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ECAR Fact Sheet for New Hampshire
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.
In addition, solvent parts washers use cleaning solutions that eventually
become spent and must be disposed of.
Regulations
Spent
parts-washer solvents are considered a hazardous waste if they are
an EPA-listed hazardous waste, or if they are a characteristic hazardous
waste with a flash point less than 140 degrees Fahrenheit or have
a toxic metals concentration above regulatory levels.
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 managed as such.
See the ECAR Hazardous Waste fact
sheet for more information.
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
In
addition to the solvents used, the parts washing systems generate
sludge, which is usually hazardous because it contains toxic metals
and solvents from the parts cleaned. Store all sludges from tanks
in a closed and properly labeled (such as “WASTE SLUDGE”) container.
Rags used to wipe parts off after being washed are also hazardous
if they contain toxic metals at concentrations exceeding regulatory
limits or listed hazardous solvents. See the ECAR
Shop Towels fact sheet.
Many
parts washers use filters that must be periodically changed. You
need to determine if your used filters are hazardous by using the
same process you used to determine if your solvent is hazardous.
Links
to the Regulations. Use the following links to view the regulations
pertaining to solvent cleaning processes.
New Hampshire Hazardous Waste
Management Requirements
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 solvent 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.
- Consider
using a less hazardous solvent cleaner such as a citrus-based
cleaner.
- Carefully
review Material Safety Data Sheets (MSDS) to avoid hazardous materials
whenever possible.
- Keep
cleaning container closed when not in use to avoid evaporation,
spills, fires and explosive hazards.
- 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 New Hampshire DES Waste Management
Division at
603-271-2900.
- To
report a spill or leak during business hours, call the DES at
603-271-3899. If after hours or the weekend, call the New Hampshire
State Police Hazardous Material Response at 800-346-4009 (in-state),
or 603-271-3636 (out-of-state).
- To
report an environmental incident or complaint, contact the nearest
regional office or link to the DES Public Information
Center.
Related
ECAR Fact Sheets
- Hazardous
Waste
- Aqueous
Cleaning
Other
Relevant Resources
- DES Fact Sheet on Federal
and State Hazardous Materials and Waste
- DES Fact Sheet on Identifying
Hazardous Wastes
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