ECAR Fact Sheet for Minnesota
Solvent 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 solvent cleaning methods such as parts washers containing mineral spirits. Aqueous cleaning (e.g., pressure washers, enclosed spray washers, steam cleaning) is covered under a separate fact sheet.

Used solvents are often the largest hazardous waste stream created by automotive recyclers. Used solvents can be harmful to workers and the environment because they are toxic and they emit dangerous vapors.

Regulations

If your operation still uses a parts washing system that contains a hazardous solvent, you may be generating listed hazardous wastes. In addition, many solvents may be hazardous because of ignitability.

The following are some of the common spent halogenated and non-halogenated solvents used in degreasing operations that are considered hazardous:

• 1,1,1-trichloroethane
• Acetone
• Benzene
• Carbon tetrachloride
• Chlorinated fluorocarbons
• Isobutanol
• Low flash point mineral spirits
• Methanol
• Methylene chloride
• Methyl ethyl ketone (MEK)
• Methyl isobutyl ketone (MIBK)
• Ortho-dichlorobenzene
• Tetracholoroethylene
• Toluene
• Trichloroflueoromethane
• Xylene

Determining whether your used solvents are hazardous can rely on ignitability. Both low-flash (flash point below 140°F) and high-flash (flash point 140°F or greater) solvents are available. The Material Safety Data Sheet (MSDS) gives the flash point.

If you own your unit, evaluate the solvent when it is no longer useable (becomes a waste). If you lease the unit, it is considered spent (waste) and requires evaluation when it is picked up for recycling or disposal. If you manage the spent solvent as a hazardous waste, no evaluation is needed.

Any amount of low-flash solvent must be managed as hazardous waste. Hazardous waste requirements do not require testing; however, your hauler or disposal company may require testing in order to properly characterize, ship and dispose of the waste.

If using a high-flash solvent, you can either manage the waste as hazardous or perform a test to ensure that the waste is nonhazardous. The testing company and your regulatory authority can help you determine which contaminants to test for based on the type of cleaning you do.

When using hazardous solvents in your parts washing system, you are required to keep track of the amount generated each month and dispose of them as hazardous waste. For more information on handling, storing and disposing hazardous wastes, see the Auto Recycling Plain Language Guide to Solid/Hazardous Waste Management.

Links to the Regulations. Use the following links to view the regulations pertaining to aqueous cleaning processes.

Minnesota Hazardous Waste Rules

Federal Hazardous Waste regulations Part 261 - Identification and Listing of Hazardous Waste

Federal Hazardous Waste regulations Part 262 - Standards Applicable to Generators of Hazardous Waste

Self-Audit Checklist

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 solvent cleaning operations.

1. Are spent solvents stored in drums, tanks or other containers that are in good condition? Open containers, and rusting or leaking containers cannot be used for spent solvent storage.
2. Are solvent storage containers and tanks properly labeled? All used antifreeze storage containers must be labeled "hazardous waste."
3. Is the area around the solvent storage containers free of releases? Releases must be stopped and the released material cleaned up and managed properly.
4. Is spent solvent transported to a recovery facility by a certified transporter? Check your records and verify that all shipments of spent solvent were removed from your property by a state certified transporter. Check with Michigan's DEQ for a list of registered hazardous waste transporters.

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 solvent cleaning.

• Wipe off parts with a rag or wire brush before soaking in parts washer.
• Do not clean parts unnecessarily.
• Reduce the quantity of solvent used by implementing a two-stage cleaning system. The first stage should clean the dirtiest parts. The second stage uses cleaner solvent for final cleaning and rinsing. When the cleaning solution in the second stage is no longer effective, it can then be used to replace the solvent in the first stage. Fresh solvent is then used to replace the second stage.
• Parts washers should have a recirculating feature with built-in filtration to continuously remove dirt and contaminants. This will extend the life of the solvent.
• Drip racks or trays can help increase drainage from parts to minimize solvent loss.
• When not in use, solvent streams should be turned off and lids on parts washers should be kept closed to reduce evaporative solvent loss.
• Do not dispose of used solvent on the ground or in a storm drain
• Do not combine spent solvent with used oil.
• Contract with a solvent management company to supply and recycle solvent.
• Keep accurate records of solvent, wash water, sludge processing and disposal for 3 years.

Contacts

For more information, contact the Minnesota Pollution Control Agency (MPCA) Regional Office closest to you:

1. Northeast Region (Duluth) 218-723-4660.
2. North Central Region (Brainerd) 218-828-2492.
3. Northwest Region (Detroit Lakes) 218-847-1519.
4. Southwest Region (Marshall) 507-537-7146.
5. Southeast Region (Rochester) 507-285-7343.

*Report petroleum and fuel spills of five or more gallons, and any other chemical spill (including lead-acid batteries) which may cause pollution, to the State Duty Officer at 651-649-5451 or 1-800-422-0798.

Related ECAR Fact Sheets

1. Hazardous Waste
2. Aqueous Cleaning

Other Relevant Resources

1. Solvents Audit Checklist

2. Managing Parts Washer Solvent (4 pgs)
3. Managing Aqueous Parts Washers (5 pgs)
4. Selecting and Managing Brake and Carburetor Cleaners (6 pgs)

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