Drycleaners are faced with environmental, fire and Occupational Safety and Health (OSHA) regulatory oversight. Therefore, drycleaners must be aware of the processes that present potential hazards and related regulation and compliance issues. This primer focuses only on the environmental issues. However, Table 3 compares the relative regulatory burden for each type of dry cleaning process.

Table 3

Issue	Perc	Petroleum	Wet Clean	CO 2
OSHA	High	High	Low	Moderate
Fire	Low	High	Low	Low
Hazardous Waste	High	Moderate	Low	Low
Air Quality	High	Moderate	Low	Low
Wastewater	High	High	Moderate	Low
All Environmental Regulations	High	Moderate	Low	Low

Hazardous Waste

Hazardous waste is regulated by the Resource Conservation and Recovery Act (RCRA). RCRA gave EPA the authority to control hazardous waste from "cradle to grave." This includes generation, transportation, treatment, storage, and disposal of hazardous waste. RCRA also set forth a framework for management of nonhazardous wastes.

Perc dry-cleaning facilities typically generate hazardous wastes in the form of cooked-powder residues, still-bottom residues, spent cartridges, spent solvents, and button/lint trap wastes. These wastes are perc-based and have EPA Hazardous Waste Numbers of F002 and/or D039. Dry cleaners also may occasionally dispose of unused perc.

Petroleum dry cleaners generate many of the same types of wastes. These wastes may be considered ignitable hazardous waste if the flashpoint is less that 140?F. Ignitable hazardous wastes have an EPA Hazardous Waste Number of D001. Many of the newer petroleum solvents have been developed with a flashpoint greater than 140?F to avoid classification as ignitable.

Dry cleaners generating hazardous waste must accurately document their monthly hazardous waste generation rate and on-site storage amount. These amounts are used to determine which hazardous waste generator category applies and the applicable set of hazardous waste regulations that must be met. Further information on determining generator categories and applicable recordkeeping, storage, transportation, and disposal requirements can be found in Part II of EPA?s Plain English Guide for Perc Cleaners or in EPA?s RCRA in Focus Dry Cleaning. State requirements may be stricter that federal requirements, therefore facilities should always check with their state regulatory agency.

Air Emissions

The two largest potential sources of air emissions from the perc dry-cleaning industry are the release of perc vapors into the atmosphere during transfer of clothes from the washer to the dryer, and the venting of the dryer exhaust. To eliminate these sources of air pollution, EPA regulations are phasing out use of transfer machines. Regulations are also phasing in requirements on installation of control devices for dryer exhaust.

In September 1993, the U.S. Environmental Protection Agency (EPA) issued the National Emission Standards for Hazardous Air Pollutants (NESHAP) for all perc dry cleaners (40 CFR Part 63, Subpart M). These regulations require all perc dry cleaners to implement pollution prevention steps including leak inspections and repair schedules, good housekeeping practices, and record-keeping requirements. This NESHAP also specified air emissions control requirements based on the type of equipment used, the installation date and the amount of perc purchased per year.

Title V of the Clean Air Act requires major "sources" of air pollutants to obtain operating permits in addition to NESHAP requirements. Major sources are defined as facilities with the potential to emit more than 10 tons per year of a single hazardous air pollutant or more than 25 tons of a combination of hazardous air pollutants. Perc is considered a hazardous air pollutant. Dry cleaners should contact their applicable state programs for information in determining whether Title V or other air permits are required.

Many petroleum dry-cleaning facilities in ozone Clean Air Act non-attainment areas are subject to New Source Performance Standard (NSPS) requirements (40 CFR Part 60 ? subpart JJJ). NSPSs set requirements for good housekeeping practices, monitoring of filter usage, and set limits on solvent losses.

Wastewater

The Clean Water Act of 1972, as amended in 1977, established the basic structure for regulating discharges of pollutants into the waters of the United States. It gave EPA the authority to regulate both wastewater discharges directly to surface waters via the National Pollutant Discharge Elimination System (NPDES) and discharges to municipal sewer systems. The act made it unlawful for any person to discharge any pollutant from a point source into navigable waters, unless a permit was obtained under its provisions.

Perc dry cleaners generate separator waters from sources, including carbon adsorbers, stills, muck cookers, and refrigerated condensers. Direct discharge (without containerization) of untreated separator water into a municipal sewer system is exempt from hazardous waste requirements (40 CFR Part 261.4) and is subject to state and local publicly owned treatment works (POTW) requirements. The POTW must be notified and approve of this discharge. Documentation of this approval should be maintained on site. State regulations and POTWs may establish additional requirements for this discharge. Perc-contaminated separator water that is containerized is subject to the same hazardous waste determination, storage, recordkeeping, and management requirements as other hazardous wastes discussed prior.

Petroleum dry-cleaning facilities also generate wastewaters. Petroleum solvent discharge to a POTW may be prohibited if the flashpoint is less than 140?F and presents a potential fire or explosion hazard. Petroleum dry cleaners are encouraged to review their material safety data sheets and applicable discharges as well as their state and local POTW regulations. At a minimum, the POTW should be notified and approve of this discharge. Documentation of this approval should be maintained on site.

Underground Storage Tanks

Though rare, dry-cleaning facilities storing perc or petroleum solvents in underground tanks are subject to underground storage tank regulations. These regulations require monitoring for spills and overflows, corrosion protection, and leak detection.