The world wouldn’t be where it is now without machine shops.  Manufacturing operations such as tool and die plants, aerospace parts manufacturers, surgical fitting fabricators, firearms manufacturing, and other metalworking industries (particularly precision work) have had a long history in Massachusetts, from the founding of the Springfield Armory in 1777 through the present day.

As any good machinist knows, though, if you want to work with metal you have to know a fair amount about oil, which is used in many forms in metalworking operations.

The two kinds of oil most commonly used are:

  • Way oil, also known as lube oil, slide oil, or brown oil, is a high-grade hydraulic oil formulated with a tackifier, an additive that improves the oil’s adhesion to metal surfaces such as the hydraulic pistons or sliding surfaces found in CNC machines, lathes and other heavy machine tools, to prolong the useful life of the oil and prevent it from oozing into the working process.
  • Modern cutting fluids, sometimes called metalworking fluids, cutting lube, or cutting oils, are sprayed, misted or flowed onto machining surfaces in manufacturing for several purposes—they lubricate the cutting process and allow machines to go faster, they cool the process and prevent tip welding, where the drill bit or other machine tool overheats to the point where it welds itself onto the workpiece. These products are typically an emulsified mixture of oils and water (either water outside oil or oil outside water),  by means of an oil engineered to be water soluble, or a surfactant or detergent additive. Most cutting fluids range from 1% to 5% oil by volume, and the emulsions can remain stable for weeks. Cutting oils used in these mixtures may be petroleum based or derived from plant or animal materials (lard and fish oil are surprisingly common, especially for manufacturing food grade equipment components), or based on synthetic oils (often used in milling and grinding). High-flash kerosene is sometimes used for working with aluminum.
CNC head
Close-up view of a CNC machine and cutting fluid

In addition, some facilities use quantities of other kinds of oil, such as lubricants, rust preventatives (especially in firearms manufacturing), quench oils, and other products.

It makes economic sense to reuse cutting fluids as much as possible, but cutting fluids deteriorate and almost inevitably become contaminated with way oil and other oils, such as oil films used to protect bar stock, etc., which form separate phase liquids called “tramp oils” that float in blobs on top of a container of cutting fluid, and that would foul the process if allowed to recirculate through the system. If you let a drum of well-used waste cutting fluid sit for a few hours, more often than not a layer of tramp oil will partition out on top. Many modern CNC machines have onboard sumps in which the cutting fluid accumulates before it is recirculated, fitted with skimmers or other devices to remove separated tramp oils. Some larger facilities have central cutting fluid management systems with sophisticated tramp oil separators.

Eventually any machine shop or metalworking facility generates waste oil. In the late 1980s, EPA developed a regulatory framework for waste oils that didn’t meet the RCRA criteria for hazardous wastes (40 CFR 279), and which has been implemented by most states, in many cases along with the states’ identification of waste oil (variously defined) as a state-listed waste.

These regulations ultimately had two goals. The first was regulatory, in order to prevent the inappropriate disposal of hazardous wastes. The second reason was to provide for the beneficial reuse of oils that would otherwise have to be disposed.

Cutting fluids can also accumulate concentrations of RCRA metals (chromium, cadmium, lead, etc.) or chlorinated solvents such as perchloroethylene (PCE), trichloroethylene (TCE), or 1,1,1-trichloroethane (TCA), which were historically widely used for degreasing and cleaning metal parts before and after working on them. The older generation of consultants and manufacturing veterans remember the ‘old days’ when jet engines or other machines were dipped whole into vats of solvents for degreasing, like deep-frying a Thanksgiving turkey, and “waste oil” was historically a sort of catch-all waste stream that could contain many other things, including solvents, PCBs from transformer and hydraulic oils, pesticides and caustics. The use of waste oil containing highly toxic dioxins for oiling dirt roads is what turned Times Beach, Missouri into a ghost town. The use of solvents like PCE, TCE and TCA  has decreased greatly over the last couple decades (down by about 90% since 1991, based on data provided by the Massachusetts Toxics Use Reduction Program) but they are still used in reduced quantities and remain of concern.

Uncontaminated way oils are readily recyclable, useful for fuel blending or lube base production, and can typically be recycled as heating fuel in standard waste oil burners if no other option is economical. It’s therefore a good idea to keep spent hydraulic and way oils and tramp oils separate from cutting fluids.

Cutting fluids, by contrast, can pose a number of problems:

  • Although the percentage of oil in a cutting fluid is small, environmental regulations in many states require that the whole volume of the material be managed as a waste oil or hazardous waste, because of the RCRA “mixture rule” requirement that goes with being a listed waste. This can result in relatively small facilities generating enough oil/water mixtures to trigger Large Quantity Generator status, which comes with higher annual regulatory fees, planning and training requirements, etc.
  • On their own, dewatered non-petroleum cutting oils typically have little fuel value, limiting their reuse options, although they can be blended with other oils with higher fuel values to produce a marketable fuel product.
  • Breaking the emulsions and separating the oil from water is advantageous, but this can involve some fairly complicated chemical treatment, such as heating, acidification to a pH of roughly 2 and subsequent neutralization, or the addition of a salt or acetate. Even then the separated decant water will still likely contain some oil and may need to be evaporated, recycled into the process with new oil additives, or treated as an industrial wastewater.
  • Residual cutting fluids will also often cling to metal turnings, and well-managed shops will typically clean their turnings with a centrifuge, wringer, bath, or other means to remove most of these residues before shipping them for recycling.
  • Potentially most seriously, waste cutting fluids or their sludges can contain chemical impurities picked up during use, including metals and solvents. These contaminants can greatly increase the cost of managing the oil, ranging from “off-spec” costs for water, solids or halogens, to needing to manage the oil as a hazardous waste. Addressing these complications after they come up can cost time and money.

One common problem with waste oil is based in simple chemistry. Much of the waste oil generated by commerce and industry is reused for fuel, whether burned in the ubiquitous waste oil fired space heaters, or sent to a plant for batching, re-refining and resale. When oil containing chlorine-containing compounds is burned, the chlorinated compounds break down and the result is hydrochloric acid (HCL). This poses health hazards to workers and the public, and can also corrode and damage the oil-burning equipment. The more chlorine there is in the oil means the more acid there is in the off-gas.

EPA’s policy therefore centered on a “rebuttable presumption” that oils containing less than 1,000 parts per million (0.1%) total halogenated compounds were unlikely to have been mixed, intentionally or not, with a listed hazardous waste, while oil containing more than this threshold were considered to be hazardous unless shown not to be by further testing or generator knowledge. Most waste oil handlers will accept oil with high halogens, but will typically assess a surcharge on a sliding scale according to the halogen concentration.

Halogens are a family of chemicals including chlorine, fluorine, bromine and iodine, so called because they readily form salts (halides) with alkaline metals such as sodium (e.g. sodium chloride, calcium chloride, or potassium bromide). They also readily bond with hydrocarbons to form ‘organochlorine’ compounds, and many of the “better living through chemistry” era’s hazardous legacy products were based on organochlorine technology, whether old standbys such as DDT, perchloroethylene, pentachlorophenol, polychlorinated biphenyls, trichloroethylene, their lesser-known cousins such as Halowax or polybrominated fire retardants, or the increasingly notorious perfluorinated compounds such as the PFAS and PFOS families.

One of the problems with this approach, of course, is that oil technology has changed a great deal since the late 1980s, and in some respects the regulations and analytical methods haven’t kept pace. Many modern waste oils contain concentrations of chlorine greater than EPA’s 1,000 ppm threshold even though they aren’t contaminated with RCRA-listed solvents, or weren’t even generated at facilities where these old solvents are used at all (not even the old and sparingly-used-just-for-repair-emergencies bottle of old-formulation 3-in-1 oil (the kind loaded with trichloroethylene) that so many maintenance men kept in their toolboxes)!

Many modern synthetic or vegetable-based machine cutting oils, as used in machine shops, contain engineered chlorinated compounds in the form of biocides such as CMIT (to keep bacteria from degrading the oil) or as “EP” temperature and pressure additives (typically chlorinated paraffins, although there has been considerable regulatory whiplash over the now-aborted phase-out of shorter-chain hydrocarbons  in favor of less toxic long and very-long-chain paraffins). Let’s just emphasize that these compounds are NOT currently listed by EPA as hazardous wastes, and for the most part didn’t even exist in trade when EPA’s waste oil policy was developed in the late 1980s. It’s also worth noting that, as we discussed in a prior blog post, cutting oils that don’t contain petroleum and that aren’t otherwise a hazardous waste often do not need to be managed as a hazardous waste or state-listed waste oil.

The sticking point is that the common ‘total halogens’ analyses (SW-846 laboratory methods 9253, 9056, 9075, 9076 and the Method 9077 field test kits such as Chlor-N-Oil) report only a total concentration of all the chlorinated, brominated or fluorinated compounds in the sample, which doesn’t tell you if your oil was formulated with a non-regulated chloroparaffin or brominated ingredient, or if it somehow became contaminated with a regulated degreaser such as trichloroethylene or a nonregulated product like a chlorinated brake cleaner. “Failing” a total halogens screening test does not automatically mean your oil is a hazardous waste. Most environmental laboratories can run chemical tests for solvents or other regulated chlorinated compounds in waste oil, and this may be necessary, but the cost can be several hundred dollars per sample to cover EPA’s entire list of potentially regulated compounds.

The first step in a solution to this conundrum is, of course, plain old good recordkeeping. Safety Data Sheets, product formulation spec sheets, and other documentation that provide information on the chemical makeup of the parent product, any additives, and most particularly, what your facility doesn’t use (e.g. solvent products containing more than the 10% chlorinated hydrocarbons threshold in EPA’s listing descriptions for solvent wastes), go a long, long way towards demonstrated that the oil doesn’t contain a listed solvent, and reducing the effort and cost of testing, handling and disposing of these materials.


Some of the OTO crew participated in the Joseph Freedman Company’s seventh annual charitable Bowl-A-Thon on November 10, 2018. This is a fun annual benefit for Camphill Village, held at AMF Lanes in Chicopee, Massachusetts.
Bowling is a great sport for engineers, since it’s a community activity (that gets us away from our labs, offices and job sites), while still letting us try to solve problems (how to knock down more pins than our teammates) using our knowledge of natural science principles such as force, friction, inertia, gravity and centrifugal force.
Some of the things we learned this time around:

  1. Lighter balls are better because they don’t lose momentum and go off-course as quickly as heavier balls.
  2. Aim for the gap right after the lead pin in the triangle for best resultsrightpocket
  3. Centrifugal force (spin) matters but is much easier said than done.index
  4. Nice and easy does it.
  5. Don’t bowl better than the boss….unless you’re bowling for the boss.

What is an oil?


This might seem like a simple question, but there are many possible answers… and sometimes an oil is not always an oil.

Let’s begin with the dictionary definition (though this is always a bit venturesome when discussing environmental regulations). The Oxford English Dictionary defines the noun ‘oil’ as:

  1. A viscous liquid derived from petroleum, especially for use as a fuel or lubricant

            1.1 Petroleum.

           1.2 [with modifier] Any of various thick, viscous, typically flammable liquids that are insoluble in water but soluble in organic solvents and are obtained from animals or plants.

                 ‘potatoes fried in vegetable oil’

            1.3 A liquid preparation used on the hair or skin as a cosmetic.

                 ‘suntan oil’

            1.4 [Chemistry] Any of a group of natural esters of glycerol and various fatty acids that are liquid at room temperature.

                  Compare with fat

  1. Oil paint.

           ‘a portrait in oils’

Even in the OED, then, ‘oil’ has multiple meanings, but we need not concern ourselves with suntan oils or oil paints (unless, arguably, someone has more than 1,320 gallons of above-ground suntan oil storage, but we will leave that question for Florida or perhaps the Jersey Shore).

Unfortunately that’s crude oil from the Exxon Valdez, not tanning oil.

Now let’s look at some of the regulatory definitions of oil that apply in Massachusetts. The narrowest definition is found in the Resource Conservation and Recovery Act and its state-level analogues such as 310 CMR 30.00:

Oil means petroleum in any form including crude oil, fuel oil, petroleum derived synthetic oil and refined oil products, including petroleum distillates such as mineral spirits and petroleum naphtha composed primarily of aliphatic hydrocarbons. It does not mean petrochemicals or animal or vegetable oils. (310 CMR 30.010)

The same regulations subsequently also define a handful of subcategories of oil, such as “unused waste oil,” “used waste oil” and “used oil fuel”, and the ‘mixture’ rule applies, but basically we have 1) petroleum only (and thereby excluding olive oil, fish oil, lard, and rapeseed “canola” oil), and 2) not petrochemicals. Petrochemicals are separately defined in the same section as “an individual organic chemical compound for which petroleum or natural gas is the ultimate raw material, except that aliphatic hydrocarbon compounds, which maintain, after use, closed cup flashpoints equal to or greater than 140o F (and which are not otherwise a characteristic or listed hazardous waste) are oils.” This would therefore apply to compounds such as white spirits, low-aromatic solvent naphtha, or high-flash mineral spirits, referring back to the aliphatic ‘petroleum distillates’ inclusion in the oil definition.

Although RCRA distinguishes between hazardous waste and waste oil, and has separate and less stringent provisions for waste oil, Massachusetts (like many states) classifies waste oil as a state-listed hazardous waste, and applies most of the same requirements to both categories. When it comes to waste management, materials meeting this definition should be listed on a Uniform Hazardous Waste Manifest as MA-01 waste oil, or if being managed as a regulated recyclable material, as MA-97 specification or MA-98 non-specification used oil fuels. Non-petroleum oils, such as spent machining coolant mixtures containing only, say, vegetable oils or lard, would not be regulated as waste oils under these regulations, but these distinctions must generally be made based on information provided by the products’ manufacturers and knowledge of the process generating the waste. This definition would, for example, exclude waste biodiesel oil, but only if it did not contain a petroleum admixture or contaminant (pure biodiesel fuel is rarely used as a transportation or heating fuel, and most commercial grades of biodiesel are sold as biodiesel/petroleum blends). Significantly, oils that don’t contain petroleum mixtures, such as a cutting fluid that is free of ‘tramp oil,’ do not need to be counted against a hazardous waste or waste oil generator’s generation or accumulation limits.

The definition in MGL c. 21E and the Massachusetts Contingency Plan is broader, as it includes non-petroleum and animal or vegetable oils, for example fryer oils and vegetable-based hydraulic oils or synthetic cutting oils, with the mixture rule applying in some circumstances per 310 CMR 40.0352:

Oil means insoluble or partially soluble oils of any kind or origin or in any form, including, without limitation, crude or fuel oils, lube oil or sludge, asphalt, insoluble or partially soluble derivatives of mineral, animal or vegetable oils and white oil. The term shall not include waste oil, and shall not include those substances which are included in 42 U.S.C. §9601(14). (310 CMR 40.006)

The MCP also has differing Reportable Quantities for petroleum and non-petroleum oils, respectively 10 gallons and 55 gallons.

The MCP in turn separately defines ‘waste oil’ as:

[U]sed and/or reprocessed, but not subsequently re-refined, oil that has served its original intended purpose. Waste oil includes, but is not limited to, used and/or reprocessed fuel oil, engine oil, gear oil, cutting oil, and transmission fluid and dielectric fluid. (310 CMR 40.006)

The 42 USC 9601(14) citation referenced above by the MCP refers to the CERCLA list of hazardous substances (in effect reiterating that a material may either be an oil or a CERCLA substance, but not both at once), and from which petroleum oils are granted certain often-litigated exemptions originally intended to cover crude oil, but which were subsequently extended by litigation to cover refined petroleum products that were not otherwise listed under CERCLA or categorically included through CERCLA’s references to RCRA (e.g. having a flashpoint less than 140oF or failing TCLP for benzene).

This distinction is important in the legal aspects of assessment and remedial matters in Massachusetts (meaning the windy, desolate parts where lawyers predominate rather than LSPs). While the MCP applies essentially the same regulatory framework and remedial requirements for both “oil” and “hazardous material” sites, section 5(a) of the 21E statute limits  liability for releases of oil falls only to current owners and operators and those who have “otherwise caused” such releases or threats of release, while liabilities for releases of hazardous materials are not so limited, and any prior owners and operators could potentially be dragged into the PRP box and dunned for cost recovery.

The definition of “oil’ used in the Clean Water Act and the Oil Pollution Act of 1990 is the broadest, since it includes a broad spectrum of non-petroleum oils, and also the most vague:

Oil means oil of any kind or in any form [and thus including mixtures], including, but not limited to: fats, oils, or greases of animal, fish, or marine mammal origin; vegetable oils, including oils from seeds, nuts, fruits, or kernels; and, other oils and greases, including petroleum, fuel oil, sludge, synthetic oils, mineral oils, oil refuse, or oil mixed with wastes other than dredged spoil. (40 CFR §112.2)

This definition even includes milk and other dairy products, since it contains fats of animal origin. Since a large spill of liquid milk products  (or, for that matter, canola oil, coconut oil, or even tea tree oil if you amassed enough of it) can have a destructive effect on a river or lake easily on par with that from a similarly sized spill of fuel oil, e.g. by rapidly depleting the water’s dissolved oxygen content and thereby annihilating fish and other aquatic life in the spill area, this makes sense from a chemical and ecological perspective. In a rare spasm of regulatory praxis for farmers, however, these and other non-petroleum materials are exempted from certain requirements for containers but are still subject to requirements for contingency plans and notification of releases to water bodies. It also raises the tempting prospect of classifying deep-fat fryers as regulated “oil-filled operational equipment.”

The OPA definition is also sufficiently vague as to create confusion and some apparent contradictions, since it gives very little idea where ‘oil’ stops—if gasoline is considered an oil, what about solvent-grade toluene that is refined from oil? Under other statutes and regulations, toluene would be considered a non-oil petrochemical, but under the OPA it is arguably an oil. Or, consider an oil terminal where large quantities of oil are processed by adding dyes required by motor fuel tax regulations. The oils would be subject to SPCC and FRP requirements, but the status of the dyes themselves could be arguable.

Department of Transportation regulations (49 CFR §130.5) emulate the OPA definition but rather sensibly break it down into three separate components, for petroleum oils, non-petroleum oils, and animal or vegetable oils.

The first result of all these different definitions of a single three-letter word can be somewhat strange, semantically speaking. Hypothetically, a release of non-petroleum oil from an OPA-regulated facility (perhaps the vast strategic reserves of extra-virgin olive oil at Rachel Ray’s house) can be reported to MassDEP as a release of oil, but the recovered product and remediation waste doesn’t have to be identified as an oil on the manifest. A further hiccup is that some waste receiving facilities, such as asphalt batching plants accepting oily soil or oil product batchers and recyclers, are limited by their permits (and likely the material requirements of their end product) to petroleum products, and generally cannot accept materials contaminated by non-petroleum oils. A thermal desorption plant (where the oil is volatilized and combusted in an afterburner) would not necessarily be so limited.

The second result is, of course, that the environmental professional must remember which regulations apply when he uses the word, particul

arly if he primarily works on MCP projects and is occasionally called to assist in hazardous waste or OPA work.


“Volatile organic compounds or VOCs” are defined (310 CMR 40.0006) in the MCP.

Volatile Organic Compounds and VOCs each mean an organic compound with a boiling point equal to or less than 2180C that are targeted analytes in EPA Method 8260B and other purgeable organic methods specified in the Department’s Compendium of Analytical Methods.

 So, what are the “targeted analytes” under: 1) 8260B; and 2) CAM?

 8260B says: It is the intent of EPA that all target analytes for a particular analysis be included in the initial calibration and calibration verification standard(s). These target analytes may not include the entire list of analytes (Sec. 1.1) for which the method has been demonstrated.

Section 1.1 lists 108 individual compounds which would appear to be the universe of 8260B targets. Labs typically target a subset (37) of these, including the common aromatic and aliphatic VOCs, as well as the long list of chlorinated VOCs.

2) CAM – The current purgeable CAM methods are limited to VPH (volatile petroleum hydrocarbon). EPH (extractable petroleum hydrocarbons) is a CAM method, but is NOT a purgeable method. Therefore, EPH target analytes should fall outside the VOC definition (more on this later). Focusing on the VPH Method, “Target VPH Analytes” are narrowly defined in CAM as BTEX plus MTBE and naphthalene.

VPH hydrocarbon fractions are not target VPH analytes, and are therefore not VOCs?  A literal read of the VOC guidance could go further and conclude that only the BTEX plus compounds are VOCs, since they alone are targeted in both 8260 and VPH. Such a literal read is contrary to clear guidance in the Q&A (Question 7) and the Vapor Intrusion Guidance Document. These sources make absolutely clear that DEP considers VPH fractions to be VOCs.

So What? Definition flexibility can be stretched further as illustrated below.

A Not So Hypothetical Case

C9 to C18 aliphatics slightly exceeded GW-2 standards within 30 feet of a residence. The LSP recommended reporting within 72 hours under 310 CMF 40.0313(4)(2), because “volatile organic compounds” exceeded GW-2 Standards. Client requested a second opinion from me (LSP2). With about 8 hours left on the reporting clock. I looked at the definition, talked to another LSP in the office, looked at Guidance Q&A question 7 and the Vapor Intrusion Guidance Document, and felt confident it was not a 72 – hour condition. I based my opinion on:

  • EPH is not a CAM “purgeable CAM Method” and thus falls out of the definition. Further the only target PAH from EPH with a boiling point below 218oC is naphthalene, which was not detected above GW-2 standards.
  • DEP guidance on the question of hydrocarbon fractions being VOCs was specific only to VPH fractions, DEP did not extend the definition in its guidance to EPH fractions.

With two LSP contrary opinions, and the clock running down, Client asked LSP1 to call DEP with the hypothetical to hopefully resolve the conflicting LSP opinions.

A few hours later (and in time), LSP1 reported back that MassDEP considers a portion of the C9-C18 aliphatics to be a VOC with reporting applicability under 310 CMR 40.0313, with the definition applying due to the overlapping VPH Fraction (C9-C12 aliphatics).

Fortunately for my client, DEP concluded the hypothetical was not a 72 – hour condition because the concentrations were relatively low, the suspect source is fuel oil and the presumed age of the release, MassDEP acknowledged that lines of evidence in our hypothetical do not require the presumption that more than 5,000 ug/L of the C9-C18 aliphatics result is in the C9-C12 range, and therefore 72-hour reporting was not required at this time.

Bottom Line and finally getting back to my opening question:

  1. Q. What are Volatile Organic Compounds in Massachusetts?
  2. 8260B targets, VPH Fractions, and sometimes C9-C18 aliphatics depending on concentrations and source.




Mark O’Malley and Paul Tanner, PG, LEP

August 22 is National Honey Bee Day

This post is the first of two concerning insects.  Today’s subject concerns honeybees, the beloved non-native insects that were first brought to North America in colonial times.  About 20% of OTO staff have direct experience with honeybees;  one engineer worked with a commercial beekeeper in high school, two chemists kept bees earlier in life,  two geologists are current backyard beekeepers, and another keeps talking about starting beekeeping, and we know she will one day.  That 20% statistic seems high. Maybe is a coincidence; maybe it’s because we are a smallish company, or maybe it points to the professional earth sciences attracting certain kinds of flowery environmentally-minded people?

This picture is not Kevin O'Reilly circa 1968

Most honeybee media reports nowadays are alarming and negative.  Commercial beekeepers that offer traveling pollination services have experienced unprecedented die-off of honeybee stocks from a combination of stressors (pesticides, transportation stress, monoculture/food non-diversity, internal and external mites and disease).  The upside is that a shift in industrial agricultural practices has started; in fact some growers are opting to secure their crop pollination by having permanent hives and beekeepers on staff and planning for a greater diversity of pollen and nectar sources in hedgerows between monoculture fields.



In a similar vein, we all can adapt and do our part to help out honeybees by: 1) consciously considering bees in our landscaping plans; 2) exercising our purchasing power,  and; 3) perhaps trying to farm this popular social insect ourselves.

Mark and Paul, the two active OTO beekeepers, wish to offer a top ten list of pro-bee considerations for you to contemplate:

  1. Mark: Planting for Bees is Rewarding! See the attached list of honeybee –friendly plants.  Example: you might consider planting asters instead of ho-hum chrysanthemums this fall.  Asters are perennial, and are positively loaded with pollen and nectar in September and October, providing a great source of nectar and pollen for bees preparing for winter.  That said, bees are efficient at focusing on the richest nectar and pollen source available; honeybees forage as much as three miles from their home, and are happy to pass over your beautifully landscaped honeybee-friendly flowerbeds to reach those freshly blossomed white flowers on a thorny brush pile.  A plant that’s producing nectar one day, is devoid of bees three days later.  Another thing, bees really like trees.  The broad root systems of trees produce a strong nectar flow and loads of pollen.  Even trees that a common person might not associate with honeybees are valuable resources.  Red maples produce some of the first early spring buds targeted by bees.  The yellow pollen from pine trees that coats windshields –  bees love it!
  1. Paul: Beekeeping Teaches Energy Conservation: As any good manager knows, delegating tasks to informed, qualified, diligent staff leads to client satisfaction and makes the manager look good.  Honeybees come pre-trained with an established hierarchy, they instinctively know their particular jobs, and they are vivacious, loyal and industrious.  My job is to keep the queen happy, keep up with medicine and feeding, and give the colony ample room to grow. The actual setup, checkups and honey extraction are indeed backbreaking work and intensive for about four weekend days per year.  Much of beekeeping, however, is watching them do the work, with morning coffee in hand, and provides truly some of the best moments in my work week.    While I’m also a fan of planting for honeybees, on the flip-side;  keeping a wild spot, bramble patch or hedgerow on your property takes no effort, will sustain weedy blooms all season long-  helping bees and the environment and saving you effort, giving you more time in August for reading the great American novel or your coworker’s thousand-page book on coal tar sites.

2. Actual setup

  1. Mark: Support your Local Beekeeper: If you would rather not farm a social insect, your purchasing power can help support your local beekeeper. Beekeeping is increasingly popular and chances are, you can find local honey, beeswax-related soap, cosmetics, candles and even furniture polish at your local farmer’s market or neighborhood market.  All this helps your local beekeeper support their operation and keep healthy bee populations thriving.

3. Local beekeeper

  1. Paul: Get Invited to More Social Gatherings: Not that beekeeping types are that good looking or popular, but try bringing a jar of local honey to your next dinner party instead of a bottle of wine or tired bouquet of flowers.  Your social calendar may change for the better!

4. Local Honey

  1. Mark: A Lesson in Foundation Engineering: This spring, with the aid of a bubble level these two hives were set-up perfectly (see photo).  The hive on the left is on a foundation of cinder blocks, with cement pavers which help spreads the load.  The hive to the right is just on cinder blocks with a slightly smaller footprint.  Over time, the hives grew taller from one box to five.  By early July the hives neared 300 pounds each.  The hive on the left with the spread concrete base has remained level.  The soil beneath the “Leaning Hive of Hampden” to the right, dried out and compressed under the hive’s weight.   Note to self, when expanding operations in 2019, seek advice from a Geotechnical Engineer.   

5. Set up perfectly 6. Leaning Hive of Hampden

  1. Paul: Intensive Focus: When I am working my bees, the sights, sounds and smells are so powerful… like all good art or creative practice, moments of time seem to slow down while paradoxically an hour can pass by in a minute.  When working an open beehive, it is not possible to think about anything else – each breath, each movement has true significance.  In an open hive, there’s the intoxicating smell of fresh wax, nectar, pollen, honey and smoke –  and the added bonus of immediate gratification – sucking on a piece of warm honey-filled comb, fresh from the hive. Then there’s the waggle dance, the queen’s distinctive shape, the baby bee emerging from a nursery cell, the selfless kamikaze attack from angry bees falling on thick leather gloves, mesh and protective clothing – protective clothing that is guaranteed 99% effective!

7. Protective clothing

  1. Mark: Beekeeping can Actually Socialize Scientist-Types: Hanging out with a social insect actually rubs off on the introvert.   Beginning beekeepers have a steep learning curve – each year the Worcester County Massachusetts Beekeepers Association puts on an 8-week course for new beekeepers in late winter/early spring.  The classes are typically one night a week for two hours.  Bee school will present you will information for selecting the Site of your first hive (or two). A Location with morning sun,  a clear flight path and space to work around the hive is key.  Over 400 people attend!  Amateur and expert beekeepers, state apiary inspectors, college professors, and even folks that have performed studies with honeybees for NASA and NOAA give presentations and instructions for those just starting out.  It’s a great place to network.

8 Location with morning sun

  1. Paul: Beehives Can be Unobtrusive:  This year I attended a 4th of July block party.  There were bands, there was dancing, it was hot, humid, sweaty and there were many open containers of sugary and malty beverages.  The neighbor’s two beehives were located behind a hedge, about 75 feet from the revelry.  There were no honeybees in sight, they are much too busy performing work;  gathering nectar and pollen or by the brook, gathering water to cool off the hive.  While my hives are in the woods (photo above), I’m intrigued by rooftop hives in urban centers, particularly in NYC. Of course you would want to check your local ordinances before you consider placing a hive at your home.

urban beekeeping

  1. Mark: Beekeeping Increases Your Awareness:  In the springtime, if the driver in front of you slows as they pass an orchard or field of dandelions, you know you’re behind a beekeeper.   I never thought a hobby dealing with insects would lead me to spend so much time looking at plants, which inevitably leads to greater awareness in general.  The variations in rainfall, sunlight and plant cover impart large changes in honey yield and subtle changes in the taste of honey from year to year.   To a beekeeper, evaluating weather patterns and blooming plants can be like gazing into a crystal ball, and it’s fun to guess how the future will taste.
  1. Paul: The Health Effects of Honey: Huh?  If  you think honey will help your allergies, sure I’ll sell you a jar! I’m a skeptic – Honey, being a simple sugar, is readily converted to energy in the human digestive system.  I don’t personally believe that pollen in the honey actually survives in the human gut to the extent that it helps with immunity to allergens.  What’s more, I don’t think my borderline excessive personal consumption of honey is particularly healthy….. but come to think of it… at least I don’t have allergies!

9. PCB Honey. Label created by Tom Speight


Please join us to commemorate National Honeybee Day on August 22.  Each of us can do our part.  We can plant bee-friendly landscapes and gardens, we can use our purchasing power to buy locally produced honey and related products and we can consider looking into beekeeping.

Put some Honey on it!

The second post in this series will concern native bees, an often overlooked class of mostly solitary insects that compete with imported honeybees, and offer important pollination services to most native plants, forest ecosystems and agriculture.   Did you know most native bees don’t sting?

Until then, Bee Well,

Mark and Paul.

I recently had the great pleasure of attending the Society for Industrial Archaeology’s annual conference, held in Richmond, Virginia. The SIA is an interdisciplinary professional organization dedicated to the understanding and preservation of industrial history and artifacts.

While there, I gave a presentation about my recent research topic, the historic manufactured gas industry of Massachusetts, and its environmental legacy. The other conference presentations covered a very wide variety of topics, ranging from the restoration of a historic pumphouse and dancehall in Richmond, to mapping pre-Civil War copper mines in the Upper Peninsula of Michigan (where masses of nearly-pure ‘native copper’ weighing hundreds of tons could be found in rock fissures), to how exactly do you preserve and restore a Cold War era CIA spyplane to use as a monument, when some of the materials used in the plane’s construction remain top secret?

Tom Tar Wars
Just a little environmental consultant humor….

The SIA is a pleasantly diverse organization; I shared a seminar panel with Frederic Quivik, a professor of industrial history who frequently serves as an expert witness in environmental litigation. He spoke on legacy issues associated with contaminated mine tailings used as railroad ballast in Idaho Also on the panel was Simon Litten, a retired forensic chemist with the New York State Department of Environmental Conservation, who spoke about the origins and industrial uses of PCBs and some of their lesser-known cousins, such as polychlorinated naphthalenes (e.g. the old Halowax products).

The conference also included a number of fascinating tours, including: visits to Fort Monroe, the Newport News waterfront (including a view of the now-decommissioned aircraft carrier USS Enterprise), the archaeological center at Jamestown, and the Virginia Mariners Museum, where parts of the warship USS Monitor of Civil War “Monitor and the Merrimack” fame are being painstakingly restored through a fascinating chemical electrolysis process.

Just a note—alliteration aside, only Yankees still call the Confederate ironclad the Merrimac, even if we usually forget the ‘k’. South of the Mason Dixon line, she is always and forever the CSS Virginia.

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An interior view of one of the gun batteries at Fort Monroe


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An excavation showing part of the footings under an interior wall at Fort Monroe, where specially-made triangular bricks were used to tie two relieving arches together underground.


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The former USS Enterprise, now being dismantled. This photo was taken from over half a mile away, which is about as close as one can get and still fit all of the ship in a photo.


The former Richmond gas works, with one of the few remaining late-period gasholders in the US.


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For me, one of the highlights of these visits involved one of the humblest objects, a four-foot length of wrought iron chain that had been lost down a water well at Jamestown circa 1608, and which through one of those flukes of chemistry and history, landed in a stratum of anaerobic soil, where the lack of oxygen preserved the chain essentially unchanged until it was recovered in the early 21st century. There really is nothing like being able to hold a genuine 410+year old artifact in your hands.

If you are interested in topics such as industrial history and the history of science or technology, consider joining the SIA.

O’Reilly Talbot & Okun Associates, Inc. participated as a sponsor in the Net Positive Symposium for Higher Education, held at one of our recently completed projects, the R.W. Kern Center on the beautiful Hampshire College campus in Amherst, Massachusetts.  The R.W. Kern Center   is Living Certified by the International Living Future Institute, meaning that:

  • The building includes regenerative spaces that connect occupants to light, air, food, nature, and community;
  • The building is self-sufficient and remains within the resource limits of the site. A “Living Building” produces more energy than it uses, and collects and treat water on site; and
  • The building is healthy and beautiful.

You can read more about the R.W. Kern Center in the certified case study here.  The building contains a number of features to meet the “imperatives” of each of performance areas.  The building includes composting toilets and treats all its grey water on site via filtering through indoor planters in the building’s common space, and through an onsite wetland.  Thermal efficiency and a rooftop solar array are included in a net-zero energy demand for the building.  Biophilic design elements mimic the beauty of the college campus, and exposed structure and systems allow visitors to see components of the building typically covered behind ceilings and walls (who knew piping systems could be so elegant?).  Materials used in the building are locally sourced and any materials that have adverse effects on human health and the environment are avoided.

The symposium was held over two days, and included tours of the Kern Center and the Hitchcock Center (another Living Building in Amherst, Massachusetts).  The symposium highlighted projects at Hampshire College, Smith College, and Williams College, and their approach to sustainable, resilient, healthy, innovative, and equitable design.  On the 2nd day, a variety of small group lectures were held throughout the day covering many aspects of sustainable design and education, as well as design, development, implementation, and construction aspects of the Kern Center and other Living Building Certified projects.   Attendees included sustainability directors, faculty/educators, students operations staff, and design and construction professionals, and many others.

OTO was fortunate to be a part of the design, construction and commissioning teams for both the R.W. Kern Center and the Hitchcock Center.  OTO provided both environmental and geotechnical engineering services, as well and indoor air quality testing services during commissioning and certifications.  We would like to thank our clients (Hampshire College and Hitchcock Center for the Environment) and other members of the team, most notably Bruner/Cott & Associates, Inc. (architects for Kern Building) and designLAB architects, inc., (architects for Hitchcock Center), and Wright Builders (General Contractor).

OTO is a proud sponsor of the International Living Future Institute and we look forward to more Living Building Projects in the northeast.

Felt at Kern
Photograph of artwork by artist Janice Arnold (JA Felt) which includes 100 feet of dyed felt cloth hung above the staircase at the R. W. Kern Center.




My name is Jhonatan Escobar and I joined O’Reilly, Talbot & Okun Associates, Inc. (OTO) after obtaining my BS in Civil Engineering in 2017.  Working as a full time field engineer represents a lifetime milestone for me..  This achievement was greatly facilitated by Western New England University (WNEU) and the extracurricular activities that were available to me while working towards my BS in Civil Engineering.  The most rewarding activity was the 2015 Solar Decathlon Latin America and Caribbean.

The Solar Decathlon ( is sponsored by the U.S. Department of Energy and has expanded to include worldwide competitions. The events involve college teams designing solar powered houses. The goal of the competition is to explore sustainable engineering and new technologies while keeping the importance of a well-designed and attractive house.  Each house is judged based on affordability, attractiveness, comfortability, and functionality.

In November 2015, I traveled with a small group of WNEU students and faculty to Cali, Colombia, where we teamed with students from the Universidad Tecnológica de Panamá for the first Solar Decathlon Latin America and Caribbean   The concept behind our solar decathlon design was constructing the energy-efficient house from four recycled cargo shipping containers. The house was equipped with solar thermal collectors, a water reuse system, and phytoremediation for humidity control, temperature and CO2.

Solar house

Construction of our solar-powered house was delayed by a week due to complications with the border patrol in Colombia. The Solar Decathalon committee would not extend the construction deadline, so we had to work very quickly as soon as the containers arrived on site.   The team worked 18 to 20 hour shifts for one week straight to meet the completion deadline.  The house was completed on the last available date, and was opened for visitor and judge showings.  Our solar powered house was awarded first place in energy efficiency and third place in electrical energy balance.


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WNE team photo

This experience was very rewarding and I suggest civil engineering students look into finding an opportunity to compete in a Solar Decathlon, or another field related competition.  Having to work the long shifts due to a situation that was out of the team’s control taught me the importance of being able to adjust to situations quickly.  I also gained experience in working as part of a teams, and learned a lot about sustainable design.  I look forward to applying these skills as I work with the geotechnical and environmental teams here at OTO.

Students from Western New England University are now competing in the Solar Decathlon China, and the next Solar Decathlon Latin America will be in 2019.



New England Trail: Hike 50 Challenge

As an avid hiker and lover of the outdoors, I often head to the breathtaking White Mountains of New Hampshire, Vermont’s Green Mountains, and the Adirondacks of New York for weekend trips.  My goal for 2018, was to find and explore local trails that I could visit on weeknights after work. I know of popular hiking areas around the Holyoke Range but those tend to be crowded, and I am craving something new. Then I learned about the New England Trail, or NET.

The NET is one of eleven National Scenic Trails in America.  It  extends 215 miles from Long Island Sound in Connecticut north through Massachusetts to the New Hampshire border. Prior to the NET being granted federal designation as a National Scenic Trail in 2009, a 114-mile portion was known as the historic Metacomet Modnadnock (M&M Trail), and another 50-mile section was known as the Mattabesett Trail.  At that time, these trails were over a half-century old and needed maintenance and care. With continued expansions of residential subdivisions and other development pressures, the trails were constantly being relocated and options for these relocations were decreasing.

New England Trail
Map of the New England Trail from the NET website.

The National Trails System Act was developed following a speech given by President Lyndon B. Johnson in 1965 on the “Conservation and Preservation of Natural Beauty.” This act allowed for the creation and protection of American trails that celebrate outdoor adventure. The federal establishment of the NET in 2009 accomplished the National Trails System Act’s primary goal of protection for long-term trail viability.

In the past few years at OTO, I’ve participated in multiple conservation land acquisitions in western Massachusetts. For these projects, I review natural resource and endangered species files, assess environmental contaminants along proposed hiking and biking trails, and engage in discussions with MassDEP about planned recreational and conservation land use. I love what I do, and these projects hold a special place in my heart because I always enjoy my time on trails whether it be skiing, snowshoeing, backpacking, or just walking with my dog.

This year is the 50th anniversary of the National Trails System Act. In celebration of this anniversary, I decided to participate in Appalachian Mountain Club’s NET Hike 50 Challenge, in which participants hike 50 miles of the NET throughout the next year. I’m already 24 miles into this challenge, and it has taken me to beautiful forests, riverside trails, waterfalls, caves, and quiet mountain tops. To my surprise, some of the prettiest trails I have discovered so far are located just out of earshot of main roads that I frequently travel. This motivates me to keep going.  I can’t help but wonder what other hidden gems I will find along my way.


If you are interested in the Hike 50 Challenge but you aren’t sure if hiking all 50 miles is for you, that’s okay. There are many options that count towards your 50.  Point-earning activities are listed at the NET website. These include joining guided hikes or scheduled events, volunteering, monetary donations, staying overnight in a shelter or cabin, bringing a friend to the trail, and so many more!   (Although I do plan to hike all 50, I am gaining extra credit by sharing this blog on social media).

Adventure awaits!

Tom Speight, CHMM, and Paul Tanner, PG, LEP

Hazmat storage - BEST

For a one-page document, EPA’s humble Form 8700-22, commonly known as the Uniform Hazardous Waste Manifest, carries a lot of very important information, is used for a number of different purposes, and is generally one of the most important routine pieces of paper in the environmental industry. Launched in the grim days of Love Canal and the Valley of the Drums, in 2018 the manifest is going electronic in a big way.

EPA created the manifest program in 1980, as part of the modern Resource Conservation and Recovery Act (RCRA) system of registered hazardous generators, transporters, and treatment, storage and disposal facilities (TSDFs). The process has had several major upsides: it has improved the environment by improving the accountability for waste, cutting down on inappropriate disposal of waste, and has spurred development of waste minimization and “greener” manufacturing processes.

The intent of the manifest is to have a single document that provides a diary of what a waste material is, where it came from, who transported it, where it went, and what was done with it—RCRA’s proverbial “cradle to grave” tracking. Once the material has reached its ultimate end or has been processed so as to lose its identity (such as being mixed with other wastes and batched into hazardous waste fuel for use at permitted cement kilns), copies of the completed manifest are sent back to the generator and the generator’s state environmental regulators to close the loop. The manifest has gone through several versions and the current form, a six-part preprinted paper form, has been in use since 2005—here’s one example (click image for larger view).

manifest example

While the waste is in transit, the manifest also serves as shipping papers under Department of Transportation regulations. Because of the hazardous nature of the waste, the manifest also includes references to emergency procedures in US DOT’s Emergency Response Guide, so that first responders can easily know what hazards may exist, what precautions to take in the event of fire, explosion, or spill, and what first aid may be necessary for affected persons.


The manifest has additional uses once the waste has gone to its ‘grave,’ (or in the case of incinerators and cement kilns, a Viking funeral).


  • Generators keep archives of manifests as documentation not only of appropriate management of the waste (in the event of a regulatory or ISO audit), but that the generator was acting within the limits of its generator category (large quantity, small quantity, or very small quantity).
  • Large quantity generators and TSDFs also rely on manifests for tracking their waste throughput for RCRA Biennial Hazardous Waste Reporting.
  • Companies that maintain ISO certifications use manifests to track waste minimization efforts, for example as part of the “Environmental Aspects” under ISO-14001:2015.
  • Facilities that have to report chemical usage under the federal Toxics Release Inventory program or the Massachusetts Toxics Use Reduction Act typically look to manifests to track how much of a chemical was managed as a hazardous waste (and what then happened to it), as opposed to being incorporated into a finished product, recovered or destroyed by an air or water pollution control system, etc.
  • In the least-optimal scenario, manifest records can be used to assess how much waste a generator shipped to a TSDF if the receiving facility falls into RCRA Corrective Action or Superfund status and generators start getting dunned for contributions to remediation costs.

Some states have also created separate regulatory programs that rely on manifests (such as the Connecticut Transfer Act), under which archived manifests are used as a primary means of evaluating whether a facility generated more than 100 kilograms of hazardous waste in a month. The “manifest trigger” can add significant cost and complexity to a real estate transaction —this is where the descriptions, waste codes and management methods under Sections 9, 13 and 19 of the manifest can really become important in determining whether a waste was really hazardous (since it is not unusual to ship materials that aren’t, strictly speaking, “hazardous waste” on a manifest) was just shipped on a manifest), and whether it was shipped for recycling or for disposal.

Unfortunately, manifests have also always meant paperwork, in some cases rooms full of boxes of archived manifests dating back to the early 1980s, and in this has to some degree been a burden shared by industry and regulators alike.

In order to keep pace with technology and to reduce the paperwork burden, prompted by Obama- era legislation, EPA is rolling out a new eManifest system for June 30, 2018, which will convert most of the existing paper system into an electronic one.

The rule requires the following eManifest be implemented on June 20, 2018. Some of the significant aspects of the roll-out include:

  • Everyone who will be signing or using manifests, including generator staff, truck drivers, transporter compliance managers, and TSDF staff, will need to create an individual user account.
  • Manifests will be prepared, signed, and transmitted digitally, although for the foreseeable future paper copies will be retained for use as shipping papers—the driver still needs a copy in his truck cab.
  • The RCRA Biennial Reporting process will be integrated with eManifest, although the logistics of this are still being worked out.
  • The system will be funded by fees charged on receiving facilities (mostly TSDFs), ranging from $4 for fully electronic documents to $20 for paper copies, with the ultimate goal of paper elimination in 5 years.
  • Manifests may become more accessible to enforcement personnel.

With June 30 fast approaching, EPA has been hitting the road, providing talks to state agencies and industry trade groups.  At one such meeting, hosted by the Connecticut Environmental Forum on April 4th, Beth Deabay and Lynn Hanifan of EPA provided a peek into the front-end of the system (generator and vendor registrations and protocols to start an eManifest) but admitted that the back end of the system (summary reports) is still under development in Washington.

As with pretty much any regulatory change or new digital technology, there will be a learning curve and some bumpy starts. Smaller waste vendors may be playing catch-up and could find the changeover difficult, but the larger national-level generators, transporters and waste facilities are already using the system on a small scale and working out some of the kinks, so hopefully the transmission to a digital eManifest will be fairly smooth.

Looking back on the transition from paper to digital here at OTO, the shift was awkward, and took some time, but we can’t imagine bookshelves of reports anymore….  the high point of the process was recycling over two and a half tons of paper in one day alone, and turning our old document storage into part of a nice new conference room. In the coming years, we will look back on the rollout of digital manifests and are likely to appreciate simpler data processing, saving shelf space and trees!