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.

Yes–Facility does clean equipment, parts, tools or other items.
No–Facility does not clean equipment, parts, tools or other items.

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:

  • Water
  • Steam
  • Surfactants
  • Chemical solvents
  • Other ___________________________________

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.

Yes–Facility keeps lids of solvent cleaning equipment closed.  √
No–Facility does not keep lids of solvent cleaning equipment closed.
N/A–Facility does not conduct parts cleaning using solvent cleaning equipment.

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
  • Perchloroethylene
  • 1,1,1-Trichloroethane
  • Trichloroethylene
  • Chloroform
  • Carbon tetrachloride.

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.

Yes–Facility has submitted a notification report.  √
No–Facility has not submitted a notification report.
N/A–Facility does not use halogenated solvents in its equipment cleaning.

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.

Yes–Spent solvents are stored as described above.  √
No–Spent solvents are not stored as described above.
N/A–No solvents are used at the facility.

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.

Third party vendor–Facility uses a third party vendor. Many facilities use third party vendors providing ‘turn key’ assistance. These vendors typically provide the solvents and parts washers, collect the spent solvents, provide transportation, and recycle or dispose of the waste.  √
Off-site disposal–Facility determines spent solvents are a hazardous waste and manages the spent solvents according to the hazardous waste program.  √
Storm sewers or surface waters–Facility has obtained an NPDES permit to discharge nonhazardous waste to storm sewers or to surface waters.  √
Sanitary sewer–Facility has obtained approval from the POTW to discharge nonhazardous waste to sanitary sewers. Discharge may require pretreatment.  √
UIC well–Facility discharges nonhazardous waste to an underground injection control (UIC) well. The facility complies with UIC program requirements.  √
Ground–Facility discards spent solvents on the ground which may affect groundwater or may flow with storm water into storm sewers and surface waterways. Warning: This practice is unacceptable.
Other–Method of disposal is not known.
N/A–Facility does not generate spent solvents or sludge.

Source: U.S. EPA Office of Enforcement and Compliance Assurance, EPA 305-B-03-004

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