Forget about hurricanes pushing oil slicks onshore in Gulf Coast states.  Ignore what you might have read about “Corexit rain” and other atmospheric disturbances.  Have no fear of a little oil in Lake Pontchartrain.  Oil has been moving onshore and slowly but steadily spreading into Gulf Coast states, even accumulating in underground reservoirs where it has the potential to leak out under pressure and cause potentially severe contamination of the surrounding soil and groundwater.  Let me guess: you’ve read all the posts over on TOD about running casing, blowout preventer inclination and seafloor subsidence, skimmers, bad cement jobs, top hats of all kinds, and relief wells, and you think you’ve read the whole story now on this crudest of episodes.  Well, here is a really trashy story about the Texas Orgasm that BP has been having lately all over the Gulf of Mexico and adjacent states.  As it turns out, oil has been making its way onto the coast through the humblest of mechanisms: those big green trash trucks coming through to service your dumpster every week, as well as the occasional cleanup site piled high with used oil boom and bags of tar balls.

Disposal of waste from BP oil cleanup sites is a sticky issue with political, economic, and ecological ramifications for many players in the region.  If you have ever attempted to legally dispose of used motor oil or other oily waste products, you know that managing these wastes is not as simple as tossing them into your trash can and sending them in a big truck to your local landfill.  At these small scales, oil and its liquid products are considered “household hazardous waste,” a class of material halfway in between ordinary household trash and true hazardous waste.  Small quantity generators of these wastes, such as households or small businesses disposing of small quantities of waste such as used oil from a company van, are exempted from the strict federal regulations governing handling and disposal of hazardous waste.  But as a concerned citizen exercising your civic duty to comply with the laws of the land (and because you wouldn’t want to despoil your own backyard), you know that you are still required to bring these items to a household hazardous waste facility or collection event.  And as soon as the material is collected, quite literally the instant you hand it over to the agency or business doing the collecting, the collector is bound by federal hazardous waste management regulations.  Since the household hazardous waste exemption exists in order to avoid overly inconveniencing residential waste generators and make it more convenient for safe and environmentally sound waste management to take place, as opposed to the actual hazardous qualities of the waste itself, one would assume that stricter requirements would apply to those generating large quantities of the waste, no?

Not so when it comes to throwing out thousands of tons of oily waste from the effort to clean up after the hot liquids gushing into the Gulf and the beaches and coastal marshes next door.  Apparently, tossing oil-soaked boom directly into a bin lined with nothing more than an ordinary trash bag (known for their ability to break when collected in packer trucks and rolled over by landfill compactors) is completely fine.  BP is the first example I know of a “conditionally exempt large quantity generator.”

Are you surprised?  If so, here is a tip for those new to studying the fossil fuel game: coal, oil and gas companies are exempt from air and water quality requirements, and the hazardous waste regulations for managing oil spill cleanup waste are no exception to the rule.  After all, the 2005 federal Energy Policy Act specifically exempted gas drilling using polluting and water-intensive hydraulic fracturing methods from the Clean Water Act, and coal-fired power plants and the mines and ash disposal sites that go with them have never been required to comply with most of the provisions of the Clean Water or Clean Air Acts.  Makes sense to me: remember, corporations are people too, and we wouldn’t want to inconvenience the fossil fuel industry or make it harder for these fuels to compete with renewable energy sources.  Considering how much we owe BP and the others willing to get their hands dirty in such a grimy business, our first imperative should be to keep the cost of fossil fuels as artificially low as possible at all costs, even if it means sullying our coastlines, coral reefs, and plankton, and even at the cost of taking us back some fifty years in the soundness of our solid waste management practices.  We need that oil, and there is no alternative!  Plus they give scads of money to politicians.  So it makes sense that we would treat these upstanding corporate citizens the way they want, by giving them lax regulations and loads and loads of tax breaks.

Anyway, there is a big mess going on down in southern Alabama and the surrounding area right now over how much of the oily cleanup waste to put where, with local residents and governments caught between their concerns over the environmental quality impacts of accepting oily waste for disposal versus the potential revenue streams available from making landfill sites available.  A recent investigation by the Associated Press caught a number of state and local environmental officials with their pants down, in many cases completely unaware that hazardous waste was being disposed in these landfills at all.  The investigation also showed evidence of environmentally unsound disposal practices at collection sites, such as heaps of oil-filled bags, collection containers with broken liners or in some cases none at all, and trucks spilling oil along the road and into local lawns as they move along their collection and hauling routes.  Meanwhile, BP and its contractors are allowed to save money and cut yet more corners by disposing of hazardous waste in facilities designed only for ordinary household waste.

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Whatcha gonna do with all that gunk?  (Photo: Mobile, AL Press Register)

Too Big To Succeed?

What do BP, AIG, and one more little company you might have heard of that goes by the abbreviation WM all have in common?  Here is one characteristic they all share: all three companies grew so large and dispersed in their operations that quality control was bound to suffer on some level.  Over the past several months, many observers have commented on what they see as a culture of negligence, indifference to safety standards, and corner-cutting to save costs at BP.  I would argue that another factor is also at play: the inability of the entity that is the mega-corporation to get control over all its tentacles.  It is easy to appreciate the challenge of changing corporate culture at a company as large as BP, with its hundreds of thousands of employees working in thousands of oilfields around the world as well as in alternative energy and in its gasoline distribution business.  The energy sector and the financial sector have seen players rise to became too big to fail, only to ultimately become too big to succeed.   Solid waste is looking more and more like it is heading in that direction every day too, as consolidation, reliance on (especially privately owned) megalandfills, and a lack of competition among major hauling and disposal operations creates a race to the bottom.  With its landfill, collection, hauling, recycling, composting, and waste-to-energy operations in the United States and Canada and a presence worldwide, is it possible that Waste Management simply has too many hands in too many cookie jars to control what must ultimately be the core of any operation: a meaningful commitment to quality?

As for the mess itself, they could always just burn the nasty but energy-dense waste at one of the fifteen waste-to-energy plants already located throughout Florida and actually make some use of the stuff instead of just burying it or flaring it straight off the side of the Discoverer Enterprise. (Sidebar: do the names of some of these vessels not suggest just a bit of arrogance on the part of these oil companies?)  But that would make just a bit too much sense for a company that seems to have lost the ability to do much of anything right other than making as big and as nasty a mess as possible out of our entire energy supply.