Pit Sludge -- Your state regulations...

[Kate Carr]

Hello all,

I'm researching an article for SSCWN's winter issue on everyone's favorite topic: Pit sludge.

I want to know what state you're in and what sort of regulations are imposed on the way you dispose of pit sludge and where you can dump it.

I know there are a few threads already started which focus on the cost of pumping your pits and disposing of the sludge. That's helpful information, too, if you'd like to include what you're spending and what sort of companies you're using to handle pit sludge removal (i.e. Environmental or haz mat specialists.)

Also -- I'm familiar with at least one state association (NY) that went through the process of testing pit sludge at self serves so as to change state regulations and how pit sludge was classified. If you can recall any other state or regional associations that have done the same, I would love to know about it.

Cheers,

 

[soapy]

The WCA years ago had California test car wash sludge. Their findings were the same as the EPA, basically it is classified as street sweepings.

 

[Washmee]

In Ohio you are required to have your sludge tested every 2 years and you must use a certified hauler. They have to take the sludge to a certified landfill where it must be placed on a containment pad to dry out before it can be buried in the landfill.

 

[robert roman]

Based on my experience, where permitted, sludge can be dewatered and then transferred to land fill or processed by licensed disposal facility.

Carwash operator’s other responsibility is to ensure what waste is disposed of does not contain substances of a type and amount that qualify as hazardous waste.

With commercial lift services, a manifest is used where the carwash operator states the waste does not contain hazards and the hauler states the waste will be properly disposed of.

However, stating that sludge does not contain hazards doesn’t mean it may not be so.

Experience shows most carwash waste contains non-hazardous material but has the potential to be hazardous depending on conditions and type of vehicles the carwash is servicing.

Nebraska Department of Environmental Quality, Florida Department of Environmental Protection and several other state agencies have found instances where carwash sump waste analyses indicated the waste did contain hazardous waste.

It makes sense when you think about. After all, most dirt, grime and contaminants that get on vehicles come from highway surface.

Read some studies of untreated highway runoff or the environmental analysis of municipal “street sweeper” sweepings. This is the same stuff that gets on vehicles.

The only way to quantify type and quantity of pollutants in sludge or effluent is to perform tests which cost between $200 and $300.

However, requirement to test or not, frequency, etc. is a grey area because environmental is most often “self-implementing” rules. This means business owner’s are responsible for understanding what is required to comply.