United States
Environmental Protection
Agency
Enforcement And
Compliance Assurance
(6602J)
EPA 305-B-96-002
August 1996
S-EPA
Plain English Guide For
Perc Dry Cleaners
A Step By Step Approach
To Understanding Federal
Environmental Regulations
LOCAL DRY OJEAN1NG SHOP
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Table of Contents
I. Part I: Statement of Goals, Guide Overview, and
Summary of Perc Waste Sources l-l
Section A: Statement of Goals 1-1
Section B: Guide Overview 1-1
Section G: Types and Sources of Perc Wastes 1-2
n. Part II: Step-by-Step Approach to Environmental Compliance II-1
Section A: Introduction II-l
Section B: Which regulations apply to my dry cleaning shop? II-4
Section C: How do I prepare my dry cleaner to comply with environmental
requirements? 11-20
Section D: How to properly operate a dry cleaning machine and shop to stay in
compliance with enviromental regulations? 11-30
HI. Part IE: Questions that an Inspector May Ask While Visiting Your Dry
Cleaning Shop m-i
Appendix A
Appendix B
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List of Tables
Section JL
TL-1 Regulatory Requirements and Recommendations II-2
n-2 Air Control Requirements for New and Existing Dry Cleaners Are Based on
Perc Purchases H-7
n-3 Typical Amounts of Hazardous Waste Generated by a Perc Dry Cleaning
Facility (for every 1,000 Pounds of Clothes Cleaned) 11-10
n-4 Categories of Hazardous Waste Generators H-l 1
II-5 Summary of Hazardous Waste Generator Requirements for Perc Dry Cleaners
in 40 CFR 261.5 & 262 II-12
n-6 Materials Used and Wastes Generated by Dry Cleaners n-18
n-7 Wastewater Requirements for Dry Cleaners with Sewer Systems 11-19
List of Figures
Section n:
H-l
n-2
n-3
n-4
n-5
n-6
EPA Form for Notification of Regulated Waste Activity 11-24
Monthly Machine Maintenance and Perchloroethylene Log II-31
Colorimetric Detector Tube II-33
Hand Bellows Pump II-34
Sample Log Sheet for Perc Purchases H-35
EPA Uniform Hazardous Waste Manifest Form H-41
11
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Part I: Statement of Goals, Guide Overview,
and Summary of Perc Waste Sources
Section A: Statement of Goals
The Plain English Guide for Perc Dry Cleaners
was developed to assist owners and operators of
perchloroethylene (perc) dry cleaning facilities in .
understanding and complying with federal air,
hazardous waste, and wastewater regulations. Your"
state or local government may have additional
requirements. EPA regional office air/small business
coordinators are listed in Appendix A to help identify
your state and local contacts.
Section B: Guide Overview
Part I describes the statement of goals, guide
overview, and the hazards associated with the use of
perc. It also summarizes the various sources of perc
waste that are produced during the dry cleaning .
process. Part n is a "step-by-step" approach to how
dry cleaners comply
with the regulations.
Section II-A
summarizes all the
requirements and
recommended actions
that are discussed in
this part. Section n-B
is a simplified version
of the federal
environmental
regulations that apply
to perc dry cleaning
facilities.
Section II-C describes the guidelines and procedures
for preparing your dry cleaning shop to make sure you
comply with federal environmental regulations.
Section TL-D describes how to properly operate your
machines and shop to stay in compliance. Remember
that your state's requirements may be stricter than the
federal requirements, so always check with your state
agency. Part in lists typical questions that an
inspector may ask while visiting your perc dry cleaning
facility. Appendix A lists EPA regional office dry
cleaning air coordinators and small business contacts.
Appendix B contains the following forms used for
compliance with federal air regulations:
• Initial Notification Report
• Compliance Report for Pollution Prevention
• Compliance Report for Control Requirements
(necessary where compliance with an emission
control device is required).
These completed forms must be submitted to the
appropriate EPA
regional coordinator in
Appendix A.
1-1
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Section C: Types and Sources
of Perc Wastes
It is important for you to know the hazards
associated with the use of liquid perchloroethylene
(perc), and the kinds and sources of perc wastes that
are produced by the dry cleaning process. Although
perc is the most common cleaning solvent used in the
dry cleaning industry, it is also suspected of causing
cancer and has been found to be moderately toxic to
people. It is classified as a pollutant in both air and
water regulations. Its disposal is regulated as a
hazardous waste.
Air Emissions
The two largest potential sources of air emissions
from the dry cleaning industry are the release of perc
vapors into the atmosphere during transfer of clothes
from the washer to the dryer and 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.
Identification Number for generating hazardous waste.
It is also needed when filling out the Uniform
Hazardous Waste Manifest (Figure n-6, page 11-41).
This Manifest must accompany each hazardous waste
shipment to ensure the hazardous waste arrives at its
final destination.
Wastewater
The only source of process wastewater that would
be of general concern to a dry cleaner is separater
water, since it contains perc. Separater water can be
disposed of as a hazardous waste or treated in a mister
or an evaporator. Disposal of untreated separater water
into on-site disposal systems such as dry wells,
cesspools, and septic tanks is prohibited. Disposal into
a municipal sewer system is subject to state and local
Publicly Owned Treatment Works (POTW)
requirements.
Hazardous Waste
Dry cleaning facilities typically generate wastes in
the form of cooked powder residues, still bottom
residues, spent cartridges, and button/lint trap wastes.
These wastes are perc-based and have an EPA
Hazardous Waste Number of F002. Dry cleaners may
also occasionally dispose of unused perc and these
wastes have a Hazardous Waste Number of U210.
The EPA Hazardous Waste Number is needed when
filling out the Notification of Hazardous Waste Activity
form (Figure n-1, page n-24) when obtaining an EPA
1-2
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Part II: Step-by-Step Approach to
Environmental Compliance
Section A. Introduction
Part II of this guide gives you "step-by-step"
instructions to how dry cleaners comply with the
regulations. Table H-l summarizes all the monitoring,
record keeping, and reporting requirements you need to
follow, as well as recommended actions. The table is
divided into three columns: air, hazardous waste, and
water. The table shows what requirements you must do
to start your dry cleaning business and how to stay in
compliance while you are doing business.
The requirements for staying in compliance are further
divided into those that must be performed on a daily,
weekly, monthly, or occasional basis. Each
requirement is discussed in one of the four sections that
follow this introduction. They will help you answer
four basic questions:
• How do I prepare my shop to comply with
environmental regulations?
• What regulations apply to my dry cleaning shop?
• How do I properly operate and maintain my shop?
• What do I do if an accident happens?
LOCAL DRY CLEANING SHOP
II-l
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TABLE n-1
GENERAL REGULATORY REQUIREMENTS AND RECOMMENDATIONS
Pro-Operation
Daily
Weekly
Monthly
AIH
/" EPA recommends that
serious consideration be given
to consulting with a reputable
dry cleaning trade association
/ Check with your EPA
Regional Air Office to find out
how state and local authorities
should be contacted
S Purchase correct dry
cleaning machine and control
equipment
/ Be sure refrigerated
condenser gets down to 45 °F
/ Fill out and send in Initial
Notification Report and
Pollution Prevention
Compliance Report. Include
Control Requirements
Compliance Report if a control
device is required
/" Check with your EPA
Regional Air Office to find out
if you are required to obtain a
Title V permit
/ Follow good housekeeping
practices
/" Monitor carbon adsorbers,
refrigerated condensers as
required
/" Perform leak detection and
• *
repair
S Record solvent purchases
and calculate yearly
consumption
HAZARDOUS WASTE
/ Obtain a U.S. EPA Identification
Number
/ Select a hazardous waste hauler
/ Select a hazardous waste
management facility
«/" Develop a hazardous waste
contingency plan, if it is required
f
/ Follow proper storage and
management procedures
/ Inspect waste storage areas
«/" Review manifest log for status of
shipped waste (file exception report
if no receipt from final destination)
«/" Check quantity of hazardous
waste to determine generator status
/ Inspect emergency control
equipment
WATER
/ Contact state and
local wastewater
authorities for
potential permit
requirements,
including sampling,
record keeping, and
reporting
requirements
S EPA recommends
you test groundwater
for perc contamination
under prospective
plant site, especially if
dry cleaner was on the
site previously
S EPA recommends
not putting anything
down the drain with
perc in it
/ Close floor drains
connected to drain
fields, septic systems,
and dry wells
/" Do not make
discharges to the
sewer that exceed
local requirements.
Do not make any
discharges to the
septic system or other
shallow disposal wells
t/ Follow any
sampling, reporting,
and record keeping
requirements
n-2
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TABLE 11-1
CONTINUED
AIR
HAZARDOUS WASTE
WATER
Each Time You
Ship Hazardous
Waste
/ Complete hazardous waste
manifest for each shipment of waste
transported off site and enter into
manifest log
/ Follow proper handling
procedures for transport (labeling,
placarding, forms, etc.)
If You Have an
Accident or Spill
/ Follow startup, shutdown,
malfunction plan (may be
standard operating procedures
oranOSHAplan)
/ Follow contingency plan, if it is
required
/ If discharge of perc
to sewer is greater
than 15 kg/mo, make
Hazardous Waste
Notification
/ Report any toxic or
hazardous waste
discharge to a septic
sewer system to state
or EPA Underground
Injection Control
(UIC) program
directors
* Small dry cleaners must perform leak detection and repair once every two weeks.
n-3
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Section B. Which
regulations apply to my dry
cleaning shop?
First you must determine how your shop is
classified under the regulations for air, hazardous
waste, and wastewater. Each regulation has its own
separate way to determine classification.
YOU MAY NOT BE SUBJECT
TOALLOFTHE
REGULATIONS.
AIR regulations depend upon: 1) the yearly
amount of perc your dry cleaning shop purchases;
2) the type of dry cleaning machine(s) used; and 3) the
date the machine(s) was installed. HAZARDOUS
WASTE regulations depend upon the amount of
hazardous waste your shop generates each month or
stores on-site. WASTEWATER
PRETREATMENT regulations for hazardous wastes
depend upon the amount of perc your shop releases into
the sewer system each month.
This section will help you determine your
classification for each of the three sets of regulations.
Step 1: > Air
Which air requirements apply at your dry cleaning
shop.
Which air pollution control equipment is needed at
your dry cleaning shop.
How to determine your yearly perc consumption.
Hazardous
Waste
* Which wastes are hazardous wastes.
> How to determine the quantity of hazardous waste
you generate.
> How to determine your hazardous waste generator
classification.
> How your generator category may change.
Step 3: > Water
When wastewater pretreatment requirements
apply-
When requirements for underground injection
wells apply.
n-4
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Step 1: y Which federal air
requirements apply?
In September, 1993, the U.S. Environmental
Protection Agency (EPA) issued regulations to control
air emissions of perchloroethylene (perc) from dry
cleaners. These regulations set national emission
standards for hazardous air pollutants (NESHAP)
affecting all perc dry cleaners. The regulations say:
Pollution Prevention
All perc dry cleaners must perform the
following pollution prevention steps:
Inspect all equipment at least every otiher
week for leaks that are obvious from sight,
smell, or touch. Larger dry cleaners (those
required to install control equipment) must
inspect every week.
Repair leaks within 24 hours. Some leak
repairs may require the ordering of parts. If
so, the part(s) must be ordered within 2
working days of detecting the leak and
installed within 5 days of receipt.
Follow these Good Housekeeping Practices:
Keep all perc wastes in covered
containers with no leaks
Drain all cartridge filters in closed
containers
Keep machine doors closed when not
being loaded or unloaded.
Operate and maintain all equipment according
to manufacturers' instructions.
Keep a log of:
Leak detection and repair program results
Amount and date of perc purchases (at
any time know how much perc you
purchased during the previous 12
months).
Air Control
The air control requirements depend on the
installation date of your dry cleaning machines, the
type of machines (dry-to-dry or transfer), and the
amount of perc purchased each year.
The date of installation determines if your dry
cleaning machine is "NEW" or "EXISTING."
EXISTING dry cleaning machines are those
installed before December 9,1991.
NEW dry cleaning machines are those installed on
or after December 9,1991.
Note: The following amendments to the federal air
regulations (NESHAP), for perc dry cleaners, are
effective September 19,1996.
"New" transfer machines installed between
December 9,1991 and September 22,1993 follow
regulations for "existing" transfer machines. Also,
under no circumstances are "new" transfer
machines installed after September 22,1993
allowed to operate.
uuuu
Weekly
Checklist foT
Dry Cleaning
Machine
n-s
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Any dry cleaning machine or facility owner
that has changed ownership or location must keep
records that prove its original installation occurred
before December 9,1991 for dry-to-dry machines and
before September 22,1993 for transfer machines in
order to maintain "existing" machine status for
regulatory purposes.
The type of machines (dry-to-dry or transfer)
in use and the amount of perc you purchase each year
determines whether your dry cleaner is a small area
source, large area source, or major source of pollution.
An example of how to calculate the amount of perc
purchased during one year is given on page II-8.
• Small area sources are those that (1) have
only transfer machines and purchase less than
200 gallons per year of perc or (2) have only
dry-to-dry machines or have both transfer and
dry-to-dry machines, and purchase less than
140 gallons per year or perc.
• 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 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 or perc per year.
Table H-2 shows the air pollution control
requirements for NEW and EXISTING dry cleaning
machines.
Title Five (V) Operating Permit Program
The agency that issues Title V operating
permits can be your state or the U.S. EPA. Contact
your EPA Regional Coordinator (See Appendix A) to
determine which agency it is. Then contact that agency
to find out when they are planning to issue permits for
dry cleaners. Some states have indicated that they will
be developing general permits for dry cleaners. If so,
dry cleaners in those states will be required to fill out
and submit this general permit form. General permits
are the simplest type of Title V permit. Note that any
dry cleaner defined as a "major source" is required to
get a permit. If your dry cleaner is not a major source,
you should still check with the appropriate air
authorities to determine if your dry cleaner requires a
permit.
State and Local Regulations
Existing state and local regulations in effect
prior to the NESHAP continue to apply. Note that the
NESHAP rule contains the minimun Federal
requirements for emission controls. If your state or
local rules are more strict, you must comply with them.
n-6
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The Amount of Perc Purchased During One Year
for Your Pry Cleaning Store
To calculate your yearly perc consumption on
a rolling, monthly basis, add together all perc purchases
for the previous 12 months for all of the dry cleaning
machines at your shop. As each calendar month
begins, add the new perc purchases for that month and
subtract the perc purchases made in the oldest of the
12 months.
FOR EXAMPLE: at the beginning of January 1994, if
your perc purchases were as follows:
1994 Jan: 55 gal(Subtract
this month's purchases)
Feb:
Mar:
Apr:
May:
Jun:
Jul:
Aug:
Sep:
Oct:
Nov:
Dec:
1995 Jan:
O gal
55 gal
0 gal
O gal
0 gal
55 gal
O gal
55 gal
55 gal
55 gal
55 gal
O gal (Add the
new month's purchases)
330 TOTAL
I r^S i
1994 Jan:
Feb:
Mar:
Apr:
May:
Jun:
Jul:
Aug:
Sep:
Oct:
Nov:
Dec:
^
55 gal
0 gal
55 gal
0 gal
0 gal
0 gal
55 gal
O gal
55 gal
55 gal
55 gal
55 gal
385 TOTAL
^
Thus, each month you will determine a new yearly
average based upon the purchases from the 12
preceding months.
BE SURE TO COUNT YOUR
PERC PURCHASES EACH
MONTH, EVEN IF YOU
MADE ZERO PERC
PURCHASES DURING THAT
MONTH.
Your yearly total would be 385 gal. In February 1994,
to calculate your rolling yearly average add the next
month's purchases and subtract the oldest month's
purchases as follows:
n-8
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Step 2:
>Which hazardous waste
requirements apply?
Since perc diy cleaning facilities generate and
produce hazardous waste, they must comply with
hazardous waste regulations under the Federal
Resource Conservation and Recovery Act (RCRA).
These regulations cover the generation, transportation,
and management of hazardous waste and are found in
the Code of Federal Regulations under 40 CFR part
260-268. Generator requirements are found in 40 CFR
parts 261.5 and 262. The amount of waste generated
by a facility determines which RCRA regulations apply.
All perc dry cleaners generating hazardous waste
should also contact their state hazardous waste office to
determine whether their state has additional or stricter
hazardous waste requirements. Your EPA regional
contact (see Appendix A) can supply you with your
state contact.
Types of Hazardous Waste
Perc dry cleaners commonly produce four
types of hazardous waste:
(1) still residues from solvent distillation,
(2) spent filter cartridges contaminated with perc,
(3) process water (such as separator water), and
(4) cooked powder residue.
Cooked power residue, still residues, process
water, and spent cartridge filters containing perc or
valclene are "listed" hazardous wastes and have the
EPA Hazardous Waste Number F002, since these
wastes are perc-based.
How to Count the Quantity of Hazardous Waste
You MUST count all quantities of perc
wastes that are:
> Collected on-site (in your shop) prior to
treatment or disposal.
»• Packaged and transported off-site (away from
your shop).
You do NOT have to count perc wastes that:
Are left at the bottom of solvent containers
that have been emptied by conventional
means (for example, pouring or pumping) and
no more than 2.5 cm (1 in) of residue remains
in the bottom of the container, or no more
than 3 percent by weight of the total capacity
of the container remains in the container if the
container is less than or equal to 110 gallons
in size.
Are left as residue at the bottom of storage
tanks, if the residue is not removed. For
example, residues left in the bottom of the
perc storage tank are not counted as long as
they are not removed when the tank is refilled.
You reclaim continuously on-site without
storing the waste prior to reclamation. For
example, the liquid perc that is recovered
during the dry cleaning cycle and returned to
your base tank for reuse. (You do have to
count any residue removed from the machine
as well as spent cartridge filters.)
You have already counted once during the
calendar month, and treated on-site or
reclaimed in some manner, and used again.
n-9
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Are directly discharged to a sewer leading to a
municipal treatment plant or publicly owned
treatment works (POTW) without being
stored or accumulated first. This discharge
to a POTW must comply with the Clean
Water Act and any local regulations. You
should contact your local water authority
before discharging any wastes other than
sewage into the sewer system. Additional
requirements may apply if you dispose of
perc into the sewer.
Table H-3 shows some typical quantities of
hazardous waste generated at typical dry cleaners. If
you store your waste in drums you should know that
one-half of a 55-gallon drum holds about 220 Ib
(100 kg) of hazardous waste.
TABLE H-3
TYPICAL AMOUNTS OF HAZARDOUS
WASTE GENERATED BY A PERC DRY
CLEANING FACILITY (FOR EVERY 1,000
POUNDS OF CLOTHES CLEANED)
Type of Hazardous WasM
Still Residues
Spent Cartridge Filters
Standard (Carbon Core)
Adsorptive (Split)
Cooked Powder Residue
Typical
Amount of
Hazardous
(pounds)
25
20
30
40
How to Determine Your Hazardous Waste
Classification
Count up how much hazardous waste you
generate and figure out which generator category
applies to you each month. There are three generator
categories for hazardous waste producers:
• Conditionally Exempt Small Quantity
Generators (CESQGs) generate less than or
equal to 220 pounds (100 kg) of perc waste
per month.
• Small Quantity Generators (SQGs)
generate more than 220 but less than 2,200
pounds (100 to 1000 kg) of waste per month.
Most dry cleaners will be CESQGs or SQGs.
• Large Quantity Generators (LQGs)
generate 2,200 pounds (1000 kg) or more of
waste per month.
The three categories of hazardous waste generators are
described in Table H-4.
A useful rule-of-thumb is that a 55-gallon
drum can hold approximately 440 Ibs. (200 kg) of
hazardous waste, while a 15-gallon drum can hold
approximately 120 Ibs. (55 kg) of waste.
n-io
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TABLE n-4
CATEGORIES OF HAZARDOUS WASTE GENERATORS
CfEJSE»Ai:O»CA*EO6RT l
Conditionally Exempt Small
Quantity Generator (CESQG)
Small Quantity Generator (SQG)
Large Quantity Generator (LQG)
MONTHLY
'HAMl^0MWMM^^@IMli;0M.MTJ :
220 pounds (100 kg) or less per month
Greater than 220 pounds (100 kg)
but less than 2,200 pounds (1,000 kg) per month
2,200 pounds (1,000 kg) or more per month
Requirements for Hazardous Waste Generators
Requirements for hazardous waste generators
cover the storage and handling, treatment, and disposal
of the waste, from the time the hazardous waste is
generated until it is disposed. The generator is
responsible for all steps. Table n-5 provides a
summary of the hazardous waste generator
requirements.
YOUR STATE'S
REQUIREMENTS MAY BE
STRICTER THAN THE
FEDERAL REQUIREMENTS, SO
ALWAYS CHECK WITH YOUR STATE
AGENCY.
Definitions
The hazardous waste generator requirements
found in Table H-5 are defined below.
Monthly Weight Limits—the measured amount (by
weight) of hazardous waste generated at each dry
cleaning shop per calendar month.
Maximum On-site Weight Limits—the total weight
of hazardous waste that can be accumulated at any time
at a dry cleaning facility before it must be shipped off
site. Having more than the limits can cause a facility to
change generator status, therefore, change the
applicable regulatory requirements.
Satellite Accumulation—an area near the point of
hazardous waste generation where limited amounts of
hazardous waste can be stored temporarily. Satellite
accumulation provisions apply only to SQGs and LQGs
and allow a generator to accumulate up to 55 gallons of
hazardous waste in properly labeled containers at or
near its point of generation and under the control of the
operator of the process generating the waste. Once the
quantify of waste stored in the containers) has
exceeded 55 gallons, the container(s) must be dated.
The generator then has 72 hours to remove the
container(s) from the satellite accumulation area and to
place them in a hazardous waste accumulation or
storage area.
n-n
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TABLE H-S
SUMMARY OF HAZARDOUS WASTE GENERATOR REQUIREMENTS FOR PERC DRY CLEANERS
IN 40 CFR 261.5 & 262
TOMKMfcit
Monthly Weight Limits
Maximum On-Site
Weizht Limits
Maximum On-Site
Time Limits
EPA I.D. Number
Uniform Hazardous Waste
Manifest
Exception Reports
Biennial Report
Contingency Planning and
Notification
Container Maintenance
Requirements
Personnel Training
Type of Facility Required
for Off-Site Management of
Waste
TyjEEo
Quantity Generator {CESQjG)
i 220 pounds
(100kg)
i 2,200 pounds **
(1,000 kg)
None
Not federally required ***
Not federally required ***
Not federally required
Not federally required ****
Not federally required
Not federally required
Not federally required
State-approved solid waste
facility *****
or RCRA permitted/interim
status facility or recycling
facility
eUAfcAWJWSWASraOJ^
Stiwu Quantity G<»««*t<#
220 - 2,200 pounds
(100 - 1,000 kg)
s 13,200 pounds
(6,000kg)
s 180 days or
i 270 days if TSDF is over 200
miles away
Required
Required
Report within 60 days
Not Required ****
Basic plan required
Basic requirements with
technical standards under Part
265 for tanks and containers
Basic training required
RCRA permitted/ interim status
facility
MPOR
^o^**^
^ 2,200 pounds
(1,000kg)
No limit
£90 days
Required
Required
Contact transporter and
TSDF within 35 days,
submit report within 45 days
Required
Full plan required
Full compliance with
management of tanks,
containers, or drip pads
Required
RCRA permitted/interim
status facility
Provided minimum reqirements are met; namely, doing a hazardous waste determination, not exceeding
maximum storage limits and properly disposing of wastes.
For CESQGs, if quantity is exceeded, entire waste amount is subject to full SQG requirements. For SQGs
and LQGs, if maximum weight limit or time limit is exceeded, the facility is in violation for storing without a
permit. Only permitted facilities are authorized to exceed these weight and time limits; permit requirements
are extensive.
Transporters typically require. State might also require.
Even a one time generation of 1000 kg or greater in one month of an odd numbered year (1997,1999, etc.)
can make your dry cleaner subject to this requirement.
***** Check state requirements. Some states, like Iowa, do not allow hazardous waste to be sent to a sanitary
landfill in their state.
**
***
****
n-12
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EPA Identification Number—an EPA Identification
(ID) Number can be'obtained by filling out and
submitting a Federal "Notification of Hazardous Waste
Activity" form (EPAform 8700-12). This EPA ED
Number is assigned to the specific street address and
the person generating the hazardous waste. If the
person generating the hazardous waste moves, they
must notify EPA or the state of the new location,
submit a new form 8700-12, and obtain a new EPA ID
Number. If a person takes over a dry cleaner that
already has an EPA ID Number, that person will be
assigned the EPA ID Number already designated for
that dry cleaner. Federal regulations require only
LQGs and SQGs to obtain an ID number.
Some states and most transporters also require
CESQGs to obtain an EPA ID Number.
Owners/operators should contact their Federal
hazardous waste office to request the appropriate
form(s). (See Appendix A).
Biennial Report-report (EPA form 8700-13A) that
must be submitted by March 1 of each even numbered
year to the Regional EPA office by generator facilities
that during any one month of an odd numbered
year generated 1000 kg (2,200 pounds) per month
or more of hazardous waste. The report must cover
the generator activities conducted during the previous
(odd numbered) year.
Container Maintenance Requirements—apply to any
portable container in which a material is stored,
transported, treated, disposed of, or otherwise handled
(e.g., 55-gallon drums containing perc hazardous
waste). Several requirements regulate how containers
of hazardous waste must be managed. Labeling
containers with the words "Hazardous Waste" and the
date of generation are two key requirements.
Contingency Planning and Notification—needs to be
prepared in case of an emergency.
Maximum On-Site Time Limits—the amount of time
that hazardous waste can accumulate on site before it
must be removed.
Uniform Hazardous Waste Manifest—a multi-copy
shipping document It must accompany each hazardous
waste shipment to ensure the hazardous waste arrives
at its final destination.
Exception Reports—reports that indicate a missing
return copy of the hazardous waste manifest. The final
destination receiving the hazardous waste is required to
send a copy of the uniform hazardous waste manifest to
the hazardous waste generator.
Personnel Training—training to ensure all employees
are familiar with proper waste handling and emergency
procedures that are relevant to their responsibilities
during normal facility operations and emergencies.
Type of Facility Required for Off-site Management
of Waste—SQGs and LQGs are required to send their
hazardous waste to a RCRA-permitted facility. Unless
subject to stricter state requirements, CESQGs may
send their hazardous wastes to a state approved solid
waste facility (municipal landfill) or to a RCRA-
permitted facility.
n-is
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Additional Recommended Reading
For more information about the hazardous
waste regulations that apply to perc dry cleaners, it is
suggested that you read the EPA Handbook,
Understanding the Small Quantity Generator
Hazardous Waste Rules: A Handbook for Small
Business, Document Number: EPA/530-SW-86-019.
This document can be obtained from your Regional
EPA Small Business contact listed in Appendix A.
REMEMBER: YOU MUST
IDENTIFY YOUR GENERATOR
CATEGORY EACH MONTH.
What Happens When You Change Generator
Categories?
Under the federal hazardous waste
management system, you may be regulated under
different rules at different times, depending on the
amount of hazardous waste you generate in a given
month.
F
R
For example:
If in May... You generate 100 kg (220 pounds) or less
of hazardous waste
^ You would be a Conditionally Exempt Small
^ Quantity Generator (CESQG).
If. in June... Your hazardous waste totals more than 100
kg (220 pounds) but less than 1,000 kg (2,200 pounds)
•^ Your generator status changes and you would
be subject to the requirements for a Small
Quantity Generator (SQG).
If. in July...You generate less than 100 kg (220 pounds)
W^ You are once more a CESQG.
If. in September...You generate more than 1,000 kg
^ The wastes you generated in September would
be subject to all hazardous waste management
regulations applicable to a Large Quantity
Generator (LQG). Note that the hazardous
wastes you generated in September, as well as
the hazardous wastes from previous months,
are all subject to the LQG requirements as long
as you remain at that status.
As shown by the example above, your generator
status may change month to month.
n-i4
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StepS
Which wastewater
requirements apply?
Perc contact water generated by dry cleaners may
include separator water, vacuum water, and boiler
blowdown. The wastewater requirements that apply to
your dry cleaning shop depend upon:
whether you dispose of perc contact water from
your shop directly into a septic system;
whether the septic system you use is capable of
handling waste generated by more than 20 people
in one day, even if you do not dispose of perc
waste in the system;
whether you dispose of perc contact water from
your shop directly into a sewer system routed to a
municipal waste treatment plant.
Which Requirements Apply to a Dry Cleaner with
a Septic System (Underground Injection WelD?
The Federal underground injection well regulations
under the Safe Drinking Water Act prohibit the
disposal of perc-contaminated wastewater into a septic
system and are shown in Table H-6. These regulations
prohibit any disposal activity that would "endanger"
underground sources of drinking water by risking
contamination with pure perc or perc-contaminated
wastes. Thus, if your dry cleaner disposes perc waste
into a shallow disposal system, a dry well, or an
ordinary septic system, you would qualify as a Class V
underground injection well and are subject to the "no
endangerment" requirement. NOTE: EPA regulates all
large household, commercial, and industrial cesspools
and septic systems (capable of serving more than 20
people) no matter what they inject.
If found in violation of the "no endangerment"
requirement, the dry cleaner is subject to enforcement
action, remediation (including clean up and/or closure),
or may be required to obtain a permit. In most cases,
enforcement action is decided by the Federal
Underground Injection Control Director of that state
program as to what penalties or remediation may be
required. EPA-approved state UIC programs have
similar restrictions. Contact your EPA Regional Office
for the name of the state director (See Appendix A).
Hazardous Waste Septic System Discharge
Notification
If ANY amount of perc is discharged to the septic
system, you must notify immediately the EPA Regional
Underground Injection Control Program Director
and/or the State Underground Injection Control
Program Director. A list of these contacts is provided
in Appendix A.
Which Requirements Apply to a Dry Cleaner That
Discharges to the Sewer?
If your dry cleaning shop is connected to a sewer
system, you may be subject to federal pretreatment
requirements. Separator water and vacuum water
(which may have perc in it that is residual in clean
clothes and gets into the vacuum water during pressing)
may have pretreatment issues associated with them.
Table H-7 presents the wastewater requirements that
apply to dry cleaners.
n-i5
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General Prohibitions
The purpose of the federal pretreatment regulations
is to prevent discharge of pollutants, such as perc, to
the municipal treatment plant that could:
• Interfere with operation of the treatment plant;
• Pass through the plant untreated;
• Create problems with disposal of sludge from
the treatment plant; or
• Cause problems to treatment plant or sewer
system workers from exposure to chemicals,
explosion, or fire hazards of some chemicals.
Record keeping and Reporting Requirements
Reporting and record keeping requirements that
apply to perc dry cleaners include:
Notification of typical discharge
characteristics;
Notification of potential problems, including
unusually large discharges and spills;
Reporting required by the treatment plant
authority for industries that are not subject to
any federal categorical standards;
Notification of substantial change in the
wastewater discharge;
Recordkeeping for pollutant and flow feeds
that must be monitored or reported;
Notification of discharge of any hazardous
waste; and
Wastewater sampling records if sampling is
required by the treatment plant authority to be
conducted.
authority may require dischargers to sample their
wastewater periodically and report the results, or the
treatment plant authority may do the sampling itself.
For small industries such as dry cleaners not familiar
with how to collect and analyze wastewater samples,
the treatment plant authority will do the sampling. The
treatment plant authority will let you know if sampling
is required.
The treatment plant also needs to know about any
problems headed toward it through the sewer. You
must notify them immediately of any relatively large
discharge of a perc or any other pollutant that might not
ordinarily cause a problem when released in small
quantities.
If you are required to sample your wastewater,
records of all sampling information must be kept. This
includes, for all samples:
• The date, exact place, method of sampling,
and time of sampling and the names of the
person or persons taking the samples;
• The dates analyses were performed;
• The laboratory that performed the analyses;
• The analytical techniques/methods used; and
• The results of such analyses.
Dry cleaners must also keep records of any
monitoring conducted, even if it is not required by the
treatment plant authority. All of these records must be
kept for at least 3 years.
Because the treatment plant authority must know
what is being discharged into its treatment plant, the
n-i6
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Hazardous Waste Sewer Discharge Notification
In addition to the responses listed in the
contingency plan, such as contacting the proper
authorities if an accidental release occurs, if more than
IS kg per month (about 2.4 gallons) of perc is
discharged to the sewer you must notify the treatment
plant, your EPA Regional Waste Management Division
Director, and the state hazardous waste authority. The
notification must be in writing and include:
YOUR STATE'S
REQUIREMENTS MAY BE
STRICTER THAN THE
FEDERAL REQUIREMENTS, SO
ALWAYS CHECK WITH YOUR STATE
AGENCY.
• The name of the hazardous waste
("perchloroethylene").
• The EPA hazardous waste number (For example:
"F002" if it is waste from a still bottom, cooked
powder residue, or cartridge filter, "U210" if it was
unused perc from the machine or storage tank).
• The type of discharge (For example: "batch" for a
single event spill, such as a drum or container, or
"continuous" for a large spill that is not stopped).
If over 100 kg per month (about 16.6 gallons) is
discharged to the sewer then you must also include the
following in the notification:
• What hazardous constituents are in the waste (for
dry cleaners, it would be perc, or any other
potential solvents).
• An estimate of how much (mass and concentration)
was discharged during that month.
• An estimate of how much you will discharge in the
next 12 months.
n-i?
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n-is
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TABLE n-7
WASTEWATER REQUIREMENTS FOR DRY CLEANERS WITH SEWER SYSTEMS
General Prohibitions:
/ You may not discharge into the sewer any of
the following pollutants:
Pollutants including heat,
petroleum oil, and
nonbiodegradable cutting oil, that
cause pass through or interference
with the municipal treatment plant;
Pollutants that create a fire or
explosion hazard in the treatment
plant;
Pollutants that will corrode the
treatment plant, specifically any
wastewater with a pH less then 5;
Solid or viscous pollutants that
could obstruct wastewater flow;
and
Pollutants that result in toxic gases,
vapors, or fumes within the
treatment plant at levels that may
cause worker safety or health
problems.
Record keeping and Reporting:
-------
Section C: How do I
prepare my shop to comply
with environmental
requirements?
As you set up a new dry cleaning shop or continue
operating your present dry cleaning shop, you must
follow certain guidelines to make sure that your facility
complies with air, hazardous waste, and water
requirements.
Step 1: > Air
Select new dry cleaning equipment and evaluate
existing equipment.
Submit the appropriate initial reports and
compliance reports to EPA to show that air
emission requirements are being met.
Step 2: /> Hazardous
Waste
> Obtain a U.S. EPA Identification number,
which registers your dry cleaner as a
generator of hazardous wastes.
»• Select a reputable and authorized hazardous
waste transporter.
Step 3: > Water
Disconnect from the septic system any drains
located near the dry cleaning operation where
perc contact cooling water may enter them.
Step 4: y Emergency
Planning
>• Develop a contingency plan in case of an
emergency. This plan is required for certain
hazardous waste generators (SQGs), and
strongly recommended, although not required,
for CESQGs.
>• Prepare for accidents and take steps to prevent
them.
Although there are no specific operating
requirements for complying with federal wastewater
pretreatment regulations, it is advised that you contact
your state/local wastewater authority to learn if there
are any permit requirements that apply to your dry
cleaning facility.
11-20
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Step 1: ^Preparing a dry cleaning
shop to comply with air
requirements
Select New Dry Cleaning Machines/Evaluate
Existing Machines '
All new dry cleaning machines must be dry-to-dry
machines and have refrigerated condensers (at least).
A Major machine [any machine located at a dry
cleaning facility with combined perc purchases greater
than 2,100 (or 1,800) gallonsfyr] must also have a
carbon adsorber to capture remaining perc'vapors
inside the dry-to-dry machine drum.
The type of air pollution control required for an
existing dry cleaning machine is based on the amount
of perc purchased for all of the dry cleaning machines
in the entire dry cleaning facility. Table H-2 on
Page H-7 helps you determine if you are a small area,
large area, or major source and to find out your
required controls for an existing machine.
If your dry cleaning machine requires a carbon
adsorber as a control equipment, then you must prepare
a place for a sampling port in the exhaust stack. You
will use the sampling port to measure the concentration
of perc in the stack to monitor the efficient operation of
the carbon adsorber. Measure the diameter of your
duct (or stack). The sampling port must be drilled at
least 8 duct diameters downstream from any flow
disturbance, such as:
»• A bend in the duct,
»• A point where the duct diameter becomes
wider or smaller,
•• The place where another duct is piped in or
out,
*• The beginning or end of the duct.
If your duct diameter is 10 inches wide, you would
multiply this number by 8 and drill the hole at least
80 inches downstream. The sampling port must also
be at least 2 duct diameters upstream from any flow
disturbance. This would be 20 inches if your duct
diameter is 10 inches.
Drill a hole (SAMPLING PORT) in the duct (or
stack) that routes the clean air away from the carbon
adsorber. The hole that you drill must be only large
enough for the testing colorimetric tube to fit into it
(usually 1/2 inch diameter). This hole must be
covered up when not testing.
Submit Initial Report/Compliance Reports
If you open a new dry cleaning facility and
purchase one or more NEW dry cleaning machines,
you are required to:
Submit an INITIAL REPORT upon startup.
A copy of the recommended form for this
initial report is found in Appendix B.
Submit a POLLUTION PREVENTION
COMPLIANCE REPORT by 30 days after
you begin operating your equipment showing
that you are performing all of the required
good housekeeping practices at your facility.
H-21
-------
Submit a CONTROL DEVICE
COMPLIANCE REPORT by 30 days after
you begin operating your equipment. A copy
of the recommended form for this report is
found in Appendix B. Note that some states
may request additional information.
Make sure that these forms are filled out
correctly and that either the dry cleaning plant
owner or manager has signed them.
Copies of these forms can be obtained by calling the
EPA Regional Office. A list of these contacts is given
in Appendix A.
For the CONTROL DEVICE COMPLIANCE
REPORT, you are required to report the amount of
perc you purchased over the past 12 months. If you are
a new shop, report the amount of perc you purchased
during the first month as you start up your new
machine. You will not be able to make an annual
consumption determination until you have completed
one year of operation with the new machines.
your new status. (See Page n-8 for guidance
on how to calculate this 12-month average).
If you have EXISTING machines at your dry
cleaning plant:
•• You were required to submit the INITIAL
NOTIFICATION and a POLLUTION
PREVENTION COMPLIANCE
REPORT by June 18,1994.
REMEMBER:
If the amount of perc you purchased exceeded
140 gallons, you must monitor the
temperature of the refrigerated condenser.
If the amount of perc you purchased exceeded
2,100 gallons, you must install a supplemental
carbon adsorber and monitor the perc levels
for either an internal (no vent) or external
(vented) carbon adsorber.
If you have a change in your dry cleaner
status: including a change in ownership or
address, purchase of new equipment, or a
change in size category, then you must submit
within 180 days a revised pollution prevention
and control device compliance report stating
If you are required to install a control device
(according to Table H-2 on Page H-7), then
you should have submited a CONTROL
DEVICE COMPLIANCE REPORT by
October 22,1996.
If you were not required to install a control
device, then you should have submitted a
POLLUTION PREVENTION
COMPLIANCE REPORT. In this report
you should have certified that you are
performing the required leak detection and
repair program and that you are following
good housekeeping procedures. A copy of the
recommended form for the POLLUTION
PREVENTION COMPLIANCE
REPORT is found in Appendix B.
n-22
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Step 2:)> Preparing a dry cleaning
shop to comply with solid
waste requirements
Obtain a U.S. EPA Identification Number
If your dry cleaning facility transports, stores, or
disposes more than 100 kg (about 220 pounds or
25 gallons) of hazardous waste in any calendar month
(you are an SQG or LQG according to Table H-4 on
Page n-11), you will need to obtain an EPA
Identification (ID) Number before the time of your first
shipment. Some states also require CESQGs to have
EPA ID Numbers, so contact your state hazardous
waste division to check on specific state requirements.
Transporters and facilities that store, treat, or dispose
of regulated quantities of hazardous waste generated by
dry cleaners must also have EPA ID Numbers. These
12-character Identification Numbers used by EPA and
states are part of a national database on hazardous
waste activities. Note that if your dry cleaning
facility already has an EPA Identification Number,
you do not need to re-register for one. Note also that
if you are a dry cleaner with several cleaning shops,
each separate shop needs a unique Identification
Number.
To obtain your EPA Identification Number
>• Call or write your state hazardous waste
management agency or EPA regional office
(see Appendix A) and ask for a copy of EPA
Form 8700-12, "Notification of Regulated
Waste Activity." You will be sent a booklet
containing the two-page form and instructions
for filling it out. Figure H-l provides a
sample copy of a notification form to show
you the kind of information required. (NOTE:
A few states use a form that is different from
the form shown in Figure H-1. Your state
will send you the appropriate form to
complete.)
»• Fill in the form with the same kind of
information shown in the sample form in
Figure H-1. This information covers your
"installation" (your dry cleaning site) and your
hazardous wastes.
>• To complete Item X of the form, you need to
identify your hazardous waste by the correct EPA
hazardous waste number. Perc wastes will have
the hazardous waste number of F002 or U210.
The common waste types generated by dry
cleaners are:
- cooked powder residues.
- still residues.
- spent cartridge filters.
>• Make sure your form is filled out completely and
correctly and sign the certification in Item IX.
Send the form to your state hazardous waste
contact. This address is listed in the information
booklet you received with the form.
This information will be recorded by EPA and the
state, and you will be assigned an EPA ID Number.
Use this number on all hazardous waste shipping
papers.
The EPA ID Number will stays with that particular
physical dry cleaning site or location. If you move your
dry cleaning business to another location, you must
notify EPA or the state of your new location, submit a
new form, and obtain a new EPA ID Number. If
hazardous waste was previously handled at the new
location, and it already has an EPA ID Number, you
will be assigned that number for your relocated dry
cleaning business.
n-23
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Figure H-l
Pitas* ndr » 9m Inaruaiont
far FHi*y NeUttctilon Dttor*
eompManq «v« tern. TH*
intomution t»qo«B*a (w» «
nquracl oy la* (Section JO JO
o/m» Rttaure* Cen&traaen
— .— . Notification of
EPA Regulated Waste
Activity
Date Ree«iv«a
(Fof Official Uia Only)
United Sates ErMronrrgntal Protection
I I
A. First Notification
D£. Subseqijent Notification
(coaiplfte item C)
II. Him* of Installation (tncludf compmr tnd tpacHIc situ mine)
III. Location of Installation (Physictl tddrts* not P.O. Box at Pouts Number)
Str «tt (eontlnuxQ
r' '.-.;-a:'atJon Millng Addrts* fS«« /nsmjctJons)
V. insuittUon Conliet (Pvtoa to 6« canaettd ngtnttng wtttotctMUts »t siu)
Phon« Number (ttu corf* indnumftoj
VI. irwUBaUon Contact Addrtu fSM CnttructforaJ
B. S
-------
Select a Hazardous Waste Hauler and Designated
Waste Treatment Facility
Careful selection of a hauler and a designated
waste treatment facility is especially important because
you, the dry cleaning shop owner, are ultimately
responsible for any accidents during transport and the
proper disposal of your dry cleaning wastes. This
could include liability under Superfund. Before
choosing a hauler or designating a facility, check with
the following sources:
>• Your friends and colleagues in the dry
cleaning business.
> Your trade associations).
> Your Better Business Bureau or Chamber of
Commerce.
»• Your state hazardous waste management
agency or EPA regional office, which will be
able to tell you whether or not a company has
an EPA Identification Number.
These sources can supply you with information on
possible complaints against or recommendations for
specific haulers or treatment facilities.
After checking these sources, contact the hauler
and designated hazardous waste management facility
directly to verify that they each have an EPA
Identification Number, and that they can and will
handle your waste, hi some states, the hauler and
designated facility may be required to have a special
license or permit to operate. Make sure that they have
the necessary permits and insurance, and that the
hauler's vehicles are in good condition. You may also
want to ask them:
•• To provide information on their track record.
> If they have ever been cited for improper practice.
Checking sources and choosing a hauler and designated
facility may take some time—try to begin checking
before you open your shop, well ahead of the time you
will need to ship your waste.
H-25
-------
Step 3: ^Disconnect Drycleaning
Process Wastes From
Septic System Wastes
Before beginning operations, check all drains and
pipes and know where they lead. If the drains and
pipes lead to a septic tank, a dry well, or other shallow
disposal system leading to the ground, ensure that no
perc contaminated wastes are disposed through this
system. Ensure that septic systems are used to dispose
solely sanitary wastes. If a dry cleaner has been
operated at your location previously, it is recommended
that you test the septic tank and groundwater for
previous perc contamination. If you do not, in the
future, you may become liable for someone else's
previous perc contamination.
Disposing of perc contaminated waste through the
septic system has the potential to contaminate
underground sources of drinking water, including the
well that supplies drinking water to the dry cleaning
plant Stopping the contamination of groundwater may
require expensive cleanup actions, such as pumping the
septic tank and possibly removing soil and ground
water around the septic system. Be safe! Save
potential cleanup costs, time, and money, and most
importantly prevent contamination by physically
separating perc containing wastes from sanitary wastes.
If your drains and pipes lead to a municipal
sewage system, call your local publicly owned
treatment works (POTW) to let them know that you are
operating a perc dry cleaner at your site. Ask them
about local requirements that may apply. You may
need to get a permit prior to beginning operation. It is
recommended that you do not dispose of anything
down the drain that may contain perc, even if the
POTW allows it.
n-26
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Step 4;/ Contingency planning and
accident prevention
Develop a Contingency Plan
A contingency plan is a plan that prepares for any
accidents that could possibly occur. Although a written
contingency plan is not federally required for SQGs or
CESQGs, it is strongly recommended. It is also
important to check with state and local authorities for
any additional contingency plan or emergency
preparedness requirements. A contingency plan can be
thought of as a set of answers to a series of "what if'
questions. For example: "What if there is a fire in the
area where perc waste is stored?" or "What if I have a
spill of hazardous waste or one of my containers
leaks?"
The following list gives some general directions to
follow in case of an emergency:
1-800-424-8802, or in Washington, D.C.:
426-2675. As soon as possible, clean up the
hazardous waste and any contaminated
materials or soil.
In the event of a fire, explosion, or other
release, which could threaten human health
outside of the dry cleaning facility,
immediately notify the National Response
Center at 1-800-424-8802.
If you call the National Response Center, give the
following information:
>• In the event of a fire, call the fire department
or attempt to extinguish the fire using the
appropriate type of fire extinguisher.
»• In the event of a spill or accidental release (an
unusually large discharge) equal to or over
100 pounds of perc or when a spill has
reached surface water, you must contain the
flow of hazardous waste to the extent possible
and notify the National Response Center. The
Center operates a 24-hour toll free number:
»• Your shop's name, address, and EPA
identification number (if you are an SQG).
>• The date, time, and type of incident (for example,
if it is a spill or fire).
»• The quantity and type of hazardous waste involved
in the incident.
•• The extent of injuries, if any.
* An estimate of the quantity and location of any
recovered materials, if any.
The RCRA regulations require that emergency
phone numbers and locations of emergency equipment
must be posted near telephones. This means that next
to the phone you must post:
H-27
-------
>• Name, office and home phone numbers, and
address of emergency coordinator.
> A site plan showing locations of nearby:
portable fire extinguishers.
special extinguishing equipment (if it uses
foam, inert gas, dry chemicals, etc.)
fire alarms.
spill control equipment (absorbent cotton
rags).
decontaminant equipment (safety shower, eye
wash fountain).
water at adequate volume and pressure if
needed to operate emergency equipment (such
as water hoses, automatic sprinklers, water
spray systems)
>• The telephone numbers of:
fire department
police department
>• Although not required, it is strongly recommended
that you also post the following phone numbers by
the telephone:
state or local emergency response teams
hospital
local ambulance service
National Response Center
State Department of Public Safety
appoint yourself or an employee to act as the
emergency coordinator to ensure that emergency
procedures are carried out in the event of an
emergency. The responsibilities of the emergency
coordinator are:
>• He/she (or someone designated by that person)
will be available 24 hours a day (at the facility or
by phone).
>• He/she will know whom to call and what steps to
follow in an emergency.
Because most dry cleaners are small businesses, the
owner or operator probably already performs these
functions. Therefore, it is not intended (nor is it likely)
that you will need to hire a new employee to fill this
role.
If you are unsure whether you should report and
you have a serious emergency, such as a spill that
extends outside of your plant or that could reach
surface waters, IMMEDIATELY CALL THE
NATIONAL RESPONSE CENTER (1-800-424-
8802) AND GIVE THEM THE INFORMATION
THEY ASK FOR. If you didn't need to call, they will
tell you so, BUT ANYONE WHO WAS
SUPPOSED TO CALL AND DOES NOT IS
SUBJECT TO A $10,000 FINE, A YEAR IN JAIL,
OR BOTH. An owner or manager of a dry cleaner
who fails to report a release also may have to pay for
the entire cost of repairing any damage, even if Ihe
facility was not the single or the main cause of the
damage.
In addition, all employees must know proper waste
handling and emergency procedures. Review
emergency procedures with employees. You must
H-28
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Accident Prevention
In accordance with RCRA, your facility must have
appropriate cleanup materials and emergency
communication equipment for handling perc waste at
your location. Some steps you should take to prepare
for emergencies include:
*• Making sure that there are no floor drains near
the area where perc is used that lead to the
sewer, septic tank, or storm water drain.
•• Have absorbent cotton blankets in the area
where perc solvent is used or stored and
keeping them in a container marked with
"spill cleanup absorbent blankets."
*• Store hazardous waste in areas away from
doorways. The floor in your solvent storage area
should be leak-proof (such as concrete with an
epoxy coating). If there is a doorway nearby, a
concrete barrier must prevent the solvent flowing
out of the door in case of a large spill.
>• Provide room for emergency equipment and
response teams to get into any area in your faculty
in the event of an emergency.
»• Write to local fire, police, and hospital
officials or state or local emergency response
teams explaining that you handle perc wastes
and asking for their cooperation and
assistance in handling emergency situations.
>• Install and maintain emergency equipment
(such as an alarm, a telephone, or two-way
portable radios, fire extinguishers, hoses, and
automatic sprinklers) in your facility so that it
is immediately available to your employees if
there is an emergency.
*• Supervise any transfer of solvent that takes
place on your premises. Take extra
precautions if your perc solvent is delivered
from a tanker truck and piped through a hose
into your dry cleaning solvent tank. If the
hose breaks or the nozzle slips out of the tank,
a large spill could occur.
>• Set up your dry cleaning machine in a
containment trough. Although not required by
Federal regulations, some local regulations
may require this structure for new dry
cleaning machines. This structure must be
non-porous (constructed of materials such as
epoxy-coated concrete, fiberglass, or steel).
Contact your EPA Regional Small Business
contact or Dry Cleaning Trade Association for
names of manufacturers of these products. It
must be designed to contain 110% of the perc
contained in any single solvent tank. It serves
to capture perc leaks from malfunctioning
equipment and to contain spills.
H-29
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Section D: How to properly
operate a dry cleaning
machine and shop to stay in
compliance with
environmental regulations?
This section covers what a dry cleaner needs to do
during normal operation to comply with air, hazardous
waste, and water regulations. These steps include
proper operation of equipment, periodic monitoring
and reporting, and proper handling and storing of
hazardous wastes.
Another important step is cooperating with
inspection officials and using a visit by an inspector
as an opportunity to identify and correct problems.
Accompanying state or local inspectors on a tour of
your shop will enable you to ask any questions you may
have and receive advice on more effective ways of
handling your hazardous products and wastes. In
addition, guiding the inspectors through your property
and explaining your operations may help them to be
more sensitive to the particular problems or needs of
your business. Accompanying state or local inspectors
can also serve as a valuable source of information on
record keeping, manifests, and safety requirements for
your dry cleaning shop.
Step I:/ Staying in compliance with
air regulations
Follow Good Housekeeping Practices. Including
Leak Detection and Repair
To reduce the amount of perc emissions to the air,
all perc dry cleaners must:
Conduct a leak detection and repair program
once each week while the equipment is
operating. Search for all leaks that are
obvious to sight, smell, or touch. A sample
log sheet that you may use to record this
weekly check is provided in Figure n-2.
[Note that if you are SMALL AREA and
exempt from installing controls, this program
is only required every other week.]
Whenever you find any leaks, repair them
within 24 hours. Or, if parts are needed to
repair the equipment, place the order for any
repair parts within 2 working days after
detecting the leak. Install the repair parts
within 5 working days after you receive them.
Keep the doors on your dry cleaning machines
closed at all times except when loading or
removing articles.
Keep all perc and perc wastes in leak-proof,
tightly covered containers.
Place cartridge niters inside leak-proof,
tightly covered containers to drain them.
E-30
-------
Figure H-i
MONTHLY MACHINE MAINTENANCE AND
PERCHLOROETHYLENE LOG
CHHCK KVFRY 7 DAVS
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
2) 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
11) Cartridge filter housings
CHF.CK RVF.RY 7 DAYS (Applicable Sections Only) Week.
(Monitoring not required for existing plants until Date
September 22, 1996)
Week Week Week_ Week.
Date Date Date Date
Transfer system (washer) temperature difference
(Measure difference between inlet and outlet
temperatures of refrigerated condenser) (Write
°C or °F)
Dry-to-dry machines, dryers, and reclaimers
Condenser temperature (outlet) (Write °C or °F)
Carbon adsorber concentration (onm)
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 also show perc volume, parts/repair invoices, and repair orders
(if written) with this sheet and save for at least five years.
H-31
-------
> Operate and maintain all of your dry cleaning
equipment according to the manufacturer's
instructions. An operator's manual should be
included whenever you purchase dry cleaning
equipment Keep the manual near the
equipment and inform all employees where it
is kept. If you are unable to locate your
manual or operating instructions, contact your
local dry cleaning distributor or trade
association who will help you find one. If you
still do not have manuals for all ofyour
equipment, call EPA to obtain a copy of
document number EPA-4531R-94-07,
dated October 1994, for general
recommended operating and maintenance.
Monitor Control Devices
By testing your control equipment each week, you
can check to make sure that it is running without
problems. If your tests show that you have a problem,
you must fix the problem before continuing to operate
the machine.
If you have EXISTING machines, you should
have begun monitoring program for your control
equipment by September 22,1996. If you have a
NEW machine, you must begin a monitoring program
IMMEDIATELY when you start operating your
machine.
If a REFRIGERATED CONDENSER (or
chiller) is your required control equipment, you need a
temperature sensor. The temperature sensor that you
use must be designed to measure a temperature range
of at least 32 to 120°F and must be accurate to +2°F.
You must MEASURE THE TEMPERATURE
OF THE PERC IN THE COOL-DOWN AIR
STREAM. If the air stream leaving the
refrigerated condenser is still warm, perc vapors
inside the drum will not be removed sufficiently.
Measuring the temperature will show whether perc
is being removed from the drying clothes and
recycled back into the solvent tank.
If you have a dry-to-dry machine or a transfer
dryer/reclaimer, you must measure the
temperature of the perc air stream on the
OUTLET SIDE of the refrigerated
condenser. The temperature must be LESS
THAN OR EQUAL TO 45°F.
To obtain a temperature sensor, contact your
equipment manufacturer, your local dry
cleaning equipment distributor, or a trade
association.
IF YOU DO NOT HAVE A
TEMPERATURE SENSOR TO
MONITOR YOUR REFRIGERATED
CONDENSER FOR COMPLIANCE,
OR IF THE TEMPERATURE DOES NOT FALL
BELOW 45°F, EPA STRONGLY URGES YOU
TO CONTACT BOTH YOUR TRADE
ASSOCIATION AND YOUR EQUIPMENT
MANUFACTURER. PROPER INSTALLATION
OF THE TEMPERATURE SENSOR IS VERY,
VERY IMPORTANT TO YOU. IT MUST BE
DONE CORRECTLY. OTHERWISE,
COMPLIANCE MAY NEVER BE
DEMONSTRATED, AND YOU MAY DO
EXPENSIVE DAMAGE TO YOUR
EQUD?MENT. EPA ADVISES THAT A
REPUTABLE MECHANIC PERFORM THE
INSTALLATION, IF ONE IS REQUIRED.
>• If you have a transfer washer, you must
measure the DIFFERENCE between the
temperature of the perc air stream entering
and exiting the refrigerated condenser. -The
temperature difference must be GREATER
THAN OR EQUAL TO 20°F. For example,
if the temperature of the perc air stream
entering the refrigerated condenser is 90°F
and the temperature of the perc air stream
exiting the refrigerated condenser is 50°F,
then the difference would be:
90°F-50°F = 40°F, which is greater than 20°F
If you use a CARBON ADSORBER (or
"sniffer") for required control of your perc emissions, it
must have been installed before September 22,1993.
In addition:
n-32
-------
Figure H-3
•• You must SET UP A REGULAR WEEKLY
DESORPTION SCHEDULE. Your carbon
adsorber becomes useless if you do not desorb it,
or if you do not dry it thoroughly after desorbing it.
Air from your machine will pass through it without
removing the perc, and the perc will be sent into
the air where people can breathe it.
>• You must MEASURE THE
CONCENTRATION OF PERC IN THE
EXHAUST STACK OF THE CARBON
ADSORBER ONCE A WEEK to check
that the carbon adsorber is removing the perc
and not letting the perc pass by into the
exhaust.
Take the measurement during the last aeration
cycle using a colorimetric detector tube. See
Figure H-3 for a picture of the type of tube required.
Most tubes operate with a simple hand-operated pump
(See Figure H-4). Some tubes are operated with a
bellows pump that is squeezed several times. The tube
is small, and can fit in the palm of your hand. It is filled
with a chemical substance that changes color (usually
varying shades of purple) depending on the perc
concentration. Each tube can be used only one time.
The result of the colorimetric detector tube test must
show that the concentration of perc in the exhaust gas is
100 parts per million (ppm) or less. If the test shows a
concentration greater than this level, then you must
increase the number of times per week that you desorb,
or look for equipment malfunctions. Ask your dry
cleaning equipment distributor or trade association
where to buy the tubes and to provide a demonstration
on how to use them properly.
If you are a new MAJOR source that uses a
carbon adsorber with a refrigerated condenser on a dry-
to-dry machine where the exhaust passes through the
carbon adsorber before the machine door is opened,
then you must measure a concentration of 300 ppm to
an accuracy of ±75 ppm by volume inside the machine
drum with a colorimetric detector tube.
n-ss
-------
9S0213O-J..RT
Hand BeHow* Pump
Figure n-4
record the concentration (in ppm).
If you are required to measure the temperature
of your refrigerated condenser, use the
recommended log sheet found in Figure IL-2
on Page n-31 to record the temperature.
Perform Proper Record keeping and Reporting
Each dry cleaner must keep certain records to
show that good housekeeping practices and monitoring
are being done:
»• After you search your machine for leaks, you
must record your findings. It is recommended
that you use a log sheet similar to the one
found in Figure n-2 on Page n-31. If
repairs are needed, record the types of repairs
needed on the log sheet. If you ordered repair
parts, also fill in a description of the parts, and
the date they were ordered. A log of all
inspections and repairs made must be kept
in your shop for 5 years.
> Your status of SMALL AREA, LARGE
AREA, or MAJOR is determined by adding
up all of the perc purchases made for YOUR
ENTIRE SHOP during any 12-month
period. (See Tables H-2 and n-3). SAVE
THE RECEIPT EACH TIME YOU
HAVE PERC DELIVERED FOR YOUR
MACHBSE(S). On the first day of each
month, you must add together all of your perc
purchases from the previous 12 months and
record it (See Page H-8 for directions on
how to calculate the monthly rolling average).
It is recommended that you use a log sheet
similar to the one found in Figure n-5 on
Page 11-35 to record your purchases and
12-month totals.
»• If you are required to test the exhaust of your
carbon adsorber, use the recommended log
sheet found in Figure H-2 on Page n-31 to
n-34
-------
Figure U-5
SAMPLE LOG SHEET FOR PERC PURCHASES
Starting amount: (Amount of p
NOTIFICATION)
MONTH/DAY/YEAR
AMOUNT OF PERC
PURCHASED
PAGE
ere purchases reported in INITIAL
12-MONTH AVERAGE •
* Staple or keep all perc purchase receipts with this form.
n-ss
-------
Staying in compliance with
hazardous waste
regulations
Know On-Site Storage Limits
If you are a CESQG, you may store up to 2,200 Ib
(1,000 kg) of hazardous waste on your site. There is no
time limit for how long you are allowed to store this
waste. However, if you exceed this amount, you
become an SQG. If you are an SQG, you may store no
more than 13,200 Ib (6,000 kg) of hazardous waste on
your site for up to 180 days, or for up to 270 days if the
waste must be shipped to a treatment, storage, or
disposal facility that is located over 200 miles away. If
you exceed these time or quantity limits, you will be
considered a storage facility and you must obtain a
storage permit (see below) and meet all of the RCRA
storage requirements. These time limits on storage are
longer than the 90 days allowed LQGs. SQGs are
allowed to store waste for as long as 180 or 270 days
so that they will have time to accumulate enough
hazardous waste to ship it off-site for treatment or
disposal economically.
YOUR STATE'S
REQUIREMENTS MAY BE
STRICTER THAN THE
FEDERAL REQUIREMENTS, SO
ALWAYS CHECK WITH YOUR STATE
AGENCY.
Follow Requirements for On-site Hazardous Waste
Storage1
You can store hazardous waste in 55-gallon
drums, tanks, or other suitable containers if you follow
certain common sense rules that are meant to protect
human health and the environment and reduce the
likelihood of damages or injuries caused by leaks or
spills of hazardous wastes.
If you store your hazardous waste in <
containers, you must follow these rules:
»• Clearly mark each container with the words
"HAZAKDOUS WASTE," and with the date
you began to collect waste in that container.
(Labels for this purpose are also available
from your hauler or trade association.)
>• Although marking the EPA waste code on the
drum is not required by federal regulations, it
is required by most states and is highly
recommended.
* Keep containers in good condition, handle
them carefully, and replace any leaking ones.
>• Do not store hazardous waste in a container if
it may cause rupture, leaks, corrosion, or other
failure.
>• Keep containers closed except when you are
adding or removing wastes.
* Inspect the container for leaks or corrosion
every week.
n-36
-------
> NEVER store in the same container wastes
that could react together to cause fires, leaks,
or other releases. If all your wastes are perc-
related then this requirement is not of concern
to you.
* Make sure that the stored waste is taken off-
site to be properly disposed of within 180 (or
270) days if you are an SQG.
NOTE THAT MOST PERC DRY
CLEANERS DO NOT HAVE TANKS.
>• • Use the National Fire Protection Association's
(NFPA) buffer zone requirements for tanks
containing ignitable or reactive wastes. These
requirements specify distances considered as
safe buffer zones for various liquids based on
the characteristics of all combustible and
flammable liquids. Call your local fire
department of EPA regional office (see
Appendix A) if you need help.
»• Make sure that the stored waste is taken off-
site to be properly disposed of within 180 (or
270) days if you are an SQG.
However, if you do store your waste in tanks, you must
follow these rules:
>• Don't store hazardous waste in a tank if it may
cause rupture, leaks, corrosion, or other
failure.
>• Keep tanks covered or provide at least 2 feet
of freeboard (space at the top of the tank) in
uncovered tanks.
>• If your tanks have equipment that allow the
waste to flow into them continuously, provide
waste feed cutoff or bypass systems to stop
the flow in case of problems.
»• Inspect monitoring or gauging systems on
each operating day and inspect the tanks every
week for leaks or corrosion.
Know About Accumulating Hazardous Waste in
Satellite Areas
A dry cleaner that is an SQG is allowed to collect
up to 55 gallons of perc hazardous waste in a properly
labeled drum or container kept near the dry cleaning
machine. The drum must be marked with the words
HAZARDOUS WASTE or with other wording that
identifies the contents of the container. Such a drum is
then located in a "Satellite Accumulation" area.
However, once the amount of perc waste in the drum
reaches 55 gallons, it must be marked with the; date it
reaches that amount and the dry cleaner must move the
container to the designated on-site hazardous waste
storage area within 72 hours (3 days). The dry
cleaning machine operator is responsible for this drum
as long as it is kept separate from the designated
storage area. If you are an SQG this storage area can
contain up to about 13,200 Ib (6,000 kg or
30 55-gallon drums).
H-37
-------
Reduce the Amount of Hazardous Waste You
Generate
Good hazardous waste management can be
thought of as performing "good housekeeping"
practices. These include: performing proper drying
(reclamation) and distillation, using and reusing
materials as much as possible; recycling or reclaiming
waste; or reducing the amount of waste you generate.
To reduce the amount of waste you generate:
> Do not mix nonhazardous wastes with
hazardous ones. For example, do not put
nonhazardous cleaning agents or rags in the
same container as perc wastes or the entire
contents become subject to the hazardous
waste regulations.
*• Avoid mixing several different hazardous
wastes. Doing so may make recycling very
difficult, if not impossible. It may also make
disposal more expensive.
Reducing your hazardous waste means saving money
on raw materials and reducing the costs to your
business for managing and disposing of your hazardous
wastes.
Conduct Weekly Inspections
If you are an SQG, you must inspect your
hazardous waste storage areas weekly to make sure that
drums are in good condition. During your inspection,
you must make sure:
> All drums are labeled/marked appropriately.
»• There is sufficient space to walk in the storage
area.
»• All drums are stacked properly.
»• Avoid spills or leaks of hazardous products.
(The materials used to clean up such spills or
leaks also becomes hazardous waste.)
>• Make sure the original containers of
hazardous products, such as spotting
chemicals, are completely empty before you
throw them away. Use ALL of the product
>• Avoid using more of a hazardous product than
you need. For example, use no more perc
than you need to do the job.
>• All drum lids are closed tightly.
Any problems should be corrected immediately. If any
corrections are made, they should be noted in a
permanent record and kept on file for at least 3 years.
It is recommended that you place appropriate signs
warning other employees that this is a hazardous waste
storage area.
n-38
-------
REMEMBER: IF YOU ARE STILL
UNCERTAIN ABOUT HOW TO
HANDLE YOUR HAZARDOUS
WASTE, OR HAVE ANY
QUESTIONS CONCERNING THE RULES FOR
100-1000 KG/MO GENERATORS, THERE ARE
SEVERAL SOURCES LISTED IN APPENDIX A
THAT YOU CAN CONTACT FOR ANSWERS.
TAKING RESPONSIBILITY FOR PROPER
HANDLING OF HAZARDOUS WASTE WELL
NOT ONLY ENSURE A SAFER
ENVIRONMENT AND WORKPLACE FOR
EVERYONE, BUT WILL SAVE YOUR
BUSINESS MONEY. SO WRITE OR CALL
YOUR STATE HAZARDOUS WASTE
MANAGEMENT AGENCY OR THE EPA WITH
YOUR QUESTIONS TODAY.
Follow Record keeping and Reporting for
Hazardous Waste Management Practices
Each dry cleaner that is an SQG is required to
keep records to show that good housekeeping practices
and monitoring are being performed. These records
must be kept at your facility for 3 years and include:
>• Weekly records showing that the hazardous waste
storage area is in good condition or, if a problem is
found, a description of the problem and the
correction.
>• Records of monthly inspections of emergency
equipment.
> Copies of all hazardous waste manifests.
*• A log that includes the number for each hazardous
waste manifest and the day it was shipped. This
log must be checked weekly to make sure that the
return copy of each manifest has been received
within 60 days.
* Copies of all Notification of Hazardous Activity
forms submitted to and received from the state or
the EPA.
Follow Record keeping and Reporting for
Hazardous Waste Shipments;
Fill Out the Uniform Hazardous Waste
Manifest
A hazardous waste manifest is a multi-copy
shipping document that you must Gil out. It must
accompany your hazardous waste shipments. This
manifest is required for SQGs. Although manifests are
not required for CESQGs, they are recommended.
The manifest form is designed so that shipments of
hazardous waste can be tracked from their point of
generation to their final destination—the so-called
"cradle-to-grave" system. The hazardous waste
generator, the hauler, and the recipient at the final
n-39
-------
destination (the disposal/treatment facility) must each
sign this document and keep a copy. The designated
facility operator also must send a copy back to you, so
that you can be sure that your shipment arrived. You
must keep this copy, which will be signed by the hauler
and designated facility, on file for 3 years.
REMEMBER: JUST BECAUSE
YOU HAVE SHIPPED THE
HAZARDOUS WASTE OFF YOUR
SITE AND IT IS NO LONGER IN
YOUR POSSESSION, YOUR LIABILITY HAS
NOT ENDED. YOU ARE POTENTIALLY
LIABLE UNDER SUPERFUND FOR ANY
MISMANAGEMENT OF YOUR HAZARDOUS
WASTE. THE MANIFEST WILL HELP YOU
TO TRACK YOUR WASTE DURING
SHIPMENT AND MAKE SURE IT ARRIVES AT
THE PROPER DESTINATION.
»• The shipment is ready for transport.
> You have reduced the amount and hazardous
nature of your wastes to the greatest extent
possible (within your budget constraints).
States, haulers, recyclers, and designated facilities may
require additional information; check with them before
you prepare a hazardous waste shipment. Your
hazardous waste hauler often will be the best source for
packaging and shipping information and will help in
completing the manifest. If you have any trouble
obtaining, filling out, or using the manifest, ask your
hauler, your designated facility operator, or one of the
contacts listed in Appendix A for help.
You can obtain blank copies of the manifest from
several sources. To determine which source you
should use, use this system:
»• Your hauler.
>• The state to which you are shipping your waste.
*• The state where you generate waste.
>• If neither state requires a state-specific manifest,
you may use the "general" Uniform Hazardous
Waste Manifest—EPA Form 8700-22. Copies are
available from some haulers and designated
hazardous waste management facilities, or they
may be purchased from some commercial printers.
A sample copy of a hazardous waste manifest is
shown in Figure H-6. When you sign the certification
in ITEM 16 you are personally confirming that:
>• The manifest is complete and accurately describes
the shipment
H-40
-------
Figure II-6
Please print v type. If arm ttitigntii lor ait on alilt 112-gachi lYpewriur.l
Farm Approved. OMB No. 2050-O&39. Expires 9-30-91
H
e
K
t
T
0
A
UNIFORM HAZARDOUS
WASTE MANIFEST
3. Generator s Name and Mailing Address
4. jGenerator's Phone ( )
5. Transporter 1 /Company Name
7. Transporter 2 Company Name
Document No.
1 1 I 1 1 1 1 '1 1 1 1 1 1 1 1
1 1 1 1 1 I 1 1 1 II
8. US SPA ID Number
i i i i i i i i i i '
9. Designated Facility Name and Site Address 1O. US EPA ID Number
i i i i i i I i i i
12. Com
11. US DOT Description llncluding Prcptr Shipping Ntmt. H»iu4 Cllli. a/to* ID Numturl
No.
a.
"•
i
i
1
d.
i
J. Additional Oweripixxis lot M»en»tsj Lined. Above ."-•"" - .• -:- <>•--•-
... ;, j.-^/' «• A /*, " ,
•. •• • , -^- '• ' ;' " ''V'*/:'
' '' ' ' "• J f
is not required by Federal
of law.
A. State Manifest. Document Number
S. State Generator s ID
C. State* Transporter s 10
0. Transporter's Phone>
E. State Transporter's ID
F. Transporter's Phone
0. State Facility's ID
H. Facility's Phone
liners 13. 14.
Total Unit '•
Type Quantity Wi/Vo Waste No.
1 1 1 1
fill
1 1 II
I I 1 1 :
K.Handtinc; Codes for WtstesUstetfAeovc
IS. Special Handling instructions and Addition*! Information
proper snipping rume and are classified, packed, marked, and labeled, and are in all respects in proper condition for transport by nqhway
according to applicable international and national government regulations.
If 1 am > large quantity generator. 1 certify rtwt 1 have a program in place to reduce ihe volume and to«ieity ol wiste generated to me degree 1 have determined to be
economically practicable and that 1 have selected the praowable method o« treatment, storage, or disposal currently available to me wnich minimizes the present and
future threat to human health and the environment OR. if 1 am a small quantity generator. 1 have made a good laun effort to minimize my waste generation and select
Printed/Typed Name Signature miomn u*, rtir
1 1 1 1 1 !
1 7Transoorter 1 Acknowledgement ot Receipt of Materials
Printed/typed Name
Signature /won", un •*•'
1 1 1 1 >
18. Transporter Z Acknowledgement of Receipt of Materials
Printed/Typed Name
1 1 1 1 1
19, Discrepancy Indication Space
JO.Facility Owner or Operator- Certification of receipt «l hazardous materials covered by this mam esi «»ceot as noted .n item 19
Printed/Typed Name
1 I L • 1 I
EPA Form 87OO-22 (««». »•««) Previous editions are obsolete
n-4i
-------
Exception Reports
An SQG must file an Exception Report if the
return copy of the hazardous waste manifest is missing.
If the manifest copy, which must be hand signed by the
final destination facility, is not received by the SQG
within 60 days of the date that the waste was initially
shipped, the SQG must submit to the EPA Regional
Office (See list in Appendix A) a copy of the manifest
and an explanation that no confirmation of delivery was
received. If you do not receive a signed copy from the
designated hazardous waste management facility within
30 days, it is a good idea for you to find out why and, if
necessary, let the state or EPA know.
Notify Your Management Facility About Land
Disposal Restrictions
If you are an SQG (based on requirements given in
Table BE-5 on Page 11-12), for each shipment of
hazardous waste that you send off site, you must
provide the designated receiving facility with a LAND
DISPOSAL RESTRICTION NOTIFICATION.
Although no form has been developed by EPA to report
this information, the following information is required:
>• EPA Hazardous Waste number (for perc waste,
thisisF002).
>• The chemical of concern (which is
tetrachloroethylene)
»• Treatability group (wastewater or nonwastewater).
For sludge waste, or nonwastewater, the
concentration of perc in the waste cannot exceed
6.0 mg per liter. For wastewater, the
concentration of perc cannot exceed 0.054 mg/L.
The manifest document number for the
particular hazardous waste shipment. (See
item 1 on THE HAZARDOUS WASTE
MANIFEST).
Waste analysis data (if available).
Step 3: ;> Staying in
compliance with
wastewater
standards
Know General Discharge Prohibitions
You must know how much perc you are allowed to
discharge to the sewer based on state/local
requirements and the proper reporting and record
keeping activities if you exceed these levels. Contact
your state or local water agency for the specific
requirements on discharges and reporting and record
keeping. Section B, Step 3 describes which
requirements apply to dry cleaners that are connected
to a sewer system.
Know Underground Injection Well Requirements
Do not dispose of any perc waste into your
septic system. If you do, you become subject to
enforcement action, remediation (cleanup or closure),
or obtaining a permit. The specific enforcement action
will be determined by the Underground Injection
Control Program Director for your state. Section B,
Step 3 describes which requirements apply to dry
cleaners with a septic system.
H-42
-------
Part III: Questions an Inspector May Ask
While Visiting Your Dry Cleaning Shop
General ^
Are you aware of the air, hazardous waste, 9
and wastewater regulations that apply to
.perc dry cleaners?
Do you know how to contact the small business
technical assistance program in your state? Have you
received any assistance from them?
How do you usually find out about the local, state, and
federal environmental regulations impacting your dry
cleaning business?
Are you receiving articles to clean from other dry
cleaning stores?
Is your store front name the same as your actual
company's name?
Hazardous Waste
What environmental permits do you have?
Can you show them to me?
Do you have a U. S. EPA Identification Number? If so,
what is it? Can you show documentation to support it?
Show me where you store your still residues, spent
cartridges, cooked powder residue, and other hazardous
wastes. Are the containers kept closed and secured?
Are they properly labeled? Do you inspect these
containers regularly to make sure they are not leaking?
How often do you fill a 55-gallon drum with hazardous
waste?
Do you drain spotting chemicals and other chemicals
completely to make sure that the container is legally
empty and not regulated as a hazardous waste?
Do you treat your hazardous waste on site, or do you
use a hazardous waste transporter to remove it off site?
Show me your manifest logs.
Do you have an emergency plan in case of an accident?
Are all employees aware of it?
Are your perc storage tanks diked, and is the dike
coated on the inside with a sealer? Could a leak from
your perc storage tank be contained?
m-i
-------
Air
Have you sent your Initial
Notification Report and your Pollution Prevention
Compliance Report to your EPA Regional Office?
Have you sent your Control Requirements Compliance
Report if a control device is required?
Show me your records of perc purchases and
calculations for rolling yearly averages. (These records
must be kept in your shop for at least 5 years.)
Do you have a copy of the design specifications and the
owner's operation and maintenance manual for your dry
cleaning machines and control equipment? Show me
your manual. If you do not have one, show me a copy
of the EPA document, General Recommended
Operating and Maintenance Practices (EPA-4531R-
94-07), dated October 1994, which you should have on
hand instead. Does your manual contain standard
operating procedures that could be used as your
Startup, Shutdown, Malfunction plan?
If you are operating a refrigerated condenser as control
equipment on your dry-to-dry machine, show me how
you take a temperature reading for your compliance
test How often do you perform this test? Show me
your log where you record this temperature. What do
you do if the outlet temperature is above 45°F,?
If you are operating a refrigerated condenser or control
equipment on your transfer washer, show me how you
measure the inlet and outlet temperature difference on
the refrigerator condensers. What do you do if this
temperature difference is 20 °F or less?
When was your carbon adsorber/sniffer installed? How
often do you desorb your carbon adsorber? Show me
how you take an outlet perc concentration reading.
How often do you perform this test? Show me your log
where you record the ppm concentration. What do you
do if this outlet concentration exceeds 100 ppm?
Show me how you perform your leak detection test.
Show me your log where you record findings. How
often do you perform this test? Show me your log
where you record repair dates and keep orders for
repair parts.
Water
Are your pipes and drains connected to
the city/town sewer system? Or a septic system?
What steps would you take if you had a perc spill?
What would you do if that perc spill reached your
drains?
Do you understand the Federal Underground Injection
Control Program? Would you like additional
information on the program?
m-2
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APPENDIX A: EPA REGIONS
0,nver I 7 LMO
KS Kan as City
Regions
4 — Alabama
10 — Alaska
9 — Arizona
6 — Arkansas
9 — California
8 — Colorado
1 — Connecticut
3 — Delaware
3 — D.C.
4 — Florida
4 — Georgia
9 — Hawaii
10 — Idaho
5 — Illinois
Regions
5 — Indiana
7 — Iowa
7 — Kansas
4 — Kentucky
6 — Louisiana
1 — Maine
3 — Maryland
1 — Massachusetts
S — Michigan
5 — Minnesota
4 — Mississippi
7 — Missouri
8 — Montana
7 — Nebraska
Regions
9 —Nevada
1 — New Hampshire
2 — New Jersey
6 — New Mexico
2 — New York
4 — North Carolina
8 — North Dakota
5 — Ohio
6 — Oklahoma
10 — Oregon
3 — Pennsylvania
1 — Rhode Island
4 — South Carolina
8 — South Dakota
Regions
4 — Tennessee
6 —Texas
8 — Utah
1 — Vermont
3 — Virginia
10 — Washington
3 — West Virginia
5 — Wisconsin
8 — Wyoming
9 — American Samoa
9 — Guam
2 — Puerto Rico
2— Virgin Islands
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EPA Regional Office
Dry Cleaning Air Contacts
Douglas Koopman
EPA - Region I Mail Code (SEA)
JFK Federal Building
Boston, MA 02203-2211
(617) 565-3252
koopman. douglas@epamail. epa.gov
Venkata Rao
EPA - Region n
290 Broadway
New York, NY 10007-1866
(212) 637-4053
koopman.douglas@epamail.epa.gov
James C. Kenney
EPA - Region m (3AT12)
841 Chestnut Building
Philadelphia, PA 19107
(215) 566-2152
kenney.james@epamail.epa.gov
Rosalyn Hughes
EPA Region IV Atlanta Federal Center
61 Forsyth Street, SW
Atlanta, GA 30303-3415
(404) 562-9206
hughes.rosalyn@epamail.epa.gov
John Kelly (AR-18J)
EPA - Region V
77 W. Jackson Boulevard
Chicago, IL 60604
(312)886-4882
kelly.john@epamail. epa.gov
Mary K. Maruska
EPA Region VI (6T-EC)
1445 Ross Avenue
Dallas, TX 75202-2733
(214) 665-7598
marusak.mary@epamail.epa.gov
Alma Moreno-Lahm
Region VII (RAECO)
726 Minnesota Avenue
Kansas City, KS 66101
(913) 551-7380
moreno. alma@epamail. epa. go v
Scott Whitmore
EPA Region VIII (9ENF-T)
999 18th Street
Denver Place, Suite 500
Denver, CO 80202-2045
(303)312-6317
whitmore. scott@epamail.epa.gov
Angela Baranco
US EPA Region IX (AIR-6)
75 Hawthorne Street
San Francisco, CA 94105
(415)744-1196
baranco. angela@epamail. epa.gov
Chris Hall
EPA Region X (OAQ-107)
1200 Sixth Avenue
Seattle, WA 98101
(206) 553-1949
hall. christopher@epamail. epa. gov
A-2
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EPA Regional Office
Small Business Contacts
Dwight Peavey
EPA Region I (SPT)
JFK Federal Building
Boston, MA 02203
(617) 565-3230
Kathleen Malone
EPA Region H
Air Compliance Branch
26 Federal Plaza, 21st floor
New York, NY 10007
(212) 566-2061
Ray Chalmers
EPA Region m (3 AT-23)
841 Chestnut Street
Philadelphia, PA 19107
(215) 566-2061
Kimberly Bingham
EPA Region IV
Atlanta Federal Center
61 Forsyth Street, SW.
Atlanta, GA 30303
(404) 562-9038
Beth Valenztano
EPA Region V (AT-18J)
Regulation Development Branch
77 West Jackson Blvd.
Chicago, IL 60604
(312)886-3189
Lynn Prince
EPA Region VI (6PD-S)
1445 Ross Ave.
Dallas, TX 75202
(214) 665-7265
Ann Keener
EPA Region VH
Mail Code PBAF
726 Minnesota Ave.
Kansas City, KS 66101
(913) 551-7388
Laura Farris
EPA Region VHI (8ART-AP)
999 18th St., Suite 500
Denver, CO 80202
(303) 294-7539
Mike Stenburg
EPA Region K
Air Division (Al)
75 Hawthorne Street
San Francisco, CA 94105
(415)744-1102
Dave Dellarco
EPA Region X
Mail Code AT-082
1200 Sixth Ave.
Seattle, WA 98101
(206) 553-4978
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APPENDIX B
Appendix B includes copies of three types of forms used for compliance with the
National Emission Standards for Hazardous Air Pollutants (NESHAP). Every owner or operator
of a perc dry cleaning facility is required to fill out THE INITIAL NOTIFICATION REPORT
and submit it to the appropriate EPA Regional contact given in Appendix A.
The owner or operator of each perc dry cleaning facility is required to fill out THE
COMPLIANCE REPORT FOR POLLUTION PREVENTION. Where compliance with an
emission control device is required, the owner or operator must complete THE COMPLIANCE
REPORT FOR CONTROL REQUIREMENTS. These completed forms must be submitted to
the appropriate EPA Regional contact.
If you have any questions concerning these reports, call your EPA Regional contact listed
in Appendix A.
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FACILITY ID NO.
_(FROM ADDRESS LABEL)
TNTTTAT, N(TTTFTrATTDTsr KF.POKT
1. Print or type the folio wing 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. 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:
Dry-to-Dry
Transfer
B-2
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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
i ' <•
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 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 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 with no leaks, draining cartridge filters in closed
containers, and keeping machine doors shut when clothing is not being transferred.
B-3
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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.
• 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.
9. 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.
B-4
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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).
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.
B. Control is required. Fill out Part B for EACH MACHINE at your plant.
Check the appropriate box:
O 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.
B-5
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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-Tp-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.
O 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-TOrDRY MACHINE XVTTH REFRIGERATED
CONDENSER m the shaded box below the machme 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 oh 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 9/22/9,6, also
write this information in the shaded box.
C. To find out if additional control is required:
Cheek all boxes that apply:
n 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.
B-6
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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 hi 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
ROOM 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).
B-7
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FACILITY ID NO.
_(from address label)
r.OMPTTAMr.R KKPORT FOB POT I .TITTON
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.
3.
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 ALL of the machines
at the dry cleaning plant over the past 12 months (based on actual purchase receipts):
gallons
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 (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 with no leaks, draining cartridge filters in closed
containers, and keeping machine doors shut when clothing is not being transferred.
• Operate and maintain all dry cleaning equipment according to manufacturers'
instructions.
B-8
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FACILITY ID NO.
_(from address label)
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 title 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.
B-9
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FACILITY ID NO.
_(from address label)
rDMPT.TATSrrF. KPPfraT FOK rONTROT. KRQTTTRF.MFNTS
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 the dry cleaning plant
over the past 12 months (based on actual purchase receipts):
gallons
B-10
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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 DSHTIAL 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
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 on 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
B-ll
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FACILITY ID NO.
_(from address label)
D I use a supplemental carbon adsorber on a dry-to-dry machine and the 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 perc
in the exhaust from the carbon adsorber is not over 100 parts per million.
n 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.
B-12
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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.
B-13
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