&EPA
           United States
           Environmental Protection
           Agency
              Enforcement And
              Compliance Assurance
              (6602J)
EPA 305-B-96-001
August 1996
Multimedia Inspection Guidance
For Dry Cleaning Facilities
  MSfi

  III
                   LOCAL DRV CLEANING SHOP

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               NOTICE
 The  statements  in  this document are
 intended  solely  as  guidance!    This
 document is not intended, nor can it be
 relied   on,   to   create  any   rights
 enforceable by any party in litigation
 with the United States.  EPA and State
 officials  may  decide  to  follow  the
 guidance provided in this document, or
 to  act at  variance with the  guidance,
 based  on  an  analysis  of  specific  site
 circumstances.  This guidance may be
 revised without public notice to reflect
 changes in EPA's policy.

 Mention of trade names or commercial
 products in this document or.associated
references   does   not   constitute  an
endorsement or recommendation for use.

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                           TABLE OF CONTENTS
                                                                     Page
 1     Introduction	/	.......:......	';      i

 2 .    Perc Dry Cleaning Industry Overview	   3

 3     Perc Dry Cleaning Process, Equipment, and Wastes ...................   7
    ,, 3.1    Perc Storage and Delivery		,	   7
     , 3.2    Perc Dry Cleaning Processes	   7
      3.3    Machine Cleaning Steps		     7
     • 3.4    Dry Cleaning Equipment	 .  .	   9
      3.5    Perc Recovery Processes	.....'..  10
      3.6    Perc Recovery Equipment	  15
      3.7    Summary of Perc Waste Sources . .	  30

 4     EPA Air Regulations Applying to Dry Cleaners	  33
      4.1    Background	  33
      4.2    Applicability	  33
      4.3    Requirements .  , •	  35

 5     EPA Hazardous Waste Regulations Applicable to Dry Cleaners  	  47
      5.1.    Background	 ...  41
      5.2    Applicability	..:...	,  .  47
      5.3 '   General Requirements	,	 .	  50
      5.4    Waste Storage Requirements		 52
      5.5    Pre-Transport Requirements		  53
      5.6    Transporting Requirements (applicable to generators) . .	  54
      5.7    Recordkeeping Requirements  (40 CFR 262.40)	  56
      5.8    Hazardous Waste Treatment Regulations (40 CFR 265)	  56

6     EPA Wastewater Regulations Applicable to Perc Dry Cleaners	  57
      6.1    Applicability  ..  . . . ,'.;	  57
      6.2    Discharge to Septic Systems  .	:•...................  57
      6.3    Direct Discharge to Surface Waters	  57
      6.4    Indirect Discharge to POTWs	  57
      6.5  .  Other Wastewater Handling Methods	  60

7     EPA Underground Injection Control  Regulations Which Apply To Dry
      Cleaners  . ;  . . . .	  61
      7.1    Background	  61
      7.2    Applicability	  61
      7.3    Discharge, of Industrial Wastes to On-Site Disposal Systems .......;  .  61
      7.4    EPA Class V Regulations and Guidance Applicable to Dry Cleaners  ....  62
      7.5.    Inventory Requirements	  63

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                       TABLE OF CONTENTS (Continued)
8     Pollution Prevention and Waste Minimization	  65
      8.1   General Plant Management	.;.......  65
      8.2   Operation and Maintenance  Procedures	  66
    •  8.3   Equipment Modifications	:.....	  68
      8.4   Process Modifications	  68
      8.5   Alternative Cleaning Solvents 	•  . . .  .  69
      8.6   Alternative to,the Dry Cleaning Process	V 69

9     Inspection Protocol	;	• •  •	  71
      9.1   Pre-Inspection Preparation	  72
      9.2   On-Site Activities  . .  . .'	  72
      9.3   Preparation of Assessment Report .  .	 ,	  76
      9.4   Follow-Up Activities  	  77


                               LIST OF TABLES


Table 1.   Perchloroethylene Data Table	   4
Table 2.   Size Category'Determination for Applicability of Air Regulations  .	  34
Table 3.   EPA Air Requirements for Dry Cleaners	  36
Table 4.   Size Category Determination for Applicability of EPA Hazardous  Waste
          Regulations	 . . .	  48
Table 5.   EPA Hazardous Waste Requirements for Dry Cleaners	  49
                                                       \

                              LIST OF FIGURES


Figure 1.  Dry-to-dry vs.  Transfer Machines	   9
Figure 2.  Dry Cleaning Plant Process Diagram	  11
Figure 3.  Cartridge Filtration	•  •	•  17
Figure 4.  Powder Filtration	  19
Figure 5.  Distillation Unit	  22
Figure 6. ' Perc Recovery System: Refrigerated Condenser	  24
Figure 7.  Perc Recovery System: Carbon Adsorber	• •  •  26
Figure 8.  Colorimetric Detector Tube	  27
Figure 9.  Perc/Water Separator	  29
Figure 10. Hand-held Solvent Leak  Detector	  67
                                        u

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                         LIST OF APPENDICES
APPENDIX A.  MULTIMEDIA INSPECTION CHECKLIST FOR DRY
              CLEANING FACILITIES ........ ,,.....;
                                                                  Page
APPENDIX B.   MULTIMEDIA COMPLIANCE/POLLUTION
              PREVENTION ASSESSMENT REPORT FORM FOR
              DRY CLEANING FACILITIES  ........... ....... r ..... B-l

APPENDIX C.   RECOMMENDED FORMS FOR DRY CLEANERS  . , ..... '.  . . .%C-1
              1. Sample Log Sheet for Perc Purchases
              2. Monthly Machine Maintenance and Percy oroethylene Log
              3. Initial Notification Report                               .
              4. Compliance Report for Pollution Prevention
   .           5. Compliance Report for Control Requirements

APPENDIX D.   STATE REQUIREMENTS  .  . .......... .  ...... ..... : . D-l

APPENDIX E,   BIBLIOGRAPHY  . ..... .......... i ...... ....... ..... E-l
                                  iii

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                                      CHAPTER 1
                                   INTRODUCTION

Statement of Goals:
       This inspecion manual was developed to assist field personnel in State, local, and EPA
regional offices in conducting multimedia inspections of perchloroethylene (perc) dry cleaning
facilities.  Its primary goal is to enable inspectors to fulfill the traditional objective of assessing
the compliance status of individual facilities by providing specific information about the dry
cleaning process and a comprehensive summary of all EPA environmental regulations applicable
to perc dry cleaners.  However,  the  manual also focuses on the important goal of overall
improved environmental quality by approaching the inspection process with the added objectives
of providing compliance assistance to facilities and identifying pollution prevention opportunities.
        -                          -               •  •         '  '.                    j
              v                   •.       ' •           .                                ,
Section Overview:        .
       To familiarize the inspector with the dry cleaning sector, Chapter 2 first presents an
industry overview  that  describes  the chemicals and processes used  and provides  some
information on the demographics of the industry.   Chapter 3 describes dry cleaning processes
and equipment and summarizes  the various wastes that are generated.  Actual processes and
equipment will no doubt vary from plant to plant,  but this section will introduce the inspector
to the fundamental operating principles of a typical facility.
       A knowledge of the applicable EPA environmental regulations is essential to performing
a thorough inspection.  Chapters 4, 5, 6, and 7 are an interpretive guide to EPA air, hazardous
waste, wastewater, and drinking water regulations that are likely to be applicable to dry cleaners.
Specific citations to the Code of Federal Regulations  (CFR) are also provided for reference
purposes.  Chapter^ goes beyond EPA requirements and presents additional ideas on pollution
prevention and waste minimization.  Finally, Chapter  9 describes the inspection protocol and
identifies what the inspector should be evaluating.

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                                      CHAPTER 2
                   PERC DRY CLEANING INDUSTRY OVERVIEW

        The dry cleaning industry provides its customers with professional cleaning services,
• primarily for clothing. The equipment and method of cleaning are similar to the regular laundry
 process, except that  a solvent other  than water is used.  Clothes are placed into a washing
 machine, Cleaned, and then tumbled dry in a dryer. Dry cleaning is used for clothes that would
 otherwise be damaged by the regular laundry process, such as clothes made from delicate fabrics
 or clothes  made of wool,, which can not be saturated in water.

        The dry cleaning process produces toxic wastes containing varying concentrations of the
 cleaning solvent.  By far, the most common solvent used in the dry cleaning industry is liquid
 perchloroethylene (also known as perc, PCE, and tetrachlproethylene). Perc is typically recycled
 and reused repeatedly  in. a  dry cleaning system, but the recycling process produces  perc-
 contaminated hazardous solid wastes. Dry  cleaners also emit perc vapors  and produce perc-
 contaminated wastewater.  The use of  solvents other than perc, such as Stoddard solvent, is
 becoming  increasingly rare due to health, safety,  or environmental regulations associated with
 •their use.  (See Section 7.5.)                             . .
 ,    .   The almost universal popularity of perc sterns from its noD-flammability and its excellent
 cleaning properties. However, there are hazards associated with its use.  Perchloroethylene is
 a  suspected carcinogen and has been found to be moderately toxic to humans.  The toxicity can
 be quantified as an LC^ (50 percent  lethal concentration) of 18 parts per million (ppin) (in
 water) after 48 hours of exposure for daphnia magna, a sensitive water flea commonly used for
 toxicity tests.      .       • ,

        Contact  with perc vapors can irritate the eyes and throat, and  inhalation can cause
 lightheadedness and/or dizziness.: The Occupational Health and Safety Administration (OSHA)
 has set the concentration limit for the  inhalation of perc vapors in the workplace at an 8-hour
 time weighted average (TWA) of 100 ppm.  Concentrations of more than 200 ppm (but at no

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time exceeding 300 ppm) are allowed for only 5 minutes during each 3-hour period.  Direct
contact with liquid perc causes skin burns and blisters.  Liquid perc can  also be  absorbed
through the skin.  It is classified as a pollutant hi air and water regulations and its disposal is
regulated as a hazardous waste.  It is not, however, listed as an acutely hazardous waste.  Perc-
related  information is summarized below in Table 1.

                          Table 1.  Perchloroethylene Data Table             .            •
Form:
EPA Hazardous Waste # (unused perc):
EPA Hazardous WaSte # (perc-based wastes):
Fire Potential:
OSHA1 8-hr. TWA2 for inhalation:
Ecotoxcity (Daphnia. magna LC 50):
Specific Gravity:
Weight:
Chemical Formula:
Solubility in HjO:
Boiling/Condensation Point:
Melting/Freezing Point:
Colorless liquid at room temperature
U210
F002
Non-flammable
100 ppm
18 ppm in water for 48 hrs
1.62at68ฐF(20ฐC).
13.46lb/gal(1.62kg/l)
C12C:CC12
150 ppm at 77ฐF(25ฐC)
2500F(121ฐC)
-2ฐF(-19ฐC)
"Occupational Safety and Health Administration                                                .
aTime-weighted average

       The dry cleaning industry can be divided into three subsectors, according to the services
provided by the facilities.  Corn-operated dry cleaners (SIC 72151) are those that are operated
by the customer and generally do not provide accessory services such as starching and .pressing.
Coin-operated  machines are usually found hi regular laundromats.  Commercial dry cleaners
(SIC 7216) are the second, and by far the largest, category, comprising about 80 percent of the
industry. . These cleaners provide professional  dry cleaning services for retail customers.
Industrial dry cleaners (SIC 7218) are fewer hi number but are generally larger facilities that
provide bulk dry cleaning of uniforms, rags, and linens for business and industrial clients.
    'Standard industrial Classification Code, assigned by the Department of Commerce.

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          Two distinguishing'demographic features of the dry cleaning industry are critical to the
   issue of compliance with environmental regulations.  The first is that. the. dry cleaning sector is
   comprised  of a large number of facilities, many of which are small, family-run operations.
   Approximately 90 percent of these facilities employ fewer than 100 people and can be classified
   as small businesses.2 EPA'sZ>ry Cleaning Sector Compliance Strategy estimated that the actual
   number of  perc dry cleaning facilities range from 25,000 to 35,000. The number of facilities
   alone makes it difficult to ensure that each and every owner is aware of all currently applicable
   environmental regulations.  In addition, small businesses are much less likely to be members of
   such national trade organizations as International Fabricare  Institute (IFI) and  Neighborhood
   Cleaners Association.  These organizations are a traditional channel of distribution for trade-
   relevant information—owners  that are isolated from such organizations may be unaware of
   environmental regulations and compliance methods.

          Another defining characteristic. of the dry cleaning industry is the large percentage of
   owners and operators that speak a language other than English  as their first language.  About
   30 percent of operators speak Korean as their first language, whije a comparable segment speaks
   Spanish.   There  are  also smaller segments of the dry cleaning industry that are Chinese,
   Vietnamese, or French-speaking.  This multilingual aspect  of  the  dry cleaning industry also
   poses barriers to regulatory compliance. Non-English-speaking groups are also less likely to be
   members of national trade associations and often fail to receive the informatioa distributed along
   these channels.  In addition,  the literature that is received by these groups is generally in English
   and may not be understood.  To address this problem,  EPA has implemented a program to
   translate published brochures and other information about regulations into foreign languages,
   particularly Korean and Spanish.          '

          Both the  unconsolidated  nature and  multilingual aspect  of  the industry result hi
   communication barriers that must be overcome to achieve the goal of unproved environmental
   quality through compliance with environmental regulations. Both characteristics are reasons for
•    •  2As defined by the EPA Interim Policy on Compliance Incentives for Small Businesses of June 13, 1995.

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the emphasis on providing  compliance assistance during  inspections,  as  well as assessing
compliance status.                .   ,,                                   .

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                                     CHAPTER 3                                   •
         PERC DRY CLEANING PROCESS, EQUIPMENT, AND  WASTES

3.1    Perc Storage and Delivery
       Perc is delivered either in tank cars or in drums.  Drums can be stored bn-site, and the
perc pumped to the dry cleaning machines as needed.  However, in areas where delivery of perc
is frequent (weekly or monthly), there is really no need to store perc on-site at all, since it can
be pumped directly from the tank car to the dry cleaning machines.  Most machines are designed
                                       1                    %
so that the perc can be added through the button trap door,  the same opening from which the
button trap (see Section 3.5, Used Perc Filtration) can be removed for cleaning.
3.2    Perc Dry Cleaning Processes
       Professional dry cleaning services .include (1) spotting,  or treating stains with various
chemical spotting agents before washing, (2)  machine washing hi liquid perc, followed by
drying, and (3) pressing, starching, and finishing.
                           ,                                          *
       Spotting involves the use of various chemical spotting agents. The spotting process does
not ordinarily produce significant wastes, since the chemicals are sprayed onto the clothes before
they are loaded into the machine.  Unless there is a spill,  the use of these chemicals is more
likely to be subject to OSHA regulations rather than EPA regulations.  Pressing, starching, and
finishing are labor intensive but generally do riot involve the use of hazardous materials.

       The machine washing is done hi perchloroethylene.  This step  is of primary concern to
the inspector.  The processes involved are discussed in detail in the following section.

3.3    Machine Cleaning Steps
       The  machine cleaning process can.be divided  into six steps:  charging,  washing,
extraction,' transfer of clothes, drying, and aeration.

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 •  Charging. Charging of the perc involves the addition of small amounts of water and
    detergent to the perc to  aid in removal of  water-soluble  soils  and to improve the
    cleaning capabilities of the perc.

 •  Washing.  Soiled clothes are manually loaded into  the,perforated steel drum of a
    washing machine, which is then filled with charged perc.  The drum is then rotated
    and  agitated until the clothes  are  cleaned.   During this  process,  the  perc is
    continuously passed through a filtration unit at a rate of up to 240 changes per hour
    (cph) to remove accumulated soils and dyes.

 •  Extraction. After the wash cycle, the perc is extracted frqm the drum by draining
    and spinning at high speed, which forces the perc out  through the perforations. Like
    the wash and rinse cycles hi a home laundry machine, the washing  and extraction
    steps are repeated once to clean  the clothes  thoroughly. Extracted perc is piped to
    the filtration unit where it is reconditioned for reuse.                    .

 •  Transfer of Clothes.   If the dry cleaning process is taking  place in a  transfer
    machine, hi which the washing and drying steps occur in separate chambers,  then the
    clothes must be manually transferred between them. The air hi the system at the end
    of the extraction cycle is directed away from the machine when the washer door is
    "opened hi order to limit workers' exposure to perc vapors. This airstream.is passed
    once through the main perc recovery system (although these are technically  residual
    vapors),  and then vented to the atmosphere.  Even if the  venting precaution is
    observed, this step of transferring clothes damp with perc  exposes plant workers to
    perc  fumes and is a major source-of perc  emissions to the .atmosphere.  For this
    reason,  'new  EPA regulations have prohibited the  installation of new  transfer
    machines hi dry cleaning operations.

    If  a  dry-to-dry machine is used,  the transfer step  is  not necessary.  Washing,
    extraction and drying take place in the same chamber  and the machine door need not
    be opened until the clothes are dry.

•   Drying.  The clothes are  dried in'a tumble-dry process. .Clothes are dried for 12 to
    24 minutes in a rotating drum and cooled in a short cycle of unheated air.   Exhaust
    air from this step is continuously passed through a main perc recovery system, where
    the perc vapors are removed and collected for reuse.   The  outlet air from  the
    recovery system is returned to the dryer for reuse, resulting in a  closed-loop system.
    No process emissions are vented, during the actual drying step.

•   Aeration* This final step involves briefly passing fresh ah* through the dried clothes
    to remove trace amounts of residual perc before handling.  Because fresh air with no
    perc content is needed  for this step, the aeration exhaust cannot be recirculated and
    must be vented to the atmosphere, either'directly or through a residual perc recovery
    system.  The aeration continues while the clothes are being unloaded from the dryer,
    to- protect the worker from vapors that might otherwise escape from the machine.
                                     8

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3.4    Dry Cleaning Equipment
       Modern dry cleaning equipment is available in integrated units that incorporate perc
recovery operations as well as the washing and drying steps. All dry cleaning systems can be
classified as either transfer machines or dry-to-dry machines (see Figure 1). Transfer machines
are those that wash and dry the clothes in two separate chambers.  Transfer of the clothes from
the washer to the dryer is manual.  Dry-to-dry machines, on, the other hand, wash the clothes
and dry them in the same chamber. As the name implies, the clothes go in dry, and they come
out dry;                                                             ..             ,     ,
oc
                                                           Residual perc vapors vented
                                                            while door is open during
                                                                clothes transfer
                                                                  rf I^B^
                                                                  O
     Washer/Dryer
      Dry-to-dry
                              Washer
                                                                   Dryer
                                        Clothes transferred
                                           manually

                                          Transfer machine
                   •.[ Figure 1.  Dry-to-dry vs. Transfer Machines
       Transfer machines are becoming increasingly rare in modern dry cleaning plants for
several  reasons.  Concern over perc vapors released inside and outside the plant, has led to
stringent EPA and 
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of clothes  can be washed while the previous batch is drying.   The majority of modern dry
cleaning facilities now employ only dry-to-dry machines.             .

       Loading capacities of dry cleaning machines range from 8 Ib (4 kg) for coin-operated
dry-to-dry  machines to large industrial machines with capacities of about 140 Ibs (64 kg) for, dry-
to-dry machines and about 250 Ibs (114 kg) for transfer machines. A typical size for a machine
in the commercial dry cleaning sector is one with a 40 Ib (18 kg) capacity.

3.5    Perc Recovery Processes
       The $5-a-gallon purchase price of perc  (hi 1995) combined with costs for disposal  of
perc-based hazardous wastes make it economical to recover and purify it for reuse. The attached
Dry Cleaning Plant Process Diagram (Figure 2) details the integration of. the perc  recovery
process with a dry cleaning machine.  The equipment differs from plant to plant, but generally
incorporates the following processes: used perc filtration, perc distillation, perc vapor recovery,
perc/water separation, and additional perc recovery from wastes.

Used Perc Filtration (recovery of used perc from washer)
       Used perc extracted from the washer is first passed through a mechanical screen, known
as a button trap,  to remove large objects, and a finer screen to remove  lint.  Objects and lint
trapped by these  screens should be handled as hazardous wastes. After passing through these
screens, the perc  is filtered through a main filter to remove most insoluble particulars that may
remain in the  used perc, producing a clear filtrate.  This filtered perc is then renamed to the
washer drum and the process is repeated at a rate of up to 240 changes per hour (cph) during
the wash cycle.

       There are  two types of main filters that are used in the dry cleaning industry.  Cartridge
filters are the  most common and produce spent cartridges which are  contaminated with perc..
These cartridges  are  drained or  steam  stripped  before  disposal  under hazardous  waste
regulations. Powder filters are becoming quite rare, but are still used and produce spent filter
powder as  filter waste.  This waste is known as filter muck and is further treated hi a imick
                                           10

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Figure 2.  Dry Cleaning Plant Process Diagram
                     11

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 cooker to recover additional perc before disposal. Filter wastes, along with still bottom wastes
 (described below), are a primary source of hazardous wastes.

        The main filter may also be followed by a polishing filter to provide additional removal
 of trace amounts of insoluble soils.  Main and polishing filters, as well as the muck cooker, are
 described in more detail in the perc recovery equipment section (Section 3.6).

 Perc Distillation
        In addition to continuous filtration,.perc must be occasionally distilled to remove soluble
 oils and greases, dyes, and other non-volatile residues.  In order to maintain solvent quality, all
 perc in a dry cleaning machine may need to be distilled daily.

        Distillation is a process which involves heating a. mixture to separate the volatile portion
 from the non-volatile portion.  When'filtered solvent is distilled, a perc and water mixture is
 vaporized and collected.. This mixture is considered pure and is sent to the perc/water separation
 process. The residue that remains at the bottom of the distillation vessel is referred to as still
 bottom residue. This residue is the other primary source of hazardous wastes stemming from
 the dry cleaning process.  The distillation unit used hi this process is further'described hi Section
 3.6.                                                       .                  .

Main Perc Vapor Recovery (recovery of drying step emissions)
       The main perc vapor recovery system collects some of the perc vapors evaporated during
the drying  step of the cleaning cycle.  This  perc does not contain  significant  amounts  of
impurities  and does  not need to be  re-distilled.  The airstream leaving the recovery system
contains a reduced amount of perc vapors and is recirculated back to the dryer and reheated for
reuse during the drying process.   This process is closed-loop and should not vent any perc
emissions to the atmosphere.

       Mam perc  recovery systems will recover perc  vapors from the dryer exhaust airstream
(Stream C in Figure  2).  The airstream leaving the system will have up to 50.percent of perc
                                            12

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 vapors removed from it and is recirculated back to the dryer (Stream D in Figure 2) where, it
 is reheated for  reuse  in the drying  process.   This results in a closed-loop system  which
 eliminates virtually all perc emissions from the drying cycle,  Since recirculation of dryer
 process air is now required by the EPA, facility owners have an economic incentive to ensure
 that their perc vapor recovery systems are  operating as efficiently as possible.   A recovery
 system that removes a large portion of perc vapors from the dryer exhaust airstream recycles
 purer, more effective air back to the dryer.- .••

        All new (as defined-in Section 4.2) dry cleaning machines are now required to  install
           '             -               -                    *  *
 refrigerated condensers as the  main perc  vapor  recovery  system  to  recover drying step
 emissions.. Carbon adsorbers are also in use for existing machines. Both pieces of equipment
 produce a condensate consisting  pf a water/perc mixture which is  then sent to the perc/water
 separation process.  Refrigerated condensers  and carbon  adsorbers are both described in
 Section.3.6.

 Residual Perc Vapor Recovery  (recovery of aeration step emissions)
       The dryer-exhaust airstream after the drying cycle still  contains .residual perc vapors.
 However, since fresh air must be circulated throughout the system during the ensuring aeration
 step, this airstream cannot be recirculated  to the dryer and must be vented to the atmosphere.
 Complete drying before  aeration  ensures that the perc vapors vented  during this  step are
 minimized.                                          .

       A residual perc recovery  system can be installed to remove the small.amounts of perc
contained within this airstream before it is vented.  This residual perc recovery system recovers
vapors from the aeration exhaust of the dry cleaning cycle (Stream A in Figure 2) and vents the
exhaust to the atmosphere after one.pass (Stream B in Figure 2).  The perc/water mixture that
is recovered is pipeB to the separation process.  A divertef valve  is installed hi the dryer exhaust
duct to switch the flow of air between the main and residual system as  the dryer door is opened
and closed.                                      '
                                            13

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       Major sources of perc air emissions (as defined in Section 4.2) are required to install and
operate carbon adsorbers to serve as residual perc vapor recovery  systems.   Refrigerated
condensers do not have the  ability to recover the small concentration of perc vapors typically.
found  in the aeration  exhaust.   EPA does, not 'require  other sources to have residual • perc
recovery systems  at this time—they may vent aeration vapors directly to the atmosphere.  When
transfer machines are eventually phased out, these emissions will be the only deliberate source
of perc emitted to the atmosphere during  the dry cleaning process (see washer open-door cycle
perc vapor recovery, below).     •                                 •     .

Washer Open-Door Cycle Perc Vapor. Recovery (recovery of transfer step emissions)
       The perc-laden  air in a. transfer machine washer after the extraction step is vented away
from the machine during the manual transfer of clothes (while the door is open) to protect the
worker from perc fumes  (Stream E).  Like the airstream from the aeration step, this airstream
also cannot be recirculated because fresh air is being drawn into the machine during this transfer
step.  Therefore, this  airstreain must be vented to the atmosphere (Stream  F) after one pass
through a control device.

       The dryer exhaust and the washer open-door exhaust streams (Stream C and Stream E)
cannot be served  by the  same coil because the washer exhaust is much cooler and requires a -
lower temperature coil (40 CFR 63.322(f)(3)). (The two coils can; however  be contained with
the same condenser unit.) In order to prevent air from passing through the condenser until the
washer door is  opened, an exhaust damper (see Figure 2) is generally installed hi front of the
inlet '(Stream E).  As with the other perc recovery processes, the condensed distillate is directed
to the separation  process.                .    ^

PercAVater Separation                  ,
                  i-
       The condensate from the distillation process, and from all three vapor recovery processes
contain varying amounts of perc and water. • In this step, the water is separated out hi a gravity
settling tank, leaving  purified  perc  that  is sent to the storage tank for  reuse in the washing
process.  The water that is removed contains a small amount of perc (about 150 ppm) and is the
                                           14

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only source of contaminated wastewater from a typical dry cleaning plant.  The separator unit
is described in Section 3.6.                                       '
                                                                      \ '"*,*'
Wastewater Treatment
       The perc content in separator water can be further reduced to between 0.1 to 0.7 ppm
in a mister, which passes the separator water through a disposable carbon filter and then sprays
the treated water into the atmosphere.  There is no discharge of perc contaminated water to the
municipal sewer in this case.

Additional Perc. Recovery From Wastes
       Contract disposal services have traditionally disposed of perc wastes, hi landfills.  Due
to tightening of Resource Conservation and Recovery Act (RCRA) regulations and  increasing
costs  for disposal of hazardous wastes, it has become economical in many cases for contract
disposal services to further recover perchloroethylene from still bottom and filter wastes and sell
the recycled perc back to the dry cleaning industry. Specialized contractors can remove all but
about 1000 ppm (by weight) of perchloroethylene from dry cleaning solid wastes.

3,6    Perc Recovery Equipment
                                                                               ซ
       Much of the accessory equipment in a dry cleaning plant is dedicated to the recovery and
recycling of perc.   The most common types of specialized equipment used in the dry cleaning
industry are described below.

Filters (Process:  Used Perc Filtration)
       Mam dry cleaning filters can be classified into three types:  cartridge filters, disk filters,
and powder filters.  A polishing filter may follow the mam filter for additional perc clarification.
                 *-•                            •'
       Cartridge Filters
       All cartridge filters contain some kind of disposable filter element.  Most are  cylindrical
with a diameter of about 7%" (20 cm) and a height of about 14 W (36 cm)1.  They are installed
                                           15

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 in housings that hold anywhere from a single filter for small machines to 21  filters for larger
 capacity machines.  The three types of cartridges  commonly used are known as carbon core
 cartridges, all-carbon cartridges, and adsorptive cartridges.             .

       Carbon core cartridges consist of a pleated paper element to remove insoluble soils and
 a center core of activated carbon to remove dyes (see Figure 3). All-carbon cartridges contain
 only activated carbon and are used for additional color removal.  They are installed hi a section
 of the filter housing after the carbon core cartridge.  Adsorptive cartridges are similar to all-
 carbon cartridges but in addition to activated carbon, also contain some activated clay.  Activated
 clay has different adsorptive characteristics—it  is not as efficient at removing colors but can
 adsorb some types of non-volatile residues.                                               ;'

       The gaskets used to install cartridges must be in  good condition. Damaged gaskets or
 old gaskets that have hardened and are .unable to seal properly will either leak or allow unfiltered
 perc to bypass the cartridge.  Newly installed cartridges tend to allow some fine activated carbon
 panicles to pass through the paper element and do not reach  their full efficiency until a layer of
 soil (precoat) accumulates on the filter paper.                        •

       Filters need to be replaced when a certain amount of material accumulates on them.  For
 some cartridges, manufacturers recommend that filters be replaced when the pressure difference
 across them reaches a certain level. Others should be replaced when a certain weight of filtered
 soils builds up inside the cartridge. Typically, a standard size cartridge should be replaced after
 filtering an amount of perc that has cleaned  800 to 1,500 pounds (360 to 680 kg)  of clothes.
 Continued use of spent cartridges can result hi rapid pressure increases that may force unfiltered
perc through the system.

       Accumulated, solid filter waste must be treated to recover as much perc as possible before
its disposal as a hazardous waste.  Cartridge  type filters produce spent cartridges which can be
drained hi their housing to minimize perc losses.  Unfortunately, the machine cannot be operated
while the filter  is being drained. New cartridge filters have built-in stream stripping systems for
maximum perc recovery.                      ,  :                        .         '
                                            16

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                                        "3
                                        K
                                        U
     Figure 3. Cartridge'Filtration
                   17

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       Disk Filters
       Disk filters are becoming more common in new dry cleaning machines.  The filter
elements in these units are disk-shaped, reusable fabric filters with a pore size of approximately
25 to 30 microns.  A single disk filter unit can be a cylindrical unit containing Up to 40 or 50
filter elements.  Disk filter units can be used with or without diatomaceous earth (see Powder
Filters) and have a built hi centrifuge motor. When a  certain weight of filtered soils-builds up
on the disks, the entire unit is centrifuged, driving  the filtered soils to the outside  of the
cylinder.   The filtered material can then be removed and further treated before disposal as
hazardous waste, while the filter disks remain hi the unit to be reused. Disk filters are becoming
more common primarily because they do not require disposal of bulky cartridge units. Only the
filtered material, along with some diatomaceous earth, if any is used,  requires disposal.  This
can result in significant savings in waste disposal costs for the typical dry cleaning facility.
                        r
       Powder Filters  .
                                                    I
       Although cartridge and disk filters are used almost exclusively today, powder filters are
still encountered occasionally.  These filters use a powder consisting primarily of diatomaceous
earth (or diatomite), which has the tendency to form  a porous  cake when wetted.  For  each
washer cycle,  the diatomite filtration cycle consists of three steps:  (1) precoat, (2) filtration, and
(3) removal of the filter cake  (see Figure 4).

       To apply the precoat,  diatomite is added to clean perc which is then pumped through
some sort of  support material, such as a metal screen.  The thin layer of diatomite  that is
deposited on  the support is the precoat,  or base of  the filter cake.   Once the precoat has
accumulated,  the filter can begin to process used perc. The  used perc that is pumped through
the filter contains additional diatomite to dilute the soil that accumulates on the filter so that the
cake maintains its porosity.

       Non-regenerative filters are usually  only precoated at the beginning of each work day
and fresh filter powder,  known as body feedป is added at the  beginning of each filtration cycle.
                                            18

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     Figure 4. Powder Filtration
           19

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At the end of the day, when the filter cake reaches a certain thickness and causes excessive filter
pressures, the  entire cake is dislodged, removed and discarded.  In a regenerative filter,  a
larger initial pool of fresh filter powder is added to the machine at the beginning' of the day.,
At the beginning of each cycle, filter powder is drawn from this pool to form the precoat. After
each filtration cycle, the filter cake along with the embedded soils, is  bumped off and returned
to and mixed  into the pool.  In this process, a new precoat must be formed prior  to each
filtration cycle. Filter powder must be pumped for  about 2 minutes through the support before
formation of a precoat with adequate, coverage.
                                                             \      -
       The material used to support the diatomite varies from filter to filter.  Bag filters and
screen filters support the  diatomite on  bags and screens, respectively, and die filter cake is
manually dislodged from these supports.  Rigid tube filters, an advance  hi filter technology,
support the filter powder on an internal wire frame  surrounded by a filter screen; a back-wash
of reverse perc flow is used to remove the filter cake from the tube. All of tiiese filters operate
as non-regenerative filters and will rarely, if ever, be encountered today.

       Regenerative  tube  filters  are still used  in  some  dry cleaning facilities.   These  are
constructed of flexible braided metal wire, metal helical springs, or braided or knit fibers, from
which the filter cake can easily  be dislodged at -the end of each cycle.   The advantage  of
regenerative filters is  that they  do not require body feed addition and the filter cake does not
build up significant thickness, so that more soils can  be collected by a given amount of diatomite
before it must be discarded.

       To remove color and non-volatile residues, activated carbon and activated clays can be
mixed into  the filter powder.  These materials do  not form a porous cake  like diatomite and
should be added after the precoat has formed if possible, to prevent excessive build-up of filter
pressure.         <-.                                    ,
                                            20

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       Polishing Filters
       In addition to the cartridge or powder filters that are used as the'main, filter, an additional
polishing filter may be installed to  remove trace amounts of insolubles from the clarified perc.
Two popular types are those constructed with resin-bonded fibers and those consisting of a spiral
cotton element wound onto a perforated metal tube. Polishing filters are extremely fine and have •
pore "sizes of approximately 3' to 5  microns.  In order to  increase their useful life, they should
be bypassed during the precoat process for powder filters, or after installation of new .cartridges
for cartridge filters.         .          .

Muck Cooker (Process:  Used Perc Filtration)
       The spent filter cake removed from a powder filter is saturated with perc and must be
treated before disposal. This filter muck, as it is called, is transferred to a muck cooker, where
it is cooked to vaporize the perc.  The vapors are routed through a condenser to recover the perc
for reuse. -This process can recover up to 90 percent of perchloroethylene from the filter muck.
In some facilities, the distillation unit will also serve as a muck cooker.  Other facilities may
have a separate unit.

Distillation Unit (Process: Perc Distillation)
 '.                '          '             ',"••*      '
       The  distillation process removes  non-volatile residues (soluble oil, grease and other
impurities) from the perc that cannot be removed by the filtration process.  Filtered perc is
distilled by heating it with,steam coils in an atmospheric pressure still kettle (see Figure 5).  At
a temperature of 250ฐF (121 ฐC),  the perc and water are  vaporized while soluble impurities
remain at the bottom of the still.

       The1.vapor mixture is piped to a  condenser to be cooled back to a liquid state.  The
condenser contains tioils filled with continuously recirculated cooling water which runs Counter-
current to the motion .of the vapor mixture.   In order to achieve  proper condensation,  the
mixture should be  cooled to about 90ฐF (32ฐC), which requires  that the temperature of the
                                            21

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                       Thermometer
             Cooling Water Out
                                                 k        Main Steam In
                                                  ^Reducing Valve
                                             Steam Gauge
  1k*--
   y  Steam Trap
Check Valve
LEGEND
                                                                        Dirty Solvent
                                                                        Vapors
                                                                        Cooling Water
                                                                        Wastewater
                                                                        Distilled Solvent
                                                                        Distillate (Solvent/Water)
                                  Figures.  Distillation Unit
                                                 22

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cooling water leaving the condenser be close to 110ฐF (43ฐC).  The perc and water vapors
condense onto the condenser coils, drip down to a collection point, and the condensate is piped
                  *              •       '                        '             .    -   •   *
to the separator.
     >       _   -            •-                •         .
       The oils and greases remaining at the bottom of the still when the used perc is vaporized
are collectively known as still bottom residue.  Still bottom residue must be drained periodically
from the bottom of the still kettle. This residue is hauled manually in a bucket to the satellite
waste disposal container.

Emissions Control Devices (Processes: Perc Vapor Recovery Processes)
       The  two types of emissions control devices widely in use today are the refrigerated
condenser and the carbon adsorber.                                             •

Refrigerated Condenser (Figure 6)
       This device is similar to me condenser  used to condense distillation vapors,  but is
designed to  operate at a lower temperature for more complete removal of perc vapors.  To
recover perc vapors, the perc-laden airstream is passed over a matrix of refrigerated coils, which
cools the airstream to the point where the perc vapors condense onto the coils. The condensed
perc drips down to a collection point and is piped back to be reused.

       The performance of refrigerated condensers used to control dryer process emissions must
be monitored with a tempe'rature sensor installed in the outlet airstream that is recirculated back
to the dryer (Stream D in Figure 6).  Under current EPA regulations, the temperature of the air
at this point must be 45 ฐF or less during the drying process to be removing an adequate portion
of perc vapors from the dryer exhaust airstream.

       RefrigeratedTcondensers serving "to remove washer open-door cycle vapors must .also be
monitored for performance. Two additional temperature sensors must be installed on the inlet
(Stream E in Figure 6) and outlet (Stream F in Figure 6) of the exhaust from the washer.  Under
current EPA regulations, the net temperature drop of the airstream across the condenser must
                                           23

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Washer Exhaust Aiistream
(Transfer Machines Only)
     Dryer Exhaust
       Airstream
      Rccirculate
        to Dryer
         •   Refrigerated
         Condensing Coils
            Condensate to
              Separator
                                                                                        Vented to
                                                                                       Atmosphere
             Note: Temperature sensors should be installed at streams D,E, and F.
                   To should be less than.or equal to 45'F (7.2'C)
                   TE-TF should be at least 20'F(ll.rC)
               Figure 6.  Perc Recovery System:  Refrigerated Condenser
                                                 24

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be at least 20ฐF (11.1ฐC) to remove an adequate portion of perc vapors.

       Carbon Adsorber (Figure 7)
       The carbon adsorber is another type of perc vapor recovery device*  While refrigerated
condensers continuously remove perc vapors from an airstream and recycle it back to the system
as liquid perc, carbon adsorbers trap vapors in an activated carbon bed.  The outlet airstream
is continuously piped to the atmosphere or back to the dryer depending on whether the adsorber
"is used to recycle residual or main vapors.  However, the collected perc is only returned to the
system during a periodic WP process. In the process of,  the carbon bed is also regenerated and
can be reused.                        .                                       ..

    -   Activated carbon is a manmade loose granular material which has a high affinity for
adsorbing organic compounds.   The perc-laden airstream is passed through a bed of activated
carbon and the perc molecules are adsorbed on the large surface area  of the carbon material.
Removal rates for carbon adsorbers are over 95 percent.  Unlike a filter which simply loses
efficiency when it is not properly serviced,  an adsorptive bed becomes entirely ineffective when
it reaches its capacity. In essence, all the adsorptive spaces on the surface area of the activated
carbon have  been occupied and the bed ceases to adsorb  any more perc  vapors.   A typical
carbon bed can adsorb about 20 percent of its own weight in perc vapors before it  reaches its
capacity and needs, to be regenerated.

       Desorption of the accumulated perc and regeneration of the carbon bed is accomplished
through a steam stripping process (see Figure 7). This process consists of passing steam through
the bed to vaporize the perc molecules and separate them from the carbon. The combined vapor.
stream of perc and steam is then condensed and routed to the separator.  Dry cleaning facilities
are required to regenerate their adsorbers at least on a weekly basis, but the actual length of the
                  =-.                         .            ' ' '           '.
adsorption/desorption cycle  should be determined by monitoring the perc concentration in the
outlet airstream during the last run before desorption.
                                           25

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Figure 7.  Perc Recovery System:  Carbon Adsorber
                     26

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       Monitoring of carbon adsorbers is accomplished with a colorimetric detector tube (see
Figure 8). This tube contains a chemical substance that, when exposed to the adsorber exhaust,
changes colors depending on the perc vapor concentration.  Each tube can only be used once.
Some tubes are operated with a hand bellows pump that must be squeezed several times. Use
of tubes requires that a sampling port (usually Vฃ") be drilled in the outlet duct of the adsorber.
Colorimetric detector tubes are calibrated to measure perc concentrations up to  300  ppm to an
accuracy of ฑ25 ppm.          .     -~  •                                      ^
                      Colorimetric
                     Detector Tube
                                            Hand Bellows Pump
                         Figure 8. Colorimetric Detector Tube
       The sampling port must be located in a straight portion of duct without .flow disturbances
in order to obtain  accurate test  results.  Specific EPA requirements regarding location of
sampling ports are covered under the summary of air regulations (Section 4.3.2).

       Use of Refrigerated Condensers and Carbon Adsorbers
       EPA regulations have prohibited further installation of carbon adsorbers used as main
perc recovery systems, mainly because  of the potential for  human error—carbon adsorbers
                                           27

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become entirely ineffective if they are not regenerated in a timely manner. They also have other
disadvantages that discourage their use as main perc, recovery systems'.  They are mechanically
more complex  than refrigerated condensers and require more labor for maintenance  and
operation.  Furthermore, although the carbon bed can be regenerated repeatedly for up to 20
years, it eventually becomes spent and must be disposed of as solid waste.

       Carbon adsorbers do have two advantages over refrigerated condensers.   One.is their
ability to remove perc vapors from airstreams with considerably lower concentrations of perc,
which makes them appropriate for use as residual vapor recovery systems  and for controlling
fugitive emissions (e.g., from transfer machine room enclosures).  They are also able to handle
higher airflows, which in the past accounted for their higher usage in the industrial dry cleaning
sector.

Separator (Process: Perc/Water Separation)
       Condensed perc from any condensation, process will normally have a certain amount of
water that must be removed.  The separator is simply a settling tank in which a purified mixture
of water and perc from the various  condensers in the dry cleaning plant can be separated by
gravity (see Figure 9).  Liquid perc is considerably heavier than water (with a specific gravity
of 1.62) and will settle to the bottom of the  tank, while a water  layer will remain at the  top.'
The separated purified perc is piped to the solvent storage tank for reuse in the dry cleaning
cycle.  Management of .the remaining wastewater is discussed in Section 3.7.

Mister (Process:  Wastewater Treatment)
       The mister contains a disposable activated carbon filter that removes residual perc from
separator water. The treated water contains as little as 0.1 to 0.7  ppm perc and is sprayed into
the atmosphere.   Dry cleaning facilities that choose to  incorporate a mister into their  perc
                  ซซ.
recovery process should regularly replace the carbon filter as per manufacturer's instructions.
Continued use of spent filters could result in untreated separator water being sprayed into the
atmosphere.                   .     .    ,
                                           28

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Solvent/Water Condensate
 i*f * *
 X N N
i
                   Air
                                      Vent
 X N. S
S t S f
 \ X X "
s / s *
 \ \ N

 \ N \
      ', / t/s",' /•*,
         // ' .  Solvent .•//; '//
      / Y//// / ///•

      ' /     "  /
                              ..
         /S '/ SS
                                        Wastewater
                                       Solvent to
                                        Storage
                                         Tank
          Figure 9.  Perc/Water Separator
                       29

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Evaporator (Process:  Wastewater Treatment)

       An evaporator unit contains a heating device to vaporize the separator water into the
atmosphere.   Evaporators may be appropriate for larger facilities that generate  substantial

amounts of separator water.  EPA has determined that facilities that choose this  method of

handling separator water do not need to obtain a permit for hazardous waste treatment.  Dry
cleaners should check to ensure that evaporators are allowed under state and local environmental

regulations as well.              ,                                      .


3.7    Summary of Perc Waste Sources

       The various wastes that are produced during the dry cleaning process have been identified

in the discussion on dry cleaning processes  and equipment (Sections 3.1 to 3.6). In this section

they are summarized for the convenience of the inspector.          '             :


Air Emissions                              .

       •  Residual vapors vented during the aeration process. These may be vented either
          directly to the atmosphere or through a carbon adsorber, depending on the applicable
          requirements.  If a carbon adsorber is used, the- outlet airstream released to the
          atmosphere must not exceed 100 ppm perc when the machine door is open and must
          not exceed 300 ppm perc when  the machine door is closed.

       •  Open door cycle  vapors that  escape the  recovery process in the refrigerated
          condenser.  These emissions will'be minimized if the condenser is in compliance
          with monitoring requirements for refrigerated condensers.

       *  Room enclosure vapors. Vented through a carbon adsorber by room enclosures for
          transfer machines.


Hazardous Wastes                        :                       ,

       •  Still bottom residues. The residue remaining-at the bottom of a still must be drained
          and disposed of.  About 25 pounds of still residue  will be produced for each 1000
          pounds of clothes cleaned.

       •  Drained (and/or steam-stripped)  spent cartridges.  Machines  that have cartridge
          filters and dram them properly before disposal can expect to produce about 20 pounds
          in spent'carbon core cartridges for every 1,000 pounds of clothes cleaned.  More
                                          30

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          cartridges will be generated if all-carbon cartridges  are used for additional color
          removal.               .                            .

       •  Cooked powder residue.  If powder filters are used, the filter cake is cooked  in a
          muck  cooker  to remove remaining  liquid  perc.   The  residue, consisting of
          diametapeous  earth and insoluble soils removed,from the used perc, still  contains
          some residual perc and is  a solid hazardous waste.  A machine using a powder filter
          can expect to  generate about 40 pounds of cpoked powder residue for every 1,000
          pounds of clothes cleaned.

       •  Spent activated carbon.   Although the carbon in carbon beds can be regenerated
          repeatedly,  it will gradually lose  its effectiveness and  will eventually  need to be
          replaced.  The carbon will contain perc and is a solid hazardous waste.  The amount
          generated  is  fairly   insignificant,  since  a carbon  bed  can  be regenerated  for
          approximately'20 years.     •                '                   .    '           ,

       •  Button trap wastes and lint trap wastes.  Materials trapped in these screens should
          be handled as hazardous waste.                                      -.  .
Wastewater
          Separator water.  "This is the portion  of the  water/perc  mixture from  various
          condensing process in the plant that rises to the top of the water separator. It consists
          of water that is saturated with perc,  which is soluble in water to about 150 ppm.
          This water can usually be disposed of as hazardous waste or treated in a mister or an
          evaporator.  Disposal of untreated separator water into on-site disposal systems'such
          .as dry wells, cesspools, and septic tanks is prohibited.  Disposal to a municipal sewer
          system is subject to State and local POTW requirements.
                                           31

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               32

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                        •••-':  CHAPTER 4
             EPA AIR REGULATIONS APPLYING TO DRY CLEANERS
                                 j •
 4.1   Background
       The Glean Air A'ct, as amended in 1990, set the framework for EPA regulation of 189
 newly identified hazardous air pollutants, one of which is perchloroethylene. Section 112 of the
 Clean Air Act required EPA to control emissions of these hazardpus air .pollutants (HAPs) by
 promulgating national emissions standards for each category of sources that is found to emit
 HAPs. These standards are found in Section 63 of Title 40 of the Code of Federal Regulations
 and are known as the National Emissions Standards for Hazardous Air Pollutants (NESHAP) for
 .Source Categories.  Specific standards for the perc dry cleaning industry were promulgated on
 September 23, 1993, in the Federal Register (58 FR 49354) as the National Perchloroethylene
 Air Emission Standards for Dry Cleaning Facilities (Subpart M of 40 CFR Part 63).-.

       These NESHAP regulations for dry cleaners are technology-based, rather than emissions- ,
 based.  Because it would have been prohibitively burdensome  to require owners to constantly
 monitor emission concentrations and solvent mileage, the EPA decided that, as authorized under
'section 112(h) of the CAA, the standards would require installation of certain levels of emissions
 control equipment combined with mandatory performance  testing to ensure that the equipment
 is functioning properly. NESHAP standards for dry cleaners are intended to control emissions
 from major sources (defined by Section 112  as having the potential to emit more than 10 tons
 per year of PCE) to a level that is represented by maximum achievable  control technology
 (MACT).  Area  sources (non-major sources) are required in the framework of these regulations
 to  control  their emissions to  a level that is  represented  by generally  available control
 technologies (GACT).                                                      •
 4.2    Applicability
       Dry cleaning facilities are categorized into four size  categories for the purposes of
 regulation.  These are,  from smallest to largest:  corn-operated facilities^ small area sources,
1 large area sources, and  major,sources.    ' •                     .            •
                                            *                                 •
 '•  •             •' •   '                     33

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           Coin-operated dry cleaners are defined as those facilities that have only dry cleaning
           machines that are operated by the customer.  .
       Classification in the other size categories is determined by the type of machines (dry-to-

dry or transfer) in use and by the amount of perc purchased each year.
           Small area sources are those that (1) have only transfer machines and purchase less
           than 200 gallons (760 liters) per year of perc or (2) have only dry-tordry machines
           or have both transfer and dry-to-dry machines, and purchase  less  than 140 gallons
           (530 liters) per year of perc (40 CFR 63.320(d),(e)).

           Large area sources are those, that exceed perc purchase levels for small area sources
           but do not purchase enough to be classified as a major source.

           Major sources are those that (1) have only dry-to-dry machines and purchase more
           than 2,100 gallons (8,000 liters) of perc per year or (2) have only transfer machines
           or have both transfer and dry-to-dry machines, and purchase more than 1,800 gallons
          .(6,800 liters) of perc .per year. (40 CFR 63.320(g)).
Requirements for size categories are summarized hi Table 2.
       Table 2.  Size Category Determination for Applicability of Air Regulations
Facility Size Category
Coin-operated source
Small area source
Large area source
Major source
•
Transfer
Machines Only
n/a
Perc purchases
< 200 gal/yr •
Perc purchase
200 - 1,800 gal/yr
"Perc purchases
> 1,800 gal/yr
Dry-to-Dry
Machines Only
Has only customer
operated machines
Perc purchases
, < 140 gal/yr
Perc purchases
140 - 2,100 gal/yr
Perc purchases
> 2, 100 gal/yr
Both Transfer and
Dry-to-Dry Machines
n/a .
Perc purchases
< 140 gal/yr
Perc purchases
140 - 1,800 gal/yr
Perc purchase
> '1,800 gal/yr
       In addition to classifying each facility by size, each individual machine is also regulated

differently under NESHAP regulations depending on whether it is a new machine or an existing

machine; New machines are regulated more stringently and are  defined hi the context of these
                                           34

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regulations as those installed on or after December 9, 1991.  Existing machines are those that
were installed before this date (40 CFR 63.321).         .

4.3    Requirements
       The applicability of NESHAP requirements is dependent on the size category of the
facility. Coin-operated facilities are exempt from all NESHAP regulations (40 CFR 63.320(j)).
With  regard  to the three  remaining size categories, requirements  involving installation of
equipment are  generally more stringent for larger facilities.  The  intent  is to avoid unduly
burdening small businesses with requirements they cannot afford to meet.  On the other hand,
requirements involving little or no capital investment (e:g;, monitoring and recordkeeping) have
been standardized for all dry cleaners regardless of size.       •

       Requirements can be divided into four categories:        ,    .

       *  Equipment requirements  (intended to eliminate major sources of perc emissions)
       •  Emissions equipment monitoring (tests to ensure that the control devices are operating
          properly)                                      .
       •  Fugitive emissions control (prevention of miscellaneous perc emissions resulting from
          leaks, improper operation of. dry cleaning machines, or improper handling of perc
          and perc wastes)
       •  Recordkeepuig and reporting (demonstration of compliance).

A summary of all EPA air requirements applying to dry cleaners is provided, in Table 3..

4.3.1  Installation of Emissions Control Equipment
       The two largest potential sources of air emissions from the dry cleaning industry are (1)
the release of perc vapors  into the atmosphere during transfer of clothes from the washer to the
dryer and (2) the  venting  of the dryer .exhaust airstream. '  To eliminate these sources of air
pollution, 'EPA regulations are  phasing  out  the use of transfer machines and phasing in
requirements, on the installation of control devices for dryer  exhaust airstreams.
                                           35

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                       Table 3.  EPA Air Requirements for Dry Cleaners
Requirement
Size
Small Area Source
Category of Dry Cleaning Facility
Large Area Source
Major Source
Equipment Requirements
Elimination of all transfer
machines classified as new
surround all existing transfer
machines with room enclosure
vented by carbon adsorber
Installation of main perc vapor
recovery system (refrigerated
condenser or carbon adsorber)1
Installation of additional carbon
adsorber for residual perc
recovery system
Required
Not required
Required for new
machines upon start-
up. Not required for
existing machines
Not required
Not required
Required for new
machines upon start-up.
Must be installed for
existing machines by
9/23/96.
Not required

• j
Required by 9/23/96.
Required for new machines
.upon start-up. Must be
installed for existing
machines by 9/23/96.
Required for. new machines
upon startup, for existing
machines by 9/23/96.
Emissions Equipment Monitoring
Monitoring of refrigerated
condensers
Monitoring of carbon adsorbers
Weekly monitoring required
Weekly monitoring required
Fugitive Emissions Control
Leak detection program
Simple leak repairs
Leak repairs requiring order of
pans
Disposal of cartridge filters
General operation of dry
cleaning machines
Keep machine doors closed
except when transferring
clothes
Store perc and perc waste
storage in tightly sealed
containers
Biweekly inspection
Weekly inspection
Weekly inspection
Repair within 24 hours
Order parts within 2
working days. Install parts within 5 days of receipt.
Drain for at least 24 hours
As per manufacturer's specifications and
recommendations
Required . ' •
Required
Reporting
initial compliance report
Additional compliance reports
Required upon startup.
Required 30 days after startup and after any change in facility status."
**•_ Recordkeeping
Facility Log Book
Maintain on-site for 5 years.
'Perc vapor recovery systems should be refrigerated condensers, or alternatively, existing carbon adsorbers installed-before
September 22,  1993.
"Change in facility status includes a change in ownership or address of the facility, purchase of new equipment, or a
change in size category.                 •         '
                                                  36

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        The specific requirements enacted to achieve these two key process changes in the 'dry
 cleaning industry are intended to regulate major sources under maximum achievable control
 technology (MACT) standards. Large and small area sources are to be regulated under generally
 available control technologies (GACT).                             •

 Phase-Out of Transfer Machines
        For new dry cleaning systems, all emissions of perc vapors to the atmosphere  must be
 eliminated from the transfer step.   Since no  technology has been  devised  to date that can
 accomplish 100 percent elimination of all vapors during the transfer of .clothes from the washer
 to the dryer, this requirement has effectively forbidden the operation of any transfer machines
 classified as new (40 CFR 63.322(b)(2)).       ,                          .

        Existing transfer machines are allowed.  However, if they are located at a major source,
 they must be surrounded with a room enclosure  to protect workers from fugitive perc vapors (40
 CFR 63.322(a)(3)). This enclosure must be impermeable to perchloroethylene and designed and
 operated to maintain a negative  pressure inside at all times that the machine is  operating to
 ensure that all perc vapors are being vented.  The air inside the enclosure must be vented outside
 the  plant through an additional carbon adsorber separate from any adsorbers used to control
 process  emissions (40 CFR 63.322(h)).

 Control Device Requirements
       The primary method of controlling emissions is to install a control device to remove perc
 vapors from process emissions and recover them  for reuse  as a  cleaning solvent.  The two
•control  devices that are  widely  hi use  today  are  the refrigerated condenser and the carbon
 adsorber.  Current regulations include control devices used for three purposes:
           Main pefrc vapor recovery system:  removes perc vapors hi the dryer exhaust during
           the drying process and recycles the airstream back to the dryer
           Residual perc vapor recovery system:  removes perc vapors from the air remaining
           in the system at the end of the drying  cycle before it is vented to the atmosphere
                                           37

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       •   Washer open-door cycle vapor recovery system:  removes perc vapors from the air
           vented during the clothes transfer process transfer machines
       •   Room enclosure emissions control:  removes perc vapors from the air inside a room
           enclosure for transfer machines before it is vented to the atmosphere.
       Regulations governing the installation of control devices for these purposes are detailed
below.
       Main Perc Vapor Recovery System (40 CFR 63.322(a))
       Vapors from the drying stage are circulated through this recovery system repeatedly and
vapors from the open door cycle of the washing machine are passed through the control device
once before venting to the atmosphere. A refrigerated condenser should be used as the control
device for a perc vapor recovery system.  Carbon adsorbers, installed  before September 22,
1993, are also acceptable.

       Small area sources are required to install a control device for each new machine upon
startup but are not required to install such devices for existing machines.

       Large  area  and major sources are  required to install a control device for each new
machine upon startup and are also required to outfit each existing machine widi a control device
by September 23, 1996.          .

       Residual Perc Vapor Recovery System (40 CFR 63.322(b)(3))
       Major sources are further required to vent residual dryer vapors through an additional
carbon adsorber immediately before or as the door is opened.  The refrigerated condenser system
installed to remove and recovery5perc vapors does not control the residual vapors remaining in
                  
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       Washer Operi-Door Vapor Recovery System (40 CFR 63.322(f)(l))

       The main recovery system usually doubles to recover washer open-door cycle vapors as

well, although the airstreams are not mixed.  This is required for all existing transfer machines

by September 23, 1996.  New transfer machines will no longer be permitted.


       Room Enclosure Emissions Control (40 CFR 63.322(h))

       As covered above in the transfer machine phase-out section, each-room enclosure built
to contain existing transfer machines must  be vented through a separate carbon adsorber by
September 23, 1996.  Both the room enclosure and the accessory carbon adsorber are required

only for major sources.


       Requirements Concerning Use of Refrigerated Condensers               .

       Refrigerated condensers used as main perc vapor recovery  systems should be installed

and operated under the following guidelines:
          Condensers must be installed to recycle the dryer airstream back to the dryer while
          the drying-cycle is on (40 CFR 63.322(e)(l)).

          The inlet airstream coming from the dryer exhaust must be operated with a diverter
          valve, which must prevent flow through the condenser while the dryer door is open..
          This air flow  will instead be  directed to either  an additional carbon  adsorber or
          vented directly to the atmosphere/ Only when  the dryer door is  closed can the,
          condenser outlet airstream be recycled back to the dryer (40 CFR 63.322(e)(3)).

          As explained in Section 3.5 (Washer Open-Door  Cycle Perc Vapor Recovery), the
          airstreams from the washer and the dryer of a transfer machine cannot be cooled by
          the same refrigerator coils (40  CFR 63.322(f)(3)).                    •     .

          For transfer machines,  the washer airstream should not be flowing  through the
          condenser until the washer door is opened.  An exhaust damper is usually installed
          to accomplish this purpose (40 CFR 63.322(0(1))-
                                          39

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       Requirements Concerning Use of Carbon Adsorbers
       Carbon adsorbers are required to be installed in such a way that they are not bypassed
 at any time (40 CFR 63.322(g)(l)). For those adsorbers used to vent residual perc vapors, this
 requires that, practically speaking, they be hooked up in parallel with the main perc recovery
 system.  Otherwise, if the two devices are hooked up in series (one after the other), the adsorber
 will accumulate  dryer process vapors as well as  residual  vapors  and will need constant
 desorption. An exhaust damper is normally used to prevent the dryer airstream from entering
 the adsorber until ambient air is drawn into the dryer.

 4.3.2  Emissions Control Equipment Monitoring
       Weekly monitoring is'required for all emissions control devices to ensure that they are
 functioning properly and all testing results should be recorded hi a facility log book.
       *                                 •
 Monitoring of Refrigerated Condensers (40 CFR 63.323(a))
       Emissions from refrigerated condensers are monitored to confirm that the airstream is
 being cooled to a sufficient degree to condense the perc vapors.  This is done by checking the
 temperature of the airstream(s)  passing through the condenser with a temperature sensor.  The
 temperature on the outlet end of the dryer airstream (Stream D hi Figure 6) must be less than
 or equal to 45ฐF (7.2ฐC).   Condensers serving transfer machines have an additional washer
 airstream.  This airstream must be checked on both the inlet and outlet side (Stream E and F hi
 Figure 6).  The net temperature drop of the airstream as it passes through the condenser must
beatleast20ฐF(ll.lฐC).                                         •

       The temperature sensor that is used must be designed to measure a range of at least 32 ฐF
(0ฐC) to 120ฐF (48.9ฐC) and must be accurate to ฑ2ฐF (ฑ1.1ฐC).
                 u.
Monitoring of Carbon adsorbers (40 CFR 63.323(b))
       Carbon adsorbers must be desorbed weekly to remove accumulated perchloroethylene.
A carbon adsorber is virtually  useless  after it reaches its adsorption  capacity. ;Emissions are
                                           40

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monitored simply by measuring the concentration of perc vapors in the outlet airstream with a
colorimetric detector tube accurate to ฑ25 parts per million (ppm).   The perc content in the
outlet airstream of carbon adsorbers used to recover dryer process vapors (main recovery) must
be less than or equal to 100 ppm.  The outlet hi an adsorber used to recover aeration process
vapors (residual  recovery) may not exceed 100 ppm after the machine door is opened, but may
be as high as 300 ppm while the door is still closed. If the concentration of perc exceeds these
amounts and the equipment is functioning properly, the adsorber, must be desorbed on a more
frequent basis.

       Use of a colorimetric detector tube requires that a sampling port hole be drilled in the
air ducts at the point where concentration readings are to be taken.  This sampling port must be
drilled at least 8 duct diameters downstream and at least 2 duct diameters upstream from any
flow disturbance. (Example:  If the duct diameters is 3 inches, then the sampling port hole must
be drilled at least 30 inches downstream and at least 6 inches upstream of any flow disturbance.)
A flow disturbance includes any of the following:

       •  The inlet or outlet of the duct
      ••.  A bend .in the duct
       •  A contraction or expansion .
       •  A place where another duct is piped in or out.

The sampling port should be kept covered when not being used for testing.

    '   Testing should take place at the end of the periodic adsorption cycle, during the last dry
cleaning cycle before the adsorber is desorbed.  The machine should be venting to that carbon
adsorber while the test is conducted-
                                           41

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4.3.3  Fugitive Emissions Control                                 .
Leak Detection and Repair Program (40 CFR 63.322(k),(l),(m),(n))
       Dry cleaning facilities are required to conduct periodic inspections to check for leaks in
each dry cleaning machine.  Inspections must be conducted weekly at large and major sources
and biweekly at small sources and must include the following components of each dry cleaning
machine:              .

       •  Hose and pipe connections, fittings, couplings, and valves
       *  Door gaskets and seatings
       •  Filter gaskets and seatings
       •  Pumps
       •  Solvent tanks and containers
       •'  Water separators .
       •  Muck cookers        '                                      .
       •  Stills
       •  Exhaust dampers
       •  Diverter valves
       •  Cartridge filter housings.

       Any leaks detected must be repaired promptly. Repairs that do not require the outside
procurement of parts must be completed within 24-hours'.  Additional repair parts that are needed
must be ordered within 2 days and installed within 5 days of receipt.  A log of all inspections
and repairs made must be kept on site for 5 years.

Miscellaneous  Good Housekeeping Requirements
       There are also some additional EPA air requirements regarding general operation of a
dry cleaning plant.

       •  Operate machines as per manufacturer's  specifications and recommendations (40 CFR
          63.322(d))                   ••'    .
                                           42

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       . •   Keep machine doors closed except when transferring clothes (40 CFR 63.322(c))

       • •   Store perc and perc wastes in tightly sealed containers (40 CFR 63,3220))

       •   Drain cartridge filters in their housing or another sealed container for at least 24
           hours before disposal (40 CFR 63.322(i)).


 Reporting Requirements

       Dry cleaners are required to keep EPA up-to-date with basic information about their

 operations.  Each facility owner or operator must have submitted an initial report (by June. 18,

 1994,  or upon startup  of  a  new facility) that provides the following information (40 CFR

 63.324(a)):          .


       •   The name and address of the owner or operator

       •   The address (physical location) of the dry cleaning facility

     •  •   A brief description of the. type of each dry cleaning machine at the facility

       •   Documented  perchloroethylene consumption during the previous 12 months, or an
          estimate.if documentation is not available

     .  •  A description of emissions control devices that have been installed or will be installed,
          on each dry cleaning machine, where applicable

       •  Documentation to  demonstrate that any room enclosures for transfer machines are
          constructed of materials impermeable to perc and are designed and  operated to
          maintain a negative pressure at each  opening  at  all times  that the machine  is
          operating.


       Each facility owner or operator must submit a compliance report within 30 days after

all requirements applicable to that facility take effect (40 CFR 63.324(b)).  (For new facilities,

this would be 30 days after startup.)  This compliance  report is intended to explain how the

facility is complying with NESHAP requirements and must include the following information:
                                           43

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          The size category of the facility.

          Compliance status with regard to each applicable NESHAP requirement contained in
          40 CFR 63.322, which includes all emission control equipment requirements, the leak
          detection program and good housekeeping requirements. The recommended form for
          this report is provided in Appendix C and is divided into two parts:  a compliance
          report for pollution prevention, and a compliance report for control requirements.
       The information contained in the report must be certified by a responsible official, which

can be any one of the following:                                   .


       •  The president, vice president, secretary, or treasurer of the company that owns-the
          dry cleaning facility'

       •  An owner of the facility                              ;

       *  The manager of the facility

       •  A government official if the facility is  owned by a Federal, State, city,' or county
          government organization                                                     .

       •  A ranking military officer, if the facility is located at a military base.


       Facilities that later exceed perc consumption limits for then; size category must file an

additional compliance report within 180 days of the date that the change in the size category of

the facility occurred.                                                             ,


Recordkeeping Requirements

       All dry cleaners are required to keep the following information on site in a log book in

order to demonstrate compliance with EPA air regulations. All information should be complete

for the past 5 years of operation (40 CFR 63.324(d),(e)).


       •  Receipts^of perc purchases.           '     -

       •  Monthly totals of perc purchases.
                                           44

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       •  Calculations performed on the. first of each month to determine the total annual perc
          consumption for the previous 12 months.  The result is then used to determine if the
          facility can still be classified in the same size category (as per Table 2).   Facilities
          that have exceeded the consumption level for their size category are immediately
        •• categorized as the larger source but have 180 days to comply with requirements
          applicable to this new category.  As mentioned in the reporting section, an additional
          compliance report must be submitted explaining the change in source category.

       •  Dates on which dry cleaning machines were  inspected for leaks.

       •  The location of any detected leaks, and a record of repair activities.

       •  Results of temperature monitoring  of refrigerated condensers,

       •  Results of carbon adsorber outlet concentrations.


       In addition to maintaining the facility log, copies of the design specification and operating

manuals must be' kept on-site for each dry cleaning system and" each emission control device at

the facility.
                                            45

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               46

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                                     CHAPTER 5
  EPA HAZARDOUS  WASTE REGULATIONS APPLICABLE TO DRY CLEANERS

,5.1    Background
       Hazardous wastes that are not disposed of properly can cause immediate injury or death
upon contact or may be released into soil, air  or water and cause long-term damage to the
environment.  Regulations for the management of hazardous  wastes are found hi Parts 260
through 268 of Title 40 of the Code of Federal Regulations.  Requirements for generators of
hazardous wastes are most likely to be applicable to dry cleaners and are found in Parts 261.5
and  262.  These  requirements  cover the generation,  transportation,  and  management  of
hazardous wastes.  The authority  for these standards is derived from the Resource Conservation
and Recovery Act (RCRA).
                          ^

5.2    Applicability
       Dry cleaning facilities are typically regulated as  generators of hazardous wastes. (Most
dry cleaners are not subject to regulations governing the treatment, storage,  and disposal of
hazardous wastes.)  Applicability of hazardous waste requirements to generators is dependent
on the types  of waste generated, the amount  generated, and the length of time that they are
stored on-site.

      - Generators of wastes are responsible for  determining whether the wastes are hazardous
or not (40 CFR 261.11).  Wastes can be regulated as hazardous if they are listed as such (40
CFR 261..31-33) or if they exceed certain levels of ignitability, corrosivity, reactivity, or toxicity
(as defined hi 40 CFR 261.21-24).  Dry.cleaning facilities typically generate wastes hi the form
of cooked  powder  residues, still bottom residues, and spent cartridges.   These wastes are
collectively listed as"-a single type of hazardous waste. They are all perc-based arid have an EPA
Hazardous  Waste Number of F002.  In addition, dry cleaners may occasionally dispose of
unused perc (including spill residue  or materials used to clean spills). Unused perc is listed as
hazardous waste U210.  .                                  '
                                          47

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             Table 4.  Size Category Determination for Applicability of EPA
                              Hazardous Waste Regulations
Amount of Perc Waste Generated Per Month
Perc waste ฃ 220 Ibs (100 kg)
220 Ibs (100 kg) < Perc waste < 2,200 Ibs (1,000 kg)
2,200 Ibs (1,000 kg) :ฃ Perc waste
Size Category
Conditionally exempt small quantity generator
(CESQG) • •
Small quantity generator (SQG)
Large quantity generator (LQG)
       Applicability  of standards for generators  of hazardous  wastes  are  dependent oil the
 amount of waste generated (see Table 4),  The weight limits are the same for most listed wastes,
 including perchloroethylene.  Conditionally exempt small quantity generators (CESQGs) must
 generate less than or equal to 220 pounds (100 kg)3 of perc waste per month (40 CFR 261.5).
 A small quantity  generator (SQG) is one that generates more  than 220 but less than 2,200
      ป                           *
 pounds (100 and 1,000 kg)3 of waste per month (40 CFR 262.34, 262.44).  A large quantity
 generator (LQG) is one that generates 2,200 or.more pounds3 of waste per month. Dry. cleaning
 facilities  will  ordinarily -not generate  enough  perc  to  be placed  in this  last  category.
 Consequently,  requirements for LQGs are not detailed in this  manual.  They  are  however,
 included in the hazardous waste regulations summary chart (see  Table 5).             .
                                               *
       Each size category is also provided with limits on the length of time that they are allowed
 to store hazardous waste before it must be removed for disposal or treatment. These  limits are
 as follows:
          CESQG:  May store up to 2,200 Ib (1,000 kg)3 of hazardous waste on-site, with no
          time limit.
          SQG:  May store up to 13,200 Ib (6,000 kg)3 of hazardous waste on-site, for lip to
          180 days. (40  CFR 262.34(d)).  A facility that must ship the waste over 200 miles
          (320 km)' for  treatment, storage, or disposal is allowed to store waste for up  to 270
          days (40 CFR 262.34(e)).
   3 A useful rule-of-thumb is that a 55-
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Table 5.  EPA Hazardous Waste Requirements for Dry Cleaners
Requirement
Category of Hazardous Waste Generator
Conditionally Exempt
Small Quantity
Generator (CESQG)
Small Quantity
Generator (SQG)
Large Quantity
Generator (LQG)
General Requirements
Determination of whether
waste is hazardous
EPA I.D. Number
Personnel Training
Contingency Planning and
Emergency Procedures
Required
Not federally required
X
Not federally required
Not federally required
Required
Required
Employees must be familiar
with proper waste handling
and emergency procedures
Basic plan required
Required
Required
Hazardous waste handling
training program required
for all employees
Full plan required • •
(40 CFR 262.34(a)(4))
Waste Storage Requirements .
On-Site Storage Quantity
Limit • .
On-Site Storage Tirrie
Limit (Without Being
Regulated As TSDP)
Satellite Accumulation of
Waste
Storage Maintenance
Requirements
ฃ 2,200 pounds
(1,000kg)
No limit
Not applicable
Not federally required
•'ฃ 13,200 pounds
(6,000kg)
<ฃ 180 days OR
< 270 days if TSDF- is over
200 miles away (storage in
tanks or containers only)
^ 55 gallons
Partial compliance with
technical standards under
Part 265 for storage tanks
and containers
No limit
< 90 days (storage in
tanks or containers only)
^ 55 gallons
Full compliance with
management of tanks,
containers, and drip pads
Transporting Requirements
Packaging, Labeling,
Marking and Placarding
Requirements
Uniform Hazardous Waste
Manifest
Exception Reports
Type of Facility Required
for Offsite Management of
Waste '
- . • 's-.
Land Disposal Notification
Requirement
Not federally required
Not federally required
Not federally required
State-approved solid waste
facility or RCRA
permitted/interim status
hazardous waste facility
Not federally required,
In accordance with
applicable DOT regulations
Required
Report missing manifest
return copy within 60 days
of transporter accepting
waste ,
RCRA permitted/interim
status hazardous waste
facility
Required
In accordance with '.
applicable DOT.
regulations
Required
Contact transporter and
TSDF within 35 days of
transporter accepting waste
to determine status; submit
report within 45 days ,
RCRA permitted/interim
status hazardous waste '
facility
Required
v
                           49

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      TableS. EPA Hazardous Waste Requirements for Dry Cleaners (Continued)
• Requirement
Category of Hazardous Waste Generator
Conditionally Exempt
Small Quantity
Generator (CESQG)
Small Quantity
Generator (SQG)
Large Quantity
Generator (LQG)
Recordkeeping Requirements
Copy ซ*•' manifest.
Copies of biennial report
Records of waste analyses
Not *2Jerally required
Not federally required
Not federally required
Maintain copies for 5 years
Not federally required
Maintain for 3 years after
last shipment of waste
Maint2-n copies for 3
years
Maintain copies for 3
years (40 CFR 262.41)
Maintain for 3 years after
last' shipment of waste
Treatment, Storage and Disposal Facility ^                                .                   •

       A CESQG that exceeds its quantity storage limit will be categorized as an SQG (40 CFR;
261.5(g)), while an SQG .facility that exceeds its quantity limit will typically be categorized as
an LQG.  An SQG facility that exceeds its time limit, on the other hand, will be classified as
a hazardous waste treatment, storage and disposal facility and will be subject to all applicable
regulations as such, including permitting requirements (40 CFR Parts 264, 265, 270). However;
under circumstances that are beyond the control of the generator, an extension of up to 30 days
may be granted at the discretion of the. EPA Regional Administrator.  •

5.3    General Requirements
EPA Identification Number (40 CFR 262.12)
       Each  SQG must, obtain an EPA identification  number.  This can be obtained by
completing and submitting the Notification of Hazardous Waste Activity (EPA  form 8700-12).
CESQGs are federally exempt from this requirement but may be required by their State to obtain
a number.        •

Preparedness andJPrevention (40 CFR 262.34(d]i(4))
       SQGs are required  to comply with Subpart C of Part 265, which contains requirements
for preparedness and prevention  of  accidents in.facilities  with hazardous  wastes  on-site.
Requirements applicable to dry cleaners include the following:
                                          50

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       •,  Facilities must'be equipped with an internal communications or alarm system (such
          as an intercom) and a device .with which to summon outside emergency assistance
 .         (such as a telephone or two-way radio)                   •

       •  Adequate aisle space must be maintained to allow the unobstructed movement of
          emergency  personnel and equipment

       •  Arrangements must be made to familiarize police,  fire departments, and emergency
          response teams with the layout arid operation of the facility.


Contingency Planning and Emergency Procedures (40 CFR 262.34(d)(4),(d)(5))

       SQGs are required to observe the following requirements:
          One.employee must be designated the emergency coordinator on-site or on call at all
          times to be available to respond to an emergency and coordinate emergency response
          measures.                 .                                     ''•'•'•

          The following information must be posted next to the telephone:   the name  and
          telephone number of the emergency coordinator, the telephone number of the  fire
          department "(unless  the  facility has  a  direct alarm)  and the location  of all  fire
          extinguishers,  spill control material and, if present, the fire alarm.

         .The generator must ensure that all employees  are thoroughly familiar with proper
          waste handling and  emergency procedures that  are relevant to their responsibilities.

          The emergency coordinator must respond to emergencies as follows:

          -  In case of fire, call the fire department or attempt to extinguish the fire using a .
             fire extinguisher.                :.••••-'

          -  Contain any spills to the extent possible  and  clean up the hazardous waste  and
             contanlinated materials and soil as soon as possible.

          -  In case of a fire,  explosion,  or  pther release that could threaten human health.
             outside the facility, notify the National Response Center  at their 24-hr toll  free
             number (1-800-424-8802).  This.report must include:

             —  The name, address, and EPA ID number of the generator
          .   ~  The date, time and type of incident (e.g., spill or fire)
             —  Quantity and type hazardbus wastes involved in the accident
             —  Extent  of any injuries
             -  Estimated quantity and disposition of recovered materials.
                                          51

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      .  CESQGs are  federally  exempt from these requirements  but may be subject to  State
 requirements. In any case, all generators of hazardous waste are strongly encouraged to develop
 a contingency plan to respond to emergency situations.

 5.4    Waste Storage Requirements
 Satellite Accumulation (40 CFR 262.34(c))
        Satellite accumulation of wastes takes place at or near the point of waste generation, and
 is not included  in determination of compliance with on-site  storage weight and tune limits,
 provided certain conditions are met:

        •   SQGs may accumulate no more than 55 gallons of hazardous waste in a container at
           or near the point of generation                           .              .
        •   The container must be kept closed except for adding waste and marked "Hazardous
          •Waste," or must otherwise identify  the contents of the container
       •   After the 55 gallons has been accumulated, the container must be dated
       •   The generator then has 72 hours to move the container to the designated storage area
           for hazardous wastes.

       Requirements  for satellite accumulation do not apply  to CESQGs, since they are not
subject  to on-site storage limits.             •

Storage Maintenance Requirements (40 CFR 262.34(d))
       Dry cleaning facilities will generally store their wastes in drum containers:  Storage of
waste is subject to additional EPA regulations that ensure safe and proper handling of wastes and
maintenance of containers.
                 ^-                                 .-
      SQGs that store their wastes hi containers must  comply with Subpart  I of 40  CFR
Part 265 except for sections 265.176 and 265.178. Applicable requirements for dry cleaners are
as follows:                    •                         '            -  .
                                           52

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       _ป  Containers must be in good condition,  compatible and non-reactive with the waste
          stored, and should be kept closed except when it is necessary to add or remove waste
       •  Storage areas should be inspected at least weekly for leaks or deterioration
       •  Each container must be clearly marked  with the date that the container is filled and
          designated for disposal/treatment
       •.- Each container must be clearly marked  with the words  "Hazardous  Waste."
       SQGs that store their wastes  in tank systems must comply with 40 CFR 265.201.
However, these requirements will not ordinarily apply to dry cleaning facilities.
               J                        .     ,                         *

       CESQGs are federally exempt from these requirements  but  may be subject to State
requirements.

5.5    Pre-Transport Requirements
             j                          -                             '
Packaging, Labeling, Marking, and Placarding (40 CFR 262.30-33)
       Before transporting each shipment of waste, generators must package, label, mark, and
placard their  wastes in accordance with the applicable  Department of Transportation (DOT)
regulations.  Requirements include:            '.:.''

       •   Writing the manifest document number on each drum  label.
       •   Labeling.all drums with the 4-inch DOT POISON label.
       •   Marking all drums with the proper DOT shipping name and number.
       •   Each drum of. 110 gallons  or less should  be marked with  the following words and
          information in accordance with the marking requirements hi 49 CFR 172.304:
          -  HAZARDOUS WASTE—Federal Law Prohibits Improper Disposal.  If found,
             contact the nearest police or public safety authority or the U.S. Environmental
             Protection Agency.      .
          -  (Generator's Name and Address).
          -r  (Manifest Document Number).                                   ..
                                         53

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           Ensuring that the transporter uses the proper 10%-inch DOT POISON plaqard on all
           four sides of the truck that hauls away the waste.
       For more detailed information on pre-transport requirements, refer to the applicable DOT
 regulations on packaging (49 CFR Parts 173, 178, 179), labeling (49 CFR Part 172. Subpart E),
 marking (49 CFR Part 172, Subpart D), and placarding (49 CFR Part 172, Subpart F).

 5.6    Transporting Requirements (applicable to generators)
 Manifest and Exception Reporting (40 CFR 262.20-23, 42)
       All SQGs are responsible for ensuring that each shipment of hazardous waste originating
 from their facility  arrives at its intended destination. Under the Comprehensive Environmental
 Response, Compensation, and Liability Act (CERCLA, or Superfund), generators are potentially
 liable for any mismanagement of their hazardous waste.  The required  tracking tool is the
 Uniform Hazardous Waste Manifsst,(EPA form 8700-22). This is a multi-copy form which must
 be signed by the generator,  the transporter and the operator of the disposal or treatment facility,
 effectively tracking each shipment from "cradle to grave." Upon receipt of the waste shipment,
 the recipient will'return a signed  copy of the manifest to the generator, which serves as
 notification to the  generator that the waste has arrived safely.

       If the return copy of the manifest form  is not received by an SQG within 60 days of
 shipment, the SQG must submit an Exception Report to the EPA Regional Administrator, which
 must  include a legible copy of the manifest with some indication that the generator has not
 received confirmation of delivery.  It. is also  recommended that the generator, contact the
 transporter and/or  the operator of the disposal/treatment facility to determine the status of the
 waste shipment.
                  i—
       CESQGs are not federally  required to use the manifest form to track their waste
shipments, but may be required to do so by the State.  In any case, it is a recommended practice
for all generators.
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 Disposal/Treatment Facility (40 CFR 261.5(g)(3))
        SQGs are required to send their wastes to  a  RCRA-permitted facility.  CESQGs are
 allowed to send their wastes to  either  a municipal solid waste facility or a RCRA-permitted
 facility, unless otherwise regulated by State requirements.                 •            .
                                '•                                                  t-
 Land Disposal Restrictions Notification (40 CFR 268.7)
        Part 268 of Title 40 CFR  contains certain restrictions on -land disposal of solid and
 hazardous-wastes that can be safely treated or disposed of by other means.  Disposal of perc
 wastes is subject to these restrictions. Under Section 268.7, generators are required to provide
 receiving facilities of each hazardous waste shipment with a land disposal restriction notification.
 The notification is subject to the  following requirements:                           ,

        •  It must include  the EPA hazardous waste  number, the corresponding treatment
           standards (as detailed  in 40 CFR 268.7(a)(l)(ii)), the manifest number of the waste
-           shipment, and any waste analysis data that are available
        •  It must be signed by the generator
        •  A copy of the notification must be filed with the associated  manifest copies.

 CESQGs are federally  exempt  from  this requirement but should comply  with .any State
 regulations regarding land disposal restrictions.

 Self-Transporting of Hazardous Wastes
        EPA regulations allow generators to transport their own hazardous wastes..  They must,
 however, obtain an EPA transporter identification number and comply with all  applicable DOT
 regulations.  EPA requirements  for transporters of hazardous wastes are found  hi 40 CFR
 Pah 263.         -                           '
                                           55

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5.7    Recordkeeping Requirements (40 CFR 262.40)
       Each SQG must keep the following records, available for inspection:1
       •  A copy of each manifest signed by the generator and the initial transporter must be
          kept for 3  years, or until the return copy is received from the destination site.  The
          return copy should be retained for 3 years  from the date the waste was accepted by
          the initial transporter.
       •  Copies of Exception reports should be- retained for 3 years from the due date of the
          report.
       •  Records of tests and waste' analyses conducted to  determine whether wastes are
          classified as hazardous must'be kept until 3  years after the waste is last sent for
          treatment,  storage, or disposal.
       •  The period of retention for all records are automatically extended during unresolved
          enforcement actions initiated by the EPA.
5.8    Hazardous Waste Treatment Regulations (40 CFR 265)
       As previously mentioned, most dry cleaners are not subject to requirements that apply
specifically to facilities that treat, store, or dispose of hazardous waste.  One issue that deserves
clarification, however, is the regulation of evaporators used to treat separator water containing
perc.     '

       Facilities that choose this method of handling separator water do not need to obtain a
permit for hazardous waste treatment and are not subject to the requirements hi 40 CFR 265..
EPA has determined that evaporation meets the RCRA definition of "wastewater"4 (40 CFR
260.10). Dry cleaners should check to ensure that evaporators are allowed under state and local
environmental regulations.
   'Letter from the Office of Solid Waste to Mr: William E.- Wisher of the International Fabricare Institute dated
June 2, 1993.
                                            56

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                                   CHAPTER 6
 EPA WASTEWATER REGULATIONS APPLICABLE TO PERC DRY GLEANERS

6.1   Applicability
               r     -            .                  •                '.
      The perc dry cleaning industry is subject to wastewater regulations enacted under the
authority of the Clean Water Act. Wastewaters generated by dry cleaners may include separator
water, vacuum water, and boiler blowdown. The only source of process wastewater that would
generally be of concern, because of the content of perchloroethylene, is the separator water.

6.2   Discharge to Septic Systems
      Generally,  wastewater from a  dry  cleaning facility is discharged to  Publicly Owned
Treatment Works (POTWs).  Discharge of perc wastes to a septic system is prohibited by the
Safe Drinking Water Regulations because of the high potential of contaminating a drinking water
aquifer.  See Chapter 7—EPA Underground Injection Control Regulations Which Apply. To Dry
Cleaners.                                          .

6.3   Direct Discharge to Surface Waters
      Any industrial facility that directly  discharges its wastewater into surface waters must
obtain a  National Pollutant Discharge Elimination System (NPDES) Permit. The NPDES permit
program under Section 402 of CWA protects surface waters of the United Sates from pollution   .
by wastewater discharges. It is unlikely that any dry cleaners  discharge directly to surface
waters.

6.4   Indirect Discharge to POTWs  '.'-,'
      Wastewater^discharged  to  POTWs consists  of domestic sewage and industrial and
commercial wastes (e.g., wastewater from dry cleaners) that are discharged indirectly to surface
waters via sewers.  Many POTWs are required through their NPDES permits to implement a
pretreatmeht program that provides for control of toxics and compliance with narrative and
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 numeric p'retreatment standards by its users.  A POTW's authority to implement this program
 is contained in its local Sewer Use Ordinance (SUO).

       Narrative pretreatment standards consist of general and specific prohibitions (40 CFR
 403.5) which apply to all discharges  to a POTW.  General prohibitions specify that pollutants
 introduced into POTWs by a nondomestic source (e.g, dry cleaners) shall not pass through the
 POTW or interfere with the operation or performance of treatment works, create problems with
 sludge disposal,  or cause health and safety  problems for plant workers from exposure to
 chemicals.                        ,                  •

       The specific prohibitions  prevent  the discharge of pollutants that cause, the following
 conditions:
       •   Fire or explosion hazard (including discharges with a closed-cup flashpoint below
           140ฐF)                .                                               •        .
       •   Corrosive structural damage (no pH <5.6 s.u.)
       •   Solid or viscous pollutants hi amounts which will cause obstruction of flow hi the
           POTW resulting in interference                        .    .               ,
       •   Any pollutant released hi a discharge at a flow rate and/or pollutant concentration
           causing interference        ....-'
       •   Heat causing inhibition of biological activity and temperatures at the treatment plant.
           exceeding 40ฐC'(104ฐF)                                              .
       •   Petroleum oil, nonbiodegradable cutting  oil,  or products of mineral oil origin in
           quantities that will cause pass through and interference  .
       •   Pollutants that result in the presence of toxic gases, vapors,  or fumes in the POTW
           that may cause acute worker health and safety problems
                  ซ^                                   '
       •   Trucked or hauled wastes, except at locations designated by the POTW.
       Numeric standards consist of categorical standards and local limits.  Categorical standards
apply to many types-of specific industries.(e.g., metal finishers), but there are no categorical
                                           58

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standards that apply to dry cleaners.  POTWs required to develop a pretreatment program must
develop local limits to implement the general prohibitions listed above.  Local limits are site-
specific numeric standards,  enforceable by  the POTW to ensure protection of the treatment
works and the receiving water body.  Local limits apply to all discharges to the POTW including
those from dry cleaners.
      f                                          "                 ->

        As part, of the pretreatment program, POTWs  are  required to  identify  significant
industrial users (SIUs) as defined in 40 CFR 403.3. Dry cleaners may be considered significant
based on their reasonable potential to adversely affect the POTW or to violate any pretreatment
requirements (e.g., through spills or slug discharges).   The regulations further require  that
POTWs  use a  control mechanism (i.e.,   permit) to ensure all applicable standards  and;
requirements are met  by the SIUs (40 CFR 403.8(f)(2)(iii)).  Typically, dry cleaning facilities
are not issued permits. However, dry cleaners should be aware of. the requirements and contact
the local POTW to determine the status of the facility.   Permits issued by  POTWs include
effluent limitations, monitoring and reporting requirements, as well as .standard and special
conditions.

       One of the reporting requirements, found at 40 CFR 403.12, that may be applied to a dry
cleaner facility through a permit is the submission of a report at least once every 6 months-
regarding the nature,  concentration and flow of the pollutants in the wastewater, based on a
sampling study and analysis.                         .
                                             '         ••*,'"-
       Additional reporting requirements that apply to all users of a POTW include:
          A requirement to notify the POTW, EPA, and State of any discharge to the POTW
          that would be considered hazardous if discharged hi a different manner.  A discharge
          of more than 15  kg per month of perc into the sewer would be considered a
          hazardons waste (as defined  in 40 CFR Part 261).   For  dry cleaners, this  is
          equivalent to 2.4  gallons of pure perc that may  enter the sewers as a result of
          accidental spills.•
          A requirement to promptly notify the POTW hi advance of any, substantial change in
          volume or character of pollutants in their discharge, including hazardous wastes.
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           A requirement to submit a notice of discharges including slug loadings immediately
           upon identification of such discharges that could cause problems to the POTW.
       Users subject to monitoring requirements must also comply with specific record keeping
 requirements and maintain the records for a' minimum of 3 years.  Such records  include:

       •   The date, exact place, method, and tune of sampling and the names of the person or
           persons taking the samples
       •   The dates the analyses were performed
       •   Who performed the analyses .
       •   The analytical techniques/methods used   '                                   ,
       •   The results obtained.            •                           ,
       For information on the specific local requirements, the inspector should contact the local
POTW.
6.5    Other Wastewater Handling Methods                          .
       Systems that can handle separator water without subsequent discharge include misters and
evaporators.  Use of these systems is not regulated under the Clean Water Act.  The use of.
evaporators to treat separator water has also been exempted from hazardous waste treatment
regulations (see Section 5.8).  Dry cleaners should check with State  and local agencies to
determine if any requirements exist regarding the use of misters and evaporators.
                                          60

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                                     CHAPTER 7
  EPA UNDERGROUND INJECTION CONTROL  REGULATIONS WHICH APPLY
                                To DRY CLEANERS

 7.1    Background        .
                  '         " '                         -  .                              *
       Dry cleaners which use cesspools or septic systems capable of handling the sole sanitary
 waste of more than 20 people per day,-or which use on-site disposal systems for the disposal of
 industrial  waste (different types  of Class V injection wells)  are subject to Federal or State
 underground injection control (UIC) regulations established under the Safe Drinking Water Act
 (SOWA).  A Class V injection well is a subsurface apparatus which meets the definition of an
 injection well and is used to emplace fluids above or into underground sources of drinking water
 (USDW).  EPA regulates all large household, commercial and industrial cesspools and-septic
 systems capable of serving more than 20 people no matter what they inject; excluded from EPA
 regulation are individual household cesspools  and septic systems serving less than 20 people
 which inject solely sanitary waste.                                                ,

 7.2    Applicability
       The Safe Drinking Water Act prohibits the injection of contaminants through wells which
 will  cause a public  water  supply system to  violate a national drinking water  standard or
 otherwise endanger public health or the environment.  A dry cleaning facility which disposes of
perc waste and other hazardous chemicals into a Class V injection well is hi violation of the Safe
Drinking Water Act and should close its on-site disposal system immediately. EPA regulations
applicable to Class V injection wells are found hi Parts 144 and 146 of Title 40 of the Code of
Federal Regulations  (Underground Injection  Control  Program).   EPA Class  V guidance
documents are under development.
                 ซ-:                           •                      '                  •

7.3    Discharge of  Industrial Wastes to On-Site Disposal Systems
       An on-site disposal system typically includes a septic .tank and fluid distribution system,
 or leachfield, which  relies on biological organisms  and gravity flow to treat and disseminate
                                          61

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solely sanitary wastewater.  Disposal of even small quantities of industrial wastewater into a
septic system is dangerous to the .environment in two important ways:  (1) industrial waste
contains harmful chemicals-which undergo minimal change hi a septic tank before entering the
subsurface environment and  ground water resources; and (2) the industrial waste may  also
destroy biological organisms  in the  septic system necessary for sanitary wastewater treatment.
Industrial waste  fluids washed down floor drams into dry wells or cesspools undergo even less
change before entering the ground.

       Pure perc, the most commonly used dry cleaning solvent, is denser than water.  When
this solvent is released to the ground, -it "sinks" below the water table and migrates down
through sandy aquifers and fractures in bedrock.

7.4   .EPA Class V Regulations and Guidance Applicable to Dry Cleaners
       EPA Class V regulations'and guidance applicable to dry cleaners focus on:      •
          Employing pollution prevention methods such as recycling, properly hooking into
          sewers, good housekeeping methods and best management practices, holding tanks
          and removal off-site, and waste minimization
          Reporting the location of all on-site disposal systems which receive industrial waste
          to the applicable State UIC program director
          Inspecting on-site disposal  systems to determine if they are being properly operated
          and  maintained^ and  if diey  are being used to dispose of perc waste  or other
          hazardous chemicals
          Evaluating the public health and environmental risk of the injection fluid or on-site
          system based on the .site and hydrogeological setting of the system
          Requiring analysis of injected fluids, ambient monitoring, additional soil or ground
          water sampling, as warranted
                  v.
          Closing those on-site disposal systems which receive perc waste and other hazardous
          chemicals or otherwise endanger public health, USDW, or the environment
          -  Requiring ground! water remediation, as warranted                 '
          -  Closing cesspools.                  '                  .
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Cesspools receive and discharge untreated solely sanitary water.  All States except Hawaii have
recognized the high risk posed by cesspools by, at a minimum, banning the construction of new
cesspools.

      ;EPA  considers  on-site disposal systems  which  receive perc  waste and hazardous
chemicals to be high-risk and associated with a large number of documented cases of ground
water contamination, and advises closing them wherever they are found.  The highest .priority
for closure are dry wells, cesspools and  septic systems  which  discharge perc  waste and
hazardous chemicals into aquifers in Wellhead and Source Water  Protection Areas, aquifers
which are hydrologically connected to drinking water aquifers and aquifers designated as  Sole
Source Aquifers or aquifers which support sensitive ecosystems •hi estuaries, coastal zones and
watersheds.                                 •

7.5    Inventory Requirements
       EPA directly regulates Class V wells  in 16 States,5 American Samoa, the Virgin Islands,
District of.Columbia and for all Indian Tribes.   In EPA jurisdictions, all dry cleaners  who
dispose of industrial waste in on-site disposal systems must, at  a minimum,  submit inventory
information to be in compliance with UIC regulations.  In addition, dry cleaners are required
to submit inventory information for cesspools and septic systems which are capable of handling
the sole sanitary waste of more than 20 people per day, even if perc waste or other hazardous
chemicals are not disposed in the system. In the other 34 States,. Guam, Puerto Rico and the
Commonwealth of the Northern Mariannas, dry cleaners are subject to applicable State UIC
regulations.               :    -
   .5Alaska, Arizona,'California,-Colorado, Hawaii, Indiana, Iowa, Kentucky,, Michigan, Minnesota, Montana, New
York, Pennsylvania, South Dakota, Tennessee, and Virginia.   '                .
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               64

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                                        CHAPTER 8
                 POLLUTION PREVENTION AND WASTE MINIMIZATION

          .Mi compliance by dry cleaning facilities with Federal, State, and local environmental
    Canons can go a ,ong way  towards reducing releases of perc to the air, water -anToU
    However, regulatory agencies primaruy have only
                 ot                                                       have been
                 ^ 'ฐ Pr08IeSS """ป ปซซ* •*ป <ซ— soal of improved environmental
      lty,, owners  of dry deaning plants should be encouraged to take the initiative
   nnplementing pollution prevention programs in their facilities.
                           ฐfa Cement sryle wi* an emphasis on waste minimization can

                          i'ieS fฐr  Pฐ"Uti0n PreVeMi0n' ^ ฐf ^ ซ**• ป*> or -
        a, mvestment.  Some  possibilities for pollution prevention in a dry cleaning plaM are •
  presented .„ t^s section. ^ are intended to be presented to dry cleaners no, as re^el
         suggest to be considered.   Individual faciHty owners are often best Jalified ,„
          the cos. and benefits of poUution prevention opportunities and in deci  in ^ h
  pracuces would be appropriate to implement.         -

  8.1    General Plant Management

•     ,  Owners  and operators  of dry. cleaning p,anB have me  opportunity to te me ,ead in
 nnp =men,,ng a  poHution prever-tion program in their facili*. Training aU employees in proper
 waste management procedures and in waste minimization opportunities can drastically reduce
 •he .chance of -spills and accidents. Al, emp.oyees should a,so know the proper procedure in
 wh,ch to respond „ a spU, or accident  Owners have, an incentive to reduce the potential risk
 of  accents and the  actual  damage caused,  since they can- be held legaUy ,iab,e  for
 envu-onmental damage caused by the operations in their facilities.     .
                                         65

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       Conducting a waste audit can reveal opportunities for waste minimization that otherwise
may not be  obvious.   Such a waste audit  can consist of tracking all usage of perC and all
resulting wastes to determine where perc losses are occurring and how they can be prevented.
A "solvent mileage" figure can be calculated to quantify perc losses.   This figure is generally
expressed as gallons of perc used per 1,000 pounds of clothes dry cleaned. Although it may be
difficult to determine the exact weight of clothes cleared, a reasonable estimate can be  obtained
from sales totals.  This estimate can be used to calculate solvent mileage on a monthly basis.

       Managers that are not aware of proper cost analysis methods often only consider initial
purchase prices when considering investments  hi new equipment.  However, when savings
resulting from the new equipment are totaled up, the machine may. pay for itself in as little as
3 years.  These savings include reduced perc purchases, increased customer satisfaction leading
to higher sales volumes, reduced waste management disposal costs, and reduced labor costs.

8.2    Operation and Maintenance Procedures
                                                       t
       Improved general operations in a plant can reduce perc losses and minimize wastes
significantly.  Many operation-related pollution prevention opportunities deal with leak detection
and prevention. Some ideas to consider are as follows:                        ,
          Seals and gaskets need  to be periodically  replaced even  if they are not actually
          damaged.  Rubber gaskets become brittle with age and no longer form a tight seal.
          Clean lint screens to avoid clogging fans and condensers.
          Open button traps and lint gaskets only long enough to clean them.
          Hand-held solvent detectors (see Figure 10) are now available that can detect lower
          concentrations of perc than can be detected merely by smell.  These solvent detectors
          can be used to perform the periodic leak inspections and to test clothes leaving the
          dryer to^nsure that all perc has been removed.
          Small leaks  can  be  difficult to  isolate.   Drip pans  can be placed below key
          connections in the dry cleaning machine'so that leakage will collect hi the pan and
          be identified., Cleaning  and painting the  floor periodically underneath the machine
          may also help to highlight drips.                    .             •.
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                      Figure 10.  Hand-held Solvent Leak Detector
                                                                  /             .
           Check air and exhaust ducts for holes and repair as needed..

           Check exhaust dampers, even if they are difficult to access directly.   Closed-loop
           dryers have an exhaust damper that closes to prevent dryer exhaust from being vented
           during  the  drying  cycle.   Malfunctioning dampers have  been a major source of
           fugitive emissions.  They must be checked periodically as part of the required leak
           detection program  to ensure that they are ctosing properly and not venting dryer
           process exhaust.  The easiest way to check it is by placing and sealing a collapsed,
           inflatable bag over a outlet point in the air duct" somewhere downstream of the
           damper.  If an appropriate outlet is not conveniently located, a small, resealable test
           hole can  also be drilled for this purpose.  A bag that can be inflated by the outlet
           during the drying cycle signifies that the damper is not closing completely and needs
           to be repaired.
       Other pollution prevention opportunities also exist.  Often these opportunities can only
be identified by inspecting the actual plant, but some are general common sense practices and
many require little or no investment. For example:
          Avoid on-site storage of unused perc.  There is no reason to do so if the plant is
          efficient^in terms of solvent mileage) and there is sufficiently frequent perc delivery
          in the area.   Perc can be dispensed directly from a delivery tank car to the dry
          cleaning machine.  Eliminating a perc storage area frees up more space in the plant
          and also reduces the potential for a spill/

          Keep hazardous spotting chemicals locked in a metal cabinet when not in use.
                                            67

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       •  Keep spotting materials in small, airtight, spillproof containers. After spotting, load
          clothes immediately into the dry cleaning machine.

       •  Label all raw materials to prevent unnecessary disposal.

       •  Keep tight lids and bungs on all containers to prevent evaporation and spills. .   .

       •  Use spigots and  pumps  when dispensing new materials  and use runnels when
          transferring wastes to storage containers to reduce the possibility of spills.  Spill-
          proof dispensing systems  are now available on the market.

       •  Never mix wastes together.  Mixing wastes can make recycling impossible or make
          waste disposal much more expensive.

       •  Provide secondary containment, such as concrete drip pads, in storage areas for perc
          and perc wastes.
                                                                                  v
       •  If in an earthquake prone area, store  containers in earthquake-proof containers or
          storage areas.
      *                                 . *             *                                •


8.3    Equipment Modifications                                       ?

       •  Eliminate the use of all transfer machines.   The transfer process, which exposes
          clothes to the atmosphere before they are dried, is a major source of perc losses.
          .Replacing all transfer machines with dry-to-dry machines will greatly reduce perc
          purchases in a plant.                                     •   "

       *  Installation of carbon adsorbers to reduce emissions vented during the aeration cycle.
          EPA regulations only require this for major sources but removal of aeration cycle
          perc vapors is also a pollution prevention opportunity in small and large area sources.

       •  Replace older or less  efficient equipment.  In some cases, it may be beneficial to.
          replace outdated equipment to take advantage of newer, more  efficient technologies.
          Apply ing proper cost analysis techniques to determine  the real costs  and benefits
          involved can help a facility owner make the correct decision as to whether to replace
          older equipment.


8.4    Process Modifications

       •  Recycle perc through distillation. This has not been required by EPA regulations but
          is widely practiced because significant cost savings hi perc purchases  and disposal
          costs makes it economically as well as environmentally beneficial.  Dry cleaners that
          •do not filter and distill their used perc need to be informed about the  potential cost
                                            68

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           savings.  Reductions in perc usage of up to 96 percent have been reported by dry
           cleaners.                    .
           Steam strip filter cartridges to  reclaim perc.  Steam stripping can recover more
           residual perc than simply draining the cartridges.  Draining cartridges also requires
           that the entire machine be turned off for 24  hours, which is a major inconvenience.
           New dry cleaning machines can be equipped  with steam strippers for convenient perc
           removal.
 8.5    Alternative Cleaning Solvents
        The popularity of perc stems  from its  non-fiammability  and its  excellent cleaning
 properties.   To  a much lesser extent, .a flammable petroleum distillate known  as Stoddard
 Solvent is also used in the industry.  Two other previously used .solvents (CFC-113 and TCA)
 have been used but have been identified as potentially harmful to the ozone layer and are being
 phased out by the Clean Air Act beginning  in 1995.

        Existing alternative solvents with adequate cleaning ability have all been found to be more
 toxic or harmful than perchloroethylene. Stoddard solvent and its derivatives, for example, are
 highly flammable.. Their use requires explosion-proof equipment. .In some places, their use may
 be prohibited  by the local fire department.  TCA, although non-flammable and available at low
 cost, is too aggressive as a cleaning solvent, and also contributes to, depletion of the ozone layer.
 To date, the "ideal" dry cleaning solvent has not yet been developed, but facility owners should
 be encouraged to keep informed about progress made in this area through national or regional
 dry cleaners associations.       .                              -   .   '  '    '

 8.6    Alternative to the Dry Cleaning Process
       The dry cleaning process was developed to  clean fabrics that cannot be immersed into
            '  •            •
 water without being damaged  in some way.  One-promising alternative to the dry cleaning
                  v.                                  '                        . •"
process is under development and deserves special attention. Multiprocess wet cleaning is a
method for hand cleaning clothes that  relies on a  controlled application of water and soaps.
Unlike both the dry cleaning and the home laundry processes, in which each piece of clothing
                                           69

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receives the same treatment, multiprocess wet cleaning applies one of several cleaning processes
to each individual garment depending on the type and condition of the fabric:

       •   Concentrated cleaning  for heavily soiled  garments, with a concentrated cleaning
           solution and a brush                    '                                •
       •   Extensive steaming, spotting and rumble drying      •
       •   Gentle handwashing of washable fabrics, followed by drip drying
       •   Tumble  drying only for unstained garments that simply need to be freshened.

Pressing and finishing procedures  remain the same as hi the traditional dry cleaning process.

       A preliminary  study  was jointly conducted hi  1992 by the EPA,  the Neighborhood
Cleaners' Association (NCA), the International Fabricare  Institute (IFI),  the Massachusetts
        ซ
Toxics Use Reduction Institute,  and Ecoclean  (the commercial. vendor of multiprocess wet
cleaning) to evaluate the performance and economic competitiveness of this process, compared
with perc dry cleaning.

       The study concluded that although multiprocess wet cleaning is more labor intensive, the
higher labor costs would be offset by lower costs for equipment and supplies and that overall
costs would be comparable.  An economic model showed that a facility dedicated only to wet
cleaning could actually be more profitable than a traditional dry cleaning facility.  Facilities that
utilized both wet and dry cleaning were also shown to be profitable as long as the dry cleaning
equipment was fully utilized.  Performance, rated by customer satisfaction, was  found to  be
equal to or better  than the dry cleaning process,  although further research is  necessary to
determine whether  garments can be repeatedly cleaned only by multiprocess wet cleaning.

                                              i
       Multiprocess, wet cleaning  is a promising alternative that has the potential  to eliminate
all solvent wastes from the professional garment cleaning industry.  Dry cleaners should be
aware of this alternative, keep abreast of future developments, and weigh the costs and benefits
of fully or partially converting then* operations to this process.
                                            70

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                                      CHAPTER 9
                               INSPECTION PROTOCOL

       The primary purpose of the multimedia inspection protocol for dry cleaning facilities is
to determine compliance with regulations that apply to air emissions, hazardous wastes,  and
industrial wastewater. , The inspection protocol also focuses on encouraging  and identifying
opportunities for pollution prevention and the application of innovative technologies, with the
overall objective of moving the facility beyond compliance to overall improved environmental
quality.           •               .    >  .

       The multimedia inspection will utilize a process-based approach in which the inspector
identifies noncompliance with any applicable media or program specific regulation (air, water,
solid waste).            '               .    ."•..-•

       This inspection protocol .serves as a guide for the field personnel that perform these
inspections, and includes procedures, an inspection checklist, and an example inspection report.
During this multimedia compliance inspection, the inspector should generally follow procedures
outlined in the EPA Basic Inspector's Training Manual.      .   -

       The following activities are part of the multimedia compliance  inspection protocol:

       •   Pre-inspection preparation
       •   On-site activities
          -  Opening conference/discussion
          '-  Facility walk-through
             —  Materials storage area
             —  Process areas
             ~  Waste management areas
             ~  Records review
          -  Closing conference/discussion       '
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       •  Preparation of inspection report                      ;
       •  Follow-up activities. • •        '                                       .

Each of these activities is briefly described in the inspection procedures discussed below.

9.1    Pre-Inspection Preparation
       The  inspector should review  any existing  information oti the facility including any
previous noncompliance problems.  Using the available information,  he/she should complete
Part 1, General Facility-and Management information, of the Inspection Checklist which covers
general aspects  of the regulatory programs to be covered during  this inspection (i.e., air,
hazardous wastes, wastewater).  This information can then be verified during the inspection.

9.2    On-Site Activities            .
9.2.1  Opening Conference/Discussion
       During the opening conference/discussion, it is important that the inspector point out that,
in addition.to the more traditional objective of compliance evaluation, the inspection focuses on
providing compliance assistance to the facility and identifying potential pollution prevention and
innovative technology opportunities. Thus, inspection questions will address raw materials used,
housekeeping procedures and process modifications as well as wastes generated.

       The inspector should verify the information in Part I, General Facility and Management
Information, of the checklist and obtain any missing information. These questions are intended
to obtain an overall general evaluation of the regulations that apply to the facility (including
whether the facility currently has any permits).
                                         '  ' ,    *
9.2.2  Walk-Through of Facility
       The  Inspection Checklist is designed to walk-through the facility  hi a process-oriented
manner, addressing these activities sequentially:      •
                                            72

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        •   General Housekeeping (including raw materials information)
        •   Dry Cleaning Process Areas            .          •
        • '  Waste Handling and Management
        •   Records and Files.                         •

        For each of these areas, applicable media-specific compliance questions  and pollution
 prevention, innovative technology and recycling questions are included in the checklist.
   *                  . '        '                                           .    •
 General Housekeeping/Materials Storage
        General housekeeping/materials storage is  a separate section of the checklist, although
 evaluation of  these activities  should be ongoing throughout the inspection of the-facility.
 Specifically, the-inspector should be observing operation and maintenance and  housekeeping
 throughout the facility walk-through hi the storage areas, process areas, and waste management
 areas.  The walk-through of the facility should begin at the receiving area and storage area for.
 raw materials.         /
                                 •s

 Dry Cleaning  Process
   .    For each process or activity listed in .the checklist,  the  inspector should verify the.
 following for each process or activity (using the checklist questions):

       •   Description of process and equipment used        >;
       •   Types and amounts  of materials used             .         .
       • t  Types and amounts  of wastes generated
       •   General condition.                                                 .

The checklist contains  notes  for  the inspector regarding' compliance issues with respect to
individual wastes.
                                           73

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       For each type of waste generated by the process or activity, the inspector should inquire
about general or specific pollution prevention techniques and innovative technology as presented
in the checklist.                                                    .

       When  inspecting the process  or activity  areas, the  inspector should document any
evidence of noncompliance that presents an imminent threat to human health or the environment
(e.g., leaks or spills of hazardous materials).  He/she should take immediate action to notify
(1) the facility of the situation and (2) the appropriate program office for follow-up action.

       The checklist is meant only as a guide for questions,  and the inspector should ask any
other questions to obtain additional information or clarify answers.

       Waste Handling and Management                                            .
       The waste handling and management section of the checklist is organized by type of
waste being managed and includes wastewater, air emissions, and hazardous wastes.  This part
of the inspection  will  generally involve hazardous wastes  storage containers,  wastewater
treatment equipment, and air pollution control equipment.

       For the:waste  handling  and  management areas,  the  inspector should examine  the
following (using the appropriate checklist questions):

       Air and Wastewater   "
       *   Any existing permits and permit requirements
       *   Type of treatment process                                .       -  •     .
       •   Condition of treatment equipment
                 tป                                 •
       •   Any wastestreams discharged to the atmosphere, or to a sewer or an on-site disposal
          system
       •   Any instances of noncompliance.
                                           74

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       . Hazardous Wastes

       •   Any existing permit (if classified as a storage facility)

       •   Condition of storage containers and storage area
       •   Length of storage

\  .    •   Waste transportation

       •   Any noncompliance.


       The inspector should identify any media transfer of wastestreams resulting from pollution.
control/management  practices  (e.g., generation of  sludges  from wastewater treatment  or
generation of scrubber water from air pollution control equipment).              '


Records and Files                                              ,

       Evaluation of these areas will also involve records review. For example, if a facility has

a wastewater permit, the inspector should review the.permit for  selected requirements (e.g.,

limited parameters and self-monitoring frequency) and then  assess  compliance with  these

requirements. All violations should be documented.  The sections in the checklist that will likely
require records review are appropriately marked.


9.2.3  Closing Conference/Discussion

       As part of the closing conference/discussion, the inspector  should do the following:
       •  Convey the results of the inspection to the facility including all obvious violations
          noted.  However, inspectors should.refrain from  discussing monetary penalty
          amounts,  or whether  penalties will be assessed for  any  violations noted.
          Inspectors should also make the facility representative aware that any decision
          with regard to a particular violation is subject to confirmation after evaluation
          of the inspection findings by appropriate EPA .program  offices.
                 t-                •'••-.                           -
       •  Clarify information obtained and  ask any outstanding questions.

       •  Discuss  in general potential pollution  prevention and   innovative   technology
          opportunities.              .                      •
                                           75

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          Some pollution prevention opportunities may require expenditures for new equipment.
          Although it is difficult, especially for smaller facilities, to purchase expensive new
          equipment directed primarily at reducing wastes, the inspector should identify indirect
          advantages, either tangible  or intangible, whenever possible  or applicable.   For
          example:                                              '

          -  Process improvements may reduce worker risk and facilitate compliance  with
              OSHA regulations

          -  Reduction in perc usage saves the dry cleaner money

          -  Reduction hi waste generation will also reduce the costs of waste disposal

          -  New cleaning machines  can improve  the quality  of  the dry cleaning service,
              resulting in increased customer satisfaction and fewer  returns for recleaning

          -  Improved image in community can result from improved environmental practices.

       *  Distribute  general or dry cleaning specific compliance assistance literature.

       •  Distribute  general or dry cleaning specific  pollution prevention or innovative
          technology literature.

       •  Distribute  list of selected references.

       •  Provide contacts at appropriate agencies that give compliance or technical assistance
          (e.g., hotlines, technical assistance offices).


       The inspector should communicate to the facility that all results are preliminary until the

follow-up review is completed.                            •             .
9.3    Preparation of Assessment Report

       After the inspection,  the  inspector should  complete the assessment report form in

Appendix B.   This form contains  sections for results of  both compliance assessment  and

identification of pollution prevention, and innovative technology opportunities.
Compliance Assessment Sections
       The inspector  should note any  actual and  potential violations identified during the

inspection.                            ,  •                        .                  .    -
                                            76

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 Pollution Prevention Sections
     ,  The inspector should at a minimum provide a list of opportunities identified based on the
 checklist questions.  However, the checklist questions do not. cover the full range of pollution
 prevention opportunities for a dry cleaning facility.  If the inspector has additional time and the
-appropriate references (such as those listed in Appendix E), he/she can identify other potential
 opportunities that can be listed in the inspection report.

 9.4    Follow-Up Activities
       After the inspection, the inspector will be responsible for recommending the follow-up
 actions that should be taken. At a minimum, the inspector should provide a report to the facility
 (example report form shown in Appendix B) that contains a compliance assessment with a list
 of actual or potential violations  and a  list of pollution prevention opportunities (including
 innovative technology). Additional potential follow-up actions to be taken include the following:

       •  Referral to specific program office for comprehensive follow-up inspection
       •  Referral t;o technical assistance office for follow-up assistance   .
       •  Follow-up inspection to determine if facility has implemented pollution preventioij
          techniques.

       After conferring .with his/her supervisor, the inspector may take  one or more of these
actions as per State policy depending on the particular findings of the inspection. In some States
there are special programs targeted at dry cleaning facilities.  In some situations the inspector
may decide  that it is appropriate to refer the facility to a media-specific program office because
violations that could potentially pose a significant risk to human health or the environment were
found during the inspection. In any case, the appropriate follow-up actions should be determined
                                                 i                           .
in coordination  witfo the inspector's supervisor and applicable enforcement policies.
                                            77

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             APPENDIX A

MULTIMEDIA INSPECTION CHECKLIST FOR
       DRY CLEANING FACILITIES

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                              TABLE OF CONTENTS
I.    GENERAL FACILITY AND MANAGEMENT INFORMATION		. . . A-l

     A.   General Facility Information	 A-l
     B.   Facility Management .	; . . . A-2

II.   DRY CLEANING PROCESS AREA  ..... .'		.		.A-3

     A.   Dry Cleaning General Equipment Information . . . .	 A-3
 -    B.   Refrigerated Condensers Performance Monitoring	.'........	 A-4
     C.   Carbon Adsorber Performance Monitoring (complete if carbon adsorbers are used)   ....A-4
     D.   Leak Detection	;........,....-	 A-5
     E.   Miscellaneous Operation and Maintenance	 A-6

III.   PERC AND PERC WASTE HANDLING AREAS  . .	 ...	 . A-6

     A.   Perc Storage and Dispensing .	...............	A-6
     B.   Satellite Waste Accumulation Area  ......:..	...........:	A-6
     C.   Hazardous Waste Storage Area  . .	...."..	 . A-7
     D.   Hazardous Wastes  Shipping  . . .	 . . . .	: . . .  . . . . A-8
     E.   Wastewater Management	 ,	 .-.. . -. . A-8

IV.   RECORD'S AND FILES  INSPECTION ...	. .	 . .	: . . . A-9

     A.   Reporting	 . . .	 . . A-9
     B.   Recordkeeping	 .	 . A-10
V.
ADDITIONAL COMMENTS					 A-12
                                       A-i

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           MULTIMEDIA INSPECTION CHECKLIST FOR DRY CLEANING FACILITIES

I.    GENERAL FACILITY AND MANAGEMENTINFORMATION

A.   General Facility Information                               .'•.-••

1.    Date of Inspection	:	

2.    Facility Name:                              	••	—	—

3.    Facility Telephone Number:                   —_	

4..   Facility Address (physical location);           ,	-^	:—-	•-	
5.   -Mailing Address (if different):
6.   Facility Owner Contact Information
     (Name and phone):
7.   Facility Operator/Manager '(if different
     from owner) (Name and phone):
     Inspector(s):

     Name.


     (1)	
Titlft/Affiliarinn
Phnnp. Niirnhp.r
      (2)-
      (3)-
9.    Original establishment date of facility:
                                              A-l

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Multimedia Inspection Checklist
10.   Establishment date of current ownership:

11.   Establishment date at current location:

12.   Is a new.annual perc consumption level calculated on the first of each month reflecting usage for the past 12
      months?                  ,             '               .                            Yes [ ]   No [  ]
      Record most current annual perc consumption:
        Gallons:  	
        From    •      (month, year) to	
(month, year)
        Date calculated:
 13.   Size categorization of facility under federal air emissions regulations (based on. information in Question 12):

      [   ] Small area source,             .               .                  .       ,
      [   ] Large area source    ,
      [   ] Major source

 14.   Size categorization of facility under federal hazardous waste regulations:           ,        .     '.

      [   ] CESQG
      [   ] SQG ••                           '                       '        •
      [   ] LQG     '.    ' '    .                 • '     -                                 .
 15.   Does the facility have an EPA ID # as a generator of hazardous wastes?

      EPAID#:         ,          '                             •

 16,   Does the'facility discharge was'tewater into a municipal sewer?
                                             \        .
      Name of POTW:                 •
      Permit # (if applicable):            .

      If not, please explain.                   '      ..           •
                                  Yes [  ]  No [  ]
                                  Yes [  ]  No [  ]
B.    Facility Management

17.   Is the dry cleaner a member of a trade association?

      If so, *name of association: .	!	  •.
                               .    Yes[  ]   No[
      If not, ensure that the dry cleaner is aware of the role of trade organizations in providing compliance assistance.
      Distribute national or local trade association literature as appropriate to serve as initial contact points.

 18.   What types of training activities are conducted'at the facility (include safety,  emergency procedures, and
      pollution prevention programs)?         .                             •
                                                  A-2

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Multimedia Inspection Checklist
19.   Has a pollution prevention or waste minimization plan been developed by the facility?

      If so, describe:
                                                                                     Yes[  ]  No[
20.   Has the facility evaluated which wastes are probable candidates for reductions through pollution prevention
      activities?         ,                                '                              Yes [  ] . No [  ]

      If so, list the wastes and describe pollution prevention activities currently being undertaken.
21.   Is the facility owner familiar with multiprocess wet cleaning?
    .  Has the, facility considered experimenting with multiprocess wet cleaning?
                                                                                      Yes [  ]  No [  ]
                                                                                      Yes[  ]  No[  ]
•II.   DRY CLEANING PROCESS AREA
       '
A.   Dry Cleaning'General Equipment Information

22;   Supply the following information about the dry cleaning machines in use at the facility:
#
1
?.•
1
Type1



Date
Installed



New or
Existing



Manufacturer
and model
number



Perc filtration
system (s)"



Perc vapor
recovery
system'"



Installation date of .
perc vapor
, recovery system


'
 'Dryrto-dry (D) or Transfer (T)
 "List all types of filters used
 "Refrigerated condenser (RC) or carbon adsorber (CA)
 23.   New transfer machines are no longer allowed.  Is the facility in compliance?
                                                                                      Yes[  ]   Not  ]
 24.   If existing transfer machines are used, has the facility performed a thorough cost analysis to determine what the
      payback period would be on the purchase of a dry-to-dry machine?                     Yes [  ]   No [  ]

 25.   Existing transfer machines in major sources must be surrounded in a room enclosure by September 23, 1996.
      Is the facility in compliance?                   .     ,      .                        Yes [  ]   No [  ]

 26.   Were 'any carbon adsorbers that are used as perc vapor recovery systems for drying process vapors installed
     , before September 22, 1993?                               /                 '        Yes [  ]   No [  ]
27.   Does the facility use a carbon adsorber as a residual perc recovery system to vent aeration Yysl|
                                                                                                    [  ]
                                                  A-3

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            Inspection Checklist
B.    Refrigerated Condensers Performance Monitoring

28.   Are  temperature  sensors  for  refrigerated  condensers installed  for  each machine in accordance  with
      manufacturers' specifications?                                                     : Yes [ ]   No [  ]

29    Are temperature sensors for all machines designed to measure temperatures from 32ฐF to 120ฐF to an accuracy
      of ฑ2ฐF?                                                                    -   Yes[ ]   No[  ]

30.   Record temperature sensor readings if available:
Temperature Sensor
(a) Dryer airstream at condenser outlet (ฐF)
(b) Washer airstream at condenser inlet (ฐF) '
(c) Washer airstream at condenser outlet (ฐF)
(d) Washer airstream net temp, drop {(b) - (c)} (ฐF)
(e) In compliance? (Y/N) ' '
Machine
#1





Machine
#2



.' •• •,

Machine
' #3





Criteria for
compliance
Less than or equal to ,
45 ฐF
none
none
At least 20ฐF

 C.   Carbon Adsorber Performance Monitoring (complete if carbon adsorbers are used)

 31.   Are sampling ports for carbon adsorbers properly located in accordance with  federal • regulations (8 duct
    •  diameters downstream and 2 duct diameters upstream of any flow disturbance)?          Yes [  ]   No [  ]
 32.   Are they kept closed when not in use?
Yes[
No[
• 33.   Indicate the established period desorption schedule for each machine (as necessary,, as- indicated'by tests, but at
      least weekly).  Note the date when each adsorber was last desorbed and measure the perc concentration in the
      exhaust with a colorimetric detector while die drying cycle is on. (Note: It is important to .note that the perc
     . concentration should usually be measured at the end of a use cycle, just prior to desorption.  A measurement
      taken at any other time only ensures that the adsorber is in compliance at that time, not necessarily for the
      duration of the'use cycle. However, given time and logistical limitations, inspections schedules generally cannot
      accommodate desorption schedules for each machine.
Machine
' #
1
2
3
Indicate Periodic
Desorption
Schedule1






Date Last
Desorbed






Measured Perc
Concentration in
Exhaust Airstream





•
Use of Carbon Adsorber
(A,B, or C as indicated by
table below)11






Perc Concentration
Limit (as indicated by
table below)11






                                                   A-4

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 'Indicate schedule specifics (day of week, etc.)
                                                       A-5

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Carbon adsorber is used:
As main perc vapor recovery system
As residual vapor recovery system (tested during aeration while
the door is open) '
As residual vapor recovery system (tested during aeration while
the door is closed)
Indicate with
A
B
C
Perc Limit (ppm)
100
100
300 :
D.    Leak Detection

34.   Is the odor of perc readily detectable anywhere in the facility?

      If so, where?
Yes[  ]   Nd[
35.   Is the leak detection program conducted weekly or biweekly as required?
Yes [  ]   No [  ]
36.   Allow owner or designated representative to guide you through the facility and demonstrate procedures for the
      weekly/biweekly leak detection inspection for each machine.  The inspection should include the items listed
      below. Tabulate results and record any leaks detected.

      Inspection done by:                    x

   ,  [  ] Sight, smell, and feel                                                '               •      '
      [ -  ] Monitoring instrument (Type: 	i_	:	;	:—	'—	)
#
1
1
3
. 4
5
6
7
8-
9
10
.11
Components:
Hose & pipe connections,
fittings, couplings, valves ,
Door gaskets & seatings
Pumps
Solvent tank & containers
Water separators
Muck'cookers'
Stills , ..
Exhaust dampers
Di verier valves
Filter gaskets and seatings .
Cartridge filter housings
Signs of Leaking (Y, N, n/a)?
Machine
#1


/








Machine
#2











Machine
#3







i


.
Explain all "Yes" answers:

*






-
-

                                                   A-6

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Multimedia Inspection Checklist
37.   Are seals and gaskets periodically replaced before they become brittle?


38.   What type of solvent leak detection systems are in use?



39.   What other methods does the facility use to detect leaks? (e.g., drip pans, etc.)



40.   In transfer machines, is the exhaust damper easily accessible?
 -Yes[  ]   Np[
  Yes [  ] .  No [  ]
      If not, is there a suitable outlet downstream for testing the proper closure of the exhaust damper?

                 ."••'.                         •                                 Yes [  ].  No [ ]
E.    Miscellaneous Operation and Maintenance


41.   Axe all machines operated as per manufacturer's specifications and recommendations?




42.   Are machine doors kept closed except when transferring clothes?     ,        •


43. .  Are all spent cartridges drained at least 24 hours before disposal?


      Alternatively, are they steam stripped before disposal?




III.   PERC AND PERC WASTE HANDLING AREAS

               f               •                                                   .
A.    Perc Storage and Dispensing                            .   '


44.   Is perc stored on-site?


      If so, is all perc stored in tightly sealed containers and free from leakage?


45.   How frequently is perc delivery available?
Yes[


Yes['


Yes[
            No[


            No[-


            No[
  Yes[  ]   Not ]
  Yes[  ]   No[


  Yes[  ]   No[
46.   How is perc delivered to the dry cleaning machines?
B.    Satellite Waste Accumulation Area                        •


47.   Do satellite waste accumulation areas contain less than 55 gallons of accumulating wastes?
48.   Are all full containers sealed and dated less than 3 days (72 hours) ago?
  Yes[  ]   No[  ]


,  Yesf  ]   No[  ]
                                                  A-7

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Multimedia Inspection Checklist
49.   Are all containers tightly closed and free from,leakage?

50.   Are all containers clearly marked as hazardous waste?
                                                       Yes [  ]   No [ ]

                                                       Yes[  ]   No[ ]
C.    Hazardous Waste Storage Area

51.   Are all containers tightly closed and free from leakage or deterioration? .

52.   Are all containers clearly marked as hazardous waste?
                                                       Yes'[  ]   No[  ]

                                                       Yes [  ]   No [  ]
53.   Do all containers bear a date representing Ihe day the container was filled and designated for disposal/treatment?
                                                            ..-";•'.'.'   Yes[  ]• No [•].-

54.   Are all the dates on the containers hi compliance with on-site waste 'Storage time limits for generators of
      hazardous wastes? (No limit for CESQGs, 180 days for SQGs, 270 days for SQGs that must transport their
      wastes 200 miles.)                                                                Yes [  ]  No [  ]
      Note the date of oldest container:

      If the time limit is exceeded, does the facility have the required EPA permit for storage facilities?
             '     ,            •        ...      •                  .                      Yes.[' ].- No[  ]

55.   The facility must not be storing quantities of waste in excess of the quantity storage limits.  Determine whether
      the facility is in compliance  as follows:

        Determine the total weight of all pere wastes in the storage area.

        Each 15-gallon,container  can hold about 120 Ibs (55 kg) of perc waste.

        Each 55-gallon container  can hold about 440 Ibs (200 kg) of perc  waste.
        Maximum quantity limits are as follows:  CESQG—2,200 Ibs; SQG^13,200 Ibs.
        For 15-gallon containers:


        # of full containers:

        For 55-gallon containers:
x  120 Ibs/container  =
                                x  440 Ibs/container  =?
        # of full containers

        On-site storage quantity limit (Ibs):

      Is the facility in compliance?
. Ibs in storage
                                           . Ibs in storage
                                                       Yes[  ]   No[
                                                   A-8

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Multimedia Inspection Checklist
      (2)-
Yes[ 3
Yes[ ]
Yes[ ]
Yes[ 3
No[
No[
No[
No[
D.    Hazardous Wastes Shipping


56.   Does the facility ship hazardous wastes off-site?


57..   Does the, facility track the wastes with a manifest form?


58.   Are all containers labeled with the 4-inch DOT POISON label?


59.   Are all containers marked with the proper DOT shipping name and number?



E.    Wastewater Management      .


60.   Does the facility discharge industrial wastewater into the following?


      Municipal sewer


      On-site disposal system which meets the definition of injection well


      Holding tank


For discharges to municipal sewers:


61.   Does the facility have a current wastewater permit?


      If not, has  the facility applied for a new permit?


62.   What parameters are limited and/or monitored hi the faculty's permit?


      •  Parameter      '                     T.imit          •         •  "
                                                                                      Yes[  1   No[ 3


                                                                                      Yes [  ]   No ( ]


                                                                                      Yes[  3   No[ 3





                                                                                      Yesf 3   No[ 3


                                                                                      Yes[  ]   No[ 3





                                                                                Mnnitnring Frequency
63.   Is monitoring conducted as required by the permit (with respect to sampling location, frequency)?
                                                                ,             .        Yes [ . ]   No.[  ]
       \                         .                   •               - -,

64.   Does the facility have a sampling point available which is representative of its process wastewaters discharged

      tothePOTW?                                      .                              Yes[ ]   No [  3


65.   Is the effluent currently in compliance with the limitations established hi the permit?      Yes [ 3   No [  ]
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      If not, describe aU violations, found, including parameter limit exceeded, date of violation, and any follow-up
      samples or actions.
66.   Has the discharge changed significantly since the permit was issued?

      If so, was the permitting authority notified?

      Describe the changes.
Yes[  ]   No[

Yes[  ]   No[
67.   Describe any wastewater treatment employed at the facility.  ,
68.   If the facility discharges to a POTW, has it complied with the recordkeeping and reporting requirements
   ,   contained in 40 CFR 403.12(o)?             '                          ,            Yes f ]  No [  ]
69.   Has the facility ever discharged 15 kg of perc to the POTW within a calendar month?


      If sa, were the proper authorities notified of the release?

For discharges to injection wells:

70.   Does, the facility have a Federal or State UIC permits?             •
Yes[  ]   No[

Yes[  ]   No-[



Yes[  ].  No[
71.   Does the facility dispose of perc wastes and/or other hazardous chemicals in the injection well?    -
                •                         .                                            Yes[  ]  No[.

For discharges to holding tanks:                       •     .                      >

72.   Does the facility have the tank pumped out regularly by a licensed waste hauler for proper,Yeg41 djspcMdl

IV, RECORDS AND FILES INSPECTION

A.    Reporting

73.   Did the facility file an initial report with EPA (by June 18,  1994, or upon startup for new.  facilities)?
                                                                                     Yes[  ]  No[

      Date filed:	                    ,
74.   Did the facility file a compliance report (within 30 days of startup or 30 days after NESHAP regulations take
      effect)?    .                             '      ••>           ...   .     ''"•-.
                        '  ,                '               '..:;•              Yes[  ]
      Date filed:	i_	                 ....                         •   ''..
                                                A-10

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      Note to inspector: Ask to see copies of the initial report and compliance report.
B.    Recordkeeping

75.   Are the results of temperature sensor monitoring for refrigerated condensers kept on record for the past 5 years
      of operations?                          •                                           Yes [  ]   No,[ ]

      Do the results show that all refrigerated condensers are in compliance with performance requirements?
                                                         ,                              Yes[  ]   No[ ]
      . '    • i              • •    .       '                   •
76.   Are the results of colorimetric tube monitoring for carbon adsorbers kept on record for the past 5 years of
 '   ' operations?                                        '          .       '              Yes [  ]   No [ ]

      Has a periodic (at least weekly) desorption schedule been established and adhered to for each adsorber?
                                                               ;•'•'••         '  Yes[  ].  NoT ]
      Does monitoring of adsorbers take place during the last run prior to desorption?
Yes[  ]   ,No[
      Do the results show that all carbon adsorbers are in compliance with performance requirements?
             .                ••••.'•••                  ,                ,        Yes[  ]   No[
77.   Are monthly totals of perc purchase records kept on-site for the past 5 years?
Yes[  ]   No[
78.   Are records of weekly/biweekly inspections for leaks available for each machine for the last 5 years (or since
      startup of facility)?                                                                Yes [  ]   No [  ]
79.   Are any detected leaks repaired within 24 hours whenever possible?

80.   Are all needed repair parts ordered within 2 working days?

81.   Are needed repair parts installed within 5 days of receipt? .

82.   Note any recurring problems:
Yes[  ]   No[  ,]

Yes[  ]   No[  ]

Yes [  ]   No [  ]
83.   Are copies of manifest forms maintained on-site for 3.years?

84.   Are any return copies of manifest forms (from the waste receiving facility) missing?
Yes[
          No[
                                                                                       Yes[  ]   No[  ]

 85.   If so, have exception reports been filed and copies maintained on-site?                  Yes [  ]   No [  ]

      What action has been taken to determine the status of the waste shipment or notify the proper authorities?
                                                  A-ll

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86.   Are copies of the design specifications and operating manuals for each dry cleaning system and' each emission
      control device kept on-site at the facility?                          .                  Yes [  ]   No [  ]
                                                  A-12

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87.   Has the solvent mileage been calculated for each machine?

     . If so, record the results (gallons perc/1,000 Ib clothes) —
Yes[  ]   No[
      If not, does the facility owner,understand how to calculate solvent mileage and how to use it as a waste
      minimization indicator?                                 .  ,                          Yes [  ]  No [ ]
                                                   A-13

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Multimedia Inspection Checklist
V.   ADDITIONAL COMMENTS
                                           A-14

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                    APPENDIX B

   MULTIMEDIA COMPLIANCE/POLLUTION PREVENTION
ASSESSMENT REPORT FORM FOR DRY CLEANING FACILITIES

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Multimedia Compliance/Pollution Prevention Assessment Report Form
FACILITY NAME AND
LOCATION:
MAILING ADDRESS:
(if different)
FACILITY CONTACT(S):
           Name
Title/Affiliation
Phone Number
INSPECTION DATE:

INSPECTORฎ:

           Name
REASON FOR VISIT:

AREAS VISITED:
DATE FORM COMPLETED:
Title/Affiliation
Phone'Number
                                     B-l

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Multimedia Compliance/Pollution Prevention Assessment Report Form
I.      GENERAL FACILITY DESCRIPTION

       Provide a general description of the facility (e.g., building age, length of business at this
       location, previous owners/operators at the site, dry cleaning capacity,, brief description of
       processes, brief overview of wastes generated and disposal methods used, and status of P2
       implementation efforts).
                                             B-2

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Multimedia Compliance/Pollution Prevention Assessment Report Form
II.     COMPLIANCE ASSESSMENT

       Air Quality
     •  Describe any observed, or potential violations:
       Referral to other program office
       Hazardous Waste [Resource Conservation and Recovery Act (RCRA)]
       Describe any observed or potential violations:
       Referral to other program office
       Wastetfater
       Describe any observed or potential violations:
       Referral to other program office
                                            B-3

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Multimedia Compliance/Pollution Prevention Assessment Report Form
HI.   POLLUTION PREVENTION (P2) AND INNOVATIVE TECHNOLOGY
      OPPORTUNITIES IDENTIFIED

      List each waste at the facility with any associated P2 and innovative technology opportunities.
      Use additional sheets for more information.
Raw Materials or Waste Description
•

•





Pollution Prevention and Innovative Technology Opportunities
,







                                        B-4

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 Multimedia Compliance/Pollution Prevention Assessment Report Form


TV.    CONCLUSIONS AND RECOMMENDED FOLLOW UP

 A.     Compliance Violations and/or Issues [add regulatory references (i.e.,,40 CFR 261.30)].
B.     Potential P2 Opportunities and Innovative Technologies.  (These are only suggestions and not
       regulatory requirements.)
C.     Follow-up Responses to Compliance Questions Asked During On-Site Assessment. (This
       section should include responses to compliance questions asked during the on-site assessment
       that the inspector was unable to answer.)
                                           B-5

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                         APPENDIX C

       RECOMMENDED FORMS FOR DRY CLEANERS
(taken from Draft Plain English Guide for Perc Dry Cleaners (U.S. EPA, 1995))

          1.  Sample Log Sheet for Perc Purchases
      :    2.  Monthly Machine Maintenance and Perchloroethylene Log
          3.  Initial Notification Report
          4.  Compliance Report for Pollution Prevention
          5.  Compliance Report for Control Requirements

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                                              FIGURE H-5
SAMPLE LOG SHEET FOR PERC PURCHASES
Starting amount: (Amount of p
NOTIFICATION)
, MONTH/DAY/YEAR





*






'



\ . ' ' ' •



AMOUNT OF PERC
PURCHASED
f








-•'•>" ' '


"' •





• . • '

PAGE
ere purchases reported in INITIAL
12-MONTH AVERAGE
•



















*       Staple or keep all perc purchase receipts with this form.
                                                C-l

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                                         Figure H-2                         .
              MONTHLY MACHINE  MAINTENANCE  AND
                         PERCHLOROETHYLENE LOG
        FVRRY 7 DAYS
Put N - for No Leak ' Week__ Week 	 Week— Week 	 Week 	
Put Y - for Perceptible Leak Date Date Date Date Date
1) Hoses, pipe connections, fittings, couplings,
and valves
^) Door gaskets and seatings
3) Filter gaskets 'and seatings
4) Pumps
5) .Solvent tanks and containers
6) Water separators
. 7) Muck cookers
8) Stills •
9) Exhaust dampers
10) Diverter Valves • , '
1 1) Cartridge filter housings











'.









.






















'
V





(



 CHECK RVERY 7 DAYS (Applicable Sections Only)  Week	   Week.

 (Monitoring not required for existing plants until    •      Date      Date
 September 22, 1996)
                   Week	  Week _  Week.

                   Date      Date      Date
Transfer system (washer) temperature difference
(Measure difference between inlet and outlet •
temperatures of refrigerated condenser) (Write
ฐCorฐF)
Dry-to-dry machines, dryers, and reclaimers
Condenser temperature (outlet) (Write ฐC or ฐF)
Carbon adsorber concentration CoDm)

.













Perchloroethylene purchased:
Running 12 month total	
Date and description of repairs or adjustments .
. gallons (calculate on first of every month).
. gallons per year.
Were parts ordered? —.— If yes, when and what parts were ordered?    •	
If yes, when were parts installed?	   •  •	;	.       	    .	  •
Staple or keep all solvent purchase receipts which alsb show perc volume, parts/repair invoices, and repair orders
(if written) with this sheet and save for at least five years.
                                              C-2

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FACILITY ID NO.
_(FROM ADDRESS LABEL)
                          INITIAL NOTIFICATION REPORT

1.  Print or type the following for each separately located dry cleaning plant (facility).  The
    owner of more than one plant must fill out a separate form for each plant.
    Owner/Operator:.
    Mailing Address:
    City: '.—,	
          . State:
Zip:.
    Plant Address:
    Street Address:
    City:	_
    Stater	
                  County:
                  Zip:	
    Phone Number:
2.  Check the box below if:

    D your dry cleaner is a pick-up store.                                        '
    D your dry cleaning plant has only coin-operated dry cleaning machines that are
       operated by the customers.                                ,
  .  D your, dry cleaning plant has only petroleum dry cleaning machines.

    If you checked either box above, you can STOP HERE and return the form to the
    address given in the accompanying letter.    .

3.  Write in the total, volume of perchloroethylene (perc) purchased for ALL of the
    machines at,the dry cleaning plant over the past 12 months:

                                       '  -  gallons
    'NOTE:  If perchloroethylene purchase records have not been kept at the plant, the
   .         volume may be estimated for this initial report.

    Method of determining gallons (circle one):

                                actual       estimated

4.  Next to each machine type listed below, write the number of machines of that type
    located at your plant:                •
                              Diy^to-Dry
                           Transfer
                                         C-3

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FACILITY ID NO.
_(FROM ADDRESS LABEL)
5.  Provide the following information for EACH MACHINE at your plant. If you have
    more than four machines at your plant, make additional copies of this page.

Machine Type ,
(Circle One)
Date Machine Was
Installed
Control Device (Use
WORKSHEET on
Pages 5 & 6 to
Determine Required
Control)
Date Control Device
Was Installed or Is
Planned to' Be
Installed
Machine 1 -
Dry-to-Dry
or
Transfer



Machine 2
Dry-to-Dry
or
Transfer

,

Machine 3
Dry-to-Dry
or
Transfer



Machine 4
Dry-to-Dry
or
Transfer



6.  ;The following pollution prevention practices must be performed at your plant starting on
    12/20/93. These practices are listed on an attached sheet that can be posted next to your
    machine:                       ,

    •  Conduct a weekly leak detection and repair program to inspect all dry cleaning
       equipment for leaks that are obvious from sight^ smell, or touch. NOTE: This
       program is required every other week if you wrote NO CONTROL REQUIRED in
       the shaded box in Question 5.

    •  Repair leaks within 24 hoursi.after they are found, or order  repair parts  within two
       working days after detecting a leak that needs repair parts.  Install the repair parts by
       five working  days after they are received.

    •  Keep  a log of the weekly (or biweekly) results of the leak detection and repair
       program.

    •  Follow good housekeeping practices, which include keeping all perc and wastes  ' .
       containing perc in covered containers withno leaks, draining cartridge filters.in
      ' closed containers, and keeping machine doors shut when clothing is not  being, •
       transferred.                     •       .              •
                                         C-4

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FACILITY ID NO.
_(FROM ADDRESS LABEL)
    •  Operate and maintain all dry cleaning equipment according to manufacturers'
       instructions.

7.  The following records must be kept at your plant:

    •  A log of the results of the leak detection and repair program.

  .  •  A log of the amount of perc purchased for the past 12 months, calculated each
       month.                                                ' ,
                                                        .       /    •   t  '

    •  The operation and maintenance manuals for all dry cleaning equipment at the plant.

8.  If a room enclosure is installed  on a transfer machine as stated in Question 4, the
    following information about the room enclosure must be attached to this report:

    •  Description of the materials  that the room enclosure is constructed of to show that it
       is  impermeable to perchloroethylene;          .,

    *  Explanation of how the room enclosure is operated to maintain a negative pressure at
       all time while the transfer machine is operating; and

    .•  Explanation of how the room enclosure exhausts  into a carbon adsorber.
                           i            "i      . '                     •
9.- Print  or type the name and title of the Responsible Official for the dry cleaning plant:
    Name:
                        Tide:
    A Responsible Official can be:        .            .

    •  The president, vice president, secretary, or treasurer of the company that owns the
     .  dry cleaning plant;

    •  An owner of the dry cleaning plant;

    ••  The manager of the dry cleaning plant;

    •  A government official, if the dry cleaning plant is owned by the Federal, State, City,
       or County government; or

    •  A ranking military officer,  if the dry cleaning plant is located at a military base.
                                         C-5

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FACILITY ID NO.
_(FROM ADDRESS LABEL)
           •'..;.'              WORKSHEET

A.  To find out if control is required:

    Check all boxes that apply:

    D I reported less than 140 gallons in Question 3 (page 1).
    *  • '       ' . -                              ' i-
    D I reported less than 200 gallons in Question 3 (page 1) AND .reported only transfer
       machines in Question 4 (page 1).

       If you checked either box above and all your machines were installed before 12/9/91,
       you can STOP HERE.  Write NO CONTROL REQUIRED in the shaded box on
       page 2 for each machine at your plant that was installed before 12/9/91.  For those
     .  machines installed on or after 12/9/91, continue with the rest of the worksheet.
                 -'*'-'                            '    '
       .YOU ARE FINISHED WITH THE WORKSHEET.  GO TO QUESTION 6 (page
       2).        •             ,        .

       If you did not check a box above, go to Part B below.
                 	         a            ...    .     ._..	       .   ......

B.  Control is required. Fill out Part B for EACH MACHINE at your plant.

    Check the appropriate box:         •    ' •   ••'*-•

    D Machine was installed BEFORE 12/9/91.

       If you checked this box, your required control is a refrigerated condenser or a carbon
       adsorber that was installed before 9/22/93. Write REFRIGERATED CONDENSER
       or CARBON ADSORBER in the shaded .box below the machine on page 2.

       Control must be installed by 9/22/96.                        ,
                                       C-6

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FACILITY ID NO,
.(FROM ADDRESS LABEL)
    D Machine was installed ON OR AFTER 9/22/93.                       .

       If you checked this box, your required control is a dry-to-dry machine with
       refrigerated condenser.

       Write DRY-TO-DRY MACHINE WITH REFRIGERATED CONDENSER in the
       shaded box below the machine on page 2.  NOTE:  NO NEW OR USED
       TRANSFER MACHINES CAN BE INSTALLED AFTER 9/22/93.

       Control must be installed when machine is installed.

    p Machine was installed ON OR AFTER 12/9/91 AND BEFORE 9/22/93.

       If you checked this box, your required control is-a dry-to-dry machine with
       refrigerated condenser.  Write DRY-TO-DRY MACHINE WITH REFRIGERATED
       CONDENSER in the shaded box below the machine on page 2.

       If the machine you have is NOT a dry-to-dry machine with a refrigerated condenser,
       the machine must use either a refrigerated condenser or carbon adsorber from
       9/22/93 until 9/22/96. After 9/22/96, any carbon adsorbers on dry-to-dry machines
       must be replaced with a refrigerated condenser.  If the machine is a transfer machine
       with a carbon adsorber or a refrigerated condenser,  you may keep this installation
      . until 9/22/96.. If you plan to keep a dry-to-dry machine with a carbon adsorber or a
       transfer machine with either  a refrigerated  condenser or carbon absorber until
       9/22/96, also write this information in the shaded box.          .        .        .

C.  To find out if additional control is required:                .

    Check all boxes that apply:        ••'.'•'...
                          1  '    •                 t
    D I reported 1,800 gallons or less in Question 3 (page 1).,

    D I reported 2,100 gallons or less in Question 3 (page 1) AND I reported only dry-to-
       dry machines in Question 4 (page 1).

      .If you checked either box above, you can STOP HERE. No additional controls are
       required.                             •

       YOU ARE FINISHED WITH THE WORKSHEET. RETURN TO QUESTION 5
       (page 2) and write in the dates the controls were or will be installed.

       If you did not check a box above, go to Part D below.                      .
                                       C-7

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FACILITY ID NO.
_(FROM ADDRESS LABEL)
D.  If additional control is required, fill out Part D for EACH machine at your plant:

    Check a box below, if it applies:

    D  Machine is a dry-to-dry machine that was installed ON or AFTER 12/9/91.

       If you checked this box, you are also required to install a supplemental carbon -
       adsorber.                                          '

       Write SUPPLEMENTAL CARBON ADSORBER in the shaded box below the
       machine on page 2.

    D  Machine is a transfer machine.

       If you checked this box, you are also required to install a room enclosure. Write
       RQOM  ENCLOSURE in the shaded box below the machine on page 2.
       YOU ARE FINISHED WITH THE WORKSHEET. RETURN TO QUESTION 5
       and write in the dates all controls were or will be installed (page 2).
                                      C-8

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FACILITY ID NO.
_(from address label)
              COMPLIANCE REPORT FOR POLLUTION PREVENTION

1.  Print or type the following for each separately located dry cleaning plant (facility).  The.
    owner of more than one plant must fill out a separate form for each plant.
    Owner/Operator:.
    Mailing Address:
    City: _—_	
          .State:
Zip:.
    Plant Address:

    Street Address:
    City: '.	;	
    State:	;—
                  County:
                  Zip: _—
    Phone Number:
2.  Write in the total volume of perchloroethylene (perc) purchased for ALL of the
  .  machines at the dry cleaning plant over the past 12 months (based on actual purchase
    receipts):

           -                            •    gallons               ,
3.  The following pollution prevention practices must be performed at your plant as of  ,
    12/20/93.      .           .                                      '

    •  Conduct a weekly leak detection and repair program to inspect all dry cleaning
       equipment for leaks that are obvious from sight, smell, or touch.  NOTE:  This
       program is required only every other,week (biweekly) if you reported NO
       CONTROLS REQUIRED in the INITIAL NOTIFICATION REPORT.

    •  Repair leaks within 24. hours after they are found, or order repair parts within two
       working days after detecting a leak that needs repair parts.  Install the repair parts by
       five days after they are received.

    •  Keep a log of the weekly (of biweekly) .results of the leak detection and repair
       program.              -     .

    •  Follow good housekeeping practices, which include keeping ail perc and wastes
       containing perc in covered containers with no leaks, draining cartridge filters in
      ' closed containers, and keeping machine doors shut when clothing is not being
       transferred.
                                         C-9

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FACILITY ID NO.
_(from address label)  .
    •  Operate and maintain all dry cleaning equipment according to manufacturers'
       instructions.                                                 •

4.  The following records must be kept at your plant:

    •  A log of the results of the leak detection and repair program;

   . •  A log of the amount of perc purchased for the past 12 months, calculated each
       month; and              '    , '   •'                       •

    •  The operation and maintenance manuals for all dry cleaning equipment at the plant!

5.  Print  or type the name and tide of the Responsible Official for the dry cleaning plant:
    Name:
                        Title:
    A Responsible Official can be:
    *  The president, vice president, secretary, or treasurer of the company that owns the
       dry cleaning plant;

    •  An owner of the dry cleaning plant;

    •  The manager of the dry cleaning plant;

    •  A government official, if the dry cleaning plant is owned by the Federal, State, City,
       or County government;  or                             .

    •  A ranking military officer,  if the dry cleaning plant is located at a military base.
                                         C-10

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FACILITY ID NO.
_(from address label)
              COMPLIANCE REPORT FOR CONTROL REQUIREMENTS

1.  Print or type the following for each separately located dry cleaning plant (facility).  The
    owner of more than one plant must fill out a separate form for each plant.
    Owner/Operator:.
    Mailing Address:
    City:     . 	
          . State:
Zip:.
    Plant Address:

    Street Address:
    City: '.	
    State: _	
    Phone Number:
                 County:
                 Zip:	
2.  Write in the total volume of perchloroethylene (perc) purchased for the dry cleaning
    plant over the past 12 months (based on actual purchase receipts):

                                           gallons
                                        C-ll

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FACILITY ID NO.
_(from address label)
3.  Fill out the table below for each machine at your plant.  Use the WORKSHEET on
    pages 5 and 6 of the INITIAL NOTIFICATION REPORT to determine required
    controls.  A copy of the INITIAL NOTIFICATION REPORT is attached.

1
2 '
3 .
4
•5
6
7
Machine Type
(Dry-to-Dry
or Transfer)







Date Machine
Purchased







Required Control

. •. . '.





Date Control Installed.
• • ' ' '

• j / . .




4.  If you listed a required control in Question 3 (page 1) for any machine at your plant,
    you must monitor your control.                ,

    To find out what type of monitoring is required, check all boxes that apply:

    D I use a refrigerated condenser oh a dry-to-dry machine to meet the required control.

       If you checked this box, you are required to perform a weekly monitoring test to
       show that the temperature on the outlet side of the refrigerated condenser is less than
       or equal to 45 degrees Fahrenheit.

    D I use a refrigerated condenser on a transfer machine to meet the required control;

       If you checked this box, you are required to perform a weekly monitoring test to
       show that the temperature on the outlet side of the refrigerated condenser on the
       transfer dryer is less than or equal to 45 degrees Fahrenheit AND that the difference
       between the inlet and the outlet temperature of the. refrigerated condenser on the
       transfer washer is greater than or equal to 20 degrees Fahrenheit.

    D I use a carbon adsorber on a dry-to-dry or a transfer machine to meet the required
       control, OR
                                         C-12

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FACILITY ID. NO.
_(from address label)
    D I use a supplemental carbon adsorber on a dry-to-dry machine and me exhaust passes
       through the carbon adsorber IMMEDIATELY UPON door opening.

       If you checked either of the two boxes above, you are required to perform a weekly
       monitoring test with a colorimetric detector tube to show that the concentration of
     1  perc in the exhaust from the carbon adsorber is not over 100 parts per million.

    D I use a supplemental carbon adsorber on a dry-to-dry machine and the exhaust passes
       through the carbon adsorber BEFORE the machine door is opened.

       If you checked this box, you are required to perform a weekly monitoring test with a
       colorimetric detector tube to show that the concentration of perc inside the dry
       cleaning machine drum at the end of the drying cycle is not over 300 parts per
       million.                                    '

    D I use a room enclosure on a transfer machine.

       If you checked this box, you are required to vent all air from inside the room
       enclosure through a carbon adsorber.  The room enclosure must be constructed of
       materials impermeable to perc, must be designed and .operated to maintain a negative
       pressure at all times while the transfer machine is operating, and must exhaust to a
       carbon adsorber.            .
                                        C-13

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FACILITY ID NO.
_(from address label)
5.  Print or type the name and title of the Responsible Official for the dry cleaning facility:
    Name:
                         Title:
    Examples of Responsible Officials:
     •  The president, vice president, secretary, or treasurer of the company that owns the
        dry cleaning facility;

     •  An owner of the dry cleaning facility;

     •.  The manager of the dry cleaning facility;

    , •  A government official, if the dry cleaning facility is owned by the Federal, State,
        City, or County government; or                            .

     •  A ranking military officer, if the dry cleaning facility is located at a military base.
                                           C-14

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                        APPENDEXD
                           •*.




                  STATE REQUIREMENTS




(Insert State Requirements for area of country where this document is being used.)

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 APPENDIX E



BIBLIOGRAPHY

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                                      BIBLIOGRAPHY
                                 i              '                      ".          ,

 Alaska Health Project, Waste Reduction Makes Good Business Sense for Dry Cleaners  Alaska Health
    '  Project, 1987.

 Delaware DNREC, Pollution Prevention Program.  Pollution Prevention Success Story:  Capitol
      Cleaners.  Delaware Department of Natural Resources and Environmental Control.

 Grayson, Martinet al., ed.  "Drycleaning."  Encyclopedia of Chemical Technology, Vol  8  New
      York, John Wiley & Sons, Inc., 1979.             '

 Hawaii Department of Health, Solid and Hazardous Waste Branch—Environmental Management
      Division.  Hazardous Waste Minimization News, Vol. 3, No. 1.  State of Hawaii Department of
      Health, September 1994.
                                      ,' '       '•        .        *                          '

 Hawaii Department of Health, Solid and Hazardous Waste Branch—Environmental Management
      Division.  Waste Minimization in Action: Dry Cleaning Bulletin.  State of Hawaii Department of
      Health.     '              .

 IFI.  "Distillation. " IFI Focus on Dry Cleaning Vol. 5, No.6.  International Fabricare Institute
     January 1982.

 IFI.  "Filtration."  IFI Focus on Dry Cleaning Vol. 5, No.5. International Fabricare Institute   '
    ' January 1982.                              ......

 IFI.  "Trouble-Shooting the Cleaning System."' in  Focus  on Dry Cleaning Vol. 6, Np.l.
     International Fabricare Institute, January 1982.

 Los Angeles County, Industrial Waste Section. Dry Cleaning Industry:  Pollution Prevention
     Opportunities Checklist.  County Sanitation,Districts  of Los Angeles County.

 MDEP, Bureau of Air Quality Control and the Office of Pollution Prevention. Small Business
     Technical Assistance Program:  Summary of Dry Cleaners Air Emissions Issues.  State of Maine
     Department of Environmental Protection.        .     ' '.

MDEP, Bureau of Air, Quality Control.  Dry Cleaner. Inspection Checklist.  State of Maine
    'Department of Environmental Protection, January 1994.

NJDEP.  Dry Cleaner Self-Audit Checklist.  New Jersey Department of  Environmental Protection
    Winter 1995.                                                                       '

Santa  Monica DeparQnent of General Services. Hazardous Waste Reduction Facts: Commercial Dry
    Cleaners.  City of Santa Monica.                       .

U.S. EPA, Design for the Environment Program.  Federal Environmental Regulations Potentially
    Affecting the Commercial Printing Industry.  EPA 744B-93-003.  U.S. Environmental Protection
    Agency, October 1993.                                    ,
                                            E-l

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U.S.EPb..-Dry cleaning and Laundry Plants. EPA/530-SW-90-027b.  U.S. Environmental   ,'
     Protection Agency.


Washington State Department of Ecology, Office of Waste Reduction.  Dry cleaner's Fact Sheet.
  .  Washington State Department of Ecology, November 1988.
                                           E-3

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