Is your company a dry cleaning business, or does your company have dry cleaning machines on site?
Dry cleaning shops generate hazardous wastes, air emissions and wastewater and must comply with both federal and state regulations. Please note the regulations vary and depend on whether your machines use perchloroethylene (PERC) or non-chlorinated, hydrocarbon-based petroleum solvents.
For a comprehensive summary of requirements, see our Environmental Compliance Guide for Ohio Dry Cleaners.
The tabs present additional information and resources to assist in complying with regulatory requirements. For additional assistance, call the OCAPP Hotline at (800) 329-7518 - Weekdays, 8 a.m. - 5 p.m.
In Ohio, all dry cleaners using PERC are required to obtain air pollution permits for their dry cleaning machines. If your machines use petroleum solvents instead of PERC, you still need air pollution permits for your shop. If you use silicon-based products or a wet cleaning process, contact your district Ohio EPA office for more information.
A Permit-to-Install and Operate (PTIO) is needed before installing a machine. The permit application forms are available through the links below.
All PERC dry cleaning machines need an air pollution Permit-to-Install and Operate (PTIO). A general permit is available. The required forms are 3150a-Permit to Install and Operate Application and #3846 Emissions Activity Category Form: Dry Cleaning Facility.
Please read the qualifying criteria checklist and general permit application instructions carefully before completing the forms.
Air permit applications are processed through your Ohio EPA District Office or your Local Air Agency. If the Ohio EPA inspects your facility, the air inspector will focus on your compliance with the permit requirements. It is very important you have the permit-required records available for the inspector.
The air pollution permit requires you to track PERC purchases and to maintain your machines to prevent PERC leaks.
These forms can be sent with permit forms or separately.
NESHAP Notification of Compliance Status Form (Ohio version)
Ohio form required by 2006 amendments to Subpart M. Due by July 28, 2008 (existing facilities), and upon installation of new facilities. (English Only)
Consolidated Report (all)
Reports required by the original NESHAP Subpart M rule, including Initial Notification, Compliance Report for Control Requirements and Compliance Report for Pollution Prevention.
For machines using perchloroethylene
This rule applies nationwide to all dry cleaning machines that use perc. It defines requirements for new machines as well as operating and monitoring records that all operators must keep. (Annotated MS Word version)
Explains requirements of the federal NESHAP rule.
Ohio's regulations for perchloroethylene dry cleaners. See pages 61-63 of .pdf file. These are additional requirements to the federal NESHAP, Subpart M standards.
|Dry Cleaning Facilities: National Perchloroethylene Air Emission Standards (40 CFR 63, Subpart M)||Federal rule requires that dry cleaning facilities co-located with residential properties must phase out the use of perchloroethylene by Dec. 21, 2020|
For machines using petroleum hydrocarbon solvents:
These federal rules apply nationwide to all petroleum solvent dry cleaners having a total washer capacity of 84 pounds or more.
Ohio's regulations for petroleum dry cleaners. See pages 63-66 of .pdf file.
Compliance Test Methods and Procedures
Test Methods: Paragraph (J) - Perc Content of Filter Waste
Paragraph (L) - Emissions From Dryer (petroleum solvent)
Paragraph (M) - Petroleum Content of Filter Waste
Paragraph (N) - Time of Dryer Recovery Cycle (petroleum solvent)
This popular calendar helps businesses track all monthly perc receipts, machine maintenance, and solvent usage to comply with EPA air permits and regulations. Click on the left for the PDF version or call OCAPP at 1-800-329-7518 for a hard copy.
A list of leak detection instruments. Facilities using perc must check their machines monthly for leaks using a leak detection instrument. (For reference only, Ohio EPA does not endorse or guarantee the performance of equipment on the list).
Guidance on how to complete Non-Title V Air Emissions Reports (sent every 2 years to air permit holders).
Compliance Resource Page for NESHAP Subpart M Compliance
Link to resources from the network of state small business assistance programs. Contains links to compliance information from U.S. EPA and state contact info.
(This link is temporarily not working.)
This NIOSH guide explains the evolution of dry cleaning machine design and the features of newly required 4th generation machines.
Wastewater discharges from dry cleaning operations are regulated under Ohio's water pollution control laws. Requirements depend upon the manner in which you are, or will be, discharging your wastewater.
Discharging to a Local Wastewater Treatment Plant
If you want to discharge to your local wastewater treatment plant, also called a publicly owned treatment work (POTW), contact them directly to check on local requirements and on whether you need a discharge permit from them. Because POTWs are not generally designed to treat wastewater containing chemicals and other contaminants from dry cleaning processes, you may be required to treat the wastewater before discharging to them.
Note: Even if you have a small volume of wastewater or contaminants, you still need written permission from the POTW to discharge to them. You must provide them with information on your wastewaters, 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 wastewaters. Be aware that many POTWs will not accept waste water that contains PERC.
Discharging Directly to Waters of the State
A facility that wants to discharge wastewater directly to any waters of the state, needs a National Pollutant Discharge Elimination System (NPDES) permit from Ohio EPAs Division of Surface Water. Examples of waters of the state include streams, rivers and lakes. Discharges that enter a conveyance system (like a ditch or storm sewer) that leads to a waterway may also require a NPDES permit.
The NPDES permit helps to maintain the quality of surface waters by controlling the quantity and types of pollutants that can be discharged. The permit typically contains discharge (effluent) limitations, as well as monitoring and reporting requirements. In addition, you may be required to treat wastewater to remove contaminants and meet effluent limitations before the wastewater is discharged. If you need to construct a wastewater treatment system, this requires a separate Permit-to-Install (PTI) from Ohio EPAs Division of Surface Water.
Because of the types of contaminants generated by dry cleaning operation and the cost of wastewater treatment equipment, this is not generally the recommended permitting option for wastewater discharges.
Discharging to an On-site Sewage Treatment System (Septic Tank)
If your shop is located in an area that does not have access to sewers and you need to construct an on-site sewage treatment system (for example, a septic tank), or if you have an on-site system now, it is very important that you're aware of Ohio's on-site system regulations.
Only sanitary waste and wastewater (from bathrooms and hand washing sinks) can go to an on-site sewage treatment or disposal system. Process wastewater containing chemicals, oils or other contaminants cannot go into an on-site system.
Separator water and water from washing machines are examples of process wastewaters. You must find another way to manage your process wastewater, such as installing a separate holding tank. A holding tank requires a Permit-to-Install (PTI) from Ohio EPAs Division of Surface Water. If you have chemicals in your wastewater, your tank may also be regulated as a hazardous waste tank by Ohio EPAs Division of Materials and Waste Management. You'll need to contact a hauler to empty your holding tank. The wastewater must be evaluated and delivered to a commercial wastewater treatment facility or, if hazardous waste, a hazardous waste disposal facility.
Bottom Line: Consider locating in an area with access to city water and sewer. This makes wastewater management much easier and probably not as costly.
If you discharge process wastewater to an on-site sewage treatment system, contact Ohio EPA for further information on how to address this discharge issue.
Any business generating wastes must evaluate them to determine if they are hazardous wastes under Ohio EPA's regulations. There are specific regulations on how hazardous waste needs to be handled at your shop. There are also record-keeping requirements. All hazardous wastes must be sent off site to a permitted hazardous waste disposal facility.
Common hazardous wastes generated by dry cleaners include:
- Spent solvents
- Spent carbon and cartridges from adsorbers
- Still residues (sludge)
- Filter powder (muck)
- Filters and filter media
- Discarded chemicals
- Most separator water
These are considered hazardous wastes mainly because they come in contact with the solvents used in dry cleaning, primarily perchloroethylene (also known as PERC or tetrachloroethylene) and petroleum solvents (for example, Stoddard solvent).
See the Environmental Compliance Guide for Ohio Dry Cleaners for more detailed information on waste disposal requirements.
The best way to reduce pollution is to prevent it in the first place. Pollution prevention (P2) can range from low-cost improvements to changes in equipment and operating practices. Below are some examples of the many P2 options for dry cleaners.
Improve Operating Practices
- Size garment loads correctly. Do not overload or underload.
- Use recommended amounts of detergents and sizing to ensure good cleaning performance and minimize re-cleans.
- Minimize the time machine doors and button traps are open to reduce solvent losses.
- Clean lint screens regularly to avoid clogging of fans and condensers.
- Use spigots and pumps when dispensing new materials and funnels when transferring wastes to storage containers to reduce possibilities of spills.
- Provide secondary containment in areas where solvents are stored.
- Keep storage and work areas clean and well organized, and keep all containers properly labeled.
- Use water-based or less hazardous pre-spotters instead of those containing solvents.
- Use petroleum solvents that have higher flash points and lower volatile organic compound (VOC) content.
- Use solvents and techniques that have been developed as alternatives to PERC, including silicon-based products, glycol ether products and liquid carbon dioxide.
- When upgrading, buy energy efficient equipment and appliances.
- Switch to carbon adsorbers that use a polymer surface for adsorbing solvent vapor. These adsorbers can be regenerated.
- Consider wet cleaning. (See discussion on wet cleaning)
- Consider technologies such as ultrasonic or carbon dioxide cleaning.
While the air regulations require you to conduct some pollution prevention (P2), you may find that additional P2 activities also make sense for you. P2 strategies can improve your business performance, reduce operating costs and enhance your company's image. In addition, you can reduce your regulatory burden by reducing waste. For example, a dry cleaner classified as a hazardous waste SQG may be able to reduce wastes generated to get down to a VSQG category. Finally, P2 provides environmental, health and safety benefits and can reduce your potential for liability related to noncompliance or violations.
The most advanced pollution prevention options involve alternatives to PERC and other organic dry cleaning solvents. Wet cleaning is a good example of a PERC alternative.
Wet cleaning begins with inspecting garments for fabric type, construction, dirt and stains. A garment may be spot-cleaned, steamed and then washed in a washing machine that carefully regulates water temperature and agitation. Drying is done in drying cabinets, computer-controlled dryers or similar units. Garments are then pressed and finished with traditional techniques.
During the 1990s, the Center for Neighborhood Technology (CNT) worked with the dry cleaning industry on alternative cleaning processes, including a study of wet-cleaning operations at three dry cleaners. Their research revealed:
- Most garments that now are dry cleaned can be safely wet cleaned.
- A strong customer demand exists for alternative garment cleaning methods.
- Changes in color are not a significant problem in wet cleaning.
- Only a small percentage of garments were difficult to clean well in a cost-effective manner.
- The wet cleaning process is not a significant concern to wastewater treatment officials.
- Wet cleaning is safer than traditional dry cleaning for employees, for customers and for communities.
- Wet cleaning is viable in both mixed use and 100 percent settings.
- A total of 25-30 percent of garments in any shop do not have a Dry Clean Only label and should be wet cleaned if possible.
- The most effective way to increase the percentage of wet cleaning is to learn how to process wools and silks that have Dry Clean Only labels.
- The attitudes of the owner and staff are critical to successful wet cleaning.
- Training and education help shops do more wet cleaning.
- The financial profile of a wet cleaner is essentially the same as the profile of a dry cleaner.
More information about wet cleaning can be found on CNT's Making Dry Cleaning Safer webpage.
Visit our Customer Support Center for frequently asked questions, training and publications related to dry cleaning.
If you need help financing equipment that reduces air pollution, such as buying more efficient dry cleaning machines, contact the Ohio Air Quality Development Authority's Clean Air Resource Center: (800) 225-5051 or (614) 224-3383, www.ohioairquality.org
The Clean Air Resource Center (CARC) is an independent, non-regulatory state agency. CARC is not part of the Ohio EPA. CARC does not enforce air quality regulations. Instead, CARC helps businesses meet EPA air regulations while also reducing costs and gaining tax exemptions.
CARC provides loans to help businesses finance air pollution control or prevention projects, for example, new dry cleaning machines with cleaner emissions. In addition to loans, they also provide small business grants to cover the closing costs of financing pollution control projects.
For additional assistance, call the OCAPP Hotline at (800) 329-7518 - Weekdays, 8 a.m. - 5 p.m.