ECAR Fact Sheet for Florida
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.

Regulations

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.

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 sumps).
• Wastewater, which may be contaminated with oil and/or metals such as lead and zinc.

Management and disposal options for these two wastes are discussed below.

Oil, Sludge, Sediment. Oil and solids that are removed from aqueous cleaning operations should be managed as hazardous waste unless you have performed tests that indicate they are non-hazardous. For more information, see the Auto Recycling Plain Language Guide to Solid/Hazardous Waste Management. If the wastes are non-hazardous, then you should maintain test records that support your determination.

Wastewater. Wastewater from your aqueous cleaning process is regulated in one of several different ways, depending on how it is disposed of. There are three primary options for disposing of wastewater from aqueous cleaning:

1. Haul it to an approved treatment facility. Before you haul wastewater you must perform a hazardous waste determination. This may involve getting it tested by a laboratory. If the wastewater is "hazardous" you must manage it using special procedures. For more information, see the Auto Recycling Plain Language Guide to Solid/Hazardous Waste Management. If the wastewater is non-hazardous, then you should maintain test records that support your determination.
2. Discharge it to a sanitary sewer system. Most likely, you will need to obtain a permit or written permission to discharge to your local sewer system and you must follow any local rules that apply. You will also have to follow certain federal and state rules. These rules may or may not be stated in your permit. A summary of the federal and state rules is given below.
3. Discharge it to a stream, pond, lake, wetland or other water source. This is a potential option, but one that requires a NPDES permit (National Pollutant Discharge Elimination System). If you obtain this type of permit, you will be required to frequently collect samples of your wastewater and have them analyzed at a laboratory. You will also have reporting and recordkeeping responsibilities.

Most auto recyclers use option 1 or 2. Option 1 is an economical solution when there is a sufficiently small volume of wastewater generated (see BMPs for minimizing the volume). Option 2 is viable when the facility is located in an area served by a sanitary sewer system. Before you begin to discharge industrial wastewater using option 2 you must acquire a permit or written notification from either your local sewer district or DEP. You will also have to meet certain rules found in federal and state regulations.

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 Underground Injection Control (UIC) program rules that are designed to prevent the contamination of underground drinking water supplies. For more information see the Septic Tanks and Disposal Wells Fact Sheet.

Links to the Regulations and Forms. Use the following links to view the regulations and permit forms pertaining to wastewater.

NPDES Permits

Underground Injection Control

Pretreatment Requirements for Industrial Discharges

Self-Audit Checklist

When an inspector comes to your facility, there are certain things they check 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.

1. Are the sludges generated by cleanout of 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.
2. Does your facility discharge wastewater from aqueous cleaning? Are the discharges authorized by a 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 floor drains and sinks do not discharge to the ground, a septic tank, a storm sewer or a waterway.

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.

Contacts

1. Industrial Wastewater Contacts at DEP.

Related ECAR Fact Sheets

1. Wastewater
2. Floor Drains
3. Septic Tanks and Disposal Wells

Other Relevant Resources

1. DEP Pretreatment Program

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