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ECAR Fact Sheet for Massachusetts
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
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, as
well as used filters.
Oil,
Sludge, Sediment. Oil skimmed from an aqueous cleaning
solution must be managed in accordance with the Massachusetts used oil requirements. Waste oil and other solids
that are removed from aqueous cleaning operations should be managed
as hazardous waste. 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.
Wastewater. Nonhazardous spent aqueous cleaning solutions
can be discharged to your local sewer system or treatment plant
if they meet local discharge limits and with the appropriate permits.
The sewer authority/treatment plant may require you to treat your
cleaning solution before discharging to the sewer. Contact your
local sewer authority to find out their requirements. The discharge
of cleaning solutions to the sanitary sewer also may require a permit
from the Massachusetts Department of Environmental Protection (DEP).
Check with DEP to find out if you need a permit. Spent parts washer
cleaners, both solvents and aqueous cleaners, should never
be discharged to a septic system or storm water sewer.
Pretreatment. To meet these rules, you may need to install treatment equipment
such as an oil/water separator to prevent oil and sludge from being
discharged to the sewer. This is referred to as "pretreatment.”
The oil and sludge collected by pretreatment equipment will have
to be periodically removed and disposed of. The waste oil and other
parts of the mixture likely will need to be managed as a hazardous waste (you must make a hazardous waste
determination). In most instances, wastewater will require some form of pretreatment
prior to discharge into the sewer system.
Links
to the Regulations and Forms. Use the following links to view the regulations and permit forms pertaining
to wastewater.
Massachusetts Clean
Water Act – Located Under Water Pollution Control
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 Massachusetts Department of Environmental Protection at 617-338-2255 or 800-462-0444, or contact
the DEP Regional Service Center
near you.
- EPA Region 1 can be reached at (888) 372-7341.
- To report a spill or leak, call
the 24-Hour DEP Emergency Response hotline at 617-556-1133 or
888-304-1133.
- To report an environmental incident
or complaint, contact the Environmental
Strike Force at 617-556-1000 or 888-VIOLATE (1-888-846-5283).
Related
ECAR Fact Sheets
- Solvent Cleaning
- Wastewater
- Hazardous Waste
Other
Relevant Resources
- Massachusetts DEP
Fact Sheet – Regulation of Industrial Wastewater, Holding Tanks
and Containers
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