WASTE  I •
    Washington Dangerous Waste
  Regulations and the Dry Cleaning
                 Sponsored By:
          Washington State Department of Ecology,
          Office of Waste Reduction and Recycling

                Presented By:
               ERM - Northwest. Inc.
                 Bellevue. WA
          Program Funded by a U.S. EPA RTTTA Grant

                    TABLE OF CONTENTS

                    Reducing Hazardous Waste
             Washington Dangerous Waste Regulations
                   and the Dry Cleaning Industry

Hazardous Waste Regulatory Summary
Identifying Hazardous Wastes                           1-1
Dry Cleaner Wastes                                    1 -3
Regulatory Status                                      1 -4
Summary Table of Regulatory Requirements              1-6

The Dry Cleaning Process and Waste Reduction Techniques
The Dry Cleaning Process                               2-1
 -Industry Summary                                  2-1
 -Potential Hazardous Waste Produced                   2-2
 -Regulations Regarding Each Type of Hazardous Waste   2-2
Waste Reduction Techniques                          2-4
 -Source Reduction                                  2-4
 -Recycling                                          2-8
 -Waste Reduction for Specific Waste Types             2-8
 -Waste Reduction by Type of Dry Cleaning System        2-9

References and Information Sources

Washington Hazardous
 Regulation Summary
       for Dry Cleaners
      Waste Reduction Workshop
          Dry Cleaners

     Summary of Washington Dangerous Waste Regulations
                         for Dry Cleaners
The  entire scope of hazardous waste handling, from  "cradle-to-grave"
Including generation, storage, transportation, treatment and disposal, is
governed by the Resource Conservation and Recovery Act (RCRA).

RCRA Is designed to Improve all aspects of hazardous waste management.
The  Act  provides for managing,  tracking, regulating  and minimizing
wastes. It also Includes measures for proper training and requirements
for personal protective equipment to help ensure worker safety.

The  U.S.  Environmental Protection Agency (EPA) oversees RCRA and
develops the federal RCRA regulations  that set  the standard for the
nation.  Final control of RCRA programs can be given to Individual states
provided that the state develop a hazardous waste program at least as
stringent as the established federal program.  Washington's hazardous
waste program Is run by the Washington Department of Ecology (DOE).

Washington's counterpart to RCRA Is the Hazardous Waste Management
Act (Chapter 70.105 RCW).  Washington regulates more  substances than
the  federal program and  refers to them  as Dangerous  Wastes.   The
regulations are contained In the Dangerous Waste Regulations. Chapter
173-303 of the Washington Administrative Code (WAC).

Complying with the state Dangerous Waste regulations includes following
Department of Transportation (DOT) regulations for hazardous materials.
DOT regulations cover  labeling, placarding  and  other  handling
requirements, for the safe transportation of hazardous wastes.

The  following discussion is only a summary of the Washington dangerous
waste regulations.  Those requirements  which apply to the typical dry
cleaner are highlighted.  Contact your regional Department of Ecology
office for a complete copy of the State Dangerous Waste regulations.

Identifying Hazardous Wastes

Dry  cleaning businesses generate  waste.   It is the responsibility of each
business to determine whether their waste is regulated as dangerous. In
general, a dangerous waste is any  discarded material  which, if improperly
disposed of. may pose a threat to human health or the  environment.  A
waste is  considered dangerous,  and regulated by  the  state,  if it  is
specifically listed in the state regulations or possess  one of the following

      •  Ignitablllty.
      •  EP Toxlcity.
      •  Corrosivlty. or
      •  Reactivity.

A waste may also be regulated as a dangerous waste if it meets any of the
criteria for  designating the waste as toxic,  persistent, or carcinogenic.
Tests should be conducted if it is unclear whether or not a waste meets
any of the above characteristics or criteria.

Depending on the level of hazard posed, a waste may be designated as a
Dangerous  Waste (DW). an Extremely Hazardous Waste (EHW) or an
Acutely Hazardous Waste (AHW).  These latter two wastes are  regulated
more stringently.  Details on the designation of EHWs and AHWs can be
found in the Washington Dangerous Waste regulations or in the  Guide for
Hazardous  Waste Generators (see  the bibliography  at  the end of  this

Characteristics of Dangerous Waste

Ignitable:  Substances that burn or combust at a temperature  less than
140*  F are considered ignitable (flammable).  They can be liquids, solids.
flammable gases or oxidizers.  Non-liquid ignitables  are capable, under
standard temperature and pressure,  of causing fire through friction,
absorption  of moisture or  spontaneous  chemical  changes.   Typical
ignitable substances in the dry cleaning industry are solvents such a's
Stoddard solvent.  These substances can yield dangerous wastes  that pose
a fire hazard.

EP Toxic:  Wastes are toxic if. after being tested by a chemical extraction
procedure  (EP). they are found to contain high concentrations of heavy
metals or specific pesticides.  Toxic wastes can cause illnesses such as
cancer, kidney damage, birth defects and blood disease.  Although some
dry cleaning solvents  such as  perchloroethylene  may cause  similar
illnesses, they usually do not test positive for EP Toxlcity.

Corrosive: Corrosive wastes are acidic liquids (pH less than or equal to
2). alkaline liquids (pH greater than  or equal to 12.5) or liquids that
corrode steel  at a rate greater than 0.25 inches per year.  These wastes
can dissolve most materials; specialized containers are necessary to resist
corrosion.   Corrosives may dissolve the skin and lungs and extreme care
must be used when handling them.  Corrosive wastes are generally not
produced by the dry cleaning industry.

Reactive:  Reactive wastes are very unstable  and readily, rapidly or
violently change when mixed with or exposed to  water, heat, pressure or
other materials. These wastes, especially cyanide or sulfide compounds.
may generate toxic gases under mildly acidic  or alkaline conditions.
Chromic  acids,  perchlorates and peroxides  are  common  reactive
substances.  Wastes produced from reactive substances are hazardous
because they may  explode or  spontaneously  ignite in air or  water.
Reactive wastes are typically not generated by the dry cleaning industry.

Criteria for Identifying Hazardous Wastes

Toxic:  A substance may qualify as "toxic" if it falls one of four tests.
These tests determine the concentration of a substance  needed to kill
50% of a test population.  The  tests include  fish toxlcity, orally dosed
rats, inhalation by rats and the skin of rabbits.

Persistent;  Persistent wastes do not break down easily.  The test for
persistence applies only  to  halogenated  hydrocarbons and certain
polycycllc  aromatic   hydrocarbons  (including  many  solvents).
Perchloroethylene is an example of an Extremely Hazardous, persistent

Carcinogenic:  If a waste contains one or more substances which are
determined to be carcinogenic by the National Institute for Occupational
Safety and Health,  or In scientific documents, it may  be a carcinogenic
waste under these  regulations.  The waste  is subject to the hazardous
waste regulations  if it is generated  in quantities over 220 pounds per
month or batch and if the concentration of the carcinogenic substance(s)
is greater than 0.01% of the waste.   (A waste is designated an Extremely
Hazardous Waste if the  concentration of the carcinogenic substance is
greater than 1%).  Perchloroethylene  is a carcinogenic waste.

Dry Cleaner Wastes

Solvent wastes  represent a large portion of dry cleaning dangerous waste.
Some petroleum solvents (e.g..  Stoddard  solvent) and   halogenated
solvents  (e.g..  Perchloroethylene  (PERC). Valclene (CFC-113) become
dangerous wastes when they are contaminated and are no longer fit for
use without first being regenerated, reclaimed or reprocessed.

Some of these wastes  are  specifically listed  in the regulations as
dangerous (e.g.. spent PERC)  while others are designated as dangerous
wastes because they  exhibit the characteristic of "ignltabillty" (e.g..
Stoddard solvent).

Waste materials generated as a result of solvent  use In  dry cleaning
operations Include:
      •  Spent halogenated solvents and still bottoms
        from the recovery of these solvents

           -  spent tetrachloroethylene (PERC)         F002
           -  spent trtchlorotrifluoroethane (CFC-113)   F002

      •  Spent petroleum solvents (e.g.. stoddard solvent) D001

      •   Filter cartridges
              contaminated standard cartridge          F002
              (PERC. CFC-113)
           -  contaminated absorptive  cartridge         F002
              diatomaceous earth cartridge             F002
              (PERC powder machines)
           -  cartridges containing Stoddard solvent    D001

      •  Discarded containers or drums which are not
        legally empty
           -  containing PERC residues                U210
              containing Stoddard solvent residues      D001
 Regulatory Status

 The more waste produced and/or accumulated by a dry cleaner, the more
 regulatory requirements there are to meet.  Each company must comply
 with the requirements set for their generator  category.

 First Identify your dangerous wastes and the Quantity  Exclusion Limit
 (QEL) for each waste.  The QEL is used  to  distinguish whether  a
 dangerous waste is subject only to the small quantity generator, the 220-
 2.200 Ibs. generator, or the fully regulated generator provisions.  There
 are two possible QEL's. 20  Ibs per month or batch, or 2.2 Ibs. per month
 or batch. ("Batch" means any waste which is generated less frequently
 than once a month.) To determine your regulatory status, count the total
 amount of dangerous waste you generate per  month or per batch  in each
 QEL category  and  determine if you  have exceeded the QEL  for the
 aggregated waste amounts in either category.

 Dangerous waste generators are  allowed to  temporarily  accumulate
 dangerous waste on  site without a storage permit. However, accumulation
 time and quantity vary depending on the company's generator status as
 described below:

Fully Regulated Generators
     Generates or accumulates 2,200 Ibs. (approximately five 55 gallon
     drums) or more of dangerous waste or 2.2 Ibs. or more of acutely
     hazardous waste per month or per batch.

Generators of Between 220 and 2,200 Ibs. of Hazardous Waste
     Generates between 220 (one half of one 55 gallon drum) and 2.200
     Ibs.  of dangerous waste per  month or per  batch and never
     accumulates more than 2.200 Ibs. at any time.

Small Quantity Generators
     Generates less than 220 Ibs. of dangerous waste and less than 2.2
     Ibs. of acutely hazardous waste per  month or per batch and never
     accumulates more than the QEL for the waste at any time.

An outline for  the Dangerous Waste  Generator Requirements of each
generator category is  attached.

                                 SUMMARY OF WASHINGTON DANGEROUS WASTE
                                            GENERATOR REQUIREMENTS
                                                          29O • 2^2OO lbs
                                                                                   Small Quantity Generators
                                                                                               22 IbsAHW •
• Identify all DW on-slte
• Delennlne pounds per month or batch
  generated/max, amount accumulated at
  anyone time

• Notify State Agency to obtain a
  EPA/State ID *

•Up to 90 days
• In contalnera which are:
 - compatible with DW stored
 - closed unless adding/removing waste
 - handled to avoid damage
• Segregation
 - Ignltabfe or reactive waste stored 50ft
   from piopeity line
 - Incompatlbles stored separately

• No more than 55 gallons of DW
  or 1 quart AHW

• RCRA hazardous waste labels
• DOT labels
• Accumulation start date
• Major rtsk(s) (e.g. corrosive)

• Storage area weekly
• Tanks dallY
• Facility for potential DW spills
• Emergency prevention/detection equipment

• Follow DOT regs for packaging, labeling
  marking and placarding
• Use HW manifest
• Use transporters and TSD
  facilities with State/EPA ID*'s
• File any necessary exception reports
• Ship wastes within 00 days
• Identify all DW on-slte
• Determine pounds per month or batch
  generated/max, amount accumulated at
  at any onetime

• Notify State Agency to obtain
 a EPA/State ID*

• Same as other fully regulated generator
  - Up to ISOdavs. 270 days If TSD to more
   than 2OO miles away loot to exceed
   2.200 Ibe. of waste)
• Same as fully regulated generator
                                                          • Same as full regulated generator
                                                          • Same as  fully regulated generator
 •Same as fully regulated generator except:
  - Letter to EPA In-place of exception report
  - Ship wastes within 180 days (270 If TSD
   Is located more than 200 miles away)
• Identify all DW on-slte
• Determine pounds per month or batch
  generated/max amount accumulated
  at any one time

• Notify State Agency to obtain
   a EPA/State ID* (optional)

• Same as other fully regulated generator
- No time limit If less than 220 Ibe. of DW
   and 2.2 IDS of AHW are accumulated
 > Not applicable
                                          > DOT labels (If necessary)
                                          > Accumulation start date
                                          • No Inspections required
 No manifest required
 Use  licensed solid waste facility

                                 SUMMARY OF WASHINGTON DANGEROUS WASTE
                                            GENERATOR REQUIREMENTS
                                                                                                   I Quantity Generators
            • Certify on each manifest that you          • Same as fully regulated generator
              have a waste mitiimiyatin^ program
            • Annual reports require documentation
              of waste mintn»iTntiftti efforts
            • Each employee who handles
             dangerous waste must be
              thoroughly trained In
              -regulatory compliance
              -emergency response
              -emergency equipment

            • Contingency Flan
            • Preparedness/Prevention requirements
            • Incident reports to EPA
            • Emergency Procedures

            • Exception Reports
              (fife within 45 days)
            • Annual Reports

            • Manifests Oyrs)
            • Exception reports (3 yrs)
            • lest results/sample analyses (3 yrs)
            • Training documentation
            • Inspection logs
            • Annual report (3 yrs)
• Employees must be familiar with
 proper waste handling and emergency
                                                                                                  • No requirement
• No requirement
                                                          •  Emergency Procedures
                                                          • Preparedness/Prevention requirements
                                                          •  Same as fully regulated generator
                                                          • Manifests (3 yrs)
                                                          • Exception reports (3 yrs)
                                                          • Test results/sample analysis (3 yrs)
                                                          • Inspection logs
                                         • No requirement
                                         • Annually reporting If you have
                                          a EPA/Slate ID »
                                         • No requirement
    Dangerous Waste
    Acutely Hazardous Waste
    Environmental Protection Agency
    Department of Transportation
    Resource Conservation and Recovery Act
    Treatment Storage and Disposal Facility


(206) 867-7000
(509) 575-2490
(509) 456-2926
• Ftor a complete list of substances which are regulated at 2.2 Ibs. see the Dangerous Waste Regulations.

The Dry Cleaning
Waste Reduction
  Waste Reduction Workshop
      Dry Cleaners

Industry Summary

Commercial and Industrial dry cleaners use solvents rather than water
to clean textiles.   The  main differences between  commercial  and
Industrial dry cleaners is the size of equipment and type of clientele.
Industrial dry cleaners generally handle larger volumes of garments
containing more oil and  heavy metals than commercial dry  cleaners
because their primary  customers Include  businesses and linen

Both commercial and industrial dry cleaners use four basic  cleaning
agents in their process. These Include:

     •  dry cleaning solvent
     •  detergents.
     •  stain and spot removers, and
     •  prespot.

There are two types of machines utilized by dry cleaners dry-to-dry
and transfer.  In a dry-to-dry unit the clothing is dried in the same
machine that does the cleaning.  In a transfer machine, clothing is
transferred  to a reclaimer.

There are three major types of dry cleaning systems, and they differ by
the type of solvent used.  These Include:

      • Pgrchtoroethylene  (PERC)
        This is the most common type of dry cleaning solvent  and Is
        used In at least  50% of all dry cleaning businesses.  PERC is
        nonflammable and provides  high quality results at a relatively
        low cost.  Unfortunately, this chlorinated solvent also known
        as tetrachloroethylene. Is toxic.

      •  Valclene
        This  is  a  chlorinated  fluorocarbon.  also  known  as
        trtchlorotrifluoroethane or  freon.  It Is nonflammable  like
        PERC. but not as effective in cleaning.  Because this solvent  is
        very expensive.  It Is used In dry-to-dry closed-loop machines
        which have a smaller solvent consumption.  It Is also toxic
         and persistent

      •  Stoddard solvent
         This Is a petroleum distillate similar to kerosene.  Petroleum
         solvents are cheaper than PERC but have the disadvantage of
         being highly  flammable.  Because of this potential hazard.

        petroleum solvents are  typically used In transfer machines
        rather than dry-to-dry units. The use of petroleum solvents Is
        decreasing due to fire hazard restrictions and concerns.

Potential Hazardous Wastes Produced

A variety  of wastes are produced by the dry cleaning industry.  The
hazardous  wastes  include waste solvents,  contaminated  filter
cartridges, sludges and still bottoms and solvent containers.  All of
these can contribute to the monthly generation of hazardous waste.

        These are produced by equipment without recycling units.

        Filter cartridges^
        These are  filters of paper and carbon or dlatomaceous earth
        which are contaminated with solvent.
         Still bottoms from the  reclamation of used solvents which
         contain dirt, oil, grease, detergent, additives and solvent.

         Empty product containers  and drums which may  contain
         residual solvents.
 Regulations Regarding Each Type of Hazardous Waste

 Dry cleaners are regulated by the amount and type of hazardous wastes
 they produce.  Some of the wastes are specifically listed as hazardous
 wastes in the regulations  while others are regulated because they
 exhibit  a hazardous characteristic  (i.e..  ignitabillty.  corrosivlty,
 reactivity, EP toxicity).   The  types of hazardous wastes typically
 generated by dry cleaners, their hazardous properties,  and EPA waste
 code are listed below:
         Perchloroethylene:  toxic, persistent. F002
         Trichlorotrifluoroethane: toxic, persistent. F002
         Stoddard solvent: ignltable. D001

         Used Filter cartridges
         These are hazardous waste if there is any listed solvent left in
         them, or  if they are contaminated  with petroleum solvents
         and meet the regulatory test for ignitability. The waste code
         for filter cartridges would be either  F002  or D001  (for
         ignitable waste), depending on the solvent used.

     •  Containers
        The  containers  In which solvent is sold are  considered
        hazardous waste unless they are being recycled, reused or are
        legally empty.  They are either F002 waste or "ignltable" D001
        waste depending on the particular solvent (see above).  The
        definition of "empty" according to regulations Is as follows:

           • All wastes have  been removed that practically can  be
             removed by methods of pouring, pumping, etc., and

           •  No more than 1  inch of residue  remains  on the bottom
             of a container, or

           •  No more than  3% by  weight of the total container
             capacity remains in a container equal to or smaller than
             110 gallons, or

           •  No more than 0.3% by weight of  total container capacity
             remains for a container larger than 110 gallons.


This section discusses waste reduction techniques in the dry cleaning
industry.  Minimizing the production of hazardous wastes in your dry
cleaning business makes sense because It can help you to:

      •  Reduce operating costs by using less raw materials;

      •  Avoid expensive transportation and disposal costs;

      •  Reduce your regulatory requirements, saving time and money;

      •  Improve workplace health and safety;

      •  Reduce the liabilities associated  with the transportation and
        treatment of hazardous waste; and

      •  Reduce potential damage to the environment.

Federal and state regulations require that hazardous waste generators
(of greater than  220  Ibs/month)  must  manage  their  wastes  in
accordance with the appropriate hazardous waste regulations and
certify  that they have a program in place to  minimize the volume
and/or toxicity  of hazardous  wastes.   The  EPA defines waste
minimization as both source reduction and recycling.

     This  Includes  good  housekeeping  techniques,  product
     substitution, and   changes In processes which  reduces the
     amount  of hazardous wastes produced  at the source of
     generation.  Keeping the covers on solvent containers  when not
     In use to minimize vapor loss Is an example of source reduction.

     This includes the recovery and reuse of hazardous wastes such as
     spent solvents.  An example Is the Installation  of  a  solvent
     recovery distillation unit which regenerates used solvent and
     returns it to the process.

Source Reduction

There are many ways to reduce the amount of hazardous waste
produced In  your dry  cleaning  business without  buying new
equipment.   Improved "housekeeping"  practices can minimize the
chance of material losses.  They can be as simple as keeping records of
your hazardous materials purchased to  avoid overstocking or as
complex as changing management's perspective on the substitution of
raw materials to ones which are less hazardous.  Reducing the amount
of hazardous waste leaving your operation generally means a cost
savings  for the business.

Most source reduction opportunities are a function of how personnel
think of hazardous waste  generation. Therefore, if these  practices are
to have their greatest positive effect,  they must  have the full support
and authority of management. These practices include:

     A) Personnel practices
           • Management initiatives
           • Employee training

      B) Loss prevention  measures
           • Waste stream review
           •  Spill/leak prevention program
           •  Preventive /corrective maintenance

      C) Waste stream segregation

      D) Material handling and storage

A)    Personnel Practices

      Management Initiative

Management support is  critical to any waste reduction program.  If
there is not enough visible support from management, employees will

see little Incentive to look for waste reduction opportunities and the
waste reduction  program will not be as effective  as  it could be.
Employee incentive programs  such as awards for waste reduction
ideas can help foster awareness of waste reduction policies, goals, and

By conducting  a waste reduction assessment,  management  can
determine their shop's waste reduction potential.  An audit consists of
the following fundamental steps:

     • Identify plant processes  where chemicals are used and waste Is

     • Evaluate existing waste management and reduction methods;

     • Research alternative technologies;

     • Evaluate feasibility of waste reduction options;

     • Implement measures to  reduce wastes; and

     • Periodically evaluate your waste reduction program.

     Employee Training

Employee  training is  an important part  of  your waste reduction
program.  The personnel responsible  for operating  and monitoring
process equipment, loading and unloading hazardous materials,  and
purchasing, storing and transferring chemicals, should be trained to
adhere to  safe operating procedures.  Including the  handling of
hazardous wastes and proper equipment use.

Employees should be trained before they start working with hazardous
materials and on-the-Job any time new procedures are Implemented
or new^ equipment or  materials are used.  Employees should also be
made aware of the hazards of the solvents they will work with by
reviewing the Material Safety Data Sheet (MSDS) prepared for each
chemical and  through training  required  under federal and state
occupational safety and health regulations. This awareness will help
identify their personal responsibility in maintaining safe  practices
which  help  minimize hazardous waste production.

Training should also be given on hazardous substance spill prevention.
such as how to detect leaks in the dry cleaning systems.  Techniques
for minimizing the potential for a release of  hazardous substances
should be emphasized.

Employees should be cautioned not to  accept a sample product from a
vendor (for example, a new stain remover) because it may become  a

hazardous waste when discarded or may generate a hazardous waste If
used. Employees should be trained to read the label and MSDS sheet
and understand what is in the product and how it should be used.

To be  effective  as  a waste  reduction  measure,  employee training
should address the waste disposal costs and liabilities  that  your
company incurs as a generator of hazardous waste.  Understanding the
causes of solvent loss and waste generation as they relate to  their
individual areas of responsibility will promote employee participation
in your waste reduction efforts.

B)   Loss Prevention Measures

     Waste Stream  Review

A waste stream review is the first step in evaluating the potential for
waste reduction in your business.  The review can be designed to help
you  identify  waste  streams  and  potential  waste  reduction
opportunities.  A careful review of the  raw materials and processes
used, operating practices  and discussions with employees can yield
the Information necessary to begin a waste reduction program.

     Spill/Leak Prevention

Spilling and leaking of hazardous substances  can create hazardous
wastes which must  be properly managed.  If  the material used In the
clean up,  such as water  or absorbant. Is  contaminated with  the
hazardous substance, it must be discarded as a hazardous waste. Quick
response  to  a  spill can  minimize the  amount  of spill material.
including any contaminated soil or water, that must be treated as  a
hazardous waste. Therefore, spill and leak prevention are Important
ways of minimizing your hazardous waste generation.

Spills can be prevented by:

      • Identifying areas where spills or  leaks might occur and taking
       precautionary measures;

      • Using all equipment properly;

      • Checking containers and  equipment regularly to  ensure that
       they are not  leaking; and

      • Handling all  containers of hazardous materials properly .

Leaks, both liquid and vapor, can be prevented by:

      • Periodically replacing  seals on  the dryer deodorizer and
       aeration valves;

     • Replacing the door gasket on the button trap;

     • Replacing the gasketlng around the cleaning machine door or
       tighten the  closure;

     • Repairing holes In air and exhaust ducts;

     • Checking hose connections and couplings;

     • Cleaning lint screens to avoid clogging fans and condensers:

     • Opening button  traps  and lint gaskets only long enough to

     • Checking pumps  and storage tanks;

     • Checking baffle assembly In cleaning machine bi-weekly; and

     • Checking air relief valves for proper closure.

     Preventive and Corrective Maintenance

A maintenance program, whether  preventive, corrective or both can
help cut costs  of repairs, waste disposal  and business interruptions.
Proper maintenance can also prevent hazardous waste releases due to
equipment failure and facility degradation.  A thorough maintenance
program  minimizes equipment breakdown  and reduces  wastes
generated from leaks and unexpected failures of the equipment

One of the simplest things you can do  to reduce hazardous waste
generation and  operating costs  is  to  use good housekeeping
techniques. This includes simple things such as making sure all bungs
and lids on all solvent containers  are on tightly.   Make sure all raw
material containers are  labeled. Regular inspection and replacement
of dryer door  gaskets  and deodorizer valve  seals which could be
leaking solvent should be a part of this program.

Additionally, make sure  the size of the garment load Is correct relative
to the  size of the equipment.  Overloading  results In Incomplete
solvent extraction while  underloading Increases  the amount of solvent
loss per unit of garment cleaned due to inherent losses in the system.

To help prevent spills, use containers and/or shelving or storage areas
that are earthquake and  shake  proof.

C)    Waste Stream Segregation

It  Is important not to mix different waste streams.  Once a non-
hazardous waste is contaminated with a hazardous waste listed in the
regulations, the entire waste stream becomes a  "listed"  hazardous
waste and must be managed as such.  Mixing of two non-hazardous
wastes could  result in the  formation of a waste  that  exhibits a
hazardous characteristic.  In addition, mixing wastes can Increase the
volume of hazardous waste you generate and potentially Increase your
regulatory requirements for the management of these wastes.

D)   Material Handling and Storage

In order to  prevent spills of hazardous materials, all containers should
be Inspected to be certain  that they are in good shape and that all
rings, bungs and lids are on securely.

Use good common sense  when handling and transporting containers
of hazardous materials.  Make certain that the  equipment used to
transport the containers is in good condition and that safety standards
are observed.

Solvents should be carefully drained from their containers to ensure
that the  container is legally  empty and therefore not a  hazardous
waste.  Product containers should not be reused unless they have been
adequately rinsed and are used to store the same or other  compatible

Material handling improvements:

     • Monitoring how much material is needed;

     • Monitoring amount of chemicals used and wastes produced;

     • Monitoring emission control  system;

     • Ordering raw materials in appropriate unit sizes to avoid waste
       and reduce your inventory,

     • Maintaining product Material  Safety Data  Sheets to monitor
       chemical ingredients of wastes; and

     • Considering waste  management  costs  when buying new
       materials and equipment.


There are several types of recycling methods currently being used in
the dry cleaning industry.  Dirty, used solvents and cooling water used
In distillation  units can be regenerated and returned to the process.

Most recycling techniques will be discussed below by specific waste
type or type of dry cleaning system.

Waste Reduction for Specific Waste Types

Spent Solvents  and Sludges from Solvent Stills

Solvent waste reduction can be accomplished In several ways. Many
dry  cleaners are  using equipment with  built-in or added solvent
distillation  units  which  extend  the  life  of solvent product while
producing a reduced waste volume of  still  bottoms.   Adding  a
prewashing step to the process, which removes some of the dust and
oils up front, can also extend the life of the  solvent.

Maximizing solvent recovery from sludges generated In the distillation
process can also reduce solvent waste. This can be  accomplished by
using a Alter press or a heat or steam unit. Solvent vapor loss can be
minimized by routine inspection and repair of gaskets on dryer doors,
seals on dryer and deodorizer valves and air ducts and exhaust vents.
The  transfer of clothing laden with residual solvent from a washer to  a
dryer unit can  also result in solvent vapor loss.  Dry-to-dry machines
can  help to minimize this type of loss.

Spent Filter Cartridges

The  amount of contaminated filter material generated by dry cleaners
can  be reduced by using the filters as long as possible.  The life of  a
filter can be extended by  adding a prewashing step in the process to
remove excess  dirt and oils.   You can also recover solvent from the
filters by letting the filters drain in a closed container and heating the
filter cartridge directly in the wheel, lint  trap or solvent still to
vaporize and capture additional solvent.  Some dry cleaning systems
remove this solvent while the filter is  in its housing using  either dry
heat or live steam.

Empty containers

Legally  empty containers (see the  definition  of  "empty"  in  the
Regulatory Summary) do not constitute hazardous waste. Many solvent
vendors will accept emptied containers back for refill.  Containers
recycled in this manner are not regulated as hazardous wastes. If the
containers have been adequately rinsed,  they may be disposed of at  a
licensed sanitary landfill.  You must check with local authorities  first
for specific  restrictions.

Waste Reduction by Type of Dry Cleaning System

perchloroethylene  Systems

Several different types of solvent recovery systems are available on the
market within a wide  price and capacity  range.  The main types of
recovery systems  Include carbon  adsorption systems,  refrigeration
units and solvent stills.

     palliation Unit

     The dry cleaning  Industry has been reclaiming  and  reusing
     solvents for many years now.  thus reducing the  amount of
     feedstock solvent needed.  Most older dry cleaning equipment
     Includes a solvent recovery  step or the machines have been
     retrofitted  with solvent distillation units. Newer machines are
     generally closed loop systems which are very efficient in terms
     of solvent heat, and water recovery.

     The still bottoms produced as a result of the  distillation process
      contain dirt,  filter material and  residual  solvent.   Proper
      operation of the still can keep the solvent content of the still
      bottoms to a minimum.

      Carbon Adsorption

      Equipment designed with carbon adsorption (CA) systems as an
      Integral part of the machine is available. In addition,  existing
      machines can be retrofitted with an assortment of CA units.  The
      unit does require the installation of steam plumbing.  Exhausts
      from  storage  tanks,  distillation units, sludge coolers, dryer
      condensers and plant ventilation systems can be routed to the

      Solvent laden air  attaches to the carbon bed.  Air cleaned of
      solvent is  exhausted to the outside.  During the desorption, the
      carbon bed is regenerated by flushing it with steam to pick up
      solvent.    The  steam  and  solvent  vapor  then  undergo
      condensation back to the liquid state with the resultant liquid
      containing water, solvent and contaminants.   The solvent In this
      condensate is then recovered by distillation or other means and
      returned to the process loop.  Carbon adsorption can remove
      more  than 96% of the solvent In the exhaust system that would
      otherwise be ventilated to the outside. The  carbon adsorption
      unit must be adequately maintained in order to ensure maximum

       Because of the economics of  these units, they are best suited for
       larger industrial cleaners who  will realize  a faster return on

investment than smaller commercial establishments.  Although
smaller commercial establishments may not show a profit from
using  this system,  the equipment can  be operated without
significant effect on  plant  profitability.  However, as solvent
prices  continue to escalate, the pay-back economics for carbon
adsorption systems are likely to improve.

Refrigera. ^"/Condensation

An alternative to carbon adsorption Is  the refrigeration solvent
recovery  unit.   In  the  refrigerated  condenser system,  the
stripped air is returned directly to the dry  cleaning  machine.
eliminating the need for external venting ducts.

Incoming  solvent laden air is cooled by refrigeration to  strip it of
its solvent.  The temperature of the solvent air is cooled  below
the dew point of the vapor, causing it to condense. The solvent
free  air is  returned to the  dry cleaning machine,  and  the
condensed vapor drains to a water separator.  The recovered
solvent is fed into a storage tank for future  use and the  water
from the separator is discharged to the sewer.

An  advantage of refrigeration  units  over carbon  adsorption
systems Is that they do not require a costly steam Installation to
regenerate the carbon. Although capital costs tend to be slightly
higher for refrigeration units than for carbon absorbers,  the
annual operating costs are less.

Azeotropic Conditioning

This is a  newer technology utilizing a continuous and automatic
azeotroplc distillation  system.   Azeotropic  conditioning uses
lower  temperatures to vaporize solvents and  then condense the
vapor  back to a  liquid, which becomes  100% pure distilled
solvent.  The non-volatile residues are carried away with the
washwater  and not  suspended  in  the solvent  as  with  other

 Solvent recovery can be as high as 100% and virtually no solvent
is in the  discharge.   Effluent from the process contains water,
biodegradable detergent, dirt and  residues and may be released
to  the sewer system.   The system  eliminates the use of
disposable  filters and the generation of still bottoms.  Once
installed  little maintenance is required.

However, azeotropic conditioning does require a high initial
 capital outlay, and  detergent used in  the system  must  be
biodegradable, low foaming and non-corrosive.

Valclene Systems fFluorocarbonsl

Some of the first solvent recovery systems were developed In the dry
cleaning Industry for fluorocarbon recovery.  This Is due to  the high
cost of fluorocarbons.  Most other solvent recovery systems are based
on the designs for fluorocarbon  systems so the descriptions  provided
above for the perchloroethylene systems are applicable here as well.

Petroleum Systems  (Stoddard solvent)

Dry  cleaners which use Stoddard solvent (a petroleum distillate) can
use  similar solvent recovery  technologies as perchloroethylene dry
cleaners.   The systems  available can recover  up  to 95% of the
petroleum distillate vapors from the  dryer exhaust depending upon
how the unit Is operated.

Carbon adsorption technology for petroleum systems Is similar to that
of plants using perchloroethylene. Solvent recovery can be as  much as
95%. however,  annual and capital costs of carbon adsorption may be
too great at present for widespread acceptance of this technology by
plants using petroleum solvents.

Condensation systems for Stoddard solvent are relatively new. They
employ steam-heated  colls to drive the solvent out of the fabrics. The
petroleum Is then separated out of the water and recovered for reuse.
This type of condensation unit can show a 90% efficiency in reduced
solvent vapor that  would otherwise be exhausted by a  conventional

Solvent recovery dryers can cost as much as three  times the price of
conventional non-recovery dryers, so capital costs can be quite high.
However, the pay-back period is not long and larger operations may
accomplish  pay-back in as little as three years.  Smaller operations
with smaller units face a longer pay-back period of at least eight years.


Alaska Health Project. 1987, Waste Reduction Assistance Program
      (WRAP) On-slte Consultation Audit Report: Drv Cleaner.

Alaska Health Project 1987. Waste Reduction Tips for Dry Cleaners.

Campbell. M. E.. W. Glenn and L. Plm, Profit From Pollution
      Prevention:  A Guide to Industrial Waste Reduction and
      Recycling. Drv Cleaning.  Pollution Probe Foundation.

Massachusetts Department of Environmental Management. Bureau of
      Solid Waste Disposal. 1985. Solvent Recovery In the Dry
      Cleaning Industry. SIC 7216.

Montana Department of Health and Environmental Sciences, 1988.

      Wastes: Dry Cleaners and Commercial Sundries.

ICF Consulting Associates. Inc.. 1986. Guide to Solvent Waste
      Reduction Alternatives; Final  Report, prepared for: California
      Department of Health Services.

Wolf. K and Christopher W. Myers.  1987 Hazardous Waste

      Solvents In the Dry Cleaning Industry.  Rand  Publication Series
      ISBN:  0-8330-0872-2


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