Letters From The Earth

Proactive or punkie?

October 11, 2010

The wind blew very, very hard several weeks ago here in Chicago. After the storm I went out to see if there was any damage. Our yard was fine but a neighbor lost a huge maple tree, probably 75 to 85 years old. I went over to look at the damage and noticed that the trunk had snapped off about 20 feet up. This was odd, so my inspection continued. When I looked closely I saw that the wood was punkie; it was worthless and had no value.

My dad had taught me that word. In the context of the tree it meant that the tree had no fiber, it was rotten and wouldn't even make good fire wood. In the context of business I define punkie as "of little substance": no strengths, no program, not sustainable, not certifiable, not practical, and so on.
I was fascinated to later learn that there actually is a punk tree. It is called a cajuput, an Australian, myrtaceous tree or shrub having lanceolate, aromatic leaves. My dad never told me about punk trees. Probably just as well.

Punkie, it seems to me, is exactly what is happening in Washington DC, where the Environmental Protection Agency (EPA) has decided not to define nonhazardous secondary materials recycled by manufacturers for heat recovery as solid waste.

The issue with the EPA is a proposed rule that would allow manufacturing and industrial facilities to recycle spent solvents, fuels, scrap plastics, shredded tires, used oil, and industrial sludge in boilers or process heaters for the purpose of heat recovery. These facilities would not have to comply with the Clean Air Act emission restrictions. This is downright punkie and makes no sense at all.

The latter part of the proposal is the problem. If these same secondary materials were simply being disposed of in a boiler, what is called "absent recycling," emission restrictions would come into play.
A final EPA rule in 2000 established emission controls for the category of "commercial and industrial solid waste incinerators" – the CISWI Rule. This was challenged in 2001, but only as it pertained to cement kilns. Suffice it to say, we have been debating the issue of solid waste recycling for almost 10 years and this has resulted in the proposed rule that came out early this summer. Balderdash and punkie.

What is not punkie is the responsibility of the generator of byproduct to follow closely regulatory requirements. I became aware of a situation involving a convertor who was cited by a state agency for failure to comply with hazardous waste management and liquid industrial waste regulations. An inspection at a manufacturing site determined violations of the following statutes:

a) A person (company) that generates a solid waste must determine if that waste is hazardous or not;
b) Must maintain copies of waste evaluation on site for three years from the date the waste was last sent for off-site treatment or storage.

There are definitely teeth in this kind of regulatory law and it is the responsibility of the generator to follow the requirements to the letter. If you use a third party to handle disposal you must require them to be compliant. Neither the plant that was inspected nor their third party had copies of waste characterizations for the following waste streams:

-Spent mineral spirits
-Spent non-hazardous parts washer waste
-Spent used oil
-Spent rags contaminated with ink

While the EPA's failure to define non-hazardous materials for consumption in a boiler is punkie, the above is specific and requires close compliance with regulatory requirements. In other words, mind the law or pay the consequences.

In another case, the EPA has a proposal that I believe is counterproductive to industry and our economy. It makes me wonder if Washington sometimes provokes just to be downright onerous. In this particular case, EPA is proposing a rule under the Maximum Achievable Control Technology (MACT) Act that will affect emissions from industrial boilers.

The costs for the pulp and paper industry alone could approach $12 billion in new capital equipment. At risk are 30 paper mills and almost 17,000 jobs. If you further extrapolate, there is an estimated ripple effect of 3.25 jobs related to each pulp and paper worker, which explodes to a minimum of 100,000 lost jobs due to stricter air pollution regulations. American Forest and Paper Association CEO Donna Harman says, "EPA has a choice – they can regulate in a way that protects both jobs and the environment or they can regulate in a way that sacrifices jobs." Even new paper mill power plants would probably be out of compliance. She continues, "The EPA methodology used in establishing the rule is unrealistic and urges the agency to use a risk-based approach to avoid costly and conflicting controls."

I'm all for cleaner emissions, but want to use judgment, reality, and economic practicality in arriving at better emission levels. This one doesn't make sense and I will want to discuss the proposed changes in a future column. Proactive or punkie, that's the question.

Defining "green" requires sorting fact from fiction. In other words, weed out the "greenwash" from the truly green. Here's how complicated this can be: How do you define a green cleaner? What characterizes a green lubricant? If a cleaner is biobased but cannot be disposed down a drain, is it green? If a lubricant can't be drain-disposed but can be made into biodiesel, then is it green? If a lubricant is biobased and biodegradable but was created using hazardous fertilizers and insecticides, is it green? What if a solution is biobased, drain-disposable, grown organically and locally, contains zero percent hazardous chemicals, is recirculated, and then delivered by bicycle, but is not effective at its intended purpose and therefore the material it's intended to lubricate or clean deteriorates and must be discarded before its intended life cycle – is it green? (I love that one). All of these are from Kate Bachman, the editor of Green Manufacturer. She poses great questions as all of us, Walmart included, try to take punkie out of definitions and measurements. Someone said, "It isn't easy being green." I think it was Kermit the frog, on Sesame Street. Boy, was he was right.

Last night I had dinner at a restaurant that claimed everything on its menu was organic. Salads and pastas are easy. Beef, fish, and pork are more difficult. I decided to leave it alone and sit back and have a second martini. I didn't want to become an argumentative punk.

Another Letter from the Earth.


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