Wastewater Management
Treatment processes such as cleaning, washing, and de-inking involve using various chemicals, solvents, and detergents to remove inks, clays, plastics, adhesives, and other materials, which generates wastewater contaminated with the treatment chemicals and the material removed from the paper, which may be hazardous, such as heavy metals in the printing inks like copper, lead, zinc, and chromium. Containment breaches or improper disposal of wastewater can release these contaminants into soil and groundwater or discharge through drains into other water sources.
Sludge
Sludge generated as a by-product from the recycling process, particularly from de-inking and flotation operations, is a solid waste containing various hazardous materials such as heavy metals, dioxin, coatings, adhesives, dyes, and fillers such as calcium carbonate and clay. Disposal of the sludge, or sludge ash created from incinerating the waste, can create liability at the landfill or other non-owned disposal site. Landspreading is another way of disposing of sludge, as it can contain some trace nutrients, but contaminants such as heavy metals can pollute the receiving soils and groundwater.
Bleaching Processes
Bleaching recycled pulp uses hazardous chemicals, often the same as those used to bleach virgin pulp, including hydrogen peroxide and sodium hydrosulfite. Chlorine and chlorine dioxide could also be used, creating highly toxic chlorinated byproducts, such as dioxins and furans. Releasing the bleaching agents can result in environmental cleanup and third-party liability. Exposure to even a low level of chlorine could be fatal. Bleaching processes also generate effluent containing these chemicals; improper handling or disposal could result in environmental liability.
Chemical Storage
During the storage and handling of chemicals and solvents, a containment breach, leak, or spill can lead to environmental liability. Failure to segregate or the mixing of incompatible materials can create hazards. Spent chemicals and wastewater may be considered hazardous waste and require special disposal procedures.
Equipment Leaks
Shredding equipment, sorters, bailers, forklifts, conveyors, compactors, and trucks may be used for conducting business. Petroleum-based fluids may leak from on-site equipment and vehicles, at pickup sites, in transit between pickup and drop-off points, or docked in the yard. If maintenance and fueling are also conducted, these products may be spilled or leaked from stock supplies. Products include diesel fuels, hydraulic fluids, cleaners, and coolants. Releases can contaminate soil, be carried off-site in stormwater run-off, or contribute to fire hazards. Idling diesel tractor-trailers may also produce significant localized toxic exhaust emissions.
Leachate
Manufactured paper products have chemicals that leach from paper when exposed to moisture. Recyclers use their working yard, outdoor storage, and other storage containers, directly exposing them to stormwater, transient flooding, leaks, fire sprinkler deployment, or firewater. Paper leachate can discharge pollutants into storm drainage systems and cause severe impacts on water quality at outfalls to surface water, and damage natural resources. Potential pollutants in the leachate can include inks, adhesives, varnishes, dyes, polypropylene, barium, dioxin, PAHs, sulfate/sulfides, and silicates.
Fire Emissions
Fires involving various types of paper release emissions of small particles. Some can be grouped into the classes of priority pollutants for the National Ambient Air Quality Standards for PM10 and PM2.5. Some will be present as ultra-fine particles, which have been shown to cause serious health impacts. Chemicals may include PAHs, 1,3-butadiene, phenols, and benzene. Some of these chemicals are carcinogens.
Odor and Gas Irritants
Odors can be a nuisance and irritant to neighboring properties, resulting in claims for third-party bodily injury or diminution of property value. Using chemicals, including chlorine and gases produced during processes, such as hydrogen sulfide, can cause eye, nose, and throat irritation, headaches, nausea, and coughing and could aggravate existing medical conditions such as asthma.
Environmental Pollution Liability Can Provide Coverage For
Integrated General Liability/Site Pollution, options to include XS, Automobile, and Workers’ Compensation may be available
Monoline Site Pollution Liability
Third-party claims for bodily injury, property damage
First-party and third-party cleanup
Defense of third-party claims
Emergency response costs
Natural resource damage
First and third-party transportation pollution liability
Loading and unloading
Products pollution liability
Crisis/reputation management
Civil fines and penalties
Off-site services pollution liability
Business interruption expenses
Non-owned disposal sites