Air and Water Quality ENVE 649 1 Consider

Air and Water Quality ENVE 649 1

Consider a parts cleaner that uses a solvent. You’ll see these in many mechanic shops and other industrial operations. A sludge of grease, dirt, and metal fragments settles to the bottom. 2

Solvent Parts Washer Solvent Sludge Floor Drain 3

If you pour sludge into drums and move them to the storage yard. 4

If you remove the sludge and put it in barrels, you have generated a hazardous waste and entered the RCRA regulatory matrix. 5

If you take the barrels of sludge back into shop and pour down floor drain. Floor Drain 6

If you take the barrels and pour them down the floor drain, you almost certainly violated RCRA and perhaps other laws. 7

Now suppose the process is modified such that the sludge is directly piped to the floor drain. (Perhaps “sludge” is not a good example, imagine it is a wash water that is contaminated with solvent, dirt, metal fragments, and grease. ) 8

Solvent Parts Washer Overflow pipe Floor Drain 9

The governing laws will depend on where the floor drain leads. 10

To POTW or River Floor Drain To dry well 11

If the pipe leads to a Publicly Owned Treatment Works or the river, your operation will come under the Clean Water Act. If the pipe goes to a “dry well, ” or otherwise enters the ground water, it comes under the Safe Drinking Water Act. 12

Solvent Parts Washer Solvent evaporates Sludge, which is mostly solvent, also evaporates 13

If the solvent evaporates, it may be regulated under the Clean Air Act 14

So • This rather simple industrial process may come under several different sets of regulations. 15