REDUCING
HAZARDOUSiS
WASTE I
Washington Dangerous Waste
Regulations and the Dry Cleaning
Industry
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
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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
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Washington Hazardous
Waste
Regulation Summary
for Dry Cleaners
Waste Reduction Workshop
for
Dry Cleaners
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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
characteristics:
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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
handbook).
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.
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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
waste.
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).
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Waste materials generated as a result of solvent use In dry cleaning
operations Include:
WASTE TYPE
WASTE CODE
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
(PERC)
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:
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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.
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SUMMARY OF WASHINGTON DANGEROUS WASTE
GENERATOR REQUIREMENTS
29O 2^2OO lbs
Small Quantity Generators
22 IbsAHW
Notlficati
Batsfflts
Transport
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
except
- 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
except-
- 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
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SUMMARY OF WASHINGTON DANGEROUS WASTE
GENERATOR REQUIREMENTS
Washington
I Quantity Generators
mining
Certify on each manifest that you Same as fully regulated generator
have a waste mitiimiyatin^ program
In-place
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
EPA
DOT
RORA
TSD
TO ABREVIATlOffB / AdtONTMS
Dangerous Waste
Acutely Hazardous Waste
Environmental Protection Agency
Department of Transportation
Resource Conservation and Recovery Act
Treatment Storage and Disposal Facility
Northwest
Southwest
Central
Eastern
(206) 867-7000
(206)753-2353
(509) 575-2490
(509) 456-2926
Ftor a complete list of substances which are regulated at 2.2 Ibs. see the Dangerous Waste Regulations.
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The Dry Cleaning
Process
and
Waste Reduction
Techniques
Waste Reduction Workshop
for
Dry Cleaners
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THE DRY CLEANING PROCESS
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
suppliers.
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.
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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.
solvents
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.
Containers
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.
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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.
WASTE REDUCTION TECHNIQUES
Introduction
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.
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Reduction
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.
Recycling
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
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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
benefits.
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
generated;
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
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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;
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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
clean;
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
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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
materials.
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.
Recycling
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.
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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.
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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
CAunlt
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
efficiency.
Because of the economics of these units, they are best suited for
larger industrial cleaners who will realize a faster return on
2-10
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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
systems.
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.
2-11
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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
dryer.
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.
2-12
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References
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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