Machine Shops

Metal filings, dust, and paint chips may be generated from grinding, shaving, and sanding operations. Metal-containing fumes and oily mist and smoke can be generated from machining operations. If not properly controlled, these could create hazardous air quality for employees and third parties. In addition, particulates and pollutants could be carried outside, potentially impacting soils or groundwater or collecting in stormwater.

Machine shops may use or previously have used chlorinated compounds as metal working fluids or solvents. Chlorinated volatile organic compounds are mobile, migrating through uncoated concrete and traveling readily in soil and groundwater. These compounds are highly volatile and persistent in the environment. Releases of these compounds can lead to expensive cleanups and third-party claims.

Flammable and combustible liquids, including oils, gasoline, cleaners, solvents, paints, and thinner, may be stored and used in operations at machine shops and create a fire hazard. A fire can spread throughout a facility and emit toxic fumes and smoke from the burning materials or due to a mix of materials resulting from the fire. Firefighting solutions such as water and foam could create contaminated run-off that spreads to nearby storm drains or properties, resulting in environmental cleanup and tort liability.

Oil-water separators designed to separate oils from coolants may be present at these facilities and could be either in-ground or aboveground. They can develop leaks over time that allow oil or coolant to seep from the system into the surrounding environment.

Waste metal working fluids, waste oils, solvents, chips, grit, and other waste materials may be generated by machine shop operations and can be considered hazardous. Improper storage and handling of wastes can lead to releases that may cause contamination. Additionally, waste generators are responsible for determining if their wastes are hazardous and require special disposal or recycling procedures. Waste generators retain “cradle to grave” liability for their disposed of wastes, and improper characterization and disposal can result in regulatory violations and environmental liability.

Wastewater from machine shops can contain metals, oils, grease, degreasers, suspended solids, and other pollutants. Wastewater treatment systems may be present at facilities, or wastewater may be taken to a non-owned disposal site or wastewater treatment facility. Releases of insufficiently treated wastewater or spills during storage, transport, or transfer from wastewater storage areas could create environmental risks. Improper waste disposal could lead to environmental liability or legal consequences for violating regulatory requirements.

Stormwater run-off could contact chemicals, metals, wastes, or other outside storage. Trucks delivering raw materials or picking up products or wastes can leak automotive fluids on the property and collect in stormwater run-off. Suppose adequate precautions are not taken to prevent pollutants from entering stormwater. In that case, pollutants can impact soil or groundwater at a facility or neighboring properties, migrate to storm drains, and be discharged to surface waters.

Transporting waste materials from the facility by the owner or third-party carriers to disposal sites or recycling centers can lead to environmental liability while on the road and during loading and unloading operations. Spills, leaks from accidents, or improper cargo securement can lead to third-party claims and cleanup liability.