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ECAR Fact Sheet for Oregon
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 water-based 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.
Replacing
hazardous parts wash solvent with non-hazardous substitutes is one
pollution prevention alternative. There are many water-based degreasers
and cleaning systems on the market today. If you are considering
changing to a waterbased cleaner, you should first test the product
to determine its effectiveness for your application. Using a non-hazardous
degreaser is only beneficial if it does the job.
Water-based
parts washing alternatives include:
- Hot Soap or Jet-Spray Washers and
- Aqueous
Cleaners (Alkaline and Microbial)
Regulations
Washers.
Hot soap or jet spray washers are like “dishwashers” for parts.
They use non-toxic detergent and hot water to remove oil, grease,
and dirt. Parts are placed inside the washer and the lid is closed
during cleaning.
Sludge
from oil, grease and other contaminants will accumulate in the washer.
To extend the life of the detergent, this sludge should be cleaned
out frequently. Prior to disposal, this sludge must be determined
hazardous or non-hazardous. Hazardous sludge must be managed and
disposed of as a hazardous waste.
Land application of sludge is not recommended since even non-hazardous
sludge may contain enough oil or heavy metals to contaminate soil
or groundwater. If non-hazardous sludge is land applied, do so in
accordance with applicable regulations.
Some
hot soap washers evaporate water so that more has to be added. Others
generate wastewater that must be disposed of. Wastewater from hot
soap washers may be discharged to the city sewer, provided approval
is obtained from the local wastewater treatment authority. If wastewater
pH is above local discharge limits, simple neutralization may be
required.
Hot
soap washer wastewater should not be discharged to septic tanks.
If that is not possible, the water can be collected in a holding
tank and hauled to the nearest wastewater treatment plant (if the
water is non-hazardous and the treatment plant will accept it.)
Prior
to discharge, oil must be removed from the wastewater. You may manage
the skimmed oil with your used oil.
Aqueous
Cleaners. Unlike petroleum-based solvent cleaners, water-based
aqueous cleaners are less toxic and not ignitable. They may be discharged
to the city sewer with prior approval from the wastewater treatment
plant. Disposal of spent aqueous cleaners in a septic system is
not recommended. Spent aqueous cleaners may be hazardous because
of corrosivity or toxicity (lead and/or benzene) content from contamination
from grease and oils. If aqueous cleaners are disposed of off-site,
a hazardous waste determination
must be performed. Grease and oil from parts will accumulate in
the parts washer. This sludge should be managed as described above
for hot soap washers.
Links
to the Regulations and Forms. Use the following links to view the regulations and forms pertaining
to aqueous cleaning.
Industrial General Permit Application Form
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.
- Very heavily soiled parts should be pre-cleaned by wiping
with a rag.
- 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 Oregon Department
of Environmental Quality (DEQ) at 503-229-5696
or 800-452-4011 (toll-free in Oregon).
- To report a spill or leak, contact the Oregon Emergency Response System (OERS) at 800-452-0311.
- To report an environmental incident or complaint,
contact the nearest DEQ Regional Office.
Related
ECAR Fact Sheets
- Solvent Cleaning
- Wastewater
- Hazardous Waste
Other
Relevant Resources
- Oregon DEQ Website Frequently
Asked Wastewater Questions
- OR Vehicle Dismantlers webpage
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