12 CHAPTER II LITERATURE REVIEW 2.1 Waste Management Strategy The production of waste throughout Malaysia and the rest of the world is increasing at a rapid pace. As countries become more industrialized and the wealth of the citizens increases, there is an increase demand for goods and services. Corporation looking to increase sales and therefore profits often feed this craving with advertising for their products. The results is an ever-spiraling demand for goods resulting in more and more wastes (Goh, Kiam Seng, 1990, Kreith, F., 1994 and Bishop, P.L., 2000). The environmental impacts of this have been all too evident: despoiled air and water, hazardous waste dumps, rapidly depleted resources and other environmental problems. As the types and amounts of wastes generated very considerably community to community and countries, the good management system is required to determine the most effective means for managing the wastes. As such waste management decisions depend heavily on waste generation and populations together with other local factors as well, such as availability of waste treatment facilities, waste generators particularly industries, public attitudes and behaviours, applicable regulations and financial constraints (Kreith, F., 1994). Attempts to eliminate the problem through end-of-pipe treatment of wastes after they are produced have helped (Peavy, H.S; et. al., 1985), but the problems are too large for this to be a solution. What is needed is a major overhaul of the way we manage wastes and the environment (Markandya Anil and Dale, N., 2001). The 13 recent and proposed industrial waste management practices are as shown in Figure 2.1. In the past, industry showed little concern for the types or amounts of waste generated and the public had little knowledge of the impacts of these wastes on the environment. These wastes were usually just discharged into the air or nearby river, or they were dumped or buried on land as shown in Figure 2.1. Disposed materials that we thought to be gone forever through dilution in air or water or by burial in ground may have some adverse effects on human health and the environment. As these impacts became known, industries began to treat their wastes to remove the most egregious one. Eventually, some industries began recycling and reusing some of their waste materials as shown in the current pollution prevention practices. Other industries, recognizing the product and pollution prevention are intimately related, began marketing the environmental “greenness” of their products as a way to attract new customer (Freeman, H.M, (1995), Ortolano L., (1997), Voorhees, J. and Wollner, R.A. (1998) and Bishop, P.L., (2000)). This was the beginning of the pollution prevention era. What is needed is a goal of “zero pollution” of which most process waste production is eliminated through process changes, as much remaining waste as possible is recycled, reused or recovered at either facility of origin or another facility (Nemerow, N. L., 1995) as shown in Figure 2.1. The little residue remaining after recycling and reuse can be treated and disposed of in environmentally acceptable manner. 2.2 Regulations Motivate Pollution Prevention The Government of Malaysia has set out its position clearly in respect of a strategy for sustainable development in the Sixth Malaysia Plan 1991-1995 (Sham Sani, 1993 and Sixth Malaysia Plan,1991-1995). The Sixth Malaysia Plan contains a clear policy statement regarding the need to fully integrate environmental concerns into the overall planning and development process. The attention is drawn to the need to maintain a balance between the competing demands of growth and sustainable development. The need for more effective environmental management is 14 Past Industrial Practices Products Raw Materials Process Energy Waste Environment Recent Industrial Practices Products Raw Materials Energy Process Treatment Waste Residual waste to environment Current Pollution Prevention Practices Raw Materials Energy Products Process Residuals Recycles Recycle, Reuse, Recovery Waste Treatment Residual waste to environment Secondary Products Ideal Future Industrial Practices Raw Materials Energy Products Process Residuals Recycle, Reuse, Recovery Recycles Secondary Products Residuals Reprocess Reprocess Recycle, Reuse, Recovery Recycles Source: Bishop, P.L., 2000. Figure 2.1: Recent and Proposed Industrial Waste Management Practices 15 stressed, as is the need of careful management of natural resources as a further basis for sustainable development. It is the further aim of the Government to render all scheduled waste harmless at the site of origin or at specially designed treatment plants. Disposal of nondegradable waste and treatment residues must take place in properly constructed secure landfill. Further, the National Policy on the Environment was approved by the Government on the 2nd October 2002 and formally launched on 14th November 2002 (Hajah Rosnani Ibarahim, 2002). The National policy on the Environment is based on eight principles that harmonize economic development goals with environmental imperatives, under the topics: stewardship of the environment; sustainable use for natural resources; integrated decision – making; role of private sector; commitment and accountability; and active participation in the international community. The linkages exist between government regulations and corporate decisions to adopt pollution prevention. Some companies see pollution prevention as a strategy for complying with regulations in a cost-effective manner. Other companies are proactive and view pollution prevention as a means to cut costs and risks by reducing pollution below levels required by regulations. Some companies have even gone as far as adopting the goal of eliminating all waste discharge (Ortolano, L., 1997). As a comparison Table 2.1 and Table 2.2 list some regulatory programmes that are linked to the surge in corporate interest in pollution prevention within the United States and Malaysia. Two items on the list that are predominant are: liability for future cleanup costs and cost of compliance with regulations issued. According to Freeman (1995), the complex regulatory maze created by government is not the only one faced by industries. Firms also face stringent requirements under federal air and water pollution control laws as well as penalties for violating environmental laws include both substantial fines and the possibility of imprisonment for corporate staff. Collectively, these regulations and penalties for non-compliance have motivated many companies to embrace waste source reduction and recycling as a way of avoiding the paperwork, time and expense to satisfy waste management regulations (Freeman, H.M., 1995; and Norhayati Mohd. Yusof, 2001). In addition, waste source reduction and recycling provides a way for companies to buffer themselves against 16 the uncertainties associated with satisfying regulations that are subject to continual modification and reinterpretation by environmental agencies and the courts. Table 2.1: Malaysia: Examples of Federal Laws and Programmes Encouraging Source Reduction in Relation to Toxic and Hazardous Waste Federal laws, Environmental Quality Act (EQA), 1974 concerning air and water pollution control and hazardous waste management. The Environmental Quality (Clean Air) Regulations, 1978. The Environmental Quality (Sewage and Industrial Effluent) Regulations, 1979. The Environmental Quality (Scheduled Waste) Regulations 1989. Malaysian Agenda for Waste Reduction (MAWAR), Department of Environment, 1996 (Environmental Management for Sustainable Development). Cleaner Production, Ministry of Science, Technology and Environment (MOSTE) and SIRIM Berhad, 2000. Table 2.2 also lists three measures passed by Congress of the United States that have fostered pollution prevention. One measure is a requirement under the programme for generators of hazardous waste to certify (on shipping manifests) that a program is in place “to reduce the volume and toxicity of waste generated” where economically practicable. According to Ortolano, L., 1997, a second regulatory measure that has led firms to prevent pollution is the Toxic Release Inventory (TRI), which Environmental Protection Agency (EPA) issues annually under the Emergency Planning and Company Right to Know Act (EPCRA) of 1986. Each year, firms releasing more than minimal quantities of or more of hundreds of toxic chemicals listed by Environmental Protection Agency (EPA) must report those releases to EPA. The annual Toxic Release Inventory is made available as a written report and in digital form (on a CD-ROM), and this has provided governments, interested citizens, and environmental groups with details of toxic discharges by individual companies. 17 Table 2.2: United States: Examples of Federal Laws and Programmes Encouraging Sources Reduction in Relation to Toxic and Hazardous Wastes Comprehensive Conservation Response, Compensation and Liability Act (CERCLA)’s liability provisions. Federal Laws concerning air and water pollution control and hazardous waste management. Resource Conservation and Recovery Act, 1976 (RCRA)’s requirement for certifying that waste reduction programmes are in place. Emergency Planning and Community Right to Know Act (EPCRA)’s 1986 – Toxic Release Inventory. Pollution Prevention Act, 1990. Source: Ortolano L., 1997. Soon after the first Toxic Release Inventory (TRI) was issued in 1988, environmental groups publicized information on which firms had the largest releases of toxics. The resulting adverse publicity led many companies to improve their ranking in the TRI by reducing discharges of toxics. Public pressure, which is often heightened by information on toxic releases, has been a factor leading some companies to take a pro-active stance regarding pollution prevention. The TRI can work in favor of companies, since improvements in rankings among companies listed in the TRI are a source of positive publicity and allow firms to gain the public’s confidence. Further to Ortolano, L., 1997, outlined the third federal mandate fostering Pollution Prevention Act of 1990. The act directs Environment Protection Agency (EPA) to establish a pollution prevention office, and to compile and disseminate information on techniques for waste source reduction. In addition the act requires companies to report annually to EPA, providing details of their toxic waste under EPCRA. Thus rigorous hazardous waste laws such as RCRA and CERCLA, in the United States and EQA, 1974 with the three subsidiaries of the Scheduled Waste Regulations in Malaysia; along with demanding requirements in the control of toxic 18 wastewater and air discharges, have led many companies to adopt pollution prevention as a keystone in their efforts to manage wastes. These measures are illustrated as in Table 2.3 Table 2.3: Hierarchy of Pollution Prevention Measure’s Waste source reduction. Minimize amount and harmfulness of wastes by Improving operating procedures Changing inputs Redesigning production processes Reformulating products Onsite recycling and reuse Reduce final waste discharge by processing intermediate wastes to recover materials valuable for use as process inputs or for sale to others. Off-site recycling and reuse Transport wastes off-site for processing to recover materials valuable for use as process inputs or for sale to others. End-of-pipe treatment Use chemical, physical and biological process and incineration to transform wastes into less harmful substances. Source: Ortolano, L., 1997. 2.3 Toxic and Hazardous Waste Management Toxic and hazardous waste is one of the environmental key issues of the 1980’s. (Abbou, R., 1988). Monitoring of these wastes means that the whereabouts of such wastes are known at all times; “ from cradle to grave” as shown in Figure 2.2 (Sinha, R.K., 1994 and Mariana, Md. Nor, 1998). Control of hazardous wastes can fully be achieved when adequate facilities are available. Control means that competent authorities can act rapidly to assure that the possibility for inappropriate handling of wastes or dumping are minimized. Control means also that the authorities have the power, both legally and financially, to act quickly in order to reduce danger posed to men and the environment. For adequate monitoring and control, countries need legislation on hazardous waste. In 19 the legislation, definition of ‘waste’ and ‘hazardous’ must be assured (Lindgren, G.F., 1983 and Abbou, R., 1988). Waste Generator Cradle Recovery or Treatment Facilities Disposal Facilities Grave Figure 2.2: Principle of Toxic and Hazardous Waste Management - Cradle to Grave 20 A policy of hazardous waste management is consistent with policies to control the use of toxic and dangerous substances, to conserve resources, to preserve health and to protect the environment, the main objectives of hazardous waste legislation are: The prevention of generation The promotion of re-use and recycling The reduction of emissions of final disposal; e.g. incinerator. The abatement of diffuse dispersion of hazardous wastes into the environment. Thus the essential objectives of all provisions are the protection of human health and the safeguarding of the environment (Sinha, R.K., 1994, Dupont, R.R., et.al, 2000 and Lee, Heng Keng, 2003). 2.4 Identification and Classification of Toxic and Hazardous Wastes Hazardous wastes are a category of industrial waste needing special care in handling, treatment and disposal due to the potential adverse impact resulting from the hazardous properties of the waste. In general, the basic for determining if a waste is a hazardous typically occurs in either of two ways; identification and classification as outlined by the Environment Protection Agency of the United States (EPA) and European Economic Community (EEC) (Abbou, R., 1988, and La Grega, M.D., et. al., 2001). Malaysia has also adopted a system similar to that of EPA in determining the toxic and hazardous wastes (Department of Environment, Malaysia, 2000). Firstly, identification of toxic and hazardous wastes is the procedure of determining whether a specific waste from an industrial source is scheduled waste or not. This may be done from information on it chemical composition, its properties or source of waste. Laboratory test may indicate that it exhibits one or more of the characteristics deemed to make a hazardous waste. For Malaysia, the hazardous waste must first be identified as scheduled waste. 21 Secondly, classification of scheduled waste is the procedure used to specify the type of waste. It may be a list of specific wastes compiled and classified by the government because it is known or suspected of having the potential to exhibit hazardous characteristics. These scheduled wastes are classified into different types and are given a specific waste code. As been used in other countries such as the USEPA (Lindgren. G.F., 1983 and La Grega, M.D. et.al, 2001), the underlying principle of identification and classification in Malaysia also requires at least any of the following characteristics that will make a waste hazardous. Explosively/Ignitability Waste easily ignited or exploded and thus posing a fire hazard during routine management. Corrosivity Waste is capable of injuring human tissue, and of corroding containers holding hazardous substances, enhancing the introduction of contaminants into the environment; waste that is highly acidic or alkaline. Reactivity Waste has a tendency to become chemically unstable under normal management condition; has tendency to react violently and explode. Toxicity (Human toxicological properties and toxicological Properties) Substances and preparation which, if they are inhaled or ingested or if penetrate the skin may involve serious, acute or chronic health risks and even death. Another alternative to the regulatory classification system is to classify a waste according to the following hierarchy: (i) Form or phase distribution (e.g. liquid or solid); (ii) Organic or inorganic; 22 (iii) Chemical class (e.g. Solvents or heavy metals); (iv) Hazardous constituent as it affects treatability (e.g. hexavalent chromium). This system is effective for engineering purpose as shown in Table 2.4. Table 2.4: Engineering Classification System for Hazardous Waste Major Category Characteristics Inorganic aqueous waste Liquid waste composed Primarily water but containing acids/alkalis and/or concentrated solutions of inorganic hazardous substances (e.g. heavy metals, cyanide). - Organic aqueous waste Liquid waste composed primarily of water but containing admixtures or dilute concentrations of organic hazardous substances (e.g., pesticides). - Rinse water from pesticide containers Washing of chemical reactors and formulation tanks Organic liquids Liquid waste containing admixtures or concentrated solutions of organic hazardous substances. - Spent halogenated solvents from metal degreasing and dry cleaning. Distillation residues from production of chemical intermediates Liquid wastes composed primarily of petroleum-derived oils. - Oils Examples - - - Inorganic sludges/solids Organic sludges/solids Sludges, dusts, solids and other nonliquid waste containing inorganic hazardous substances - Tars, sludges, solids and other nonliquid waste containing inorganic hazardous substances - - - Source: La Grega, M.D., et. al, 2001. Spent sulfuric acid from galvanizing Spent caustic baths from metal finishing Spent ammoniacal etchants from manufacturing electronic components Rinse water from electroplating Spent concentrates from hydrometallurgy Used lubricating oils from internal combustion engines. Used hydraulic and turbine oils from heavy equipment operations. Used cutting oils from machinery manufacture Contaminated fuel oils Wastewater treatment sludge from mercury cell process of chlorine production Emission control dust from steel manufacture and smelters Waste sand from coking operations lime sludge from coking operations Dust from deburring of chromium parts in fabricated metal industry Sludges from painting operations Tar residues from production of dyestuff intermediates Spent filter cake from production of pharmaceuticals Distillation bottom tars from production of phenols Soil contaminated with spilled solvents Slop oil emulsion solids 23 In summary, the basic procedure for identification and classification of scheduled waste in Malaysia is shown in flow chart, Figure 2.3. Obtain description of waste from producer Is description in First Schedule? Yes No Is the waste nonscheduled? Yes Consider source of waste and whether hazardous materials are used in process Determine basic properties of waste Does the waste appear to conform with the description No Yes Does the waste appear to have hazardous properties? Yes Demand an analysis Use classification provided Probably not scheduled waste Identify components and classify accordingly Source: Department of Environment, 2000. Figure 2.3: The Procedure for Identification and Classification of Scheduled Waste in Malaysia. No 24 2.5 Legislation and Policy on the Toxic and Hazardous Waste Management in Malaysia Most actions taken today to manage wastes especially toxic and hazardous wastes are done in response to legal requirement, as these wastes are potentially harmful. For this reason legislation has been introduced in the Environment Quality Act 1974 (EQA) to control the way, which they are stored, handled, treated and disposed off (Mariana Md. Nor, 1998 and Lee, Heng Keng, 2003). The Environment Quality Act 1974 (EQA) came into force on 15 April 1975 and was amended in 1976,1985 and 1996. 2.5.1 Definition of Waste Waste is defined in EQA 1974 as: “Any matter prescribe to be scheduled waste or any matter whether in a solid, semisolid or liquid form, or in the form of a gas or vapour, which is emitted, discharge or deposited in the environment in such volume, composition or manner as to cause pollution” This definition is appreciably different from that which is widely used internationally. In the European Union (EU) and many other countries, waste is defined as any material, which the holder discards or intends to discard (Lieben, P. and Huisman, J.W, 1988). The Basel Convention definition is similar but uses “dispose of” instead of “discard” (UNEP, 1998). In Malaysia, therefore a material only become waste at the point at which it is emitted, discharged or deposited and then only if it causes pollution. Could thus be argued that material which would, in most countries, be considered to be waste may not be waste if it is managed in a manner so as to cause no pollution. According to Bishop, P.L., (2000), a waste may not be necessarily have to be waste and suggested that a better definition of waste: “ A waste is a resource out of place” It is the responsibility of pollution prevention personnel to find the right place to turn the waste into a resource. 25 2.5.2 Definition of Toxic and Hazardous Waste The hazardous waste definition distinguishes between these wastes that can be safety manage at non-hazardous waste facility (i.e., a municipal landfill), and those that require management under more stringent standards (Abbou, R., 1988). A number of countries have defined “ hazardous wastes” in their respective laws (Lieben, P., and Huisman J.W., 1998). Examinations of a compilation of these definitions indicators that these are no universally accessed definition of toxic and hazardous wastes. The definitions that are use in various countries or international organization are somewhat similar, only different in term use as shown in Table 2.5. Table 2.5: Terms of Toxic and Hazardous Wastes in Selected Countries and International Organizations Term Country/Organisation Hazardous Basel Convention, United States of America, Canada, China, Organisation for Economic Cooperation and Development (OECD) Chemical Denmark, the Netherlands Special United Kingdom, Federal Republic of Germany Toxic and dangerous Italy, France, European Economic Community (EEC) Toxic Belgium Problem Finland Scheduled wastes Malaysia The primary legislation influencing the classification of scheduled waste in Malaysia is the Environment Quality Act, 1974. Section 2 of EQA 1974 has defined scheduled wastes means “any waste prescribed by the Minister in the regulations as scheduled wastes”. 26 In addition specific subsidiary has been introduced under the provisions of section 18,21 and 51 of Environmental Quality Act, 1979 in the form of three regulations specifically related to scheduled wastes namely: Environmental Quality (Scheduled Wastes) Regulations, 1989 Environmental Quality (Prescribed Premises)(Scheduled Wastes Treatment And Disposal Facilities) Order, 1989. Environmental Quality (Prescribed Premises) (Scheduled Waste Treatment And Disposal, Facilities) Regulations 1989. In addition to the scheduled wastes management, various other environment regulations are in force and apply to the toxic and hazardous wastes: Environmental Quality (Prescribed Activities) (Environmental Impact Assessment) Order 1987. 2.5.3 Custom (Prohibition of Export) Order (Amendment) (No.2) 1993;and Custom (Prohibition of Import) Order (Amendment) (No.2) 1993. Environmental Quality (Scheduled Wastes) Regulations, 1989 These regulations are generally referred to as the “Scheduled Waste Regulations” and provide the specific rules for the handling, treatment and disposal of scheduled wastes. They provide for “cradle to grave” control. The important sections are: Section 2 Interpretation- gives the definitions of term used. One of the most significant is the definition of scheduled waste, being “any waste falling within the categories of waste listed in the First Schedule” First schedule of the regulation defines 107 categories of scheduled wastes covering all except radioactive waste which are controlled by the Atomic Energy Licensing Act, 1984. Specifically excluded from the definition also are municipal waste and municipal sewers. 27 Every waste type mentioned in the First Schedule, must be considered as scheduled waste regardless of its hazardous properties. The list of waste types is divided in two parts: the first part identifies certain wastes by their composition only, whilst the second also includes a specific source in addition to composition. Part I: Scheduled wastes from non-specific sources -49 types of waste from 28 different non-specific sources. The numbering Nxxx indicates waste from non-specific sources. Part II: Scheduled wastes from specific sources -59 types of waste from 30 different specific sources. The numbering Sxxx indicates waste from specific sources. Examples of waste listed in Parts I and II of the First Schedule are given below: The complete list is available in the Schedule Waste Regulations. Part I: Scheduled waste from non specific sources 1. Mineral oil and oil contaminated waste NO11 NO12 NO13 NO14 NO15 NO16 Spent oil or grease used for lubricating industrial machines Spent hydraulic oil from machines, including plastic injection moulding machines, turbines and die-casting machines. Spent oil-water emulsion used as coolants Oil tanker sludges Oil-water mixture such as ballast water Sludge from storage tank 2. Waste containing polychlorinated biphenyls (PCB) or polychlorinated triphenyls (PCT) NO21 Spent oil contaminated with PCB and PCT NO22 Discarded electrical equipment or part containing or contaminated with OCB or PCT NO23 Containers contaminated with PCB or PCT Part II: Scheduled wastes from specific sources 1. Mineral oil and oil contaminated waste SO11 SO12 SO13 SO14 Waste oil or oily sludge from wastewater treatment plant oil refinery or crude oil terminal Oily residues from automotive workshop or service station oil or grease interceptor Oil contaminated earth from re-refining of use lubricating oil Oil or sludge from oil refinery maintenance 2. Tar or tarry residues from oil refinery or petrochemical plant SO11 Tar or tarry residues from oil refinery or petrochemical plant 28 Section 3 Notification of the generation of scheduled waste- introduces a requirement for schedule wastes generators to notify the Department of Environment (DOE) of the types and amounts of generated using the form set out in the Second Schedule. Section 4/5 Treatment and disposal of scheduled wastes-require that Scheduled wastes must be treats and disposed of at prescribed (and therefore licenced) premises and that, as far as practicable, it must be rendered “innocuous” (by treatment) before disposal. Section 6 Reduction in the generation of scheduled wastes-requires that scheduled wastes must be reduces (in quantity) to the maximum extent using the best practical means. Section 7 Responsibility of waste generator- to handle waste properly at all times (handling storage, treatment, delivery for treatment/disposal) Section 8 Storage of scheduled wastes- gives direction on how to store and label scheduled wastes. Incompatible wastes, which are described in the Fourth Schedule, must be stored in separate containers. Labeling must be done in accordance with the Third Schedule. Section 9/10 Inventory and Consignment Notes- waste generators must keep an inventory of schedule wastes generated, treated and disposed of and complete a consignment note for every consignment of scheduled wastes sent for treatment/disposal. It specifies how this information is to be distributed (to the DOE and, for consignment notes, to other parties). The forms to be used for the inventory are set out in the Fifth Schedule and for the consignment note in the Sixth Schedule. Section 11 Information to accompany scheduled wastes being transported- the information required is set out in the Seventh Schedule. These include: a) Properties of wastes, including associated risks b) Safe handling procedures c) Precautions in case of spill or accidental discharge causing personal injury d) Steps to be taken in case of spill or accidental discharge causing material damage. 29 Section 12 Spill or accidental discharge- describes the responsibilities of the waste generator and the contractor (transport) in the case of accidental discharge including the obligation to inform the Director General. Section 13 Compounding of offences- gives the direction for compounding of offences according to the procedure prescribed in Environmental Quality (Compounding Offences) Rules 1978. The schedule to the regulations, each of which has been explained above are as follows: First Schedule Definition of schedule wastes; Part I - Schedule wastes from non specific sources Part II - Scheduled wastes from specific sources 2.5.4 Second Schedule Form for notification of scheduled wastes Third Schedule Labelling requirement for scheduled wastes Fourth Schedule Scheduled wastes of potential incompatibility Fifth Schedule Form of inventory of scheduled wastes Sixth Schedule Consignment note for scheduled wastes Seventh Schedule Information to accompany scheduled wastes consignments Environmental Quality (Prescribed Premises) (Scheduled Wastes Treatment and Disposal Facilities) Order, 1989 This order prescribes the types of scheduled wastes facilities, which are to be treated as prescribed premises – and therefore require: An Environmental Impact Assessment (EIA) (Section 34A, EQA, 1974) A written permission for construction (Section 19) A licence to occupy and use the premises (Section 18) 30 The prescribed premises are: 2.5.5 Off-site storage facilities Off-site treatment facilities Off-site recovery facilities Scheduled wastes incinerators Land treatment facilities Secure facilities Environmental Quality (Prescribed Activities) (Scheduled Waste Treatment and Disposal Facilities) Regulations, 1989 These regulations require occupiers of the scheduled wastes facilities defined in the above Order to maintain records of the types and quantities of Scheduled wastes received, stored and processed and to submit this on a quarterly basis to the Department of Environment, Malaysia (DOE). They also specify the measures to be taken when an occupier ceases to be a licence holder, where upon any scheduled wastes which have not been treated or disposed of must be transferred to a licenced facility within 30 days. 2.5.6 Environmental Quality (Prescribed Activities) (Environmental Impact Assessment) Order, 1987 This order defines the prescribed activities, which require an Environmental Impact Assessment (EIA) before they may construct or operated. EIA is a mandatory legal requirement for all Prescribed Activities under the EIA Order, 1987. According to Harrop, O.D. and Nixon, A.J., (1999), there are now around 70 developing and transitional countries with EIA legislation in place and some of these countries, there are considerable activity with respect to the reorganization of government responsibilities for EIA at national and regional levels, the revision of EIA systems and the development of more detail procedures or guidelines to support EIA practice. 31 Section 34A of the EQA, 1974 specifies legal requirement in respect of EIA for Prescribed Activities: It empowers the Minister of Science, Technology and Environment, after due consultation, to prescribe any activity which may have significant environmental impact as a ‘Prescribed Activity’ The section further requires the Project Proponent of a Prescribed Activity to submit a report (the EIA) to the Director General of Environment Quality before approval for the proposed activity is granted by the relevant approving authority. The Department of Environment, Malaysia has outlined that the EIA report must contain an assessment of the impact of the Prescribed Activity on the environment. It also detail the proposed measures that shall be instituted to prevent, reduce or control adverse impact on the environment and the report should be in accordance with the guidelines issued by the Department of Environment particularly “A Handbook of Environment Impact Assessment (EIA) Guidelines, 2000”. In practice the EIA must be approved by DOE before the approval from the final Authority. The ultimate approval body will usually be one of the following: The National Development Planning Committee for Federal Government sponsored projects The respective State Planning authorities for State Government sponsored projects The Regional Development Authorities or State Executive Committee (EXCO) The Ministry of International Trade and Industry (MITI) for industrial projects. All prescribed waste treatment and disposals projects are subject to an EIA under the EIA Order, 1987. These prescribed premises include all the five (5) Prescribed Activities listed under sections 18(a) of EIA Order, 1987. Figure 2.4, 32 demonstrates the possible inter-relationship within these Prescribed Activities. The relevant items under the Schedule of Prescribed Activities are quoted below: Section 18 - Waste Treatment and Disposal a. Toxic and Hazardous Waste (i) Incineration plant (ii) Recovery plant (off-site) (iii)Wastewater treatment plant (off-site) (iv) Secure landfill facility (v) Storage facility (off-site) It is noted that toxic and hazardous (or scheduled) wastes can be treated or recovered at sources without the requirement for a separate EIA other than the EIA that might be requires for the industrial or selected activity producing the wastes (Rosli Zul, 1998). The aims of an EIA are to ensure that potential problems are foreseen and addressed at an early stage in the project’s planning and design (Canter, L.W., 1996). To achieve this aims, the assessment’s findings are communicated to be various group who will make decisions about the proposed project; the Project Proponents and their investors, as well as regulators, planners and politicians. Having read the conclusions of an EIA, projects planners and engineers can shape the project so that its benefits can be achieved and sustained without causing inadvertent environmental problems. (Morgan, R.K., 1998, Harrop, O.D., and Nixon, A.J., 1999). The legal frameworks, procedure and guidelines for EIA introduced in countries and organizations around the world follow some generally agreed principles, which have been described as a hierarchy of core values, guiding principles and operational principles. (Sadler, 1996 and Lee, N. and George, C., 2000). 33 34 According to Sadler, (1996) the core values of EIA are: Integrity The EIA process should conform to accepted standards and principal of good practice. Utility The process should provide balance, credible information for decision making Sustainability The process should promote environmentally sound development The same sources gives the main guiding principles as: A well-founded legislation base with clear purpose specific requirement and prescribed responsibilities Appropriate procedural controls to ensure the level of assessment, scope and consideration and schedule for completion are relevant to the circumstances Incentive for public involvement with structured opportunities tailored to the issues and interest at stake Problem –and decision –orientation, concerned with the issues that matter, the provision of consequention information, and explicit linkage to approvals and condition setting. Follow-up and feedback capability, including compliance and effects monitoring, impact management, and audit and evaluation Sadler (1996), further also sets out the main operational principles for effective EIA practice. EIA should be applied: To all development projects or activities likely to cause potentially significant adverse impacts or add to actual potential foreseeable cumulative effects; As a primary instrument for an environmental management to ensure that impacts of development are minimized avoided or rehabilitated; In a way that the scope of review is consistent with the nature of the project or activity and commensurate with the likely issues and impacts; and 35 On the basis of will defined roles, rules and responsibilities for key actors. Further, EIA should provide the basic for: Environmentally sound decision making in which terms and conditions are clearly specified and enforced; The design, planning and construction of acceptable development projects that meet environmental standards and management objectives; An appropriate follow–up process with requirements for monitoring, management, audit and evaluation; Follow-up requirements that are based on the significance of potential effects and on the uncertainties associated with prediction and mitigation; and Learning from experience with a view to making future improvements to the design of projects or the application of the EIA process. 2.6 Licensing And Inspection of Scheduled Waste Management Facilities The overall legislation relating to licensing of prescribed premises/activities and to scheduled waste management facilities is the Environmental Quality Act 1974 (as amended)- and the subsidiary regulations. The licensing is described in Part III, Licences of EQA, 1974 and the general explanation of the licensing requirements are covered in Section 10 to Section 17 of the EQA, 1974 as shown in Table 2.6. Under this Act, the Director General of Department of Environment shall be the licensing authority. The Director General of the Department of Environment: (i) May grant any application for licence or for a renewal or transfer there of, either to conditions or unconditionally and where an applications is granted subject to conditions, the conditions shall be specified in the licence to which the application relates; (ii) May during the currency of a licence or vary any condition attached to the licence revolve or vary any condition attached to the licence or attach new conditions 36 thereto whether in addition to or in substitution for existing conditions and shall notify the holder of the licence of his action in that behalf; or (iii) Shall not grant any application for a licence in respect of any premises the use whereof as such would contravene any town planning scheme or any law respecting the use or development of land. These sections also explain the licences application should be made in writing and before varying any condition attached to the licence, consideration are taken into account (Environmental Quality Act, 1974): (i) Whether it would be practicable to adapt the existing equipment or industrial plant to conform with the varied or new condition; (ii) The economic life of the existing equipment, control equipment or industrial plant, having regard to the data of purchase; (iii) The quantity or degree of out-back of emission discharge or deposit of wastes to be achieved by the varied or new condition; (iv) The estimated cost to be incurred by the licences to comply with the varied or new conditions; and (v) The nature and size of the trade, process or industry being carried out in the premises. Further the licensing procedure has been elaborated explained in the Environmental Quality (Licensing) Regulations, 1977(Department of Environment, 2002). Table 2.6: Malaysia: Environmental Quality Act, 1974. Licences, Part III Section 10 : Licensing Authority Section 11 : Licences Section 12 : Power to attach conditions to licences Section 13 : Duration and Renewal of licences Section 14 : Transfer of licences Section 15 : Register of licences Section 16 : Licences to comply with licence Section 17 : Licence Fees 37 2.6.1 Outline of Licensing Process The licensing process for prescribed premises/conveyances involves a four stage process (Rosli Zul and Azhar Daud, 1998) namely: (i) Environmental Impact Assessment (EIA); (ii) Processing of the Written Permission; (iii) Pre-licensing Inspection. (iv) Processing of the Operating Licence For all types of applications for scheduled wastes treatment and disposal facilities except land treatment/disposal, the application are required to obtain an approval for the EIA from the Department Environment prior to submitting their application for written Approval/Permission for establishing the facilities, EIA has a key role to play in the way in which new development proposals are designed, approved and implemented. To be effective, the process needs to be integrated into the project planning cycle with environmental studies taking place in parallel with the project design as it provides a useful framework within which environmental consideration and design can interact. Used in this ways, the EIA can indicate how the project design might be modified to anticipate and minimize possibly adverse effects and provide for a better environmental option or alternative process/design/location (Department Environment, Malaysia, 2000). The Written Permission is required before any construction or start-up operation can begin. It imposes conditions relating to the design and construction of a facility. After the facility has been constructed, it is inspected for conformance to the written permission approval conditions under the pre-licensing visit. Following the issuance of Written Permission, the applicants are required to construct/establish the premises according to conditions stipulated in the Written Permission. The main purpose of the visit is also to ensure that the premises had been constructed according to the drawing/plan submitted to the Department of Environment as well as to ensure all the approval conditions of the EIA and Written Permission are fully complied with (Rosli Zul and Azhan Daud, 1998). 38 An operating licence (usually referred to simply as a licence) is required before a facility/conveyance can operate. The operating licence specific a set of conditions pertaining to operation and maintenance. It is issued on confirmation that the facility conforms to the conditions of the Written Permission. It is based on the pre-licensing visit and the full compliance to the conditions stipulated. According to the Department of Environment, 2002) even before the application, the written permission and licence for premises can be considered, the applicant of the prescribed premises must: Meet to have obtained planning approval from the relevant planning authority under the requirement of Section 20, EQA, 1974. Have already obtained the EIA approval (EQA Section 34A) for the prescribed activity- where applicable Under Section 11(3)(b) of the EQA and reaffirmed in Section 4 of the Environmental Quality (Licensing) Regulations, 1977 licences can however be varied, revoked or suspended by the Director General if found necessary (Environmental Quality Act, 1974). In general the flow chart of the application licensing of the Waste Management Facilities in Malaysia is shown in Figure 2.5. 2.7 Classification of Toxic and Hazardous Waste Management Facilities A hazardous waste facility may involve the contiguous land, structure, and other improvements and appurtenances used for storing, recovery, recycling, treating or disposing of hazardous waste (La Grega, M.D., et. al., 2001). Many hazardous waste generators recognized the need for specialized treatment and disposal of these wastes. Many generators constructed and operated their own hazardous wastes facilities referred to as on-site facilities (Nemerow, N.L., 1995). Other generators, not having a suitable site or not generating a sufficiently large volume of waste to justify the investment on-site facility, transported their waste off-site to specialized facilities for treatment and disposal. Such facilities are referred to as commercial, off-site facilities (Sinha, R.K., 1994 and Nemerow, N.L., 1995). 39 APPLICATION ACCEPTED Prescribed Activity Submit RM 1000.00 payment together with required documents No Conduct EIA Initial Site Assessment EIA Approval EIA Approval No Submit information as required together with RM 1000.00 payment (if not yet) Yes Written Permission Yes Pre-Licensing Visit Submit Form AS 1 and RM 100.00 payment (if not yet) Licence and Compliance Table Record Applicant Source: Department of Environment, Malaysia, 2002. Figure 2.5: Flow Chart of Processing of Written Permission and New Licence for Prescribed Premises (Schedule Wastes) A hazardous waste facility may function with just one technology or it may combine multiple technologies (for recovery and treatment of hazardous waste) particularly if it in a commercial facility serving a number of generators. According to La Grega, M.D. et. al., (2001), the main types of facilities as shown in Figure 2.6, other than storage facilities are classified under the following major categories: 40 (i) Recovery or recycling facilities of recovered material as a saleable product (typically solvent, oils, acids or metals), some recovered energy values in waste; (ii) Treatment facilities involve changes in the physical or chemical characteristic, using any of a wide variety of physical, chemical, thermal or biological methods; (iii) Land disposal facilities are permanent placement of waste on or below land surface; (iv) Fully Integrated Facility. Some large commercial facilities employ aqueous treatment, incineration, land disposal and possibly other components to form a fully integrated facility as shown in Figure 2.7. Example of this category is Kualiti Alam Sdn. Bhd. (kualiti Alam, undated). The approach to technically evaluate a licence application will differ from facility to facility. Consequently, a classification system is needed to classify the more common toxic and hazardous facilities types. The following are currently the identified classifications of toxic and hazardous facilities for licensing purposes: Scheduled waste transportation Off-site storage and transfer stations* Secure landfill* Scheduled waste incineration – on site incineration and off-site incineration* Clinical waste incineration Off-site physico-chemical treatment/solidification* Centralized waste treatment facility (e.g. electroplating park) Resource recovery – spent oil and oily wastes, spent solvent, metal dross/metal hydroxide and catalyst Land treatment 41 Waste Generation Recovery / Recycling - Solvent recovery Fuel blending Metal recovery Oil recovery Energy recovery Products Land Disposal Treatment - Residuals - Landfill - Deep well injection Thermal destruction Aqueous treatment Stabilization Biological treatment Residuals Source: La Grega, M.D, et. al, 2001. Figure 2.6: Recovery, Treatment and Disposal Technology It should be noted that the classification types marked with an asterisk are facilities provided by Kualiti Alam (Mariana Md. Nor, 1998). Under the terms of Kualiti Alam’s 15 years concession (as from 18 December 1995), the Ministry of Science, Technology and The Environment has given an assurance that no further facilities of these types will be licenced during the period of Kualiti Alam’s concession. However, existing licences before 18 December 1995 date can continue to be renewed. Pre-Shipment Waste analysis Waste Receiving Storage & Preparation Organic residue Scrubber water Incineration Liquid Organic Recovery Leachate Physical Chemical Treatment Stabilization Slag Fuel, Solvent Land Disposal Source: La Grega, M.D, et. al, 2001. Figure 2.7: Waste Management Flow Diagram for Fully Integrated Hazardous Waste Management Facility 42 2.7.1 Exclusive Right of Kualiti Alam -The History of Scheduled Waste Management System in Malaysia During the mid 1960’s rapid growth began to occur within the manufacturing sector in Malaysia and this trend seems set to continue well into the foreseeable future. The contribution of these manufacturing industries to the Gross National Product (GNP) increased from 11% in 1966 to 24% in 1988, doubling in 20 years. This era was the beginning of the generation of hazardous waste in Malaysia. By the early 1980’s the government recognized the growing problem of this waste production and by 1981 an Australian Consultant is assigned to compile a desktop report concerning this matter. The report recommended a general waste management strategy consisting of the following aspects; a secure landfill, chemical fixation plant, incineration plant and recycling/reuse center. These should be backed up by legislation/regulations, notification by waste generators of waste arising and licences for transport, treatment and disposal sites (Goh, Kiam Seng, 1990) In October 1984, a Danish consultancy conducted a survey, which resulted in the formation of draft regulations on hazardous waste management, but these were not implemented. By 1985 the Department of Environmental (DOE) initiated a hazardous waste survey/programme to collect data on the volumes and types of hazardous waste arising within the country. A total of 700 factories were investigated in order to identify which waste could be recycled, treated, incinerated or landfill. During1985 to 1998, 29 sites were investigated on Peninsular Malaysia to find a central site as recommended in the Danish study. At the same time the French Government studied the hazardous waste arising from the metal finishing industries in Klang Valley and designed a physio-chemical treatment plant to deal with this waste. They also began work on developing a computer system for tracking and monitoring the scheduled waste within the country (Goh, Kiam Seng, 1990). During April to December 1987, Consultancy of Dames and Moore, working on from the 1985, DOE work, conducted a study on the feasibility of central treatment and disposal facility within Malaysia. A preliminary site was proposed but was subsequently rejected by the government, as they could not guarantee the minimum volume of waste, which would be delivered to the site. The study 43 estimated that a total of 377,000 MT of scheduled waste was generated within the country during 1987. In addition to this it was estimated that a further 600,000 containers contaminated with scheduled waste were disposal of annually within the solid waste system. The study also discovered that the waste generation was not evenly distribution throughout Malaysia, each state was slightly different in terms of volumes and types (Department of Environment, Malaysia, 1995). Many solid disposal sites exist throughout the country but during the study all found to be unsuitable for hazardous waste. The study concluded by recommending that a central integrated treatment and disposal facility to be built, including facilities for storage, incineration, physical-chemical treatment, stabilization and secure landfill. They estimated that in 1992 there would be a total 200,000 MT of scheduled waste which would be ‘landfill able’ and therefore secure sites for future disposal need to be develop in order to prevent the growing stockpile of stored waste from building up any further. The report suggested that this facility be built in the state of Selangor and is also fairly central within the country. The government stated that any development would be done only on private basis due to the huge finance (Goh, Kiam Seng, 1990). Following on from the Dames and Moore study the Department of Environment, Malaysia in 1995, conducted a further study to determine the exact breakdown of the waste types generated. This would enable the best management and treatment strategy to be developed concerning toxic hazardous waste. The result of the study is shown in Table 2.7 (Department of Environment, 1995). Subsequently in March 1989, the Government of Malaysia, realizing the growing problem, brought into force the first formal legislation in an attempt to control; the nations hazardous waste arising from’ cradle to grave”. The legislation was in the form of the three Environmental Quality Regulations brought in under the provisions of Section 18, 21 and 51 of EQA, 1974. 44 Table 2.7: Major Types of Scheduled Waste Arising in Malaysia Rank No Waste type Rank No Waste type 1 Acids (with heavy metals) 11 Rags /paper/plastic. Contaminated 2 Sludge with heavy metals 12 Paints/dye/ink/pigment (solvent based) 3 Mineral Sludge 13 Oil sludge 4 Asbestos 14 Pathogenic/pathological 5 Paint/dye/ink/pigment 15 Spent solvents, non halogenated 6 Dust/Slag/Cinder/Ashes 16 Sludge- paints etc (water based) 7 Alkalis 17 Sludge – paints etc (solvent based) 8 Oil & Hydrocarbons 18 Spent solvents, halogenated 9 Others 19 Resin and glue 10 Photographic wastes Source: Department of Environment, 1995. However there was still no actual waste strategy for dealing with the waste itself and in December 1995 the government commissioned the Department of Environment, Malaysia to conduct a second study into the selection of potential regional disposal sites. Based on the previous reports, a national scheduled waste programme is to be developed. This study involved selecting and recommending one site in each of the eleven (11) states across the Peninsular for developing an integrated plant, primarily a secure landfill but also storage, treatment and incineration units. The philosophy of the selection site selection was to locate the sites as close to the major waste sources as possible. This would reduce transport distances and therefore costs and also minimize risk of accidents. Dames and Moore in the 1987 report suggested that the optimum acceptable distance to transport wastes would be within a 25-30km radius from source to final destination. They also estimated that the cost will be paid by the generators and should be kept at a minimal so to avoid illegal dumping. With regard to this philosophy a regionalisation and zoning approach was adopted for the Master National Plan. This involved dividing the 11 Peninsular States 45 up into four regions according to waste generation, industrial densities and transport routes. Each region consisted of several states and division was set as follows: Northern Region; Perak, Penang, Kedah, Perlis Central Region; Negeri Sembilan, Selangor, Melaka, Federal Territory Southern Region; Johor Eastern Region; Kelantan, Terengganu, Pahang It was anticipated that at least one integrated plant be located in each region, with possible extra sites within the major producing states (Department of Environment, 1995). According to the 1995 Report, after the selection procedure had been completed a total of 11 potential sites had been identified as being suitable for the development as a secure landfill site with two sites were selected for each region. * Northern Region : Central Region : Southern Region : Eastern Region : 1. Ladang Bukit Mertajam* 2. Lahat 1. Bukit Nanas * 2. Bukit Lanchong 1. Foh Chong Estate * 2. Sedenak Estate 1. Bukit Mak Indah 2. Gambang The asterik are the final recommended or preferred sites. The others are suggested can be used as alternative or emergency sites. In June 1989, the government selected two private firms to design the proposed plant at Bukit Nanas. On the 18th of December 1995 the company Kualiti Alam Sdn.Bhd. was given approval to develop the Integrated Scheduled Waste plant and run the national strategy. This is a consortium made up of Malaysia and Danish companies. To ensure the long term viability of the project, Kualiti Alam was given the exclusive right to establish and operate the plant for 15 years covering Peninsular Malaysia (Mariana Md. Nor, 1998 and Alfred Ang, 1999). This national concession 46 also includes the responsibility for the collection, transport, treatment, and disposal of the nation’s waste with charges set for these services, which each generator must pay. They actual site of the integrated Scheduled Waste Management facility is located on Lot 1918, Tanah Merah Estate, Bukit Nanas, Negeri Sembilan (Kualiti Alam, undated). 2.7.2 Kualiti Alam Sdn.Bhd. - The Integrated Scheduled Waste Management System The Malaysian Government has privatized the management of scheduled waste based on ‘ polluters pay’ principle. For a period of 15 years from the start of operation of the waste management system, the company, Kualiti Alam Sdn. Bhd. (KA) has been granted the exclusive rights to collect and treat all scheduled waste generated in Peninsular Malaysia which can not treated within the premises of the waste generators (on-site treatment). The Integrated Scheduled Waste Management System of Kualiti Alam consists of: A centralized integrated Waste Management Centre (WMC) to treat and dispose of the different types of scheduled wastes (Kualiti Alam, undated). Kualiti Alam will provide complete waste management of collection of scheduled wastes from the waste generator’s premises, transportation, and treatment to final disposal. The Waste Management Centre (WMC) is located in the middle of an oil palm plantation, and covers an area of 56 hectares of which 19 hectares have been cleared (Alfred Ang, 1999). The Waste Management Centre (WMC) has four main treatment facilities: Incineration plant Physical/chemical treatment plant Solidification plant Secure landfill 47 All treatment and disposal facilities are now fully operational. The WMC treats all 107 categories of scheduled wastes as listed in the Environmental Quality (Scheduled Wastes) Regulation 1989, except: Radioactive waste Pathological waste Explosive waste The solidification plant stabilizes neutral inorganic waste from waste generators and internally produced waste (originating from physical/chemical treatment plant in the form of sludge or from the incineration plant in form of flyash). This unit is expected to have a capacity of 15,000 MT/year. In the physical/chemical treatment plant, inorganic wastes will be pHneutralized cyanides will be destroyed by oxidation and heavy metals will be precipitated as very insoluble products. These products are then stabilized and finally placed in the landfill. This plant is designed to have a capacity of 15,000 MT/year. The incineration plant will treat all organic waste classified to be applicable for thermal destruction. It is consist of rotary kiln at 1200oC with a capacity of 30,000 MT/year. The incineration process produces slag, fly ash and flue gas cleaning products. While slag is deposited directly into the landfill, other residues will be solidified and deposited in the secure landfill. The landfill is constructed and monitored according to all environmental requirements. Beside these three treatment facilities, the secure landfill is also located at the Waste Management Centre, it has a system of containment for the final disposal of treated wastes and should be enough capacity to last 25-30 years (Alfred Ang, 1999). Each landfill cell is protected by meter thick compacted clay at the base, and a layer of geomembrance and another layer of geonet further fortify it. There is also a piping system to channel leachate into the collection sump where leachate is regularly pumped out for testing. The overall waste management flow chart of Kualiti Alam is 48 shown in Figure 2.8. As mark of its commitment towards the environment and excellence, Kualiti Alam Sdn. Bhd. has four certifications, namely OHSAS 1S001, 1S0/ IEC 17025,1S0 14001 and ISO 9002, (Kualiti Alam, undated). 2.8 Licence Application Overview Permitting or licensing is the action of regulatory agencies to authorize construction and operation of a facility. Facilities cannot operate without holding a valid permit with the facility site, design, and operations do not violate health and environmental standards (LaGrega, M.D., et. al, 2001). 2.8.1 Types of Licence Application and Fees According to the Department of Environment, Malaysia, there are five (5) different of licence applications that may be required for the scheduled waste-related premises or conveyance. The processing fee, which is non-returnable, varies according to the application. These are as summarized as shown in Table 2.8. 2.8.2 Functional Issues in Licence Application As the licensing process involves the stages of written permission, the prelicensing visit and the operating licence; according to the Department of Environment, Malaysia there are some of the functional issues to be addressed in the application as shown in Table 2.9. As a comparison, by any measure; according to La Grega, M.D., et. al, (2001); the USEPA permit application process for a hazardous waste facility is length, expansive, and burdensome. Unlike Malaysia, in many states in the United States, a facility developer must also submit a separate permit application to satisfy the state’s particular requirements specify the technical requirements of a permit application. The major elements of a typical application are as follows: 49 Source: Kualiti Alam Sdn. Bhd. Figure 2.8: Waste Management Flow Chart of Kualiti Alam Sdn. Bhd. Table 50 Table 2.8: Types of Licence Application and Fees Application Type Processing Application Fee 1 Application for new licence Written permission Licence to operate RM 1,000 RM 100 2 Application to renew licence Renewal of licence Exceeding expiry date Late renewal RM 100 RM 10,000 penalty RM 10 per day delay 3 Application to transfer licence Transfer of licence RM 30 4 Application to amend conditions of licence Amendment of Licence Compliance Schedule No processing fee 5 Application for Contravention Licence for Land Disposal Contravention licence under No processing fee Section 24(1) for land disposal applicable to local Councils Source: Environmental Quality Act., 1974. Table 2.9: Functional Issues to Address in Written Permission/Licence Application Functional issues 1. General Issues 1.1 Documents 1.2 Drawings 1.3 Design 1.4 General Requirements 2. Operation and Maintenance 2.1 Waste identification 2.2 Operation 2.3 Maintenance 2.4 Safety procedures 2.5 Emergency response plan 2.6 Pollution control 2.7 Record keeping 3. Monitoring 3.1 Monitoring plan 3.2 Sampling/testing 3.3 Record keeping Source: Department of Environment, 2002. Written Permission Inspection Operating Inspection (once/twice Licence a year) 51 In general the approval conditions for Written Permissions and Operating Licences should fulfill four criteria as follow, (i) necessary; (i) enforceable; (iii) unambiguous; (iv) comprehensive (Department of Environment, Malaysia, 2002). It must be equally recognized that well-operated waste management facilities (especially for resource recovery) are to be encouraged to promote the effort towards sustainable development, which actively benefits the environment. Therefore, in preparing the approval conditions the Department of Environment always take into conditions that the approval conditions must: Be proportionate to the risks and costs (e.g. not to insist on in-house resource recovery) Reflect the underlying regulatory objectives (e.g. to at least comply with regulatory limits) Not impose unwarranted burden on those regulated (e.g. not to impose high-tech cleaner technology) Very often, many of the approval conditions will come from the supporting data submission giving the description of facility design, operating plan and closure plan ( Rosli Zul and Azhar Daud,1998). Other approval conditions to be included must address the technical and procedural requirement to protect the environment and health. They should include the: Types and quantities of waste; Technical requirements; Safety and security precautions; Reporting procedures. For Malaysia, it should be noted that the Department of Environment since 1999 has recently introduced the following new compulsory approval conditions for all facilities (Rosli Zul,1999): Waste permitted, including quantities and specific waste generators Waste Acceptance Criteria 52 Standard Operating Procedure (SOP) Procedure and training in accident response Waste disposal procedures Control of ambient air quality Records keeping Copies of all information to be sent to State DOE Thus, most approval conditions are generic in nature and the licence holder are obligated to comply with the standard conditions imposed in operating the specific waste management facility. 2.9 Inspection of Waste Management Facilities According to the Department of Environment, Malaysia, inspections may be carried out as part of standards procedures, e.g. Waste Management Facilities licensing, but they may also are undertaken at random to ensure conformity with legislation (Rosli Zul, 1999). As could be expected: The passage of time shown up deficiencies in operating practices and possibly in the original licence conditions Operators new to the field of waste management may experience problems In view of the above, as least on a yearly basis, the inspection the Waste Management Facilities to be checked on compliances with the approval conditions and the environmental regulations. This will, in any event, be required by virtue of the licence renewal process (Rosli Zul and Azhar Daud, 1998). 2.9.1 Types of Inspection There are a number of different of Waste Management Facilities inspection: 53 Inspection of Schedule of Compliance for Written Permission Pre-Licence inspection Annual inspection before renewal Inspection when contravention of licence conditions is suspected In Malaysia, when undertaking an inspection of the Waste Management Facilities, normally following documentation are pre-assessed (Rosli Zul, 1999): Written Permission Conditions Licence Conditions EIA Conditions Set of Schedule Waste Regulations Check list Waste Acceptance Criteria Standard Operating Procedure The detailed inspection process for licenced waste management facility will depend on the facility and Table 2.10 shows a generic checklist for waste management facilities. Each of the documents are carefully perused before the inspection and each item contained are carefully inspected so as to ensure compliance (Department of Environment, Malaysia, 2002). 2.10 Treatment and Disposal Methods for Scheduled Wastes Treatment and disposal facilities together with treatment technologies are therefore designed to change the character of waste thus rendering it less hazardous or altering it into a more environmentally acceptable form. Despite this, treatment only changes the form or state of the waste and one still left with fraction or residue to dispose of (Wentz, C., 1995 and LaGrega, M. D. et. al, 2001). 54 Table 2.10: Inspection of Waste Management Facilities CONDITION General Process Housekeeping Personnel Safety INSPECTION Current process Cleanliness Use of protective clothing Use of safety equipment: - Eye wash solutions - Fire Extinguishers - Spill cleanup equipment Emergency Response Plan (ERP) Emergency escape ERP - exist and be approved by DOSH ERP manual Documentation Consignment notes Copies of all consignment notes Waste acceptance Waste Acceptance Criteria Operation Procedure Standard Operating Procedure Plant maintenance Plant maintenance register Accidents Accident register Storage Storage inspection records Availability Document accessibility Waste handling Storage methods Conform with methods Segregation Incompatible wastes must be segregated Containers Good containers condition Labeling Labeling of waste code and danger symbols Storage ventilation Ventilation Holding duration Inventory records - not exceed 180 days Operation Waste acceptance Waste acceptance criteria Operating Procedures Standard Operating Procedure Specific conditions Licence conditions adherence Management supervision Level of supervision Monitoring Air emissions House monitoring records conform with licence conditions Ambient air House monitoring records Effluent House monitoring records conform with licence conditions Noise House monitoring records conform with licence conditions Source: Modified from Department of Environment, 2002. 55 There are now several forms of treatment available, the main processes used are often divided up into chemical, physical, thermal and biological. These technologies are used for volume reduction, separation, detoxification, destruction, and storage and material recovery. Consequently, recovery and reuse are strongly preferred options over treatment or disposal as accepted internationally of waste management hierarchy approach (Government Institutes, Inc., 1987, Abbou, R., 1988 and Price, R.L., 1991). The choice of treatment method will depend firstly on available methods and secondly on environmental and economic considerations. The options are related to the particular of hazardous substances in the waste such as: Composition of the waste Concentration of relevant substances Availability of appropriate recovery methods Value of the substances to be recovered Content of “other” hazardous substances. According to United Nation, a material is recycled if it is used, reused, or reclaimed (recovered). A material is “ reclaimed” if it is processed to recover a useful product, including conversion into energy as fuel (Abbou, R., 1988) Recycling is the concept of any utilization of hazardous waste for some applications, now or traditional, one type of recycling is disintegrating the product or waste and mixing it with primary raw materials in the production of new products of the same kind. Another type of recycling, recovery or reclaiming, is the more complete disintegration of the product or waste into bulk material, including elements (e.g. metals), which can be traded or used in the origin production. Table 2.11 and Figure 2.9 give a simplified overview of general recovery/ treatment options, for the main group of industrial wastes. In Malaysia treatment and disposal facilities for schedule waste are regulated by the Environmental Quality (Schedule Wastes) Regulations, 1989, together with the subsequent orders and regulations. 56 Acids, Alkalis, reactive (3) Solids containing metals/heavy metals Solution containing metals/heavy metals Inorganic sludge “Inert” inorganic waste Secure landfill PCT (1) Scheduled Wastes Incineration (2) Recovery Solidification (2) Table 2.11: Overview of Recovery/Treatment Option Inorganic waste Organic waste Solvents Oils Pesticides PCB, Chlorinated hydrocarbons Organic sludge, resins, paints Note: 1. 2. 3. PCT (Physical/ Chemical treatment will often be followed by solidification). The residues from the solidification process and incineration have at a secure landfill. The acids can often be used in the neutralization of alkalis and vice versa. In the Environmental Quality (Prescribed Premises). (Scheduled Waste Treatment and Disposal Facilities) Order, 1989, the following scheduled wastes treatment and disposal facilities are considered as prescribed premises: Off-site recovery facilities i.e. premises occupied or used for the recovery material or product scheduled wastes which are not produced on those premises. 57 WASTES Low- concentration effluents, wastewaters Acids, alkalis TREATMENT DISPOSAL Pretreatment Neutralisation Sewer Reactive wastes Toxic inorganic Physical and / or chemical Heavy metals Solidification Water Landfill Land Nontoxic inorganic Solvents, Oil Resins, paints, organic sludge Recovery Organic chemicals Chemicals Pesticides Incineration Chlorinated Hydrocarbons Biodegradable wastes Air Biological Land, water Source: Adapted from: Wentz, C., 1995. Figure 2.9: Treatment and Disposal Alternatives for Industrial Wastes 58 Off-site storage facilities i.e. premises occupied or used for the storage, collection or transfer of schedule wastes which are not produced on those premises. Off-site treatment facilities i.e. premises occupied or used for the processing of schedule wastes which are not produced on those promises. Schedule waste incinerators i.e. premises occupied or used for the thermal destruction of scheduled wastes. Secure landfills i.e. premises occupied or used for the disposal of scheduled waste on land Land treatment facilities i.e. premises used for the land treatment of scheduled wastes. According to Lee, Heng Keng, et. al, 2001, the Department of Environment, Malaysia has outlined the minimum percentage of recoverable components from scheduled wastes must in accordance to the Guidance Document on Transboundary Movements of Hazardous Wastes Destined for Recovery Operation as shown in Table 2.12. Table 2.12: Recoverable Components from Scheduled Wastes Types of Wastes Metal Hydroxide Sludge Spent Catalysts Recoverable Components Copper (Cu) Gold (Au) Nickel (Ni) Silver (Ag) Zinc (Zn) Chromium Oxide Cobalt (Co) Copper Compounds Nickel Oxide Nickel (Ni) Palladium (Pd) Platinum (Pt) Zinc Oxide (ZnO) Minimum Percentage (dry weight basis) 10 0.05 5 2.5 20 10 20 10 10 8 1.0 0.2 10 The most commonly available technologies for the scheduled wastes are as summarized in Table 2.13. 59 Table 2.13: Treatment and Disposal Technologies for Scheduled Wastes Technology Resource Recovery Treatment Final Disposal 2.11 Process Methodologies Gravity separation Coalescence separation Filtration / ultra-filtration Emulsion splitting Air floatation Solvent recovery Distillation Metal recovery Precipitation of metals Ion Exchange Electrolytic cell Physical Chemical Neutralization Solidification Immobilization Incineration High temperature destruction Land treatment Biological degradation Secure landfill Burial with protection of groundwater Oil recovery Resource Recovery Technologies As disposal of scheduled wastes gets more strictly regulated and more expensive, the recovery of valuable materials from the wastes will become more attractive. Economic will always be the driving force for an industry to choose between resource recovery and their disposal (Government Institute Inc., 1987, Duport, R., et. al, 2000 and Anil Markandya and Dale.N., 2001). The resource recovery technologies considered are: Oil recovery processes Solvent recovery processes Metal recovery processes The recovery facilities can be situated on-site as well as off-site; their characteristics are described as follows: 60 2.11.1 Oil Recovery A generalized method of oil recovery is not possible since oil can be present in wastewater in one of three distinct forms and its form will directly affect the method of recovery: Free oil _ Easily rises to the surface and can be readily skimmed off by any of several available mechanisms Emulsified oil _ A bit difficult to remove unless the emulsion is first broken Dissolved oil _ Removable biologically or by adsorption with activated carbon Basically, oil recovery consists of 2 or 3 stage. There is, however, a number of processes to choose from in each step (La Grega, M.D., et. Al, 2001), as shown in Table 2.14. Table 2.14: Step 1 Oil Recovery Processes Examples of Involvement Activity Pre-treatment Waste volume reduction Removal of impurities Emulsion splitting 2 Treatment Oil water separation Typical Processes Settling Filtration Additional of emulsification Chemicals Application of heat Gravity separation Coalescence separation 3 Refining (Optional) Purification Ultra-filtration Air floatation Distillation Acid/clay process As mentioned earlier, the recovery process option to be depends on the form of the wastes oil. The objective is to select the most appropriated process to segregate the oil and water for the intended use the recovered oil (Price, R.L., 1991). 61 As such, the decision on the recovery process cannot be made without knowing the: Actual composition of the waste oil in terms of: Oil droplet velocity (where applicable) Oil Droplet size distribution Emulsified state Concentration of oil on the wastewater Recovery processes available for waste oil Cost of using the different process for actual waste oil quality Utilization of the recovered oil. The options of the treatment and recovery of waste oil are presented in Figure 2.10. Option 1 Option 2 Treatment (Oil water separation) Pre-Treatment Refining (Distillation) Option 3 Reuse for original purpose Reuse fuel supplement Option 4 Source: Adapted from Department of Environment, 2002. Figure 2.10: Treatment and Recovery of Waste Oil Refining waste oil by distillation produces either a product that can be reused for the original purpose or waste oil with low content of impurities suitable for burning in a combustion plant for energy production. However, it is noteworthy that distilling waste oil can also give rise to: 62 A wastewater fraction which has to be treated before discharge e.g. by ultra-filtration. A distillation residue, which will require final treatment/destruction at Kualiti Alam . 2.11.2 Recovery Methodologies The different technologies used in the recovery of waste oil are briefly described below. (a) Gravity Separation of Oil and Water Gravity separation of oil and water/particulate matter is the simplest process used in recovery of waste oil. It is a passive process that utilizes the principle of the difference in specific gravity between oil and water. In simple terms, the wastewater is allowed to collect and settle in a vessel. The vessels used for gravity separation are either the API (American Petroleum Institute) Separators or the Parallel Plate Interceptors (PPI). The free oil, being lighter than water, rises to the surface. Once the oil-water separation is completed, the top oil layers are separated from the surface to an oil recovery tank using a belt on rope-skimmed facility or by pumping. The API separator is designed to remove oil droplets down to 150 microns in size. However, the resultant effluent has typically an oil concentration greater than 100 ppm. Further, API separators are ineffective in treating emulsions. (Department of Natural Resources, King Country, Washington, October 1995 adapted from Department of Environment, Malaysia, 2002). (b) Coalescence Separation A coalescing separator unit can handle the separation of non-emulsified oil. The separator has special elements with oleophilic and oleophobic properties. 63 Usually, a substance that is oleophilic will also be hydrophobic. Similarly, oleophobic substances are also hydrophilic. When oily water hits the knitted mesh surface of the coalescer elements, oil droplets in the water will spread out and be adsorbed onto the oleophilic surface of the elements. Similarly, the water portion wills be adsorbed onto the oleophobic surface of the elements. When more incoming oil and water droplets accumulate on these two surfaces and grow, larger droplets are formed. These larger droplets then migrate from one area of the elements to another. This migrating motion gradually accomplishes the coalescing effect, resulting in a hundred fold increase in liquid drop diameter, this in turn accelerates the oil/water separation. As a result of the coalescence effect, only large drops of oil emerge at the outlet. The coalescing plate interceptor (CPI) separator is typically designed to remove droplets down to 60 microns. They can attain effluent concentrations down to 10 to 20 ppm but are ineffective in treating emulsions. (Department of Natural Resources, King Country, Washington, October 1995; adapted from Department of Environment, Malaysia, 2002). (c) Emulsion Splitting Emulsion splitting is the best solution for removing emulsified oil. It is usually brought about by a pH change through the addition of chemicals such as lime or polyelectrolytes. Lime was the chemical of choice some years ago with polyelectrolytes no more popular because less sludge is produced using it. The applications of heat can also assist in splitting emulsions. The optimum chemical does and an optimum wastewater pH to be considered. Too little or too much chemical dosage can markedly affect separated from the water. For this, the air floatation method is usually applied. (d) Air Floatation Air floatation is used to separate low-density solids and hydrocarbon solids from liquids by air floatation. Air is introduces into the waste liquid in the form of 64 micro bubbles, which attach to the free oil (and suspended particles) to be removed. With a specific gravity less than water, the bubble-attached oil rises to the surface. Mechanical skimmers then remove the floating particles from the floatation unit while the liquid is withdrawn from the bottom. The air floatation system is capable of removing droplets down to 5 microns. They are usually used for secondary treatment producing an effluent having 1 to 25 ppm oil. Floatation systems can remove unstable emulsion. (Department of Natural Recourses, King Country, Washington, October 1995; adapted from Department of Environment, Malaysia, 2002). (e) Ultra Filtration Ultra- filtration is an alternative method for the treatment of emulsified oil. In this process, oil-contaminated wastewater is pumped through a membrane. Under applied static pressure, the ultra-filtration membrane allows the passage of water and most of the dissolved substances (chlorides, sulphates etc) while large molecules (emulsified oil being one of them) are retained. Ultra-filtration can be operated as batch, single-stage continuous or multi stage operation (f) Distillation In the distillation process the waste oil is separated into fractions depending on their individual boiling-points wherein the compounds with low boiling- points are first distilled off and so on. When the light and the heavier fractions are distilled off, a distillation residue- a kind of tarry material- remains in the plant. The residue is considered as scheduled waste and has to be treated at Kualiti Alam. (g) Acid/clay Process Another process for refining that is sometimes used is the acid/clay process, when concentrated sulphuric acid and diatomataceous earth is used to remove water and other impurities. It should be noted that this process produces a very hazardous 65 acid tar waste by-product, which is extremely difficult to treat or dispose of. Consequently, its use should be discouraged. 2.11.3 Use Recovered Oil and /or Waste Oil (a) As a fuel The uses of recovered oil and / or waste oil as supplementary fuel deserve special mention. Both are often used as fuel in combustion plants or brick kilns, replacing fresh fuel oil. However, the quality of some recovered oil and waste oil may contain contaminants depending on the recovery method and the source of the oil. Burning of waste oil of low quality usually results in air emissions above the acceptable level, unless suitable emission controls are in place- such as at Kualiti Alam, where they could be used as a replacement for fresh fuel, if the price levels were attractive. Currently, no quality requirement exists in Malaysia for the recovered oil and/or waste oil used as supplementary fuel in combustion plants. Unlike in Denmark, if the recovered oil or waste is not up to specifications, it may need to be distilled before it can be used as a supplementary oil (Ministry Environment and Energy, Denmark, 1977) An alternative is to blend waste oils, possibly together with non-halogenated solvents and other high calorific value wastes to form fuel of relatively constant specification. This can then be used as fuel of somewhat higher quality- for example in cement kilns. These are particularly attractive because they offer a higher temperature and a longer residence time than a hazardous waste incinerator and combust in alkaline conditions, thus removing harmful acid gases. Air emissions from the kiln when using waste oil tend to be similar or even better than when they use normal fresh fuel. 66 (b) Other Uses Waste oils may also be used as a timber preservative or may be converted into low-grade grease or lubricant. 2.12 Solvent Recovery Solvents are used in almost every industry to some extent. In the chemical industry for example, they are materials and to increase the efficiency of the reaction (Freeman, H.M.,1995). The rate of a reaction is dependent on the free energy of activation, Go, which is the difference between the energy of reactions and the transition state (Bishop. P.L., 2000). As such, the rate of reaction can be altered by proper selection of the solvent used. Most solvent used in organic chemical synthesis have been organic compounds; the most commonly used solvents are volatile organics, such as alcohols, chlorinated hydrocarbon, arenas, and nitriles, which cause many problem in the environment. The main technology used in the recovery of solvent is distillation. The feasibility and extent of recovery are governed largely by the quantity involved and the complexity of solvent mixtures to be separated (Freeman H.M., 1995). In addition, however, some paint solvents, mainly white spirit, are recovered for the making of low-grade paints in Malaysia. The waste types suitable for the technology are organic solvents, such as: White spirit Methanol Iso-propyl alcohol (IPA) Acetone Methyl ethyl ketone (MEK) Dimethyl formamide (DMF) Trichlorethylene (TCE) 67 2.12.1 Solvent Recovery Methodologies Ideally, the various solvents used in the different processes should first be segregated and then recovered separately. Center for Hazardous Materials Research, University of Pittsburgh (1991), outlines, the main solvent recycling and minimization techniques are: Distillation Separation techniques that rely on boiling point differences between the components of a liquid waste; Solids Removal Elimination of suspended particles to reduce fouling; Emulsion or Dispersion Breaking Separation of solvent or oil droplets in water, or of water droplets in oil; Dissolved and emulsified organic recovery Organic separations techniques that concentrate the organics so they can be recovered. There are numerous manufacturing of solvent recovery equipment in a variety of sizes. The smallest of these units recover solvents having a boiling point at 160oC or less. The waste solvent is recovered in batches, although clean solvent can be drawn of during operation. Recovery levels range from 80 to 95 percent, depending on the amount and type of contamination. Other separation technologies used by solvent processors include filtration, simple evaporation centrifugation and stripping (La Grega, M.D. et.al, 2001). 2.13 Metal Recovery There are a number of different processes for the treatment of waste containing metals, depending on the source of the waste and the objective of the treatment. Typical processes are: 68 Precipitation of metals Ion exchange Electrolytic cell Re-melting The first two technologies are pre-treatment steps to be followed by the metal recovery activities. The electrolytic method results in the direct recovery of the metals. The waste types suitable for the technology are as shown in Table 2.15. Table 2.15: Metal Recovery Recovery Process Waste Types Metal Recovery Metal precipitation Electroplating wastes Chromium Ion Exchange Electroplating wastes Chromium, Copper etc Electrolytic recovery Photo-finishing wastes Silver Electronic wastes Precious metals Solder dross Solder Re-melting 2.13.1 Metal Recovery Methodologies (a) Metal Precipitation. There are basically three metal precipitation methods, namely: - Precipitation by chemical reduction (using a reducing agent) - Precipitation by alkali/hydroxide and - Precipitation by sulphide A brief description of each of these methods is described below: Alkali/Hydroxide Precipitation Optimum precipitation of solid metal hydroxide is achieved by adjusting the pH the wastewater to the usually moderate alkaline range. This accomplished by measured addition of lime or caustic soda to the wastewater with concurrent pH monitoring. 69 The precipitated metal hydroxides are coagulated (using coagulating agents) in a clarifier and deposited as sludge. Proper clarifier design and good coagulation are important for efficient metals removal. It must be mentioned that this method is subject to interference when mixed wastes are treated. Sulphide Precipitation In this process, heavy metals are precipitated as a sulphide precipitate. Sulphide is added to the waste solution with the pH maintained within a narrow pH range above eight (8). The sulphide normally used is: - Either a soluble suphide such as sodium sulphide, calcium polysulphide, sodium hydrosulphide - Or the less soluble ferrous sulphide (as powder or slurry form) Careful management of this type of precipitation is important. Usually, an automatic controller adds the sulphide as pH control is critical. A well-operated sulphide precipitation system can remove most of the metals from the wastewater. The disadvantage of the soluble sulphide method is that in the presence of excess sulphide, some hydrogen sulphide gas can be produced, which is extremely toxic. (b) The Ion Exchange Technique Example of the off-site recovery facility of chemical waste: Ion exchange cartridges are installed at the electroplating factory to absorb the heavy metals from the drag-out/rinse waste system into the ion exchanges resins. Most of the metals ions are absorbed as monometallic ions. In other words, these ion-specific cartridges absorb only copper or only zinc or only chromium ions. The “loaded” ion exchanges cartridges are collected for regeneration at the off-site facility. Regeneration releases the heavy metals into the washing liquor. The heavy metals are then recovered from the washing liquor using the electro-winning process. 70 In the electro-winning process, an electric field is applied between two electrodes immersed in an electrolyte, the positive metal ions are drawn to and deposited at the cathode. The deposited metal, which has a purity of 99%, is removed for re-use. The type of metallic ions which the ion exchanges facility can handle are chromium (VI), copper, lead, nickel, tin, silver, zinc and cyanide. (c) Electrolytic Metal Recovery (EMR) The waste types suitable for the technology are mainly waste from the metal finishing industry (Electroplaters, rolling mills, printed circuit board manufacturers and metal coating firms). The following are examples of electrolytic metal recovery. Chromium Recovery An EMR unit is usually positioned at the rinse tank immediately downstream of the plating tank to capture the bulk of the drag-out. Solution from the rinse tank is made to circulate through an electrolytic cell. In the electrolytic cell, a direct current is passed through the metal bearing solution. Element metal is deposited on the cathode while oxygen is evolved at the anode. Metal deposition is allowed to build up to a thickness of about one-half inch. The power is then shut off and the deposited metal is removed from the cathode. Most electrolytic cells, under favorable, can recover 99% of the dissolved metal from the drag-out/rinse solutions. The chief hurdle to EMR is the cost of power required to deposit metal from low concentration solutions. However, this is increasingly offset by the rising cost of the primary metals recovered. Silver Recovery In the electrolytic silver recovery, the silver-bearing solution is passed between two electrodes through which a controlled direct electric current flows. Silver plates out on the cathode as almost pure metal. Considerable agitation and large plating surface areas are necessary to achieve good plating efficiency and high 71 quality silver up to 96-98 percent purity. The cathodes are removed periodically and the silver is stripped off. Electronic Wastes Electronic wastes contain precious metals, in particular gold and platinum. These may also be recovered by electrolytic means. (d) Re-melting Re-melting is used for the recovery of solder dross. This technology for recovering metals can grouped as pyrometallurgical (La Grega, M.D., et.al. , 2001). Pyrometallurgy uses the differences in melting and boiling properties to separate metals at high temperature. Roasting or smelting typically provides the heat. It is a simple process and is used extensively in Malaysia (Department of Environment, 2002).