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ECAR Fact Sheet for Pennsylvania
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 sometimes be managed as used
oil and recycled. Check with
your oil handler about the possibility of proper cleaning, collection
and market of oily wastewater as fuel additives. 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 ECAR Hazardous
Waste fact sheet. If the
wastes are non-hazardous, then you should maintain test records
that support your determination.
Wastewater. Nonhazardous spent
aqueous cleaning solutions can be discharged to the municipal sewer
system if they meet local discharge limits or with permission from
the local water treatment facility. The treatment facility may require
you to treat your cleaning solution before discharging to the sewer.
Contact your local facility to find out their requirements. Spent
parts washer cleaners, both solvents and aqueous cleaners, should
never be discharged to a septic system.
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.
Pretreatment. To meet these
rules, you may need to install treatment equipment such as an oil/water
separator to prevent oil and sludge from being discharged to the
sewer. This is referred to as "pretreatment." The oil and sludge
collected by pretreatment equipment will have to be periodically
removed and disposed of. The skimmed oil may be eligible for recycling
along with your used oil. However, other parts of the mixture may
need to be managed as a hazardous
waste (you must make a hazardous
waste determination). In most instances, wastewater will require
some form of pretreatment prior to discharge into the sewer system.
Links to the Regulations and Forms.
Use the following links to view the regulations and permit forms
pertaining to wastewater.
General
National Pollutant Discharge Elimination System (NPDES) Industrial
Permit
Pennsylvania
Hazardous Waste Management Requirements
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.
- 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 Pennsylvania Department of Environmental Protection Division
of Hazardous Waste Management at 717-787-6239.
- To report a spill or leak, call
1-800-541-2050.
- To report an environmental incident
or complaint, contact the nearest DEP
Regional Office.
Related
ECAR Fact Sheets
- Solvent
Cleaning
- Wastewater
- Hazardous
Waste
Other
Relevant Resources
- Illinois
EPA Fact Sheet on Managing and Reducing Parts Washer Wastes
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