ECAR Fact Sheet for Virginia
Aqueous Cleaning

Regulations
Self-Audit Checklist
Best Management Practices
Contacts
Related ECAR Fact Sheets
Other Relevant Resources

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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 ECAR Hazardous Waste fact sheet or 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 three options for disposing of wastewater from aqueous cleaning:

1. Haul it to a publicly owned water treatment facility (POTW). 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.
2. Discharge it to a municipal sanitary sewer system. You will need to obtain a Virginia Pollution Abatement 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.
3. Discharge it to a stream, pond, lake, wetland or other water source. This is a potential option, but one that requires a VPDES permit (Virginia Pollutant Discharge Elimination System). If you obtain this type of permit, you will be required to frequently collect samples of your wastewater and have them analyzed at a laboratory. You will also have reporting and recordkeeping responsibilities.

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.

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, possibly 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.

Virginia Pollution Abatement (VPA) Permit

Virginia Pollutant Discharge Elimination System (VPDES) Permit

Virginia 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.

1. 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.
2. 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.
3. 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.
4. 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

1. For more information on water
2. To report a spill or leak during business hours, contact the nearest DEQ Regional Office. During nights, holidays and weekends, call the 24-hour number at 1-800-468-8892.
3. To report an environmental incident or complaint, contact the nearest DEQ Regional Office.

Related ECAR Fact Sheets

1. Solvent Cleaning
2. Wastewater
3. Floor Drains
4. Septic Tanks and Disposal Wells
5. Hazardous Waste

Other Relevant Resources

1. Aqueous Parts Cleaning for Auto Repair and Fleet Maintenance From EPA Region 9

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