ECAR Fact Sheet for Michigan
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 auto 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.

Regulations

If your operation still uses a parts washing system that contains a hazardous solvent, you may be generating listed hazardous wastes. In addition, many solvents may be hazardous because of ignitability.

When using hazardous solvents in your parts washing system, you are required to keep track of the amount generated each month and dispose of them as hazardous waste. For more information on handling, storing and disposing hazardous wastes, see the Auto Recycling Plain Language Guide to Solid/Hazardous Waste Management.

The following are some of the common spent halogenated and non-halogenated solvents used in degreasing operations that are considered hazardous:

• 1,1,1-trichloroethane
• Acetone
• Benzene
• Carbon tetrachloride
• Chlorinated fluorocarbons
• Isobutanol
• Low flash point mineral spirits
• Methanol
• Methylene chloride
• Methyl ethyl ketone (MEK)
• Methyl isobutyl ketone (MIBK)
• Ortho-dichlorobenzene
• Tetracholoroethylene
• Toluene
• Trichloroflueoromethane
• Xylene

Solvent cleaning operations are a source of volatile organic compounds (VOCs) commonly found at auto recycling shops. If you use cleaning solutions containing 5 percent or more of any of the following chemicals, contact the Clean Air Assistance Program (CAAP) at (800) 662-9278:

The link to these requirements is http://www.epa.gov/ttn/atw/degrea/halopg.html. 

Links to the Regulations. Use the following links to view the regulations pertaining to solvent cleaning processes.

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

Michigan’s Natural Resources and Environmental Protection (Act 451), Part 111 regarding Hazardous Waste Management and administrative rules

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.

1. 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.
2. Are solvent storage containers and tanks properly labeled? All used solvent storage containers must be labeled "hazardous waste”, date waste first put into drums, and waste code."
3. Is the area around the solvent storage containers free of releases? Releases must be stopped and the released material cleaned up and managed properly.
4. Have the waste solvents and still bottoms from recycling units been properly characterized?
5. Is spent solvent transported to a recovery facility by a permitted and registered transporter? Check your records and verify that all shipments of spent solvent were removed from your property by a state registered transporter. Check with Michigan’s DEQ for a list of registered hazardous waste transporters.
6. Proper operating procedures of the solvent cleaner are:
   • Keep the solvent cleaner covered with a lid when not in use.
   • Clean parts and let them dry in a basket or on a rack for at least 15 seconds.
   • Close cover when allowing parts to soak.
   • Close cover after use.
   • Post operating procedures near the cleaner.

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.
• 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

1. For more information, contact MDEQ’s Environmental Assistance Center at 1-800-662-9278.
2. For reporting spills/releases or pollution emergencies, contact: 1-800-292-4706.

Related ECAR Fact Sheets

1. Hazardous Waste
2. Aqueous Cleaning

Other Relevant Resources

1. Recycled Materials Market Directory Oils and Solvents Category for list of recyclers
2. Michigan Hazardous Waste Treatment, Storage and Disposal Facility Directory

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