In honor of Groundhog Day this February, I’m going to describe a “normal” trip that I take on a semi-regular basis. I received a call from a relatively small manufacturer that was having some environmental issues and received our name from a contractor that they use. They asked if I’d come out to take a look. I happily obliged.
Most facilities I visit have many similarities and this facility wasn’t an exception. On the grounds are a couple of big steel buildings, substantial amounts of concrete in the front, and the rear of the property is largely bare ground. The steel buildings usually have a crane or two; there is equipment manufactured for oil and gas, shipyards, off-shore platforms, or pipeline facilities. Some facilities make items for all of these types of industries while some only make items for a single industry.
On a typical visit, the same thing happens: I meet an environmental manager. They are a go-getter and get things accomplished, but rarely have much, if any, environmental background. Often, I end up with the Safety or the Quality Control Supervisor. It is always apparent that they want to be environmentally compliant, but they seldom know what that means or entails. They were often volunteered for this environmental task, or accepted it begrudgingly, which is why I’m here – to help them out!
As we walk around these Sites, I inevitably ask “do you generate any waste?”, which 98% of the time results in “no, we don’t have any of that around here.” And yet, as we walk – I can plainly see waste oil and oil filters, the sawdust towards the back of the facility (environmental material is typically at the back of the facility on bare ground, rather than the preferred alternative of concrete or pavement), and unattended sandblast material everywhere. Now, many of these items can be recycled without an issue, but that doesn’t negate their need to be managed as waste material. Depending on the facility type and types/amounts of wastes generated, some of these materials might need to be on a TCEQ Notice of Registration; and if they are recycled, they might need to have a Recycling Notification. In most cases, there is a regulatory prescribed time limit for waste storage before a potential notice of violation can be issued.
While conducting a typical site visit, I ask if the facility has a stormwater plan, which almost always results in a bewildered look – while I’m watching sandblast material wash down the parking lot drain. The supervisor often asks if they need one, to which I explain that it would depend on their Standard Industrial Classification (SIC). I then ask if they have more than 1,320 gallons of oil stored at the site, which is always a steadfast “no” until they start working through the addition in their head and ask if small containers and waste oils also count. At this point, I inform them that oily waters also count against the total, and suddenly these calculations have culminated in 4,000 gallons of oils stored at the site which would pull the facility into federal Spill Prevention, Control, and Countermeasure regulations.
At the most recent facility I visited, and similarly to many of my visits, we finally arrive at the very back of the property and there are 10 drums of waste paint. The Quality Control manager, by this time, beats me to the punch line, “I guess this is just more waste we have.” I tell him he’s lucky, he’s in Texas, so the paint is considered a Universal Waste – while it still needs to be handled and disposed of properly, it does not count towards the generator status or need to be included on the Notice of Registration. Plus, it can be stored at the site for up to a year if it is properly containerized and labeled.
I always enjoy these meetings, and the Quality Control or Safety manager that got stuck with trying to navigate the complicated world of environmental compliance rules usually enjoys it as well. The purpose isn’t to catch wrongdoing – but to help. While helping managers and facilities inexperienced with environmental regulations is something I look forward to, these site visits can feel a bit like Groundhog Day. It is far better to have us help than to be caught off guard by a regulator during a surprise inspection.
I’ll do this again next week, at a different facility, but with very similar findings. It will be Groundhog Day all over again.
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