FLORIDA DEPARTMENT OF ENVIRONMENTAL PROTECTION
SEPTEMBER 30, 2010
40 CFR (Code of Federal Regulations)
Chapter 376, F.S. (Florida Statutes)
Guidance Letter dated April 12, 2006,
Subject: Management of Drycleaning
DO I GENERATE A WASTE ?
Abandoned - dumped
NOT considered recycling except for fuels
Stored in lieu of disposal
Inherently Waste Like
lint separator water
SOLID or HAZARDOUS WASTE?
Listed in40 CFR 261 Subpart D
Characteristically Hazardous Spent
Ignitable - flash point140o F
Corrosive - pH 2 or 12.5
Toxic - by TCLP test
HOW DO I KNOW?
MATERIAL SAFETY DATA SHEET
WHO WE INSPECT!
Treatment, Storage or Disposal Facilities
3 Categories based on rate of generation
Minimum Requirements - CESQGs
Identify all hazardous wastes generated
Dispose of them properly
Increasing regulation based on the amount
of waste generated per calendar month
SMALL QUANTITY GENERATORS
Generatebetween 100 (220 pounds) and
1000 (2200 pounds) in a calendar month.
May not generate more than one kilogram
(2.2 pounds in one month) of acute
May notstore more than 1000 kilograms
(2200 pounds) of hazardous waste on site.
CALCULATE YOUR STATUS
ONE MONTHS GENERATION
6 Filters = 6 x 13 lbs. = 78 lbs.
3 gal. Condensate per week = 3 gal
x 7 lbs. x 4 weeks = 84 lbs.
5 gal. Sludge = 5 x 13 = 65 lbs.
TOTAL = 227 lbs
CHECK YOUR MANIFEST
Your manifest gives you your weights.
Filters = 60 pounds per drum
Sludge = 195 pounds per drum
CESQG vs SQG vs BMP
BEST MANAGEMENT PRACTICES
IN SECONDARY CONTAINMENT
secondary containment of dry cleaning
January 1, 1997*
Secondary containment around all solvent
or waste solvent storage areas.
All machines and equipment with capacity
of one quart or more.
SECONDARY CONTAINMENT -
Equipment with tank capacity of one quart or less.
Seal floor surface
at least 2 feet around
Solvent Resistant Sealer.
Department does not recommend any
Resistant to all solvents for 72 hours.
Maintain Floor and Sealant.
Sealant specifications and date of
application must be maintained.
Emergency Information Posted Next
Notify Emergency Authorities
at concentration of 150 ppm
How to Manage
less than .7ppm
Discharge to the Sewer
less than .53ppm
Prohibition on Discharging to the Ground
or Septic Tank
KEY POINTS TO REMEMBER
Have documentation to support effectiveness of
Following instructions on servicing
Dispose of waste filters or absorption media as
IF YOU DESIGN YOUR OWN SYSTEM
Have analytical results showing that it works.
MERCURY CONTAING BULBS
Label each container
– Spent Mercury containing lamps (or devices) for
– Accumulation start date*
Containers must be kept closed
Do not intentionally break lamps and
take precautions to prevent breakage
Ensure employees handling lamps are
Keep records of shipments 3 years
Spill one quart of drycleaning solvent
outside secondary containment.
Cleanup the spill.
Notify State Warning Point at:
FDEP HW CONTACT
13051 North Telecom Parkway
Temple Terrace, Florida 33637
813/632-7600 ext. 410
Web Site: www.dep.state.fl.us