Hazardous Waste Program

							      DRYCLEANER
ENVIRONMENTAL WORKSHOP


                    SPONSORED BY
    FLORIDA DEPARTMENT OF ENVIRONMENTAL PROTECTION

                                                  JIM DREGNE
                                               SEPTEMBER 30, 2010
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    WASTE RULES

   40 CFR (Code of Federal Regulations)
 Chapter   376, F.S. (Florida Statutes)
 Guidance   Letter dated April 12, 2006,
    Subject: Management of Drycleaning
    Separator Water.
 WASTE DETERMINATION

DO I GENERATE A WASTE ?
    Abandoned - dumped
    Burned
       NOT considered recycling except for fuels

    Stored in lieu of disposal
    Inherently Waste Like
         filters   sludge
          lint     separator water
  SOLID or HAZARDOUS WASTE?

 Listedin 40 CFR 261 Subpart D
 Characteristically Hazardous Spent
  Materials
     Ignitable - flash point140o F
     Corrosive - pH  2 or 12.5
     Reactive
     Toxic - by TCLP test
HOW DO I KNOW?


GENERATORS KNOWLEDGE

MATERIAL SAFETY DATA SHEET


ANALYTICAL TESTING
  WHO WE INSPECT!

 Generators
     Site Specific

 Transporters



 Treatment,    Storage or Disposal Facilities
  (TSDFs)
 GENERATORS


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
 hazardous waste.
 Maynot store 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
MANIFEST
  CESQG vs SQG vs BMP

 CESQG   RULES

 SQG   RULES

 BEST   MANAGEMENT PRACTICES
  CONTAINER MANAGEMENT

 CLOSED

 LABELED

 GOOD   CONDITION
 APPROPRIATE   CONTAINER
 IN   SECONDARY CONTAINMENT
OPEN CONTAINER
CLOSED CONTAINERS
LABELLING
  SECONDARY CONTAINMENT

 Section 376.3078(7)(a)(b)requires
  secondary containment of dry cleaning
  solvents.
 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
SECONDARY CONTAINMENT
SECONDARY CONTAINMENT
       SECONDARY CONTAINMENT -
           SPOTTING BOARDS


Equipment with tank capacity of one quart or less.
           Secondary containment
           Seal floor surface
                at least 2 feet around
  FLOOR SEALANTS

 Solvent  Resistant Sealer.
 Department does not recommend any
  particular brand.
 Resistant to all solvents for 72 hours.
 Maintain Floor and Sealant.
 Sealant specifications and date of
  application must be maintained.
SPOTTING BOARD
  EMERGENCY PLANNING

 Emergency     Information Posted Next
  Telephone.
 Fire   Extinguisher.
 Spill   Material
 Notify   Emergency Authorities
 Train   Employees
  SEPARATOR WATER

          at concentration of 150 ppm
 Generally
 How to Manage
     Manifest Offsite
     Evaporate Onsite
             less than .7ppm
     Discharge to the Sewer
             less than .53ppm

 Prohibition on Discharging to the Ground
  or Septic Tank
SEPARATOR WATER
SEPARATOR WATER
SEPARATOR WATER
                SEPARATOR WATER
                   TREATMENT
 KEY       POINTS TO REMEMBER
          Have documentation to support effectiveness of
           system
          Following instructions on servicing
          Dispose of waste filters or absorption media as
           hazardous.

 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
    recycling……..
  – Accumulation start date*
 Containers must be kept closed
 Do not intentionally break lamps and
  take precautions to prevent breakage
 Ensure employees handling lamps are
  trained
 Keep records of shipments 3 years
  SPILL RESPONSE

 Spillone quart of drycleaning solvent
  outside secondary containment.
 Cleanup   the spill.

 Notify   State Warning Point at:
     (850) 413-9911
 DON’T FORGET



   GOOD
HOUSKEEPING
FDEP HW CONTACT

   Jim Dregne
       13051 North Telecom Parkway
       Temple Terrace, Florida 33637
       813/632-7600 ext. 410
   James.dregne@dep.state.fl.us
   Web Site: www.dep.state.fl.us
Any Questions?




THANK YOU