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.

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.

2018-06-01 10.14.25
An interior view of one of the gun batteries at Fort Monroe


2018-06-01 10.26.15
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.


2018-06-01 11.16.25
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.


2018-06-01 15.31.30

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.

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!


Well, it’s done.


I’m proud and distinctly relieved to announce the publication of my book, Manufactured Gas Plant Remediation: A Case Study (2018, CRC Press).  Like any proud parent, I can’t fight the urge to talk about it.


So, here’s a quick introduction to what it is about. The ‘case study’ in the title refers to the entire state of Massachusetts, since this is the first state-level overview of the gas industry.

Northampton gasworks
A gasholder in Northampton, Massachusetts, one of four surviving in the state out of what were once hundreds.


‘Manufactured gas’ refers to several types of gas made from coal or oil during the 19th and early 20th centuries, and which was used much as we use natural gas in the present day. The term ‘natural gas’ was actually coined to distinguish gas naturally present in coal beds or oil reservoirs from gas made out of coal. Manufactured gas lit the foggy streets of Victorian England (some parts of Boston and London still have gas street lights). It also lit houses, heated uncounted numbers of kitchen stoves, and fueled innumerable industries. By the early 1900s, most cities and large towns had at least one gasworks; Massachusetts alone had roughly 100 manufactured gas plants (“MGPs”) and the second largest manufactured gas industry in the country, second only to New York).


On a larger scale, the gas industry also:


  • Played a crucial role in the development of urban areas and industries during the 19th and early 20th Centuries, since many industries sought to locate in communities where gas service was available. Where this wasn’t possible, many industrial plants would start their own private gas plants, some of which fell into disuse and were forgotten, while some expanded to serve the neighboring mill towns and in the fullness of time grew into utility plants themselves.


  • Became the first major example of the modern concept of a public utility, together with all the government regulations that went with it.


  • Launched the modern organic chemical industry, with coal tar derivatives becoming feedstocks for manufacturing aniline dyes, ammonium sulfate fertilizers, creosote, laboratory reagents, explosives, plastics and disinfectants, most notably carbolic soap (familiar to anyone who’s seen A Christmas Story as the foul-tasting red soap). Modern organic chemistry exists largely because of the numerous byproducts the manufactured gas industry provided.


The first half of the book reconstructs the history of the gas industry from its origins in the early 19th century through the general changeover to natural gas in the middle of the 20th century, including discussions of gas-making processes, equipment, business practices, and important persons. Some of this information is specific to Massachusetts, but the discussion of gasmaking technology is universal to the gas industry.



1915-Fall River-Chas St-Panorama-NEAGE copy
A panoramic photograph of the a gasworks in Fall River, Massachusetts, from 1915


A waterfront view of the New England Gas & Coke coking plant in Everett, Massachusetts, from 1899. At the time, this was the largest modern coking plant in the world, and would supply much of metropolitan Boston’s gas supply until the 1950s.

The second half of the book deals with the ‘dark side’ of this industry, namely its troublesome environmental legacy. Due to the toxicity of many gasmaking byproducts such as coal tar, sites contaminated due to gasworks operations can pose a risk to public health. The assessment, remediation, and redevelopment of coal tar sites pose a significant technical and financial challenge. This part of the book includes information on the chemical composition, origins, and hazards posed by gasworks wastes including coal tar and cyanide wastes, as well as on regulatory issues, assessment and remediation strategies, and other useful topics.

An example of buried materials encountered at a former gasworks

My coauthor, Allen W. Hatheway (one of the preeminent experts on MGPs and coal tar sites, and author of several other publications), and I started the research and writing process in March 2012. At the beginning our goal was simple—to compile an inventory of all of the former manufactured gas plants in Massachusetts. As we continued with our research, however, (to paraphrase J.R.R. Tolkien) “the tale grew in the telling,” and the project eventually grew into a rather large book. This was partly because there were so many former gasworks and partly because a discussion of these sites required a vast amount of historical, technical and modern regulatory context.


I’ll be giving presentations on this topic at several conferences in 2018 and 2019, including the Society for Industrial Archaeology annual conference in Richmond, VA this June.


The book is available from Amazon or direct from the publisher.

A lot of what OTO does involves helping clients manage risks. Sometimes we do this in a reactive mode– digging up leaking gasoline tanks, capping abandoned landfills, and otherwise resolving problems that already exist. The proactive side is less obvious and dramatic (ok, and maybe a little less fun), and consists mostly of identifying potential hazards, planning how to deal with them, and helping train staff in how to respond.

Multiple Planning Requirements

There is a surprisingly large amount of this work, because many federal environmental laws and regulations include emergency planning requirements.

For example:

  • RCRA Contingency Plan for hazardous waste Generators and Treatment, Storage and Disposal Facilities (40 CFR 262.34, 264.52, 265.52, and 279.52);
  • Spill Prevention, Control, and Countermeasures plans under the Oil Pollution Act (40 CFR 112)
  • Facility Response Plans under the Oil Pollution Act (40 CFR 112.20 and 112.21); (with review and approval from EPA, Coast Guard, DOT and Department of the Interior regulators as appropriate)
  • Clean Air Act Risk Management Plan( 40 CFR part 68)
  • DOT Facility Response Plan (49 CFR part 194);
  • OSHA Emergency Action Plan (29 CFR 1910.38[a])
  • OSHA Hazwoper (29 CFR 1910.120)
  • OSHA Process Safety Management (29CFR 1910.119);


Combining Plans

Wouldn’t it be nice if you could somehow combine all of these into one plan?

Well, as it happens, you can.  This isn’t really a new thing—EPA’s guidance for “integrated contingency plans,’ sometimes referred to as the “One Plan” concept, was published in the Federal Register in June 1996 (61 FR 28641, June 5, 1996 and 40 CFR 265.54), and EPA Region 1 and the Massachusetts Office of Technical Assistance produced a demonstration model plan several years ago. The “one plan” option provides a means to combine numerous contingency plans into one living document that can address multiple overlapping (or we could say ‘redundant’) requirements. It can’t cover all of them, but it can usually cover the ones listed above.

When you consider how much of the required content of each kind of plan listed above overlaps, combining them makes a great deal of sense. At bottom, a good plan consists of four components:

  1. A description of the location/situation and risks including information such as: standard precautions; potential hazards; potential receptors; an analysis of what could go wrong; and what would happen as a result (e.g. an oil slick on a river upstream of a drinking water intake, or an anhydrous ammonia cloud over an urban area). The degree of analysis is the major variable among the various plan types, for example a SPCC or FRP requires evaluation of potential releases to water bodies, whereas the RMP is concerned principally with releases of airborne vapors or gases.
  1. Emergency contact information for facility and corporate staff, emergency response personnel, regulators, and emergency management agencies such as the Coast Guard or the Local Emergency Planning Committee;
  1. Written procedures for what facility staff should do in the event of an emergency, and
  1. Documentation of relevant things such as changes to the facility, inventories of available equipment, updates to the plan, and staff training. After all, the best plan in the world doesn’t mean much if it’s not documented.

For example….

Consider, for example, a commercial dairy processing facility located along a river—ok, milk sounds innocuous, but it’s probably more complicated than that. Animal fats can be as destructive to aquatic life as heavy fuel oils- one of the major effects of any sort of oil or fat is a huge increase in chemical and biochemical oxygen demand (COD and BOD) which depletes the oxygen level in the water to a level that fish and other critters can’t survive. Animal fats are therefore covered under the Oil Pollution Act, so a SPCC is required. It could also be the case (as it often is), that the facility has a massive refrigeration plant using anhydrous ammonia, which triggers the Clean Air Act’s Risk Management Plan and OSHA Process Safety, RCRA generator status for various hazardous wastes, etc. Then let’s assume EPA thinks the facility could cause ‘substantial harm’ to the river in the event something goes wrong, and requires a Facility Response Plan (an “FRP”) on top of the SPCC.

That’s five planning requirements right there, but at bottom most of them are going to deal with the same regulated materials, the same staff, and the same emergency response procedures, so having one well-maintained and drilled plan instead of five makes complete sense. It’s also far easier to keep one plan up to date than five, particularly when that means documenting inspections, staff training (and for some plans, such as Facility Response Plans, actual drills).

Train Like It’s For Real


Of course, having a plan on paper is only the first part, since if it only exists on paper even the best and most comprehensive plan won’t do any good without training and practice. At our recent in-house OSHA refresher training, OTO had a guest speaker who had been an OSHA inspector for 37 years.  He presented us with a number of case studies for industrial accidents, and one recurring theme was emergency action plans that essentially existed only on paper, and provided no value at all when an actual emergency occurred, since staff couldn’t implement a plan they hadn’t been trained on.

Staff need to be trained, equipment bought and maintained, and procedures practiced both in the field and as tabletop exercises. Effective plans represent ongoing commitments, and require inspections, training and documentation. This of course means money, in terms of staff time, hiring an engineering consultant to assist in developing plans, and sometimes hard construction costs, such as upgrading secondary containment for tanks, modifying stormwater systems to reduce potential spill exposures or modernizing HVAC systems to keep pace with vapors or fumes. Many plans, such as the SPCC, require the party responsible for the facility to certify that they are committing the necessary resources to make the plan workable. Good plans are also ‘living’ documents, which means that if you change your operation, say by adding another 20,000 gallon aboveground storage tank, you would need to change your plan, and if one part of your plan turns out not to work, you update your plan.

While it’s always good to be the “man with a plan”, sometimes all you need is one plan.





With all the hubbub in Washington DC lately, it’s been largely overlooked that some of the regulatory changes that started under the previous administration are only now coming to fruition.

Hazmat storage - BADHazmat storage - BEST

For example, the Hazardous Waste Generator Improvement Rule went into effect on the federal level on May 30, 2017 by amending parts of the regulations promulgated pursuant to the Resource Conservation and Recovery Act (RCRA).  RCRA was passed in 1976 and provides the national regulatory framework for solid and hazardous waste management.  These changes will become effective in Massachusetts, Connecticut, and other states with authorized hazardous waste programs as the states update their regulations.

RCRA’s ‘generator requirements,’ haven’t changed much in the last thirty years—the last major change happened in 1984. The new requirements  address the process by which a person or company who generates a waste: 1) evaluates whether or not it’s a hazardous waste or a solid waste; 2) stores the waste and prepares it for transport; and 3) maintains records of the waste’s generation and treatment, recycling or other management.

Changes in Hazardous Waste Generation

Industry has changed a great deal since RCRA went into effect. In the last ten years, the amount of hazardous waste generated in Massachusetts has dropped from 1,121,752 tons in 2001 to 39,108 tons in 2015, even as the number of registered waste generators nearly doubled (EPA Biennial Hazardous Waste Report, 2001 and 2015). Interestingly, EPA national biennial reports indicate the quantity of RCRA waste generated in Massachusetts didn’t change very much between 1985 (114,381 tons) and 2001, although there was some fluctuation as EPA added new categories of generators and wastes to RCRA. The general trend over time has led to there being fewer Large Quantity Generators, and many more Very Small Quantity Generators, so that a representative slice of the modern population of generators consists mostly of auto repair businesses, retail stores, pharmacies, and small manufacturing operations rather than the large factories and sprawling chemical plants of the 1970s and early 1980s.

This changing waste generation demographic (for lack of a better word) matters a lot, since compliance with these generator requirements generally happens at the ‘factory floor’ level, and while Kodak or Monsanto plants had chemical engineering departments to help with waste characterization and management, small shops generally don’t.

While the new rule makes over 60 changes to the RCRA regulations, its main goal is to clarify the ‘front end’ generator requirements. Some of these changes are major; others involve only routine regulatory housekeeping; and some are potential compliance pitfalls for generators.  Several of these changes dovetail with EPA’s 2015 changes to the Definition of Solid Waste, which opened up expanded opportunities for recycling certain materials rather than requiring that they be handled as solid or hazardous wastes.

Other changes in the new rule include:

  • Under some circumstances, Very Small Quantity Generators (VSQGs) will be allowed to send hazardous waste to a large quantity generator (LQG) that is under the control of the same “person” for consolidation before the waste is shipped to a RCRA-designated treatment, storage or disposal facility (TSDF). This is most likely to benefit large “chain” operations, such as retail stores, pharmacies, health care organizations with many affiliated medical practices, universities, and automotive service franchise operations.
  • One of the common problems for VSQGs or SQGs is that since generator status is determined by the quantity of wastes generated, sometimes exceptional events (such as a spill or process line change) occur which bump them up into the Large Quantity Generator category, triggering many other regulatory requirements even if the status change is only for the space of a single month. The Generator Improvement Rule would allow a VSQG or SQG to maintain its existing generator category following such events, as long as certain criteria were met..
  • The addition of an explanation of how to quantify wastes and thus determine generator status.
  • Changes to the requirements for Satellite Accumulation Areas, and for the first time, a formal definition of a Central Accumulation Area.
  • An expanded explanation of when, why and how a hazardous waste determination should be made, and what records must be kept. The final rule does not include requirements proposed in the initial rule that generators keep records of these determinations until a facility closes. The rule also recognizes that most generators base their waste determinations on knowledge of the ingredients and processes that produce a waste, rather than laboratory testing.
  • Clearer requirements for facilities that recycle hazardous waste without storing it.
  • Small Quantity Generators will have to re-notify their generator status every four years.
  • A clarification of which generator category applies if a facility generates both acute and non-acute hazardous waste (for example, a pharmacy that generates waste pharmaceuticals that are P-listed acute hazardous wastes).
  • Revising the regulations for labeling and marking of containers and tanks
  • “Conditionally Exempt Small Quantity Generators” will be renamed Very Small Quantity Generators, a term already used in many states including Massachusetts.
  • Large and Small Quantity Generators will need to provide additional information to Local Emergency Planning Committees as part of their contingency plans

The new rule also contains several expanded sections on exemptions applicable to wastes together with a distinction between “conditional requirements,” such as those which would qualify a waste for an exemption, and ‘independent requirements,” such as container labeling and spill prevention, which are mandatory across the board.

In addition, the rule makes many relatively minor changes, such as updated references to other regulations and rearranging portions of the Code of Federal Regulations text into a more intuitive order.

As with any new or revised regulation, we can expect a learning curve, particularly as implementation filters down to the state agencies. In the meantime, EPA has the Final Rule on its website, along with several fact sheets and FAQs


This picture is of a coal mine in West Virginia; the publication it was in was dated 1946, where it was presented as an example of ‘the bad old days.’ I found it in an old copy of the quarterly employee magazine of Eastern Gas and Fuel Associates, a holding company which used to have a very large vertically-integrated slice of the American coal industry– they owned coal mines, railroads, a fleet of colliers (coal transport ships), coking plants, blast furnace plants for making pig iron, and even a chain of general stores in mining towns.  They even owned Boston Consolidated Gas Company — this was back when gas was still mostly made out of coal, so for Eastern to own a major gas company made a lot of sense. When natural gas came along in the ’50s, Eastern Gas and Fuel promptly bought ownership stakes in the gas pipeline companies.

This was decades before the phrase “Safety First” was coined, but even so, the mining and transportation industries carry a lot of known hazards with them and Eastern Gas and Fuel evidently made a point of contrasting the ‘bad old days’ above with the image of a modern industrial company, for example the following page on drum handling, from another issue:


That’s still pretty good advice, even sixty years later.  So is “Don’t get hurt” for that matter, but we’re a lot more sophisticated about it lately.

Another year is drawing to a close and everyone’s thinking about the future a little more.  At OTO we spend a lot of time thinking about the future because so much of what we do boils down to risk management and contingency planning.  Whether it’s human health risk assessment for a Brownfield site, evaluating potential seismic hazards for a hospital building, or preparing a spill response plan for an oil terminal, the focus of our work is planning for a safer future.

People, particularly engineers, like to think that what we create will last and be sustainable. How long should something be expected to last, though? This is an interesting question in the United States, where there are very few structures more than a century and a half old, and almost none more than two centuries old—my own house was built in 1900 and is considered “old,” but in many parts of the United Kingdom it’s possible to attend church on Sunday in a chapel built eight centuries ago.

Most consumer electronic products made these days can generally be expected to last a few years at most (although our cars definitely last longer than they used to). For example, Apple, despite all the attention given to its trendsetting designs like the smartphone, has been buffeted by a long series of class-action lawsuits  over such problems as the batteries in third-generation iPods failing en masse after less than two years, raising questions of sustainability, planned obsolescence, and even unfair trade practices such as ‘designed to fail.’ Although the thought of replacing your cell phone every two to three years used to rankle, by now pretty much everyone seems by now to be used to the idea. I’d be happy to get four years’ use out of a cell phone, but I’m pretty sure that in ten years’ time it won’t even be able to connect with the programming languages in use in 2026 any more than it could connect to one of Alan Turing’s vacuum tube powered Bletchley Park computer prototypes from the Second World War codebreaking project. This isn’t necessarily progress, mind you—just a recognition that making things less backwards-compatible can be part of making them profitable ….but yet, vinyl records are enjoying a surge in popularity.

The design life for most civil engineering projects, such as roads, buildings, and water supply systems, is in the range of 25-50 years, based on judgments made on the expected durability of the materials used in construction, and the capacity of the design versus demand.  Take for example a town’s water and sewer system designed in 1950 based on assumptions about projected population growth. If a major new employer relocates to town and as a result the local population spikes, some of the assumptions may no longer hold, and the mains will have to be enlarged and another water source found. Where a lot of infrastructure is created at once, however, this can create major problems further down the road; most of the United States’ modern highway and major bridge infrastructure was built within a roughly 20 year period after the Second World War and is now at or well past the end of its original lifespan, and badly in need of repair or replacement, largely because reinforced concrete is not nearly as inert and eternal as was previously thought.

With environmental issues such as contaminated sites and solid waste landfills, we generally consider a timescale of about a century, which makes sense because most of the contaminants we worry about—gasoline, fuel oils, even many chlorinated compounds—will have geochemically weathered into nothing within that time… yes, someday we will be free of PCE and TCE, though lead and arsenic will always be with us, and PCBs with five or more chlorines seem to be built for the ages. Still, this timespan is reflected in some of the material choices we make. For example, a cap for a landfill or CERCLA site might be constructed of several layers of engineered but ultimately natural materials (a clay layer to prevent water infiltration, venting and drainage layers of sand and gravel, a barrier layer of cobbles to stop burrowing animals, and an outer layer of grassy turf, all graded and contoured to shed water without erosion into grassy swales) because these are durable, and even somewhat self-repairing. By contrast, a simple concrete or asphalt slab, however reinforced, will eventually crack, spall, and buckle, while its stormwater drains into  pipes that will silt up, clog, and fail.

Some man-made structures have, of course, endured for much longer. Thomas Telford’s 1,368-foot wrought-iron Menai Bridge, completed in 1826, remains in daily use.


The Pont du Garde aqueduct in southern France, built sometime between 40 and 60 AD (the reigns of the infamous Roman emperors Caligula and Nero), remains pretty much intact, but was maintained over the years, surviving the fall of Rome and the Middle Ages largely because local noblemen could rent it out as a toll bridge.


The Great Pyramid of Giza is somewhere around 4,500 years old; when Julius Caesar met Cleopatra around 48 BC, the pyramid was as ancient to Rome’s most famous dictator as Caesar is to me.

The Great Pyramid of Giza

For some projects, however, the design period starts to sound like deep time, where the project needs to remain viable not for years or decades, but for centuries or even millennia.

One of the singular engineering projects of our day is the Onkalo (Finnish for “hiding place”) nuclear waste depository under construction in a sparsely-settled area on the western coast of Finland. Construction began in the 1990s and the facility is planned to be complete in 2020, and eventually reach capacity in 2100. For a country with a small population and no conspicuous natural resource wealth like that enjoyed by oil countries, Finland is no stranger to major engineering projects, though these are generally of a decidedly pragmatic bent in contrast to the half-mile-tall Burj Khalifa superskyscraper in Dubai. The country is, after all, proudly home to one of the world’s largest commercial shipbuilding industries, producing everything from warships to cruise liners (if you ever sailed Royal Caribbean, the liner was probably built in Finland) to nuclear-powered icebreakers.  They’re also used to making things that last– for example, the old Nokia 3310 cell phone, best remembered for being almost indestructible…. in stark contrast to the third-generation iPod.

The Burj Khalifa, 2722 feet tall.

Finland gets a quarter of its electricity from nuclear power plants, and a national law requires Finland to take responsibility for the country’s own nuclear waste, rather than trying to fob it off on someone else.  This is accordingly Finland’s third such facility , and is intended to store a century’s worth of spent nuclear fuel from power plants in massive vaults carved into migmatic gneiss bedrock nearly 1,400 feet underground, with the goal of isolating the material for as long as high-level radioactive waste remains dangerous… or “only” about a hundred thousand years.

A profile of the Onkalo facility


A conceptual view of Onkalo at final build-out

The US, by contrast, simply buried the reactors used in the initial Manhattan Project research in a forty-foot deep hole in the ground on land in rural Illinois that is now a nature preserve, marked only by little more than a stone tabled inscribed “Do Not Dig,” and has been dithering over a long-term storage facility at Yucca Mountain, Nevada since 1978.

Site A/Plot M Disposal Site, Red Gate Woods, Illinois

A hundred thousand years is about ten times as long as the period since h. sapiens shook off his Paleolithic frostbite at the end of the last Ice Age, got a dog and started planting wheat, and it’s more than twenty times as long as all of our species’ recorded history. Nothing built by man has lasted even a tenth as long (Stonehenge and the Watson Brake mound complex in Louisiana area are each a comparatively trifling 5,000 years old), and probably very little that exists now will endure other than scars on the land created by mines, canals, and other geoengineering projects. If I can paraphrase the Scottish philosopher and mathematician John Playfair (who publicized the work of James Hutton, “discoverer” of geologic time), our minds grow giddy by looking so far into that abyss of time.

At that point, the matter of a design period is no longer just an engineering question, but a philosophical one too, as explored in the documentary Into Eternity, which explored the Onkalo facility. It’s no longer enough to find a geologically stable location and pick materials that could be expected to last so long. A repository like this would have to survive not just earthquakes and groundwater leaching, but also a nuclear World War Three and another ice age. Can you wager on there even being a government to maintain such a facility, when most of the world’s countries are less than 100 years old, and even the oldest continuously operating human organizations, such as the Roman Catholic Church, are “only” about 1,500 years old? Or, since financial assurance mechanisms may not survive a war, a financial collapse, or a post-apocalyptic new dark age, should the repository be able to endure without any human intervention at all?

 How do you keep someone ten thousand years from now from unwittingly opening it? No deed restriction (or any other document, for that matter) will outlast the paper or hard drive it’s recorded on unless it’s regularly recopied onto durable media, and who’s going to do that? How do you design a warning sign when the language you speak now may be as long lost as the Sumerian tongue is today, and the radiation trefoil’s meaning could be as lost to posterity as the story behind Paleolithic cave paintings, and even stone-carved hieroglyphics are weathered into illegibility after five or six millennia?  Do you even put up warning signs at all, or just bury it as deeply as possible and hide it as well as you can, hoping the whole thing will never be rediscovered?


A portion of the Lascaux Caves paintings


The Long Now Foundation was founded to explore these issues in 01996. The 0 isn’t a typo, it’s like the sixth digit on your car’s odometer; the philosophical goal of the foundation is to explore methods by which mankind and its artifacts last long enough for that 0 to tick over into 1. Its signature project is the 10,000 year clock (which is pretty much what it sounds like), which started receiving more attention after some of the foundation’s ideas were included in Neal Stephenson’s 2008 science fiction novel Anathem. If that sounds too quixotic, a similar but more pessimistic-sounding project is the Svalbard Global Seed Vault, a repository of plant seeds built deep underground in an abandoned coal mine on the sub-Arctic island of Svalbard, where seeds would hopefully survive for hundreds or thousands of years, including, natural or man-made disasters and giving mankind a shot at restarting global agriculture, if need be.

How do you design something that may well need to outlast modern civilization (or put even less optimistically, to survive modern civilization, or at least its darker impulses)?  Now THAT is engineering for the long term!

 ….At least the chlorinated hydrocarbons will be gone by then…..

I met a traveler from an antique land,

Who said—“Two vast and trunkless legs of stone

Stand in the desert. . . . Near them, on the sand,

Half sunk a shattered visage lies, whose frown,

And wrinkled lip, and sneer of cold command,

Tell that its sculptor well those passions read

Which yet survive, stamped on these lifeless things,

The hand that mocked them, and the heart that fed;

And on the pedestal, these words appear:

My name is Ozymandias, King of Kings;

Look on my Works, ye Mighty, and despair!

Nothing beside remains. Round the decay

Of that colossal Wreck, boundless and bare

The lone and level sands stretch far away.”

–Percy Bysshe Shelly, Ozymandias, 1818