ECAR Fact Sheet for Arizona
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.
In addition, solvent parts
washers use cleaning solutions that eventually become spent and
must be disposed of.
Regulations
If
your operation still uses a parts washing system that contains a
hazardous solvent, you are likely generating listed hazardous wastes.
In addition, many solvents may be hazardous because of ignitability
(low flash points).
The
Arizona Department of Environmental Quality (ADEQ) has adopted the
federal requirements regarding hazardous wastes, and has added several
more stringent state requirements. Therefore, when using hazardous
solvents in your parts washing system, you are required to either
recycle the used solvents or manage them under the state's hazardous
waste requirements. This means keeping track of the amount generated
each month and disposing of them as hazardous waste. For more information
on handling, storing and disposing hazardous wastes, see the ECAR Hazardous Waste fact sheet.
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
In addition to the solvents used, the parts washing systems generate
sludge, which is usually hazardous because it contains toxic metals
and solvents from the parts cleaned. Store all sludges from tanks
in a closed and properly labeled (such as “WASTE SLUDGE”) container.
Rags used to wipe parts off after being washed are also hazardous
if they contain toxic metals at concentrations exceeding regulatory
limits or listed hazardous solvents. See the ECAR
Shop Towels fact sheet.
Any
stored hazardous waste that is not being accumulated in a satellite
accumulation container must be labeled with the words "Hazardous
Waste." If accumulating waste in a satellite accumulation container,
the container may be labeled with its contents, such as "Waste Sludge,"
but once the container is full and moved to storage, it must be
labeled "Hazardous Waste" and the accumulation start date must appear
on the label.
Many parts washers use filters that must be periodically changed.
You need to determine if your used filters are hazardous by using
the same process you used to determine if your solvent is hazardous.
The skimmed oil may contain hazardous waste. However, you may still
be able to manage it as used oil.
Links
to the Regulations. Use
the following links to view the regulations pertaining to solvent
cleaning processes.
Hazardous Waste Management Requirements - Arizona Administrative
Code 18-8-260 through 18-8-280.
Federal
EPA 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.
- 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.
- Are
solvent storage containers and tanks properly labeled? All used antifreeze storage containers
must be labeled "hazardous waste."
- Is
the area around the solvent storage containers free of releases? Releases must be stopped and the
released material cleaned up and managed properly.
- 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.
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.
- Implement two-stage part cleaning-- use dirty
solvent first then virgin solvent for final cleaning to reduce
solvent purchases.
- 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.
- Consider using a less hazardous solvent cleaner
such as a citrus-based cleaner.
- Carefully review Material Safety Data Sheets
(MSDS) to avoid hazardous materials whenever possible.
- Keep cleaning container closed when not in use
to avoid evaporation, spills, fires and explosive hazards.
- 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 ADEQ Inspections and Compliance
Section at 602-771-4673.
- To
report a spill or leak, call the Arizona DEQ Emergency Response
number at 602-771-2330 or toll free at 800-234-5677. To report a leaking underground storage tank, call 602-771-4303.
- To
report an environmental incident or complaint, contact the nearest regional
office.
Related
ECAR Fact Sheets
- Hazardous Waste
- Aqueous Cleaning
Other
Relevant Resources
- Arizona Green Business Automotive Program
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