ECAR Fact Sheet for Florida
Solvent Cleaning
Regulations
Self-Audit Checklist
Best Management Practices
Contacts
Related ECAR Fact Sheets
Other Relevant Resources
BACK
to VIRTUAL
TOUR
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
Cleaning
solvents are useful, but they can cause several different types
of problems if they are not handled properly. Some solvents
can pose a fire or explosion hazard. Some can cause immediate
or long-term health effects if excessively high concentrations are
inhaled or absorbed through the skin. Some can contribute
to air pollution. And most solvents can cause environmental
problems if not properly disposed of.
The
disposal of many types of used solvents is covered under hazardous
waste rules. Your responsibilities under these rules may depend
on how much solvent you use. For many types of solvent cleaning
operations above a certain minimum size, you may also need an air
pollution control permit. This fact sheet will help you determine
what permits you will need and what practices you should follow
in order to keep your solvent cleaning operations safe and in compliance
with the rules.
Regulations
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 Stoddard
solution or mineral spirits. Aqueous cleaning (e.g., pressure washers,
enclosed spray washers, steam cleaning) is covered under a separate
fact sheet.
The
regulations applicable to your solvent cleaning operations depend
mainly on the type of solvent(s) used. Some solvents are more heavily
regulated than other solvents due to their potential to cause greater
environmental damage and/or due to employee health impacts. In general,
solvents can be placed into three categories:
- Solvents
that contain chlorine (referred to as halogenated solvents) are
the most heavily regulated. Examples of halogenated solvents include
trichlorethlyene (TCE), methylene chloride, and perchlorethylene
(PCE or PERC). To determine the type of solvent you are using,
refer to the MSDS provided with each chemical by the vendor. Any
product you use that contains compounds with "..chloro..." in
its list of ingredients is a chlorinated compound. Chlorinated
organic solvents may be included in such products as carburetor
cleaners, engine degreasers, and brake cleaners.
- Non-halogenated
solvents that have a "flash point" of less than 140oF
(e.g., mineral spirits).
- Non-halogenated
solvents that have a "flash point" of 140oF
or higher (e.g., light aliphatic naphthas or hydrotreated light
petroleum distillates).
Note:
Petroleum-based solvents are classified according to their flash
point. The term "flash point" refers to the temperature
at which a material could ignite if exposed to a spark. Materials
with a low flash point (100-140oF) will ignite more easily
than materials with a higher flash point (140-200oF.)
The hazardous waste rules also use the 140oF cutoff point.
Spent solvents with a flash point less than 140oF are
a hazardous waste.
Spent
halogenated and low flash point solvents are automatically hazardous
wastes because they are toxic and/or ignitable. Non-halogenated
solvents with a flash point of 140oF or higher are notnecessarily
hazardous. However, users of these solvents must be cautious. Most
of these solvents have a flash point just above 140oF.
If the solvent becomes contaminated during use with a low flash
point liquid, then the mixture may be hazardous. Also, metals such
as lead may accumulate in the solvent during use causing the solvent
to be a hazardous waste when it is removed from service. For non-halogenated,
high flash point solvents, you can either assume they are hazardous
or conduct a hazardous waste determination to find out their regulatory
status. Hazardous wastes must be handled, stored and disposed of
according to specific rules. For more information, see the Auto
Recycling Plain Language Guide to Solid/Hazardous Waste Management.
Certain
solvent cleaning operations are regulated under federal air pollution
regulations referred to as National Emission Standards for Hazardous
Air Pollutants (NESHAP) for Halogenated Solvent Cleaning. These
rules have also been adopted by the state of Florida. The regulated
processes are those that use methylene chloride, perchloroethylene,
trichoroethylene, methyl chloroform, carbon tetrachloride, or chloroform
in a concentration of greater than 5% with one of the following
cleaning methods:
- Immersion
batch cold-solvent cleaning equipment with a capacity exceeding
two gallons.
- Remote-reservoir
batch cold-solvent cleaning equipment of any volume.
- Batch
vapor cleaning equipment of any volume.
- In-line
(continuous) cold or vapor cleaning equipment of any volume.
The
rules only apply to solvent cleaning operations above a minimum
size, (e.g., open-top vapor degreasers with an open area of 10.8
square feet or more). However, local rules may vary and you should
check with DEP concerning your operations. To comply with the NESHAP
you may need to obtain a permit and install equipment that prevents
evaporative losses of solvent and/or follow certain work practices.
For more information see DEP’s
web page for halogenated solvent degreasers
and the NESHAP regulation identified below.
Waste
Management and Disposal/Recovery Options. Parts washer solvents
are considered wastes when they are removed from the washer unit,
or if they remain in an idle parts washer over 90 days after the
unit ceases operation. Unless testing proves otherwise, spent solvents
should be managed as a hazardous waste. The 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 the date on which accumulation of the
waste began.
A generator
may accumulate as much as 55 gallons of hazardous waste in containers
at or near the point of generation where wastes initially accumulate
as long as the conditions in the above paragraph are followed, with
the exception of the accumulation date. This is known as satellite
accumulation. The date must be marked on the container once the
55-gallon limit is reached and the waste must be moved to the container
storage area or off-site within three days.
A company
registered with the DEP must transport hazardous waste, including
waste solvent, sent off-site. The transporter must have a hazardous
waste ID number issued by EPA or DEP. The wastes must be sent to
a facility that is authorized to accept spent solvent. This may
include a treatment, storage, or disposal facility, a recycler,
or a boiler or industrial furnace.
Links
to the Regulations. Use the following links to view the regulations
pertaining to solvents.
Florida
Hazardous Waste Regulations
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
Florida
Solvent Metal Cleaning Air Rules (62-296.511).
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 solvent cleaning operations.
- Determine
the regulatory status of your spent solvent. Determine if
your spent solvent is a hazardous waste. This can be accomplished
by referring to the MSDS for the solvent or by testing. If it
is hazardous, verify that the hazardous waste rules for storage
and disposal/recovery are followed. You may also have reporting
and recordkeeping requirements, depending on your regulatory status
(determine
your regulatory status).
- Determine
if your solvent cleaning operations require an air permit.
Certain minimum sized halogenated solvent cleaning processes require
air permits.
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.
- 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, lids on parts washers should be kept closed to reduce
evaporative solvent loss.
- Do
not combine spent solvent with used oil. If any hazardous substance
(e.g. solvent cleaner, brake cleaner) is suspected of contaminating
a load of used oil, the transporter may refuse to pick it up,
leaving the you to deal with managing the contaminated used oil
as hazardous waste.
- Contract
with a solvent management company to supply and recycle solvent.
Contacts
- Air
Resource Management District Offices
- Small
Business Assistance Program (SBAP)
- DEP
Hazardous Waste Compliance Assistance Program: 800-741-4337.
Related
ECAR Fact Sheets
-
Hazardous Waste
Other
Relevant Resources
- DEP’s
web page for halogenated solvent degreasers.
BACK
to VIRTUAL
TOUR
|
