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.
在典型的访问中，发生同样的事情：我遇到一个环境经理。他们是一个go-getter，并完成了事情，但很少有很多，如果有的话，是环境的。通常，我最终得到了安全或质量控制主管。他们始终显而易见的是，他们想要环境兼容，但他们很少知道这意味着什么。他们经常为这项环境任务自愿，或接受它沉思，这就是为什么我在这里 - 帮助他们！
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.
进行典型的现场参观时,我问e 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.
在我访问的最新设施，同样到了我的许多访问，我们终于抵达了房产的背部，有10个浪费油漆。质量控制经理，到这时，将我击败了拳，“我猜这比我们更浪费了。”我告诉他他很幸运，他在德克萨斯州，所以油漆被认为是一个普遍的废物 - 虽然它仍然需要正确处理和处理，但它不计入发电机状态，或者需要在注册通知时计算。此外，如果它可以在网站上存储，最多可以在一个年内被正确地集装箱和标记。
我总是享受这些会议，而且试图导航的质量控制或安全经理通常享有它的复杂世界。目的不是捕获不法行为 - 但要帮助。虽然帮助管理者和设施缺乏经验的环境法规是我期待的，但这些网站访问可以感觉有点像地下一天。在令人惊讶的检查中，我们可以帮助我们的帮助，我们的帮助比监管机构要被篡改更好。
我将在下周又一次地在不同的设施，但具有非常相似的发现。这将是Groundhog Day。
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