One Site's Trash is Another Site's Treasure

I had the privilege of working as an environmental investigator for the state of Texas in the Houston region. A large part of my territory was the Houston Ship Channel. The ship channel is a 52-mile long industrial corridor with many facilities interlocked with adjacent facilities. I view this industrial corridor as a huge jigsaw puzzle. I see it as thousands of interlocking pieces of amazing engineering. I cannot think of a single facility that is a complete stand-alone in its operations, where it neither receives, nor sells finished product or raw material to another channel facility. As a regulator, I had the privilege to enter and learn the engineering of almost every facility of the Houston Ship Channel.

When waste minimization and the new regulations surrounding "by-products" became a focus of the regulatory agency, facilities up and down the ship channel looked for ways to avoid generating their unusable end products, "waste." If the waste coming out of Plant A could be used by Plant B, then Plant A did not have to define their end product as waste; hence, Plant A's waste generation amounts would be lowered. If a plant could lower its waste generation amounts significantly, there was a possibility of falling into a less-regulated status within the rules. As you can guess, every facility wanted to be less-regulated environmentally.

It was during my years as a Waste Program investigator that I was assigned to inspect a certain facility. The inspection proceeded as most inspections did, except for a request from the facility's environmental staff. The staff had been tasked with getting rid of a very large tank's contents. Normally, this tank held very expensive raw material; however, somewhere along the way of transport, unloading, and storage into this tank that held several tens of thousands of gallons, this raw material had become contaminated and was no longer usable within the facility's processes. The entire tank's contents had to go. For the environmental staff, two major concerns were at hand. The first was that the material was classified as hazardous under the law in its waste form. Having to dispose of this extremely large volume of hazardous waste would have ruined the facility's status as a small quantity generator (SQG) and their goal of generated waste minimized. The second issue was that waste disposal dollars came out of the Environmental Department's budget. Paying for the entire tank to be disposed of as hazardous waste would have depleted the department's budget with only half the year gone. The request posed to me was for a less expensive solution. Practically speaking however, the staff was not hopeful. I told them I would have to think about, and I did.

A couple of days later while sitting at my office desk, I realized that this contaminated material may be unusable in their facility, but it still had the elements required for use as raw feed by a different facility several miles upstream along the Houston ship Channel. I contacted the original facility, which we can call Facility A, and told them about this other facility perhaps being able to use their material as its raw feed, and I asked permission to pass names and phone numbers along to this other facility. They granted me their permission. Subsequently, I contacted the second facility, which we shall call Facility B, and told them I knew about a very large cache of off-spec raw material with the same elements that their facility required, and would they possibly be interested in receiving it. They were. After the same set of permissions were granted to pass along names and phone numbers, I contacted Facility A. I left it to the two facilities to deal with each other regarding acceptability, payments, and transport. About three days later, I received a joint call from both facilities, as well as the permitting engineer from headquarters, who had just happened to write both facilities' permits. It had been determined that this material was both wanted and suitable for Facility B, and the question by all parties was for confirmation that all compliance requirements had been met, and they had. Facility A was going to be able to remove the tank's contents and off-spec product, not waste. Facility B was going to be able to get an entire tank of raw material for very cheaply. A win win for both. In my opinion, this type of transaction was what we, the inspectors, should consider as part of our focus when doing our jobs. I am happy to say that I was able to create this type of scenario a few more times in my career.

Unfortunately, before the conference call had quite come to its conclusion, a series of clicks indicated that both facilities had disconnected from the line. Assuming that the engineer and I were the only two parties left on the line, we spoke openly about the two facilities and the transaction in general. I am still thankful to this day that everything we said was positive and encouraging. As you can probably guess where I'm heading with this, both facilities' staffs were still on the line listening to the two of us talk about them. After several minutes, one of the staff members spoke up and said, "We're still here." Then that moment, panic, did I just say something I might regret?

I learned two things from this transaction. First, it is always worthwhile to extend oneself into situations out of the ordinary if it looks like something extraordinary can come from it. Second, if it sounds like parties have been disconnected from a conference call, hang up and establish a new connection before continuing the conversation when assuming they are not on the phone.