![]() POLLUTION PREVENTION AND BEST MANAGEMENT
PRACTICES
|
SOURCE OF EMISSIONS |
TRANSFER UNITS |
DRY-TO-DRY (vented) |
DRY-TO-DRY (non-vented) |
Machine vent |
4.0 |
3.1 |
0 |
Clothing transfer |
2.5 |
0 |
0 |
Equipment leaks |
2.5 |
2.5 |
2.5 |
Losses in waste |
3.2 |
3.2 |
3.2 |
TOTAL | 12.2 | 8.8 | 5.7 |
A variety of hazardous wastes are generated by the dry cleaning industry, such as waste solvents, used filters and filter cartridges, still bottoms, muck, contaminated condensate water and absorbents, and solvent containers.
The typical wastes, their hazardous properties, and EPA waste code include:
The EPA waste code for all of the above would be either F002 or D001, depending on the solvent contamination.
NOTE: There is a big concern about wastewater (i.e. "Down the drain") contaminated with perc and its potential for groundwater contamination. South Florida is particularly sensitive in that all drinking water comes from the ground. Through complex chemical and biological processes, perc degradation has the following sequence of decay: Tetrachloroethylene Trichloroethylene Cis 1,2 Dichloroethylene/Trans 1,2 Dichloroethylene 1,1 Dichloroethylene Vinyl Chloride. Vinyl Chloride has a potential long-term carcinogenic effects in water, which could affect living organisms, including humans, through ingestion.
The P2-BMP for Dry Cleaners has been developed to achieve the following OBJECTIVES:
A. FACILITATE COMPLIANCE with all federal, state, and local environmental regulations governing the use, storage, generation, and disposal of hazardous materials and hazardous wastes, and air emissions within the dry cleaning industry.
B. ASSIST DISTRIBUTION OF THE FLORIDA SBAP Complete Multi-Media Environmental Compliance Assistance Guide for Dry Cleaning Industry to facilities located in BROWARD County.
C. ASSIST DRY CLEANERS in their mission to be good neighbors in implementation of pertinent pollution prevention techniques and waste minimization options.
D. PROVIDE INFORMATION on substitute solvents, alternative dry cleaning technologies, and research initiatives nation-wide.
The following STRATEGIES have been established:
1. DEVELOP P2-BMP FOR DRY CLEANERS OPERATING IN BROWARD COUNTY, a dual document which includes the local environmental requirements and Florida SBAP guide, in order to eliminate confusion for dry cleaning facilities in BROWARD County concerning the regulatory requirements.
2. ENSURE DISTRIBUTION OF P2-BMP TO EACH FACILITY. This document can be used by each dry cleaner as a self-audit manual, to ensure compliance and implementation of pollution prevention techniques.
3. ORGANIZE WORKSHOPS AND PROVIDE TRAINING to dry cleaner owners/operators. At these workshops the entire document will be reviewed and all the questions will be answered. A TRAINING CERTIFICATE OF COMPLETION will be presented to the participants of workshops.
4. PROVIDE TECHNICAL ASSISTANCE thru confidential, non-regulatory on-site visits, upon request. The dry cleaner owner/operator should contact the pollution prevention section staff at 519-1257 or 519-1421 for this kind of technical assistance.
Florida's Small Business Assistance Program (SBAP) has already published the Complete Multi- Media Environmental Compliance Assistance Guide for Dry Cleaning Industry. This guide was developed based on Federal and State of Florida requirements and also includes pollution prevention opportunities and a waste reduction program. The DNRP has considered it necessary to add to this document the local environmental requirements applicable to all dry cleaning facilities operating in Broward County. This dual document is intended to eliminate confusion for dry cleaning facilities in Broward County concerning the regulatory requirements.
The Broward County Code of Ordinances (BCCO) Chapter 27, known as "Broward County Natural Resource Protection Code", regulates the activities, facilities and items which pose a threat to the public health, safety and welfare of the citizens of Broward County and endanger the environment and natural resources. The Department of Natural Resource Protection (DNRP) is responsible for the protection, restoration and enhancement of Broward County's natural resources and environmental quality of life. This mission is accomplished through programs which are governed by the provisions of the BCCO Chapter 27 mentioned above.
In this part of P2-BMP document, we have attempted to summarize the local environmental code requirements applicable to dry cleaners. A self-audit checklist is provided to assist the facility owner/operator in evaluating the level of compliance with Broward County environmental regulations. If a non-compliant item is identified during the self-audit, instructions advising how to correct the discrepancy are provided directly below the question. This allows the owner/operator an opportunity to correct the problems, and to prevent potential fines or penalties by DNRP staff who may discover these same violations at a later date if not corrected. It is the responsibility of the owner/operator to understand what regulations affect their business, determine if the facility is in compliance and correct any discrepancies discovered.
In order to protect the air, waters, soils, and other natural resources, Broward County declares that the generation, use, storage, handling, processing, manufacturing, and disposal of hazardous material must be regulated. The unauthorized presence of hazardous material in the air, waters, soils, or other natural resources is prohibited and a responsible party shall take the necessary action to remediate and to remove such substances, in order to restore such natural resources to a condition which does not pose a threat to health, safety, or to the environment. The DNRP shall have the authority to license, evaluate, review, and administer all hazardous material activities, and all environmental assessment and remediation actions performed in Broward County (Sec. 27-351).
A hazardous material facility operating license shall be obtained by the owner/operator for any existing, new or proposed facility that generates, stores, processes, uses, handles, or manufactures hazardous material in quantities greater than specified in the definition of a hazardous material facility (Sec. 27-356(b)(1)a.). Application for license shall be submitted on DNRP forms and shall provide all information as requested therein (Sec. 27-356(b)(2)).
The owner/ operator is responsible for complying with all applicable requirements of the federal, state, and local government environmental laws and regulations.
The following issues and checklist address the local requirements provided in BCCO Chapter 27 "Broward County Natural Resource Protection Code". All dry cleaners within Broward County must comply with all applicable requirements.
A. ARTICLE XII. HAZARDOUS MATERIAL
YES / NO
Within a one month period of time do you have, generate, store,
process, use or handle twenty-five (25) gallons or more of
hazardous materials or is any extremely hazardous substance present in
excess of the threshold planning quantity?
If NO, your facility is not regulated by the Article
XII Hazardous Material. Proceed to Prohibitions.
If YES, your facility is governed by BCCO Chapter 27 Article
XII Hazardous Material, no matter what solvent is used, and is subject
to the following requirements:
YES / NO
Do you have a valid HAZARDOUS MATERIAL FACILITY LICENSE?
If NO, you must apply and obtain from DNRP a hazardous
material facility license to operate a dry cleaning facility in
Broward County. Application for license shall be submitted on DNRP
forms. All information shall be provided as requested therein.
YES / NO
Do you fully comply with the general conditions printed on the
back of Hazardous Material Facility License, which are applicable to
all licenses issued by DNRP?
If NO, take necessary measures to ensure full compliance with
each general condition.
YES / NO
Have you identified all the hazardous materials used,
processed, stored or handled at your facility and all the
hazardous wastes generated during your operation?
If NO, see typical hazardous materials used and hazardous
wastes generated by dry cleaners. The Material Safety Data Sheets
(MSDS) should be used for an accurate determination of hazardous
materials.
YES / NO
Have you complied with all federal and state hazardous
waste requirements?
Before answering, please review and complete the checklist of Hazardous
Waste of SBAP Complete Multi-Media Environmental Compliance
Assistance Guide. Take the necessary actions to correct all
discrepancies.
Please answer all the questions that apply to your facility. If the question does not apply, check N/A.
YES / NO
Are individual storage containers labeled and maintained in
accordance with all applicable federal and state standards?
If No, instruct employees on proper labeling. Please review
the labeling requirements provided by SBAP Complete Multi- Media
Environmental Compliance Assistance Guide section 4.3 Hazardous
Waste.
YES / NO / N/A
Are sump pumps used to remove rainwater from hazardous material
containment manually operated to prevent an automatic release of
hazardous material to ground?
If NO, instruct employees to manually operate sump pumps at
all times.
YES / NO / N/A
Are all monitoring wells installed, tested and maintained as
required on the license?
If NO, install any monitoring wells required in accordance
with the most current version of DNRP's "Minimum Criteria for
Monitoring Wells and Sampling" and perform testing as specified
in the license.
YES / NO
Have you developed procedures to ensure the appropriate and safe
handling and cleanup of any release of hazardous material? DNRP
may also require the owner/operator of a licensed hazardous material
facility to prepare a spill contingency plan.
If NO, establish emergency response procedures to ensure for
the safe handling and cleanup of any release of hazardous material.
You should review and comply with the requirements that apply to you
under the federal law 40 CFR 262.34(d)(4) and (5) and mentioned by
SBAP Complete Multi-Media Environmental Compliance Assistance
Guide section 4.3.3(c) Preparedness and Prevention.
YES / NO / N/A
Does storage tank configuration - with the exception of
underground storage tanks provide for complete visual inspection?
If NO, ensure that all aboveground storage tanks provide for
complete visual inspection.
YES / NO
Are all primary containments product-tight?
If NO, instruct employees to ensure compliance.
YES / NO
Do you provide secondary containment for all hazardous materials?
If NO, provide secondary containment, unless the hazardous
material is contained solely in consumer products packaged for
distribution and use by the general public or is a commercial product
used for janitorial or minor maintenance purposes.
Note:Secondary containment is an impermeable coating, membrane, surface or structure in which tanks or containers are placed. A double-walled tank is considered secondary containment.
YES / NO / N/A
For tanks or containers larger than one hundred ten (110) gallons,
does secondary containment hold one hundred ten (110) percent of
the volume of the largest tank or container?
If NO, provide the appropriate secondary containment to ensure
compliance with this requirement.
YES / NO
For tanks or containers of one hundred ten (110) gallons or less, does
the secondary containment hold twenty (20) percent of the combined
volume of all tanks or containers within the secondary containment,
but no less than the volume of the largest tank or container?
If NO, provide appropriate secondary containment to ensure
compliance with this requirement.
YES / NO
Are all secondary containment areas constructed of materials of
sufficient thickness, density, and composition so as not be
structurally weakened as a result of contact with the released
hazardous materials?
If NO, take necessary actions to ensure compliance with this
requirement.
YES / NO / N/A
Are all secondary containment areas provided with a roof to
prevent rainwater from entering the area or, as an alternative,
equipped with a lockable valve to enable the controlled release of any
accumulation of clean rainwater?
If NO, provide each secondary containment with a roof or
lockable valve.
YES / NO / N/A
Is all rainwater removed from the secondary containment area
within twenty- four (24) hours of its accumulation?
If NO, instruct employees to do so.
YES / NO / N/A
Is any and all rainwater which comes into direct contact with any
hazardous material collected and disposed of in accordance with
requirements established for hazardous waste?
If NO, establish procedures and instruct employees on proper
handling of contaminated rainwater.
YES / NO / N/A
Did you secure or permanently seal all floor drains in a hazardous
material handling, usage or storage area which lead to a drain field,
septic tank, or storm water system?
If NO, immediately secure or permanently seal these floor
drains to prevent the release of hazardous material to a drain field,
septic tank or storm water system.
YES / NO
Are all storage containers designed and constructed in accordance
with the applicable standards established by the National Fire
Protection Association, the American Society for Testing and
Materials, the EPA or with alternate DNRP approved standards?
If NO, contact the agencies mentioned above for corrective
actions.
YES / NO
Are hazardous materials properly stored and handled on-site prior
to disposal?
If NO, instruct employees to ensure for proper storage and
handling on-site of hazardous materials.
YES / NO
Are hazardous materials accessible to inspection at any time?
If NO, ensure the accessibility to inspection of hazardous
material at any time.
YES / NO / N/A
Did you remove all defective containers from service?
If NO, remove immediately from service defective containers.
Instruct employees on repairing or decontamination and disposal of in
accordance with federal, state and local regulations.
YES / NO
Do you avoid outdoor hazardous materials usage, including
disassembly of any machinery, equipment or vehicles?
If NO, discontinue outdoor hazardous materials usage, unless
drip pans, secondary containment, or other steps are taken to prevent
any release.
YES / NO
Do you avoid outdoor storage of disassembled parts?
If NO, do not store disassembled parts outside, unless empty
and in a manner which prevents contact with rainwater.
YES / NO
Are all drums containing hazardous material stored within a
secondary containment area which is protected from weather or in a
building and in accordance with all applicable fire codes?
If NO, instruct employees on proper storage of drums
containing hazardous material.
YES / NO
Are reactive or incompatible materials stored in separate
containers, in secondary containment areas, and in a manner which
eliminates the potential for commingling in the event of a release?
If NO, ensure proper storage of reactive or incompatible
materials. Please see also SBAP Complete Multi-Media Compliance
Assistance Guide section 4.3.3(b) Incompatible Wastes.
YES / NO
Do you perform all hazardous material transfer, dispensing, or
mixing activities in a manner which prevents any unauthorized release
to the environment?
If NO, develop procedures to ensure prevention of any
unauthorized release of hazardous material to the environment.
YES / NO
Do you comply with federal and state regulations regarding
industrial wastewater disposal?
Before answering, please review and complete the checklist of section
4.6 Wastewater on page 54-57 of SBAP Complete Multi-Media
Environmental Compliance Assistance Guide. Take the necessary
actions to correct all discrepancies.
YES / NO
Do you have Publicly Owned Treatment Works (POTW) permission or
approval to release hazardous materials into a sanitary sewer system?
If NO, contact your POTW and obtain the permission or approval
for your industrial wastewater (boiler/chiller/cooler blowdown,
solvent-water mixture from water separator, condensate from carbon
desorption and steam presses, etc.) discharge into sanitary sewer.
YES / NO
Do you keep hazardous waste on-site for a period of time longer
than allowed in accordance with federal and state regulations, such as
180 day accumulation and storage time limit if you are a Small
Quantity Generator or 90 day accumulation and storage time limit if
you are a Large Quantity Generator of hazardous waste?
If YES, you may be required to obtain an extension from
Florida Department of Environmental Protection (FDEP).
YES / NO
Do you use DNRP licensed waste haulers for transporting all
discarded hazardous materials, including used oils, to be disposed in
accordance with federal, state and local regulations?
If NO, contact immediately the DNRP licensed waste haulers.
Please review SBAP Complete Multi-Media Environmental Compliance
Assistance Guide section 4.3.3.(e) through 4.3.8 to ensure
compliance with federal and state regulations.
YES / NO
Do you keep on-site for five (5) years all reports and records,
including hazardous waste manifests, bills of landing, or other
equivalent manifesting for all hazardous material disposal and are
they available upon request for inspection by DNRP?
If NO, establish procedures to maintain a copy of reports and
records for five years. Please note that this local requirement is
more stringent than the federal and state provisions which require
these records to be kept for three (3) years only. Please review SBAP
Complete Multi-Media Environmental Compliance Assistance Guide
section 4.3.3.(d).
YES / NO
Are Material Safety Data Sheets (MSDS) maintained on-site for each
listed toxic substance?
If NO, ask your suppliers to send to you the up-dated MSDS for
all chemicals used or stored at your facility and develop and maintain
a file with these MSDS. Please review SBAP Complete Multi-Media
Environmental Compliance Guide section 4.12.1 Florida
Right-to-Know Law .
B. OTHER DNRP LICENSES THAT MAY APPLY TO DRY CLEANING FACILITIES
The owner/operator must apply to DNRP and obtain all applicable environmental licenses required by Broward County Natural Resource Code. The following check list addresses some DNRP licenses that may apply to dry cleaning facilities.
YES / NO
Do you have installed on your facility or do you intend to install
aboveground storage tanks which have individual storage tank
capacities of greater than five hundred fifty (550) gallons and/or
underground storage tanks which have individual storage tank
capacities of greater than one hundred ten (110) gallons?
If NO, no action is necessary.
If YES, provide all information requested on Application form
section 11-13.
A combined Hazardous Material and Storage Tank Facility License will
be issued by DNRP.
YES / NO
Is your facility located within wellfield zone 1 or 2? Maps
illustrating wellfield zones in Broward County may be reviewed at the
DNRP office.
If NO, no action is necessary.
If YES, provide all information requested on Hazardous
Material Facility License Application forms and a license will be
issued by DNRP. This license replaces the Hazardous Material Facility
License which is issued for facilities located in wellfield zone 3 or
outside of zones of influence.
YES / NO
Have you experienced a spill or other discharge of hazardous
material exceeding the reportable quantity threshold or have you
discovered the presence of any contaminant in the air, water or soil
at a level which exceeds any applicable federal, state or local
regulatory cleanup standards?
If NO, no action is necessary.
If YES, take the necessary measures to stabilize the
situation, immediately report such incidents by phone to DNRP at (954)
519-1499 and provide written notification to DNRP within seven (7)
calendar days. Written notification should be addressed to Division
Director, Pollution Prevention and Remediation Programs Division. A
determination of whether your facility will need an Environmental
Assessment and Remediation License will be made by DNRP following
review of all pertinent information in accordance with BCCO Sec.27-356
(e). Please also review SBAP Complete Multi-Media Environmental
Compliance Assistance Guide section 4.12.2 State Dry-cleaning
Solvent Cleanup Registration .
C. CLOSURE REQUIREMENTS
(Sec.27-356(b)(4)e. & 27-317(a)(4)
YES / NO
Do you intend to cease operations, initiate a temporary shutdown,
transfer your license, permanently remove from use or close an
underground or above ground storage tank which has a capacity of
greater than one hundred ten (110) or five hundred fifty (550) gallons
respectively?
If NO, no action is required.
If YES, notify in writing DNRP at least thirty (30) days prior
to initiating one of these activities. Failure to notify DNRP may
subject owner/operator to enforcement action. Conduct appropriate
activities to ensure for the proper removal and disposal of all
hazardous material at the facility.
The following summary of GENERAL PROHIBITIONS may apply to dry cleaning facilities (Sec.27-353):
No person shall cause, permit, suffer, or allow the usage, storage, abandonment or disposal of hazardous material:
A. In a manner which violates a provision of any federal, state, or local regulation; or
B. In a manner which causes, or may cause, an unauthorized release of hazardous material.
The following PROHIBITIONS may apply to dry cleaning facilities (BCCO Chapter 27 Art. V. WATER RESOURCE MANAGEMENT Sec. 27-193 & Sec.27-194):
NOTE: If you have a storm water management system at your facility, you are required to consult with FDEP and Broward County Water Resource Division (BCWRD) and/or your local Water Management District for permitting, operating and maintenance requirements.
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