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EMA Case Study Series Chemical contamination clean up effectiveness - Chuchawan Trace - Debe, Trinidad 2006 1 Introduction Acting on information received from Public Health Officials of the Victoria Public Health District – of a possible health hazard posed by a chemical factory operating in Chuchawan Trace, Debe [South Trinidad] the Environmental Management Authority [EMA] initiated an assessment destroyed by fire, leaving exposed drums containing chemicals and other combustible materials on the site. These chemicals subsequently contaminated the site and the surrounding areas which included open pasture land, cane fields as well as adjacent residences. which revealed that the Petroleum Laboratories Company Limited [Petrolab] was using the site for the indiscriminate dumping and unsafe long term storage of unknown chemicals in metal buckets and drums. The environmental audit is a process used to assess a facility's compliance with local government regulations. The objective of the audit is to identify compliance issues so that they can be corrected before environmental degradation or enforcement actions occur. “MUSHROOM clouds of black smoke billowed over the village of Debe near San Fernando yesterday afternoon as fire raged for hours at a chemical site, causing villagers to evacuate their homes. Barrels containing chemical substances from the lab and storage facility at Chuchawan Trace exploded and shot some 100 feet into the air. The chemical fire blazed for at least six hours.” – Trinidad Newsday, March 20th 2005 However on March 19, 2005 (before any proceedings could be undertaken to address this company’s noncompliance with health and safety standards) the Petrolab facility was The Next Step The EMA contracted Green Engineering to conduct a Phase 1 Environmental Site Assessment [ESA] of the burnt out area and subsequently to perform a Phase 11 ESA to further assess the site and to initiate site cleanup in order to prevent further environmental contamination. Phase I ESA typically includes a detailed site description, physical setting review (aerial photographs, interviews, etc.) and a site reconnaissance visit. Also included is a hazardous materials review, photographic documentation and preparation of a detailed report with appropriate conclusions and recommendations. ESA work performed under this standard is typically done at commercial properties, industrial properties and any other property having a known history of environmental issues or for a property that may have been impacted by 2 an adjacent property. Phase 11 Site Objectives included determining: • Levels of volatile emissions and the impact on nearby residences • The nature and the extent of chemical contamination at the burnt out site to include surface and subsurface migration • And initiating a pre-clean up mitigation plan with a view to isolating and securing the site thereby reducing any further risk to public health and the environment. A Phase II ESA is most often preceded by a Phase I ESA, which has identified the presence or likely presence of contamination at a site. A phase II ESA involves sampling, analyzing and measuring and for that reason is generally considered an “intrusive investigation”. Findings and Results • • • Soils showed signs of contamination and distress Initial gas chromatograph [GC] and mass spectrometry [MS] full scan chemical analysis of chemicals in the drums identified the presence of benzene and benzene related compounds, esters and ketones. Laboratory X-Ray Fluorescence [XRF] tests conducted on the solid chemicals revealed that Titanium [Ti] was the most common metal present. (These and other metal contaminants – or their oxidized residues – were believed to be ingredients of metal-treating chemicals and pigments.) Toxicity Characteristic Leaching Procedure (TCLP) tests were conducted on the visibly stained soil samples in order to verify the absence of toxic metals for land burial of this material. The results confirm that TCLP contaminants for the contaminated/ stained soil samples were well below detection limits and Environmental Protection Agency [EPA] Regulatory levels. [Both Toluene and Benzene were absent] What does the TCLP Analysis Show? The TCLP analysis simulates landfill conditions. Over time, water and other liquids percolate through landfills. The percolating liquid often reacts with the solid waste in the landfill, and may pose public and environmental health risks because of the contaminants it absorbs. The TCLP analysis determines which of the contaminants identified by the EMA are present in the leachate and their concentrations. 3 4 Site clean up and restoration The tasks associated with this phase of the project included: 1. Removal of contaminated soil and hazardous material from the area 2. Treatment and disposal of hazardous chemicals and wastes 3. Restoration of the affected area in order to meet the soil cleanup standards in keeping with the Ministry of Energy and Energy Industry’s Guidelines. Project activities included: . . . Chemical drum identification and segregation . Hazardous waste treatment and disposal of both solid and liquid chemicals Building demolition Removal of scrap metal and other construction waste . and the Biological treatment of waste water removed from the septic underground storage tank. 5 Site preparation and worker safety Prior to each work day, the site was isolated and warning signs and caution tape were used to demarcate the work zone. The work environment was tested daily for toxic and flammable gases. Before the commencement of hot works, gas monitoring was conducted daily to detect explosive and flammable gases. Throughout the duration of the project, all the appropriate safety procedures and personal protective equipment were employed for the handling and treatment of all waste materials on site. The restored area was tested and verified as having met the soil clean up standards in keeping with the Ministry of Energy and Energy Industries [MOEEI] guidelines This included the use of respirators, coveralls, full body suits, gloves, head protection, and eye protection, etc. to minimise exposure to any toxic components of the waste. Daily safety briefings and discussion of work programs were conducted by the Site Supervisor with workers outlining potential issues and/ or hazards associated with the assignment. The Petrolab site restoration was completed with the addition of a final layer of top soil material. A decontamination station was set up for the decontamination of workers at the end of the work day. Bringing it all together All “hazardous” chemical materials and contaminated soils were removed from the Petrolab site and disposed of in an environmentally safe and acceptable manner, using environmentally sound methods. 6 On the issue of Corporate Social Responsibility [CSR] Today’s companies may invite litigation and eventually lose customers and profits while tarnishing images if they ignore “corporate social responsibility” (CSR). The increased cost of civil and criminal litigation incurred by companies who do not embrace environmental concerns is clearly a risk that that will be always present. There are additional hidden costs generally overlooked when a company refuses to implement CSR policies. These include the loss of good staff, decline in reputation, exposure to naming and shaming by pressure and interest groups, decline in stock value (if listed), increased cost of borrowing, increased insurance premiums, loss of good-quality business partners and loss of customers. Environmental Management Authority [EMA] 8 Elizabeth Street, St. Clair P.O. Box 5071 Port of Spain, Trinidad – W.I. Telephone: 1-868-628-8042 Fax: 1-868-628-9122 Email: [email protected] EMA Green Tips Practice waste reduction. Make a list of current waste chemicals and ask, for each item, "Is there a way I can avoid producing this waste?" Try to reduce the toxicity and amount of waste generated. Consider the following: Replace toxic raw materials with non-toxic raw materials wherever possible. Replace toxic operational supplies, such as cleaners and solvents, with non-toxic materials wherever possible. Improve production process efficiency so that less raw material ends up as waste that must be disposed. Reuse samples in production. Encourage employees to think "waste reduction." Better yet, include them in the planning process - they have good ideas. Give them an economic incentive to reduce waste. Reuse process by-products and wastes as raw materials, either on-site or in another company's process. 7