Confessions Part 2
TECHNOLOGY FOCUS
CONFESSIONS OF A METALWORKING FLUID MANAGER
PART 2 - WELCOME TO MY NIGHTMARE
by Anonymous
FEBRUARY 2002:
My introduction to the management of environmental matters at the plant I worked at was simple. It was 1990, and everybody did whatever he or she wanted, with whatever chemical or material they wanted. My job was to take the end result of this and find someone to “haul it away.” Also, to “fill out any stupid forms our liberal government required.” I remained silent during the anti-environmentalist sermons since my present lowly status was, in part, a reward for my past occasional verbal indiscretions which were often mistaken as a lack of respect. If I didn’t find a way to change people’s attitudes toward me, I might discover that there was actually a worse position on the payroll than my current one. (I would discover later that there was not).
Our facility was really something to behold. The perfect movie set for Terminator IV. Built in the early 30’s, time had somehow passed right over this place, and the mentality of the people inside. The saw-tooth roof windows had been properly aligned for pre-air-conditioned buildings in the Sunbelt. They were screwed shut and painted over when air-conditioning was invented. The heat treat area was large, and almost always filled with smoke. The roof was covered with oil deposits and occasionally caught fire. Lighting was 1930’s original, minus the sunlight from the windows. I actually found areas in the warehouse that had lumen readings rivaling that of moonlight. Workers were using flashlights to read their micrometers. Floors were pitted, unpainted, and covered in an oily sheen that I would later learn was metalworking fluid. There were drums of chemicals everywhere. Water flowed constantly past furnaces that had not been used in years. Electrical connection boxes dangled from steel poles without covers, bare wires exposed. The electrical system was so screwed up that no one person knew how to turn out all of the lights in the building. The answer was to leave them on all the time.
The Maintenance area was a museum of obsolescence. Many of the machines were pre-WWII. Nothing was state-of the art. Everything was state-of-decline. I won’t describe the bathrooms. Stepping in the place it was hard to believe you were in America. The few MSDS’s we had were stuffed in the cardboard box with the waste manifests. No one knew what chemicals were at the facility, let alone in what quantities or where they might be. The evacuation team identified on a memo in the break room included people that had been dead for years. In all likeihood, some of them were still on the property.
I learned that there were basically four waste streams at this facility categorized on a sophisticated physical property recognition system known as the POUR system:
1. You can pour it, and it looks like oil. |
Waste Oil Tank |
2. You can pour it, but it doesn't look like oil. |
Waste Metalworking Fluid Tank |
3. You can pour it, but it came from the plating area |
Hazardous Waste (any empty drum) |
4. You can’t pour it |
Trash Compactor |
A beautifully simple system. If you couldn’t pour it into a drum, it went in the trash compactor. Therefore, something solid that was dripping with something else went to the trash compactor. If it was liquid from the hazardous plating process, it was poured into a drum and was placed in the “drum storage area.” The drum storage area was lower hell - no other way to describe it. On my first visit to the “area” I multiplied an estimate of about 300 drums of various chemicals -- new, waste, unlabeled, mislabeled -- and stacked three high on a chemically pitted square of concrete, surrounded by a falling fence and lock that any three-year-old could walk past. Many of the drums were leaking and all were exposed to rain. The contents of the majority of the drums were unknown. Labels were missing or no longer readable. Most of the drums contained various metalworking fluids; many of them were years old. In the Texas summer sun, they played together like the wind and percussion sections of an underworld orchestra. Whistling and spitting of the leaking drums, accompanied by the untimely and unpredictable booming bass of the expanding, well-sealed drums. This morbid chemical symphony played a warning song far more ominous than the decrepit fence, pitted concrete, and faded "Danger" signs.
Waste oil was pumped into an above ground tank in the back, in an area that actually had a berm around it, and also served as a major storage area for metal scrap and whatever else. By far, the vast majority of the liquid waste was waste metalworking fluid, which everyone affectionately called “coolant.” This waste stream dominated the greasy manifests in the cardboard boxes. It was stored in an enormous tank behind the factory in the same bermed area as the much smaller waste oil tank. It was an interesting set-up. All of the paint was pealing off the tank. Air was pumped into a perforated pipe in the sludge in the bottom of the tank, which created an ugly gurgling sound like the continuous bowel movement of a pitifully sick elephant. This was suppose to prevent solidification of the waste on the bottom of the tank. It didn't. There were two hatches at the top, big enough to climb down into. The problem was, the fumes at the top of the tank were so nauseating that no one dared even lift a hatch. There was a small, float activated sump pump in the ground near the tanks. It would pump whatever liquid drained from the trash compactor into the waste oil tank, next to the waste coolant tank. The big problem was this stuff called rain. When it rained, the pump would run all night, overflowing the tank with storm water and causing hundreds of gallons of oil to wash out through the top of the tank. The following morning's result was a mess that could only be cleaned up with a lot more rain. Looking back, I wonder what happened over at the cooling tower when it rained. The cooling tower was a huge open tower and tank system with chromium based biocides mixed in the water that splashed over rotting timber planks. Nothing grew on the ground around the cooling tower.
Twice a week, the Beverly Hillbillies would show up in the worst looking tanker truck you ever saw. It was covered in grease, rattled, leaked, and blew more smoke than a horny Cowboy in a singles bar. They would rumble around the back and suck out some of whatever was in the waste metalworking fluid tank. It was then that a wonderful and final miracle took place. They would “haul it away.” Ah yes,..”away,” the great beyond of garbage. That landfill in the heavens. One almost has a vision of that crappy, leaking, truck rumbling down the road before rising into a thick fog on some weird highway in the sky, following a great light. The only thing better than “away”, was “far away.” This left me with two questions for old Bill: Who are “they” and where in hell is “away”? He wasn’t exactly sure of either, but it was pretty clear he didn’t want to know. That was my job now.
My first act in my new position was to inform my new boss (the VP of Manufacturing) that I didn't know what I was doing, neither did old Bill, and I would have to take some courses to get up to speed. I would also need some books, and to remodel the asbestos closet that I worked in. No problem. I signed up for everything I could find and was in class more than at work. Within 3 months I had enough information, acronyms, and legal citations to be a real pain in the ass. Now I could at least start to get things done. At one of the classes offered by the state environmental agency, I ventured to introduce myself to the lecturer during a break. Looking back, I don’t know exactly what I was thinking when I did this, but whatever it was, it was a really bad idea. When I told him which factory I was responsible for, he actually burst out laughing. I stood there while he yelled to a colleague across the room, “Hey Bob, this guy in charge of the old XXX factory!” Now at least three of them were laughing out loud and all of the other students were looking at me. When he caught his breath, he simply shook his head, wiped a tear from his eye and said, “Good luck buddy.” This removed any doubt that I may have been hanging onto. I was screwed. Years later, I would read the book "A Civil Action" and think back to this time, at this place.
Basics:
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Don’t ever get into this situation, no matter how bad you need a job.
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If you find yourself in this situation, get an education immediately, any education. State agencies and local colleges may offer some options. Take them all. It is the only way to protect yourself and do your job.
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You will need the legal and regulatory citations to get money from the company to get anything done. You are in EHS. If it doesn't have to be done, it won't be. No citation, no money. No money, no change. This is the real reason industry always lobbies for any alternative to a regulation. The metalworking fluid and lubricants industry are no exception.
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Metalworking fluids are chemicals with safety issues. Metalworking fluids are a significant waste stream. Therefore, metalworking fluid management and environmental engineering responsibilities are closely related and suitable for consolidation in many facilities. You'll see why this makes sense.
Next Month: Part 3 – F-Troop, the new team.