中石化安順廠土壤污染整治管理監督之探討

Management and Supervision Experience of the Remediation of China Petrochemical Development Corporation An-Shun Plant Soil Contamination Site

張皇珍(Hwang-Jen Chang)

《土壤及地下水污染整治》 1卷1期 (2014/07) Pp. 1-13

https://doi.org/10.6499/JSGR.2014.0101.001

摘要

中石化公司安順廠污染場址位於台南市安南區，面積37.1公頃，因曾設置鹼氯工廠及五氯酚工廠，該場址含有高濃度戴奧辛及汞污染物，為國際矚目之土壤污染整治場址，無類似整治技術可援用，整治範圍包括陸域及水域，如廠區、海水貯水池、樹林區等。場址列管期間經歷土壤及地下水污染整治法兩次修正，實為土壤及地下水污染整治法之試金石。台南市政府環境保護局2002年公告該場址為污染控制場址起，依法陸續執行場址之公告、緊急應變措施、監測、管理監督、計畫核定及經費求償等。筆者自2006年至台南市政府環境保護局服務，長期積極與中央長官、學者專家及同仁討論，發展多項創新管理措施，包括整治計畫導入量化整治進度查核機制、進行模場測試及實廠試運轉以確認技術可行性、驗證機制及複合式環境管理等等，將於本文說明分享。此外，中石化公司安順廠污染場址內海水貯水池之底泥整治目標係參考底泥品質指標或土壤污染管制標準，亦於文中提出討論。文末就多年來管理經驗提出建議，以供土壤及地下水污染整治法未來修正之參考。

關鍵字

創新管理 ； 土壤及地下水污染整治法

並列摘要

The China Petrochemical Development Corporation (CPDC) An-Shun plant soil contamination site (CPDC-AS site), with an area of 37.1 hectares, is located in Tainan City, Taiwan. The plant produced chlor-alkali and pentachlorophenol (PCP), with the mercury cathode method being used in the former process. Mercury contamination of the soil may thus result from the leakage of mercury during the manufacturing process or the disposal of mercury waste. In addition, polychlorinated dibenzo-pdioxins and polychlorinated dibenzofurans (PCDD/Fs), byproducts of PCP manufacturing, cause further contamination of the CPDC-AS site. Both high concentrations of mercury and PCDD/Fs contamination make the CPDC-AS site a unique soil contamination case, with remediation efforts being further complicated due to the presence of land and water areas at the site. The Soil and Groundwater Pollution Remediation Act (SGPRA) of Taiwan was enacted in 2000 and revised in 2010. Based on this, the CPDC-AS site was declared a control site in 2002, and then a remediation site in 2004. The management and supervision experience gained in the remediation of the CPDC-AS site serve as a valuable reference for applications of the SGPRA. The first challenge that the local authority, the Environmental Protection Bureau of Tainan City Government (TN-EPB), faced with regard to site remediation management and supervision was that the polluter, CPDC, refused to take responsibility for the remediation efforts. TN-EPB thus took the necessary steps to avoid expansion of the contamination and protect local residents, with the related costs been paid for by the Soil and Groundwater Pollution Remediation Fund (SGPRF). TN-EPB then demanded compensation from CPDC, which began a lengthy process of litigation between the two parties. In 2007 the Supreme Administrative Court reached a verdict that CPDC should take responsibility for the remediation of this site. TN-EPB then asked CPDC to submit a remediation plan and asked for compensation from the company based on the Court's verdict. However, TN-EPB also faced other challenges with regard to the enforcement of the SGPRA in terms of the management and supervision of CPDC-AS site remediation, such as the decision as to which remedial actions should be taken, pushing CPDC to keep to remediation progress, and dealing with the issue of secondary pollution control. TN-EPB thus developed a set of novel management strategies for the effective management and supervision of the AS site remediation. First, TN-EPB asked CPDC to include quantitative check points into the remediation plan, such as the percentages by which the contamination area or the amount of contamination would be reduced. Based on SGPRA article 38 and paragraph 2, if the implementer of a control or remediation plan fails to implement the content of the plan, as approved by the relevant authority, they shall be fined NT$200,000 to NT$1,000,000, and may be fined for each violation. TN-EPB was thus able to push CPDC to act in accordance with the agreed remediation plan, as well as effectively monitor progress. TN-EPB also asked CPDC to include actions related to air quality, wastewater quality, and waste disposal at the CPDC-AS site during in the remediation plan, to avoid the secondary pollution during these efforts. Second, the CPDC-AS site is unique in that it is contaminated with both dioxin and mercury, and since the related treatment strategies are different, this made the choice of remedial actions more complex, with no off-the-shelf technologies being available to deal with this problem. TN-EPB thus required CPDC to carry out a pilot plant test and preliminary operation of the full-scale plant before carrying out remediation at the site. The results of the pilot plant test and preliminary operation of the full-scale plant were then reviewed by the TN-EPB and the examining panel of the CPDC-AS site. Second, the CPDC-AS site is unique in that it is contaminated with both dioxin and mercury, and since the related treatment strategies are different, this made the choice of remedial actions more complex, with no off-the-shelf technologies being available to deal with this problem. TN-EPB thus required CPDC to carry out a pilot plant test and preliminary operation of the full-scale plant before carrying out remediation at the site. The results of the pilot plant test and preliminary operation of the full-scale plant were then reviewed by the TN-EPB and the examining panel of the CPDC-AS site. This paper provides details of the experiences, challenges, and novel management strategies that TNEPB adopted when enforcing the SGPRA during the management and supervision of the CPDC-AS site remediation. It is anticipated that this work could serve as a valuable reference for any revisions that are made to the SGPRA in the future.

並列關鍵字

novel management strategies ； Soil and Groundwater Pollution Remediation Act