For printed copies of this or other pollution prevention publications distributed by the Ohio Environmental Protection Agency, Office of Pollution Prevention, please call the Office of Pollution Prevention at 614/644-3469. A printed copy of the Office of Pollution Prevention publications distribution list, "Pollution Prevention Information Available from Ohio EPA", may also be ordered by calling 614/644-3469. State of Ohio Environmental Protection Agency Fact Sheet Managing and Reducing Hazardous Wastes From Dry Cleaning August 1993 Dry cleaning is a service industry involved in cleaning apparel and goods. Although not every dry cleaning facility or laundry produces hazardous waste, those facilities that use solvents in the cleaning process are likely to be subject to Resource Conservation and Recovery Act (RCRA) and state requirements that cover the generation, transportation, and management of hazardous waste. The types of establishments that make up this industry include: - Retail dry cleaning stores - Industrial and linen supply plants with dry cleaning operations - Leather and fur cleaning plants, and - Self-service laundromats with dry cleaning equipment. Dry cleaners and launderers typically use one or more of the following solvents: - Perchloroethylene (perc, tetrachloroethylene) - Petroleum Solvents (stoddard, quick-dry, low-odor or 140ø F) - CFC-l 13 (1, 1, 2-trichloro- 1, 2, 2-trifluoroethane, valclene). Scheduled for production phaseout on 12/ 31/95 - 1, 1, l-trichloroethane (1, 1, 1-TCA) There are three principal steps in dry cleaning operations: cleaning or washing, extracting, and drying. Cleaning steps involve washing the garments, extracting used solvent, and "drying" the solvent, which involves the use of hot air to evaporate solvent from clothing. Hot air then passes through condensing coils where it is condensed back into a liquid for reuse. Extraction is essential to any dry cleaning operation. It reduces solvent losses, eliminates waste and dripping of solvents, and reduces the weight of wet garments. The drying process removes any solvent remaining in the garments by tumbling them in a stream of warm air. When the removal of solvent is complete, the clothes often are treated with a stream of fresh air, a process called deodorizing or aerating. The types of waste that may be produced from dry cleaning operations besides spent solvents include spent carbon, carbon cartridges, still residues from solvent distillation (still bottoms) and cooked powder residues ("muck"). Managing 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 (40 CFR) Chapter 261, and in Ohio's Hazardous Waste Management Rules, Ohio Administrative Code (OAC) Chapter 3745-51. For example, tetrachloroethylene (perc) used in dry cleaning is a listed hazardous waste with a RCRA hazardous waste code of F002 when spent, or U2 10 as a pure commercial chemical product if discarded prior to use. Any other waste coming in contact with a listed waste also becomes a listed waste by virtue of the "mixture rule." A characteristic waste is not listed by name in the regulations. Instead it exhibits one or more of the four hazardous characteristics (ignitable, reactive, corrosive, and toxic). As an 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), which has replaced the Extraction Procedure (EP). The TCLP test simulates the acidic conditions found in a landfill and determines how much of certain regulated substances would leach from the waste if it is placed in a landfill. Regulatory levels are set for 39 hazardous constituens in terms of ppm (parts per million), and any waste exceeding these levels is a toxic hazardous waste. 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. Conditionally Exempt Small Quantity Generator (CESQG) - generates less than 100 kg of hazardous waste in a calendar month (about 220 pounds or 25 gallons). Small Quantity Generator (SQG) - generates between 100 and 1000 kg of hazardous waste per month (25 to 300 gallons). Large Quantity Generator (LQG) - generates more than 1000 kg of hazardous waste per month. Large quantity generators may accumulate hazardous waste for 90 days without a permit before sending it off-site. Small quantity generators can accumulate hazardous waste for 180 days without a permit. Storing Waste Hazardous waste must be stored in containers that are in good condition and made of or lined with materials that are compatible with the waste. Containers holding hazardous waste must always be closed during storage except when it is necessary to add or remove waste. Containers also must not be opened, handled or stored in a manner which may rupture them or cause them to leak. Containers holding hazardous waste must be marked with the date upon which each period of accumulation begins, and labelled or marked clearly with the words "Hazardous Waste." Before sending hazardous waste off-site, containers must be labelled, packaged, marked, and placarded in accordance with Department of Transportation regulations. Please call the Public Utilities Commission of Ohio (PUCO) Department of Transportation (DOT ) if you have any questions about DOT regulations. Use of Manifests Hazardous waste manifests are required of all SQGs and LQGs sending waste off-site. Manifests are not required for SQGs who are reclaiming their waste under a contractual agreement if the following conditions are met: - Type 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; and - The generator maintains a copy of the reclamation agreement for at least three years after termination or expiration of the agreement. In managing hazardous wastes 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 LQG who has not received a signed copy of the manifest from the facility to which the waste was sent, within 35 days of being sent off-site, must contact the transporter and/or the owner or operator of the facility to determine the status of the waste. If a copy is not received within 45 days, the generator must submit an exception report to the Ohio EPA including a legible copy of the manifest with a cover letter explaining the efforts taken to locate the waste. A SQG who does not receive a copy of the manifest with the signature of the owner or operator of the designated facility within sixty days of the date the waste was accepted by the initial transporter must submit a legible copy of the manifest, with some indication that the generator has not received confirmation of delivery, to the Ohio EPA Division of Hazardous Waste Management (DHWM). 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. Liability Although a waste disposal or recycling firm is often 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 LQGs and SQGs. They are voluntary for CESQGs although some commercial treatment, storage or disposal facilities require all customers to obtain them, independent of size. Notification forms and booklets may be obtained by calling Ohio EPA DHWM at (614)644-2977. Record Keeping Requirements LQGs must prepare an annual hazardous waste generator report to be submitted to Ohio EPA by March 1 each year. Report forms can be obtained by contacting the Data Management Section at (614) 644-2977. Generators are required to keep copies of manifests for at least three years. Additional Requirements for LQGs In addition to the requirements outlined elsewhere in this fact sheet, LQGs must ensure that employees who handle hazardous waste are provided with initial and annual refresher training regarding proper waste handling and emergency procedures. The site must be maintained and operated to minimize the possibility of fire, explosion or release of hazardous waste. Communi- cation and alarm systems must be available at the site, as well as emergency equipment such as for fires, spills and decontamination. The LQG must also have a contingency plan available which is implemented in the event of a fire, explosion or release involving hazardous waste. Pollution Prevention Pollution prevention is the use of source reduction techniques to reduce risk to public health, worker safety, and the environment. It is also the use of environmentally sound recycling to achieve these same goals. Pollution prevention includes source reduction, recycling, and reuse. Besides the obvious benefits of reduced risks to human health and the environment, side benefits include a potential reduction in liability and an enhancement to a company's image. Economic incentives can be significant, depending on the nature of the processes and the competitiveness of the business environment. Getting Started 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/or operating practices. U.S. EPA published the proposed perchloroethylene emission standards for dry cleaning facilities on December 9, 1991. Although not published in final form at the time this fact sheet was printed, incorporation of the measures outlined below will not only reduce waste and save you money, but they may be required by law in the future. A comprehensive program to detect and fix leaks in dry cleaning equipment has been shown to be a low cost method of reducing hazardous waste and emissions. The following components should be inspected weekly for leaks visually or by using a portable halogenated-hydrocarbon detector: 1. Hose connections, unions, couplings, and valves, 2. Machine door gaskets and seatings, 3. Filter head gasket and seating, 4. Pumps, 5. Solvent base tanks and solvent and waste storage containers, 6. Water separators, 7. Filter sludge recovery, 8. Distillation units, 9. Diverter valves, 10. Saturated lint from the lint basket, and 11. Cartridge filters. The entire exhaust should be vented through a carbon adsorber, refrigerated condenser, or equally effective control device. Perc must be stored in tightly sealed containers that are impervious to the solvent and chemical reaction of the perchloroethylene. The time that the door of the dry cleaning machine remains open should be minimized. Lint traps should be cleaned frequently and the lint placed in a tightly sealed container. Used cartridge filters should be drained in their housing or other sealed container for a minimum of 24 hours, or be dried in an enclosure vented to the control device. Other good management practices include the following: - Keep all containers properly labeled, and keep them covered to avoid evaporation and spillage. - Keep hazardous wastes separate from nonhazardous wastes to decrease risk of contamination - Minimize the opening of button traps and lint baskets. - Do not underload or overload machines. Underloading makes less efficient use of solvent, and allows losses of solvent at the same rate as a properly loaded system. Overloading can cause loose belts, and make drying difficult. - Use good record-keeping practices to keep track of how much solvent and other materials are purchased, delivered and sent off-site as waste. - Inspect materials upon delivery and return to the supplier any that are not acceptable. - Consider purchasing more efficient equipment such as add-on carbon adsorption or refrigeration units or a dry-to~dry machine if you are currently using a transfer system. Frequently Asked Questions What is the status of my separator water? Separator water may be hazardous if it contains solvents. It may be recycled, reused (which is the preferable method), or discharged into a sewer connected to a municipal sewage treatment plant. Discharge to the sewer system may occur only after receiving permission from the local plant authority. A permit will be required in most cases. Separator water should never be discarded by disposal into a septic system or by throwing it out onto the ground. Besides being illegal, this activity may be harmful to the septic system, surface waters and to wildlife. Where can I recycle my waste? There are many reputable companies which recycle waste from dry cleaners. Please call the Ohio EPA Central Office or one of the District Offices for a list of commercial treatment, storage, or disposal facilities in the state of Ohio. You also may contact the Central Office or the District Office in which the facility is located for information on the compliance history of any firm you wish to utilize. Do I need to use a manifest? A manifest is required for shipment of hazardous wastes off-site by all SQGs and LQGs, even if the waste is recycled. They are not required for CESQGs. If you are a SQG and have entered into a contractual agreement with a recycling facility, you may not need to use a manifest. See the section on contractual arrangements above. I am a CESQG. When do I need to send my waste off-site? The CESQG may accumulate up to 1000 kg of hazardous waste before it must be sent off-site. What are my liabilities for the waste? The generator of hazardous waste will always be liable for any waste produced. This is why pollution prevention is so important. Waste should be reduced, reused, or recycled whenever possible and only incinerated or disposed if there is no other alternative Can I mix different types of waste? Mixing of wastes is not encouraged. If you mix a hazardous waste with a nonhazardous waste, the whole mixture may become hazardous, which will increase disposal costs significantly. If in doubt, call your waste contractor to find out if they prefer to keep different types of waste segregated. For more information Ohio EPA Central Office Air Pollution Regulations Division of Air Pollution Control (614)644-2270 Hazardous Waste Rules Division of Hazardous Waste Management (614)644-2956 Pollution Prevention Office of Pollution Prevention (614)644-3469 Separator Water Rules Division of Water Pollution Control (614)644-2001 Ohio EPA District Offices Central District Office 3232 Alum Creek Drive Columbus, Ohio 43216-3669 (614)728-3778 Northeast District Office 2110 Aurora Rd. Twinsburg, Ohio 44087 (216)963-1200 Northwest District Office 347 North Dunbridge Rd. Bowling Green, Ohio 43402 (419)352-8461 Southeast District Office 2195 Front St. Logan, Ohio 43138 (614)385-8501 Southwest District Office 40 S. Main St. Dayton, Ohio 45402 (513)285-6357 PUCO Department of Transportation (614)466-3016 U.S. EPA RCRA/Superfund Hotline (800)424-9346 Small Business Ombudsman Hotline (800)368-5888 Trade Associations Ohio Cleaners Association (614) 221-1900 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 Administrative Code Chapters 50 - 69 dealing with hazardous waste.