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© 1996 SBEAP 

 

Kansas Dry Cleaners 

Complying with Kansas Environmental Regulations 

 

Prepared by the Kansas Small Business Environmental Assistance Program

 

 

Kansas SBEAP

The Kansas Small Business Environmental Assistance Program (SBEAP) helps small businesses comply with the Clean Air Act Amendments of 1990 and the Kansas Air Quality Act. SBEAP provides technical assistance to diminish the burden of compliance. Its staff can introduce businesses to pollution prevention practices such as changes in product design, substitution of materials, process optimization, and in-plant recycling. SBEAP also offers compliance assistance to help businesses with permitting and reporting requirements. SBEAP is not a regulatory program; all assistance is confidential.

 SBEAP provides many services, all free to Kansas small businesses, including:

  • Compliance workshops and seminars. 
  • Technical manuals, pamphlets, and fact sheets for specific businesses. 
  • A quarterly newsletter, Kansas AIRLines, providing up-to-date news and compliance information. 
  • On-site technical assistance. 
  • A toll-free hotline, 800/578-8898. 
  • An Internet site for electronic access to information: http://sbeap.niar.twsu.edu.
Kansas SBEAP is a consortium composed of the University of Kansas’ Center for Environmental Education and Training (CEET), Kansas State University’s Pollution Prevention Institute (PPI), and Wichita State University’s Center for Technology Application (CTA). SBEAP is funded through a contract with the Kansas Department of Health and Environment.

 

Telephone Assistance

For general information, fact sheets, Kansas AIRLines newsletter, or other SBEAP publications:
SBEAP Resource Center at KU, 785/864-3968
For assistance with assessments, technical information, or permits:
SBEAP Technical Assistance Hotline at KSU, 800/578-8898
If you have a question or concern, or are unsure of whom to call:
Office of the Public Advocate, Kansas Department of Health and Environment, 800/357-6087 (in Topeka, 296-0669)

Written by Terrie Boguski and Marc Crouse. Edited by Felice Stadler, with significant contributions by Tim Piero and Jean Waters.
Adapted from the SBEAP Dry Cleaners pamphlet and the Dry Cleaners Quick Reference Manual. Printed August 1997. Kansas SBEAP

 

 

 

 

 

Contents

Introduction .

 Perchloroethylene Dry Cleaning Air Quality.

Pollution Prevention Compliance for Dry Cleaners Using Controls Permits

Petroleum Dry Cleaning

Hazardous Waste Regulations Alternative Dry Cleaning Technologies

 Definitions

 

 

Introduction

T he most commonly used dry cleaning solvent is perchloroethylene (perc). Under the Clean Air Act, the U.S. Environmental Protection Agency has established a maximum achievable control technology (MACT) standard that regulates perc dry cleaners.
Clean air regulations have been in effect for Kansas perc dry cleaners since September 1993, after EPA finalized the MACT standard. The regulations were first published in the Federal Register on September 22, 1993, and amended on December 20, 1993 (58 FR 49376, September 22, 1993, and 58 FR 66298, December 20, 1993). The regulation is included in Chapter 40 of the Code of Federal Regulations, Part 63, Subpart M (40 CFR 63 M). Recently EPA also issued guidance concerning occasional exceedances of perc consumption for dry cleaners who are otherwise in compliance with the regulations. The details of the perc MACT standard are discussed in the first four sections, pages 5–17. Petroleum solvent (Stoddard, quick-dry, or low-odor) is another type of dry cleaning solvent for which a MACT standard is planned by November 15, 2000. The current regulations for petroleum dry cleaning are discussed on pages 18–19.
Hazardous waste regulations, the environmental surcharge and solvent fee, and Kansas environmental remediation regulations are discussed on pages 20–26. Both perc and petroleum solvent dry cleaners are affected by these requirements. Alternative dry cleaning technologies are covered on page 27.
This pamphlet summarizes the environmental regulations that affect Kansas dry cleaners. It does not include all the details contained in the U.S. EPA or Kansas regulations. We encourage you to obtain copies of the regulations. Call the SBEAP hotline at 800/578-8898, or call the appropriate KDHE office for further information. It is your responsibility to ensure that your facility is in compliance with all environmental regulations.

 

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Perchloroethylene Dry Cleaning Air Quality

This MACT standard affects all dry cleaners who use perc (also referred to as tetrachloroethylene or PCE).
All dry cleaners were required to be in full compliance with the MACT standard by September 23, 1996. Dry cleaners using dry-to-dry machines installed before December 9, 1991, and dry cleaners using transfer machines installed before September 22, 1993, were required to comply with certain parts of the regulation by December 20, 1993.
If you install new machines or add-on control devices, you must be in full compliance at startup. Whenever you get new equipment, you also must notify KDHE that you are in compliance (see Reporting Requirements on page 15).
The compliance requirements differ, depending on how much perc you purchase annually, the types of machines you operate, and when your machines were installed (see Table 1). If you need more assistance in determining your compliance requirements, contact Kansas SBEAP.
Table 1 summarizes your source status as defined by your perc consumption.


TABLE 1.
Perc Consumption Limits
Type of Machine Small Area Source Large Area Source Major Source
Dry-to-dry only < 140 gallons (530 liters) perc/year 140 to 2,100 gallons (530–8,000 liters) perc/year > 2,100 gallons (8,000 liters) perc/year
Transfer only< 200 gallons (760 liters) perc/year200 to 1,800 gallons (760–6,800 liters) perc/year >1,800 gallons (6,800 liters) perc/year
Both dry-to-dry and transfer < 140 gallons (530 liters) perc/year 140 to 1,800 gallons (530–6,800 liters) perc/year > 1,800 gallons (6,800 liters) perc/year

< means less than > means greater than

 

Compliance Overview

All perc dry cleaners must meet certain pollution prevention requirements (see page 9).
All new perc dry cleaners (installed after September 22, 1993) must be dry-to-dry machines and be equipped with refrigerated condensers.

Small Area Sources
You are a small area source if:

  • You operate dry-to-dry machines or both dry-to-dry and transfer machines and use less than 140 gallons (530 liters) of perc per year (12-month rolling average, calculated on the first day of each month).
    or
  • You operate only transfer machines and use less than 200 gallons (760 liters) of perc per year (12-month rolling average, calculated on the first day of each month).

If you meet the above criteria and your dry-to-dry machines were installed before December 9, 1991, or your transfer machines were installed before September 22, 1993, you need only meet the pollution prevention requirements of the MACT standard (see page 9). You should also review the guidelines for occasional exceedances on page 8.
If you have new equipment (dry-to-dry machines installed after December 9, 1991) , you must meet the same requirements as a large area source.

Large Area Sources
You are a large area source if:

  • You operate only dry-to-dry machines and use between 140 gallons and 2,100 gallons (530–8,000 liters) of perc per year (12-month rolling average, calculated on the first day of each month).
    or
  • You operate both dry-to-dry and transfer machines and use between 140 gallons and 1,800 gallons (530–6,800 liters) of perc per year (12-month rolling average, calculated on the first day of each month).
    or
  • You operate only transfer machines and use between 200 gallons and 1,800 gallons (760–6,800 liters) of perc per year (12-month rolling average, calculated on the first day of each month).

If you are a large area source, you must meet pollution prevention requirements (page 9) and these additional requirements:

  • Use a refrigerated condenser or equivalent control device to remove perc from the air stream contained within each dry cleaning machine.
    or
  • Use a carbon absorber to remove perc from the air stream contained within each dry cleaning machine (carbon adsorbers are allowed only if installed before September 22, 1993). See pages 10–16 for requirements associated with control equipment, monitoring, and reporting.

Major sources
You are a major source if:

  • You operate only dry-to-dry machines and use more than 2,100 gallons (8,000 liters) of perc per year (12-month rolling average, calculated on the first day of each month).
    or
  • You operate only transfer machines or both transfer and dry-to-dry machines and use more than 1,800 gallons (6,800 liters) of perc per year (12-month rolling average, calculated on the first day of each month).
If you are a major source, you must comply with the requirements for large area sources, including pollution prevention requirements. You also must comply with the requirements listed below.

If you operate a transfer machine:

  • And you already have a carbon adsorber or refrigerated condenser (installed before September 22, 1993), you must install a room enclosure around each transfer machine and vent the room enclosure to a carbon adsorber. Room enclosures cannot be vented to refrigerated condensers.
  • And you have no refrigerated condenser or carbon adsorber, you must install a refrigerated condenser on the transfer system and a room enclosure vented through a carbon adsorber.

If you installed a new dry-to-dry machine after December 9, 1991:
You must use a carbon adsorber with a refrigerated condenser for vented machines. The air from within the machine must pass through the carbon adsorber before the door of the machine is opened or as it is opened. For nonvented machines, the carbon adsorber is required following the refrigerated condenser.

CASE STUDY
Cottage Cleaners, Forest Lake, Minnesota
Change: Replaced an old transfer dry cleaning machine with a new and more efficient dry-to-dry machine.
Cost: $49,000 purchase cost for a new dry-to-dry machine.
Savings: $2,246 per year for perc; reduced the amount of perc used from 455 gallons (1,720 liters) per year in 1990 to 38 gallons (145 liters) per year in 1992.
$593 per year for hazardous waste disposal; reduced generated hazardous waste from 375 gallons (1,420 liters) per year in 1990 to 240 gallons (910 liters) per year in 1992.
Compliance with OSHA and 1990 CAAA requirements for perc emissions.
High employee satisfaction with new equipment.
Maintained high-quality cleaning results and customer satisfaction.

Courtesy of MnTAP, Minneapolis, Minnesota

Occasional Exceedances
If you exceed your allowable perc consumption as calculated in your 12-month rolling average, and it has been at least three years since your most recent prior exceedance, this will not affect your source status. For example, a small area source that uses more perc than allowed once every three years will not be reclassified as a large area source. Likewise, a large area source will not be reclassified as a major source if perc consumption limits are exceeded only once every three years.
If you are a small area source and your 12-month perc use exceeds the allowable limits more frequently than once in three years, you have 180 days to comply with large area source requirements. Likewise, if you are a large area source and your 12-month perc use exceeds the allowable limits more frequently than once in three years, you have 180 days to comply with major source requirements.
If you have more frequent exceedances, you can request that KDHE determine whether they were unusual or “episodic” occurrences. Episodic exceedances (those not expected to recur) should not affect the regulatory status of your facility. Compliance requirements for small and large area sources and major sources are summarized in Table 2.

 

TABLE 2.

Compliance Requirements
    

 

Small Area Source Large Area Source Major Source
Existing machines (installed before December 9, 1991) Pollution prevention
  • Pollution prevention
  • Refrigerated condensers or existing carbon adsorbers
  • Pollution prevention
  • Refrigerated condensers or existing carbon adsorbers
  • Room enclosure with carbon adsorbers around transfer machines
New machines* (installed after December 9, 1991)
  • Pollution prevention
  • Refrigerated condenser
    • Pollution prevention
    • Refrigerated condenser
    • Pollution prevention
    • Refrigerated condensers followed by carbon adsorbers

    * Transfer machines installed between December 9, 1991, and September 22, 1993, are treated the same as existing machines.

     

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    Pollution Prevention

    Pollution prevention is an important part of the MACT standard for perc dry cleaners. You must comply with the following good housekeeping, maintenance, and recordkeeping requirements:

    Good Housekeeping and Maintenance

    • Close machine doors immediately after transferring articles to or from the machines.
    • Keep machine doors closed between transfers.
    • Follow the manufacturer’s instructions for operating and maintaining machines and equipment.
    • Drain cartridge filters in a closed container for at least 24 hours.
    • Store all perc and wastes in sealed containers that do not leak.
    • Inspect all dry cleaning equipment at least biweekly for any leaks that are obvious by sight, smell, or touch. Leaks include instances where drops of perc are visible on the outside of a machine or where air can be felt coming from a machine. (Large area sources or major sources must inspect weekly.) Dry cleaning equipment includes hoses, pipes, fittings, couplings, valves, gaskets, seals, pumps, solvent tanks and containers, water separators, muck cookers, stills, diverter valves, and cartridge filter housings.
    • Repair any leaks within 24 hours or, if repair parts must be ordered, within five days of receiving the parts. Parts must be ordered within two working days of finding the leak.
    • Keep copies of design specifications and operating manuals for each dry cleaning machine. If you do not have an operating manual, contact the Public Advocate at 800/357-6087 for a generic operating manual.

     

    Recordkeeping (Keep records for five years.)

    • Keep records of the amount of perc purchased for the past 12 months. This should be an ongoing record, the 12-month total calculated on the first day of each month.
    • Keep records of your leak inspection and repair program. This includes dates of inspections, locations or parts where leaks are found, part order and receipt dates, and dates repairs were made.
    If you are required to do more than pollution prevention, additional recordkeeping is required (see page 11).

     

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    Compliance for Dry Cleaners Using Controls

    If using refrigerated condensers installed on a dry-to-dry machine, dryer, or reclaimer:
    • Operate the machine so that air-perc vapor is not released to the atmosphere while the drum is rotating. Air-perc vapor should be recirculated through the machine without venting to the atmosphere.
    • Install a diverter valve to prevent outside air drawn into the machine when the door is open from passing through the condenser.

    If using refrigerated condensers installed on a washer:
    • Operate the machine so that air-perc vapor is not released to the atmosphere until the washer door is open.
    • The same refrigerated condenser cannot be shared by a washer and a dry-to-dry machine, dryer, or reclaimer.

    If using carbon adsorbers:
    • Carbon adsorbers cannot be bypassed so that air-perc vapor is released to the atmosphere without passing through them.

    If using room enclosures:
    • Room enclosures must be constructed of materials through which perc vapor cannot escape.
    • Room enclosures must operate with a negative pressure at each opening while the dry cleaning machine is operating.
    • Room enclosures must be vented to a separate carbon adsorber or equivalent control device, and not share a carbon adsorber in common with a dry cleaning machine.

    CASE STUDY
    General Perc Dry Cleaning Operations
    Change: Add refrigerated condensers.
    Cost: $7,000–8,000 installed.
    Savings: 40–50 percent reduction in perc use. Reduced hazardous waste disposal cost.

    Courtesy of MnTAP, Minneapolis, Minnesota

     

    Monitoring and Recordkeeping Requirements

    All dry cleaners must follow recordkeeping requirements for pollution prevention (see page 9). In addition,
    If you use a refrigerated condenser, you must:
    • Measure weekly the temperature of the air-perc vapor stream at the outlet of the refrigerated condenser on each dry-to-dry machine, dryer, or reclaimer, using a temperature sensor (temperature should be equal to or less than 45° F).
    • Measure weekly for existing transfer equipment the difference between the temperature of the air-perc vapor stream entering the refrigerated condenser on each washer and the temperature of the vapor stream leaving the refrigerated condenser. You must use temperature sensors (temperature difference should be equal to or greater than 20° F).
    • Keep records of temperature sensor monitoring results, including dates when measurements and calculations are performed.

    If you use a carbon adsorber, you must:
    • Measure weekly the concentration of perc in the exhaust of the carbon adsorber at the end of the last dry cleaning cycle prior to desorption, using a colorimeter detector tube. (The concentration of perc should be equal to or less than 100 parts per million by volume.)
      or
    • For new no-vent, dry-to-dry machines using greater than 2,100 gallons (8,000 liters) of perc per year (major sources), measure weekly the concentration of perc in the dry cleaning drum at the end of the dry cleaning cycle. (The concentration of perc should be equal to or less than 300 parts per million by volume.)
      and
    • Keep records of colorimetric detector tube monitoring results, including dates when measurements are performed.

    Figures 1, 2, and 3 show monitoring requirements for small and large area sources and major sources

     

    Figure 1.
    Monitoring Requirements for Small Area Sources

     

    Transfer machines No monitoring; pollution prevention only
    Existing dry-to-dry machines No monitoring; pollution prevention only
    New dry-to-dry machines Weekly measurement of perc air stream must be less than or equal to 45° F.

     

    Figure 2.
    Monitoring Requirements for Large Area Sources

     

    Transfer machines If using refrigerated condenser Weekly measurement of perc air stream temperature

    On dryer: less than or equal to 45° F On washer: greater than or equal to 20° F difference between inflow and outflow temperatures

    If using carbon adsorber*

    Weekly measurement of exhaust stack using colorimetric tube must be less than or equal to 100 ppm

    Existing dry-to-dry machines

     

    		 

    		 
    If using refrigerated condenser or no-vent refrigerated machine Weekly measurement of perc air stream must be less than or equal to 45° F
    New dry-to-dry machines Must use refrigerated condenser or no-vent refrigerated machine Weekly measurement of perc air stream must be less than or equal to 45° F

    * Carbon adsorbers are allowed only if installed before September 22, 1993.

     

    Figure 3.
    Monitoring Requirements for Major Area Sources

     

    Transfer machines If using refrigerated condenser Weekly measurement of perc air stream temperature

    On dryer: less than or equal to 45° F On washer: greater than or equal to 20° F difference between inflow and outflow temperatures

    If using carbon adsorber*

    Weekly measurement of exhaust stack using colorimetric tube must be less than or equal to 100 ppm

    Existing dry-to-dry machines

     

    		 

    		 
    If using refrigerated condenser or no-vent refrigerated machine Weekly measurement of perc air stream must be less than or equal to 45° F
    New dry-to-dry machines Must use refrigerated condenser or no-vent refrigerated machine Weekly measurement:
    For carbon adsorber: exhaust stack less than or equal to 100 ppm

    For no-vent carbon adsorber: less than or equal to 300 ppm

    * Carbon adsorbers are allowed only if installed before September 22, 1993.
    Room enclosures are required for transfer machines that are major sources.

     

    Reporting Requirements

    All dry cleaners must submit:
    • Initial notification reports (due June 18, 1994, or within 30 days of equipment installation).
    • Pollution prevention compliance reports (due June 18, 1994, or within 30 days of equipment installation).

    In addition, large area sources and major sources must submit control requirements compliance reports (due October 23, 1996, or within 30 days of equipment installation).
    If you are a small area source and you exceed your perc consumption limit, you must submit a control requirements compliance report within 180 days of when you determined that you exceeded perc consumption limits. In this report, you will state your new yearly perc consumption and show that you are in compliance with the requirements for large area sources.
    If you are a large area source and you exceed your perc consumption limit, you must resubmit a control requirements compliance report within 180 days of when you determined that perc consumption limits were exceeded. In this report, you will state your new yearly perc consumption and show that you are in compliance with the requirements for major sources.
    If you have not exceeded your allowable perc consumption within the past three years or if unusual circumstances apply, contact the Kansas Department of Health and Environment (KDHE) for further information. You may be able to avoid changing your source status (see Occasional Exceedances on page 8).
    Reporting requirements are summarized in Table 3.
    Reminder
    When you install new equipment, you must submit another initial notification, pollution prevention compliance report, and control compliance report.

     

    TABLE 3.

    Reports
    Report Type of Facility Due Date
    Initial notification
    • Small area source
    • Large area source
    • Major source
    		July 18, 1994, or within 30 days of equipment installation
    Pollution prevention compliance
    • Small area source
    • Large area source
    • Major source
    		July 18, 1994, or within 30 days of equipment installation
    Control requirements compliance
    • Large area source
    • Major source
    		October 23, 1996, or within 30 days of equipment installation

     

    Send reports to: Director of Air, RCRA, and Toxins U.S. EPA Region 7 726 Minnesota Ave. Kansas City, KS 66101
    Send copies to: Kansas Department of Health and Environment Bureau of Air and Radiation Building 283, Forbes Field Topeka, KS 66620

     

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    Permits

    If you are a major source of HAP (hazardous air pollutant) emissions, you are required to get a Class I air operating permit from KDHE.
    Under this MACT standard, dry cleaning facilities that are classified as small or large area sources were originally required to get a Title V permit. However, EPA deferred the permit requirement in June 1996. If you are a small or large area source perc dry cleaner, the new deadline to get a Title V permit from KDHE is December 9, 2000.
    New dry cleaners and modified or reconstructed facilities may be subject to KAR 28-19-300 construction permitting and approval requirements.
    If you need help determining which permit may apply to you, contact SBEAP.

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    Petroleum Dry Cleaning

    EPA is planning to develop a MACT standard for petroleum dry cleaners, scheduled November 15, 2000. In the meantime, the following equipment is regulated if it is installed at facilities having a total manufacturer’s rated dryer capacity equal to or greater than 84 pounds (38 kilograms) and constructed after December 14, 1982:
    • Petroleum solvent dry cleaning dryers.
    • Washers.
    • Filters.
    • Stills.
    • Settling tanks.

    The total manufacturer’s dryer capacity is the sum of the rated capacity for each petroleum solvent dryer that:
    • Is in existing operation.
      or
    • Is proposed for operation after a facility modification is finished.

    A dryer is exempt from these regulations if it was constructed between December 14, 1982, and September 21, 1984, and uses less than 4,700 gallons (17,800 liters) of solvent per year.

    Requirements

    • Every dryer installed must be a solvent recovery dryer.
    • All solvent filters must be cartridge type filters and must be drained in their sealed housings for eight hours before removal.
    • All dryers must have leak inspection and repair notices posted on them with a clearly visible label. Leak inspection and repair notices also must be recorded in a manual (see 40 CFR Part 60.622 for recommended label wording).
    • You must perform an initial test to verify that the flow rate of recovered solvent from the solvent recovery dryer at the end of the recovery cycle is no greater than 0.05 liters per minute (50 milliliters per minute).
    • You must maintain a record of this performance test as explained below.

    Petroleum Dry Cleaners

    You must conduct performance tests for a minimum of two weeks, with at least 50 percent of dryer loads monitored for their final recovered solvent flow rate.
    It is suggested that the measurement of the flow rate of recovered solvent be taken from the outlet of the solvent-water separator.
    Near the end of the recovery cycle, you must divert the entire flow of recovered solvent to a measuring container, such as a graduated cylinder.
    As the recovered solvent collects in the graduated cylinder, you must record the elapsed time in periods of one minute or greater.
    Calculate the recovered solvent flow rate by dividing the volume of solvent collected in a period by the length of time elapsed during the period. The results must be expressed in liters per minute (there are 1,000 milliliters in a liter).
    You must continue with the recovery cycle and monitoring procedure until the flow rate of solvent is less than or equal to 0.05 liters per minute.
    Keep for five years records of the types of articles cleaned and the total length of the cycle.
    See pages 31–32 for tables of weights and measures and metric/customary conversion.

     

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    Hazardous Waste Regulations

    Most dry cleaners are generators of hazardous waste. You therefore should become familiar with the statutes and regulations that apply to the handling and disposal of hazardous wastes. It is your responsibility to determine which of your wastes are hazardous and to ensure that they are transported and disposed according to the law. You may want to read the Hazardous Waste Generator Handbook published by KDHE for more information. You may order it by calling the SBEAP Resource Center at 785/864-3968.

    Definitions of Hazardous Waste

    EPA has defined a waste as hazardous if it has certain properties that could pose danger to human health or the environment after being discarded. There are two categories of hazardous waste: listed and characteristic. Perc, when used as a solvent, is a listed hazardous waste (EPA waste code F002). Petroleum solvents are not a listed hazardous waste, but are potentially hazardous because they may be considered ignitable (see definition of ignitable below).
    Hazardous waste products produced by most dry cleaners include, but are not limited to:
    • Still bottoms.
    • Filter casings.
    • Separator water.
    • Partially empty solvent containers or drums that may contain residual solvents.
    • Spotting board residues.
    In addition to the wastes specifically listed as hazardous, a waste is considered hazardous if it exhibits one or more of the following characteristics: ignitability, toxicity, corrosivity, or reactivity.
    A waste is ignitable if it has a flash point* of lower than 140° F (consult the material safety data sheet); readily causes fires and burns so vigorously that it creates a hazard; or is an ignitable compressed gas or an oxidizer as defined by Department of Transportation (DOT) regulations. Certain solvents used in routine maintenance and cleaning of equipment may be ignitable.

    *The lowest temperature at which vapors above a volatile combustible substance ignite in air when exposed to flame.

    Categories of Hazardous Waste Generators

    Kansas regulations define three categories of hazardous waste generators: small quantity generators, Kansas generators, and EPA generators. You must determine your generator category to determine which regulations apply to you. Your facility may change its status from one category to another, depending on how much waste it generates in a given period.
    In determining your status as a hazardous waste generator, count all quantities of hazardous waste that:
    • You store on site.
    • You package and transport off site.
    • You place directly in a regulated on-site treatment or disposal unit.
      or
    • You generate as still bottoms or sludge and remove from product storage tanks
    .
    Do not count wastes that:
    • Are specifically exempt (for example, used oil that is recycled).
    • May be left in the bottom of containers that have been completely emptied by conventional means such as pouring or pumping.
    • Are reclaimed continuously on site without storing. (However, count residue removed from recycling apparatus and spent cartridge filters.)
    • Are managed in an elementary neutralization unit, a totally enclosed treatment unit, or a wastewater treatment unit.
    • Are discharged directly to a publicly owned treatment works (POTW) without being stored. Discharging perc wastewater to a POTW is not allowed in Kansas.
      or
    • Are already counted once during the month, reclaimed, and used again.

    You can reduce your quantity of hazardous waste by separating hazardous waste and nonhazardous waste. A mixture of these two types of waste must be treated as hazardous.

    Small Quantity Generator
    You are considered a small quantity generator if your facility meets both of the following conditions:

    • You produce no more than 55 pounds (25 kilograms) of hazardous waste in a calendar month.
      and
    • You accumulate no more than 2,200 pounds (1,000 kilograms) of hazardous waste at any time.
    Requirements as a Small Quantity Generator
    As a small quantity generator, you are not subject to any notification or reporting requirements, but you are required to manage your hazardous waste in an environmentally sound manner.
    You must identify all the hazardous waste you generate.
    • Accumulations of 55 pounds (25 kilograms) or more must be recycled, properly treated or disposed on site, or transported to an authorized hazardous waste facility.
    • Smaller accumulations may be disposed by recycling, reusing, reclaiming, disposing at a permitted solid waste landfill (such as a municipal or county landfill), or disposing at a permitted hazardous waste facility. They may also be neutralized and discharged to the sanitary sewer. (You may not discharge such hazardous waste as perc wastewater, solvents, sludges, or pesticides to the sanitary sewer.)
    You may not dispose of any quantity of hazardous waste by dumping it on the surface of the ground or into surface waters, burying it at an unpermitted site, or using waste such as a solvent to kill weeds.
    For more information, contact the KDHE Bureau of Waste Management at 785/296-1617.

    Kansas Generator
    You are considered a Kansas generator if your facility meets both of the following conditions:

    • You generate between 55 pounds (25 kilograms) and 2,200 pounds (1,000 kilograms) of hazardous waste in a calendar month.
      and
    • You accumulate no more than 2,200 pounds (1,000 kilograms) of hazardous waste at any time.

    EPA Generator
     You are considered an EPA generator if your facility meets any of the following conditions:

    • You generate in any single month or accumulate at any time 2,200 pounds (1,000 kilograms) or more of hazardous waste.
      or
    • You generate in any single month or accumulate at any time 2.2 pounds (1 kilogram) of acutely hazardous waste.
      or
    • You generate or accumulate at any time more than 55 pounds (25 kilograms) of debris and contaminated materials from the cleanup of acutely hazardous waste spillage.
    Requirements As a Kansas or EPA Generator
    As a Kansas or EPA generator, you are subject to several regulations, including obtaining an EPA identification number, preparing a manifest for all off-site shipments of hazardous waste, and meeting emergency preparedness requirements. If you think you may be classified as either a Kansas or an EPA generator, contact KDHE at 785/296-1617.

    Shipping Waste Off Site

    The three most important things to remember when shipping hazardous waste off site are:
    • Choose a reputable hauler and facility with EPA ID numbers.
    • Package and label all waste appropriately.
    • Prepare a hazardous waste manifest. (Make sure your copies are readable.)
    You must ensure that your transporter and waste facility meet applicable state and federal regulations. Disposal facilities must have permits issued by EPA or the state in which the facility is located. Under federal law, you may use only authorized hazardous waste transporters and disposal facilities that have been assigned EPA identification numbers.
    The hauler you choose will transport your waste, and the waste management facility will be its final destination. But remember that you are still responsible for the waste you produce.

    Kansas Environmental Surcharge and Solvent Fee

    An environmental surcharge and dry cleaning solvent fee is collected by the Kansas Department of Revenue (KDR). The surcharge is used to fund the cleanup of contaminated sites associated with dry cleaning.
    The surcharge is 2 percent of gross receipts (not including sales tax) received from dry cleaning or laundering services that purchase dry cleaning solvents. In 1997, the solvent fee is $4.00 per gallon for perc and $0.40 per gallon for petroleum solvents. For perc, the fee increases $0.25 each year until the fee rate reaches a maximum of $5.50. For petroleum solvents, the fee increases $0.025 each year until the fee rate reaches a maximum of $0.55 per gallon.
    Dry cleaners currently registered for the retailers’ sales tax have been automatically registered for the environmental surcharge and solvent fee.

    Kansas Environmental Remediation Regulations

    KDHE recently adopted additional regulations for dry cleaners, implemented by the Bureau of Environmental Remediation in KDHE. These new regulations implement the Kansas Dry Cleaner Environmental Response Act and supplement existing state hazardous waste regulations (see pages 20–26). The regulations include:
    • Registration of dry cleaning facilities.
    • Performance standards for dry cleaners.
    • Removal of dry cleaning wastes from closed facilities.
    • Use of surcharge funds for cleanup of contaminated sites.
    An overview of the Kansas Dry Cleaner Environmental Response Act follows. For more detailed information, contact the KDHE Bureau of Environmental Remediation at 785/296-6370.

    Registration of Dry Cleaning Facilities
    You must register each of your dry cleaning facilities with KDHE’s Bureau of Environmental Remediation annually. New facilities (those beginning operation after January 3, 1997) must submit a registration form within 30 days of beginning operation. New owners must submit a registration form within 30 days of assuming ownership. Contact KDHE’s Bureau of Environmental Remediation at 785/296-6370 to get the registration forms.

    Performance Standards for Dry Cleaners
    The compliance date for the following new requirements is July 3, 1997, for existing dry cleaners. New dry cleaners must comply at startup.
    Small quantity generators of hazardous waste should dispose of perc waste in an acceptable on-site facility or send the waste to an approved hazardous waste treatment, storage, or disposal facility. Dry cleaners that are Kansas or EPA generators continue to comply with KAR 28-31(1–4).
    You must clearly label with the words “Hazardous Waste” each container in which hazardous waste is collected or stored.
    You must mark with the date on which hazardous waste accumulation began any containers used to store hazardous waste for more than 72 hours.
    Dry cleaning wastewater may not be stored for more than 60 days.
    You may not discharge any dry cleaning solvents into sanitary sewers, storm sewers, septic tanks, underground storage tanks, water bodies, or soil.
    You may evaporate dry cleaning wastewater at your facility in a heated evaporation unit made of materials impervious to the solvent (perc or petroleum solvent) if the wastewater contains no free-phase solvent (no droplets suspended in the water or separate layer at the bottom).
    Keep hazardous waste containers in good condition. Inspect containers weekly for deterioration. Keep inspection logs and records of repairs for at least five years.
    Keep hazardous waste containers closed except when adding or removing waste.
    Do not store incompatible wastes in the same container. If you are not sure of compatibility, do not mix wastes.
    The compliance date for the following new requirements is January 3, 1999, for existing dry cleaners. New dry cleaners must comply at startup.
    You must construct a dike or other secondary containment structure around each dry cleaning unit and each solvent or waste storage area. For perc users, the structure must be made of epoxy or steel. For petroleum solvent users, concrete also may be used.
    Floor drains are not allowed in secondary containment structures.
    You must inspect your secondary containment structures weekly. Any deficiency must be repaired within five calendar days.
    You must keep records of inspections and repairs for at least five years.
    Perc deliveries must be made using a direct-coupled delivery system. Alternative technologies may be used with KDHE approval.

    Removal of Dry Cleaning Wastes from Closed Facilities
    If you cease operation of your dry cleaning facility for at least 45 continuous days, you must remove all dry cleaning solvents and wastes from your facility within 45 days after the last day of operation.
    Dry cleaning wastes must be disposed according to state and federal hazardous waste regulations.

    Use of Surcharge Funds for Cleanup of Contaminated Sites
    If your facility has released dry cleaning solvent, contaminating local groundwater, you may apply to KDHE to have the contaminated site ranked for cleanup using the dry cleaning environmental surcharge fund. You will need to provide an analysis of one groundwater sample to prove that the release has occurred. Soil samples may be substituted for groundwater samples with approval from KDHE. Priority will be given to sites that require emergency action.
    The cost of collecting information for ranking a contaminated site will be credited to the payment of a $2,500 deductible. Therefore, keep records of the cost of collecting the necessary information. The deductible payment will be required from each dry cleaning facility that has contributed to the contamination of the site.
    If you have spent more than $2,500 in corrective actions, you may request reimbursement from KDHE. Obtain approval from KDHE before proceeding with any corrective action. If you request reimbursement for corrective actions, you must provide the following records:

    • Notice of KDHE eligibility for site cleanup.
    • Work plans for actions for which you are asking to be reimbursed.
    • All reports generated during the corrective action.
    • Notice of KDHE approval for the corrective action.
    • Contractor and subcontractor invoices.

    If you need more information about ranking a contaminated site, use of the surcharge fund, or reimbursement for corrective actions, contact KDHE at 785/296-6370.

     

     

     

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    Alternative Dry Cleaning Technologies

    New technologies will help dry cleaners reduce emissions by avoiding the use of perc. Some developing technologies are listed below.
    • Multiprocess wet cleaning—a water-based cleaning process that relies on heat, steam, pressing, and soap to clean clothes.
    • Ultrasonic washing—involves the immersion of textiles in a water bath using mechanical energy to create pressure waves to remove soil from garments.
    • Microwave drying—converts electromagnetic radiation to thermal energy so water can evaporate quickly.
    • Supercritical carbon dioxide cleaning—uses liquefied carbon dioxide in the cleaning process.
    EPA tested the multiprocess wet cleaning method for four weeks in November and December 1992. In this test, more than 1,500 garments from persons employed in government agencies were collected. The garments were separated into lots of 50 and cleaned either by the wet cleaning method or perc dry cleaning. The total costs for wet cleaning and dry cleaning were compared. Customer satisfaction surveys were completed and performance tests of the garments were made. In addition, data were collected from equipment vendors, industry organizations, and EPA reports to project costs for converting an existing dry cleaning plant and for designing a new wet cleaning facility. The general results of the cost and performance study indicate that the wet cleaning process appears to be economically competitive and acceptable to customers.
    A nationwide demonstration project is also being conducted by the Center for Neighborhood Technology (CNT) in Chicago in cooperation with EPA. Three types of data are being collected: results of customer satisfaction surveys, evaluations of cleaning and finishing quality, and cost analyses. For more information about this project, contact CNT, 2125 West North Ave., Chicago, IL 60647-9886, 773/278-4800.

    CASE STUDY

    Utopia Cleaners, Arlington, Massachusetts
    Change: Replaced perc dry cleaning machine with wet cleaning machine.
    Cost: $1,000 purchase cost of DaeWoo wet cleaning machine (one-quarter of the capacity of the previously used dry cleaning machine). Increased time spent pressing each garment. Wet cleaned garments tend to be more wrinkled than dry cleaned garments.
    Savings: $825 to $963 per year for perc.
    $1,800 per year in perc disposal costs.

    Employees and customers are no longer exposed to perc vapors.

    Utopia is no longer regulated under the Clean Air Act. Utopia expects to process 80 percent of the garments it handles in the wet system and send out the remaining 20 percent to a conventional perc dry cleaner under the same ownership.

    Courtesy of the Massachusetts Toxics Use Reduction Institute

     

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    Definitions

    Biweekly: Any consecutive 14-day period.

    Carbon adsorber: A bed of activated carbon through which an air-perchloroethylene gas-vapor stream passes, and which adsorbs the perchloroethylene on the carbon. Carbon adsorption (sniffer) systems can handle high air flows with low solvent concentrations and reduce solvent vapors in exhaust by 95 percent. Carbon beds range in size from 100 to 1,000 pounds (45 to 455 kilograms) of activated carbon.

    Cartridge filter: A separate filter unit containing both filter paper and activated carbon that traps and removes contaminants from perc or petroleum solvent, together with the piping and ductwork used in the installation of this device (part of the carbon adsorber).

    Colorimetric tube: A glass tube (sealed before use) containing material impregnated with a chemical that is sensitive to perchloroethylene and designed to measure the concentration of perchloroethylene in the air.

    Distill: The process of heating a mixture to separate the perchloroethylene from water and waste organic matter.

    Dryer: A machine used to remove perc or petroleum solvent from articles of clothing or other textile or leather goods, after washing and removing excess petroleum solvent, together with the piping and ductwork used in the installation of this device.

    Existing source: A source that uses machines installed before December 9, 1991.

    PCE: An abbreviation for perchloroethylene.

    Perc: PCE.

    Perceptible leak: Any perc or petroleum solvent vapor or liquid leak that is conspicuous from visual observation or that bubbles after application of a soap solution, such as pools or droplets of liquid, open containers of solvent, or solvent-laden waste standing open to the atmosphere.

    Petroleum dry cleaner: A dry cleaning facility that uses petroleum solvent in a combination of washers, dryers, filters, stills, and settling tanks.

    Reconstructed: When any component of the dry cleaning system is replaced, and the fixed capital cost of the new component exceeds 50 percent of the fixed capital cost that would be required to construct a new comparable source.

    Refrigerated condenser: A vapor recovery system to which an air-perchloroethylene gas-vapor stream is routed and the perchloroethylene is condensed by cooling the gas-vapor stream. Refrigerated condensers recover solvent emissions by chilling the air stream below the dew point, causing the solvent and water vapor to condense.

    Separator: A device that boils (or evaporates) the water that has been condensed and separates it from the air-perc vapor exhaust stream.

    Settling tank: A container that uses gravity to separate oils, grease, and dirt from petroleum solvent, together with the piping and ductwork used in the installation of this device.

    Solvent filter: A discrete solvent filter unit containing a porous medium that traps and removes contaminants from petroleum solvent, together with the piping and ductwork used in the installation of this device.

    Solvent recovery dryer: A class of dry cleaning dryers that employ a condenser to condense and recover solvent vapors evaporated in a closed-loop stream of heated air, together with the piping and ductwork used in the installation of this device.

    Still: A device used to volatilize, separate, and recover petroleum solvent from contaminated solvent, together with the piping and ductwork used in the installation of this device.

    Tetrachloroethylene: Another name for perchloroethylene (perc).

    Transfer system: Any system in which washing and drying are performed in different machines. This may be a washer and dryer, washer and reclaimer, or dry-to-dry machine and reclaimer. Dry-to-dry machines are considered to be a transfer system if clothes are transferred to different machines.

    Washer: A machine that agitates fabric articles in a perc or petroleum solvent bath and spins the articles to remove the solvent, together with the piping and ductwork used in the installation of this device.

     

    TABLE 4.

    Weights and Measures
    Metric System U.S. Customary System
    Linear Measure
    10 millimeters = 1 centimeter
    10 centimeters = 1 decimeter
    10 decimeters = 1 meter
    10 meters = 1 dekameter
    10 dekameters = 1 hectometer
    10 hectometers = 1 kilometer

    Area Measure
    100 sq. millimeters = 1 sq. centimeter
    10,000 sq. centimeters = 1 sq. meter
    1,000,000 sq. millimeters = 1 sq. meter
    100 sq. meters = 1 are (a)
    100 ares = 1 hectare (ha)
    100 hectares = 1 sq. kilometer
    1,000,000 sq. meters = 1 sq. kilometer

    Volume Measure
    1 liter = 0.001 cubic meter
    10 milliliters = 1 centiliter
    10 deciliters = 1 liter
    10 liters = 1 dekaliter
    10 dekaliters = 1 hectoliter
    10 hectoliters = 1 kiloliter

    Weight
    10 milligrams = 1 centigram
    10 centigrams = 1 decigram
    10 decigrams = 1 gram
    10 grams = 1 dekagram
    10 dekagrams = 1 hectogram
    10 hectograms = 1 kilogram
    1,000 kilograms = 1 metric ton

    		 Linear Measure
    12 inches = 1 foot
    3 feet = 1 yard
    5 1/2 yards = 1 rod
    40 rods = 1 furlong
    8 furlongs = 1 mile
    3 land miles = 1 league

    Area Measure
    144 sq. inches = 1 sq. foot
    9 sq. feet = 1 sq. yard
    30 1/4 sq. yards = 1 sq. rod
    160 square rods = 1 acre
    640 acres = 1 sq. mile
    1 sq. mile = 1 section
    6 sections = 1 township

    Liquid Measure
    4 gills (2 cups) = 1 pint
    2 pints = 1 quart
    4 quarts = 1 gallon

    Dry Measure
    2 pints = 1 quart
    8 quarts = 1 peck
    4 pecks = 1 bushel

    Weight
    27 11/32 grains = 1 dram
    16 drams = 1 ounce
    16 ounces = 1 pound
    100 pounds = 1 hundredweight
    20 hundredweight = 1 ton

     

    TABLE 5.

    Metric/Customary Conversion

    Temperature
    Conversion Table
    To Convert Into Multiply By To Convert Into Multiply By
    Centimeters Inches
    Feet
    Meters
    Millimeters    		 .394
    .0328
    .01
    10
    Feet Centimeters
    Inches
    Meters
    Miles
    Yards    		 30.48
    12.00
    .3048
    .0001894
    .6777
    Gallons Pints
    Liters
    Quarts    		8.0
    3.785
    4.0
    Grams Ounces
    Pounds
    Kilograms    		 .035
    .002
    .001
    Inches Centimeters
    Feet
    Meters
    Yards    		 2.54
    .0833
    .0254
    .0278
    Kilograms Grams
    Ounces
    Pounds    		 1,000
    35.274
    2.205
    Kilometers Feet
    Meters
    Miles
    Yards    		 3281
    1000
    .621
    9144
    Liters Cups
    Pints
    Gallons
    Milliliters
    Quarts    		 4.226
    2.113
    .264
    1000
    1.057
    Meters Centimeters
    Feet
    Inches
    Kilometers
    Miles
    Millimeters
    Yards    		 100
    3.281
    39.37
    .001
    .0006214
    1000
    1.093
    Miles Feet
    Yards
    Kilometers    		 5,280
    1,760
    1.609
    Ounces Grams
    Pounds
    Kilograms    		 28.35
    .0625
    .028
    Pints Liters
    Quarts
    Gallons    		 .473
    .50
    .0125
    Pounds Grams
    Ounces
    Kilograms    		 453.59
    16.0
    .454
    Quarts Pints
    Liters
    Gallons    		 2.0
    .946
    .25
    Yards Inches
    Feet
    Meters
    Miles    		 36.00
    3.00
    .914
    .0005682
    © 1989 Franklin International Institute, Inc.

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