ECAR Fact Sheet for Wisconsin
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.
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
Wisconsin Department of Natural Resources (DNR) has adopted the
federal requirements regarding hazardous wastes. 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
Links
to the Regulations. Use
the following links to view the regulations pertaining to solvent
cleaning processes.
Federal
Hazardous Waste regulations Part 261 - Identification and Listing
of Hazardous Waste
Federal
Hazardous Waste regulations Part 262 - 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.
Check with DNR for a list of registered hazardous waste transporters.
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 Wisconsin's DNR Auto Salvage Sector
Resource Specialist at 715-831-3263, or contact the WDNR
Regional Office in your area. For northern Wisconsin, call
715-635-2101 or 715-365-8900; West Central Wisconsin,
call 715-839-3700; Northeast Wisconsin, call 920-492-5800; Southeast
Wisconsin, call 414-263-8500; and, for South Central Wisconsin,
call 608-275-3266.
- All
spills should be immediately reported using Wisconsin's 24-hour
toll free hotline at 800-943-0003. If you discover a discharge
through analysis of soil or water, use the Hazardous
Substance Release Fax Notification Form.
Related
ECAR Fact Sheets
- Hazardous Waste
- Aqueous Cleaning
Other
Relevant Resources
- Wisconsin's
Auto and Scrap Recycling Website
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