Checklists: Check Solvents: Used Solvents and Parts Cleaners Information Shop Tour Stop #1
|The following questions and guidance are taken from the
Consolidated Screening Checklist For Automotive Repair Facilities.
A ‘√’ next to a response in the guide indicates that is the preferred response in terms of environmental compliance. If you select a response without a ‘√’, you may still be in compliance; however, you should verify that you are in compliance by contacting the appropriate federal or state regulatory agency and discussing your activity with them.
EQUIPMENT CLEANING AND SPENT SOLVENTS
An automotive repair shop may clean various kinds of equipment using solvents. The types of wastes created from equipment cleaning include sludge, wastewater, and the ‘spent’ (used, ready for disposal) cleaning solvents. Auto shops must follow EPA waste management regulations for ‘waste’ or ‘spent’ solvents.To assist the shop in seeking alternative, less hazardous solvents, review EPA’s Solvents Alternative Guide (SAGE). This on-line guide provides pollution prevention information on solvent and process alternatives for parts cleaning and degreasing.
Does the facility clean equipment/parts on-site?
A typical operation found at most automotive repair facilities involves the cleaning of engine parts, tools, and other small items. The facility may use some type of solvent cleaning equipment, such as a parts washer or a dip tank.
What kind of cleaning agents does the facility use?
Various cleaning agents can be used for equipment/parts cleaning, including steam, pressurized water, surfactants (soap), and chemical solvents. If the shop uses hazardous chemical solvents, technicians should wear protective safety gear, follow good housekeeping practices, such as, keep labels clean and on the proper containers to avoid misuse and potential injury or contamination, and good ventilation. The facility uses one or more of the following cleaning agents:
Does the facility keep the lids of solvent cleaning equipment closed?Facilities should keep the lids or covers of solvent cleaning equipment (e.g., parts washers, dip tanks) closed except when actually cleaning parts or adding or removing liquid to prevent evaporation of solvents.
If halogenated solvents are used in cleaning equipment, has the facility submitted a notification report to the air permitting agency?EPA issued national emission standards for hazardous air pollutants (NESHAP) to control toxic air pollutant emissions from solvent cleaning equipment (including dip tanks and parts washers) that use any of six halogenated solvents. These halogenated solvents include:
Methylene chloride, trichloroethylene, and 1,1,1- trichloroethane are the three halogenated solvents most likely to be used in auto repair shops.Tip: The shop can tell if these chemicals are contained in the solvent by reading the label on the container or reading a Safety Data Sheet (SDS) that accompanies any hazardous material. If the facility does not have an SDS, one may be requested from its vendor.
All owners and operators of solvent cleaning equipment that use these solvents must submit an initial notification report to their state or local air quality authority. This report must include information on each solvent cleaning machine and control equipment, and the yearly estimated consumption of each halogenated solvent used. Additional NESHAP requirements depend on the type of solvent cleaning machine (e.g., batch vapor, in-line) that a shop uses. Contact your state or local air quality authority for more information.
Does the facility store solvents in labeled containers?
Stored in containers.Containers must be compatible with the substance they are storing, and have no signs of leaks or significant damage due to major dents or rust. Keep containers closed (e.g., lids are on, caps are screwed on tight) except when actually adding or removing liquid.Labeled. Label containers holding spent solvents that are hazardous and those that are transported for disposal. Note: Solvents in a parts washer do not need labels.
How does the facility manage/dispose of spent solvents?The automotive shop may use an outside vendor that undertakes the proper handling and disposal of spent solvents. If not, the automotive shop must determine if the spent solvents are hazardous. If they are, do not mix them with nonhazardous wastes such as used oils. All hazardous waste must be stored, manifested, transported and disposed of in compliance with hazardous waste requirements. Only treatment, storage, and disposal facilities should dispose of hazardous waste.
Do Not Forget the Sludge: Sludge created from parts cleaning operations may be a hazardous waste. Make a waste determination. If the sludge is determined to be a hazardous waste, it must be managed in accordance with the hazardous waste regulations.
Source: U.S. EPA Office of Enforcement and Compliance Assurance, EPA 305-B-03-004
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