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ECAR Fact Sheet for Michigan
Aqueous Cleaning
Regulations
Self-Audit Checklist
Best Management Practices
Contacts
Related ECAR Fact Sheets
Other Relevant Resources
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The following fact sheet was prepared by the ECAR Center staff. Once prepared, each ECAR Center fact sheet undergoes a review process with the applicable state environmental agency(ies). You can check on the status of the review process here. Please read the disclaimer on the status page. While we have tried to present a summary of the essential information on this topic, you should be aware that other items, such as local regulations, may apply to you.
What You Need to Know
Various methods are used to clean oil and grease from auto parts before sale. This fact sheet covers the environmental issues associated with aqueous cleaning methods such as enclosed spray washers, hot dip tanks, pressure washers, and steam cleaning. Solvent Cleaning (e.g., Stoddard solution, mineral spirits) is covered under a separate fact sheet.
Aqueous cleaners are one of the most popular choices for degreasing parts at automotive recyclers and are a good alternative to petroleum-based and halogenated solvents. Some of the benefits of aqueous cleaners are that:
- There is less risk of hazardous exposure for workers;
- They are not flammable or explosive;
- The oils and greases can be removed more effectively; and
- They can provide potential savings in disposal costs, since used aqueous cleaning water may be eligible for discharge into public sewer systems.
With aqueous cleaning processes there are two major environmental concerns:
- Oil, sludge, sediment and similar concentrated wastes that are removed from cleaning operations (e.g., cleanout of recycling equipment and oil water separators).
- Wastewater which may be contaminated with oil and/or metals such as lead and zinc or from cross contamination from listed solvents.
Management and disposal options for these two wastes are discussed below, as well as used recycling filters. It will be necessary to determine if oils, other solids, and used cleaners that are removed from aqueous cleaning operations are hazardous waste by either testing or knowledge. For more information, see the Auto Recycling Plain Language Guide to Solid/Hazardous Waste Management. If the wastes are non-hazardous, then manage them as liquid industrial waste and maintain characterization records that support your determination for at least 3 years.
Oil, Sludge, Sediment. Oil skimmed from an aqueous cleaning solution can be managed as used oil and recycled. Most recyclers will accept skimmed oil with used motor oil as long as it is not contaminated with solvent.
Wastewater. Disposal of wastewater from your aqueous cleaning process is regulated in one of several different ways. There are three primary options for disposing of wastewater from aqueous cleaning:
- Have it hauled to an approved treatment facility by a permitted and registered transporter. Talk to the disposal company regarding their requirements. Meet manifest and other record keeping requirements.
- Discharge it to a municipal sanitary sewer system. Contact the local sewer authority for authorization to discharge and requirements. It is recommended to get this authorization in writing.
- Obtain an NPDES permit from the MDEQ Water Bureau for any discharges to waters of the state. Examples of waters of the state include streams, rivers, lakes, ponds, marshes, waterways, wells and springs. If your floor drains lead to any water of the state, you must have a discharge permit for this activity. This may not be a cost effective disposal option.
It is important to note that discharging industrial wastewater to a septic tank is not a viable option. Septic tank systems, wells, drain fields, cesspools and similar disposal sites are regulated by federal and state rules that are designed to prevent the contamination of underground drinking water supplies. For more information see the ECAR Septic Tanks and Disposal Wells Fact Sheet.
Used Filters. Some metal casing filters may be recycled along with spent engine oil filters with the permission of the recycler. Contact your oil recycler to determine if they will take your filters. Plastic and cloth filters should not be recycled with used oil filters. Determine if these filters are a hazardous waste and manage accordingly.
Links to the Regulations and Forms. Use the following links to view the regulations and permit forms pertaining to wastewater.
Federal EPA Standards Applicable to Generators of Hazardous Waste
When an inspector comes to your facility, there are certain things he or she checks to see if you are in compliance with environmental regulations. It makes good sense for you to perform a "self-audit" and catch and correct problems before they result in penalties. Also, there are some compliance incentives associated with self-audits (see Audit Policy Page).
Use the following list to audit your aqueous cleaning operation.
- Are the sludges generated by cleanout of recycling equipment, sumps and similar devices associated with aqueous cleaning properly managed and disposed of? Perform a hazardous waste determination for these wastes. If they are found to be hazardous, you must manage them on-site according to hazardous waste rules and dispose of them at an approved facility. If not hazardous, handle as liquid industrial waste.
- Does your facility discharge wastewater from aqueous cleaning to waters of the state? Are the discharges authorized by a DEQ NPDES permit? Check all uses of water and steam. Determine where wastewater is generated and discharged. You must have a permit or written authorization for all industrial wastewater discharges. Be certain that wastewater put into floor drains and sinks do not discharge to the ground, a septic tank, a storm sewer or a waterway.
- Does the facility have authorization to discharge wastewater from aqueous cleaning to the local sewage treatment plant? Obtain all required approvals prior to discharge.
- If discharge to a sewage plant is not allowed and there isn't a DEQ permit, arrange to recycle and reuse the solution, or properly dispose of the solution. You may need to test the solution to determine whether it is a hazardous waste.
Best Management Practices (BMPs)
Most regulations tell you what you have to do to be in compliance, but they don't explain how to do it. That's where "best management practices" come into play. BMPs are proven methods that help you to get into compliance and stay there. The following BMPs are recommended for aqueous cleaning.
- Install cleaning equipment that efficiently uses water or is capable of recycling water.
- Install an on-site capture and reuse system for wastewater. These are commonly used by auto recycling facilities in association with pressure washers and enclosed spray washers.
- Remove caked-on grease and oil from parts with a scraper or knife before aqueous cleaning to reduce cleaning time and water usage.
- Conduct cleaning operations on a contained or indoor impervious surface.
- Do not dispose of used cleaning solution on the ground or into a storm drain.
- For more information, contact MDEQ's Environmental Assistance Center at 1-800-662-9278.
- For reporting spills/releases and pollution emergencies, contact: 1-800-292-4706.