SPECIAL LICENSING CONDITIONS FOR RAMAT HOVAV

SPECIAL LICENSING CONDITIONS FOR RAMAT HOVAV

The 12 year history of the hazardous waste site in Ramat Hovav, Israel's central site for the storage and treatment of hazardous substances, resembles a tale of high expectations and dashed hopes. As the site changed administrative hands time and time again, professional guidelines for safe operation were drafted, presented and all too often ignored. With the establishment of the Environmental Services Company (Ramat Hovav) Ltd. in January 1990, a subsidiary company of the Ministry of the Environment, hopes ran high that the absorption and treatment of hazardous waste at the site will finally be accorded the high priority it requires.

Unfortunately, complaints concerning nuisances and inadequate professional and safety procedures, began reaching the Ministry of the Environment soon after the establishment of the company. Complaints hailed from neighboring industrial plants, from residents of the area and from the Ramat Hovav Industrial Local Authority. The latter threatened to file a police complaint and close the hazardous waste site if matters were not resolved. The multitude of complaints led the director-general of the Ministry of the Environment to appoint an expert committee in November, 1990 to review operations at the site. The report, presented in May 1991, confirmed the charges and pinpointed a long line of deficiencies in the operation of the site.

Major Findings

The committee concluded that the goals set by the relevant authorities for operation of the Ramat Hovav hazardous waste site were not achieved by the company. Major deviations from required storage and neutralization procedures were discovered. Among the most severe findings were improper routing of the various types of hazardous wastes to inappropriate storage and/or treatment facilities, direct discharge of concentrated hazardous wastes into the collection ponds, neutralization in the open rather than in the designated industrial neutralization facilities, faulty landfill, and improper storage of organic and other wastes, all in contravention to specific requirements and procedures set by the Ministry of the Environment. Deficient administration and supervision led to an untenable situation requiring large-scale and costly rehabilitation work.

In light of the dire findings, the committee recommended the following:

* The Ministry of the Environment should reformulate procedures for the absorption and sampling of hazardous waste at the site.

* The Ministry should formulate a list of wastes suitable for storage in ponds; all other wastes will be stored in controlled locations or will be neutralized in the designated industrial neutralization facility.

* All neutralization operations will be carried out within the plant's installation and not in the open.

* The collection ponds for organic wastes should be thoroughly examined.

* A settling installation for wastes flowing from the central neutralization plant should be set up.

* Certain parts of the landfill site should be dismantled and made suitable for burial.

* Storage procedures for organic wastes should be carefully adhered to and safety procedures should be reviewed and tested.

* A detailed plan for constructing an incinerator should be put into effect.

* Rehabilitation work should be undertaken in the collection ponds for acidic and heavy metal sludge and organic wastes and in the landfills.

* Monitoring drills should be conducted to follow-up over the possible contamination of ground and groundwater.

* Monitoring procedures should be set for pollutants emitted in the area.

Special Conditions to the Business License

The report, which was submitted to the company, was summarily rejected by the board of directors. The Ministry of the Environment, therefore, decided to utilize its new authority within the framework of the Licensing of Businesses Law, 1968, with respect to granting approval to business licenses subject to the fulfillment of special conditions. The director of the southern district of the Ministry of the Environment, within his capacity as "giver of approval" within the framework of the law, issued special conditions calling for general and specific measures to ensure environmentally safe operation of the hazardous waste site in Ramat Hovav. The conditions went into force in October 27, 1991.

Following are the salient points enumerated in the licensing conditions:

* Provision must be made for ongoing, 24-hour a day alert at the site, including telephone and wireless communication to the emergency room of the Ramat Hovav Industrial Local Authority and the fire services in Beersheba.

* The plant will absorb all manner of hazardous waste materials in its facilities with the exception of radioactive, explosive or biological waste (excluding cytotoxic waste of hospitals) or hazardous wastes originating outside of Israel.

* The plant will continue to absorb organic hazardous materials designated for incineration although the appropriate facilities do not yet exist on condition that these materials will be stored in sealed, appropriate barrels, in accordance to professional guidelines.

* The plant may store sludges in collection ponds in accordance with specific conditions until such time as treatment and disposal in an appropriate facility is possible. Only acidic oily sludges and sludges of specific plants enumerated in the conditions may be stored at the site, each in a separate pond.

* Waste materials or their derivatives may not be removed from the bounds of the plant and new treatment methods may not be carried out without prior written approval following the presentation of an environmental impact questionnaire.

* Open ponds will be used only for evaporation and the storage of sludge.

* Any treatment or neutralization process which is accompanied by a chemical reaction, with the exception of the solidification of acidic oily sludge, will be carried out in reactors connected to the appropriate absorption systems. A plan for the improvement of the reaction systems should be submitted.

* New storage ponds will not be established at the Ramat Hovav site until all means are taken to ensure impermeability, to prevent leakages and to undertake monitoring.

* The plant will prepare and submit a detailed plan, with timetable, for the rehabilitation of wastewater and waste storage ponds slated for closure or for the renewed operation of filled- up ponds.

* The plant will set up an incinerator for the treatment of organic waste at the Ramat Hovav site,in accordance to a detailed plan and timetable.

* Landfilling in Ramat Hovav will be undertaken only in accordance to international professional standards following presentation of complete details on the type of waste, quantity and packing method; composition; landfill method; location; and types of additional waste materials buried nearby.

* The plant will only absorb hazardous material which is packed, labelled and unloaded in accordance to approved conditions. An on-site laboratory will validate the details included in the bill of lading.

* The plant will maintain an updated file on the types of waste stored and buried at the Ramat Hovav site, including records and maps of the specific locations.

* The following surveys must be carried out:

- emissions surveys of air pollution sources designated to facilitate solutions for prevention and abatement of air pollution.

- risk assessment surveys, the first of which will relate to accidents and malfunctions liable to occur in the course of operation and to contingency plans.

- assessment of leakage risks from the intermediate storage sites to assess the risk of groundwater pollution, especially as a result of faulty packing.

* A professional alert team will be set up within the plant including a duty officer to solve problems related to emergencies at night, on weekends and holidays.

* In case of detection or identification of an event, the duty or liaison officer will notify the following bodies immediately :the police, the fire services, the southern district of the Ministry of the Environment and the Ramat Hovav Local Industrial Authority.

* A liaison officer appointed by the plant will ensure that all necessary means for the implementation of the special conditions will be implemented within the plant.

* The plant will maintain a diary of events with details on malfunctions or accidents including time, character of the event, measures taken, etc. These records will be presented to the district office of the Ministry of the Environment.

* Instruments, monitors and detectors will be installed within the domain of the plant and within each of the stacks for the purpose of monitoring emissions.

* In case of violations of the following concentrations, at a half hour average, immediate measures will be undertaken to solve the problem including halting the process which caused the violation. Following are the maximal levels permitted for the following pollutants:

a. total suspended particulates (TSP) - 50 mg/m3
b. hydrogen sulfide (H2S) 5 mg/m3
c. inorganic chlorine compounds (as HCL) 30 mg/m3
d. hydrocyanic acid (HCN) 20 mg/m3
e. nitrogen oxides (as NO2) 500 mg/m3

* Monitoring results will be submitted at the end of each month to the district office.

* The plant will submit a monthly report on the types and quantities of waste received at the site.

* The plant will prepare, with approval from the Hydrological Service, a monitoring plan designated to monitor the leakage of hazardous materials underground and to groundwater. In case leakage is discovered, the contamination will be halted immediately and means will be undertaken to solve the problem and prevent its recurrence.

Implementation of these special conditions, formulated in coordination with the company, is expected to prevent or at the very least, reduce accidents and long-term environmental risks to a minimum. Implementation of the conditions represents a major breakthrough in the professional operation of Israel's central site for the storage and treatment of hazardous substances.