Many states and local jurisdictions may require registration or permits for dry cleaners and some assess special environmental fees for dry cleaner cleanup funds. In many states, dry cleaners must replace old equipment with new dry cleaning machines that significantly reduce air emissions and wastewater. In addition, some states are moving to phase out the use of Perc.
Most states offer environmental assistance, tools, and/or response funds for dry cleaners. For example, the Minnesota Pollution Control Agency's Small Business Environmental Assistance Program publishes an annual compliance calendar for dry cleaners that summarizes the regulations and can be used for required record keeping.
Understanding the chemicals used in your dry cleaning process is crucial to managing wastes appropriately. Some common dry cleaning solvents, most notably Perc, are considered hazardous waste when spent, and are subject to federal and state hazardous waste regulations. Regulations include requirements for making a hazardous waste determination, labeling, tracking storage times, and using licensed hazardous waste shippers and hazardous waste manifests. Solvent-contaminated wastewater, lint/debris, and filters may also be considered hazardous waste.
Spent solvents may be considered listed hazardous wastes as either F002 (Perc and certain other spent halogenated solvents) or F005 (certain spent non-halogenated solvents). Mixtures of such listed hazardous wastes and other solid wastes must also be managed as hazardous waste. Dry cleaning wastes may be characteristic hazardous wastes based on ignitability (D001) or toxicity (D039 for perchloroethylene). (For more details, see the EPA Hazardous Waste page or the CRC Hazardous Waste page.)
The improper storage of hazardous waste is one of the key areas regulators review at dry cleaners. All waste that is determined to be hazardous must be kept in a labeled, closed, compatible container with adequate access and aisle space. If the waste container is directly attached to the machine, then it may need to be sealed and labeled. A form of secondary containment is recommended and may be required depending in part on surroundings such as a nearby floor drain.
The EPA has guidance for dry cleaners: RCRA in Focus - Dry Cleaners, a Perc webpage, and a Plain English Guide for the Dry Cleaners. State regulations and guidance should also be consulted.
The Clean Air Act regulates air emissions of hazardous air pollutants (such as Perc) and volatile organic compounds from dry cleaners. Most local and state environmental agencies also regulate dry cleaners, and many require operating permits. The amount of solvents used annually, and the location and size of the facility are also factors in determining air emissions requirements. Federal and state regulations generally require operators to ensure that leak detection equipment is operational, to repair any leaks immediately, and to maintain service records on all Perc-containing equipment. Distilling used solvent to recover clean solvent can generate volatile emissions and may be regulated. (The CRC Air page has more detail on air regulations.)
Wastewater discharges from dry cleaning facilities are restricted under the Clean Water Act, and discharges containing some types of solvents, such as Perc, are hazardous wastes. The dry cleaning operator needs to understand the types of solvent used and the regulations in their state and local jurisdiction.
In some places, dry cleaners can discharge wastewater down the drain to the local sewage treatment plant (also called the Publicly Owned Treatment Works or POTW), although discharges of hazardous wastes may not be allowed. Every wastewater utility has different rules and discharge limits, depending on what the POTW can handle. State and local wastewater regulations typically require dry cleaners to obtain wastewater permits or register with the local wastewater treatment facility. Typically you must provide the treatment plant with information on your wastewater, including the amount (gallons per day) of each of your various wastewaters and the concentration of pollutants (such as Perc) expected to be present in your wastewater.
If the POTW does not accept solvent-contaminated wastewater, you must properly manage the wastewater in containers or tanks in accordance with applicable waste regulations and send the wastes off-site to an authorized treatment, storage, or disposal facility.
Some state regulatory agencies provide guidance for dry cleaners, such as this Oregon wastewater management fact sheet or this New Jersey Dry Cleaner Checklist. Specific requirements may also exist at the local level - State Coalition for Remediation of Drycleaners.
Emergency Planning and Community Right-to-Know Act (EPCRA) regulations establish reporting obligations for facilities that use or store certain chemicals. Dry cleaning solvents, such as Perc, are generally not considered "extremely hazardous substances" under federal EPCRA regulations. However, a release of Perc into the environment in an amount exceeding 100 pounds within a 24-hour period would require emergency response notification under federal rules. State and local jurisdictions may have broader or more stringent reporting or emergency response notification requirements.
Past use of dry cleaning solvents has led to environmental contamination, affecting soil and groundwater in some areas, including from perc-containing wastewater leaking through sewer pipes. Under the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA or Superfund), persons responsible for such contamination may be held responsible for clean-up. In addition, CERCLA requires reporting to the National Response Center of any release of a hazardous substance that exceeds a reportable quantity within a 24-hour period.
There are alternative dry cleaning technologies that reduce the environmental compliance and health risks associated with traditional dry cleaning solvents. These include liquid carbon dioxide (CO2), Hydrocarbon, silicon-based solvent, and wet cleaning. Switching to these methods can reduce the environmental impact of your business and reduce the cost of hazardous waste disposal. However, it is important to evaluate and understand environmental issues associated with alternatives.
There are other ways a dry cleaner can reduce its environmental impact. The Green Cleaners Council lists the areas they evaluate under their green cleaner rating system; these areas include waste reduction and recycling, energy use, solvents and hazardous waste, education, and water conservation. Many cleaners recycle hangers and the Drycleaning & Laundry Institute International has a hanger recycling program to encourage customers to recycle hangers. Reducing the use of plastic bags and plastic bag recycling are also encouraged.