The Case of the Oily Rags
Outside of the city’s Fleet Operations maintenance bays, there is a dumpster with a nicely painted sign stating “Deposit Oily Rags Here.” As the newly appointed EH&S manager for the city, you ask the next pressing question to the maintenance supervisor, “After you put your oily rags in the dumpster, where does the dumpster go?” His response was, “they take them out to the power plant and burn them.” Two days later, while you are out at the power plant, you ask the operations manager about the burning of oily rags in the unit. He tells you that they used to do that, but now, with the newer changes in place from the EPA, they are not allowed to. So, you ask yet another obvious question, “Then why are these dumpsters of oily rags coming out here?” He was surprised that you mentioned it because he had been wondering that himself. Now he has four dumpsters on his property filled with oily rags.
- Should the oily rags stay on the power plant site?
- What responsibility does Fleet Operations have?
- How might this situation be different if the former city EH&S manager had collaborated with other city managers and employees?
- Identify the specific section of RCRA that applies to this scenario.
- Identify health and safety concerns that might occur if the oily rags were loaded into the incinerator.