ECAR Fact Sheet for Connecticut
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. Degreasers used to clean metal parts may be organic solvents (chlorinated or nonchlorinated) or aqueous (water-based) cleaners. This fact sheet covers the environmental issues associated with organic or solvent cleaning methods. Aqueous cleaning (e.g., pressure washers, enclosed spray washers, steam cleaning) is covered under a separate fact sheet.

Organic solvents usually contain volatile organic compounds (VOCs), which can evaporate quickly. Many VOCs combine with combustion emissions to form ground level ozone, a major component of “smog.” Ozone damages lungs and degrades many materials. When solvents are released and reach water, even in very small quantities, they may render the water unfit for human consumption and uninhabitable for aquatic life. Many organic solvents are also combustible, which may pose a fire hazard.

The Connecticut Department of Environmental Protection (CT-DEP) has prepared a guidance document to help auto recyclers manage solvents. Much of that information is included in the fact sheet below. You can access the link to CT-DEP's Auto Recycling Compliance Guide under Other Relevant Resources.

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 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

The CT-DEP has adopted the federal requirements regarding hazardous solvents. Therefore, when using hazardous solvents in your parts washing system, you are required to make a hazardous waste determination establish whether or not disposal of waste solvents and parts washer solutions is subject to hazardous waste regulations. For more information on handling, storing and disposing hazardous wastes, see the ECAR Hazardous Waste fact sheet.

Any parts washer that uses VOCs at room temperature must follow these equipment

design and operating procedures:

1. The cover must be easily operated with one hand and closed whenever the parts washer is not being used for 2 minutes or more.
2. Parts must be covered during draining.
3. Waste solvent must be stored in covered containers.
4. Cleaned parts must be drained for at least 15 seconds, or until dripping ceases, whichever is longer.
5. Degreasing solvent must be sprayed as a compact fluid stream (not a fine, atomized, or shower type) and at a pressure which does not exceed 10 psi.
6. Operation must cease at the occurrence of any visible solvent leaks.
7. Post labels on or near each unit summarizing the applicable operating requirements.
8. Keep monthly records on the amount of solvent added to each unit and maintain on-site for at least three (3) years.

Sediment Management.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. Spent filters can sometimes be recycled along with used oil filters. Skimmed oil may be recycled with your used oil.

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

Connecticut's 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.

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.

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

1. For more information, contact the CT-DEP Bureau of Waste Management at 860-424-4193.
2. To report a spill or leak, immediately call the Connecticut Department of Environmental Protection, Oil and Chemical Response Division at 860-424-3338, 24 hours/day.  Should this number become unavailable for any reason, call 860-424-3333.
3. To report an environmental incident or complaint, contact the nearest regional office.

Related ECAR Fact Sheets

1. Hazardous Waste
2. Aqueous Cleaning

Other Relevant Resources

1. Connecticut DEP's Auto Recycling Compliance Guide

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