Environmental Guide for Ohio Dry Cleaners - Summary

Introduction
Dry cleaning establishments provide an important cleaning service in Ohio. However, this service is often accompanied by the generation of hazardous waste and air emissions, and the potential release of contaminated water to surface or ground water.

This fact sheet introduces the environmental regulations relevant to Ohio dry cleaners. It also discusses ways to potentially reduce environmental risk and regulatory burden through reducing the generation of wastes and emissions at the source and by recycling. A more detailed version of this brochure is available from the Ohio Environmental Protection Agency (Ohio EPA), and can be obtained by calling any of the Ohio EPA offices listed on page 4.

Process overview
Dry cleaners typically use either perchloroethylene (perc, tetrachloroethylene) or petroleum solvents (stoddard, quick-dry, low-odor or 140 F) as cleaning solvents. The dry cleaning process consists of three principal steps: cleaning or washing the garments; extracting used solvent; and "drying" thegarment.

Four basic types of dry cleaning machinery have evolved over time, each representing a higher level of technology. However, all are still in use today. They include transfer (wet-to-dry), dry-to-dry, dry-to-dry with refrigerated condensers, and dry-to-dry with refrigerated condensers and carbon absorbers.

Waste streams
Dry cleaning can be responsible for releases of chemicals to the land, air and water. Evidence suggests that the primary chemical solvent used in dry cleaning, perc, can be damaging to human health and to the environment.

Environmental regulations have been developed to reduce that risk. Dry cleaning operations may be subject to regulations for hazardous waste, air emissions, and wastewater, whether they discharge to a wastewater treatment plant, directly to a body of water, or to an underground well or storage tank. (Ohio EPA, 1993; U.S. EPA, 1995)
Hazardous waste - Most dry cleaners generate hazardous waste. Spent perc from the dry cleaning process is hazardous waste, as is any other waste coming in contact with it, including filters, filter media, still residues (sludge), and filter powder (muck) containing perc. Hazardous waste generators are categorized into one of three classifications based on the amount of waste produced each month. Hazardous waste regulations differ for the three classifications, with the heaviest burden placed on those dry cleaners that generate the most waste. Among other things, dry cleaners that generate more than 100 kilograms or 220 pounds of hazardous waste per month are required to notify Ohio EPA and receive and identification number. All generators are required to send all hazardous waste to a permitted hazardous waste facility. Ohio EPA is currently developing a fact sheet specifically addressing the management of separator water. For more information, contact Ohio EPA, Division of Hazardous Waste Management. Surface Water - Dry cleaners can generate wastewater, such as the solvent-contaminated wastewater from water separators. To establish which wastewater requirements and regulations affect you, determine where your wastewater goes. Wastewater that is discharged to the sanitary sewer requires a permit or written confirmation that no permit is required from the operator of the local treatment plant or from Ohio EPA. For more information, contact Ohio EPA, Division of Surface Water, Pretreatment Unit. Wastewater that is directly discharged to a storm sewer, river, stream, lake or ditch requires a permit from Ohio EPA. For more information, contact Ohio EPA, Division of Surface Water, Industrial Permitting Unit.
Air Emissions - All dry cleaners must have a permit from Ohio EPA's Division of Air Pollution Control. In addition, new federal regulations for dry cleaners using perc contain a number of requirements. How dry cleaners will be affected by these regulations will be determined by the type of cleaning equipment used, the amount of perc used each month, and the date cleaning equipment was installed. The requirements are the heaviest for those dry cleaners that use greater amounts of perc. For more information about obtaining a permit or about how these regulations may affect you, contact Ohio EPA, Division of Air Pollution Control. Ground Water - Some dry cleaners may be discharging wastewater to a disposal well or septic system. These dry cleaners are actually operating Class V injection wells that are subject to regulation and must be permitted. Class V injection wells generally inject fluids into or above an underground source of drinking water and are frequently located in areas not served by a sanitary sewer system, or where sewer systems are inadequate. If you operate a Class V well, you must notify Ohio EPA. For more information, contact Ohio EPA, Division of Drinking and Ground Waters, Underground Injection Control Unit.
Pollution prevention
More than three quarters of the perc used at a dry cleaning facility can be lost to the atmosphere through emissions. A significant amount of perc also can be lost as hazardous waste. These represent both generation of pollutants and considerable loss of valuable raw material.

The best way to reduce pollution, wastes or emissions is to prevent them in the first place. Some pollution prevention activities are required by the new air regulations. Others are voluntary activities.

In addition to obvious environmental and human safety benefits, pollution prevention can also potentially reduce liability, enhance a company's image and save money.

Perhaps most important, in light of the previous discussion of the environmental regulations facing dry cleaners, pollution prevention may help reduce a dry cleaner's regulatory burden. For example, if a dry cleaner can reduce enough of its hazardous waste generation, it can increase the amount of time hazardous waste can be kept on-site and avoid certain reporting requirements.

Pollution prevention at dry cleaning facilities involves good housekeeping practices to minimize losses of solvents in liquid and vapor form, and also modifications to processes, equipment and operating practices. Options range from easily implemented, low-cost improvements, to more significant changes to equipment and operations.

The most significant changes obtainable through readily available technology include equipment upgrades, such as changing from a transfer machine to a dry-to-dry or closed-loop, dry-to-dry machine.

A dry cleaner can strategically address pollution prevention by first identifying all waste streams and emissions, including leaks, determining their sources, and then investigating what changes will be most feasible and effective.

For more information regarding pollution prevention for your operations, contact Ohio EPA, Office of Pollution Prevention.

Who to call at Ohio EPA
Division of Air Pollution Control
(614) 644-2270
Small Business Assistance Program
(614) 644-4830

Division of Drinking and Ground Waters,
Underground Injection Control Unit

(614) 644-2752

Division of Hazardous Waste Management,
Technical Support Unit

(614) 644-2956

Division of Surface Water,
Industrial Permitting Unit

(614) 644-2037
Pretreatment Unit
(614) 644-2021

Office of Pollution Prevention
(614) 644-3469

References
Ohio Environmental Protection Agency (Ohio EPA). August, 1993. Managing and reducing hazardous waste from dry cleaning. Ohio Environmental Protection Agency, Division of Hazardous Waste Management, Columbus, Ohio.

Source Reduction Research Partnership. 1991. Source reduction of chlorinated solvents: Dry cleaning of fabrics. California Department of Toxic Substances Control, Alternative Technology Division. Sacramento, California.

U.S. Environmental Protection Agency (U.S. EPA). September, 1995. Profile of the dry cleaning industry. EPA 310-R-95-001. U.S. Environmental Protection Agency, Office of Enforcement and Compliance Assurance. Washington, DC.


This document was prepared by the Ohio Environmental Protection Agency. April, 1996