IN
c
DRY CLEANING
United States Solid Waste and
Environmental Protection Emergency Response
Agency (5305W)
EPA530-K-99-005
June 1999
www.epa.gov/osw
-------
Hotline
U.S. Environmental Protection Agency
8()() 424-9346 or TDD 800 553-7672.
In the Washington, DC, area: 703 412-9810
or TDD 703 412-3323.
•<8J Printed on paper that contains at least 30 percent postconsumer fiber.
-------
Foreword 2
Frequently Asked Questions About RCRA 3
The Life Cycle of a Typical Dry Cleaning Waste 6
Requirements for Regulated Dry Cleaners 8
Reduce or Minimize the Hazardous Wastes You Generate 10
Other Environmental Laws Affecting the Dry Cleaning Industry 14
Contacts Resources 16
-------
f you are a dry cleaner, your facility probably generates some
hazardous waste. That means you must follow regulations
issued by the U.S. Environmental Protection Agency (EPA)
under a law called the Resource Conservation and Recovery Act
(RCRA). Under RCRA, you are required to follow certain practices
and procedures associated with the safe management of hazardous
waste. RCRA. in Focus provides an overview of the basic federal
regulations covering wastes that are likely to be hazardous in your
business. It also provides recycling and pollution prevention options to
help businesses decrease the amount of hazardous waste they generate.
RCRA IN FOCUS
-------
RCRA is a federal law that encourages environmentally sound methods for managing
commercial and industrial waste as well as household and municipal waste. It regulates facilities that
generate, transport, treat, store, or dispose of hazardous waste. The vast majority of dry cleaners are
considered hazardous waste generators, rather than treatment, storage, and disposal facilities
(TSDFs), which are subject to more rigorous regulations.
The term "RCRA" is often used interchangeably to refer to the law, the regulations, and EPA
policy and guidance. The law describes the waste management program mandated by Congress that
gave EPA authority to develop the RCRA program. EPA regulations carry out the Congressional
intent by providing explicit, legally enforceable requirements for waste management. EPA.guidance
documents and policy directives clarify issues related to the implementation of the regulations.
All ot the RCRA hazardous waste regulations can be found in the Code oj Federal Regulations
(CFR), Title 40, Parts 260 to 279. The CFR can be accessed at or
purchased through the U.S. Government Printing Office (GPO).
Any dry cleaner that generates waste is potentially subject to RCRA hazardous waste
requirements. "You must conduct tests required by the regulations or use your knowledge of and
familiarity with the waste you generate to determine whether it is hazardous waste (as opposed to
other types of waste). You might be subject to substantial civil and criminal penalties if you fail to
properly or completely identify hazardous waste generated by your business.
To be considered hazardous waste, a material first must be classified as a solid waste. EPA defines
solid waste as garbage, refuse, sludge, or other discarded material (including solids, semisolids,
liquids, and contained gaseous materials). If your waste is considered solid waste, you must then
determine if it is hazardous waste. Wastes are defined as hazardous by EPA if they are specifically
named on one of four lists of hazardous wastes (listed wastes) or if they exhibit one of four
characteristics (characteristic wastes). Each type of RCRA hazardous waste is given a unique
hazardous waste code using the letters D, F, K, P, or U and three digits (e.g., D001, F005, P039). See
pages 10 to 13 for additional information on dry cleaning waste codes.
Listed Wastes. Wastes are listed as hazardous because they are known to be harmful to human
health and the environment when not managed properly, regardless of their concentrations. The
lists include the following three types of waste:
• Non-Specific Source Wastes. These are material-specific wastes, such as solvents, generated
by several different industries. Waste codes range from F001 to F039. Examples include
perchloroethylene (perc), trichlorethane (TCA), and chlorofluorocarbons (CFC-113).
• Specific Source Wastes, These are wastes from specifically identified industries. Waste codes
range from K001 to K161. Dry cleaning facilities typically do not generate specific source wastes.
• Discarded Commercial Chemical Products. Off-specification products, container residuals,
spill residue runoff, or active ingredients that have spilled or are unused and that have been, or
are intended to be, discarded. Waste codes range from P001 to P205 and U001 to U411. An
example is unused perc (U210) from dry cleaning facilities.
ou may be regulat-
ed both by your
state hazardous waste
agency and EPA. RCRA
allows states to receive
legal permission, known
as authorization, to
implement the RCRA
hazardous waste pro-
gram. You must always
contact your state
authority to determine
which state require-
ments apply to your
business.
To operate a haz-
ardous waste program, a
state's regulations mast
be consistent with, and
at least as stringent as,
the federal program.
Some states adopt more
stringent requirements
for facilities handling
hazardous waste, 'which
are considered part of
the authorized program.
all the RCRA
Hotline at
800 424-9346 or TDD
800 553-7672 for addi-
tional information about
RCRA rules and regula-
tions. In the Washington,
DC, area, call 703 412-
9810 or TDD 703 412-
3323.
DRY CLEANING
-------
CRA regulates the
treatment, storage,
and disposal of hazardous
waste being generated
now and in the future.
Superfund was created to
pay for the identification,
inspection, investigation,
ranking, and cleanup of
abandoned or uncon-
trolled hazardous waste
sites that people responsi-
ble for contamination are
unable or unwilling to
dean up. Call the RCRA
Hotline for more infor-
mation.
CRA contains spe-
cial provisions for
the management of used
oil destined for recycling
or reuse. These manage-
ment standards apply to
oil refined from crude oil
or any synthetic oil that
has become contaminated
through use by chemical
or physical impurities.
Used oil that will be recy-
cled or reused is subject
to special management
standards, rather than the
hazardous waste stan-
dards, unless it is treated
as a waste (i.e., you decide
to send the used oil for
treatment and disposal
rather than recovery or
recycling).
Characteristic Wastes. Even if your waste does not appear on one of the hazardous waste lists, it still
might be regulated as hazardous waste if it exhibits one or more of the following characteristics:
• Ignitability. Ignitable wastes create fires under certain conditions or are spontaneously
combustible, and have a flash point less than 60 °C (140 °F). Examples are TCA and CFC-113,
spent filter cartridges, and distillation residues from perc recoveiy and treatment, as well as
Stoddard's solvent. The waste code for these materials is D001. Petroleum dry cleaners using
higher flash point solvents might be exempt from regulation.
• Corrosivity. Corrosive wastes are acids or bases that are capable of corroding metal containers,
such as storage tanks, drums, and barrels. Battery acid is a good example. The waste code for
these materials is D002.
• Reactivity. Reactive wastes are unstable under "normal" conditions. They can cause explosions,
toxic fumes, gases, or vapors when mixed with water. Examples include lithium-sulfur batteries
and explosives. The waste code for these materials is D003.
• Toxicity. Toxic wastes are harmful or fatal when ingested or absorbed. When toxic wastes are
disposed of on land, contaminated liquid may drain (leach) from the waste and pollute ground
water. Toxicity is defined through a laboratory procedure called the Toxicity Characteristic
Leaching Procedure (TCLP). The waste codes for these materials range from D004 to D043.
If your dry cleaning business generates hazardous waste, you must manage it according to
regulations for your specific generator type. Hazardous waste generators are divided into three
categories, according to how much they generate in a calendar month:
• Large Quantity Generators (LQGs). LQGs generate greater than or equal to 1,000 kg
(approximately 2,200 Ibs) of hazardous waste per month, or greater than 1 kg (approximately 2.2
Ibs) of acutely hazardous waste per month.
• Small Quantity Generators (SQGs), SQGs generate greater than 100 kg (approximately 220
Ibs) but less than 1,000 kg of hazardous waste per month.
• Conditionally Exempt Small Quantity Generators (CESQGs). CESQGs generate less
than or equal to 100 kg of hazardous waste per month, and less than or equal to 1 kg of acutely
hazardous waste per month.
Some states do not recognize the CESQG class. Contact your state environmental agency to find
out if the CESQG status is recognized. To find your appropriate state contact, call the RCRA
Hotline at 800 424-9346.
Under the federal RCRA requirements, your generator status might change from one month to
the next as the quantity of waste you generate changes. You must comply with whichever standard
is applicable for a given month. In many cases, small businesses that fall into different generator
categories at different times choose to always satisfy the more stringent requirements (usually state
requirements) to simplify compliance. Generators must "count" the amount of waste generated in a
calendar month, which involves adding up the total weight of all quantities of characteristic and
listed waste generated at a particular facility. Certain wastes, such as those that are reclaimed or
recycled continuously on site, are not counted under the federal regulations.
RCRA IN FOCUS
-------
The RCRA regulations contain many exclusions for wastes and waste management practices that
arc not considered to be hazardous. Several exclusions and exemptions pertain specifically to the dry
cleaning industry. Some states, however, do not recognize the federal exclusions.
As part of your solvent recovery operations, you probably generate wastewaters containing trace
amounts ot solvent. Most dry cleaners discharge this wastewater to a publicly owned treatment
works (POTWs) and, therefore, it is not considered a hazardous waste. The following table provides
a brief description of exclusions and exemptions potentially applicable to the dry cleaning industry.
Check with your implementing agency (state or EPA) for information about additional
requirements or special conditions to the exclusions and exemptions.
Domestic Sewage
Exclusion
Mixtures of domestic sewage and other wastes that pass through
a sewer system to a PO'l'W tor treatment are excluded from the
definition of solid waste. Generators are encouraged to contact
their local POTW to find out what regulations might apply.
Wastewater Treatment Unit A tank system used to store or treat wastewater as part of an
Exemption onsite wastewater treatment facility with a National Pollutant
Discharge Elimination System (NPDES) permit or subject to
pretreatment standards is exempt from the RCRA regulations.
Closed Loop Recycling
Exclusion
Spent solvents reclaimed and returned to the drycleaning
process tor reuse are excluded as long as only tank storage and
the entire process is enclosed (e.g. hard piped). Controlled
flame combustion cannot be used, and the spent solvents cannot
accumulate more than 12 months before being reclaimed.
f dry cleaning facilities
store their per-
chloroethylene (perc) in
underground storage
tanks (USTs), they are
subject to the UST reg-
ulations under RCRA.
Among the regulator}'
requirements for U'STs
are corrosion protection,
equipment for prevent-
ing spills and overfills,
and implementation of a
leak detection program
that provides monitoring
for leaks at least once
every 30 days. Dry
cleaners subject to UST
regulations should
contact the RCRA
Hotline or their state
environmental agency
for further guidance.
DRY CLEANING
-------
ou've got a large vat of used perc. ~You produce less
than 100 kg of hazardous waste per month, and you
recover it on site. This example details one typical
dry cleaning waste life cycle and illustrates the most com-
mon scenario of activities you would conduct as an envi-
ronmental manager. A CESQG recovering used perc on
site is only one possible waste life cycle at a facility. Other
•waste life cycles could be different depending on the
waste, the type of waste management units used, and the
amount of waste generated.
OFF
FOR
OR
Ensure that your ha/ardous
waste is delivered to one of
seven types of facilities to
which CESQGs may send
wastes (e.g. hazardous waste
TSDFs, certain state licensed
or permitted municipal solid
waste facilities, and recyclers).
You may also treat or dispose
of your hazardous waste on
site provided your facility
meets the same criteria for
oftsite facilities.
U.S.
OF
DARDS
Before shipping waste off
site for treatment, storage,
or disposal, package, label,
and mark waste containers
in accordance with all
applicable DOT require-
ments. For more informa-
tion, call the DOT Hotline
at 800 467-4922.
RCRA IN FOCUS
-------
IDENTIFY
By running tests or using
knowledge of the waste,
identify whether your dry
cleaning waste is hazardous.
Based on these analyses, you
determine that the appropri-
ate RCRA hazardous
codes for the perc generated
by your diy cleaning process
are and D039.
As a second step, determine
how much hazardous waste
you have produced in a cal-
endar month. You do not
need to count wastes that are
never stored or accumulated
and that are: (1) discharged
directly to a sewer where the
waste mixes with domestic
sewage, and then passes to a
POTW; or (2) recycled
directly in an onsite process.
CMI.0fl0ETHYI.ENE
Filter the used perc and return part of
the filtered perc to the charged perc
tank for reuse. Place the filter cake and
collected solids (muck) in a muck
cooker to recover additional perc,
'Vapors from the muck cooker are vent-
ed to a condenser to recover more perc.
Distill the remaining perc to remove
oils, fats, and greases and return it to
the charged solvent tank Vent the dis-
tillation column to recover even more
perc. (Check for Clean Air Act require-
ments.) Distillation residues accumu-
lated on site are sent off site for dispos-
al. CESQGs may accumulate up to
1,000 kg of non-acutely hazardous
waste for an indefinite amount of time.
DETERMINE
Based on the waste count-
ing, determine your gener-
ator status. In this example,
you have produced less
than 100 kg in the past
month, which means you
are a CESQG in this calen-
dar month. If the amount
of waste you generate fluc-
tuates from month to
month, you may wish to
satisfy the more stringent
requirements each month
to simplify compliance.
DRY CLEANING
-------
The following table presents an overview of the federal RCRA regulatory requirements for dry cleaners that are either LQGs, SQGs, or CESQGs. As noted, your state might
have different or more stringent requirements.
EPA Identification
Number
Hazardous
Identification
Used Oil Standards
Waste Counting
Accumulation Area
Other Accumulation
Areas (Time and
Quantity Limits)
Storage Unit
Requirements
Air Emissions
Preparedness and
Prevention
• Obtain an EPA identification number for each facility within your company. EPA and states use this 12-character identification number
to track hazardous waste activities.
• Obtain an EPA identification number by submitting form 8700-12 (Notification of Regulated Waste Activity), which is provided by your
state hazardous waste agency. This is a one-time notification. Contact your state regarding the need for renotification if circum-
stances at your facility change.
»Identify whether you generate hazardous waste to determine if you are subject to the RCRA hazardous waste regulations. Test pro-
cedures are described in 'Test Methods for the Evaluation of Solid Waste, Physical/Chemical Methods, SW-846" or can be per-
formed by a local laboratory,
* If you generate used oil, you are subject to a separate set of management standards from the hazardous waste management stan-
dards, if the used oil will be recycled. If the used oil is to be treated and disposed of, perform the hazardous waste identification step
listed above.
» Determine how much hazardous waste you generate to determine your generator status.
• You can accumulate waste in a "satellite accumulation area" with minimal regulatory burden. This area must be at or near the point of
generation and under the control of the operator of the process generating the waste.
* There is no time limit on accumulation in the satellite accumulation area for waste under 55 gallons.
• There is a 55-gallon accumulation limit in the satellite accumulation area. Excess waste beyond the 55-gallon limit must be moved
from the satellite accumulation area within 3 days.
• You must accumulate the waste in containers.
* Waste containers must be marked with the words "Hazardous Waste" or other words that identify their contents.
• This waste is exempt from other accumulation provisions while in the satellite accumulation area.
* If waste accumulation does not meet the requirements for satellite accumulation, it is subject to more stringent requirements. LQGs
can accumulate waste on site for up to 90 days without a permit. SQGs can accumulate waste for 180 days, or 270 days if the SQG
must transport the waste more than 200 miles to a destination facility,
• Begin counting accumulation time when waste is first generated or removed from satellite accumulation area.
» Waste must be put in an exempt unit, recycled, or sent off site within the proper time period stated above.
* If an LQG or SQG accumulates wastes beyond the allotted time period, the facility is fully subject to the requirements of a hazardous
waste storage facility unless granted an exemption. SQGs cannot accumulate more than 6,000 kg of hazardous waste at any time.
» CESQGs cannot accumulate more than 1,000 kg of hazardous waste, more than 1 kg of acutely hazardous waste, or 100 kg of spill
residue from acutely hazardous waste at any time.
• Accumulate waste only in units that are in good condition, remain closed except when adding or removing waste, are inspected at
least weekly, are compatible with the types of waste, and meet special standards for ignitable waste and incompatible waste.
• LQGs can use accumulation tanks and containers that have been assessed for integrity, have a secondary containment system, and
are inspected each operating day. SQGs can use certain accumulation tanks and containers.
* LQGs can use containment buildings as well.
• For all units, the date that the accumulation period begins must be clearly marked and visible on each container. All containers and
tanks must be clearly marked or labeled with the words "Hazardous Waste" and accumulation units must be shut down and closed
permanently in accordance with standards at the end of the unit life.
• LQGs and SQGs can treat their waste without a RCRA storage permit in accumulation units that meet standards.
• LQGs must comply with organic air emissions requirements.
• LQGs and SQGs must comply with preparedness and prevention requirements, including the following:
- An adequate internal alarm or communications system.
- A device capable of summoning emergency personnel.
-------
Contingency Plan
Personnel Training
DOT Packaging
Offsite Management
of Waste
Onsite Management
of
Manifest
Land Disposal
Restrictions
Notification
Hazardous Waste
Minimization
Biennial Report
Recordkeeping
ruiiciuiw me uunuui uquiprnwriL
- Adequate water pressure to operate fire control systems.
- Adequate testing and maintenance of all emergency systems.
- Access to communication or alarm systems during waste handling activities.
- Adequate aisle space for emergency response.
- An arrangement with local emergency response authorities.
• LOG facilities must prepare a facility contingency plan in accordance with regulations,
• The contingency plan must be designed to minimize hazards from fires, explosions, or any unplanned of hazardous waste or
constituents.
• A copy of the contingency plan must be kept on site and an additional copy must be submitted to all local emergency services
providers.
• LQGs and SQGs must have an emergency coordinator on site or on call at all times to respond to emergencies.
• Emergency response information must be posted next to the telephone,
• In the event of a fire, explosion, or release that could threaten human health outside the facility, or when a spill has reached surface
water, the emergency coordinator must notify the National Response Center at 800 424-8802.
• LQGs must have a personnel training program in accordance with regulatory standards.
- Training must instruct facility personnel about hazardous waste management procedures and emergency response.
- Training must be completed within 6 months from the applicability of requirements.
- The facility must undertake an annual review of initial training.
• SQGs must ensure that all employees are thoroughly familiar with proper waste handling and emergency procedures relevant to their
responsibilities.
• Before being transported, waste must be packaged, labeled, and marked in accordance with applicable DOT requirements. Call the
DOT hazardous materials information line at 202 366-4488 for information.
• Hazardous waste sent off site for handling may only be sent to a hazardous waste TSDF or recycling facility unless otherwise
exempt. CESQGs: See onsite management of waste below.
• CESQGs may either treat waste on site, if the generator qualifies as one of the following types of facilities, or ensure delivery of
waste to one of the following types of facilities: permitted RCRATSDF; interim status TSDF; state-authorized to handle hazardous
waste; permitted, licensed, or registered by to handle municipal solid waste according to standards; permitted, licensed, or reg-
istered by state to handle nonmunicipal waste; if managed after January 12, 1998, facility is permitted, licensed, or registered by
state to handle nonhazardous waste in accordance with standards; facility beneficially uses, reuses, or legitimately recycles or
reclaims its waste; facility treats its waste prior to beneficial use, reuse, or legitimate recycling or reclamation; or a universal waste
handler in accordance with standards.
• Hazardous waste sent off site must be accompanied by a manifest, a rnultipage form that documents the waste's progress through
treatment, storage, and disposal. It can be obtained from your state agency.
1 The manifest must have enough copies to provide the generator, each transporter, and the destination facility with one copy for their
records and a second copy to be returned to the generator after completion by the destination facility operator.
• SQGs that have a contractual agreement with a waste reclaimer that specifies the types and frequencies of shipments do not need
to manifest the wastes if they retain a copy of the agreement in their files.
• Waste must meet certain treatment standards under the LDR program. Waste must be treated to reduce the hazardous constituents
to levels set by EPA or the waste must be treated using a specified technology. All waste sent off site for treatment, storage, and
disposal must be accompanied by appropriate LDR program notifications and certifications. There are no required forms, but
these papers must indicate whether or not wastes meet treatment standards or whether the waste is excluded from the definition
of hazardous or solid waste, or is otherwise exempt,
1 To encourage generators to produce less hazardous waste, LQGs are required to have a program in place to reduce the volume and
toxicity of waste generated to the degree economically practicable, and must select a currently available treatment, storage, or dis-
posal method that minimizes present and future threats.
• LQGs and SQGs must sign a certification of hazardous waste minimization on the manifest.
• SQGs must make a goocf faith effort to minimize waste generation and to select the best available waste management method that
they can afford.
• LQGs must submit biennial reports of waste generation and management activity by March 1 of every even-numbered year. EPA,
other agencies, and the public use this information to track trends in hazardous waste management.
1 LQGs must maintain personnel training records until the facility closes.
• LQGs must keep copies of each biennial report for 3 years.
• LQGs and SQGs must keep a copy of each manifest for 3 years.
• LQGs and SQGs must keep records of test results, waste analyses, and other hazardous waste determinations for 3 years.
-------
ecycling and pollution prevention measures can significantly reduce your regulatory
burden and might save your business considerable money. This section presents infor-
mation on hazardous wastes typically generated by dry cleaning facilities and provides
suggestions for how to recycle them or implement pollution prevention activities.
Three types of dry cleaning facilities are presented: perc plants, nonperc chlorinated
solvent plants, and petroleum solvent plants. The following examples show hazardous wastes typi-
cally generated by the dry cleaning industry and provide suggestions for how to recycle, treat or dis-
pose of them.
Only the federal hazardous waste codes are provided here. \bur state might have different codes
for some waste streams. You should check with your state hazardous waste authority for additional
waste codes and requirements.
Wastes Generated
Possible RCRA
Waste Codes
Potential Recycling,
Treatment, and
Disposal Methods
F002 and D039.
• Directly reuse spent solvent without prior reclamation.
• Distill spent solvent to recover pure solvent,
• Ship spent solvent to a hazardous TSDF for recovery, treatment, and/or disposal,
Wastes Generated
Possible RCRA
Waste Codes
F002 and D039,
Potential Recycling,
Treatment, and
Disposal Methods
• Drain filter cartridges well,
• Return recovered solvent to charged solvent tanks or distillation units.
• Store spent filter cartridges and filter (muck) in containers.
• Ship filter cartridges and muck to a hazardous TSDF for treatment and/or
disposal,
Potential Pollution
Prevention Methods
• Install filter recovery units,
• Install muck cooker to recover additional solvent,
• Replace cartridge filters with spin disk filters to reduce fugitive emissions.
10
RCRA IN FOCUS
-------
Wastes Generated
Possible RCRA
Waste Codes
F002 and D039.
Potential Recycling,
Treatment, and
Disposal Methods
• Distill filtered solvent to remove oils, fats, etc,
• Accumulate and store distillation residues in closed containers,
• Ship distillation residues to a hazardous TSDF for treatment and/or disposal.
Potential Pollution
Prevention Methods
Vent still condenser offgases to a carbon adsorption unit for additional solvent recovery.
Regenerate carbon adsorber with hot air stripping rather than steam stripping.
Wastes Generated
Possible RCRA
Waste Codes
F002 and D039.
Potential Recycling,
Treatment, and
Disposal Methods
Potential Pollution
Prevention Methods
• Heat muck to recover additional solvent.
• Accumulate and store rnuck cooker residues in closed containers,
• Ship muck cooker residues to a registered hazardous waste TSDF for treatment and/or
disposal,
• Vent muck cooker condenser offgases to a carbon adsorption unit for additional solvent
recovery.
• Regenerate carbon adsorber with hot air stripping rather than steam stripping.
Wastes Generated
Possible RCRA
Waste Codes
Potential Recycling,
Treatment, and
Disposal Methods
Potential Pollution
Prevention Methods
D039and U210.
Use, reuse, or reclaim unused perc to avoid disposal,
Send unused perc to a hazardous waste TSDF for treatment and/or disposal.
Find a legitimate use for the unused perc.
Return unused perc to the distributor.
DRY CLEANING
11
-------
Wastes Generated
Possible RCRA
Waste Codes
Potential Recycling,
Treatment, and
Disposal Methods
F002, FOOS.and D001.
• Directly reuse spent solvent without prior reclamation.
• Distill spent solvent to recover pure solvent,
• Ship spent solvent to a hazardous TSDF for recovery, treatment, and/or disposal.
Wastes Generated
Possible RCRA
Waste Codes
F002, F005, and D001.
Potential Recycling,
Treatment, and
Disposal Methods
Potential Pollution
Prevention Methods
• Drain filter cartridges well,
• Return recovered solvent to charged solvent tanks or distillation units.
• Store spent filter cartridges and filter (muck) In closed containers.
• Ship spent filter cartridges and muck to a hazardous waste TSDF for treatment and/or
disposal,
• Install filter recovery units.
• Replace cartridge filters with spin disk filters to reduce fugitive emissions.
12
RCRA IN FOCUS
-------
Wastes Generated
Possible RCRA
Waste Codes
F002, F005, and D001.
Potential Recycling,
Treatment, and
Disposal Methods
Distill filtered solvent to remove oils, fats, greases, etc,
Accumulate and store distillation residues in closed containers.
Ship distillation residues to a hazardous waste TSDF for treatment and/or disposal.
Potential Pollution
Prevention Methods
Vent still condenser off gases to unvented refrigeration systems for additional solvent
recovery.
Wastes Generated
Possible RCRA
Waste Codes
Potential Recycling,
Treatment, and
Disposal Methods
Potential Pollution
Prevention Methods
D001.
Ship spent solvent to a hazardous TSDF for recovery, treatment, and/or disposal.
Use alternative petroleum solvents with a higher flash point or lower volatile organic
compounds (VOC) content.
DRY CLEANING
13
-------
o review the
RCRA regulations
referred to in this docu-
ment, consult the fol-
lowing citations in 40
CFR:
Part 260—Hazardous
waste management sys-
tem: general.
Part 261—Identification
and listing of hazardous
waste.
Part 262—Standards
applicable to generators
of hazardous waste.
Part 263—-Standards
applicable to transporters
of hazardous waste.
Part 264—Standards for
owners and operators of
hazardous waste and
specific types of haz-
ardous waste manage-
ment facilities.
Part 265—Interim status
standards for owners and
operators of TSDFs.
Part 266—Standards for
the management of spe-
cific hazardous wastes
and specific types of
hazardous waste man-
agement facilities.
continued
The Water Pollution Control Act, commonly known as the Clean Water Act (CWA), is the federal
program designed to restore and maintain the integrity of the nation's surface waters. CWA controls
direct discharges to surface waters (e.g., through a pipe) from industrial processes or storm-water sys-
tems associated with an industrial activity. It also regulates indirect discharges, or discharges to
PO'l'Ws, through a public sewer system, by requiring industrial facilities to pretreat their waste
before discharging to a public sewer. Industrial pollutants from the dry cleaning industry that might
be regulated by CWA include perc, trichloroethane, and CFC-113. A CWA provision that typically
applies to dry cleaners is the NPDES, which controls direct discharges to surface waters, and the
POTW prctrcatmcnt program.
CWA Resources:
• 40 CFR Parts 100 to 129 and 400 to 503
• Internet access:
• EPA Office of Water: 202 260-5700
• Your state water authority, regional EPA office, and local POTW
The Clean Air Act (CAA) regulates air pollution. It includes national emission standards for new
stationary sources within particular industrial categories. It also includes national emission standards
for hazardous air pollutants, which are designed to control the emissions of particular hazardous air
pollutants (I LAPs). Perc is a I LAP All dry cleaners who use perc in both transfer and dry-to-dry
machines, are required, regardless of size, to undertake a number of pollution prevention steps,
including inspecting dry cleaning equipment, keeping a log of leak detection and repairs, following
good housekeeping practices, and operating equipment according to manufacturers instructions.
You must also keep a log of the amount of perc purchased for the past 12 months.
CAA Resources:
• 40 CFR Parts 50 to 99
• Control Technology Center, Office of Air Quality, Planning and Standards, EPA, general infor-
mation: 919 541-0800; publications: 919 541-2777
• Internet access:
The Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) of
1980, commonly known as Superfund, authorizes EPA to respond to releases, or threatened releas-
es, of hazardous substances that might endanger public health, welfare, or the environment, that
might come from any source. Supertund also grants EPA the authority to force parties responsible
for environmental contamination to clean it up or to reimburse response costs incurred by EPA.
The most important part of this act applicable to diy cleaners is the hazardous substance release
reporting requirement. The person in charge at your business must report to the National Response
Center (phone: 800 424-8802) any release of a hazardous substance that exceeds a designated
"importable quantity" for that substance within a 24-hour period. Also, if you are responsible for
contamination caused by perc-containing wastewater leaking through sewer pipes, you might be
held liable under CERCLA.
Superfund Resource:
• Internet access:
14
RCRA IN FOCUS
-------
The Superfund Amendments and Reauthorization Act (SARA) of 1986 created the Emergency
Planning and Community Right-to-Know Act (EPCRA). This law was designed to improve com-
munity access to information about potential chemical hazards and to facilitate the development of
chemical emergency response plans by state and local governments. The EPCRA regulations estab-
lish several types of reporting obligations for facilities that store or manage specified chemicals. The
solvents typically used by dry cleaners (i.e., perc, trichloroethane, CFC-113, and Stoddard's solvent)
are not extremely hazardous substances. A release of perc into the environment exceeding 100
pounds within a 24-hour period, however, would require emergency response notification. Also,
many of the chemicals used by dry cleaners may be considered hazardous chemicals as defined by
the Occupational Safety and Health Act (OSHA). Contact your local OSHA office if you have ques-
tions about whether the chemicals used in your dry cleaning business are considered hazardous
under OSIIA.
EPCRA Resources:
• 40 CFR Parts 350 to 372
• The State Emergency Response Commission (contact available from RCRAI Iodine)
• Internet access: and
The Safe Drinking Water Act (SDWA) mandates that EPA establish regulations to protect human
health from contaminants present in drinking water. Under the authority of SDWA, EPA developed
national drinking water standards and created a joint federal-state system to ensure compliance with
these standards. EPA also regulates underground injection of liquid wastes under the SDWA to pro-
tect underground sources of drinking water.
SDWA Resources:
• 40 CFR Parts 141 to 148
• SDWA Hotline: 800 426-4791
• Internet access:
Part 268—Land disposal
restrictions.
Part 270—EPA adminis-
tered permit programs: the
Hazardous Waste Permit
Program.
Part 271—Requirements
for authorization of state
hazardous waste programs,
Part 272—Approved state
hazardous waste manage-
ment programs.
Part 273—Standards for
universal waste manage-
ment.
Part 279—Standards for the
management of used oil.
See the regulations at
.
The Toxic Substances Control Act (TSCA) allows EPA to collect data on chemicals to evaluate,
assess, mitigate, and control risks that might be posed by their manufacture, processing, and use.
Dry cleaning facilities might be affected by some of the TSCA requirements.
TSCA Resources:
• 40 CFR Parts 702 to 799
• TSCA Hotline: 202 554-1404
• Internet access:
or additional informa-
tion on any of these
laws, ontact the RCRA
Hotline at
800 424-9346 or
703 412-9810 in the
Washington, DC, area.
TDD (hearing impaired):
800 553-7672 or 703 412-
3323 in the Washington,
DC, area.
DRY CLEANING
15
-------
U.S. Environmental Protection
Agency
Phone: 800 424-9346
or TDD 800 553-7672
In the Washington, DC, area:
703 412-9810, or TDD 703 412-3323
Home page:
Answers questions on matters related
to RCRA solid waste, hazardous
waste, and underground storage tanks,
EPCRA, and CERCLA.
U.S. Environmental Protection
Agency
RCRA Information Center (5305W)
401M Street, SW.
Washington, DC 20460
Phone: 703 603-9230
Fax: 703 603-9234
E-mail: rcra-docket@epa.gov
Holds and provides public access to
all regulator)' materials on RCRA and
distributes technical and nontechnical
information on RCRA issues.
U.S. Environmental Protection
Agency
Small Business Ombudsman (2131)
401M Street, SW.
Washington, DC 20460
Phone: 800 368-5888
Fax: 202 401-2302
Home page:
Helps private citizens, small business-
es, and smaller communities with
questions on all program aspects with-
in EPA.
U.S. Environmental Protection
Agency
Headquarters Library
401 M Street, SW., Room 2904
Washington, DC 20460
Phone: 202 260-5921 or 5922
Fax: 202 260-6257
E-mail: library-HQ@epa.gov
Home page:
Maintains environmental reference
materials for EPA staff and the general
public, including books, journals,
abstracts, newsletters, and audiovisual
materials generated by government
agencies and the private sector. Also
provides access to online computer
service bulletin boards and CD-ROM
systems.
U.S. Environmental Protection
Agency Pollution Prevention
Clearinghouse (PPIC)
401 M Street, SW. (7409)
Washington, DC 20460
Phone: 202 260-1023
Fax: 202 260-4659
E-mail: ppic@epa.gov
Hazardous Materials Information
Phone: 800 467-4922
Provides information about DOT's
hazardous materials regulations.
Superintendent of Documents
P.O. Box 371954
Pittsburgh, PA 15250-7954
Phone: 202 512-1800
Fax: 202 512-2250
Home page:
Prints and distributes the Code of
Federal Regulations. Title 40, Parts
260 to 299, contains most of the
RCRA requirements.
Phone: 800 424-8802
In the event of a fire, explosion, or
other release of hazardous waste that
could threaten human health outside
the facility, call the NRC to report the
emergency. The NRC will evaluate
the situation and help you make
appropriate emergency decisions.
EPA Home Page
< www.epa.gov>
RC.MA Hazardous
Resources
Code of Federal Regulations
Envifosetise
(contains technical, policy, and general
information on pollution prevention
topics)
Office of Enforcement and
Compliance Assurance
(provides easy to understand compli-
ance information targeted to specific
industry sectors)
RCRA Online
(searchable database with interpretive
memos and other information written
by EPA to clarify regulations)
Fabricare Legislative and
Regulatory Education
Organization
National Clothesline
< members.aol.com/ncleci'
index.html >
(contains links to other garment care
websites, including 19 relevant orga-
nizations)
Neighborhood Cleaners
Association International and the
New York School of Drycleaning
-------
International Fabricate Institute
12251 Tech Road
Silver Spring, M.D 20904
Phone: 301 622-1900
Fax: 301 236-9320
Home page:
Call the RCRA Hotline (800 424-
9346} to order any of the following
documents:
Understanding the Hazardous Waste
Rules: A Handbook for Small Businesses,
1996 Update (EPA530-K-95-001) pro-
vides an overview to help small busi-
ness owners and operators understand
how best to comply with federal haz-
ardous waste management regula-
tions. This booklet defines the three
categories of hazardous waste genera-
tors and assists small quantity genera-
tors in determining if federal regula-
tions apply. This document explains
how to obtain an EPA identification
number, manage waste on site, and
ship waste off site.
RCRA: Reducing Risk From Waste
(EPA530-K-97-004) provides a brief
overview of the national RCRA pro-
gram and the role of the states. This
booklet defines RCRA hazardous
waste and how the RCRA. regulations
apply to generators, transporters, and
TSDFs. It focuses on hazardous waste
but also addresses municipal and
industrial nonhazardous solid waste.
It provides examples of waste and
waste treatment and disposal meth-
ods, waste minimizing tips, links to
other environmental laws related to
hazardous substances, a glossary of
terms, and a guide to the RCRA sec-
tion of the Code of Federal Regulations.
Identifying Your Waste: Tfie Starting Point
(EPA530-F-97-029) is a short
brochure that explains how to deter-
mine if you generate hazardous waste.
It explains the definition of solid
waste and describes the five ways that
wastes can be considered hazardous.
In addition, it provides information
about how to manage the various
types of waste that are generated by
small businesses.
Call the Pollution Prevention
Information Clearinghouse (202 260-
1023) to order any of the following
documents:
Design for the Environment: Garment and
Textile Care Program Fact Sheet (EPA
744-F-93-004) is a document pro-
duced by EPA's Design for the
Environment (DfE) program. The
DfE Garment and Textile Care
Project is a voluntary effort between
representatives of the garment care
industry and EPA, The goal of the
project is to evaluate, test, and pro-
mote alternative technologies, materi-
als, or processes that reduce waste and
prevent pollution. One aspect has
been encouraging "wet cleaning" and
other alternatives to traditional dry
cleaning using perc. This document
provides an up-to-date description of
the program and research efforts.
Common Questions About Dry Cleaning
(EPA 744-K-96-003) addresses some
of the potential health and environ-
mental concerns with perc, and
attempts to answer questions that
consumers have about dry cleaning.
The booklet also provides informa-
tion on alternative garment care tech-
nologies, such as wet cleaning.
Wet Cleaning (EPA 744-K-96-002)
offers a summary of the alternative
technology known as "machine wet
cleaning" and lists garment care facili-
ties nationwide that offer this service.
Plain English Guide for Perc Diy
Cleaners: A Step-by-Step Approach to
Understanding Federal Environmental
Regulations (EPA 303-B-96-002) sum-
marizes the national environmental
regulations that apply to garment care
professionals who use perc, and pro-
vides a step-by-step approach to com-
pliance.
Dry Cleaning Sector Compliance Strategy
(EPA 305-F-96-003) outlines EPA's"
strategy to provide compliance assis-
tance to the perc garment care indus-
try. It provides a background of the
industry and describes primary com-
pliance issues. It is meant to help fed-
eral, state, and local regulators under-
stand the specific compliance needs
and challenges of the garment care
industry.
Chemicals in the Environment: Perc
(EPA 747-F-94-020) explains what
perc is, how it is used, and what hap-
pens once it enters the environment.
-------
------- |