, some major corporations brought lawsuits and attempted to lessen the impact of the regulations. However, in the intervening years, continued research on the human health effects of water and air pollution has resulted in a heightened awareness of their deleterious impact on the human system. As a result, compliance with environmental regulations is now the norm rather than the exception for the industrial sector. An example of this is the tightening of the ambient air quality standards for particulates over the years. In the early years, dustfall buckets (measured particulates >40 I-m diameter) and total suspended particulates (measured particulates <40 I-m diameter) were targeted by the NAAQS. Human health research indicated that finer particulates (10 I-m and less), which penetrate deeper into the human respiratory system, are more harmful than the larger particulate matter. Fine particulate matter has a much greater surface area-to-volume ratio relative to larger particulate matter, which allows the fine particulate matter to adsorb and absorb hazardous volatile substances and carry them deep into the human lung. This ‘‘piggyback’’ effect of fine particulate matter with hazardous air pollutants has resulted in the diameter of the particulate standard being reduced over the years. The current NAAQS standard for fine particulate matter is PM-10, which means particles less than or equal to 10 I-m. But a PM-2.5 NAAQS standard has been proposed by the EPA and awaits promulgation at the time of writing.

Permits
Air Permits

One of the provisions of the 1970 Clean Air Act initiated the requirement for air pollution sources to obtain a permit for construction of the source and a permit to operate it. The construction permit application must be completed prior to the initiation of construction of any air pollution source. Failure to do so could result in a $25,000 per day fine. In some states, initiation of construction was interpreted as issuance of a purchase order for a piece of equipment; in others, groundbreaking for the new construction. Therefore, to ensure compliance with the air permit requirement, this author suggests that completion of the air permit be given first priority in any project involving air emissions into the atmosphere. The best practice is to have the state-approved permit in hand before beginning construction. Most states have their permit forms on the Internet, and a hard copy can be downloaded. Alternatively, the permit forms can be filled out electronically and submitted.

Recently, many states have offered the option of allowing an air pollution source to begin con- struction prior to obtaining the approved construction permit. However, the required paperwork is not trivial, and it may still be easier to fill out the permit form unless extenuating circumstances demand that construction begin before the approved permit is in hand. The caveat is the state could disapprove the construction (which the company has already begun) if, after reviewing the permit application, the state disagrees with the engineering approach taken to control the air pollution.

Water Permits

Any person discharging a pollutant from a point source must have a National Pollution Discharge Elimination System (NPDES) permit. This applies to persons discharging both to a public treatment works or directly to a receiving water body. These permits will limit the type of pollutants that can be discharged and state the type of monitoring and reporting requirements and other provisions to prevent damage to the receiving body or treatment facility. In most states, the state department of environmental quality is responsible for issuing permits. In states that have not received approval to issue NPDES permits, you should contact the regional EPA office.

Wastewater permits that regulate the discharge of many pollutants can be broken down into the general categories of conventional, toxic, and nonconventional. Conventional pollutants are those contained in typical sanitary waste such as human waste, sink disposal waste, and bathwater. Con- ventional wastes include fecal coliform and oil and grease. Fecal coliform is present in the digestive tracts of mammals, and its presence is commonly used as a surrogate to detect the presence of pathogenic organisms. Oils and greases such as waxes and hydrocarbons can produce sludges that are difficult and thus costly to treat. Toxic pollutants are typically subdivided into organics and metals. Organic toxins include herbicides, pesticides, polychlorinated biphenyls, and dioxins. Nonconven- tional pollutants include nutrients such as phosphorus and nitrogen, both of which can contribute to algal blooms in receiving waters.

The EPA maintains many databases of environmental regulatory data. Among these is the Permit Compliance System (PCS) database http: / / www.epa.gov / enviro / html / pcs / pcs query java.html. This database provides many of the details governing a facility’s wastewater discharges. Specific limitations typically depend on the classification and flow of the stream to which a facility is dis- charging. Surface waters are classified as to their intended use (recreation, water supply, fishing, etc.), and then the relevant conditions to support those uses must be maintained. Discharge limitations are then set so that pollution will not exceed these criteria.

Total suspended solids, pH, temperature, flow, and oils and grease are typical measures that must be reported. In the case of a secondary sewage treatment, the minimum standards for BOD5, sus- pended solids, and pH over a 30-day averaging period are 30 mg / L, 30 mg / L, and 6–9 pH, respec- tively. In practice, these limits will be more stringent, and in many cases there will be separate conditions for summer and winter conditions as well as case-by-case limitations.

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