ECAR Fact Sheet for Colorado
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
Spent
parts-washer solvents are considered a hazardous waste if they are
an EPA-listed hazardous waste, or if they are a characteristic hazardous
waste with a flash point less than 140 degrees Fahrenheit or have
a toxic metals concentration above regulatory levels.
Under
the Colorado Department of Public Health and Environment's (CDPHE)
regulations, waste solvents must be handled as hazardous waste or
proven through laboratory testing that they are non-hazardous. Waste solvents must be stored in containers that are in good
condition and made of materials or lined with materials that are
compatible with the stored wastes. The container must always be
closed during storage, except when it is necessary to add or remove
wastes. It also cannot be opened, handled, or stored in a manner
that may cause it to rupture or leak. Containers holding hazardous
waste must be clearly marked with the words “Hazardous Waste” and
managed as such. See the ECAR Hazardous Waste fact sheet for more information.
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.
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.
Spills.When a chemical spill or release
occurs in Colorado, there are a number of reporting and notification
requirements that must be followed by the agency or individual responsible
for the spill. These requirements tend to be confusing, and regulations
often overlap.
At minimum, notify the Colorado 24-hour Emergency Spill/Release Reporting
Line at 877-518-5608 and the Local Emergency Planning Committee
at 303-273-1622, immediately or within 24-hours. Refer to the Spill Response Fact Sheet to determine your reporting requirements.
Links
to the Regulations. Use
the following links to view the regulations pertaining to solvent
cleaning processes.
Colorado
Hazardous Waste Management Requirements
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 solvent 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.
- 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 Colorado Department
of Health and Environment's technical assistance line at 303-692-3320,
or toll-free at 888-569-1831, if outside of the 303 area code.
- To report a spill or leak, at minimum, call the Colorado
24-hour Emergency Spill/Release Reporting Line at 877-518-5608
and the Local Emergency Planning Committee at 303-273-1622, immediately
or within 24-hours. Refer to the Spill
Response Fact Sheet
to determine your reporting requirements.
- To report an environmental incident or complaint, contact
the nearest regional office.
Related
ECAR Fact Sheets
- Hazardous Waste
- Aqueous Cleaning
Other
Relevant Resources
- Colorado's Automotive Salvage Yard Waste Management Practices
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