&EPA
Nigerian
Environmental
Survey
Oct. 21 -Nov. 11, 1978
Appendices
United States
Environmental Protection Agency
February 1979
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NIGERIAN ENVIRONMENTAL SURVEY
APPENDICES
I LISTING OF DISCUSSIONS AND INSPECTIONS
II OVERVIEW OF NIGERIA'S EXISTING LEGAL AND INSTITUTIONAL ARRANGEMENTS
RELATING TO ENVIRONMENT AND NATURAL RESOURCE MANAGEMENT
III EFFLUENT GUIDELINES AND EMISSION FACTORS FOR PULP AND PAPER
IV REFUSE MANAGEMENT IN DEVELOPING COUNTRIES
V ENVIRONMENTAL ASSESSMENT INFORMATION FOR DEVELOPMENT OF A PERMIT
VI TYPICAL UNITED STATES WASTE WATER DISCHARGE PERMIT
VII SAMPLE SPCC PLAN FORMAT FROM AMERICAN PETROLEUM INSTITUTE BULLETIN D-16
VIII STATE AND LOCAL REFUSE PLANNING GUIDELINES FOR FINANCIAL ASSISTANCE GRANTS
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APPENDIX I
LISTING OF DISCUSSIONS AND INSPECTIONS
VISIT TO LAGOS STATE
October 23-28, 1978
Piscussion: Permanent Secretary, Works & Planning
Chief Engineer, Sewage
Chief Engineer, Water
Chief Engineer, Highway
Chief Engineer, Drainage
Chief Engineer, Mechanical
Project Manager, Master Plan-Unit
Chief Town Planning Officer
Chairman & Officials of Lagos State Refuse Disposal Board
Permanent Secretary, Ministry of Agriculture
& Natural Resources
Representatives of Office of Attorney-General
Lagos Island Local Government
Lagos Mainland Local Government
Mushin West Local Government
Mushin East Local Government
Ikeja Local Government & Supervisory Councillors
& Officials
General Manager, Lagos State Development & Property Corp.
Inspection: Iju Water Works
Incinerating Plants
University of Lagos
Federal Laboratory, Oshodi
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VISIT TO IBADAN STATE
October 30-31, 1978
Piscussion: Ministry of Trade, Industries & Cooperatives
Ministry of Local Government & Information
Ministry of Agriculture & Natural Resources
Ministry of Works & Housing
Water Corporation
Ibadan Municipal Government
Ibadan Metropolitan Planning Authority
Property Development Corporation
University of Ibadan
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VISIT TO KWARA STATE
November 1-4, 1978
Discussion: Military Administrator
Emir of 11 orin & Chairman, Ilorin Local Government
Permanent Secretary, Ministry of Local Government
Permanent Secretary, MANR
Permanent Secretary, Ministry of Health
Permanent Secretary, Ministry of Econ. Dev.
Permanent Secretary, Ministry of Works & Transport
General Manager, Kwara Water Corporation
Emir of Borgu
Inspection: Ilorin Public Water Works
Pulp and Paper Factory - Jebba
Kainji Dam
Bacita Sugar Factory
Iron & Steel Site - Ajaokuta
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VISIT TO KANO STATE
November 8-10, 1978
Discussion:
Commissioner for Ministry of Trade,
Permanent Secretary and Officials -
Permanent Secretary and Officials -
Permanent Secretary and Chairman -
Kano Municipal Area Council
Industry & Cooperatives
Ministry of Agriculture
& Natural Resources
Ministry of Works
& Housing
Ministry for Local
Gov't. & Community Develop
Inspection: Kano Textile Printers Ltd.
National Oil & Chemical Marketing Company
Kano Urban Development Board
Water Resources and Engineering Construction Agency
Bayere University
Challawa Water Station
Federal Industries Ltd.
Nigex Ltd.
Holts Tanneries Ltd.
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APPENDIX II
OVERVIEW OF NIGERIA'S EXISTING LEGAL AND INSTITUTIONAL ARRANGEMENTS
RELATING TO ENVIRONMENT AND NATURAL RESOURCE MANAGEMENT
Introduction
This report1 highlights some of the key legal and institutional
arrangements involved with environmental or natural resource management
matters in Nigeria. The information was obtained primarily during
the EPA Survey Team visit, October 20-November 11, through much discus-
sion with officials, and legal research.
Therefore, due to time constraints, it was not possible to do
detailed legal research for each state. Rather, an effort was made
to get some impression of the Federal-State relationship through the
states visited and to highlight some of the states' legislation for
illustrative purposes.
Therefore, particularly at the State level, this report is in no
way intended as a comprehensive analysis of the Nigerian legal system
relating to the environment. The intent is to present a good overview
at the Federal level (since Federal legislation has in most areas
been a pattern for State laws), and then state examples where they
have been researched, without the expectation that these represent
all states.
1 Information in this report was gathered substantially during
the survery team visit. Two considerations have influenced the report
in its present form: 1) time constraints which prevented further
details through specific research if this member was to obtain the
necessary information for an overview, and 2) a concern for a manage-
able size. I have tried to present an accurate account of the legal
and institutional situation within these constraints. Comments are
always welcome for clarification and completeness. Special thanks should
be given to legal officials throughout Nigeria for their help in gather-
ing information.
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The potential capacity for local water management and pollution
control contained by these statutory water corporations makes them
very important institutions at the state level. They have the responsi-
bility to ensure that water is supplied in potable quality and adequate
quantity.12 Some of the legislation requires that the water agencies
"from time to time, . . . examine any surface or underground waters
for the purposes of determining what, if any, pollution exists and
the causes thereof . . . ." 13 Following the pattern of the Federal
Waterworks Ordinance, state water corporation legislation prohibits
pollution of water entering the waterworks by "any foul, noisome, or
injurious matter, or any earth deposit or excavated matter ... 14
These water agencies are key state institutions which should definitely
be consulted and involved with any development of environmental regula-
tion in the water supply area.
A note of caution is appropriate, however. Each State with a water
authority has established the institution according to that State's
particular needs. Therefore, it would not be appropriate to generalize
too extensively when formulating Federal provisions affecting this
area. For example, the jurisdiction of a water authority may vary
from State to State. Oyo State's Authority is responsible for only
water supply, with Public Works having sewage and drainage; Kano
State Authority is responsible for all water resources including sewage
and drainage. Also, the supervising body for a water authority may
vary. In Oyo State, it is the State Military Governor; in Kwara, the
Ministry of Works; in Kano, the military Governor. This highlights
the need to allow States to comment on Federal guidelines affecting
these areas so that particular circumstances can be taken into account
for the State programs.
12 See, e.g., Kano Water Edict, Section 13(c); Oyo Water Edict,
Section 6.
13 Kano Water Edict, Section 10(g); Oyo Water Edict, Section 7(e).
14 E.g., Kano Water Edict, Section 44; Oyo Water Edict, Section 40.
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I. Background
Nigeria is a Federal Military Government (FMG). It has three
governing bodies: the Supreme Military Council (SMC), the Federal
Executive Council (FEC), and the National Council of States. The
23-person SMC combines the executive and legislative functions and
is the top policymaking unit. It rules by decree. The 25-person
FEC, with civilian and military members performs the role of a cab-
inet. The Head of State, Lt. Gen. Olusegun Obasanjo, heads both
councils. The Military Governors of the States sit in an advisory
capacity to the SMC on the National Council of States.
All 19 States have military Governors. To lay the groundwork
for transition to civilian rule, each Governor now has a civilian
administrator counterpart. The Governors appoint civilian commis-
sioners for specific State Ministries. Each State government has an
Executive Council and its own budget. The States derive a large part
of their revenues from the Federal Government.
Except for placing government decrees beyond judicial review,
military rule has done little to alter Nigeria's system of State and
Federal courts. The Federal Supreme Court of Lagos, the court of
final appeal, has orginal and appellate jurisdiction. The High
Courts of Justice in the States have wide original jurisdiction and
also hear appeals from lower-level courts.
The Judiciary is based on English Common Law, statutory law,
customary law at some levels, and Islamic law in some areas on cer-
tain matters affecting Moslems. Presently, the statutory instrument
at the federal level is the "Decree." The State Government's rule by
"Edict." Both Federal and State Governments issue "regulations" pur-
suant to authority in Decrees of Edicts. The Local Governments enact
"Bye-laws" for local matters when authorized by State or Federal
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legislation (usually through a Local Government Edict, public health
law, or road/traffic law). Bye-laws are always approved by the State
Commissioner responsible for that matter.
II. Legislation Affecting Natural Resources
A. Land
The Land Use Decree, 1978,1 has modified the traditional land
use principles which have been practiced under customary law in Nigeria.
This Decree, subject to certain exemptions, vests all state land in
the Military Governor of the State to be "held in trust and administer-
ed for the use and common benefit of all Nigerians . . . .1,2 Previously
land was more directly administered by local authorities for the same
purpose.
In application, the Decree specifies that "all land in urban
areas shall be under the control and management of the Military
Governor of each State,"3 and that all other land shall be under the
control and management of the Local Government where the land is situat-
ed. The Decree also establishes a "Land Use and Allocation Committee"
for each State, composed of members appointed by the Military Governor,
4
to advise the Military Governor on all land use matters. A similarly
appointed group known as the "Land Allocation Advisory Committee" is
5
established to advise each Local Government. While the Military Governor
is authorized to grant statutory rights of occupancy to any person
for any purpose on any state land, the Local Government units are
given the power to grant on non-urban land customary rights of occupancy
to any person for grazing, agricultural, and other purposes ancillary
6
to agricultural purposes.
1 Federal Land Use Decree, 1978 (Decree No.6), 29 March 1978.
2 Id., Section 1.
3 Id., Section 2 (1) (a).
4 Id., at Section 2(2).
5 Id-, at Section 2(5).
6 Id., at Section 6.
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B. Water
(1) Federal
At the federal level, the principle legislation is the Water
Ordinance.7 This ordinance was enacted in 1913 and has not been up-
dated. However, discussions are currently underway within the respon-
sible Ministry to amend and modernize the ordinance.
The Waterworks Ordinance regulates the supply from any waterworks
to domestic, industrial, or agricultural uses, both public and private.8
It prohibits the pollution of any waterworks or water which may be
carried into the waterworks by "any foul, noisome or injurious matter,
or any earth deposit, or excavated material."9
(2) State
Recent legislative developments in water regulation have come at
the state level. Each State has its own waterworks legislation which
is generally compatible with Federal legislation. Most states have
state water authorities. For example, Kano and Oyo States have state
legislation 10 establishing water corporations. It is through these
corporations that a substantial part of the water activity is conducted.
They are primarily responsible for water supply and the construction
and management of waterworks projects necessary for water resource
development at the local level.11
7 Water Ordinance, Cap. 213, 1915, in Laws of the Republic of Nigeria 1958.
8 Id., at Section 2.
9 Id., at Section 22.
10 Kano State Water Resources and Engineering Construction Agency
Edict, No. 3 of 1975 (hereinafter referred to as "Kano Water Edict");
Oyo State Water Corporation Edict, No. 24 of 1977 (hereinafter referred
to as "Oyo Water Edict").
11 See, e.g., Kano Water Edict, Sections 9 and 10; Oyo Water Edict,
Sections 6 and 7.
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(3) River Basins
Two principle federal decrees are involved here: the River
Basins Development Authorities Decree 1976 15 and the Niger Delta
Basin Development Authority Decree 1976.16 The River Basins' Decree
establishes 10 corporate river basin authorities to oversee in specified
areas comprehensive development of underground water resources, schemes
for flood and erosion control, construction of dams and other related
works, and supply of water from its waterworks when so requested by the
State Governments.17 The Niger Delta Decree establishes a corporate
authority for the Niger Delta Basin to develop that area.18
Both decrees give the respective authorities powers to control
pollution in the rivers and lakes in each authority's area " in accor-
dance with nationally laid-down standards,"19 as well as general water
management authority in their areas. Considering their broad range of
powers and the expanse of territory they collectively cover, these
authorities will need to be directly involved with development of
regulatory schemes for environmental protection and natural resource
management impacting their jurisdictions.
15 River Basins Development Authorities Decree 1976 (Decree No. 25)
(hereinafter referred to as "River Basins Decree").
16 Niger Delta Basin Development Authority Decree 1976 (Decree No. 37)
(hereinafter referred to as "Niger Delta Decree").
17 River Basins Decree, Sections 1 and 2.
18 Niger Delta Decree, Sections 1 and 2.
19 River Basins Decree, Section 2(1) (f); Niger Delta Decree, Section
3(1) (h).
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(4) Navigable Waters and the Ocean
The Territorial Waters Decree 1967,20 extends the limits of the
territorial waters of Nigeria to twelve nautical miles. This is an
extension with respect to jurisdiction over offences committed in
those waters.
The Exclusive Economic Zone Decree 1978, establishes a Nigerian
Exclusive Economic Zone (EEZ) of 200 miles.21 Exclusive rights to
exploration and exploitation of the natural resources of the seabed,
subsoil, and superadjacent waters of the EEZ are vested in the Federal
Government of Nigeria.22 The Decree is subject to the provisions of
any treaty and to any universally recognized rights of other states
(including landlocked states).
The Sea Fisheries Decree 1971, 23 licenses sea fishing ac-
tivities, prohibits certain fishing methods, and allows the Commissioner
to regulate in the interest of sea fishing. No express provision dis-
cusses control of pollution for the protection of fish but this could
arguably come within the regulatory powers of the Commissioner. Federal
legislation for inland fisheries regulation is under consideration. At
present this is a state matter, but federal regulation is contemplated
to provide some standardization in waters shared by two or more states.
In the Petroleum Decree 1969, the Commissioner charged with
responsibility for petroleum development is authorized to make regula-
tions with respect to petroleum exploration and exploitation for "the
20 Territorial Waters Decree 1967 (Decree No. 5), Sections 1 and 2.
21 Exclusive Economic Zone Decree 1978 (Decree No. 28), Section 1.
22 Id-, at Section 2.
23 Sea Fisheries Decree 1971 (Decree No. 30).
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prevention of pollution of water courses ... 24 The Petroleum Refining
Regulations 1974, reguire the manager directing a refinery operation
to ensure that drainage and water conform to good refining practices.25
C. Forestry
At the Federal level, current legislation consists of the Forestry
Act 1938.26 The Ministry of Agriculture and Water Resources, Department
of Forestry, began initiatives in 1975 to update the legislation.
Negotiations are still underway with the Federal Ministry of Justice.
The existing legislation is effective only in federal forests.
Since there are no national parks or forests, the law has served sole-
ly as a guide for state legislation and is not itself enforced. If
the proposed Kanji National Parke is established, the Federal legisla-
tion will be used.
As indicated above, State legislation is the primary regulatory
mechanism in forestry. States have generally followed the 1938 federal
model. One example is the Forestry Law 1938, of the old Western Region.27
When Oyo State was established out of the Western Region, the law was
adopted from that version formerly in force (which was patterned after
the Federal law). It has standard provisions relating to the establish-
ment of Government Forest Reserves and Government Protected Forests.28
It grants comprehensive powers to make regulations for forest management
and control and prohibits certain unauthorized activities in forest
reserves and protected forests.29 There is substantial potential for
regulation within the legislation but enforcement has been a major
problem.
24 Petroleum Decree 1969 (Decree No. 51), Section 8 (b) (iii).
25 Petroleum Refining Regulations 1974 (L.N. 45 of 1974), Section 43
(1).
26 Forestry Act (Cap. 38) 1938, in Laws of the Rebublic of Nigeria 1958.
27 Forestry Law (Cap. 38) 1938, Western Region.
28 Id., Section 4-21
29 Id. , Sections 46, 49, 51.
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Oyo State has now updated the old version of the Forestry law
and has added some innovative provision. For example, it has estab-
lished a Forest Trust Fund " to be applied for regeneration or af-
forestation of particular forest reserves or generally . . . .30
It appears that forestry legislation is in a period of flux in
many States.
D. Wildlife
At the federal level, wildlife legislation is in a position similar
to that of the forestry legislation. The states are the primary actors
in wildlife management to the extent that it occurs. There is federal
wildlife legislation that originally, during the colonial days, was
used as a pattern for the regional legislation. Many States retain
this old law.
The Federal Wildlife Animals Preservation Ordinance 31 was enacted
in 1916, during the period when Lagos was a protectorate. It contains
the standard colonial provisions, requiring licenses for the killing
of certain game species according to various schedules. Several provi-
sions and the schedules would need revision if the legislation were to
comply with international norms developing through the Convention on
International Trade in Endangered Species. State legislation patterned
after the federal law would similarly need updating. Kano State has
recently amended its wildlife law, increasing the penalties, and re-
placing the schedules with new lists of animals for which hunting is
prohibited, "specially protected" animals, and "protected" animals.32
30 Oyo State Forestry (Cap. 38) Edict 1970, (Edict No. 1), Section
31(1) and (2).
31 Wildlife Animals Preservation Decree (Cap. 221) of 1916, in
Laws of Republic of Nigeria 1958.
32 Wild Animals Law (Amendment) Edict 1978 (Edict No. 13 of 1978).
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E. Minerals
(1) Petroleum
The entire ownership and control of all petroleum in, under or
upon any lands out to the 200-mile limit of the Exclusive Economic
Zone is vested in the Federal Republic of Nigeria.33 Petroleum regula-
tion has gone through many phases in Nigeria, the current principle
legislation being the Petroleum Decree 1969,34 the Petroleum Refining
Regulations 1974,35 and the Nigerian National Petroleum Corporation
Decree 1977.36
The legislation is detailed, authorizing regulations in a wide
range of activities to maintain strong control over petroleum explora-
tion and exploitation. In the regulations, "petroleum products" in-
cludes motor spirit, gas oil, diesel oil, automotive gas oil, fuel oil,
aviation fuel, kerosene, liquified petroleum gas and any lubricating
oil or grease or other lubricant.37 The regulations require the manager
of a refinery operation to "adopt all practicable precautions including
the provisions of up-to-date equipment ... to prevent the pollution
of the environment by petroleum or petroleum products; and where
such pollution occurs the Manager shall take prompt steps to control
and, if possible, end it."38
33 Petroleum Decree 1969 {Decree No. 51), Section 1.
34 Id.
35 Petroleum Refining Regulations 1974 (L. N. 45 of 1974).
36 Nigerian National Petroleum Corporation Decree 1977 (Decree No.
33) .
37 Petroleum Refining Regulations 1974, Section 48.
38 Id., at Section 43.
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Since 1977, the Nigerian National Petroleum Corporation (NNPC)
has been responsible for overseeing the actual exploration, processing,
purchasing, marketing, and research activities surrounding the petroleum
industry in Nigeria.39 It is a parastatal organization with commercial
and regulatory activities. It appears that to-date the thrust of its
efforts have been in the commercial area and efforts still are necessary
in issuing regulations to fulfill its responsibilities in areas of
management, inspection, protection of property and the environment.
Nigeria is a party to the International Convention for the Preven-
tion of Pollution of the Sea by Oil (1954), and the Oil in Navigable
Waters Decree 1968,40 brings this convention in force nationally.
III. Health and Safety Legislation
A. Public Health
The Federal-State relationship with respect to Public Health
legislation is, again, similar to that occurring with the forestry
and wildlife legislation. The federal legislation was the colonial
pattern which the states used (as they gained authority to regulate
their own health areas), and continue to use today.
The federal Public Health Ordinance 195841 contains general provi-
sions prohibiting nuisances including any pool, drain, well, collection
of sullage water "or other thing in such a state or condition as to
be injurious to health 42 It also prohibits the fowling of any water
used as a supply to man or beast."43 The broad authority within this
Public Health legislation could arguably encompass environmental
39 Nigerian National Petroleum Corporation Decree 1977, Section 4.
40 Oil in Navigable Waters Decree 1968 (Decree No. 34).
41 Public Health Ordinance (Cap. 165) 1958.
42 Id., at Section 7.
43 Id., at Section 13.
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regulation for human health protection, at least until a specific environ-
mental protection regime and standards are enacted in each state.
B. Sewage and Refuse Disposal
This is essentially a State or local Government matter. Local
Government edicts enacted by the States in 1976 provide that "a Local
Government shall have responsibility for, and power to make bye-laws
for . . . sewerage, refuse and nightsoil disposal . . . .1,44
Using that power, local governments have issued bye-laws to regu-
late refuse disposal. For example, the draft Ibadan Municipal Government
Collection and Disposal of Refuse Bye-Laws, 1978, made under the Local
Government Edict. These bye-laws prohibit the deposit of refuse in
other than an approved place and authorized a fee for municipal govern-
ment refuse collection.45
In some cases States have established separate edicts. The Lagos
State Government has proclaimed, for example, several separate edicts
to relieve the refuse and litter problems in the city. Edict No. 9
(1977) established the Lagos State Refuse Disposal Board, which is
still operating. (Several states have tried using Refuse Disposal
Boards with varying degrees of success. For example the Refuse Board
in Oyo State was dissolved in April 1978, with a new Division in the
State Ministry of Works assuming the Board's responsibilities.) The
Lagos State Environmental Sanitation Edict (1978) prohibits the dispo-
sal of rubbish and refuse in any place except those set aside by the
proper authority for such purpose.46 The Lagos State Ban on Street
Trading Edict (1978) required the removal of street trader, a group
contributing substantially to the litter on public streets and highways.
44 See, e.q., Oyo State Local Government Edict 1976 (Edict No. 5).
45 Drabt Ibadan Municipal Government Collection and Disposal of
Refuse By-Laws, 1978, Sections 3, 10-13.
46 Lagos State Environmental Sanitation Edict 1978, Section 2.
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C. Factories
Factory regulation is a federal matter, coming within the federal
jurisdiction of trade and commerce. The federal factories' legislation
has provisions for the health, safety, and welfare of the persons
employed in the factories,47 It requires the registration of factories
(10 or more persons employed by manual labor for trade and gain) and
authorizes government inspection of a plant for dangerous conditions
and practices.48 While the legislation does not apply to persons or
conditions affecting persons outside the factory employ, the provisions
in health, safety, and welfare for employed persons are comprehensive.
The regulations define "occupational diseases" to include "lead poison-
ing, phosphate poisoning, mercury poisoning, manganese poisoning,
arsenic poisoning, aniline poisoning, carbon bisulphide, benzene poison-
ing, chrome ulceration due to chromic acid or bichromate of potassium,
sodium or ammonium anthrax silicosis, pathological manifestations due
to radium or x-rays; toxic jaundice due to tetha-chorethane or nitro
or amino derivatives of benzene or other poisonous substances, toxic
anemia, primary epitheliomatus ulceration of skin due to the handling
or use of tar, pitch, bitumen, mineral oil, paraffin, or the compounds,
products or residues of these substances, poisoning by halogen deriva-
tives of hydrocarbons of the aliphatic series, compressed air illness,
asbestosis.49
D. Labour
Labour regulation is also a federal matter. The Labour Decree
1974 provides that where an industrial or agricultural undertaking is
remote and isolated it shall be declared a labour health area and
47 Factories Act 1956 (Cap. 66), as amended, in Laws of Republic of
Nigeria 1958.
48 Id., at Section 5, Parts III, IV, V.
49 The Factories (The Declaration of Occupational Diseases Notice)
Regulations (L. N. 114 of 1956), Schedule.
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the employer shall be required to comply with special regulations.50
The special regulations which are authorized deal with planning and
layout of towns and villages, construction and provision of public
facilities and housing, supply of water, health services, etc.51 The
broad powers authorized here could be used to provide environmental
controls and occupational health protection for workers. Since indus-
trial activities are expanding into rural areas which could be classi-
fied remote and isolated, such regulation could promote environmental-
ly sound industrial operations.
E. Food and Drugs
With the Food and Drugs Decree 1974,52 food, drugs, cosmetics
and devices manufactured, sold, and advertised became a federal matter
and existing state laws in this area were repealed. This Decree is
mentioned only for its possible extension to some type of preliminary
hazardous substances or pesticide control when food is involved. The
Decree provides that no person shall sell any food which "has in it
or upon it any poisonous or harmful substance not being a food additive
or contaminant of a type, and within the level, permitted by regulation
. . . ."53 Arguably this could be used for some pesticide control
although it is unclear whether this extension could be upheld by legis-
lative intent.
F. Pesticides and Hazardous Substances
Except for the Food and Drug Decree mentioned above there is no
legislation in this area. Neither the federal nor state levels have
adequate pesticide or fertilizer regulations, registration or packaging
50 Labour Decree 1974 (Decree No. 21), Section 65.
51 Id., at Section 66.
52 Food and Drugs Decree 1974 (Decree No. 35).
53 Id., at Section 1(1) (a).
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requirements, or control over handling and use. The country has
expanded it use of chemicals in agriculture, and regulation is
becoming increasingly necessary.
G. General Pollution
The broad responsibility to "control pollution" at the grassroots
level is with Local Governments.54 The Local Government Edicts en-
acted by the States in 1976 authorize Local Government units to enact
bye-laws for the control of pollution. No such bye-laws were located
in the states visited and time did not permit research of other states.
But it is likely that this power could be used if Local Government
officials received some Federal and State guidance, technical expertise,
and financial support regarding possibilities.
H. Town and Country Planning
The States visited by the team had various arrangements for town
planning. Local town planning is generally under Local Government
units.55 Above this level, the State Governments generally have Plan-
ning Authorities, usually under the Ministry of Works. States have
used planning to varying degrees. For example, Kwara State estab-
lished three planning authorities for the entire state (one for every
four Local Governments). Following the master plans prepared for 102
communities in the State, these authorities are striving to organize
development projects in a systematic manner. In Oyo State, a State
Planning Authority approves citing for industrial states. While in
Kano, the planning functions have been assumed by the Ministry of
Works and Lands, and there appears to be no separate authority.
54 E.g., Oyo State Local Government Edict 1976 (Edict No. 5), Section
55 E.g., Id., at Section
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These authorities could play a significant role in influencing
and guiding development and the kind of environmental impact result-
ing therefrom. It will be important to recognize this sector when
developing Federal guidelines and State environmental programs.
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IV. Government Institutions with Environmentally Related Responsibiliites
A. Federal Ministries
Several Federal Ministries have
They include:
Ministry
Agriculture, Water, Resources,
and Rural Development
Health
Works, Housing and Urban
Development
Industries
Transport
environmental responsibilities.56
Area
agriculture, forestry,
fisheries, game reserves,
wildlife, rural development,
control of water resources
River Basin and Dam Development
and irrigation, development
of underground water, hydrology,
water supply undertaggings
Public Health, sanitation
Housing policy and
development, urban planning,
and development, lands,
protection of sea coast
against erosion
Pollution and other
environmental matters
Inland waterways,
navigation, ports
B. Parastatals
Several statutory corporations conduct activities relevant to
environmental protection. 57 The following were particularly discussed
during the team survey:
56 Federal Republic of Nigeria Official Gazette, Government Notice No.
1030, (16th July, 1975) pp. 1095-1102, as amended by recent reorgani-
zations .
57 Id.
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Organization
Responsibility Ministry
Activity
National Science and
Technology Devel.
Agency
Head of State
Research could
be applicable
to environmental
protecti on
matters
River Basin
Authorities
Agric., Water
Resources and Rural
Development, in
control pollution
Nigerian Standards
Organization
Industries
set standards
for quality
control of
products in
commerce and
industry
Nigeria National
Petroleum Corporation
regulation of
petroleum indus-
try.
C. Functions of Federal Division of the Environment
The Division of the Environment within the Federal Ministry of
Industries has responsibility for "the formulation of national environ-
mental protection policy; the formulation and monitoring of environmen-
tal standards for air, water, and land pollution, control of industrial
pollution including factory effluents and noise; control of refuse and
wastes disposal; coordination of State's programmes and activities on
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regional planning and environmental protection; setting up standards
for the control of outdoor advertisements and billboards; and for
sewage and sanitation in human settlements, natural landscapes, forestry,
58
game reserves and archeological sites." It also has responsibility
for evaluating the impact of urban development on the environment and
liaising with other affected Federal and State Ministries to ensure
planning and compliance with environmental control standards.59
These responsibilities have been established by Federal Executive
Council decision and lack the necessary statutory enforcement authority
in most areas.
D. Interministerial Environmental Groups
The Federal Executive Council directed in April 1977 that an
interministerial committee, comprising the Ministries of Housing,
Urban Development and Environment (Chairman), Health, Industries,
Water Resources, and Works should be formed to study environmental
pollution from industries. This Interministerial Committee was formed
and has since expanded in representation and subject matter. Now it
meets monthly, bringing information to the Director of the Division of
the Environment (Chairman) on activities in the technical ministries
of relevance to the Division's environmental mandate.
At one point, the establishment of a National Environmental Advisory
Committee was proposed. But this proposal has not yet been approved.
The interministerial Committee has been maintained and continues to
be active.
58 Functions and Organization of the Federal Ministry of Housing,
Urban Development and Environment, approved by Federal Executive
Council, 17th March 1976, pp. 4-5 dealing with environmental
functions transferred to Federal Ministry of Industries, December
16, 1977.
59 Id.
-------
V. Non-Governmental Groups with Environmental Interests
During meetings with Federal Nigerian officials, non-governmental
initiative in the environment were discussed. These discussions were
brief and by no means thorough. However the non-governmental activities
mentioned will be noted here. (This is not meant to be a comprehensive
account of all non-governmental activities underway.)
In February 1978, the launching ceremony was held for a national
conservation youth group called the National Union for the Conservation
of Nature and Natural Reources. Participation in this organization
focuses on secondary students and recent graduates. Since the organiza-
tion is just getting started, they are interested in project ideas.
The Federal Assistant Director of Forests gave the launching ceremony
address, and that department is encouraging the group as much as possi-
ble.
In 1976, a UNESCO-sponsored program for trainee teachers was
initiated. Called the Youth Environmental Programme for West Africa,
it is located at the Edujemi College of Education, acquired the services
of a UNESCO advisor in 1977, and is supported by the Federal Forestry
Department. Because time did not allow a visit with participants in
this programme, I was unable to gather information on specific projects
undertaken.
A National Committee of the World Wildlife Fund is in the planning
stages. This effort has been gaining local support since the early
1970's, and plans to officially launch its program in late 1979 or
early 1980. The pro-tem chairman of the group is Alhaji Chief S. L.
Edu, a distinguished and successful member of the Nigerian Business
communi ty.
-------
The World Wildlife Fund endorsement of a national chapter is
conditioned upon official endorsement of the effort by the Federal
Government. The Federal Commissioner for Agriculture, Rural Devel-
opment, and Water Resources, on behalf of the Federal Government,
has okayed the formation of the Committee; so the commitment has
been given. Through discussions with Chief Edu, it appears that plans
remain definite for establishment of the Committee, with the thrust
being in the conservation of natural resources. This group could have
substantial influence with government and the public. Where possible,
their participation and that of other non-governmental environmental
groups in environmental and natural resourece management issues could
be useful in formulating and implementing sound programmes.
During discussions at the University of Ife, it was noted that
there is an active Ecological Society of Nigeria, composed primarily
of members from the academic community. The Society is assisting to
sponsor a conference in 1979 on "Ecology and Development", which will
be coordinated by the University of Ife.
Finally, Nigeria has a Man and the Biosphere program (MAB), which
is sponsored by UNESCO. The organization is purely research oriented,
with participants coming from the Universities. University professors
take an area in wildlife or natural resources conservation and do
research on it. There is need for more applied research and to help
move toward this goal the Federal Forestry Department has been ap-
proved as a member.
-------
VI. Policy Developments
A. Third National Development Plan 1975-80
The Third National Development Plan includes a section on "Environ-
mental Policy."60 This section recognizes Nigeria's growing problems
in the environmental sector, both with respect to 'primary' environmen-
tal problems mainly attributable to underdevelopment (e.g., inadequate
water supply, waste disposal, etc.), and 'secondary' environmental dif-
ficulties generated in the process of accelerated developments (e.g.,
pollution). It calls for efforts to grapple effectively with these
problems and enhance the quality of life for all.
B. Fourth National Development Plan, 1981-86
Guidelines for preparation of the Fourth Development Plan call
for increased attention "on providing the infrastructure for environ-
mental assessment and management" particularly with respect to:
(i) Secondary Environmental Pollution --
especially with respect to industrial
activities as they affect water, land,
and air.
(ii) noise pollution.
(iii) natural disasters: - Floods, soil erosion,
and desert encroachment.61
60 Third National Development Plan 1975-80, Vol. 1, p. 292 (Central
Planning Office, Federal Ministry of Economic Development, Lagos).
61 Guidelines for preparation of Chapter 11, "Housing and Environmental
Development" for Fourth Plan period, environmental sections pp. 4-5,
(sent to all government ministries as official Government intent
for the plan period, copy available in office of Director of Federal
Division of Environment.)
-------
These guidelines also direct that the environmental characteris-
tics of the country will be documented to achieve a meaningful environ-
mental management program. Then based on this documentation, environmen-
tal quality standards will be proposed and made mandatory by legislation.
In addition the Department of Environment is called upon to
adopt guidelines to enhance environmental conservation and prevent
degradation. These guidelines shall include steps to ensure environmen-
tal planning as an integral part of all project planning by agencies.
In this regard the Government calls for the development of an
environmental impact statement process for the Fourth Plan period:
. . . [T]he feasibility studies for all projects,
both private and government, shall be accompanied by
an environmental impact statement.62
The guidelines provide that the onus will be on the owners of the
project to take account of the likely environmental impact and show
they have planned to mitigate it. Federal, State and local
governments will be required to set appropriate standards according
to any unique characteristics of the area. Finally, in the
guidelines, the Government calls for the development of "a strong
inspectorate unit" in the Federal Environmental Division.
62 Id., at 5.
-------
VII. The New Constitution
On 1st October 1979, a new constitution shall come into force in
Nigeria as the supreme law throughout the Federal Republic.63 It
establishes three branches of Federal Government: a federal National
Assembly (consisting of a Senate and a House of Representatives),
an Executive (with a President, Vice President and Ministers), and
the Judiciary (Federal and State courts).64 It also recognizes a
system of local government through democratically elected local govern-
ment councils.65
With respect to the environment, the new Constitution, in Chapter
II, lists Fundamental Objectives and Directive Principles of State
Policy. It provides that the State social order is founded on ideals
of freedom, equality and jtistice,-and that in furtherance of the social
order:
. . . exploitation of human or natural
resources in any form whatsover for reasons
other than the good of the community shall
be prevented; 66
Also, when discussing fundamental rights, the constitution provides
for compensation for any compulsory acquisition of property according
to specified procedures. But nothing in the provisions on compulsory
acquisition will be allowed to affect any general law:
. . . providing for the carrying out of
work on land for the purpose of soil-
conservation 67
63 Constitution of the Federal Republic of Nigeria (Enactment) Decree
1978, Decree No. 25, Schedule: The Constitution of the Federal
Republic of Nigeria 1979, section 279
64 Id., at sections 4-6.
65 Id., at section 7.
66 Id., at section 17(1) (d).
67 Id., at section 40(1) and (2) (L).
-------
That provision could have broad positive consequences in officially
endorsing and protecting soil-conservation programs, which include a
wide variety of measures in reforestation, water management, water-
sheds, agricultural practices, etc., to preserve and restore the
nation's land areas.
The Second Schedule to the Constitution consists of a list of
legislative powers. The exclusive Federal powers include regulation
of sea fishing, interstate navigation, meteorology, mines and minerals,
national parks, nationally significant archives, trade and commerce,
interstate waters, etc.68 Concurrent (Federal or State) powers include
regulation of electric power; industrial, commercial, or agricultural
development; scientific and technological research, etc.69 Functions
of the Local Government Councils include construction and maintenance
of roads, drains and other public facilities, provision and maintenance
of public conveniences and refuse disposal, development of agriculture
and natural resources, (other than exploitation of minerals), provision
of health services, regulation of sale of food to public, etc.70
This breakdown of powers and responsibilities highlights the need for
close coordination and consultation among all levels of government in
environmental protection and natural resource management matters.
Particularly Local Governments have significant impact as they deal
directly with the people in many priority environmental areas: e.g.,
health, sanitation, water disposal, agriculture, natural resources
management, etc. Both State and Local Governments should be consulted
and their participation integrated into the development of specific
regulatory schemes as much as possible for a responsive and successful
environmental protection program.
68 Id., at Second Schedule, Part I.
69 Id., at Second Schedule, Part II.
70 Id., at Fourth Schedule.
-------
APPENDIX III
EFFLUENT GUIDELINES AND EMISSION FACTORS
FOR
PULP AND PAPER
-------
Fr A'440/1-76/047-a
I oup I, Phase II
Development Document for Interim Final
and Proposed Effluent Limitations Guidelines
and Proposed New Source Performance
Standards for the
BLEACHED KRAFT, GROUND WOOD,
SULFITE, SODA, DEIN& AND
NON-INTEGRATED PAPER MILLS
PULP, PAPER, AND PAPERBOARD
Point Source Category
S7^
"ITED STATES ENVIRONMENTAL PROTECTION AGENCY
JANUARY 1976
Vol 1
Segment of the
-------
SECTION II
RECOMMENDATIONS
INTRODUCTION
The effluent limitations for existing sources are shown in Table 1 and
Table 2 for BPCTCA and BATEA, respectively. Standards of performance
for new sources are shown in Table 3.
The average of daily values for 30 consecutive days should not exceed
the maximum 3 0 day average shown in the tables. The value for any one
day should not exceed the daily maximum as shown in the tables. The
limitations and standards are in kilograms of pollutant per metric ton
of production (pounds of pollutant per short ton of production).
Effluents should always be within the pH range of 5.0 to 9.0.
For all of the wood pulping subcategories, the following allowances
for BOD5 and TSS should be added to BPCTCA effluent limitations for
mills with wet wocdyard operations as defined in Section IX:
Production in kkg (tons) is defined as annual tonnage produced from
pulp dryers (in the case of market pulp) and paper machines divided by
the number of production days in the 12 month period. Pulp production
is to be corrected, if necessary, to the "air dry'1 moisture basis.
Ammonia nitrogen effluent limitations will be developed at a later
date for ammonia base sulfite mills. Insufficient data exists to
determine representative ammonia nitrogen levels discharged by these
mills, but sparse data indicate that their effluents contain 1 to 3
kg/kkg (2 to 6 lb/ton) .
Color has been identified as a significant pollutant parameter for
sulfite mills but effluent limitations or standards have not been
established at this time. Sparse data indicate that effluents
discharged from these mills contain 200 to 250 kg/ kkg (400 to 500
lb/ton) of color. No technology is foreseen to be available prior to
1983 for removing color from these effluents and thus color removal by
sulfite mills is not practicable at this time.
Max 3 0 day
average
kq/kkq (lbs/ton)
Max daily
average
kq/kkq (lbs/ton)
B0D5
TSS
0.5 (1.0)
0.75(1.5)
0.9 (1.8)
1.6 (3.2)
3
-------
TABLE 1
Subcategory
BPCTCA
Effluent Limations In kg/kkgObs/ton)
Maximum 30 Day Averaqe
B0D5 TSS
Maximum Day
B0D5 TSS
35.85
29.4
28.05
23.0
44.6
49.5
Dissolving Kraft
13.35
(26.7)
19.3 (38.6)
25.65
(51.3)
Market Kraft
7.9
(15.8)
15.85(31.7)
15.2
(30.4)
BCT Kraft
6.95
(13.9)
15.1 (30.2)
13.35
(26.7)
Fine Kraft
5.7
(11.4)
12.4 (24.8)
10.95
(21.9)
Papergrade Sulfite
19.6
(39.2)
24.0 (48.0)
37.6
(75.2)
Market Sulfite
20.85
(41.7)
26.65(53.3)
40.0
(80.0)
Low Alpha
27.4 (54.8)
(85.8)
Dissolving Sulfite
22.35
(44.7)
42.9
High Alpha
33.65(67.3)
52.3 (
104.6)
Dissolving Sulfite
26.3
(52.6)
GW-Chemi-Mechani cal
7.05
(14.1)
10.45(20.9)
13.5
(27.0)
GW-Thermo-Mechanical
5.0
10.0
9.2 18.4)
9.6
(19.2
GW-CMN Papers
4.45
( 8.9)
7.9 (15.8)
8.55
(17.1)
GW-Fine Papers
4.0
( 8.0)
7.3 (14.6)
7.7
(15.4)
Soda
7.2
(14.4)
13.4 (26.8)
13.85
(27.7)
Deink
9.45
(18.9)
14.2 (28.4)
18.15
(36.3)
NI Fine Papers
4.25
( 8.5)
5.9 (11.8)
8.2
(16.4)
NI Tissue Papers
6.25
(12.5)
5.0 (10.0)
11.4
(22.8)
NI Tissue
(24.6)
Papers (FWP)
6.4
(12.8)
9.45(18.9)
12.3
(71 -)
(58 )
(56..)
(46 n)
(89 )
(99 )
50.85(101 )
62.5 (125.U)
19.45 (38 °)
17.05
14.7
13.5
24.8
26.35
11.0
10.25
pH for all subcategories shall be within the range 5.0 to 9.0.
(34
(29. )
(27.0)
(49 )
(52 )
(22.0)
(20 -)
17.6 (35.0
Zi nc*
Subcategory
6W:Chemi-mechanical
GW-Thermo-mechanical
GW:CMN Papers
GW:Fine Papers
Maximum 30 Day Average
kg/kkg(lbs/tonj
0.06
0.05
0.05
0.048
(0.12
(0.10)
(0.10)
(0.096)
Maximum Day
kg/kkqQbs/ton)
0.12 (0.24
0.105 (0.21
0.105 (0.21)
0.095 (0.19)
~Applicable only to mills using zinc hydrosulfite.
4
-------
TABLE 2
BATEA
Effluent Limitations in kg/kkg(lbs/ton)
Subcateqory Maximum 30 Day Average Maximum Day
80D5 TSS B0D5 TSS
Dissolving Kraft
5.8
11.6)
3.95(
7.9)
11.15
22.3)
7.35
14.7)
Market Kraft
3.55
7.1)
2.6 (
5.2)
6.8
13.6)
4.8
9.6)
BCT Kraft
3.0
6.0)
2.05 (
4.1)
5.8
11.6)
3.8
7.6)
Fine Kraft
2.55
5.1)
1.75(
3.5)
4.95
9.9)
3.25
6.5)
Pacergrade Sulfite
8.9
17.8)
3.0 (
6.0)
17.1
43.2)
5.6
11.2)
Market Sulfite
10.05
20.1)
3.45 (
6.9)
19.3
38.6)
6.4
12.8)
Low Alpna
12.5)
Dissolving Sulfite
11.4
22.8)
3.35(
6.7)
21.9
43.8)
6.25
High Alpha
17.6)
Dissolving Sulfite
13.8
27.6)
4.75 (
9.5)
26.5
53.0)
8.8
GW-Chemi-Mechanical
3.9
7.8)
1.65(
3.3)
3.15
6.3)
3.1
6.2)
GW-Thermo-Mechanical
2.1
4.2)
1.45 (
2.9)
4.05
8.1)
2.65
5.3)
GW-CMN Papers
1.85
3.7)
1.45 (
2.9)
3.55
7.1)
2.65
5.3)
GW-Fine Papers
1.75
3.5)
1.35(
2.7)
3.35
6.7)
2.55
5.1)
Soda
2.55
5.1)
1.75(
3.5)
4.95
9.9)
3.25
6.5)
Deink
2.6
5.2)
2.7 (
5.4)
5.05
10.1)
4.95
9.9)
NI Fine Papers
1.35
2.7)
0.7 (
1 -4)
2.6
5.2)
1.3
2.6)
NI Tissue Papers
2.15
4.3)
1.1 (
2.2)
4.15
8.3)
2.05
4.1)
NI Tissue Papers(FWP)
1.9
3.8)
1.0 (
2.0)
3.7
7.4)
1.85
3.7)
pH for all subcategories shall be within the range 5.0 to 9.0.
5
-------
TABLE 2 (cont.)
BATEA
Effluent Limitations in kg/kkg(1bs/ton)
Color
Subcategory Maximum 30 Day Average Maximum Day
kq/kkq(lbs/ton) kq/kkq(lbs/ton)
Dissolving Kraft
125 (250)
250
(500)
Market Kraft
95.0 (190)
190
(380)
BCT Kraft
65.0 (130)
130
(260)
Fine Kraft
65.0 (130)
130
(260)
Soda
65.0 (130)
130
(260)
Zinc*
Subcategory
GW:Chemi cal-mechani cal
6W:Thermo-mechanical
GW:CMN Papers
GW:Fine Papers
Maximum 30 Day Average
kg/kkg(1bs/ton)
0.048 (0.096)
0.0415(0.083)
0.0395(0.079)
0.0415(0.083)
Maximum Day
kg/kkg(lbs/ton)
0.095 (0.19)
0.085 (0.17)
0.085 (0.17)
0.075 (0.15)
~Applicable only to mills using zinc hydrosulfite,
6
-------
TABLE 3
Nl jOURCE PERFORMANCE STANDARDS
kg/kkg(lbs/ton)
Subcategory
Maximum 30 Day Averaae
TO TSS
Maximum Day
BOD TSS
Dissolving Kraft
6.1
12.2)
8.35
16.7)
11.75(23.5)
15.5 (31.0)
Market Kraft
2.55
5.3)
2.9
5.8)
5.15(10.3)
5.35(10.7)
3CT Kraft
3.7
7.4)
5.0
10.0)
7.05(14.1)
9.3 (18.6)
Fine Kraft
2.55
5.1)
3.75
7.5)
4.95( 9.9)
7.0 (14.0)
Papergrade Sulfite
4.65
9.3)
2.9
5.8)
8.95(17.9)
5.35(10.7)
Market Sulfite
4.65
9.3)
2.9
5.8)
8.95(17.9)
5.35(10.7)
Low Alpha
Dissolving Sulfite
11.15
22.3)
10.0
20.0)
21.45(42.9)
18.6 (37.2)
High Alpha
18.9)
Dissolving Sulfite
13.8
27.6)
9.45
26.5 (53.0)
17.6 (35.2)
GW-Chemi-Mechanical
3.9
7.3)
3.3
6.6)
7.5 (15.0)
6.15(12.3)
GW-Thermo-Mechamcal
2.3
4.6)
3.15
6.3)
4.45( 8.9)
5.85(11.7)
GW-CMN Papers
2.0
4.0)
3.15
6.3)
3.85( 7.7)
5.85(11.7)
GW-Fine Papers
1.9
3.8)
3.0
6.0)
5.6 ( 7.4)
5.6 (11.2)
Soda
3.15
6.3)
4.3
8.6)
6.0 (12.0)
7.95(15.9)
Deink
3.9
7.8)
4.0
8.0)
7.5 (15.0)
7.45(14.9)
NI Fine Papers
1.35
2.7)
1.4
2.8)
2.6 ( 5.2)
2.6 ( 5.2)
NI Tissue Papers
2.15
4.3)
2.2
4.4)
4.15( 8.3)
4.1 ( 8.2)
NI Tissue Papers(FWP)
1.9
3.8)
1.95
3.9)
3.7 ( 7.4)
3.65( 7.3)
pH for all
subcategories shall be within the range 5.0 to 9.0.
Zinc*
Subcategory
GW.Chemi-mechanical
GW.Thermo-mecham cal
GW:CMN Papers
GW-Fine Papers
Maximum 30 Day Average
kq/kkg(1bs/ton)
0.0-18 (0.095)
0.0455(0.091)
0.0455(0.091)
0.044 (0.088)
Maximum Day
kq/kkq(lbs/ton)
0.095 (0.19)
0.09 (0.18)
0.09 (0.18)
0.09 (0.18)
*Applicab 1e only to mills using zinc hydrosulfite.
7
-------
AP -42
Part
A
If
ACTORS
SECOND EDITION
(Third Printing with Supplements 1—5)
i ^'r
U.S. ENVIRONMENTAL PROTECTION AGENCY
Office of Air and Waste Management
Office of Air Quality Planning and Standards
Research Triangle Park, N.C. 27711
-------
10. WOOD PROCESSING
Wood processing involves the conversion of raw wood to either pulp pulpboard, or one of several types of
wjllbojrd uuluding plywood, parucleboard, or hardfaoard This scuion presents emissions data for chemical
wood pulping for pulpboard and plywood manufacturing and for woodworking operations The burning of wood
waste in boilers and conical burners is not included as it is discussed in Chapters I and 2 of this publication
10 I CHEMICAL WOOD PULPING Reused by Thomas Lahrc
10 1 1 General1
Chemical wood pulping involves the extraction of cellulose from wood by dissolving the hgnin that binds the
cellulose fibers together The principal processes used in chemical pulping are the kraft. sulfite, neutral sulfite
semii_hemical (NSSC), dissolving, and soda, the first three of these displjy the greatest potential for causing air
pollution The kraft process accounts for about 65 percent of ail pulp produced in the United States, the sulfite
and NSSC processes, together, account for less than 20 percent of the total The choice of pulping process is de-
termined by the product being made, by the type of wood species available, and by economic considerations
10 1.2 Kraft Pulping
10 1 2 1 Process Description1 -The kraft process (see Figure 10.1.2-1) involves the cooking of wood chips
under pressure in the presence of a cooking liquor in either a batch or a continuous digester The cookang liquor,
or "white liquor," consisting of an aqueous solution of sodium sulfide and sodium hydroxide, dissolves the lignin
that binds the cellulose fibers together
When cooking is completed, the contents of the digester are forced into the blow tank Here the major portion
of the spent cooking liquor, which contains the dissolved ligrun, is drained, and the pulp enters the rnitul stage of
washing From the blow tank the pulp passes through the knotter where unreacted chunks of wood are removed.
The pulp is then washed and, tn some mills, bleached before being pressed and dried into the finished product.
It is economically necessary to recover both the inorganic cooking chemicals and the heat content of the spent
"black liquor," which is sepjratcd from the cooked pulp Recovery is accomplished by first concentrating the
liquor to a level that will support combustion and then feeding it to a furnace where burning and chemical recovery
take place
Initial concentration of the weak black liquor, which contains about 15 percent solids, occurs in the multiple-
effect evaporator Here process steam is passed countercurrent to the liquor in a series of evaporator tubes that
increase the solids content lo 40 to 55 percent. Further concentration is then effected in the direct contact
evaporator This is generally a scrubbing device (a cyclonic or venturi scrubber or a cascade evaporator) tn svhich
hot combustion gases from the recovery furnace mix with the incoming black liquor to raise its solids content to
55 to 70 percent
The black liquor concentrate is then sprayed into the recovery furnace where the organic content supports
combustion The inorganic compounds fall to the bottom of the furnace and are discharged to the smelt dissolving
tank 10 form a solution called "green liquor " The green liquor is then conveyed to a causticizer where slaked
lime (calcium hydroxide) is jdded lo convert the solution bjck to white liquor, which can be reused in subsequent
cooks Residual lime sludge from the causticizer can be recycled after being dewatered and calcined in the hot
lime kiln
Many mills need more steam for process heating, for driving equipment, for providing electric power, etc , than
can be provided by the recovery furnace alone Thus, conventional industrial boilers thai burn coal, oil" natural
gas and in some cases, bark and wood waste aic commonly employed.
4/76
Wood 1'roccv.ing
10 l-J
-------
o
10
CHIPS
RELIEF
HEAT
NONCONDENSADLES
I CH3SH, CH3SCH3. H2S
EXCHANGER
t ,
n
ITS
O
2
-n
O
73
VJ
CH3SH, CH3SCH3, H2S
H2S, CH3SH, CH3SCH3,
AND HIGHER COMPOUNDS
NONCONDEHSABLES
0
0
z
0
m
OO
TO
H W.
ACCUM
TURPENTINE
CONTAMINATED WATER
PULP
FILTER
BLACK
LIQUOR
PULP 13% SOLIDS
SPENT AIR, CH3SCH3,"*"
AND CH3SSCH3
s.
WHITE
LIQUOR
CONTAMINATED
—- WATER
AIR
_L
STEAM, CONTAMINATED WATER,
j H2S, AND CII3SH
OXIDATION
TOWER
"O
o
zo
3>
-I
o
30
BLACK LIQUOR
50% SOLIDS
DIRECT CONTACT
EVAPORATOR
BLACK
Ua2$
Na OH
LIQUOR 70% SOLIDS^
CaO Na2S04
WATER
i
RECOVERY
FURNACE
OXIDIZING
ZONE
REDUCTION
ZONE
¦AIR
Na2S + Na2C03
-j
ON
Figure 10 1 2-1 Typical kraft sulfate pulping and recovery process
-------
10 1 2 2 Emission and Conirols1_6-Pariiculate emissions from the kraft process occur primarily from the re-
covery furnace, the lime kiln, and the smelt disserving tank These emissions consist mainly of sodium salts but
include some calcium salts from the lime kiln They are caused primarily by the carryover of solids plus the sub-
limation and condensation of the inorganic chemicals
Paniculate control is provided on recovery furnaces in a variety of ways In mills where either a cyclonic
scrubber or cascade evaporator serves as the direct contact evaporator, further control is necessary as these devices
are generally only 20 to SO percent efficient for particulates Most often in these cases, an electrostatic precipitator
is employed after the direct contact evaporator to provide an overall particulate control efficiency of 85 to 5s 99
percent In a few mills, however, a venturi scrubber is utilized a:, the direct contact evaporator and simultaneously
provides 80 to 90 percent particulate control In either case auxiliary scrubbers may be included after the
precipitator or the venturi scrubber to provide additional control of particulates
Particulate control on lime kilns is generally accomplished by scrubbers Smelt dissolving tanks jre commonly
controlled by mesh pads but employ scrubbers when further control is needed
The characteristic odor of the krjft mill is caused in large part by the emission of hydrogen sulfide The major
source 's the direct contact evaporator in which the sodium sulfide in the black liquor reacts with the carbon
dioxide in the furnace exhaust The lime kiln can also be a potential source as a similar reaction occurs involving
residual sodium sulfide in the lime mud Lesser amounts of hydrogen sulfide are emitted with the noncondensible
off-gasses from the digesters and multiple-effect evaporators
The kraft-processodor also results from an assortment of organic sulfur compounds, all of which have extremely
low odor thresholds Methyl mercaptan and dimethyl sulfide are formed in reactions with the wood component
lignin Dimethyl disulfide is formed through the oxidation of mercaptan groups derived from the ligmn These
compounds are emitted from many points w11hin a mill, however, the main sources are the digester/blow tank
systems and the direct contact evaporator
Although odor control devices, per se, are not generally employed m kraft mills, control of reduced sulfur
compounds can be accomplished by process modifications and by optimizing operating conditions For example,
bljck liquor oxidation systems, which oxidize sulfides into less reactive thiosulfates, can considerably reduce
odorous sulfur emissions from the direct contact evaporator, although the vent gases from such systems become
minor odor sources themselves Noncondensible odorous gases vented from the digester/blow tank system and
multiple-effect evaporators can be destroyed by thermal oxidation, usually by passing them through the lime
kiJn Optimum operation of the recovery furnace, by avoiding overloading and by maintaining sufficient oxygen
residujl and turbulence, significantly reduces emissions of reduced sulfur compounds from this source In addi-
tion, the use of fresh water instead of contaminated condensates in the scrubbers and pulp washers further reduces
odorous emissions The effect of any of these modifications on a given mill's emissions will vary considerably
Several new mills have incorporated recovery systems that eliminate the conventional direct contact evaporators
In one system, preheated combustion air rather than Hue gas provides direct contact evaporation In the other,
the multiple-effect evaporator system is extended to replace the direct contact evaporator altogether In both ot
these systems, reduced sulfur emissions from the recovery furnace/direct contact evapoiator reportedly can be
reduced by more than 95 percent from conventional uncontrolled systems
Sulfur dioxide emissions result mainly from oxidation of reduced sulfur compounds m the recovery furtucc
It is reported that (he direct contact evaporator absorbs 50 to SO peicent of these emissions, further scrubbing, if
employed, can reduce them another 10 to 20 percent
Potentj.il -.ourccs o/ carbon monoxide emissions from the kraft process include the recovery furnace and lime
kilns The m.i|or cause of carbon monoxide emissions is furnace operation well above rated capacity, nuking it
impossible in inainiam oxidizing conditions.
4/77
Wood Processing
10 1-3
-------
Some nitrogen oxides are also emitted from the recovery furnace and lime kilns although the
amounts are relatively small Indication® are that nitrogen oxides emissions) from each of these sources
are on the order of 1 pound per air-dried ton (0 5 kg/air-dried NIT) of pulp produced.5 6
A major source of emissions in a kraft mill is the boiler for generating auxiliary steam and povver.
The fuels used are coal, oil, natural gas, or bark/wood waste Emission factors for boilers are presented
in Chapter 1.
Table 10 1 2-1 presents emission factors for a conventional kraft mill The most widely used
particulate controls devices are shown along with the odor reductions resulting from black liquor
oxidation and incineration of noncondensible off-gases.
10.1.3 Acid Sulfite Pulping by Tom Lahre
10 13 1 Process Description14 - The production ol acid sulfi te pulp proceeds similarly to kraft pulp-
ing except that different chemicals are used in the cooking liquor. In place of the caustic solution used
to dissolve the lignin in the wood, sulfurous acid is employed. To buffer the cooking solution, a bisul-
fite of sodium, magnesium, calcium, orammonium is used. A simplified flow diagram of a magnesium-
base process is shown in Figure 10.1.3-1.
Digestion is carried out under high pressure and high temperature in cither batch-mode or con-
tinuous digesters in the presence of a sulfurous acid-bisulfite cooking liquor. When cooking is com-
leted, the digester is either discharged at high pressure into a blow pit or its contents are pumped out
at a lower pressure into a dump tank. The spent sulfite liquor (also called red liquor) then drains
through the bottom of the tank and is either treated and disposed, incinerated, or sent to a plant for
recovery of heat and chemicals. The pulp is then washed and processed through screens and centri-
fuges for removal of knots, bundles of fibers, and other materials. It subsequently may be bleached,
pressed, and dried in paper-making operations
Because of the variety of bases employed in the cooking liquor, numerous schemes for heat and/or
chemical recovery have evolved. In calcium-base systems, which are used mostly in older mills, chemi-
cal recovery is not practical, and the spent liquor is usually discarded or incinerated In ammonium-
base operations, heat can be recovered from the spent liquor through combustion, but the ammonium
base is consumed in the process In sodium- or magnesium-base operations heat, sulfur, and base
lecoverv are all feasible
If recovery is practiced, the spent weak red liquor (which contains more than half of the raw
ma term Is as dissolved organic solids) is concentrated in a multiple-effect evaporator and direct contact
evaporator to 55 to 60 percent solids. Strong liquor is sprayed into a furnace and burned, producing
steam for the digesters, evaporator;., etc , and to meet the mills power requirements
hen magnesium base liquor is burned, a flue gas is produced from which magnesium oxide is
rccovered in a multiple tvclone as fine white powder The magnesium oxide is then water-sluked ami
used as cir< ulating liquor in a series of venturi scrubbers which are designed to absorb sulfur dioxide
from the flue gas and form a bisulfite solution for use in the cook cycle. When sodium-base liquor is
burned, the inorganic compounds are recovered as a molten smelt containing sodium sulfide and
sodium carbonate This smelt may be processed further and used to absorb sulfur dioxide from the
flue ga-> and »u I fur burner In some sodium-base mills, however, the smell may be sold to a nearby kraft
mill .is raw material for producing green liquor
10 1-1 EMISSION F VCTORS 4/77
-------
-1
-1
*
o
o
*0
T
0
n
n
tti
t/>
05
©
t—l
cn
Table 10 1.2-1. EMISSION FACTORS FOR SULFATE PULPING3
(unit weights of air-dried unbleached pulp)
EMISSION FACTOR RATING A
Source
Type
control
Particulates'1
Sulfur
dioxide (SO?)0
Carbon
monoxided
Hydrogen
sulfidelS1!0
RSH,RSR,
RSSRfS")0''
lb/ton
kg/MT
lb/ton
kg/MT
lb/ton
kg/MT
lb/ton
kg/MT
lb/ton
kg/MT
Digesier retlef and
UntreatedS
—
—
—
—
—
—
0 1
0 05
1 5
0 75
blow tank
Brown stock washers
Untreated
_
_
0 01
0 005
_
—
0.02
0 01
0 2
0 1
Multiple effect
Untreated^
—
—
0 01
0 005
—
—
0 1
0 0^
0 4
0 2
evaporators
Recovery boiler and
Untreated ^
150
75 ,
5
2 5
2 - 60
1 - 30
12'
6'
V
0 51
direct contact
Venturi
47
23 5
5
2 5
2 - 60
1 - 30
121
61
1'
0 5*
evaporator
scrubber!
121
Electrostatic
8
4
5
2 5
2 - 60
1 - 30
61
I1
0 51
precipitator
l.
Auxil lary
3 - 1 5k
1 5-7 5k
3
1 5
2 - 60
1 - 30
121
61
11
0 5'
scrubber
Smelt dissolving
Untreated
5
2 5
0 1
0 05
—
—
0 04
0 02
0 4
0 2
tank
Mesh pad
1
0 5
0 1
0 05
—
—
0 04
0 02
0 4
0 2
Lime kilns
Untreated
45
22 5
0 3
0 15
10
5
0 5
0 25
0 25
0 125
Scrubber
3
1.5
0 2
0 1
10
5
0 5
0 25
0 25
0 125
Turpentine
Untreated
—
—
—
—
—
—
0 01
0 005
0 5
0 25
condenser
Miscellaneous
Untreated
—
—
—
—
—
—
—
-
0 5
0 25
sources1
For more detailed data on specific types of mills, consult Reference 1.
^References 1, 7. 8
cReferences 1, 7. 9, 10
^References 6. 11 Use higher value for overloaded furnaces.
References 1. 4, 7-10, 12. 13 These reduced sulfur compounds are usually expressed as sulfur.
'rSH methyl mercaptan, RSR-dimethyl sulfide. RSSR-dimethyI disulfide
9lf the noncondensible gases from these sources are vented to the lime kiln, rocovery furnace, or equivalent, the reduced sulfur compounds
are destroyed .
^These factors apply when either a cyclonic scrubber or cascade evaporator is used for direct contact evaporation with no further controls.
'These reduced sulfur compounds (TRS) are typically reduced by 50 percent when black liquor qxiddtion is employed but can be cut by 90 to
99 percent when oxidation is complete and the recovery furnace is operated optimally
'These factors apply when a venturi scrubber is used for direct contact evaporation with no further controls.
Use 15(7 5) when the auxiliary scrubber follows a venturi scrubber and 3(1 5) when employed after an electrostatic precipitator
'insludes knolter vents, biownstock seal tanks, etc When black liquor oxidation is included, a factor of 0 6(0 3) should bo used
-------
RECOVERY FURNACE/
ABSORPTION STREAM
EXHAUST
m
IS!
if)
J.
>
n
~j
j
o
s
w
WOOD
CHIPS DIGESTER
STEAM FOR
PROCESS AND POWER
->
-1
Figure 10 1 3-1. Simplified process flow diagram of magnesium-base process employing
chemical and heat recovery.
-------
If recovery is nol practiced, an acid plant of sufficient capacity to fulfill the mill's total sulfii
requirement is necessary Normally, sulfur is burned in a rotary or spray burner The gas produced i
then cooled by heat exchangers plus a water spray and then absorbed in a \ arietv of different scrubbei
containing either limestone or a solution of the base chemical. Where recover* is practiced, fortific.
tion is accomplished similarly, although a much smaller amount of sulfur dioxide must be produce
to make up for that lost in the process.
10 1.3 2 Emissions and Controls14 - Sulfur dioxide is generally considered the major pollutant <
concern from sulfite pulp mills. The characteristic "'kraft" odor is not emitted because volatile r>
duced sulfur compounds are not products of the hgnin-bisulfite reaction
One of the major SO; sources is the digester and blow pit or dump tank system. Sulfur dioxide
present in the intermittent digester relief gases as well as in the gases given off at (he end of the coo
when the digester contents are discharged into the blow pit or dump tank The quantity of sulfur ovu.
evolved and emitted to the atmosphere in these gas streams depends on the pH of the cooking Iiijuo
the pressure at which the digester contents are discharged, and the effectiveness of the absorptio
svstems employed for SO: recovery Scrubbers can be installed that reduce SO: from this souice by .
much as 99 percent.
Another source of sulfur dioxide emissions is the recover) system Since magnesium-, sodium-, an
ammonium-base recovery systems all utilize absorption systems to recover SO; generated in the r.
cover) furnace, acid fortification towers, multiple-effect evaporators, etc , the magnitude of S(
emissions depends on the desired efficiency of these systems. Generally, such absorption svsten
provide better than 95 percent sulfur recovery to minimize sulfur makeup needs
The various pulp washing, screening, and cleaning operations are also potential sources of SC
These operations are numerous and may account for a significant fraction of a mill's SO; emission*,
not controlled
The only significant particulate source in the pulping and recovery process is the absorption svsto
handling the recovery furnace exhaust Less particulate is generated in ammonium-base svstems th.
magnesium- or sodium-base systems as the combustion productions are mostly nitrogen, water v.ipo
and sulfur dioxide
Other major sources of emissions in a sulfite pulp rntil include the auxiliary power boilers hmi
sion factors for these boilers are presented in Chapter 1.
Emission factors for the various sulfite pulping operations are shown in Table 10 1.3-1.
10 14 Neutral Sulfite Semichtmical (NSSC) Pulping
10 I 4 1 Process DescriptionI»7'IS'16 - In this process, the wood rhipsare cooked in a neutral solution i
sodium sulfite and sodium bii at horuite The sulfile ion reacts with the ligmn in the wood, and 11
sodium bicarbonate acts as a buffer to maintain a neutral solution The major difference betw ecu th
process (.is well as all semichenucal techniques) and the kraft and acid sulfite processes lli.il onlv
portion of the lignin is removed during the cook, after which the pulp is further reduced hv median
cal d is integral i on Bern use of this, yields as high as 60 to 80 percent can lie achiev ed as opposed lo 50 l
55 percent for other chemical processes.
1/77
Wood Prorr^iiif;
10.1
-------
Table 10.1.3-1. EMISSION FACTORS FOR SULFITE PULPING3
Source
Base
Conn ol
Emission factor*5
Emission
factor
rating
Part,cul3te
Sulfu
Dioxide
Ib/ADUT
¦ kg/ADUMT
Ib/ADUT
kg/ADUMT
Digester diow D't 01
Neg^
dumo lankC
All
None
Neq
10 70
5 35
C
MgO
Piocess changee
Neg
Neg
26
1 3
c
MgO
Soubbei
Neg
Neg
1
0 5
B
MgO
Piocess change
and scruboe«
Neg
Neg
02
0 1
B
MgO
All exhaust
vented through
Neg
Neg
0
0
A
recovery system
NH3
Process change
Neg
Neg
25
12 5
D
nh3
Process change
Neg
Neg
0 4
0 2
B
and scruboer
Na
Process chanqe
and scruober
Neg
Neg
2
1
C
Cd
Unknown
Neg
Neg
67
33 5
C
Recovery wsiem'
MgO
Muliiclone ana
2
9
4 5
A
ventun
scrubbers
NH3
Ammonia
0 7
0 35
7
3 5
B
absorption and
mist eliminator
Na
Sodium carbonate
4
2
2
1
C
SCruobei
Actd plant^
NH3
Scrubber
Neg
Neg
03
02
C
Unknown^1
Neg
Neg
0 2
0 1
0
Ca
Jenssen
Neg
Neg
8
4
c
scrubber
Other sources'
All
None
Neg
Neg
12
6
0
aAII emission factors represent long-term average emissions
''Factors expressed in terms of lb (kg) of pollutant per air dried unbleached ton (MT) of pulp All factors are based on data
in Reference 14
cThese factors represent emissions that occur after the cook is completed and when the digester contents are discharged in-
to the blow pit or dump tank Some relief gases are vented from the digester during the cook cycle, but these are usually
transferred to pressure accumulators, and the SO2 therein is reabsorbed for use in the cooking liquor These factors repre-
sent long-term average emissions, in some mills, the actual emissions will be intermittent and for short time periods
^Negligible emissions
eProcess changes may include such measures as raising the pH of the cooking liquor, thereby lowering the free SO2, reliev-
ing the pressure in the digester before the contents are discharged, and pumping out the digester contents instead of blow-
ing ihem out
'The recovery system at most mills is a closed system that includes the recovery furnace, direct contact evaporator, multi-
ple effect evaporator, acid fortification tower, and SO? absorption scrubbers Generally, there will only be one emission
point for the entire recovery system These factors are long-term averages and include the high SO2 emissions during the
periodic purging of the recovery system
"Acid plants are necessary in mills that have no or insufficient recovery systems
^Control is practiced, but type of control is unknown
1 Includes miscellaneous pulping operations such as knotters, washers, screens, etc
10.1-8
EMISSION FACTORS
4/77
-------
I lit. NSS( pnncss v.mcs 11hiii mill lo mill Sonic mills dispose. <>1 Ificir spent liquor some mills recover thi
11 ink 1111; c lie 11 ik.lis .mil some, which .lie opera led in eoiijunel n in witli krall nulls, mix I heir '-.pent liquor wilh tin
ki ill lii|iiui .is .1 soiiicc ill 11i.ike11p elieinie.ils When recovery is practiced, llic steps involved parallel those of thi
slilllk pinciss
10 14 J I missions .mil ('onIlols 1 Pirticulale emissions jrc j potential problem only when recover
sysknis ,ne employed Mills lli.il do pr iclicc recovery btil jre not operjled in conjunction with kraft operation
olii n nlili/c llmdi/ed lied te.iclois lo burn their spent liquor liecjuse (he Hue gas contains sodium sulfate anc
stidiiiin c.iiboii.ite dust, ellicicni p.irticul.ite collection may be included lo facilitate chemical recovery
A poic'iili.il gaseous pollutant is sulfur dioxide I lie absorbing towers, digester/blow lank system, and recover)
linii.ice aie the ui.im souices ol tins pollutant with the amounts emitted dependent upon the capability of the
seiiibhmg devices installed lor control and recovery
Hydrogen sulfide can also be emitted Irom NSSC nulls using krafl-typc recovery furnaces The main potcntia
sniiiej is ilie absorbing tower where a significant quantity of hydrogen sulfide is liberated as the cooking liquor p
made Other possible sources include the recovery furnace, depending on the operating conditions maintained, a
well as die digestcr/blow tank system in mills where some green liquor is used in the cooking process Where greer
liquor is used, it is also possible that significant quantities of mcreaptans will be produced Hydrogen sjlficji
emissions can be eliminated if burned to sulfur dioxide prior to entering the absorbing systems
Because the NSSC process differs greatly from mill to mdl, and because of the scarcity of adequate data, nc
emission factors are presented
References for Section 10 1
1 llcndriekson, t R et al Control of Atmospheric Emissions in the Wood Pulping Industry Vol 1 U.S
Department of llealih, Lducation and Welfare, PUS, National Air Pollution Control Administration, Wash
ington.DC Final report under Contract No CPA 22-69-I8 March 15,1970
2 Britt, K W Handbook of Pulp and Paper Technology New York, Remhold Publishing Corporation, 1964
p 166-200
3 llcndriekson, |£ R et al Control of Atmospheric Emissions in the Wood Pulping Industry Vol III US
Department of Health, Education, and Welfare, PHS, National Air Pollution Control Administration, Wash-
ington, DC Final report under Contract No CPA 22-69-18 Mjrch 15, 1970
4 Walthcr, J E and H R Amberg Odor Control in the Kraft Pulp Industry Chem Cng Progress 66 73
80, March 1970
5 Galcano, S T and K M Leopold A Survey of Emissions of Nitrogen Oxides in the Pulp Mill TAPPI
56(3) 74-76, March 1973
6 Source test dat i from the Olficc of Air Quality Planning and Standards, US Enviionmcnt.il Protection
Agency, Research Triangle Paik, N C 1972
7 Almnsphcnc 1 missions from the Pulp and Paper Manufacturing Industry US Envnonmenlal Protectioi
Agency Research I riangle Paik, N C Publication No EPA-J50/ 1 -73-002 September 1973
1-/77
Wood Processing
JO. 1-9
-------
* LSI <>\sur R O and H B Cooper Particulate Matter Reduction Trends in the Kraft Industry NCAS1 paper,
( urvjllis Oregon
9 Padficld D H Control of Odor Irom Recovery Units by Direct-Contact Evaporative Scrubbers with
0\idi/cd ULck Liquor TAPP! 56 83-S6, January 1973
10 Wjlthcr, J t and H R Amberg Emission Control at the Kraft Recovery Furnaces TAPPI .5.5(3) i ]85-
I 188 August 1972
11 Control Techniques for Carbon Monoxide Emissions from Stationary Sources U.S Department of Health
Education and Welfare, PHS, National Air Pollution Control Administration, Washington, DC. Pubbcation
No \P 65 March 1970 p 4-24 and 4-25
12 Blosser, R 0 ct al An Inventory of Miscellaneous Sources of Reduced Sulfur Emissions from the Kraft
Pulping Process (Presented at the 63rd APCA Meeting St Louis June 14-18, 1970 )
13 Factors Affecting Emission of Odorous Reduced Sulfur Compounds from Miscellaneous Kraft Process
Sources NCASI Technical Bulletin No 60 March 1972
14 Background Document Acid Sulfite Pulping Prepared by Environmental Science and Engineering, Inc.,
Gainesville, Fla , for Environmental Protection Agency under Contract No. 68-02-1402, Task Order No 14
Document No EPA-450/3-77-005 Research Triangle Park, N.C. January 1977.
15 Benjamin, M et al A General Description of Commercial Wood Pulping and Bleaching Processes J Air
Pollution Control Assoc. 19(3) 155-161, March 1969
16 Gjleano S F and B M Dillard Process Modifications for Atr Pollution Control in Neutral Sulfite Senu-
Cheinicai Mills J Air Pollution Control Assoc 22(3) 195-199, March 1972
10 1-10
EMISSION FVCTOIIS
4/77
-------
10 2 PULPBOARD
10 2 1 General'
Pulpboard manufacturing involves the fabrication of fibrous boards fruni a pulp slurry This includes two dis-
tinct types of product, paperboard and fiberboard Paperboard is a general term ihjl describes a shcci 0 012 inch
(0 30 mm) or more in thickness nude of fibrous material on j papcr-lorming machine 2 Fiberboard, jlso referred
to as particle board, is thicker than paperboard and is made somewhat differently
There are two distinct phases in the conversion of wood to pulpboard (I) the manufacture of pulp from raw
wood and (2) the manufacture of pulpboard from the pulp This section deals only with the latter as the former
is covered under the section on the wood pulping industry
10 2 2 Process Description1
In the in .uufacture of paperboard, the stock is sent through screens into (he head box from which it flows
onto a mowig screen Approximately IS percent of the water is removed by suction boxes located under the
screen Another SO to 60 percent of the moisture content is removed in the drying section The dried board
then enters the calendar stack, which imparts the final surface to the product
In the manufacture of fiberboard, the slurry that remains after pulping is washed and sent to the stock chests
where sizing is added The rellned fiber from the stock chests is fed to the head box of the Doard machine The
stock is next fed onto the forming screens and sent to dryers, after winch the dry product is finally cut and
fabricated.
10 2 3 Emissions1
Emissions from the paperboard machine consist mainly of water vapor little or no particulate matter is emit-
ted from the dryers 3-5 Particulates are emitted, however, from the fiberboard drying operation Additional
particulate emissions occur from the cutting and sanding operations. Emission factors for these operations are
given in section 10 4 Emission factors for pulpboard manufacturing are shown in Table 10.2-1.
Table 10 2-1. PARTICULATE EMISSION FACTORS FOR
PULPBOARD MANUFACTURING3
EMISSION FACTOR RATING E
Emissions
Type of product
fb/ton
kg/MT
Paperboard
Neg
Neg
F iberboard15
06
03
^Emission factors expressed as units per unti we70
2 The Dictionary o! P iper New Yoik \inertcJi) Pjpcr and Pulp Association 1940
4/76
EMISSION FACTORS
10 2-1
-------
3 llouyh G W jnd L J Gross Air tnmsion Control in a Modern Pulp and Pjper Mill Aincr Paper Industry
51 36, February 1969
4 Pollution Control Progress J Air Pollution Control Assol 17 410. June 1967
5 Private lommumution between I Gellinan and the National CouikiI of the Paper Industry for Clean Air
and Stream Improvement New York October 28. 1969
10 2-2
Wood Proceviiiii;
4/76
-------
10 3 PLYWOOD VENEER AND LAYOUT OPERATIONS
By Vuimus l.ahrc
103 1 Process Description1
Plywood is j material made of several thin wood veneers bonded together with an adhesive Its uses arc many
and include wall hidings, sheathing, roof-decking, concrete-iormboards, floors and containers.
During the manufacture of plywood, incoming logs are sawed to desired length, debarked, and then peeled
into thin, continuous veneers of uniform thickness (Veneer thicknesses of 1/45 to 1/5 inch are common )
These veneers are then transported to special dryers where they are subjected to high temperatures until dried to
a desired moisture content After drying, the veneers are sorted, patched, and assembled in layers with some
type of thermosetting resin used as the adhesive The veneer assembly is then transferred to a hot press where,
under presssure and steam heat, the plywood product is formed Subsequently, all that remains is trimming,
sanding, and possibly some sort of finishing treatment to enhance the useluliness of the plywood
10 3 2 Emissions2 3
The main sources of emissions from plywood manufacturing are the veneer drying and sanding operations
A third source is the pressing operation although these emissions are considered minor
The major pollutants emitted from veneer dryers are organics These consist of two discernable fractions
(1) condensibles, consisting of wood resins, resin acids, and wood sugars, which form a blue haze upon cooling
in the atmosphere, and (2) volatiles, which are comprised of terpines and unburncd methane—the latter occurring
when gas-fired dryers are employed The amounts of these compounds produced depends on the wood species
dned, the drying time, and the nature and operation of the dryer itself In addition, negligible amounts of fine
wood fibers are also emitted during the drying process
Sanding operations arc a potential source of particulate emissions (see section 10 4) Emission factors for ply-
wood veneer dryers without controls are given in Table 10 3-1.
Table 10 3-1 EMISSION FACTORS FOR PLYWOOD MANUFACTURING
EMISSION FACTOR RATING B
Organic compounda-b
Coridcnsible
Volatile
Source
lb/10' ft3
kg/103 m2
lb/104 ft2
kg/103 m"
Veneer dryers
36
1 9
2 1
1 1
aEmission factors i-xpresscd m pounds ol pollutant per 10,000 square feci of 3/8 in plywood produced (kilograms per 1,000
square meters on j l-cm basis)
bRelerences 2 and 3
4/76
EMISSION FACTORS
10 3-1
-------
References for Section 10 J
1 Hemming C B Lncyclopedia of Chemical Technology 2nd kd Vol 15 New York John Wiley and Sons
IOhS pS%-407
2 Monroe, I- L et al Investigation of Emissions from Plywood Veneer Dryers Final Report Washington
Slate University Pullman Washington Prepared for the Plywood Research Foundation and the US Ln
vnonmcntal Protection Agency Research Triangle Park. N C Publication No APTD-1 144 February 1972
3 Mick Allen and Dean McCargar Air Pollution Problems in Plywood Particleboard and Hardhoard Mills in
the Mid-Willamette Valley Mid-Willamctic Valley Air Pollution Authority, Salem Oregon March 24, 1969
-------
APPENDIX IV
REFUSE MANAGEMENT IN DEVELOPING COUNTRIES
A. Objectives
The objectives of the refuse program are to promote the protection
of health and the environment by:
1. Providing technical and financial assistance to State and
local governments and agencies for the development of refuse
management plans which will promote improved refuse management
techniques (including more effective organizational arrangements),
new and improved methods of collection, processing, or recovery of
refuse and the environmentally safe disposal of refuse.
2. Providing grants for the design, construction, acquisition,
and maintenance of refuse systems, equipment and facilities.
3. Prohibiting future open dumping on the land and requiring the
conversion of existing open dumps to sanitary landfills which do
not pose a danger to the environment or to health.
4. Regulating the transportation and disposal of hazardous or
industrial wastes which have adverse effects on health and the
environment.
5. Providing for the promulgation of rules, regulations, and
guidelines for solid waste collection, transport, separation,
recovery, and disposal practices and systems.
6. Promoting a national research and development program for
improved solid waste management and resource conservation techniques,
more effective organizational arrangements, and new and improved
-------
methods of collection, processing, and environmentally safe disposal
of refuse and non-recoverable residues.
7. Promoting the demonstration, construction, and application of
refuse or solid waste management practices which preserve and
enhance the quality of the environment.
8. Establishing a cooperative effort among the Federal, State,
and local governments and their designated agencies.
9. Instituting a permit or licensing system for private haulers
or industrial, commercial or hazardous wastes to insure that the
refuse is disposed in a sanitary landfill and is not dumped in a
promiscuous manner.
Definitions
1. The term "refuse or solid waste" means any garbage, refuse,
sludge from a waste treatment plant, water supply treatment plant,
or air pollution control facility and other discharged material,
including solid, liquid, semi-solid, or contained gaseous material
resulting from industrial, commercial, mining, and agricultural
operations, and from community activities.
2. The term "refuse management" means the systematic administration
of activities which provide for the collection, separation, storage,
transportation, transfer, processing, treatment and disposal of
refuse.
3. The term "refuse facility" includes: a) any collection, pro-
cessing or resource recovery system or component thereof; b) any
system", program, or facility for resource conservation and; c) any
facility for the treatment of refuse including hazardous wastes,
whether such facility is associated with facilities generating such
waste or otherwise.
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4. The term "refuse planning" includes refuse management, compre-
hensive planning, implementation planning, or management, as well
as guidelines, rules, regulations, and agreements which further the
objectives.
5. "Hazardous waste" means any refuse or combination of refuse or
solid wastes which, because of its quantity concentration, physical,
chemical, or infectious character, may cause or significantly
contribute to an increase in serious irreversible, or incapacitating
reversible, illness; or pose a substantial present or potential
hazard to human health or the environment when improperly treated,
stored, transported, or disposed of, or otherwise managed.
Refuse Collection-Disposal Guidance
Refuse management is the orderly process of picking up from many
locations the discards of a community and hauling them off to a
processing or disposal site. The objectives of the collection
disposal cycle should be to: 1) protect the health and aesthetic
conditions of the community by collecting and disposing of refuse
in a sanitary fashion; 2) provide a desired level of service in
terms of frequency and point of collection on a continuing basis
and 3) achieve these objectives with the highest productivity at
the least cost to the government.
By definition, increased productivity means more tons collected
per hour with the same or less labor. Generally, this will result
in the lowest cost. Many people think the only means to increase
productivity is for laborers to work harder. In general, this is
not true. Higher productivity can be achieved in almost any refuse
system through the correct policy decisions and improved management
techniques in operations.
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Primary management decisions affecting productivity are: 1) system
policies on method of collection and funding; 2) equipment selection;
3) vehicle routing - scheduling; 4) distance and time to the
disposal site and 5) management of the operation.
Collection Methods and Funding Policies
The initial decisions on the type of collection-disposal practices
should be predicated on the long-range funding commitment by the
local government to operate the system. In many instances, local
governments have acquired vast amounts of new equipment, but did
not make provision for the follow-up on funding to adequately maintain
and operate the collection disposal system. It is not unreasonable
to assume that annual operating costs will be about equal to the
initial capital investment made m the equipment. Thus, a city
purchasing two million dollars worth of new trucks must also plan
on spending two million dollars annually over the next five years
for labor, repairs, maintenance insurance, overhead and administrative
costs. In a typical U.S. collection system, costs for various
functions are: labor 60 percent; maintenance and truck operation
20 percent; depreciation 10 percent and administration 10 percent.
In the U.S., collection costs are generally 85 percent of total
collection-disposal costs and the land disposal aspects accounts
for only 15 percent of system costs.
The higher the annual operating budget, the higher can be the level
of service to the citizens. Cities with high budgets often have
twice a week household collection from the backyard, whereas cities
with lower budgets have once a week curbside collection.
An overlooked fact in the U.S. refuse collection-disposal cycle is
that 15 percent of the U.S. refuse, generally in rural areas, is
not house to house collection. The homeowner in these communities
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5
must transport or carry their waste to a centralized location for
bulk bin collection. Often, the bi/lk bins are 1-5 miles from the
residents homes.
Very few governments in developing nations are affluent enough to
afford a high level of refuse collection service. Therefore, bulk
bin collection appears to be least costly, most productive means of
collection, and ordinary sanitary landfilling the least costly means
of disposal. The following table of average U.S. collection-
disposal costs is presented to help decision makers understand the
economics of various collection-disposal options and their costs.
1. Type of Refuse and Generation Rates
In general, the more affluent a community, the more waste is
generated. While the U.S. generation rate of citizens is 2.75
pounds per person a day, a good typical generation rate in
developing nations is 0.5kg or about 1 pound per person per
day. Another big variation is type of waste. In the U.S.,
about 75 percent of the waste is inorganic or combustible
materials, whereas in developing nations, about 75 percent of
the waste stream is organic or vegetable matter. The weight
of uncompacted organic refuse is 400 pounds per M or about 3
times greater than inorganic refuse. Therefore, the type,
size, and kind of equipment utilized for collection and disposal
of organic wastes should take this into consideration. For
example, compacting inorganic waste to 500 kg per cubic yard
is difficult, whereas compacting organic wastes in devloping
nations to the same density is not difficult. Naturally, the
heavier density of organic wastes will influence the size and
type of truck, (chassis, frame, axles and body) needed to do
the job.
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6
U.S. Average Costs Per Ton For Various
Refuse Options 1978
(Costs include Interest and Depreciation on Capital)
Activity Dollars per ton Ratio to landfill costs
Landfilling 4.15 1.0
Collection
(individual houses) 32.00 7.7
Collection Bulk Bins
(a) Rear Loaders 6M3 24.25 5.8
(b) Front Loaders 6M3 13.00 3.1
(c) Tilt Frames 26M3 6.00 1.4
Transfer Station to
Landfill 6.40 1.5
(17 mile-l way distance)
Incinerators 30.00 7.2
(80 percent organics)
Incinerators-Supplemental
Fuel 48.00 11.5
(80 percent inorganics)
L(
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7
In developing nations, the large amount of organic material
and its corresponding density have not always been understood
in selection of equipment. For example, three men can usually
lift a barrel of inorganic material into a packer truck,
whereas a barrel full of organic matter cannot be lifted into
a truck. However, organic waste is more dense than inorganic
waste, thus compaction and blowing or loose refuse is not a
serious problem. Thus, the weight and density of vegetable
wastes is a contributing factor to utilizing bulk mechanical
collection of refuse in developing countries.
2. Door to Door Collection
This is the highest level of service a community can provide
its citizens. It is also the most expensive, about $45 per
household per year or $30 a ton. It assumes every citizen or
household has a container, or purchases plastic bags, that
trucks can maneuver down the streets, and a dependable, highly
organized labor force is available for collection. About 75
percent of the U.S. is collected once a week at the curb. For
those affluent citizens in the U.S., as well as developing
nations who desire a higher level of service, such as more
frequent collection or backyard carryout service, it is
customary to contract with private haulers of the refuse and
pay a higher price direct to the hauler for the higher level
of service. This same principle could be applied to collection
from affluent citizens in developing nations.
3. Buik Bin Collection
This is the lowest level of service and the lowest cost method
of collection a government can provide the citizens. Bulk
3 3
bins or containers ranging in size from 6M to 26M are common
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throughout the world. About 15 percent of the U.S. citizens
refuse and all of the commercial and industrial waste is
collected in this manner. The bulk bins are placed at strategi
or convenient locations and citizens transport their waste to
the centralized bin locations.
Bulk bins can and should work well in developing nations for
the following reasons:
a. It is the most cost effective means in terms of
labor and equipment necessary to do the job. Costs
per ton, depending on size of containers, are only one-
fourth to one-half of the costs of door to door collection
b. Management is simplified. Fewer trucks and number of
workers are needed thereby reducing management problems.
c. Maneuvering trucks down narrow streets is avoided.
d. Collection can be done at night and the time lost nego-
tiating day-time traffic may increase productivity by 50
percent, thus lowering costs. All big U.S. cities do
night-time collection in central areas of the cities.
e. Injuries are reduced since laborers do not lift the
refuse.
f. If night collection is instituted, truck maintenance can
be done during the day.
g. Most cities in developing nations now have centralized
points for locating bulk bins such as markets, dust bins,
and night soil stations; these points are known and used
by the citizens.
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9
h. Based on the U.S. experience, 97 percent of the citizens
can and will get their refuse to a central collection
point (bulk bin) and there is no reason to think citizens
in developing nations will not follow the same trend.
l. Weight of refuse (organics) is heavier in developing
nations and thus mechanical means for loading vehicles
is warranted.
Common objections to bulk bins are:
a. Some affluent citizens insist on pickup at their house.
These citizens should either pay a private hauler or have
their household help carry the refuse to a centralized
location.
b. What do we do with all the excess labor?
Excess labor should be utilized with wheelbarrows,
s shovels, and brooms in cleaning up the streets, ditches,
gutters, and around the centralized bin locations and
depositing the refuse into the bulk bins for collection.
c. Drivers must be paid a night wage differential. This is
a valid argument to bulk bin collection at night, but the
increased productivity will more than make up the differ-
ence. The higher night wage differential can also help
the city attract and hold qualified, trained drivers.
e. Drivers are subject to robberies and equipment to vandalism.
Conventional dumping of bulk bins does not require drivers
to leave the truck, therefore, robbery is difficult.
Trucks can be equipped with floodlights on top of the cab
to discourage vandals, and the driver and helper can
carry mace or other gas repel 1 ants to discourage vandals.
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Selection and Placement of Bulk Bins
It is not unusual for a city to operate two types of bulk
3 3
bin systems. Small bins of the 6M - 9M are placed in
strategic locations in residential areas, perhaps one per city
3 3
block. Larger 26M to 45M bins are placed at market areas,
public housing developments, apartments, government buildings,
and other areas where there is a high concentration of people.
Although the body of the truck is quite different for col-
lecting each type of bin, selection of the truck chassis,
motor, etc. might be the same. About 80 percent of all truck
repair costs are for the chassis and only 20 percent for the
packer (body). Cities which can standardize the truck frame,
engine, and transmission, will have lower maintenance costs,
since the mechanics must only learn to repair one kind of
truck and the city can reduce the number of spare parts in
their inventory.
When utilizing bulk bins for refuse, it is important to keep
the sides as low as possible so citizens can throw their
refuse over the side. If the sides are high, wood or concrete
platforms must be constructed so citizens can walk up a ramp
to throw their refuse into the bin. In general, a 48-inch
high bin is the recommended height. Cities need not reduce
3
the M size of the bin to have low sides, but merely change
the length or width of the bulk bin. Although the initial
capital cost for bins is high, bins usually have a 10-year
life and can be easily fabricated by local companies. Hinged
tops or sliding sides are not worth the extra investment. The
purpose is to reduce blowing paper, insects, rodents,and odor.
In practice, only one lid in 100 containers in developing
nations or the U.S. is ever entirely closed. Also, the
trouble with lid maintenance and problems of filling the bulk
bins full is eliminated if lid or sliding sides are not used.
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11
There are four primary types of bulk bin collection equipment
on the market (Table 2 presents 3 types).
a. Rear loading compactors - This is the least efficient
method and most costly, for several reasons. Trucks must
back up to the container and often laborers must push,
pull, or position the container before hooking onto the
container. Even bulk bins with wheels are difficult to
position, since they drag in mud, on stones, or in de-
pressions. Also, maintenance of the wheels is difficult
and expensive. Dumping the containers with a cable and
winch is slow. Because of the time and extra labor
needed for emptying the bins, this system is estimated at
10 ton per day per truck or $30 a ton in the U.S. This
assumes two trips a day to the landfill, loose inorganic
3
waste at 140 pounds per M and $45,000 for the vehicle.
Naturally, hydraulic dumping systems, compaction cycle
time, traffic, and distance between bins and to the
landfill will influence all the cost examples.
b. Front loading compactor trucks. This is the most customary
type of commercial or bulk bin collection vehicle used in
the United States. In practice, it can be operated with
only the driver. Truck costs range from $50,000 to
$70,000 depending on the size of truck and packer. Based
on two trips a day to a disposal site, these vehicles
generally move 20 ton a day at $15.00 per ton. Bin sizes
o 3
are generally 3f"r to 6M . Larger trucks must have tandem
rear axles which have higher operating costs than do
smaller, single rear axle trucks.
c. Roll off or tilt frame non-compaction trucks are generally
used to move large amounts of heavier density wastes such
as the organic wastes in developing countries. Container
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12
Three types of Bulk Container Trucks
Bulk Container - Rear Loading Average 10 Tons Per Day at $30.00
per ton.
Tilt Frame or "Roll Off" Non Compactor Trcuk Average 38 Tons
per day at $7.50 per ton.
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(bin) size and truck size can be varied to accommodate
3
weight and density of refuse. A 26M bin hauling loose
refuse generally does not need a tandem axle truck.
Costs for this system are estimated at $7.50 per ton for
about four trips daily to the disposal site. Nets or
tarpaulins should be provided for covering the load if it
is overly full, windy conditions exist, or the refuse is
high in organics, such as paper. However, most vegetable
refuse found in developing countries is moist enough so
that nets are not necessary.
Side loading compactor trucks is a fourth means of
dumping bulk bins. Laterally moving arms extend 30
inches out from the truck to grab the bin and hoist it up
high to dump the containers. Most of the systems employing
these arms use 300 gallon round plastic or steel containers,
3
but the arms are adaptable to rectangular 6M bins. The
advantages of this type of mechanical loading are that
the truck can collect bins in 12 foot streets, the truck
never needs to back up, and the compaction is all done
from front to rear, eliminating the need and cost for
multi-push and packing blades. Also, the empty vehicle
weight is less than conventional rear packers, allowing
more payload. Typical cost estimates are $15.00 per ton
for moving 20 ton a day.
Conventional side loading packers for bulk bins have
been on the market for years, but these require additional
labor to position the bins, the same as required by rear
packers. These are not as cost efficient as the newer
type side loaders.
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Decisions on Number of Bulk Bins
The first and most important decision administrators must make
is the volume of waste generated in the city on a daily basis
and the weight of the refuse. If we assume a generation rate
in developing nations of 0.5kc per person a day and 200kg to a
cubic meter, then a city of 1 million inhabitants needs 1250
cubic meters of boxes daily. Twenty percent additional should
be added for seasonal variations and contingencies. Thus,
3
1500 M in bins are needed for each million persons. If we
assume the city plans to empty each bin every two days, and
operate the system 6 days a week using the 20 percent seasonal
3
variation to take care of the 7th nonwork day, then 3,000 M
in bulk bins are needed per million residents.
3
A more difficult decision is to determine the mix of 26M bins
3
and 6M bins. Since the larger bins are the least costly to
collect, planners shculd first attempt to locate sites where
the large bins can be placed and serviced. Population density
3
and truck services should also be considered. If a 6M bin
were placed at the corner of a city block to service more than
2,000 persons, it would have to be serviced daily. In general,
for cost effectiveness and service, it works best to locate as
3
many 26M bins at strategic locations as possible. If we
3
assume 60 sites for large 26M bins were located, then the
need for 1,560 cubic yards of bins are satisfied. The re-
maining 1,440 cubic yards needed for collection every two days
3
would require 250 of the 6M bins. Planning for the location,
size and frequency of collection is never perfect, and adjustments
will be needed after the collection system is started. Rather
than change the size of bulk container, or location, the
easiest adjustment is to change the frequency of service.
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3
For example, a 26M bin at a market might need serviced daily,
3
whereas a 26M bin at an apartment might only need emptied
3
twice a week. The same principle applies to 6M bins. Radio
equipped trucks and a supervisor who reports when bins are
full will pay for itself quickly in mileage costs saved
servicing partially filled bins.
Determining the Number of Trucks
Determining the number of trucks needed is more difficult
than determining the number and size of bins. Time and
motion studies are needed to determine: minutes needed to '
service each container; time between containers; time to
disposal site; time to return; time needed at disposal site
and return; time to and from the garage; allowances for
breakdowns and other variables. This phase of a refuse system
design should be done by a multi-discipline task force of
engineers, planners, and transportation experts who often,
under the best of circumstances, can overlook the fact that
time delays at a landfill or transfer station, adverse weather
conditions, or accidents on main roads, can and will impact
seriously on the number of trucks needed. Collection at night
can help reduce the error in the number of trucks needed
because of less traffic congestion and delays which occur
during night operations.
There is no rule of thumb or standard for determining the
number of trucks needed for a city. Each municipality must,
by necessity, calculate the time needed for each vehicle to
service a given number of bulk bins and then add at least 20
percent to the fleet of trucks for downtime, repairs, and
contingencies.
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If we assume the tilt frame trucks make four trips a day to
3
the disposal site and there are 30 of the 26M sites to be
removed nightly, then 8 trucks are needed. If each of the
front loading compactor trucks can make 3 round trips to the
disposal site with 5,000kg loads, then each truck can service
12 of the 6M^ bins nightly. Since 125 of the 6M^ bins must be
serviced nightly, 13 trucks are needed. This does not allow
for breakdowns and contingencies.
In summary, for each one million persons, the city would need
60-26M^ bins and 8 trucks and 250 of the 6M^ bins and 13
trucks. To accommodate breakdowns, repairs, and maintenance,
every municipality must have spare vehicles. Some cities with
excellent maintenance programs are able to operate with only
10 percent spare vehicles, but the normal amount is 20-30
percent spare vehicles.
All cities must make extensive plans for phasing in new col-
lection practices over a 1-3 year period, since training of
drivers, mechanics, and supervisors and routing of vehicles,
takes time and diligent work. It is imperative that a city do
one area at a time and do a thorough, complete job before
moving to another area. Spreading crews and trucks over an
entire city leads to chaos and a breakdown of what might have
been a good job if confined to one area.
Landfills and Transfer Stations
The lowest cost means of refuse disposal is landfilling
(Table I). The second lowest cost means of disposal is to
process the refuse through a transfer station on to transfer
trailers, generally hauling 15 tons each to the landfill. The
general rule of thumb of when it is advisable to initiate the
use of transfer stations for hauling refuse to remote land-
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17
fills is: when the round trip time to the landfill requires
more than one hour and 10 minutes driving time, or when the
haul distance is more than 15 miles one way.
Assuming a city has a landfill in the south and east quadrant,
often the most cost effective means of collecting and dis-
posing of refuse is to direct haul from these quadrants to the
landfill and erect transfer stations for the north and west
quadrants.
Many cities today have one or two primary roads bisecting the
main city and these roads can provide fast access to a new
landfill 10-15 miles from the center city if the landfill is
located adjacent to the main highway and if refuse is haule'd
at night when traffic congestion is limited. Some communities
in the U.S. have found it to their advantage to use toll roads
to reach a remote landfill rather than erect a transfer station
or contend with center city traffic.
Sanitary landfilling is the least costly operation in refuse
collection and disposal and should be utilized when and where
practical. In the U.S., the average cost in 1978 was $4.15
per ton. In general, as tons placed per day increase, costs
for landfill ing decrease. Costs for taking refuse through a
transfer station add an estimated $6.40 per ton to refuse
costs. This assumes an average 34 mile round trip haul.
Hauling costs are estimated at 12 cents per ton per nnle for
truck and driver.
New York, placing 13,000 tons a day, had an average cost of
$247 per ton in 1977 and Dallas, Texas, operating 7 landfills
in 1978, had average costs of less than $3.00 per ton. Over
80 percent of all landfill costs are for equipment and the
labor to operate the equipment.
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There are 5 primary principles to operating a sanitary landfill
around which policy makers should center their decisions: a)
protection of the groundwater for the present and foreseeable
future, especially if it will contaminate a public water
supply; b) discouragement of scavengers, usually through the
use of fences; c) control of insects and rodents; d) no open
burning and; e) periodic covering with dirt of the site. This
latter aspect is the most expensive aspect of landfill operation.
Although bulldozers have been the favored piece of landfill
equipment over the years, the trend toward landfill compactors
is rapidly gaining acceptance. The big advantage of landfill
compactors is that the refuse is more densely packed, therefore
more refuse can be put in the same amount of space at no
additional cost over a conventional bulldozer. Hauling of
cover material should be done with a scraper which moves 15-30
M3 of dirt.
Incinerators and Composters
Only 4 percent of the U.S. waste stream is burned in incinerators.
Incinerators have not proven feasible due to high operating
costs. They are also a major source of air pollution. Only
about seven incinerators can meet the U.S. air pollution
standards. In the 1950's, over 300 municipalities had incinera-
tors, and by 1978 this had decreased to about 42 cities.
The feasibility of operating incinerators in the U.S. is much
more favorable than in developing nations because the refuse
is 80 percent inorganics such as paper, rubber, and plastics,
which burn without supplemental fuel. In order to burn organic
refuse of the type found in developing nations, supplemental
fuel must be used. This is both expensive and directly opposed
to energy conservation. In addition to the technology needed
to build the plants, skilled, trained workers are needed to
operate the plant on a 24-hour basis for economy of scale.
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19
Typical skills needed to operate a facility are certified
welders, electrical and mechanical engineers, tool and die
mechanics, and firebrick masons. Explosions do occur from
paint, propane cans, and other volatile materials, putting the
incinerator out of use, often for long periods of time.
Electrostatic precipitators, while doing a good job, require
considerable amounts of electricity and periodic maintenance.
Electrical brownouts or blackouts of a power supply for even a
short period of time can often result in a long and costly
delay on starting up the operation again. In all cases, there
is an incinerator residue of 10-35 percent, depending on the
completeness of the burn and amount of glass, metal, and other
non-combustibles present. This must be transported to the
landfill. Thus, the decision to install incinerators in
developing countries before an adequate refuse collection
disposal system is instituted cannot be considered a prudent,
rational decision.
Composting of organic wastes is a more rational decision.
However, composting is much more expensive than landfilling
and has several disadvantages. How do you separate the organic
from inorganic wastes with a high degree of reliability.
Pieces of glass in compost are not wanted by farmers since it
cuts their feet and the feet of their animals. Anaerobic
digestion of the organic matter must occur before the compost
is trucked to the farm and this requires some technical
ability for controlling the time, temperature, air, and turning
of the organic matter before it becomes compost. A major
problem is trucking the compost to farms and spreading the
compost. Trucking is expensive, and farmers don't want the
compost during the growing season or rainy season. Farmers do
not have the equipment to spread the compost and the city
might have to purchase a compost spreader or pay the farmer to
spread the compost. Finally, compost is not a fertilizer.
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Over the years, urban dwellers in all nations have gotten the
mistaken impression that compost is a substitute for organic
fertilizer. Compost is a soil conditioner, especially good
for loosening up clay-type soils. The fertilizer value for
increasing crop yield, especially nitrogen, is less than 0.2
percent. Thus, one ton of compost has a fertilizer value
equal to a 2.5kg bag of urea (nitrogen) fertilizer. Farmers
are rational individuals and will always select fertilizer
over compost. In summary, the best use of compost is to
spread it on undeveloped land before the land is brought into
production.
Operational Management
Assuming several policy decisions have been made on funding-type of
service and equipment needed to do the job, operational management
decisions must be made and implemented that will result in a viable
refuse collection-disposal system.
Operational management of any refuse system in any city or nation
is difficult. Most municipal administrators have the ability to
manage white collar workers and their related functions in an
office situation. When this same expertise is applied to the
management of blue collar workers, a fleet of trucks and a big
repair-maintenance facility, something goes wrong. Often, municipal
administrators cannot communicate with the blue collar workers, or
can't identify with the basic problems and needs of the workers to
keep the system functioning in an efficient manner. In one instance,
maintenance of 50 trucks was in chaotic condition because the city
purchasing department exercised control over vehicle parts by
holding up the paperwork for two months, even though the refuse
budget adequately provided for parts acquisition. Labor unrest
existed in another city because some drivers worked only 3 hours a
day while others worked 6 hours daily. Administrators and planners
had not balanced the workload equally among the crews. This should
be done on an annual basis and always has the support of the unions.
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21
Many management studies in recent years have pointed out that wages
are not the number one issue in developing and maintaining a
contented labor force. More important factors are working conditions,
good equipment, a fair equitable workload, a grievance procedure,
and support of management in their work.
In our experience, the management skills and chain of command that
will work best in any municipal refuse collection and disposal
system is similar to the military chain of command. The Administra-
tor (Battalion Major) passes orders to his department heads for
collection, disposal, and maintenance (Lieutenants). The department
heads pass orders to supervisors (first sergeants), onto foremen,
(staff sergeants), to drivers or mechanics (corporals), who direct
laborers (privates). The key to drawing this parallel between army
organization and municipal waste management is the supervisor or
first sergeant. In the army, as well as a refuse collection system,
supervisors or first sergeants have the ability to communicate
between blue collar workers and managers (officers).
Based on a large number of observations, retired military personnel
have been very successful when placed in a corresponding position
in refuse management. Often, supervisors or foremen from large
construction companies provide another source of trained personnel
who have the ability to communicate between blue collar workers and
management.
The three primary problems in refuse management which lead to a
breakdown of the system are 1) vehicle maintenance, 2) span of
control over vehicles and crews and 3) "permissiveness" in manage-
ment. All require diligent management to overcome.
Vehicle maintenance is the number one management problem contributing
to missed collections and a breakdown of the refuse collection
disposal system. New York, with 1700 refuse trucks generally has
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22
600 down for repair daily. No other vehicle takes the abuse of a
refuse truck. It must make hundreds of starts and stops a day in
traffic congestion, often over poor roads, and then negotiate a
landfill with full load. Although driver abuse is a contributing
factor to vehicle breakdowns, most vehicle malfunctions are attribu-
table to improper truck specifications. For these reasons, it is
almost impossible to over-spec a refuse truck. Frames should be
extra heavy duty, axles should be over-specified by 30-35 percent
to take the wear and tear of a landfill. Engines, transmissions,
drive shaft and rear end should be the best available. No one has
ever complained that a refuse truck was too strong for the job.
While many cities base their purchases on low bid, the trend is
toward life cycle costing. Under this method, truck purchases are
based on what the total lifetime cost of the vehicle will be over 5
years, not the initial purchase price (Table 3). Almost all refuse
trucks are depreciated over 5 years.
It is much more important to develop data on the truck costs over
a five-year period than the body or packer mechanism. Truck main-
tenance costs are about 80 percent of total costs and the body only
20 percent of the maintenance costs. Often, good quality bodies
can be removed from old chassis and placed on new trucks for several
additional years of life.
Well managed maintenance garages are generally divided into three
units: 1) normal or periodic maintenance for oil and lubrication,
2) small repairs such as brakes, fuel, electrical, tires, and 3)
major maintenance for the drive train. There have been two trends
in recent years for major maintenace. First, complete dealer or
truck manufacturer maintenance of the drive train and second, the
use of modular or replacement engines rather than rebuilding engines
in the maintenance shop. If a chassis manufacturer must also
-------
TABLE 3 . EXAMPLE LIFE CYCLE COSTS
Year:
Capital Investment arid Depreciation:
trade-in value {% of delivery price) 75%
Investment, start 50,000
Year-end value 37 ,500
Yearly capital cost 12,500
55%
37,500
27,500
10,000
40%
27,500
20,000
7,500
3055
20,000
15,000
5,000
25%
15,000
12,500
2,500
Debt Service and Insurance:
Average yearly investment
Yearly debt cost @ 12%
43,750
5,250
32,500
3,900
23,750
2,850
17,500
2,100
13,750
1,550
Operation and Maintenance:
Yearly estimated cost
3,000
4,000
6,000
9,000
12,000
Downtime:
Availability factor
Hours not available
Cost 0 $10/hr
Reserve vehicle
95%
60
600
94%
120
1,200
91%
180
1,800
83%
240
2,400
85%
300
3,000
Obsolescence:
Productivity factor
Extra hours required to match
Production of new model
Cost 9 $10/hr
Total Annual Cost
Cumulative Vehicle Cost
982
40
400
$21,750
$21,750
%%
80
800
$19,900
$41,650
9425
120
1,200
$19,350
$61,000
92%
160
1,600
$20,100
$81,100
905$
200
2,000
$ 21,150
$102,250
PO
CO
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24
prepare a bid for drive train maintenance over a a five year period,
it will force life cycle costing on the decision makers and the
initial purchase of the truck chassis will be more favorably spec'd
for the job. Performance bonding should accompany the drive train
maintenance contract.
Poor maintenance of refuse trucks often occur when the work must be
performed in garages which service highway, police, and other
municipal vehicles. Most mechanics don't want to work on big, old,
smelly, dirty, refuse trucks and thus these vehicles are serviced
last. Therefore, a separate garage for refuse vehicles is recommended.
Selection of mechanics and training is difficult. In any nation,
there is a shortage of heavy equipment mechanics. In general,
these workers require higher pay if a city is to retain competent,
qualified truck mechanics. Many municipal garages servicing refuse
trucks often employ the wrong type of mechanics or do not provide
them with the proper equipment. A study of 200 refuse trucks in a
major U.S. city over 30 days indicated 117 trucks needed electrical
repairs, 90 brake service, 89 body, and 61 fuel repairs. Only 48
trucks needed engine work. Thus, this garage needed more mechanics
who knew and understood electrical problems and brakes than they
did engine mechanics.
Training of mechanics is generally best accomplished by sending
the men off to school rather than trying to train them on the job.
However, aptitude for the type of training is very important. A
man who has an interest in brakes or transmissions may not have the
same inclination to learn electrical repairs. Tire changers might
not have a desire to learn hydraulic cylinder repair. An electrical
system repair mechanic might best be recruited from an electronic
school. A good brake mechanic might be obtained from a farm
implement dealer. If the mechanics, even after specialized training,
are not capable of doing the job, they should be put to work on
-------
25
something else and training of replacement mechanics started over
again. In the U.S., it is not unusual to employ one good mechanic
for every 5-7 trucks. While this ratio is not possible in develop-
ing nations, one quality mechanic can often do the work of several
uninterested, poorly trained or wrong aptitude mechanics. The role
of the foreman and supervisor of the maintenance garage is to con-
tinually circulate thru the shop monitoring the mechanics and work
being performed.
Periodic maintenance is a necessity. Often, the excuse is used
that there is not time available. If this is a problem, schedule
oil changes and grease jobs on weekends or at the opposite time of
collection, even though overtime must be paid to mechanics. Tires
and batteries should be checked daily and replaced if they show any
signs of malfunctioning during operation. It is false economy to
carry tires and batteries on vehicles until they break down. The
lost time of drivers and workers, as well as the expense of on-
route repair or towing,.is higher in the long run than discarding
tires and batteries before they are worn out.
For some refuse collection systems, it has worked well to schedule
periodic and small maintenance repair jobs at night, if collection
is made during the day or during the day if the trucks are operated
at night. Standardization of truck chassis types, body engines,
transmissions, etc., will facilitate a higher level of performance
by mechanics since they only need to learn repair of one type of
truck. It also allows the maintenance garage to carry a minimum
number of parts. All garages should carry a large number of the
common parts and inventory control of these parts is very important.
An adequate replacement supply of belts, radiators, f"el injectors,
clutches, generators, starters, etc. will, in the long run, make it
possible to keep the fleet operating. The worst practice appears
to be overstocking of infrequently used parts or carrying an in-
ventory of parts for obsolete or salvaged vehicles.
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26
A service contract with the seller of truck chassis for repair of
the drive train components has several advantages for local municipal
governments. The need for highly skilled mechanics necessary to
repair or overhaul transmissions and engines is avoided. Often,
the city wage scale is not sufficient to attract these specialized
mechanics. To overhaul these major items, specialized equipment
for servicing is needed and cities cannot afford this equipment for
limited use. Some dealer contracts guarantee the minimum number of
trucks that will be operational each day or provide for backup
trucks when an excessive number are in the shop for major repairs.
In general, the number of vehicles down for repair in a well managed
maintenance facility is 10 percent of the fleet. In poorly managed
maintenance facilities, 25-35 percent down for repairs is not
uncommon. In general, each lost truck hour costs the city $10 for
not having use of the truck.
Everyone subscribes to "periodic maintenance", but in reality
seldom achieves the objective. Too often, the words "we don't have
time" or "every truck has to go out today" is the excuse used for
not performing periodic maintenance. This is false economy and
will quickly lead to serious and costly breakdowns. Clogged oil,
air, and fuel filters on diesel trucks can ruin engines quickly,
causing onroute breakdowns and expensive repairs. A leaking
hydraulic cylinder can quickly lead to a scored cylinder and the
need for replacement at a cost of several thousand dollars, all
because a few dollars worth of gaskets or packing weren't installed
at the first sign of deterioration.
It is very easy for the casual, uninformed observer to determine
the quality of a refuse maintenance garage. Is the garage clean
and neat? Are tires and tools put away? Is the floor covered with
oil and grease? Are the tires, batteries, and parts lying all over
the place, or are they neatly stored? Is the garage large and well-
lighted or small and dingy? Does the outside yard look like a
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27
truck salvage yard or a new truck dealers parking lot? The answer
to these questions will almost always determine the quality of the
service of the maintenance garage.
Span of control over vehicles, drivers, and crews is the second
largest contributing factor to poor refuse management. Depending
on the size of the city, a large number of trucks and workers leave
a central garage each morning with a $50,000 piece of equipment to
do a job and report back to the garage 8 hours later. During this
period of time, drivers and crews are often out-of-touch with any
sort of management. They have no supervision to keep them working
and will tend to featherbed. Often, they are confronted with
unusual situations or problems. The truck breaks down, a traffic
jam or detour ruins their work schedule and productivity. Often, a
man is injured. The crew or driver may not know the route if they
are substituting for the regular crew; overlap of routes, half-
filled trucks and missed collections result.
Two methods are generally helpful in overcoming the problems
associated with span of control. The use of radio equipped trucks
and foremen in pickup trucks driving the area providing supervision
generally work best. If a driver can communicate his problem to a
central office, and if the supervisor can shuffle trucks or crews
around, the seriousness or productivity delay of onroute problems
can be minimized. In cities utilizing bulk bins for the collection
of refuse, the supervisor can make the decision by radio of which
containers are full and need tipping, thus increasing productivity
and reducing costs. Foremen and supervisors should have the ability
to reroute trucks to save time and be able to place containers so
they are in the most advantageous position for refuse collection.
Other duties of foremen are to switch and interchange crew members
who work well together and train new drivers on routes. In practice,
about 1 foreman is needed for each 5-7 routes. Radio equipped
trucks can and will increase productivity, thereby lowering costs
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28
and recovering the initial investment in a short period of time.
They are especially helpful if the city is divided into areas for
collection and all trucks and crews must stay in the area until the
entire job is completed.
Permissive management of labor is the third factor contributing to
poor refuse collection and disposal. Collection of refuse is not a
choice vocation even for blue collar workers. Refuse collection is
dirty, smelly, heavy, boring, and a physically exhausting occupation
with little chance of advancement. For these reasons, the drivers
and workers attracted into the occupation are not of the highest
caliber. In the U.S., as well as other nations, many of the
employees are functional illiterates. However, this does not
prevent these individuals from being excellent sanitation workers
providing they are trained and given incentives such as pay, vacations,
and the opportunity to go home early when the job is done. In
practice, low I.Q. drivers may be more desirable because they
concentrate on one thing--driving--while high I.Q. drivers often
have their mind on other things.
In the U.S., as well as developing nations, poor refuse management
can generally be attributed to permissive management. Absenteeism
is not dealt with harshly; the city has no grievance procedure;
drinking on the job is allowed; truck abuse by drivers is overlooked;
accidents forgiven; featherbedding and loafing tolerated. A normal
8-hour workday with one hour of non-productive time quickly can
degenerate into a 4 or 5 hour workday. In essence, workers will do
no more than they are required to do. If administrators and
supervisors tolerate permissiveness in the maintenance garage, onroute,
or at the landfill, then the solid waste system will be very costly
to operate and eventually break down.
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29
For these reasons, management must develop rules and regulations
regarding employee relations and enforce them. A grievance pro-
cedure with several steps to dismissal is the recommended method.
Common problems and courses of action practiced in some cities are
automatic 3-day suspension for drinking on the job, grounding the
driver for accidents at a reduced pay level until the accident is
investigated, dismissing employees for several unexcused absences
or instances of truck abuse. Many a driver has caused $5-$10,000
damage to a truck by trying to "clutch" it out of a hole in a
landfill; no refuse system should tolerate this kind of truck abuse
from drivers.
Contract Collection and Disposal of Refuse
Because management of any refuse system is different under the
best of conditions, many U.S. cities are contracting with private
firms for collection. Some of the large U.S. cities turning part
of their collection service over to private firms are New Orleans,
Oklahoma City, and Phoenix. Several hundred smaller cities have
turned over the entire operation to private firms.
Common reasons given by these cities for contracting the service
are: 1) no new capital for equipment, 2) labor problems are too
difficult to negotiate, 3) our present management can't implement
the changes needed, and 4) private firms can do it at less cost.
All of these statements are valid except the fact that private
firms can do it at less cost. By definition, any city should be
able to collect refuse at less cost because cities don't pay the
same taxes and are non-profit. In reality, refuse collection-
disposal in many U.S. cities is so poorly managed that private
firms can often provide the service at 25-40 percent less cost
because of better management practices. In general, private
contractors pay higher wages than do cities, but they usually have
-------
30
a productivity per worker or per truck that is double that of the
city. Private firms tend to purchase only the best equipment and
often depreciate it over 3 years. They dismiss employees who do
not produce. Maintenance is of primary importance. Laborers are
placed on an incentive system to get the job done quickly and
thoroughly. In essence, private firms provide diligent management.
However, some U.S. cities such as Pontiac and Flint, Michigan, St.
Petersburg, Florida, and Springfield, Mass., have municipal managed
systems that are lower in cost than would be the service if it were
done by private firms. Thus, the decision of whether to contract
the refuse collection-disposal operation or do it with city equipment
and employees should rest on the capability of the city to effectively
manage and continually fund the system.
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APPENDIX V
ENVIRONMENTAL ASSESSMENT INFORMATION
FOR
DEVELOPMENT OF A PERMIT
-------
25
INDUSTRIAL PLANT EVALUATION FORM
GENERAL
Company:
Location:
Contact:
Title: Phone No.
Main Office:
Raw Materials Used:
Finished Products & Current Production Rates: (Flow Diagram)
Rated Plant Capacity:
Previous Studies:
OPERATIONS
No. of Days/Week No. of Hrs/Day_
No. of Production Employees
Date Visited:_
EPA Personnel:
Date Plant Began Operating
Current Operating Permits & Applications Filed:
-------
6
WATER S'JfFLY ?. USES
Source(s)
Treatment.
bse(s) " Quality IJs-jJ.
Analvsis:
I'/ASTf SOURCES & TREATMENT
A. Domestic Waste Quantity:
Type of Treatment:
Receiving Water:
Analysis
C. Process llaste(s)
Source S Quantity:
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27
Treatment (flow diagram)
Receiving Waters (State class i ficu'-ic.-i and uses).
Analysis of Cffluent
FUTURE PLANS (expansion, modification oc process, '..'iter rouse, by-product recovery, etc
-------
i 1.0 MOTES & OBSERVATIONS:
By
Da to
(Signature)
-------
APPENDIX VI
TYPICAL UNITED STATES
WASTEWATER DISCHARGE PERMIT
-------
"7. UT7 !i
. MM , RC. OURCl" S v"'.i : I'ROL BO.'wllj
ORD' NO. 77-0
NPL^S SO. CAOOO^m
w;\srr, d. scii^rcc rfolh ,:c;ems
tor
lodisia 'vp^ciric co'i.'ox.vrio::
Hi-'bolot Cou'v.
Th = Ca.' u'crnia State '\occr Resources Control Do^rd (State !?oard)
f 1 no <5 t t a t:
1. Loiiuia.;a-Paci:ic Corporation r ud its ureclw cssor,
Gcorria-Pacif l*. Corporation, h.-.'C r,ja"i tl. Jd police t lors
for federal per-rits, a tec.^icrl report purs^cnt to the
I.'atcr Oualitv Control Pl.n for Ccean '.'aters of California
(Ocean Plan), ana supoieTental information in letters
and petitions u'nch describe tKe corporation's discharges
to the Pacific Ocecn a.id !Iui?boldt Biy.
2. Loui sir.na-Pacific Corporation
I c ir" .ii ¦? f.01 c''ip. 01" fuol to ji ouiiti'i1t r of tJ'i. o.i
L'ci>) . ,"ii 1,1.
-------
3. 'J'lic ilcijion.il floard rcopt.cd the- !.'jU:r Quality Control
Plc.i J'or the l-orth Cor.sl.il 5.i .1 i < .'.a .in Pirn) or 'itch PO,
10 7'j, arc] adoptcj ri.vi.uor.j thereto on >iarc.!i ?j, I'jTu.
The Lin in Plan 1 rcorcor.)tc s tho Croan Pl.ii ,ir:l t'-"* !..itor
Ou.-liiy Control Policy Cot the Ki'du.i-d Hr.yi, nri -otuiric-s
of California. It contain; cfluent limitations ""nd
water quality objectives for Pacific Ocean dmchrrgcs
and pionibits nojt discharge to Humboldt Day.
4. The bcrcfitical uses of Pacific Ocean and Hurpboldt Say
include:
a. industrial water supply
b navigation
c. water contact recreation
d. r.oacontact 'ate.r recreation
e. ocean co.nnercial and iport fishing
f. mar ire hgoit at
g. fish rpigralion
h. fish spanning
i. shellfish harvesting
5. The beneficial uses of shallo • fresh groundwater on the
Samoa Peninsula incl-de domestic ¦ ater supply. Th^. uncer-
tainty of supply and the ^jsc&ptibility of this later to
degradation frorover puwoirg, percolation of scrags,
by <;a2ir>3ty fron arc~gcd material disposal and otuar
activities has o^cc-rrged dcvclopicr.^ by the Jiiii.ibaid:
Bay 'luniciprl Water District of a i.ator svsten
utili:irg ''ad "over supply. Groundwater in araas ?clyirg
upon its use should 5a protected i.ith minir.r_r.i ns'< of
degicdsLion fror.i uastc discharges.
G. The discharger has requested exemptions iron:
a. Ocean Plan Table A effluent limitations on:
Tioatirg parIiculatcs
Suspended solic:
Srttleable solics
Tucaioity, and
F''.
b. Ocean Plan Table B cfflu>_rl linitatioas on chra-iun
c. the tiro i.ch^oulc pro' lsto:- of State loard Pcso'..tio.n
Ko 1 - 5 ¦ . nd
d. E? \ r.f-'luent Li n: t itio.ns Ci'.dol l ncs b.ioed hr.t.i-
lion'. on.
BOD and rlt.
-------
Rcgor^i:nj the exrmp! ion1; fro-i Occm i 1,1:1 effluent
Imitations rccucsU '¦ by tl.o c ischarger:
a- rimtmn lJr>r L\ ~11 i, \nll not interfere
with conpljcnc-r1 '.'ith Iho '.iter cualltv oojrctixcs
set forth in Chapter IX of the Ocean Plan and will
not interfere with compli.nce v»ith the cffli:ent
quality requi r ci-icnt s soc Lorth in Chapter IV,
Tabic U of 1.hc Ocean Plan.
b. Su^nr^dod Solid.. Dischru^e 01 suspended solid':
at the rots-, soccified hc^m wall not interfere
with compliance with the iMter cjnlit; objfctr.r;
sot fartn in Cn.^ratcr II o" t!io Ocean ?l£n r>nd .'ill
not interfere with comnJ ice "ltli thi effluent
quality requirements ;et forth in Chapter IV,
'laoic 3 of the Ocean Plan. Since the "usper.dcri
solids frc-n the ua'.cr tros'mcnt plant con?iii of
silt from the Mad River th it uould nonally be
discharged to the ocean, it is ^opronnate lhat
the limitations cn suroc^d :d solids oe on a pet
basis. Thus, Hie momtoii.ig requirements vull bo
estabUshnd zo as to aive credit /or suspended
solids resulting fron vatcr treatment plant operators
c. Settl Solids. The ab .encc cf any Imitations
on sptfie.bla solids .'ill not interfere rim
compliance with the water quality objectives set
forth i-> Chapter IX of the Ocean Pi^n and '..ill rot
interfere i.ith coTpliance uirh the effluent quaiity
requirements set forth ir Chapter IV, TabJo Q of
the Occnn Plan.
d. Tu rbi di ty. The absence of any limitations on turbidil
will riot interfere with co'Tplizirce with the \fat._r
quality cbjsctivcs set forJi in C.iaptrr II of the
Ocean Plan and v,ill not ir'. orfcrc wiv.h conpli j'lct;
with the efflucrt quality requirements set forth in
Chapter IV, Tabic B of the Ocepn Plan in that tno
turbidity iron the vater tioatment plant consist; of
silt nrd clay f ro.a the Mrd River tliat v ou Id norrally
be discliaigcd to the occ.j'1.
p. rill Di .cliaige oj' el'f'vent ¦ vilIi a pll votiun the
r.,nqc '.pcciLied herein \ ¦ x 11 not interfere i/i th
coii.oli'ino: with the water ..u.ili ly obj'.ct.\es set
forth m Ch-'ptc.. II of I !'.o Ocer-i ? 1 n ."ind /ill ro'.
inui t^ro >,ith co'-pl 1 .vice .ith I'1;? effljc'i' quality
rctun 1 c..-ont •- ict toitn m Ciioptcc IV, T,,bLe li of
t! c Oce ..n r I .vi
f Cu * vn .in T.vl Tvii1 Srh.Hlu ! r ^invi cor (if St I o «**'" *
l'i ~T) 11 ~7i ."o "'i~i iIk' nijCh .u ,cr n.-_ imi.uiim
•-.1 b~Vl .i""t 1 .-T'cv uu"k.l tiit 1 or-n 11 ar.i c with -~hroniun
li"it.ilio.i b v <_ d 011 Ch ip! 1 ¦ IV, . b 1 c J ot Inr
Ocr .111 I'l.-.n 1 . no; po. -1 b 1 ( thr <.'•!<-/¦> r,pp 1 1 c: V. 1011 OL
••o "1 ri. caul ml', ,-i.d 1 lu l jm »'Ct 1 c .ibl.. cciurol
t CI" I11.0 1 urjy au.'''i I I / TV ll »I o .
-------
3. On Jur.e 21, 19 76, th disch uqor submitted In tha
Regional Eoard a roq st Cor v, nance Cro-n h.?A
effJucnt lm.ils b.T.cj on fund.-r entally di'",'c -.en
factors. 'Ihe reqjcst was suppJ omonted by trstnony
and cvic'crco presorted by the discharger dunr ] the
course of p'-blic hearings bcCoic both the ."Ugional
Board ard tac State 3oord.
Dased upon said testimony and e/idence, the State Hoard
finds that effluent exceeding t.ic HP'\ guideline U-uta-
tiors for UOD and pH has substa 111ally no adverse
effect on the marine environTier> - uhen properly diffused;
that thare w: 11 be fev if any Vv->ter quality Donof it1:
associated \ ith trcatirc-nt for 11 ID or pll, tiiot there
will be suoilantial ciiromcnl ll and energy costs
assort.ited i.'ith treatment for ".<>!) and'or pi'; and that,
therefore, un~cr the precedent established bv the
U. 3. Court of Appeals (Fourth Circuit) m its
decision in the case of Aooa 1 ?c! 11 pi Pouer Co-.o
-------
1*1. The disc'- ,-gc r is cm rent ly Oi-chan V] tindi r ".v it
discharge1 renmrrnr. I b lssutd by Lhe" Krg um..>1 Hoard
on September ,1, 19Gi , and it. n.om Lonnq .inc.' j-.'por c trig
unucr Jioniioiipg anc' Reporting I'rogi mi Ko. 7 I?
adopted bv Llie Regi.or.-i 1 Loard on December. 1), 1974.
IT IS li^R^SV CRDCRLD THAT Louisiana-Paciflc Corpora;ioa, in
order to r.cct the provisions contained in Division 1 o" tho
C
rloi' „ HCD 30 — — 3G
UOD tpuJo) lbi/day-/ 9,021 -- — 10,349
The peerage of v.il.u^ in any 30 consecutive djv ;htioJ Co plivico
\/ill not be drti i Tioctl jC Cere r th.-.n foui '.moK" • are mailed,
b/ The \alue \ h ic - j s not c\cerricu la 50 percent of the in
ary 30 cc.ocul'vc day period. Co ml inr,cr Mill rot be rictcnrined
if feuer than four es are analvcd
r/ The v .lino wmc.i v, not e\ceec;~d in 00 percent of the sarnies in
any 30 co ' tcu'.iv,1 day period. CctpJiar.co will lot oo octcinncd
if fc.oi thin ,out" sannJcc a^c .lnjly/cd.
d/ iJa-.ed oi o!0 ion.-: per day average annu il production.
-------
Co ' ".I ' turn 1
BOD
[!iycl. BarrCC'")
[iOD.
(Veneer)
Win t ¦;
lbs/cu.Ct^
lbs/day
lbs/cu.ft
lbs/day
, . . 90-dav
30-d-y- 30-day— 90 th
c/
Ave ¦ ace "c-c'.i rm
0.03
1. 500
0.015
2S3
Dai Iv
II.j <} nur
0 .09
4,500
0.045
849
Suspended
Solics o/
effluent m excess of trie
following limts is prohibited: h/j_/
Conptit beit s
Un 11 s
50%
of time
10%
o£ time
Arsenic
Cadruu.i
Copper
Lo nd
ilercur\
Ml eke 1
mg/1
my/1
ir.g/l
mg/1
mg/1
rog/1
0.01
0.02
0.2
0 .1
0.001
0.1
0.02
0.03
0.3
0.2
0.002
0.2
0/ In ,-oJition to the "jUjpencU'- .olidc 111 the raw water -.uppjy.
f/ Pou.-ds of ROD- or ^.-.po-ic'ed solid*. ,:or cubic foot of wood
proTjifti through the hyd it. J lie barker.
?,/ Pou'Cs of IJODr, per cubit, Loot of production ] 11 terms of veneer,
if tl-aL 1- the final pioducc OL th\b .cility, or per cubic foot
of oly\ooci if the vcncoi ii. further oroc-.-.-icJ into oly/ood at
tl-.i:, f^ciJily.
h/ The r'-uri'u alio dill.' in,... cm:.:.10.1 rite for each constituent
Ii'.lcJ 1 1 lLo'!i above b.' call ul.ito ! 1 voi.i (he total i:ci.te
f J 01 c.-ci r."i jiq enca --pecific day ami 1 he concentration spec: f i cc
(c
-------
Cc> ,¦ t ] I iimrs
Unit-,
/ »
o \ rie
or (nie
Si Her
mg/l
0.02
0.04
SSl.iC
mg/J
0.3
0.5
Cyanide
mg/1
0.1
0. ?
Pherolir Co lpouncK
ng/ I
0.5
1.0
Total C'lJor.ne ^e^idual
mg/1
1.0
7.0
i^m-ionia (e.i .:'(_->-;ed as mtiogm)
mg/1
40 .0
GO. 0
Total Identifiable Chlorinated
ilydreoarbns j_/
mg/1
0.002
0.004
Toxicity Co 'contration
tu
1.5
2.0
3. The discharge an
effluent in
excess of tlie
follouing
limits is prohibited
: 22/2/
50r«
10%
Constituent
Un 11 s
of time
of 11¦— 1
Total Cnro-'iura
rrg/1
o.oo:
0.01
4. The discharge of noncont«-,ct cooling water to ':ur?bold;
Day in excess of the following limits is prohibited:
30-day Daily
Aver aoe HaAiniun
2 2.0°C 24.0°C
5. Upon approval by the ?dminist r.-tor of HPA of the finding"
of "fuid^rcftal difference" cicod in rinding 0, above,
the Cello -irg li-it ctions shall apply ir. lieu of tv.c
Imitations in !i. 1., above, for the following parameters.
The li-i.i t at iops contained in D. 1. shall continue to apply
for all other parameters. Should the ^d'nir.istrntor <">pcrove
a variance but fird that limitations other than the following
=irc appropriate, the Regional Coard shall revise these
waste discharge reqairements consistent with the limitations
approved by the Adnu.nstraior.
h/ in waste discharge requirements as that not to be exceeded norc
than 10 pcrccit of tr-c tirre. The mass emij,->ion rate of the
di'.charqe during any 24-hour period '..hall not exceed the mr.\'itnu-i
allowable daily raas; e.nis-'.ion rate.
1/ The i'in\;iiun aJJownblc r.'onthly nn.s emission rate for crh
~ constituent Jij.tcd in Hon ? above shall be calculated fro'i the
tol ,il waste flow occurring in each specific -nonth and the cor-
ccntralion specified in .»«¦>¦? to dicharge rcq'J 11' Hie n ts a.s thai not
to bo o cccJea i.orc th;>n 50 percent of the tne. T to ¦anti
rm i'-ion rare of tlie d l ..c'1 .to" dunr-j av/ monthly period ph.ill
not e cecd the mmtl', allowable ironLhlv rm-^r. cmii' ion rate.
-)/ Tor tl telonti l" i ib Je Ch lor i .in l cd I'ydi ocar:;on:. «.ha)l be mr .liiirr.d
by .u.-.r. rg tlie l i.d i viciv "¦ I cc.xcntrn'iioii ' of DDL", D'll), DD1", alilm,
lit <-*, cli1 ordn.io, cih) iin, hoptarhlor, lindane, dicldnr, po1 veil lor l .ir. tea
bipiion^ , and other lucntiCi. bio cliloim.'tcd hvd roc arbon^ .
-7-
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D..1 Iv
"¦ )"iinnir
9 7,GOO
Rprnvu'."? '-'ater Li ,-ni tatior,s
1. The discharge shall not cau^o floating particulates,
fo.-.m, or grease and oil to be visible.
2. The discharge shall not cause acsthct.ic.iJly undesirable
discoloration of the ocean surface.
3. The transmi11ance of natural lic.ht shall not ba
sigrlficont ly reduced at any point outside tic mtial
dilution zone.
4. The discharge shall not cause the dissolved o yet-1 concen-
tration outside the initial dilution 7.one at an\ ti~e
to be depressed rroru than 10 percent from thsc vhich
occurs naturally.
5. The discharge shall not cause the pli outside the initial
dilution zon.i to be ch?r.gcd ot any tine more than 0.2
units Cron that ^nich occurs naturally.
6. Toe discharger shall not cause a violatior of any
other aoplicaoZe existing hater qualify stardard for
the receiving vater adopted pursuant to tne Federal
Uater Pollution Control Act r.r.d mplcmentir.g regulano-s.
If pore or less stringent applicable uat:r quality
staidards are promulgated or approved pursuant to
Section 303 of the federal 'later Pollution Control /ict
and ii-ploTienting regulations, the Regional Eoard shall
revise or modify this order ir. accordance uitn sue-.
more or less stringent standards.
7. In areas where shellfish are harvested, the discharge
shall not cause the median total coliforn organis-
conccptrat 1 on to exceed 70 per 100 n:l nor shall t"e total
col}form organism concentration exceed 230 pel 10j pi
10 percent of the time.
8. The cccrritiruun of organic "atenal; in ian;'.c
sodi'.citT snail not bo increased above that vhich ¦;ould
degrade marina life.
30-day
¦> i^ti. 'leii t Units Ay or ano
)D. (pulp) lbs/dav-/ 40,000
within the limits 3.0 and 10.0
9.
The disch.-uqc shall not cau^.e toxic conditions to exist
111 tl'e leceiving 'ater.
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10. The discharge shall lot c;.u-.n the following linuti
to be exceeded after mitiaJ dilution:
Co.' tltj<"!(.S
Um t s
2
50 Per- 90 Pcr-
centili1 cctilf i!a\ir'-~i
Grease end Oil mg/m'
?
Floating Particulates mg dry \.l/m
Toxicity Toxicity Units
10
1.0
20
1.5
0.05
D. P rovisions
1. Neitner tnc trcatnent nor the discharge of: pollutants
shal] create a pollution or a "'jisancc as defxnad oy
the California Water Code.
2. The discharge shall achieve rapid initial dilution
and effective dispersion to minimize concentrations
of pollutants not rcioved by treatment. The diffusion
system shall provide an initial dilution of effluent
with senator exceeding 100:1 at least 50 percent of
the tire and e^c.eedng 00:1 at least 90 percent of the
tine.
3. The discharge oE roncontact coolirg waters shall not
elevate the temperature of liu^ooldt Bay to the detriment
of beneficial uses of Huncoldl Bay.
4. The discharger shall comply with the following tne
schedules to assure compliance with Effluent Limitatiors
D. 1., 3. 2., D. 3., and fi. 5. All other provisions
of this peimt shall be applicable upon adoption.
Taik
Limitations n. 1. and
P 5.
Commence proosr; tion of
plan', and i.peci f j ca11 oii
for control facili'-jos
Co-p Liance
l.!r' ill lOls T. 7
Compliance Dote
Report of
Coroli.Tice Due
Progre
repor t
Co->'i<-nce orsiri.c'.ion of
control TKiliUci
Co~ i \ l .me r
April 1, 1977
July 1, 1977
May 1, 19 7 7
January 1, 1970
July 1, 19 70
April 15, 19 77
July 15, 1977
May 15, 19 7 7
January 15, 19 V.'i
July 15, 19 7G
_c>-
-------
t II' |. 11 v. Of
lili CJHLLL±i C ,1 ,mcc IXio
I laU.itlQ.is B 3 ¦
Progio s report
Progress report
Progress report
Progress report
October 1, 19 7 7
July 1, 10 7 :J
April 1, 19 79
January 1, 1900
Ov t oi i' r 15, 1977
Jul;, :5, 1973
April 15, 19 79
Joint r.y 15, 1980
Cor-cncc preparation of
plans and specifications
for control facilities
Progress report
CoTTencn construction of
control facilities
Progress report
Compliance
July 1, 1930
April 1, 19U1
January 1, 1982
October 1, 1982
July 1, 1983
July 15, 1980
April i5, 19G1
January 15, 1902
October 15, 1902
July 15, 1933
The discharger shall suD-nit to tho Regional Board on
or before each compliance repoit date, a report
detailing his co^piia-ce or noncorpli ance uitn tha
specific schedule date and tat!-.
If ronco-npl) ance is bci^.g reported, the reasons for
sucn noncompliance shall oc; staled, plus an estinatc
of L"o date r.icn the discharger will oe in conpliance.
The ci ich.irger nhall notify rhc Regional Board by
letter vhen he h?s returned to compliance with the time
schedule.
5. The discharger shall rotifv the Regional Board not
latei than 130 days in advance of implementation of
any plans lo alter production capacity of tho product
ljnc of the manufacturing, prccuciPg or processing
facility by wore thra ten percent. Such notification
shall include subnitlal of a r.ei/ Report of Waste
Discharge and appropiiate filirg fee.
G. The disrhmger shall file with the Regional Joird a
Report oL lustr Discharge at lr-ast 120 days befoic
maH i'"g any naton.il change or [-.-opened change in the
cha/a^icr, location or volur.i? cf the discharge.
7. The di -charter hill subjii to the Regional Doaid by
J.inu u'7 30 of e ich yonr, an - nual su,i-,iaiy of the
quant l tit*, oi all chi'ncal*;, lifted l\ both trx.o and
che u<. 11 i..mh;s which are u .cd 'or cooling and/or
boilor '/nlcr Lrcat'ienl and 1'nni are ui sell a rged .
-10-
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The di;.ch.u"qer shall ^ubnut to ilio Regional I'onrd
each nont.li with the ionlhly ct'l'luon! n-.oni toring
report a sumnary oT tne quantity of chromium cent n nod
m any chemicals used vlnch reach the waste stream or
which 'light roach Iho waste strnasi in the event of d~\
upset or breakdown.
3. The roquircmcnls pre ;cnbcd hc-cin do not authorj /c the
co vpi .'-.ion oC any net. causing injury to the property of
another, nor protect tnc discharger frort his liroilities
under federal, state, or local laws other than those
adopted pursuant to the Pedcral Water Pollution Control
Act, nor guarantee the discharger a capacity rignt in
the receiving waters.
9. The discharge of any radiological, chcmcal, or
bioluyiual wariare ogent is pru'iioiteci.
1&, The discharger shall permit the Regional Board:
a. entry upon premies (during normal business hours)
in -hich an effluent sourci is located or m which
any requned records arc kept;
b. access to copy any records required to be kept
under terirs and conditions of this order;
c. inspection of monitoring equipnent or records; and
d. sanpling of any discharge.
11. Ml discharges authorized by this order snail be
consistent with the terns and conditions of this order.
The discharge of any pollutant rrore frequently than or
at a level in excess of that identified and authorized
by this order shall constitute a violation of the terns
and conditions of this order.
12. The discharger shall comply with a Monitoring sad
Reporting Progran issued by the Regional Doard Executive
Ofticor and the General Provisions for "onitonng and
Reportirg and any mo.'.if icatior.s to these docunants as
nperified by the Regional Board Executive Officer.
Nam torinq rctioitj sh.ill be .submitted to the K>»gion->l
Dor.)U <~ina U. S. Pnviron iiriit nl I'roLocticn fqoncy for
each n.onth, by the 15th day of the following month,
bcgiPT. "q not lr>tcr linn the drto specified m ch^
Monitoring .ird Revolting Progi.n issued by the c!ec;ior,;:l
P.o.i.j r\ecjti''e Officer. Mouionng cird Reporting
1-roii in No. 7
-------
I-'.. Collet tod orooiunq , s Lu^lnd other od cu it l legal point
ol" f:i ¦ 00-..I I , and in icroi dain-c wilh I lie provi .ion- of
Dn'i'.jon 7.5 of thf Ciliform.i K.il or Code. lor the
puipo >' of Ihi". reqii i rcnen I , .) legal point of di spo . j J
i.\ dciinrd a-. 0110 for winch w.i .lc d 1 - (_h..reje rfquirrri'nts
have !k on pie-.t.nbed by a H(.gi.onnl Water Quality ConL'ol
Board and wm ch is in full conpJiance therewith.
15 After notice and opportunity for a hearing, this orcior
may be tormmntod or modified for cause, including,
but .iot limited to:
a. violation of any torn or condition conrai^cc in this
order;
b. obtaining thii order by -:',ropic^entaUor, or
failure co disclose fully all relevant facts;
c. a change in any condition that requires either a
temporary or pern^neit reduction or elimination
of the authorized discharge.
16. If a to\-ic effluent standard or prohibition (including
any schedule of conpliancc specified in such effluent
standard or prohib-tion) is est ablitiied under
Section 307(a) of the Federal wrier Pollution Control
Act, or amendments thereto, for a tovic pollutant wuch
is Drcsont m the discnargc authorised herein ana
sue!' =t ondoid or oroaibition ib more stringent tnsn
any Imitation upon such poJluta.it 11 this Older, the
Reqional Board shall cordvict a public hearing and
consider revising or rrodifving this order in accordance
with such toMc effluent standard or pronibition anc so
notify the aisc.narger.
17. In the event the discharger is urable to comply with
any of the conditions of this order due to:
a. breakdown of i/aste treaLnent equipment;
b. accidents caused by hunnn error or negligence; or
c. other canyos cucn as acts of nature;
the discharger *>hr>ll notify the Regional Doard C\ccuUve
Officer by telrplioee r.j ¦.oon r.i. ho or hio .-ge.'ts nave
kro' le-'CjC of iho l-cidcit and confiri tin., no I l f l ca 1i on
in \>r: wrg vi'hin t .o ee\.iall
nic'ic uo mi r t • 111}', .err i ,i(;on lo correct the orchlen
and the rl.it c.j tr^u'Of, and v.hit .Up; are being taken
to pri vent the r,roblu'i from recurring.
-------
10. llii: orcl or c\|)ircs> 1 'a yrnis fro.n tlx* iLit e ol adopt ini
and the cii ¦ i hargi-r :n'i .t file a Report of .M c Di-,ch.i."ge
in accordance wiln TiiU- / I, California Arli.u in*, t r.U i v.*
Coc'r, not later than IDO d.iys in advance of ^urh date
as opuhcatior for lSiunnrc 01" now waste dischaige
roquucncnls.
19. In (he event of any charge in control or owner; hio of
land or waste discharge facilities presently ownca or
controlled by the discharger, the discharger shall
notify the succeeding oi.ner or operator of the existence
of this order by letter, a copy of which shall bs
forwarded to the Regional Board.
20. Dy January 1, 1901, the discharger shall submit to the
Regional Board a plan for achieving effluent limitations
representing Most Available Technology Economically
Acuc.rble as OL'tcrnirod ov applying Inc EPA effluent
Imitations guidelines applicable to this dioc^arge on
that date. If the discharger desires a variance for
economic reasons urdcr the provisions of Section 3C3(c)
of the PV.'PCA, such a request, along with all supporting
natenal required by applicable regulations, shall bo
submitted to the Regional Soard by July 1, 1930.
21. This order shall serve as a National Pollutant Discharge
Elimination Systc.T permit pursuant to Section 402 of
the federal Water Pollution Control Act, or ancndscnto
thereto, and sha]l take effect at the end of ten dsyr.
froil ti'o date of adoption hereof, provided the Regional
Administrator has no ob3ections.
22. These waste discharge requirements supersede the waste
discharge rcquironcnfs issued by the K<;gioa,-.l Board cn
Seplenoer 4, 19G3.
Cert i f ic.it l o"
I, Dill Q. Dendv, executive Officer, do hereoy certify
that the foregoing is a full, true, and correct copy of an order
adopted by the California State Water Resources Control Hoard
on |,y,K 1 7 ;J77
Al( &
in j i u. nrrioy 3
Executive Officer •
-13-
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APPENDIX VII
SAMPLE SPCC PLAN FORMAT
FROM
AMERICAN PETROLEUM INSTITUTE BULLETIN D-16
-------
(Prior to (outjtti ting I'ttti /, trft-r to lrqulntmhs nvtl nntntethinn page 5 )
SriLL PREVENTION CONTROL & COUNTERMEASURE PLAN
l'AHT I
CKNHH \I, INTOKM U ION
1. Name of faciliU
2 T\ pe of facihh
3 Location of facility — .—
4 Name and arid! ess of ounei 01 opeiatoi
Name
Add i ess
5. Designated pci^on accountable foi oil spill pie\ention at facilit\
Name and title
C Facility expei icined a jepoitablo oil spill event dining the twchc mollis pnoi to Jan 10, 197-1
(effective date of 10 CFI1 Pail 112) (If YHS complete Attachment —1 )
MANA(.KMi:\T AITUOV\L
Tins SPCC Plan will be implemented as heiem desriibed
Signatui e
Name
Title
CJ.KT1HC \TlO.N
I liet ebv cei (ifv that 1 )ia\c o\.mimed Ihe f.iu!il\, and beinpr familial vmUi Ihe piovisions of 10
CFK, Part 112, attest that this SPCC Plan has !>efn piepaicd in aicoidance uitli poorl rncnfcei in£
practices
Punted Name of Registeied Piofessional laiRineei
(Seal)
Sijrnatin e of kcpslcied 1'iofesi.ional I'li^ineei
Date nefiistialion No State
(fait !) J 3
B-l
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TART I
GENERAL INFORMATION
7. I'olcnli.il .Spills — I'rcdiclion & Conlrol
Tola I
Major Type Qu.uilit.s Hale Direction Second.u >
§ouice of F.uluie (bljls)' (bbls/lu) of Flov.* Containment
Discussion:
•Attach mjp tf appropriate.
Nnmc of fiicility.
0|>oiator
(p*fi i) r«gc 2 of ^
Q-2
-------
PA 1ST I
(;em:hal im okmation
[fih(r.t>lr) ]
8. Containment or rinci Monni v stiuctui es 01 equipment to pie\ent oil from reaching
na\lR.iblc wateis ,uc piacticable (If NO, complete Attachment d:2 )
0 Inspections and RecouK
A 'J lie ) equu ed inspections inllou u ntten pi o.edui e-
I* The \n men pioceduies .mil a hmhiI of m-peclmiis, sipned b\ the appropnate
siipciwsoi cn inspectm. :n e attached.
Discussion
10 I'eisonnel. Tiainnt^. and 'spill I'tecenlion 1'ioceduies
A Pcisonne] .ueptopeih msli inted in the follow inp
(1) npei.itiiui and ruairiteii.tm e of equipment i.u pi e\ ent oil dischaijjes, and
(2) applicable jiollntion contiol laws, mles and i emulations
De^cnhe pioceduics employed foi nicti uction:
P> Scheduled pievcntion l>i lefinps foi the opoialmg peisonnel nie conducted fre-
cpienlh enough to awnc adequate undci standing of the SPCC Plan
Desuilie Imefmp pmgi.in)
Name of facility
Opetatoi
(Pari I) Pace 3 of 3
B-3
-------
(I'not la cu>ni>fitni'j I'ntt fu it giitntion* nm/ nrtwits t'tt'jc a 0'7.)
I'AKT II. ALTHItN \TB A
DKSIfiN AM) OI'KW \TING INFOItM \TION'
ONSHOKK FACIl.l'n (KX( U'UING PRODUCTION)
A l'milil* ni.iin.i^c
J. Di.iui.icc f• 0111 diked stoi.iire .tiens is contiollcd hs follows (include opciating description
of \,thes pumps, eji'ctms, etc1 (Xoh Flu/i/in-tyj>c hi his thniild vot h< asid)
2. Di.tirujtc fioni 11 nrliUcd mens is crtntiotlod ns follow? (intlwle descilption of-powk H^oons,
01 tatclimeiU Ii.t-his ntic pioieihnc foi Mipo1 vising tlic di nmnp:c of l run \\.itei fi om second.u v contnmmcnt into
;i stoim di.un oi .ui open u.itci() niitlirul ol \.il\mj; secmitv) ( A moid of inspection nnd dtamapfe events
is to lie ni.nut.lined nn a foi in smulii to Attachment —1)
N.inio o) f,« ilit\ _
Oppt.itoi
B-4
(Tarl If, A)(
-------
PART II, ALTERNATE *
DESIGN AND OPERATING INFORMATION
ONSHORE l-'AtlLin (EXCLUDING I'KODUl'TJON)
\f\< sponge t<> slut* tnrnt-. ifiimUl b* YF?^, V 0, or \ I {\'o( •! jt/ihablr) )
. nulk Storage T.inl^
). Describe l.mk desijrn. niaienals of construction, fail-safe engineering featuies, .ir.d if
needed, loirosion protection
I?. Describe socondaiy containment, desipn, construction Ri.itci ial« and \olume'
fl. Describe tank mspe<.t">n method^, pioccduies, and record keeping:
4, Internal heating toil leakage is controlled b\ one or more of the following control factori
(a) MonitoiinR the steam return or exhaust lines for oil
Describe monitoring procedure
(b) rasMii^ the steam leturn or exhaust lines through a settling tank, skimmer,
or other separation s>stem
(c) Installing external heating ,> stems
5. Disposal facilities for plant effluents discharged into navigable waters are
obscivod frequentK for induction of possible upsets which maj cause an oil spill
event
Dcicribe method .mil frt(|i>em\ of obser\.itions
Name of facility.
Operator
B-5
(P |