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ECAR Fact Sheet for Ohio
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 can be managed as used oil and
recycled. Most recyclers will accept skimmed oil with used motor
oil as long as it is not contaminated with solvent. Contaminated
oil and other solids that are removed from aqueous cleaning operations
should be managed as hazardous waste unless you have performed tests
that indicate they are non-hazardous. For more information, see
the Auto
Recycling Plain Language Guide to Solid/Hazardous Waste Management.
If the wastes are non-hazardous, then you should maintain test records
that support your determination.
Wastewater. Wastewater from
your aqueous cleaning process is regulated in one of several different
ways, depending on how it is disposed of. There are two primary
options for disposing of wastewater from aqueous cleaning:
- Haul it to an approved treatment
facility. Before you haul wastewater you must perform a hazardous
waste determination. This may involve getting it tested by a laboratory.
If the wastewater is "hazardous" you must manage it using special
procedures. For more information, see the Auto
Recycling Plain Language Guide to Solid/Hazardous Waste Management.
If the wastewater is non-hazardous, then you should maintain test
records that support your determination.
- Discharge it to a municipal sanitary
sewer system. You will need to obtain a permit or written permission
to discharge to your local sewer system and you must follow any
local rules that apply. You will also have to follow certain federal
and state rules. These rules may or may not be stated in your
permit. A summary of the federal and state rules is given below.
Option 1 is an economical solution
when there is a sufficiently small volume of wastewater generated
(see BMPs for minimizing the volume). Option 2 is viable when the
facility is located in an area served by a municipal sanitary sewer
system. Before you begin to discharge industrial wastewater using
option 2 you must acquire a permit or written notification from
your local sewer treatment agency. You will also have to meet certain
rules found in federal and state regulations.
It is important to note that discharging
industrial wastewater to a septic tank is not a viable option. Septic
tank systems, wells, drain fields, cesspools and similar disposal
sites are regulated by federal and state rules that are designed
to prevent the contamination of underground drinking water supplies.
For more information see the ECAR Septic
Tanks and Disposal Wells
Fact Sheet.
Used Filters. Some metal casing
filters may be recycled along with spent engine oil filters with
the permission of the recycler. Contact your oil recycler to determine
if they will take your filters. Plastic and cloth filters should
not be recycled with used oil filters. These filters should be managed
as hazardous
waste and disposed of by
a licensed waste disposal company.
Links to the Regulations and Forms.
Use the following links to view the regulations and permit forms
pertaining to wastewater.
Federal
EPA Standards Applicable to Generators of Hazardous Waste
Ohio
Hazardous Waste Management Standards
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 information about water discharge
permits, contact the Division of Surface Water at 614-644-2034.
- To report a spill/release or other
pollution emergencies, contact the Emergency 24-hour Hotline at
1-800-282-9378.
Related
ECAR Fact Sheets
- Solvent
Cleaning
- Wastewater
- Floor
Drains
- Septic
Tanks and Disposal Wells
Other
Relevant Resources
- Environmental Compliance Guide for Vehicle Salvage Yards
- Aqueous
Parts Cleaning for Auto Repair and Fleet Maintenance – From EPA Region 9
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