State of Ohio
Envinronmental Protection Agency
Fact Sheet
Managing Hazardous Wastes from Dry Cleaning
April 1996

There are more than 1,600 dry cleaning facilities in Ohio. Most of these dry cleaners use solvents in the cleaning process. Solvents are likely to be subject to the Resource Conservation and Recovery Act (RCRA) and state requirements that cover the management of hazardous waste.

What is a hazardous waste?

A hazardous waste is a waste that poses a potential hazard to human health or the environment when improperly handled. The most commonly used solvents in the dry cleaning industry are:

• perchloroethylene (also known as tetrachloroethylene or "perc"');
• petroleum solvents; and
• trichloroethane.

During the cleaning, extraction and drying process, dry cleaners may produce one or more of the following wastes:

• filters and filter media;
• separator water;
• spent solvents and solvent containing rags (from spill cleanup);
• spent carbon and cartridges from carbon adsorbers; and
• still residues and muck.

Most dry cleaners generate hazardous waste. Hazardous wastes are classified into two types: listed and characteristic.

Listed hazardous wastes are listed by name or process in the Code of Federal Regulations Chapter 261, and in Ohio's Hazardous Waste Management Rules, Ohio Administrative Code Chapter 3745-51. For example, perc used in dry cleaning is a listed hazardous waste with a hazardous waste code of F002 when spent. Perc has the waste code U210 as a pure commercial chemical product if discarded prior to use. Spill residues from the cleanup of perc product spills are also considered to be U210 hazardous waste.

Any other waste coming in contact with a listed waste also becomes a listed waste by virtue of the "mixture rule." This includes wastes such as filters, filter media, still residue (sludge), and filter powder (muck) containing perc.

A characteristic waste exhibits one or more of the four hazardous characteristics (ignitability, reactivity, corrosivity and toxicity). For example, a waste solvent exhibits the characteristic of ignitability if it has a flashpoint below 140 degrees F.

The characteristic of toxicity is determined by use of the Toxicity Characteristic Leaching Procedure (TCLP). This analytical test simulates the acidic conditions found in a landfill and determines how much of certain regulated substances would leach from the waste if placed in a landfill. Regulatory levels are set for 39 hazardous constituents in terms of parts per million, and any waste exceeding these levels is a toxic hazardous waste.

Perc, for example, is one of the 39 hazardous constituents. Any waste which contains 0.7 parts per million or more of perc is considered to be a D039 toxic hazardous waste.

Who is a generator?

Every dry cleaning facility that produces hazardous waste is considered a generator.

What steps are required to properly dispose of hazardous waste?

Step 1: Evaluate the facility's waste

• Consider all waste generated at the facility
• Consider all objects that come in contact with perc (e.g. maintenance residue and spill clean up material)

Step 2: Determine the facility's generator status

There are three categories of hazardous waste generators. These categories are determined by the amount of hazardous waste that is generated by a business each calendar month. The hazardous waste requirements differ for these three sizes of generators.

• Conditionally Exempt Small Quantity Generator (CESQG) - generates less than 100 kg of hazardous waste in a calendar month (220 Ibs)

Conditionally exempt small quantity generators are required to:

• Evaluate their waste (as detailed in step one above);
• Ensure delivery of hazardous wastes to an off-site permitted hazardous waste facility; and
• Limit quantities accumulated on-site to less than 1000 kg (2200 Ibs).

The requirements in Steps three through six are recommended for CESQGs, but are not required by rule.

• Small Quantity Generator (SQG) - generates between 100 and 1000 kg of hazardous waste per month (220 to 2200 Ibs).

Small quantity generators must follow steps three through six as detailed below.

• Large Quantity Generator (LQG) -generates more than 1000 kg (more than 2200 Ibs) of hazardous waste per month.

Most dry cleaners in Ohio are small quantity generators or conditionally exempt small quantify generators. Large quantity generators must comply with additional requirements. Additional guidance for large quantity generators is available by calling Ohio EPA, Division of Hazardous Waste Management, at (614) 644-2934, or your local Ohio EPA district office.

Step 3: Comply with hazardous waste accumulation requirements

Hazardous waste must be stored in containers that are:

• marked with the date upon which each period of accumulation begins;
• labeled or clearly marked with the words hazardous waste;
• in good condition and made of or lined with materials compatible with the waste;
• closed during storage except when waste is being added or removed;
• not opened, handled or stored in a manner which may rupture them or cause them to leak; and
• inspected weekly for evidence of leaks or deterioration, and the inspections documented in a log.

Small quantity generators may accumulate hazardous waste for up to 180 days.

• This may be extended up to 270 days if waste must be transported at least 200 miles to a treatment, storage and disposal (TSD) facility.
• Accumulation must not exceed 6,000 kg ( I 3,200 Ibs).

Step 4: Transportation and disposal of hazardous waste

Use of manifests

A hazardous waste manifest is a shipping form, completed by the generator, that accompanies each shipment of hazardous waste when it is transported off-site. Manifests are required of all small quantity generators and large quantity generators sending waste off-site. Manifests are not required for small quantity generators who are reclaiming their waste under a contractual agreement if all of the following conditions are met:

• The types of waste and frequency of shipments are specified in the agreement.
• The vehicle used to transport the waste to the recycling facility is owned and operated by the reclaimer of the waste.
• The generator maintains a copy of the reclamation agreement for at least three years after termination or expiration of the agreement.

• Failure to evaluate wastes;
• Failure to label and date containers;
• Failure to keep containers closed and in good condition;
• Failure to maintain manifest and LDR documents;
• Failure to conduct inspections of hazardous waste containers and emergency equipment, and/or failure to keep logs of these inspections;
• Failure to designate an emergency coordinator;
• Failure to post emergency information by the phone (see step six).

• Disposing of dry cleaning wastes improperly (for example, throwing wastes in the trash);
• Drying out dry cleaning filters;
• Storing dry cleaning wastes in containers that are leaking or in poor condition;
• Keeping wastes on-site for longer than the law allows - 180 days for SQGs; CESQGs can not accumulate more than 1000 kg

When managing hazardous waste and determining generator status the generator must look at the total of all hazardous waste produced not just the waste that is managed under a contractual agreement.

A small quantity generator should receive a copy of the manifest with the signature of the owner or operator of the designated facility within 60 days of the date the waste was accepted by the initial transporter. If a manifest is not received within 60 days the generator must submit a legible copy of the manifest with some indication that the generator has not received confirmation of delivery to Ohio EPA, Division of Hazardous Waste Management. The submission to Ohio EPA need only be a legible handwritten or typed note on the manifest itself or on an attached sheet of paper, stating that the return copy was not received.

All manifest copies must be kept for a period of three years from the date the waste was accepted by the initial transport.

Land Disposal Restrictions (LDRs)

A Land Disposal Restriction (LDR) form must accompany hazardous waste to the disposal facility. Hazardous waste cannot be landfilled without first meeting certain treatment standards. An LDR form notifies the disposal facility that waste meets treatment standards or does not meet treatment standards. An LDR form must be completed even if the waste is to be recycled. The disposal facility will treat the waste prior to land disposal if necessary. The generator must identify on an LDR form what constituents are present in the waste - this can be done by generator knowledge and/or analytical testing. All LDR forms must be kept on file for a period of five years after the date the waste was sent to the treatment storage and disposal facility.

Liability

Although a waste disposal or recycling firm is oflen hired to manage the hazardous waste generated at a dry cleaning facility, liability for the waste does not end when it leaves the cleaner's site. It is still the cleaner's responsibility to ensure that the hazardous waste is properly managed.

Identification numbers

U.S. EPA ID numbers are required of all large quantity and small quantity generators. They are voluntary for conditionally exempt small quantity generators, although some commercial treatment, storage and disposal facilities require all customers to obtain them, independent of size. Notification forms and booklets may be obtained by calling Ohio EPA Division of Hazardous Waste Management at (614) 644-2934.

Transportation Department's requirements

Before sending hazardous waste off-site containers must be labeled, packaged, marked and placarded in accordance Transportation Department regulations. Please call the Public Utilities Commission of Ohio, Transportation Department, if you have any questions regarding these requirements.

Step 5: Develop a personnel training program

Dry cleaners that are small quantity generators must ensure that their employees are thoroughly familiar with proper waste handling and emergency procedures relevant to their job duties.

Step 6: Emergency Procedures

A small quantity generator must have at least one employee either on the premises or on call at all times designated as the emergency coordinator. The emergency coordinator or his designee must respond to any emergencies that arise. The following information must be posted next to a telephone, that is available to all employees who handle hazardous waste and which is capable of contacting outside assistance:

• the name and telephone number of the emergency coordinator;
• the location of fire extinguishers and spill control material, and, if present, fire alarm(s); and
• the telephone number of the fire department, unless the facility has a direct alarm.

Emergency equipment, such as portable fire extinguishers and spill control equipment, must be immediately available to employees in the event of an emergency. Emergency equipment must be tested/inspected weekly and maintained as necessary. An emergency equipment testing log must be kept by the facility.

Please contact Ohio EPA, Division of Hazardous Waste Management, at (614) 644-2934, to order free documents. For technical assistance, ask for the Technical Support Unit or contact your local Ohio EPA district office. For information on obtaining an EPA l.D. Number, ask for the Data Management Section. For a copy of Ohio's Hazardous Waste Regulations, please call the Legal Records Department at (614) 644-2115.

For information on transportation-related issues, please contact the Public Utilities Commission of Ohio, Transportation Department, at (614) 466-3106.

For more information

Other dry cleaning documents available

Environmental Guide for Ohio Dry Cleaners, April 1996

This 16-page brochure summarizes the environmental regulations affecting dry cleaners in Ohio for hazardous waste, air emissions and wastewater. It also includes discussion of how dry cleaners can reduce environmental risk and potentially reduce their regulatory burden through pollution prevention.

This fact sheet is not intended to be the sole source of information for Ohio's hazardous waste rules. Any generator of hazardous waste should also have, at a minimum, a copy of the Ohio Administradve Code Chapters 50-69 dealing with hazardous waste.

Hazardous Waste Management, Ohio Environmental Protection Agency, P.O. Box 1049, Columbus, OH 43216-1049, (614) 644-2934