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ECAR Fact Sheet for New Jersey
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
If your operation still uses a parts
washing system that contains a hazardous solvent, you are likely
generating listed hazardous wastes. In addition, many solvents may
be hazardous because of ignitability (low flash points).
The New Jersey Department of Environmental
Protection (NJDEP) has incorporated by reference, the U.S. EPA's
hazardous waste regulations at N.J.A.C. 7:26G. Therefore, when using
hazardous solvents in your parts washing system, you are required
to prove the solvents are non-hazardous or assume that they are
hazardous and manage them accordingly. This means keeping track
of the amount generated each month and disposing of them as hazardous
waste. For more information on handling, storing and disposing hazardous
wastes, see the ECAR
Hazardous Waste fact sheet.
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.
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.
The skimmed oil may contain hazardous
waste. However, you may still be able to manage it as used oil.
Links to the Regulations. Use
the following links to view the regulations pertaining to solvent
cleaning processes.
New
Jersey Hazardous Waste Regulations
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 NJDEP Bureau of Hazardous Waste Regulation at 609-984-2014.
- To report a spill or leak, or
to report an environmental incident or complaint, contact the
NJDEP 24-Hour Hotline at 1-877*-WARNDEP (1-877-927-6337).
Related
ECAR Fact Sheets
- Hazardous
Waste
- Aqueous
Cleaning
Other
Relevant Resources
- New
Jersey Division of Solid and Hazardous Waste
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