ENV10305, Closure
ENV10305, Closure
ENV10305, Closure
Closure
Note: The source of the technical material in this volume is the Professional
Engineering Development Program (PEDP) of Engineering Services.
Warning: The material contained in this document was developed for Saudi
Aramco and is intended for the exclusive use of Saudi Aramco’s
employees. Any material contained in this document which is not
already in the public domain may not be copied, reproduced, sold, given,
or disclosed to third parties, or otherwise used in whole, or in part,
without the written permission of the Vice President, Engineering
Services, Saudi Aramco.
CONTENTS PAGES
There are many solid and hazardous wastes that can be generated by Saudi Aramco
Operations. The types, sources and potential impacts of these solid and hazardous wastes are
discussed in this section.
Definitions
To provide a frame of reference for the discussion of solid and hazardous wastes, it is
important to know some terms that are associated with the topics that are covered in this
module. These terms are discussed next.
Waste is any material that must be disposed because it has no further primary use. Waste does
not include aqueous and gaseous effluents from operating units.
Solid waste is waste that includes garbage, refuse, and sludge as well as any solid, semi-solid,
liquid, or contained gaseous material that is discarded. A discarded material is one that has
been abandoned, burned, or incinerated.
Class I wastes are hazardous wastes. A hazardous waste is a solid, liquid, or gaseous waste,
or a combination of solid wastes that may, because of its quantity, concentration, or physical,
chemical or infectious characteristics present problems as follows:
Class II wastes are non-hazardous solid wastes that are biologically or chemically
decomposable in the natural environment. Examples of Class II wastes are garbage, paper,
digested sewage, animal wastes, and other putrescible wastes.
Class III wastes are non-water-soluble wastes that are not biologically or chemically active in
the natural environment. Examples of Class III wastes are glass, plastics, rubber products,
brick, concrete, and clay.
Types
There are many solid and hazardous wastes that are generated by the petroleum industry
generally, and by Saudi Aramco operations. Figure 1 lists generic and specific types of waste
and the origins of those types of wastes that are generated by the petroleum industry.
The various types of solid and hazardous wastes (impacting agents) are categorized in three
major areas, according to the area of operation that generates the waste. These three sources
are as follows: industrial, residential/commercial, and construction.
Saudi Aramco’s waste generation, the amount, and the method of disposal for each of the
three areas that are identified are shown in Figure 2. Two of the three areas are subdivided
into several classes of wastes. For example, industrial wastes are subdivided into five types,
as follows: oily liquid; solid; oily sludge; redundant containerized chemicals; and, precoat
filter sludge/reclaim sludge. In addition, each type may be sub-categorized further. For
example, crude oil is tracked and treated separately from slop oil. Residential/commercial
wastes are divided into 4 major types, as follows: asbestos; garbage/trash/medical (non-
hazardous); medical (hazardous); and, confidential documents. Figure 2 provides additional
information about Saudi Aramco’s waste generation sources, content, physical state, methods
of storage, and disposal locations. Figure 2 is from a 1987 waste survey. The quantities
indicated are those reported by Saudi Aramco plants.
Annual
Quantity % Of
Type Of Waste (M3) Total Disposal Method
A. INDUSTRIAL
1. Oily Liquid
1.1 Oil
- Crude Oil 15,226.00 1.869 • Recovered
• Offsite Disposal
- Stop Oil 1,461.00 0.179 • Recovered
1,375.00
• Burn Pit
• Open Dumped 86.
00
- Lube & 320.00 0.039 • Landfarmed
Hydraulic Oil • Offsite Disposal
• Recycled
• Burn Pit
- Engine Oil 227.00 0.028 • Open Dumped
1.2 Oily Water 75,136.00 9.224
- Oil • Recovered
• Offsite Disposal
- Water • Evaporated Or Discharged To The Gulf
2. Solid
2.1 Asbestos * • Asbestos Disposal Site
2.2 Non- 24,423.00 3.00 • Solid Waste Landfill
Hazardous (Industrial Waste Area)
• Reclamation (RCSHF)
2.3 Hazardous 330.00 0.041 • Offsite Disposal (Beea'h) 122.00
• Reclamation (RCSHF)
208.00
* Not determined
ANNUAL
QUANTITY % of
TYPE OF WASTE (m3) TOTAL DISPOSAL METHOD
3. Oily Sludge 31,700.00 3.8922 • Landfarmed
1,740.00
• TEL Sludge
70.00
• Offsite Contractor
8,698.00
• Lagooned (Recovered) 21,192.00
4. Redundant
Containerized
Chemicals 446.00 0.055
4.1 RCSHF • Sold/Recycled
223.00
• Stored/Offsite Disposal
(Beea'h) Landfill III
223.00
5. Precoat Filter
Sludge/
Reclaim Sludge 908.00 0.111
5.1 Liquid • Lined Evaporation Pond
5.2 Solid • Landfill Class III
B. RESIDENTIAL/
COMMERCIAL
1. Asbestos 28.00 0.003 • Asbestos Disposal Site
2. Garbage/
Trash/Medical 55,630.00 67.722 • Solid Waste Landfill
(Non-Hazardous)
3. Medical 500.00 0.0061 • Medical Waste Incinerator
Hazardous)
4. Confidential 68.00 0.008
Document
4.1 Shredded • Solid Waste Landfill
4.2 Unshredded • Burned
C. CONSTRUCTION
1. Solid Waste 112,145.00 13.768 • Construction Waste Area
Landfill
Total 814,548.00 100.00
Saudi Aramco's waste generation is shown in Figure 3. Figure 3 also presents additional
information, such as, context, physical state, method of storage and disposal locations of
different types of wastes in each of the 3 major areas.
WASTE INDUSTRIAL
CATEGORY
Solid Waste Redundant Other
Waste Oil Oily Water Oily Hazardous Non- Container-ized Wastes
Description Sludge Hazardous Chemicals Caustic
Drilling
Fluids
Waste Various Various Tank Various, Various, Almost All Explor-
Source Bottoms, Most Most Facilities ation, On
Mainly Facilities Facilities And
Offshore
Waste Hydro- Hydro- Hydro- Various Various Various Rock
Content Carbons Carbons Carbons, Cuttings,
And Water Water And Chemical
Solids s
And
Water
Availability Yes, Yes, Yes, Yes, For Yes, For Yes, For No
Of Waste Some Some Some Some Some Some
Analysis Organi- Organi- Organi- Wastes Wastes Wastes
zations zations zations
Physical Liquid Liquid Sludge Solid, Solid, Solid, Liquid, Liquid &
State Of Liquid, Liquid, Gas Solid
Waste Gas Gas
Method Of Tanks, Tanks, Tanks & Drums; Lugger Drums, Not
Waste Sumps, Sumps, Lagoons, Lugger Buckets Boxes, Known
Storage Lagoons Lagoons Mainly Buckets Usually Or Bags,
On Site Drums Cartons,
Gas
Cylinders,
Etc., Stored
In Rows
Max. Various Various Various Varies For Varies For Usually 55 N/A
Vol. Of Lugger Lugger Gal Drums;
Container Buckets; Buckets; Some 540
Gal
Containers;
One 5,000
Gal
Container
Max. Various Various Various 400 Lb. 400 Lb. 1,000 Lb. N/A
Weight Of For Full For Full For Some
Container Drums Drums Drums
Avg. Not Known Not Known Not Known 7.4 Cu. Ft. 7.4 Cu. Ft. 7.4 Cu. Ft. N/A
Vol. Of For 55 Gal For 55 Gal For 55 Gal
Containers Drums Drums Drums
When
Collected
WASTE INDUSTRIAL
CATEGORY
Solid Waste Redundant Other
Waste Oil Oily Water Oily Hazardous Non- Container-ized Wastes
Description Sludge Hazardous Chemicals Caustic
Drilling
Fluids
Current
Generation 17234 75136 32608 *330 24423 446 Not
Rate Available
(Cu. M/Yr)
Projected Not Known Not Known Not Known Not Known Not Known Not Known Not
Generation Known
Rate
(Cu. M/Yr)
Entity Internal Or Internal, Contractor, Internal Or Internal Or Contractor Internal
Removing Contractor Usually Usually Contractor Contractor Or Private
Waste Buyers
Disposal Various- Waste Various- Reclama- Landfilled, Sold/ Onshore
Location Some Phases Some tion Area, Usually Or Reused 50% And
Recycled; Are Recovered Landfill Or Reclama- Commercial Offshore
Some Separated Land- Offsite tion Area Waste
Disposed And Oil Is farmed, Mgmt. 6%
By Recovered Contractor Landfill
Contractor In Plant Disposed Onsite 2%
Offsite Offsite, Landfill
Burn Pit Or Offsite 3%
Sand Stored
Stabil- Onsite 39%
ization
Frequency Varies Both Inter- Inter- Varies Varies Approx. Not
Of Waste With Each mittent mittent With Each With Each Twice Known
Removed Generator And Usually At Generator Generator Weekly
From Site Continuou Time Of
s Tank
Desludging
Quantity Of Varies Varies Varies Varies Varies 1-3 Tons Not
Waste According According According According According Known
Removed To Source To Source To Source To Source To Source
Max. Quantity Varies Varies Varies Little Is Not Known 3468 Metric N/A
Of Waste With Each With Each With Each Stored Tons
Stored Organi- Organi- Organi- Onsite-It Is
Onsite Zation Zation Zation Usually
Promptly
Removed
Mode Of Not Not Not Not Not Not Not
Payment For Disclosed Disclosed Disclosed Disclosed Disclosed Disclosed Disclosed
Removal
Other – – – – – – –
Comments
*does not include asbestos generated from industrial source
CONSTRUCTION
WASTE
RESIDENTIAL & COMMERCIAL DEMOLITION
CATEGORY
Garbage, Trash, Medical
Waste Medical (Non- (Hazardous) Asbestos Construction
Description Hazardous) Wastes
Waste Residences, Hospitals, Buildings Under Various
Source Offices, Hospitals, Clinics Renovation Structures,
Clinics Or Demolition Foundations,
Industrial
Plant, Roads,
Etc. Being
Constructed Or
Demolished
Waste Paper, Pathological: Asbestos And Concrete, Brick,
Content Cardboard, Including Asbestos With Clay, Metal
Wood, Plastic Tissue, Cement Or Other (Usually
Refuse, Animal Body Parts, Binding Agents Steel),
And Vegetable, Sharps, Lumber,
Non-Pathological Dressings, Blacktop, Etc.
Medical Waste Gloves,
Clothings,
Sheets, Etc.
Availability Of Yes, At Two Not Known Yes, Polarized No
Waste Analysis Disposal Light
Locations Microscopy
Analysis Is
Used To
Determine Type
Of Fiber
Physical State Solid Solid Solid Solid
Of Waste
Method Of Plastic Bags, Plastic Bags Plastic Bags, Stockpiled
Waste Storage Drums, Lugger Lugger Buckets Prior To
Onsite Buckets Removal
Max. Vol. Of Lugger Bucket 2-3 Cu. Ft Lugger Bucket Lugger Bucket
Container
Max. Weight Of Not Known 20 Lbs Not Known Not Known
Container
Ave. Vol. Of Not Known 2-3 Cu. Ft Not Known Not Known
Containers When
Collected
Current Generation 551,698 500 28 112,145
Rate (Cu.M/Yr)
Projected Not Determined Not Determined Not Determined Not Determined
Generation
Rate (Cu.M/Yr)
CONSTRUCTION
WASTE
RESIDENTIAL & COMMERCIAL DEMOLITION
CATEGORY
Garbage, Trash, Medical
Waste Medical (Non- (Hazardous) Asbestos Construction
Description Hazardous) Wastes
Entity Removing Contractor Contractor Contractor Contractor
Waste
Disposal Location Company Solid Company Company Company
Waste Landfill Medical Special Landfill Solid Waste
Incinerator; Reserved For Landfill In
Incinerator Ash Asbestos Disposal Area
Is Landfilled Reserved For
In Company Construction/
Landfill Demolition
Waste
Frequency Of Regularly, Incineration As Necessary As Necessary
Waste Removed (Several Times Takes Place During During
From Site A Week) Onsite Demolition Construction/
Demolition
Quantity Of As It Is Ash Removal To Varies According Varies
Waste Removed Generated Landfill As To Nature Of According
Necessary Job And Job Size To Job
Max. Quantity Lugger Bucket Possibly Little Is Stored Varies
Of Waste Stored Quantities 20-30 Bags On Site.
Onsite At Some Awaiting It Is
Locations Incineration Promptly
On Occasions Removed
Mode Of Not Disclosed Not Disclosed Not Disclosed Not Disclosed
Payment For
Removal
OTHER COMMENTS – – –
Industrial
As can be seen in Figures 2 and 3, there are many types of solid and hazardous wastes that
can result from industrial operations. The wastes that can be produced from Saudi Aramco's
industrial operations include as follows: oily liquids; solids; oily sludge; and redundant
containerized chemicals. Each of the types of wastes is discussed in this section.
Oily Liquid is an oil and water mixture. As can be seen in Figures 2 and 3, examples of oily
liquids are as follows: crude oil, slop oil, lube and hydraulic oil, engine oil, and oily water.
Oily water is by far the largest single type of oily liquid produced by Saudi Aramco's
operations.
Solid-As can be seen in Figures 2 and 3, Saudi Aramco generates three types of solid waste,
specifically, asbestos, non-hazardous waste, and hazardous waste. Almost all of the solid
waste produced by Saudi Aramco is non-hazardous waste.
Oily sludge (including TEL contaminated sludge)- Oily sludge is sludge that contains oil. Included
in this category is tetramethyl/ethyl lead (TEL) contaminated sludge. TEL is a highly toxic
gasoline additive that requires special disposal precautions.
Redundant Containerized Chemicals are excess, unwanted chemicals that have been purchased in
secure containers. The containers are safe to handle while the containers are stored or when
they are disposed. In addition to the unnecessary expense of purchasing supplies that are not
needed, redundant containerized chemicals add an extra expense to the company, specifically,
the disposal of the chemicals.
Residential/Commercial
As can be seen in Figures 2 and 3, there are many types of solid and hazardous wastes that
can result from residential/commercial operations. The wastes that can be produced from
Saudi Aramco's residential/commercial operations include as follows: asbestos; garbage;
trash; non-hazardous medical; hazardous medical; and confidential documents. Each of these
types of wastes is discussed in this section.
Asbestos is a carcinogen that was once widely used as an insulation material. As can be seen
in Figures 2 and 3, Saudi Aramco does not generate very much asbestos.
Asbestos is a good example of a mineral that was once thought to be non-hazardous, but is
now known to be hazardous. Asbestos is also a good example of why it is important to
minimize all wastes because today's "safe" chemicals might be tomorrow's hazardous waste.
Medical (Hazardous) wastes include tissue, body parts, sharps, dressings, gloves, and other
articles that can contain pathologic organisms. Hazardous medical wastes are the only wastes
that are currently incinerated in Saudi Aramco.
Confidential Documents, as the name implies, are primarily paper products. Confidential
documents, if they are shredded, are disposed in a landfill, and they are burned if they are not
shredded.
Construction
Construction wastes account for about 15% of the total wastes that Saudi Aramco generates
each year. While most of the wastes that are generated by construction are non-hazardous,
some construction wastes, such as paints and other chemicals, may be hazardous. As
discussed below in the avoidance and minimization section, the different wastes should be
kept separate. If hazardous and non-hazardous wastes are combined, all of the waste becomes
hazardous, and, therefore, the cost of disposal becomes more expensive.
Sources
As discussed in detail in ENV 101.01, Saudi Aramco operations can be divided into three
major areas of operation that can impact the environment. These three areas of operation are
as follows: production, hydrocarbon processing, and marketing. Saudi Aramco's three areas
of operation produce a variety of liquid and solid wastes, both hazardous and non-hazardous.
These solid and hazardous wastes require proper treatment and disposal to ensure that Saudi
Aramco’s operations do not create undue risks to the environment or to the public health. The
solid and hazardous wastes that are produced by Saudi Aramco's three areas of operation are
discussed in this section.
Production
Production includes activities that are associated with exploration, development, and the
commercial production of oil and gas. Some typical impacting agents that are produced in the
production area of operation include as follows: oil-based mud, bottom hole fluids, and rock
cuttings. The environments that may be impacted by production include the marine,
terrestrial, aquatic, and air. The potential impacts of the production process include soil and
aquifer contamination, salt water and shoreline contamination, smog formation, and wave
modification.
Hydrocarbon Processing
Hydrocarbon processing includes all the activities that are associated with separating crude
oil, natural gas, and water from the crude oil that is obtained from producing wells; crude oil
refining; and transportation of refined products. Hydrocarbon processing also includes all of
the activities that are associated with Natural Gas Liquids (NGL) processing.
Marketing
Solid and hazardous wastes are not generated directly by the marketing area of operation;
however, products once used may become waste oils and excess products. If the excess
products are returned, they may not always be resold or recycled, and, therefore, they may
require disposal. Examples of products from marketing include lube and hydraulic oil. The
environments that are impacted by marketing include the terrestrial and marine environments
and, to a lesser extent, the air. The potential impacts of marketing include the contamination
of land, aquifers, shorelines, and marine bodies. As an example, the distribution activity in
marketing can lead to leaks and spills.
There are many potential environmental impacts from solid and hazardous wastes that are
generated by Saudi Aramco's areas of operation. The typical impacting agents, environments
that are impacted, and the potential impacts for each area are summarized in Figure 4.
Environments Impacted
Four environments in the Kingdom can be impacted by Saudi Aramco. These areas are the:
• Terrestrial environment
• Aquatic environment
• Marine environment
• Air environment
The potential impact from solid and hazardous wastes to each of the four environments are
discussed in this section. It should be noted that the air environment is the one that is least
likely to be impacted by solid and hazardous wastes.
Terrestrial-As can be seen in Figures 2, 3 and 4, the solid and hazardous wastes that can
potentially impact the terrestrial environment include the following:
• Oily liquids
• Oily sludge
• Medical (hazardous)
• Confidential documents
• Solid waste
An example of an impact to the terrestrial environment is the contamination of land from TEL
sludge that is improperly disposed on the land.
Aquatic-As can be seen in Figures 2, 3 and 4, the solid and hazardous wastes that can
potentially impact the aquatic environment include the following:
• Oily liquids
• Oily sludge
• Medical (hazardous)
Marine-As can be seen in Figures 2, 3 and 4, the solid and hazardous wastes that can
potentially impact the marine environment include the following:
• Oily liquids
• Oily sludge
• Medical (hazardous)
An example of an impact to the marine environment is the contamination of saline water and
contiguous land that is caused by the discharge of untreated process waste water.
Air-As can be seen in Figures 2, 3 and 4, the solid and hazardous wastes that can potentially
impact the air environment include the following:
• Asbestos
An example of an impact to the air environment is the contamination of the air environment
that is caused by the release of products of incomplete combustion. An example of a product
of incomplete combustion is polyaromatic hydrocarbons (PAHs), which can result from the
open pit burning of waste oil. Particulate matter that results from incomplete combustion will
eventually deposit on land or water, potentially impacting on food and aquatic life.
Note that while improperly combusted wastes are a potential impacting agent, Saudi Aramco
does not allow the combustion of any materials in the open.
Potential Impacts
The improper management of solid and hazardous wastes has a potential impact on the
environment. These environmental impacts can be direct or indirect, and their duration may
be short-term, medium-term or long-term. The following paragraphs provide examples of
direct and indirect environmental impacts and impacts of different durations.
An example of a how a long-term impact could occur is the use of a remote area, such as the
Sabkhas, for disposal. While the Sabkhas might appear to be a good disposal site, some areas
have mineable salt deposits. The disposal, without adequate management of water, in such an
area of the Sabkhas could negatively impact the commercial viability of the salt deposits.
An area, such as the Sabkhas, containing commercial mineable salt deposits exemplifies what
is meant by an area of value within an environment. The Sabkha is part of the terrestrial
environment. An extent of the Sabkhas, as raw areas within the terrestrial environment,
would be regarded as a specific area of value, if it contained economically valuable salt
deposits. Any proposal to use an economically valuable extent of sabkha for disposal would
need to resolve conflicts between the proposed disposal operation and the economically
valuable resource. If a decision were taken to proceed with the disposal operation, the design
of the operation would need to be altered to insure that the economic value of the salt deposit
would not be negatively impacted.
Solid and hazardous waste management is the systematic reduction, segregation, collection,
transport, storage, treatment, recovery, reuse, recycle, and disposal of solid and hazardous
wastes. As the volume of solid and hazardous waste designated for management increases in
response to increasing regulatory requirements, the proper management of the waste becomes
increasingly important.
Treatment
The first objective of solid and hazardous waste management is to recover or reuse the waste
whenever possible. The recovery and reuse of the wastes eliminate the need for disposal of
the wastes. The management of solid waste for recovery, reuse, or disposal normally requires
a process or series of processes to reduce or to concentrate the waste. For example,
mechanical dewatering is used to reduce the sludge volume. Greater concentrations of the
wastes can be accomplished by thermal processes; for example, dehydration, pyrolysis, and
incineration.
Solid wastes can be concentrated after their removal from the air and water to reduce the cost
of disposal. Just how important it is to concentrate solid waste is apparent because when the
solids concentration is doubled, the volume of solid waste that has to be disposed of is cut in
half. The characteristics of the overall treatment system determines the quality and quantity
of solid waste that remains and consequently the disposal method. For example, sludge that
contains heavy metals that are readily accessible to the environment in leachate requires a
more stringent disposal method than does sludge that contains metal that has been vitrified.
An example of a vitrified metal is one that is bound in a glassy matrix. The final disposal of
solid wastes is usually done on land because many governments prohibit or limit ocean
dumping and deep-well disposal.
Storage
The storage of solid and hazardous wastes is often necessary until the wastes can be disposed
properly. This storage is usually for a short term. The temporary storage of solid and
hazardous wastes is discussed in this section.
Solid and hazardous wastes that are generated during industrial, residential, commercial, and
construction and demolition activities are generally stored on-site prior to transport for final
treatment and/or disposal. While the wastes are stored, it is essential that the wastes are
properly managed to ensure that storage practices protect the public health and the
environment. The methods of on site storage include as follows: drums, tanks, plastic bags,
sumps, and lagoons.
Disposal
The ultimate goal of a solid waste management strategy is to dispose of the wastes that can
not be recovered or reused in a manner that protects public health and the environment.
Because each waste type is distinct, different treatment and disposal methods are required to
achieve this goal. The final disposal method for each of the major solid waste types and their
sub-categories are presented in Figure 5.
Some of the “actual” disposal methods presented in Figure 5 are unacceptable disposal
methods, for example, open pit burning and lagoon. These unacceptable methods are
currently being addressed by EED and Saudi Aramco plants.
Saudi Aramco always obeys Saudi Arabian government regulations that govern the
management of solid and hazardous wastes. Saudi Arabian government regulations that
govern the management of solid and hazardous wastes are contained in documents that are
provided by the following agencies:
When there are no specific Saudi Arabian government regulations that govern the
management of solid and hazardous wastes, Saudi Aramco uses its own engineering standard
procedures, General Instructions (GIs), specifications, guidelines, codes of practices, and
manuals to conduct its operations. In situations when no applicable regulatory procedures
exist, Saudi Aramco reverts to the following:
This section examines the following sources of Saudi Aramco regulations, codes, and
standards:
SAES-S-007 covers the minimum requirements for the selection and design of sanitary landfill
sites that are located in Saudi Aramco operating areas. SAES-A-007 does not apply to the
design of hazardous waste disposal facilities.
SAES-S-007 specifies that the following four sanitary landfill design methods are acceptable:
• Area
• Trench
• Progressive slope
• Ravine
When landfill space requirements are calculated, SAES-S-007 specifies that the following
waste generation rates be used:
• Domestic waste: 2.3 kg per person per day (5 lb per person per day)
• Miscellaneous waste: 2.3 kg per person per day (5 lb per person per day)
• Construction waste: 5.5 kg per person per day (12 lb per person per day)
SAES-S-007, Sections 5.1 through 6.2, specifies standards for the following topics:
The Saudi Aramco Chief Engineer in Dhahran resolves any conflicts between SAES-S-007
and other Saudi Aramco Engineering Standards (SAES), Saudi Aramco Materials System
Specifications (SAMSS), codes, forms, and Saudi Aramco Mandatory Drawings (SAMD).
The Saudi Aramco Chief Engineer in Dhahran must also give written approval to any
deviations that provide less than the minimum requirements of SAES-S-007.
Saudi Aramco Sanitary Code-The purpose of the Saudi Aramco Sanitary Code, Section 10,
is to prescribe the requirements, limitations, and procedures for the storage, collection,
transportation, and disposal of solid waste. Inadequate solid waste collection, storage, and
disposal practices can result in health hazards. The Saudi Aramco Sanitary Code requires an
effective solid waste management program that protects the public health and welfare. The
Saudi Aramco Sanitary Code is also concerned with the preservation of the quality of the air,
water, and land. Well-planned, effectively executed policies and procedures, the application
of progressive techniques, and the recovery and reuse of solid wastes form the basis of the
Saudi Aramco Sanitary Code.
The Saudi Aramco Sanitary Code requires that a proponent organization must submit the final
detailed engineering plans and specifications for the construction and operation of a proposed
disposal site and all related facilities to the Medical Organization and other agencies before
either of the following can occur:
The plans and specifications must provide a detailed operations plan and timetable that
includes the sequence of site development, use and operation, and a proposal for monitoring
and reporting any environmental effects.
Engineering plans and specifications must include pertinent maps, exhibits, reports, legal
boundaries and property lines, the land use of the proposed site, population projections,
prevailing and seasonal winds, and other pertinent information.
The Saudi Aramco Sanitary Code, Section 10.4, contains the requirements for the
establishment of the following solid waste disposal sites:
• Land disposal
• Incinerators
• Composting plants
The Saudi Aramco Sanitary Code, Sections 10.5 through 10.27, specifies standards for the
following topics:
• Required approvals
GI 355.001 outlines the procedures for the identification of hazardous material. GI 355.001
also specifies the methods to catalog, order, and track hazardous material. GI 355.001 is
issued by the Materials Planning and Systems Department.
GI 355.001 defines a hazardous material as any material that is a physical hazard, a health
hazard, or both. Material is considered to be a physical hazard if it is one or more of the
following:
• A combustible liquid
• A compressed gas
• An explosive
• Flammable
• An organic peroxide
• An oxidizer
• Pyrophoric
• Unstable (reactive)
• Water reactive
GI 355.001, Sections 3 through 9.2, specify standards about the following topics:
GI 355.002 outlines the storehouse operations procedures for receiving, storing, and issuing
hazardous materials.
GI 355.002, Sections 3 through 8.2, specifies standards for the following topics:
GI 355.003, Sections 3 through 7.7, specifies standards about the following topics:
GI 355.004 outlines the additional precautions that are required when PCBs are handled and
stored. PCBs are a class of chlorinated oils that are used primarily in transformers and for
certain lubrication applications.
PCBs are very stable with relatively minor flammability, reactivity, or inhalation hazards.
However, in a fire PCBs have been shown to produce dioxins and furans, two toxic
substances. Skin contact with PCBs is potentially carcinogenic and is, therefore, considered a
hazard. PCB spills are considered to be dangerous because PCBs persists in the environment,
and because PCBs resist degradation and attempts to destroy them. Accordingly, strict
precautions are necessary when PCBs are handled.
• Labeling
• PCB logbook
• Procedures to handle PCB storage and mishaps that can occur when PCBs are
handled
GI 150.001 assigns the responsibilities and establishes the measures for the regulation,
identification, and use of asbestos and asbestos-containing materials.
Saudi Aramco's general policy on asbestos is to substitute safer materials for products that
contain asbestos. Until this goal can be achieved, however, Saudi Aramco has implemented
interim precautions to minimize the hazard from asbestos.
• Employee training
• Work practices
– Wet methods
– Removal or stripping of asbestos insulation
– Shearing and punching of asbestos
– Use of compressed air for cleaning purposes
• Housekeeping
• Disposal
• Personal protective equipment and clothing
– Respiratory protection
– Protective clothing
• Medical examinations
When there are no Saudi Arabian government or Saudi Aramco regulations for the
management of a solid or hazardous waste, Saudi Aramco follows international guidelines.
One important international guideline that Saudi Aramco follows is the United States of
America Environmental Protection Agency (USEPA) 40 CFR (Code of Federal Regulations).
The Resource Conservation and Recovery Act (RCRA) forms the basis of the United States of
America federal government environmental policies regarding solid and hazardous wastes.
The RCRA specifies the requirement for hazardous waste transportation, storage, and
disposal. The U.S. federal regulations under RCRA cover hundreds of pages in the Code of
Federal Regulations (CFR). USEPA 40 CFR implements RCRA.
The primary goals of the RCRA, and the USEPA 40 CFR, are to do as follows:
• Protect human health and the environment from the potential hazards of waste
disposal.
The RCRA, including its 1984 amendments (called the Hazardous and Solid Waste
Amendments [HSWA]), sets forth the framework for EPA's comprehensive waste
management programs as follows:
• Subtitle I program regulates toxic substances and petroleum products that are
stored in underground tanks.
Solid Waste
Solid waste disposal has become a significant problem in recent years because of the
increased population, which generates larger quantities of solid waste, and the need to protect
the air, water, and land from impacting agents. Solid waste comes from many sources,
including the following:
• Residential
• Commercial
• Institutional
• Industrial
• Mineral
• Agricultural
Lack of planning, lack of finances, and public opposition to living near disposal sites have
made it difficult to locate and to reserve suitable areas for land disposal operations in
anticipation of population growth. It is more difficult to locate disposal sites in or near urban
areas than it was in the past. For this reason, solid waste must be hauled greater distances.
The increased distances for haulage increase the disposal costs. These increased disposal
costs require alternative, more expensive methods to process solid waste before the waste is
disposed.
Most solid waste is disposed on land. However, the increased concern over impacting agents
of all types prohibits the use of non-engineered, non-regulated open disposal areas. Open
disposal areas also contribute to the spread of disease by providing food and breeding grounds
to birds, rodents, and other animal life.
The passage of rules and regulations aids in the development of satisfactory disposal practices
and the development of plans for all aspects of solid waste management. The development of
sanitary landfills is an attempt to improve solid waste disposal techniques and to protect the
environment from impacting agents.
Sanitary Landfills-A sanitary landfill is a method that disposes of solid waste on land by
spreading it in thin layers. The solid waste is then compacted with soil to protect the
environment. Sanitary landfilling is a carefully engineered process of solid waste disposal
that involves appreciable excavating, hauling, spreading, and compacting of earth. No
burning of solid wastes occurs at a sanitary landfill. A sanitary landfill is an acceptable and
economical method of solid waste disposal. Sanitary landfills also make otherwise unsuitable
or marginal land valuable.
Hazardous Waste
There are many options available for the disposal of hazardous waste. These options include
as follows:
• Landfarming
• Secure Landfill
• Incineration
• PCB Dechlorination
• Evaporation
Each of the methods listed for the disposal of hazardous waste are discussed in this section.
Landfarming-Landfarming is a disposal process that puts hazardous waste on the soil surface
or into the soil. Natural microbes in the soil break down or immobilize the hazardous
constituents. Landfarming facilities are also called land application or land treatment
facilities. Landfarming techniques include as follows:
Secure Landfill-A secure (hazardous waste) landfill contains and isolates hazardous wastes
that are not presently recoverable to ensure present and long-term environmental protection.
To accomplish these objectives, the landfill must be planned, designed, constructed, operated,
and maintained in accordance with existing regulations.
Historically, land disposal has been the traditional disposal method for hazardous wastes.
Unfortunately, many of these disposal sites have been poorly engineered and monitored;
therefore, the results have sometimes been tragic. Land disposal has been used extensively in
the past because it was the most convenient and inexpensive method of disposal. However,
remediation at older sites that have leaked toxins into the soil and ground water has proven to
be tremendously costly, and the originally perceived economic advantage of land disposal is
now seen to have been short sighted.
The design and operation of hazardous waste landfills has become much more sophisticated.
In most cases, hazardous wastes are initially deposited below grade in an existing natural or
excavated depression (for example, a quarry) or in a pit excavated for that purpose.
Generally, landfilling then proceeds above grade, forming a mound which increases landfill
capacity and causes drainage of incident precipitation from the landfill surface. A hazardous
waste landfill is now designed as a modular series of three-dimensional control cells.
Hazardous wastes delivered to a landfill site are placed in a manner such that only compatible
wastes are disposed together, in separate areas within the single, larger landfill.
Control cells are generally laid out in accordance with an engineered grid system that is
prepared for the site. Corner monuments for the grid are established in the field by a survey
team, This two-dimensional grid system, along with a lift designation (a lift is the distance
from the bottom of one cell to the bottom of the cell above) provides a three-dimensional
record by source, type, and date of the location of all wastes that are placed at the site.
Beneath the hazardous wastes there must be a double-liner system to stop the flow of liquids,
called leachate, from entering the soil and ground water beneath the site. The upper liner
must be a flexible-membrane lining (FML), which is usually made of sheets of plastic or
rubber. Commonly used plastics include polyvinyl chloride (PVC), high-density polyethylene
(HDPE), and chlorinated polyethylene (CPE). Rubber FMLs include chlorosulfonated
polyethylene (CSPE) and ethylene propylene diene monomer (EPDM). Depending on the
material chosen for the FML, the thickness is typically from 0.25mm (10 mils) to over 2.5mm
(100 mils). The lower liner is usually an FML, but recompacted clay at least O.91m thick and
with a permeability of no more than 1 x 1O-7 cm/s may also be used.
Leachate that accumulates above each liner is collected in a series of perforated drainage
pipes and is pumped to the surface for treatment. To help reduce the amount of leachate
formed by precipitation seeping into the landfill, a low permeability cap is placed over
completed cells. When the landfill is finally closed, a cap that may consist of an FML along
with a layer of compacted clay is placed over the entire top, with enough slope to ensure
drainage away from the wastes.
The landfill must also include monitoring facilities. The ground water flowing beneath the
site should be tested with monitoring wells placed upgradient and downgradient from the site.
There may be a need for only one upgradient well to test the "natural" quality of the ground
water before it flows under the site, but there should be at least three monitoring wells that are
placed downgradient to ensure detection of any leakage from the site. In addition, the soil
under the site, above the water table, should be tested to ensure that no leachate has leaked
past the lower liner.
Saudi Aramco does not currently have any in-Kingdom landfills for hazardous waste. There
is, though, an off-site disposal company in Jubail.
Incineration is any high temperature process that uses combustion to convert waste to a less
bulky, less toxic, or less noxious material. Using the optimum combination of parameters, an
incineration system must produce as complete combustion as practical.
These parameters are time, temperature, and turbulence. Air pollution control devices reduce
the emission of impacting agents to the air environment. Many waste materials are easily
combustible, and their products are harmless gases that easily disperse into the atmosphere
through vents or stacks.
Fixed hearth incinerators have low maintenance costs because they have few
internal moving parts. This type of incinerator is built for the destruction of
small amounts of waste at the site of waste generation.
Multiple hearth incinerators work best on wastes that have a high water content
and are of a uniform particle size. The initial capital costs of multiple hearth
incinerators are high, as are the maintenance costs, because of the internal
moving parts. Multiple hearth technology is seldom used at refineries.
• Fluidized bed incinerators pump the sludge into a hot fluidized bed of sand
about 1 to 3 mm in diameter. This process ensures the combustion of any
vaporized material. Fluidized bed incinerators burn partially dewatered sludges
with a solids content of up to 5% to 6% by weight. A compressor provides air
for combustion and fluidization. The air is preheated before it passes into the
incinerator bed.
• Liquid fuel incinerators work on the principle that liquid waste fuel must be
gaseous to burn. In liquid fuel incinerators, the waste is atomized (dispersed
into very small droplets) prior to combustion.
• Gas or fume incinerators burn only gas or vaporized material (fumes). Gas or
fume incinerators are similar to liquid injection types except that the fluid is
initially gas instead of liquid.
PCB Disposal Methods-The current methods for the destruction and disposal of PCBs are as
follows:
• Chemical dechlorination
The appropriate disposal method depends on the type of PCB contamination and the PCB
concentration. Thermal destruction is the most efficient but also the most expensive method
of PCB disposal.
For contaminated materials with high PCB levels, rotary kiln and liquid fuel incinerators are
the only suitable methods for final destruction.
Evaporation-In many Saudi Aramco operations, oily water is generated during crude oil
processing. Oily water consists of (1) water that is produced with (emulsified in) crude oil and
that is separated from crude oil during processing and (2) washwater that is used to desalt
crude oil. In the treatment of oily water, the residual crude oil is separated and is returned to
the process flow. Then, in some operations, the remaining water is disposed of through
evaporation. In other operations, the remaining water is used in secondary recovery of crude
oil (see below, "Reuse/Recycle").
Saudi Aramco design practices require that evaporation ponds shall be preceded by facilities
for the treatment of the waste water. No hazardous wastes - for example, volatile organic
compounds (VOCs) - are intentionally evaporated at Saudi Aramco facilities. All earthen
structures that are proposed for use in waste water evaporation must be properly lined to
prevent contamination of the ground waters by percolation. Ponds can be used for
percolation and evaporation only after secondary treatment and/or proof that ground water
will not be contaminated. The size of evaporation ponds is based on evaporation rates in
Saudi Aramco areas, with consideration given to sufficient depth for water storage, decreased
evaporation due to salinity increases, and proximity to residential areas.
A proper solid and hazardous waste treatment and disposal program requires two components.
The first component is an ongoing and effective monitoring and testing component to ensure
that wastes are properly characterized prior to treatment. The second component is a
treatment and/or disposal process. The treatment and/or disposal process has to be monitored
to ensure that the process has been effective.
The first step in the waste treatment and/or disposal process is to test the waste. For example,
Saudi Aramco has no disposal capability for PCB concentrations in excess of 50 ppm, which
require disposal outside of the Kingdom. Hence, wastes must be tested and monitored for
PCB contamination levels to determine whether disposal outside the Kingdom is required.
The next step is monitoring. For example, if incineration is selected as the disposal method, it
is critical that proper monitoring be conducted to ensure that maintenance and operations are
such that the incinerator has minimal impact on public health and the environment. Good
maintenance will minimize fugitive emissions from leaking valves, transfer lines, and storage
tanks. Good maintenance will also ensure that continuous emission monitoring equipment is
properly calibrated and working. The output from these monitors must be regularly checked
to validate that the incineration process is operating properly and within regulatory limits.
Landfill sites must also be monitored regularly to ensure that ground water resources are
protected from contamination by leachate. Hence, provisions for ground water monitoring
wells are included in a sanitary landfill site design. Monitoring wells are placed along the
perimeter of the site, both upgradient and downgradient of the ground water flow under the
site. The wells are drilled deep enough to penetrate the top of the water table. Periodic
sampling from the well provides an indication of existing water quality and an early
indication of contamination after site startup.
The treatment and the disposal of solid and hazardous wastes is costly and potentially can
have a negative impact on public health and the environment. Consequently, as is discussed
in this section, industry in general, and Saudi Aramco in particular, has initiated an aggressive
solid and hazardous waste avoidance and minimization program to drastically reduce the
amount of waste that requires treatment and/or disposal. The foundation for such a program
is based on the three Rs: Reduction, Reuse, and Recycle.
As has been discussed in ENV 101.01 - 101.04, the primary goal is to avoid the release of
impacting agents to the environment through avoidance and minimization techniques.
The focus of the Saudi Aramco Waste Minimization Program is on in-plant minimization of
waste through source reduction, reuse, recycle, improved maintenance and housekeeping,
process material substitution, and process modification or substitution. Even with Saudi
Aramco's efforts to minimize the amount of waste that is generated, there is still a substantial
amount of waste that is generated by Saudi Aramco operations. A review of Figure 2 will
make it very clear that Saudi Aramco generates solid and hazardous waste.
The prevention of harmful impacting agents involves the use of materials, processes, or
practices that reduce or eliminate the creation of impacting agents or wastes at the source.
Prevention includes practices that reduce the use of hazardous and non-hazardous materials,
energy, water, or other resources as well as those that protect natural resources through
conservation or more efficient use. A prevention program is a continuous, comprehensive
examination of the operations at a facility that are designed to minimize all types of waste
products. An effective prevention program will do the following:
The prevention or recycling of impacting agents at the source eliminates the need for off-site
recycling or treatment and disposal. Elimination of impacting agents at or near the source is
typically less expensive than the collection, treatment, and disposal of wastes. Elimination
also presents much less risk to workers, the community, and the environment.
There are several methods to avoid or minimize the generation of solid and hazardous wastes.
These methods include as follows:
• Reduction
• Reuse/recycle
• Improved maintenance/housekeeping
• Process modification/substitution
Reduction
The elimination of as much waste as possible at the source of generation is a primary factor in
the amelioration of waste management problems. Obviously, if wastes are not generated there
is no requirement for treatment or disposal.
As an example, waste can be minimized at the drill site by the use of a multiple pit system.
The minimized waste can reduce the costs of waste cleanup and disposal, and ultimately limit
the operator’s liability. The chronological progression of how the well is drilled should
dictate how the generated waste is managed.
The top-hole material can be segregated in one pit and later spread around the location. The
top-soil material is native soil, and, if the soil is not later contaminated with material from
deeper in the well, it can be spread on location.
As the well is drilled, saltwater, weight-up material, kick fluids, and bottom hole fluids can be
handled in various pits and treated individually. Fluid segregation minimizes the waste and
the disposal costs. If all the material is put in one large pit, the entire volume becomes waste
that must be handled for disposal in some manner.
During operations to drill the well, the liquids that are generated can be separated and pumped
back down hole where they originated. This process can limit the cost and liability associated
with the disposal of wastes. Thus, the example illustrates that if waste material is properly
handled, there can be a reduction in the need for treatment.
Reuse/Recycle
The reuse or recycling of substances that would otherwise be disposed of as waste can have
considerable economic benefits. For example, waste that contains oil can sometimes be
recycled back to operational units for recovery and/or conversion into saleable products. In
other cases, waste reduction can be achieved through beneficial reuse options. Examples of
how reuse and recycle can save money are described in this section.
The water/oil separation process that is used in Gas/Oil Separation Plants (GOSPs) in the
Southern Area sector (Southern Area Producing) of Saudi Aramco's crude oil production and
processing infrastructure is a prominent example of waste management through reuse.
• Separation of oil, gas, and, water (three-phase separation) from the produced
crude oil input to a GOSP (The gas, which enters a GOSP in solution in the
crude oil, is referred to as solution gas before it is separated and as off gas after
it has been separated. The water, which enters a GOSP emulsified in the crude
oil, is referred to as free water (water drops that are large enough to separate
without assistance of a demulsification agent) or as emulsified water (water
drops that break out of emulsion under influence of a demulsification agent)
before it is separated. After it is separated, the water is referred to as oily water
because it contains crude oil.)
• Removal of salt (desalting) from crude oil (The desalting process passes
washwater through the crude oil to dilute its salt content. The used washwater,
which entrains crude oil during desalting, is also referred to as oily water.)
In the Saudi Aramco context, the water/oil separation process is especially significant because
GOSPs are the most frequently occurring plant in Saudi Aramco and because oily water is
generated in high quantities.
Water/oil separation at a Southern Area GOSP takes place in an intricate and costly vessel
that is referred to as a WOSEP (Water/Oil Separator). A WOSEP receives oily water from
three-phase separation, dehydration, and desalting. Within a WOSEP, the residual and
contained crude oil is separated from the water. The separated crude oil is returned to the
process flow. The water, however, is not sent to disposal. Rather, the water is used in a
secondary crude oil recovery method that is referred to as waterflooding or as hydrolifting. In
this method, water is injected into the water zone of a depleted crude oil reservoir in order to
lift the crude oil back up to the production tubing.
In a Southern Area GOSP, the water/oil separation process is necessary less to recover
additional crude oil and more to treat the water that is to be used in secondary recovery of
crude oil from reservoirs. If the residual and entrained crude oil were not separated from oily
water, this crude would clog the pores in the oil bearing reservoir rock; and such clogging
would prevent the water from effectively lifting the depleted oil zone back to the production
tubing.
As can be seen from the above summary, water/oil separation in a GOSP allows treatment and
then economically profitable reuse of a substance (oily water) that would otherwise require
costly disposal.
The Star Enterprise Delaware City refinery has saved $30,000 per day in projected
incineration costs of a listed hazardous waste by the use of the waste as a feed stream to the
fluid coker. The recovered material, commonly called cuff, is an unresolved oil/water/solid
emulsion from the refinery's corrugated plate interceptor (CPI)/API separators and dissolved
air flotation (DAF) unit. These units remove oil from desalter effluent brine and from other
contaminated waste water streams. The refinery currently processes a crudes mix that has
high solids content, which exacerbates the difficulty to desalt.
Prior to 1990, Star Enterprise vacuum filtered and landfarmed the cuff on site. However, a
change in environmental regulations prohibited this disposal technique. Consequently, the
incineration or recycling of the cuff were the only treatment options available. The cuff
contained a high-chloride salt concentration that adversely affected the coker's operation.
This salt concentration in the coker threatened to require incineration as a remediation
solution. Faced with expensive costs to incinerate, and a short time frame, the refinery's
quality action teams overcame the high chlorides problems and made operational changes that
covered chloride salt concentration which enabled them to reuse cuff as a feed stream.
Problem solving with a committed partner generated a feasible solution that saved the Shell
Oil Martinez Oil refinery $10 million annually in disposal costs. At the refinery, the waste
minimization steering team recommended the installation of facilities to remove disulfides
from certain spent caustics so that they could be sold to a reclaimer.
Improved Maintenance/Housekeeping
The first step in a waste minimization program is to conduct a thorough assessment that
objectively examines unit generating procedures and practices, equipment maintenance and
integrity, and effluent streams composition. Frequently, low-cost, early-implemented
improvements can be achieved through better operating practices, housekeeping, and
maintenance.
Improved housekeeping practices can often remedy sources that contribute impacting agents.
Examples of improved maintenance and housekeeping practices include the following:
• Train operators.
As an example, the United States of America regulatory authorities provide credits for
programs that are specifically designed to reduce fugitive emissions. A survey of pump seal
leak rates indicated that a close relationship exists between the level of a pump’s fugitive
emissions and that pump’s mean time between planned maintenance (MTBPM); the longer
the pump’s MTBPM, the higher the emissions level. Therefore, increased maintenance can
reduce fugitive emissions.
The final steps in a waste minimization program involve a revision to the entire process or
product. When possible, non-hazardous raw material can be substituted for hazardous.
Examples of input material changes include: stop the use of pigments that contain heavy
metals; substitute aqueous cleaning solutions for organic cleaning solvents; and, purchase raw
materials that are free of trace quantities of hazardous impurities. Unfortunately, material
substitution opportunities are limited.
Process Modification/Substitution
While process modification can be a very effective minimization technique, the modification
of processes that currently exist and/or the substitution of new processes or unit operations
often involves the greatest risk for any minimization program. Consequently, high capital
investment is often required to develop and polish innovations into profitable processes. A
thorough site evaluation must be performed before any money is spent on environmental
projects.
Examples of how process modification/substitution can affect a waste water treatment unit are
as follows:
• Recovery and recycling of products from waste water streams can reduce loads
on a waste water treatment unit.
Ultimately, operation and process changes are limited. These changes are only part of the
solution. Technology will play a vital role in environmental-control strategies, and it will
enable plants to meet imminent deadlines. Also, some facilities, due to their physical layout,
cannot make too many process changes without huge construction expenditures. These
facilities must install control strategies that fit their physical layout. It may be hard to
rearrange the sewer system and product lines in older facilities because the areas are
congested. Add-on or end-of-pipe technologies can combine with reduction programs to
achieve control goals. These processes treat the final effluent streams' composition so that
they are within the desired limits.
In the case of prevention, national environmental goals coincide with Saudi Aramco's
economic interests. Saudi Aramco has strong incentives to reduce the toxicity and volume of
the waste it generates. A company with an effective, ongoing pollution prevention plan may
well be the lowest-cost producer and have a significant edge on its competition. Although
businesses may invest in prevention because it is the right thing to do or because it enhances
their public image, the viability of many prevention investments rests on sound economic
analyses. In essence, companies will not invest in a pollution prevention project unless that
project successfully competes with alternative investments.
In recent years, the industry and the EPA have begun to learn a great deal more about the
evaluation of prevention-oriented investments. In the first place, we have learned that
standard business accounting systems do not usually track environmental costs so that the
costs can be allocated to the particular production units that created those wastes. Without this
sort of information, companies tend to lump environmental costs together in a single overhead
account, or they simply add them to other budget line items where these costs cannot be
disaggregated easily. As a result, companies do not have the ability to identify those parts of
their operations that cause the greatest environmental expenditures or the products that are
most responsible for waste production.
It has also become apparent that economic assessments that are typically used for investment
analysis may not be adequate for pollution prevention projects. For example, traditional
analysis methods do not adequately address the fact that many pollution prevention measures
will benefit a larger number of production areas than do most other kinds of capital
investment. Second, they do not usually account for the full range of environmental expenses
that companies often incur. Third, they usually do not accommodate a sufficiently long time
horizon to allow full evaluation of the benefit of many pollution prevention projects. Finally,
they provide no mechanism for dealing with the probabilistic nature of pollution prevention
benefits, many of which cannot be estimated with a high degree of certainty.
An effective pollution prevention program can yield cost savings that will more than offset
program development and implementation costs. Cost reductions may be immediate savings
that appear directly on the balance sheet, or they may be anticipated savings that are based on
the avoidance of potential future costs. Cost savings are particularly noticeable when the costs
that result from the treatment, storage, or disposal of wastes are allocated to the production
unit, product, or service that produces the waste.
For most capital investments, the direct cost factors are the only ones that are considered
when project costs are being estimated. For projects that are designed to avoid or minimize
impacting agents, this category can be a net cost, even though a number of the components of
the calculation will represent savings. Therefore, if the cost analysis is confined to direct
costs, the incorrect conclusion that avoidance or minimization is not a sound business
investment may result. Examples of direct costs are as follows:
• Capital expenditures
– Buildings
– Equipment and installation
– Utility connections
– Project engineering
• Expenses or revenues
– Raw materials
– Labor
– Waste disposal
– Water and energy
– Value of recovered material
For projects that are designed to avoid or minimize impacting agents, unlike more familiar
capital investments, indirect costs are likely to represent a significant net savings.
Administrative costs, regulatory compliance costs (such as permitting, record keeping,
reporting, sampling, preparedness, closure/post-closure assurance), insurance costs, and onsite
waste management and pollution control equipment operation costs can be significant. These
costs are considered hidden in the sense that they either are allocated to overhead rather than
to their source (production process or product) or are completely omitted from the project
financial analysis. A necessary first step to include these costs in an economic analysis is to
estimate and allocate the costs to their source.
• Administrative costs
– Permitting
– Record keeping and reporting
– Monitoring
– Manifesting
• Insurance
• Workman's Compensation
A comprehensive prevention program can reduce the current and future costs of operations.
Examples of how costs can be reduced are described in the following paragraphs.
Materials costs can be reduced by the adoption of production and packaging procedures that
consume fewer resources, thereby creating less waste. As wastes are reduced, the percentage
of raw materials converted to finished products increases, with a proportional decrease in
materials costs.
Waste management and disposal costs are an obvious and readily measured potential savings
that can be realized from prevention. Waste management costs will decrease as prevention
measures are implemented.
Production costs can be reduced through a prevention assessment program. When a multi-
disciplinary group examines production processes from a fresh perspective, opportunities to
increase efficiency are likely to surface that might not otherwise have been noticed.
Production schedules, material handling, inventory control, and equipment maintenance are
all areas that can be optimized to reduce the production of waste of all types and also to
control the costs of production.
Energy costs will decrease as prevention measures are implemented in various production
lines. In addition, energy that is used to operate the overall facility can be reduced by doing a
thorough assessment of how various operations interact.
Facility cleanup costs may result from a need to comply with future regulations or to prepare
a production facility or offsite waste storage or disposal site for sale. These future costs can be
minimized by acting now to reduce the amount of wastes of all types that are generated.
The reduced liability that is associated with avoidance and minimization investments may also
offer significant net savings to Saudi Aramco. Potential reductions in penalties, fines, cleanup
costs, and personal injury and damage claims can make prevention investments more
profitable, particularly in the long run.
In many instances, the estimation and allocation of future liability costs is subject to a high
degree of uncertainty. It may, for example, be difficult to estimate liabilities from actions,
such as an accidental spill by a waste hauler. It may also be difficult to estimate future
penalties and fines that might arise from noncompliance with regulatory standards that do not
yet exist. Similarly, personal injury and property damage claims that may result from
consumer misuse, from disposal of waste that is classified later as hazardous, or from claims
of accidental release of hazardous waste after disposal are difficult to estimate.
Allocation of future liabilities to the products or production processes also presents practical
difficulties in a cost assessment. Uncertainty, therefore, is a significant aspect of a cost
assessment. Because many of the liabilities and less-tangible benefits of pollution prevention
will occur over a long period of time, it is important that an economic assessment look at a
long time frame and not at the relatively short time frame that is typically used for other types
of projects. Of course, the increase in the time frame also increases the uncertainty of the cost
factors that are used in the analysis.
Both civil and criminal liability are decreased by the reduction of the volume and the potential
toxicity of the generated vapor, liquid, and solid discharges. All types of waste-not only those
types that are currently defined as hazardous-should be examined. Since toxicity definitions
and regulations change, the reduction of the volume of wastes in all categories is a sound,
long-term management policy.
Civil liability is increased by the generation of hazardous waste and other potential impacting
agents. The waste that is handled affects public health and property values in the communities
that surround production and disposal sites. Even materials that are not currently covered by
hazardous waste regulations may present a risk of civil litigation in the future.
The reduction of production wastes provides upstream benefits because it reduces ecological
damage that results from raw material extraction and refining operations. Subsequent benefits
are the reduced risk of emissions during the production process and during recycling,
treatment, and disposal operations.
Figure 7 presents a summary of the methods, social benefits, and economic incentives of the
waste minimization program.
METHODS
• Reduction
• Reuse/recycle
• Improved maintenance/
housekeeping
• Process material substitution
• Process modifications/substitution
GLOSSARY
Class III wastes Non-water-soluble wastes that are not biologically or chemically
active in the natural environment
landfarming A disposal process that puts hazardous waste on the soil surface
or into the soil
medical (hazardous) Wastes that include tissue, body parts, sharps, dressings, gloves,
and other articles that can contain pathologic organisms
redundant chemicals Excess, unwanted chemicals that have been purchased in secure
containers
solid waste Waste that includes garbage, refuse, and sludge as well as any
solid, semi-solid, liquid, or contained gaseous material that is
discarded