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ECAR Fact Sheet for Indiana
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.
The Indiana
Department of Environmental Management (IDEM) has prepared a guidance
document to help auto recyclers manage solvents. Much of that information
is included in this fact sheet. You can access the link to IDEM'
s Compliance Manual for Auto Salvage Facilities under Other Relevant
Resources.
Regulations
Depending upon the type
and level of contamination, a facility's used solvent may be unacceptable
for discharge to the local Publicly Owned Treatment Works (POTW)
or may be a hazardous waste. Note that if a facility wishes to discharge
its aqueous cleaning solution, the facility's drain should be connected
to a POTW. For information on discharging used solvent to a POTW,
see the ECAR Wastewater Fact Sheet.
For information on making a hazardous waste determination and managing
hazardous waste, see the ECAR Hazardous Waste Fact Sheet.
Listed below are the
requirements that a facility must follow when managing and disposing
of aqueous-based solvents:
- Make a hazardous waste determination
and manage used aqueous solutions accordingly.
- Not discharge used aqueous solution
unless it is connected to a POTW or a holding tank or unless the
facility has a National Pollutant Discharge Elimination System
(NPDES) permit. If a facility is discharging to a POTW, the facility
must ensure that the discharge meets the effluent limits set by
the POTW.
Management and
disposal options for these two wastes are discussed below, as well
as used filters.
Oil, Sludge,
Sediment. Oil skimmed from an aqueous cleaning
solution can be managed as used oil and recycled.
Most recyclers will accept skimmed oil with used motor oil as long
as it is not contaminated with solvent. Contaminated oil and other
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 ECAR
Hazardous
Waste fact sheet. If the wastes are non-hazardous, then you
should maintain test records that support your determination.
Links to
the Regulations and Forms. Use the following links to view the regulations and permit forms pertaining
to wastewater.
Industrial NPDES
Permit Application Overview
Industrial Wastewater Pretreatment
(IWP) Applications
Indiana Hazardous Waste Regulations (Article 3)
Federal Safe Drinking Water Act Requirements
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 aqueous cleaning operation.
- 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.
- 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.
- Determine
whether the aqueous cleaning solution discharge will be
accepted by the local sewage treatment plant. Obtain all required
permits or approvals prior to discharge.
- If
discharge to a sewage plant is not allowed, arrange to recycle
and reuse the solution, or properly dispose of the solution. You
may need to test the solution to determine whether it is a hazardous
waste.
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.
- Conduct
cleaning operations on a contained or indoor impervious surface.
- Do
not dispose of used cleaning solution on the ground or into a
storm drain.
Contacts
- For more information, contact the
Indiana Department of Environmental Management (IDEM) at 800-451-6027
or 317-232-8603.
- Report spills and environmental
emergencies immediately to IDEM by telephone at 1-888-233-7745.
- Submit a pollution complaint online
through the IDEM Pollution
Complaints Clearinghouse.
Related
ECAR Fact Sheets
- Solvent Cleaning
- Wastewater
- Hazardous
Waste
Other
Relevant Resources
- Indiana
Auto Salvage Program Home
- Indiana Auto Salvage
Compliance Manual
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