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ECAR Fact Sheet for Indiana
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 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.
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
New/virgin 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 (100-140¡
F) will ignite more easily than materials with a higher flash point
(140-200¡ F.)
Low-Flash Solvents (100-140¡ F) Petroleum-based
solvents with a flash point from 100-140¡ F are also referred to
as “low-flash solvents.” This type of solvent will be an ignitable
hazardous waste and, possibly, a toxic hazardous waste when disposed.
High-Flash Solvents (140-200¡ F)
Petroleum-based solvents
with a flash point from 140-200¡ F are also referred to as “high-flash
solvents.” Used
high-flash solvent is not considered to be an ignitable hazardous
waste unless it is contaminated and its flash point drops below
140¡ F. Be aware that many high-flash solvents have a flash point
that is only slightly above the 140¡ F threshold for this group
of solvents. If the facility uses pre-cleaners that contain flammable
materials, the used high-flash solvent may become a low-flash solvent
(i.e., an ignitable hazardous waste) that is subject to more stringent
regulations. In addition to potentially being an ignitable hazardous
waste, a used high-flash solvent may also be a toxic hazardous waste
if contaminated to the extent that it exhibits hazardous waste characteristics.
If a facility's pre-cleaners contain any chemicals that are on any
of the hazardous waste lists, the used solvent will automatically be a hazardous waste.
Chlorinated solvents. Using chlorinated solvents can lead
to significant compliance work for a facility. They are almost certainly
hazardous wastes. Chlorinated
solvents include the following:
- chlorobenzene (monochlorobenzene
or benzene chloride)
- trichloroethylene (trichloroethane,
ethinyl trichloride)
- chlorinated fluorocarbons
- methylene chloride (dichloromethane,
methylene dichloride, methylene bichloride)
- tetrachloroethylene (perchloroethylene, ethylene
tetrachloride, tetrachlorethylene)
- 1,1,1-trichloroethane (methyl
chloroform, chlorothene)
Listed below are the requirements
that must be followed when managing and disposing of petroleum-based
solvents.
If a facility uses petroleum-based
solvents in immersion cleaning machines (solvent sinks) or in a
remote reservoir cleaning machine (part sprayer), it must:
- keep the solvent tank covered when not in use to prevent evaporation.
- place
a drain shelf in the basin of the parts washer. This shelf allows
solvent to drain back into the solvent tank.
- drain
all parts for at least fifteen (15) seconds or until the part
is no longer dripping.
- store
used solvent to be disposed in tightly covered or closed containers.
users
of solvents with a vapor pressure at or below two millimeters of
mercury (2.0 mm Hg) must also keep a record of each purchase,
including the following information:
- Name and address of the solvent supplier
- Date of purchase, the type of solvent
- Volume of each unit
- Total volume of the solvent; and
- Vapor
pressure of the solvent
Solvents
Used by Facilities in Lake, Porter, Clark and Floyd Counties
A 1998 air regulation
restricts the type of parts washing solvent that may be used in
these four counties. Solvents must have a vapor pressure not to
exceed one millimeter of mercury (1.0 mm Hg). This restriction applies
when solvent is sold to an individual or business in amounts greater
than five (5) gallons during any seven (7) consecutive business
days. Some vendors sell solvents that meet the new vapor pressure
limit. Check the MSDS to ensure that the solvent meets this vapor
pressure limit.
If a facility is currently
using a solvent of this type, the only additional requirement is
to keep records of the purchases. End users of these lower vapor
pressure solvents must also keep a record of each purchase, including
the following information:
- Name and address of the solvent supplier
- Date of purchase, the type of solvent
- Volume of each unit
- Total volume of the solvent; and
- Vapor pressure of the solvent
Links
to the Regulations. Use
the following links to view the regulations pertaining to solvent
cleaning processes.
Indiana Hazardous Waste Regulations (Article 3)
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 antifreeze 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.
- 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 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
- Hazardous Waste
- Aqueous Cleaning
Other
Relevant Resources
- Indiana
Auto Salvage Compliance Manual
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