Environmental Audit for the MTBE Plant Report (Assessment)

Introduction

MTBE plant was established to advance the petrochemical industry in the country. The town in which this plant is constructed is ideal because it offers various industrial advantages like good infrastructure access and reliable feedstock and accessibility to an industrial seaport.

MTBE (Methyl Tertiary Butyl Ether) is a chemical that oxygenates gasoline. This means that it contains oxygen and is used to enhance fuel. It is actually the most commonly used Oxygenate for fuel since it can be blended easily with petrol hence it serves as the best alternate gasoline component (Heilprin,200)

MTBE has a very high octane rating that makes it an ideal alternative to other octane components such as lead. Another advantage is that it is used in cleaner-burning gasoline formulation (Cater et al 36). This is what has led to the replacement of leaded fuel as it highly reduces emissions of pollutants emanating from exhaust MTBE 1is based in an industrial area. The products from this plant are sold locally and internationally. With its ever-growing use, MTBE has come to be associated with some environmental concerns. Its potential hazards have also been documented.

Environmental Policy

There is an adequate environmental policy for the project area. According to information gathered an environmental policy administration was set up in this to govern all the industries in the country. That is why every plant that is established is required to conform and clearly subscribe to the dictates of the clean environmental administration of the agency in charge. In this plant, the environmental policy is posted on the notice board. It clearly states that aims at protecting the heritage of future generations.

Before the establishment of the plant, there was a feasibility study carried out to ascertain its possible environmental impact. This has been in conformation with the national industrial strategy. In this strategy, the country has decided to concentrate industrial plants in areas that are conducive to environmental concerns. This national industrialization strategy has greatly led to many plants including MTBE 1 to be well located in areas that are conducive to the overall clean environment strategy. The national policy has therefore compelled any MTBE 1 to take charge in matters concerning air pollution, industrial and waste concerning air pollution, industrial and waste management, water treatment as well as the development of intensive environment monitoring programs (Romanow, 235).

There are adequate mechanisms for communicating the environmental policy in the plant. To this end, there is a proper management structure that is tasked to handle environmental issues in the firm. This can easily be seen from the organ gram listing the various levels. At the top are environmental issues in the organization. There is also a health officer who also falls in this category. Besides, the specialist staff under this cadre of staff. These will coordinate structure ensures that all information concerning the environment reaches the rest of the staff and even contractors. Further still, the department is equipped with tools and equipment that are crucial in training. From the account given, it was established that the staff is briefed on a monthly basis on issues concerning the environment. Quality concerns are also stressed to the staff, contractors and other third parties. What could not be established however is the period the contractors are briefed on the environmental issues. There seemed to be more emphasis on briefing the staff as opposed to the contractors, who seem to be briefed only once they are contracted. All in all the mechanisms that are in place are adequate to effectively communicate environmental policy.

The responsibilities for implementing the environmental policy objectives are what were also established. For instance, the main person responsible for implementing the policy is the environmental manager. He actually heads other specialist staff under him and he is the one solely responsible for making sure that the various objectives of the policy are implemented in the company. Whilst the responsibility of the environmental policy lies with the environmental manager the plant, stresses that all other players have a crucial role to play so that the whole environmental policy is safeguarded. The staff contractors and other third parties are therefore given rules and regulations which they are required to abide by. These rules and regulations are clearly postulated in the environmental policy.

Also, other departments are required to cooperate so that the environmental policy is implemented.

There is an environmental plan which has identified each and every environmental aspect which includes:

• Noise and vibrations
• Air emissions
• Effluent and wastewater
• Waste management
• Solid waste
• Energy management
• Water management

Under health and safety the aspects include occupational hazards. The health and safety committee has listed the risks and hazards that may occur. The unit is equally tasked with training and instructing the staff and other third parties on these risks.

There seems to be an adequate budget for the project are sufficient to mitigate the various challenges that may occur.

The management is committed to environmental issues. This can be proved from the signing of the environmental policy by the top management of the plant. This shows that the management is cognizant of the importance of environmental sustainability. This is further replicated by other managers down the structure.

Environmental issues are considered at regular meetings. This could be seen from the minutes sampled. In fact, it is encouraging to learn that environment is usually part of the meetings the overall emerging issue concerning the environment have always arisen and been discussed.

Environmental training and systems of work

All the tasks/operations that pose a significant risk to the environment have been identified. For being a solvent MTBE is said to fast percolate and reach the groundwater, giving it an unpleasant taste. Its greatest potential risk is that it can render such large amounts of water unfit for human consumption. The other risk is that of over-reliance on underground storage tanks (USTs). When this leaks, the MTBE leaks, and it is through this that it can reach the underground water. Some of the health risks of this MTBE in animals have been established.

The environmental manager together with the environmental committees have put in place a framework through which other challenges emanating from all the plant’s activities can be addressed.

There is a procedure laid down for mitigating several environmental issues. For this, MTBE 1 has put in place preventive measures. For instance, to effectively mitigate the risks in critical locations, warning signs are clearly posted. There are also clear instructions to the workers to wear gas masks while working in the plant. But this is not the only measure; there are equally preparedness mechanisms available, just in case there is a disaster. For example, there are adequate exit channels. Corrective actions are also well laid down. For all the above, there is clearly written procedure that stipulates the persons responsible for certain actions and the corrective measures that are to be taken. For example, the health officer is in charge of problems arising from human injury or any other effects. The officer keeps a detailed record of the trends, plus their corrective action.

The workers are well trained in the systems of work.

There are contractors’ agreements but the contractors are only briefed at the initial stages of their contract. The clause in the agreement stresses the need for contractors to be bound by the plants’ environmental standards. By this, it is hoped that contractors who violate this may end up losing their contracts or being subjected to legal challenges. It is also expected that the contractors take great care when loading, transporting and even unloading the materials to avoid any harm to the environment. The challenges of this could come in form of spillage of MTBE products and even bi-products both on land and sea.

From the records obtained it could not be ascertained the regularity with which the contractors are monitored. But what could be established is that contractors are usually briefed on their environmental and legal requirements only once they have been contracted. For this plant, the contractors usually sign a worksheet that is renewable. Their ability to conform is usually done at the time of their being contracted. Though it is pertinent that the contractors analyze their daily activities vis-à-vis environmental issues, this is not the case like this in only done during initial training sessions and also during refresher courses. It could be noticed that the contractors wore protective gear while at work.

All employees are adequately informed about the necessary environmental issues relevant to their work. At this point, the management has succeeded at making sure that the employees have the relevant education. From the human resources department, it was established that all employees qualified for the respective jobs they were assigned. The lowest was tertiary education. This has made sure that there is no situation where one may be found doing what one does not qualify for. Also, most employees have gained valuable experience in periods of service. This is further enhanced by the refresher courses they are subjected to. These refresher courses make them keep abreast with the ever-changing technology, legal requirements and even opportunities.

The training is of particular help too, as working in such a plant exposes one to many environmental risks. For instance, should one person ascertain a task wrongly, the effect on others and the environment at large could be unfathomable. This could lead to issues such as improper waste disposal, effluent or even product spillage, etc.

The environmental management committee through incident records has been able to identify the emerging environmental training needs of all the plant’s employees. To achieve great success, the committee, through the environmental management and the underlying structures, has effectively communicated the information to the relevant departments and personnel. This was also established because the MTBE 1 plant has well-kept records of environmental management training. The people who offer this training are equal to the task as they are well qualified and experienced trainers.

There are formal systems for recording complaints. However, most of the complaints only come from employees. Third parties seem not to have the confidence or the freedom to submit their complaints.

Products and operations

MTBE produced are under various restrictions though there is no clear record of its effects on humans.

All the materials produced and used at the plant are usually assessed with a view to ascertaining relevant environmental concerns. Through samples, materials produced and used are taken to the laboratory for analysis, but it could not be concluded as to whether such analysis is in relation to an injury to the products related to the environment. One could think that the aim of taking such material to the laboratory is just to ascertain the quality of the product. However, it was found that the plant’s management relies on findings carried out elsewhere to take the environmental measures. Mostly this is the USA, which has a stronger partnership with this plant.

The mechanisms put in place are adequate to make sure that all materials/substances used or services have the least impact on the environment. One such measure could be seen in the transportation of the product. During offloading and loading there are strict requirements against spillage. At the port there is an isolation channel constructed, where, should a spillage occur, it cannot find its way into the sea.

Emergency preparedness is another aspect that the plant’s management has greatly explored. For instance, there are evacuation halls where should fire occur; the staff can easily be evacuated.

Another mechanism is containment. There is large storage to USTs that store the products. This greatly helps to avoid subjection to bursts and any other risks.

Since there is a lot of heat used in the plant, there are several cooling measures that make sure that the staff is not subjected to detrimental temperatures. Most of these are coolants. These coolants also could prevent bursts that could occur under very high temperatures.

Signs and warnings are placed all over strategic risky areas. These effectively warn the staff and other third parties against possible accidents.

Also, operational channels are placed strategically so that most operators consult in case of a situation that brings doubt occurs. Also since technology is ever-changing, this is a good measure taken in this plant.

There are mechanisms to ensure that products or services have the least impact on the environment. This is well illustrated by the measure taken in the loading and unloading of products. For instance, at the port, there is a channel through which the ship docks. The water here can be isolated from the rest of the seawater just in case contamination occurs. Also, the trucks stand on hard impermeable stands so that should there be spillage of MTBE and other substances cannot permeate and pollute land as everything is controlled right from the wharf to the gantry. The tanks are cooled and fire extinguishers are put in place just in case of a fire. What is more, the pipes used between the trucks and even ships are special Flexi ones. These can hardly burst or get broken.

There are appropriate measures put in place to minimize adverse environmental effects associated with energy generation/transmission/use. First of all energy conservation is given first priority. Energy-saving bulbs are used. There are also instructions directing that unused rooms should have their lights put off.

On energy produced through the use of diesel engines, solar energy has been greatly used. This energy is cleaner. The V-belts of motors are checked before work starts. They are also changed well in time.

Equally, the plant stresses proper ratings of parts that it procures. This is done through strict procurement measures that put quality among anything else.

To further reduce noise and vibrations, truck drivers are instructed not to leave their trucks idling for long. They are usually instructed to immediately switch off their engines immediately after they stop.

Transportation of some materials requires notifications.

Materials Use and Storage

Ethanol and even isobutylene are stored in this project area. Ethanol and isobutylene can be hazardous to human beings if ingested. Ethanol is highly flammable and can easily cause fires if not handled properly.

The potential environmental risks for these items have been identified and assessed. For example, ethanol and can cause a fire. At the same time, if ingested, it can lead to death.

All environmentally hazardous wastes are stored in suitable facilities. For example, there are USTs constructed where these substances are stored away from any form of interruption.

Unloading and loading are done using very strict measures. First of all the design of the loading and unloading points is suitable. The place where the truck’s load is made of an impermeable floor where even if the substances are spilled they will not sip through. Also, the place is replete with an interceptor where should the spill be overwhelming the substance will get into the interceptor tank. Also, the channel is well constructed to cover for any spillage. This makes sure that the spill does not mix with the seawater. The facilities are adequate.

The storage facilities comply with the applicable licenses. For example, these substances are not allowed in open storage so there is a need to comply with the requirements set.

The storage facilities are subject to planned inspection and testing. The procurement committee is tasked with the role of sticking to high-quality products. The insurance company managing this requires that the right specifications of storage facilities are in place.

There is a de-commissioning procedure that governs disused storage facilities. First of all, there are notifications that show the intended operation. Also for some cases, there are licenses required as even this could disrupt the environment especially when it comes to those facilities at the offloading zones.

Consultants are also involved in safe decontamination and de-commissioning. There is usually standby power so in case of normal power failure the process remains a success. To avoid disruption to the normal daily work, the work is sometimes carried out at night.

Waste Management

There is a plan for waste minimization. For example, water used in other functions is usually recycled so that it can be used for other purposes. The plant advocates re-use, recycle then dispose of.

There are various categories of waste in this area. For example, there is domestic waste, industrial waste, biodegradable waste and even hazardous and non-hazardous waste.

All the waste is stored according to the regulatory requirements set out. This is why there is the separation of the waste into categories. For instance, human waste goes into the municipal sewage grid while industrial waste is the responsibility of the plant.

All regulatory requirements towards waste management are met in this project area.

The plant management takes the carriers/contractors through a prequalification assessment. By this, all regulatory requirements are met.

All wastes are not subject to regular analysis. This could not be ascertained since there were records to prove this.

The waste generated is properly classified and is handled differently.

Not all wastes transfers meet regulatory requirements for pre-notification.

There are records that show the transfer of waste. But these records only detail the number of times a particular contractor has transferred waste.

Effluent Treatment and Discharge

There is no stormwater runoff in this project are. However, domestic sewerage is discharged owing to the staff and other visitors to the plant.

All regulatory requirements for sewer discharge have been identified. The municipal authority is very strict when it comes to this.

So far all discharges meet consent requirements required by the environmental department. The facilities are adequate for effluent treatment.

The frequency of monitoring the effluent is not clear as there are no records for such. In this area, there is no surface water as it is a desert. This is not a key issue in this project area. Stormwater is not a key issue in this project area. No records could be found for this issue.

Emissions to Atmosphere

There are emissions to the atmosphere from project one is that of gas that emanates from the project. One is that of gas that emanates from the processes. Another is exhaust fumes emanating from trucks that load and unload in the project area.

All regulatory requirements have been identified. Not all emissions meet regulatory emissions. For example exhaust from trucks is something that has never been seriously factored in.

All the plans to render all emissions harmless are not adequate

The control devices are not adequate for their purpose as some emissions are treated while others are not targeted.

The records are not present.

The regularity could not be established from many records.

Not all operators are trained. This is taken to be the responsibility of a few.

No adequate assessments have been made to establish the effects of these emissions on the atmosphere. This is perhaps due to the fact that the plant is in a designated industrial area.

There are no records of fugitive emissions. But the general measures are meant for all the emissions.

Noise and Nuisances

There are not adequate measures to control noise emission from the project area. The measures put in place are general. For example, truck drivers sometimes honk on the premises of the plant.

The noise emanating from this plant is generally low. Thus it meets the regulatory requirements.

This is not an issue in this plant.

The measures are not adequate as sometimes truck drivers honk with the precincts of the project area.

Land and property management

All requirements applying to land, property and services in the project area have been identified. The placement of the project in this industrial area puts it in a position of no conflict concerning land, property and other services.

All the requirements are met by virtue of the place where the project is situated.

There exists no conflict. For example, the underground storage tanks used are inspected regularly to avoid leakage to land underground water.

Given that the area is in an industrial area there is adequate security for the project. Again since residents stay a bit far away from this area there is no big security

Hazardous places are well guarded. There is a perimeter fence around the underground tank areas and even power installations are isolated from the reach of daily staff paths.

There could be risks of land contamination but the project is in an area that is suited for its placement. Again all the challenges of land contamination were looked into before the industrial area was established here.

There are appropriate measures and procedures for assessing environmental modifications for the existing facilities. As many things change, including technology, there is usually a review by the management to always adopt environmental best practices by the plant.

This is not an issue here. The land around the project is not arable so the issue of pesticides does not apply to this area.

There was no obsolete equipment identified.

There are no radioactive materials, used in any process in this project.

Incident and Emergency Response

There are adequate procedures for reporting environmental incidents and near misses. This is because in the plant the environmental committee agrees to open free correspondence on any project area that has a record of incidences as they are reported and attended to.

Accidents occurring are reported based on the information from the health facility on the project area.

All corrective actions are hardly reported. Usually, the corrective measures will be undertaken and no one is told about them unless they discover them on their own.

The leak and spill responses are adequate. These range from the measures taken at the loading and unloading points as earlier on discussed.

Not all environmental hazards have been identified. Fire, explosion, major spill, major leak, gas release are the only ones that have been given attention. Though flooding is not a major issue here, the unplanned reaction has not been catered for at all.

There is no documented plan for the identified environmental hazards.

Emergency responses are not tested by planned exercises.

First aid procedures are well documented. The emergency personnel undergoes drills.

There is sufficient emergency equipment. There are ambulances, first aid kits in all operations facilities and many others.

Conclusions and recommendations

There are various conclusions and recommendations that can be drawn from this project. The management should strive to:

• Open communication channels in the project where all the staff can present their worries, contributions and even observations without fear or favor.
• Document most of the environmental procedures. Perhaps environmental management should be done systematically and all staff should be involved.
• Contractors should be seen to be playing an integral part in the wider environmental goals of the project area.
• Put more effort into assessing the impact of emissions on the atmosphere as this seems to have been ignored.

Contractors should be well incorporated into the project’s environmental plan. That means that they should be bound by the contract to observe the environmental direction that is in the project’s policy. But this should not stop here. The contracts must be subjected to proper audit before the contracts are also offered. This is meant to ascertain the extent of their knowledge of environmental issues. From what was found in this project it was established that the contractors are not subject to regular training about the environmental challenges emerging. This should not be allowed to continue. The participation of this cadre should be as regular as that done by the regular staff.

Waste management is another area that is causing a lot of problems. There is a great need for a clear record of the type of waste so that it is easy for the environmental management to ascertain whether the levels fall within the permitted levels.

The audit established that some environmental hazards are not included. For instance vibrations and even high temperatures emanating from heating processes in the plant. It is against this awakening that the management is advised to look into ways of documenting all the hazards so that their mitigation approaches are put in place beforehand.

The records that show waste transfer should be detailed. They should include a long on the performance of the contractor charged with the duty of transferring that waste. This monitoring should be therefore put in place to stave off any negligence on the part of the contractor.

All emissions should be targeted. Exhaust from the tracks was found not to have been documented, yet it is a big challenge. What was documented was only the noise and sometimes nuisance caused by these trucks.

All operations in the plant should be trained on the various environmental issues that take place in the industry.

Staff, contractors, and third parties should be trained through role play. By this, the trainees will have a real-life feel of how they can for example escape resuscitate a colleague, etc.

Emissions to the atmosphere are an area that the audit report found greatly in jeopardy. There is a great need for these types of emissions to be considered and documented separately so that it is easy to ascertain their effects and levels. It was for instance interesting to note that it is fugitive emissions have not been considered seriously. In as much as such emissions do not occur easily in this plant, there is a great need for an expert to be incorporated so that all the possible avenues of their occurrence are well documented and corrective measures taken.

Most of the work and tasks should be time-bound such that the tasks should be broken down into time-restricted blocks. A good reason for doing this is to make sure that all the elements of a particular problem are looked into and in good time.

There is a need to strengthen the strengths that the project has exhibited. Other measures of alternative energy such as solar even wind energy should be explored.

Finally, the core issue in driving the project should be clearly elaborated in the policy. The policy statement should inspire all to look into environmental concerns that face the organization.

Clear medical examination structures should be put in place so that their employees are shielded from suffering from occupational ailments. They should be taken for serious and regular medical examination. The audit report found the health committee silent on the issue.

Works Cited

Cater, Stephen R., Dussert, Bertrand W., and Megonnell, Neal. “Reducing the Threat of MTBE-Contaminated Groundwater.” Pollution Engineering (2000): 36. Print.

Heilprin, John. “Senate committee approves bill to phase out anti-pollution fuel additive that contaminates drinking water.” Associated Press (2001). Print.

Romanow, Stephany. “Killing the Messenger-MTBE.” Hydrocarbon Processing (1999): 15. Print.