Dry Cleaning Machine Disposal and Other Regulatory Issues
MACHINE DISPOSAL: Facility owners are required to notify the DEC Regional Air Pollution Control Engineer by Certified mail Return Receipt requested, that an existing Perc dry-cleaning machine has been taken out of service. This should be done within 30 days of taking the unit out of service by letter or on a form available from DEC. The letter notice should list Facility name, Address, DEC ID number, machine Make, Model, Serial Number and date unit taken out of service.
After installing a new dry-cleaning machine the Facility owner must file a new set of NYS Registration/Permit and NESHAPS notification forms to the local DEC Regional Office. Forms are available from the DEC Regional offices, DEC in Albany at 518-402-8403 or from the NYS SBEO at 1-800-782-8369. Most facilities should file 3 forms: NYS Registration Application, form 232-10 Perc Dry Cleaner Information Form, and a new NESHAPS Initial Notification/Compliance Report. Follow instructions on the forms.
VAPOR BARRIER COMPLETION: The 232.6(a) Vapor Barrier/Room Enclosure requires that all 6 "sides" of the room enclosure be made impervious to Perc.
At the time the Vapor Barrier requirement became effective in the late 1990's the Department noted that - for existing Perc D-C shops only , i.e., those that were in operation on or before 5/15/97 - did not have to LIFT the exiting D-C machine to get the floor sealed under it when initially installing the vapor barrier/room enclosure. The Department noted then that if the machine was ever lifted for any purpose (repair, removal, or replacement) the floor under the old machine must be totally sealed before the machine is set back down or a new machine is installed. The DEC approved Epoxy Novolac resin systems are very handy for this purpose, but sheet metal or sheet vinyl may also be used. If you need information on these materials contact DEC, in Albany at 518-402-8403 and ask for the Vapor Barrier Alternative Material Advisory memos.
Proper Disposal of Used Perc Dry-cleaning Equipment
As many New York dry-cleaners are already aware, there are many regulations and requirements which Perc dry-cleaners must abide by. In the past most of the regulatory requirements have been associated with New York State's Part 232. You should however be aware that the disposal of dry cleaning machines comes under the Hazardous Waste Regulation - Part 236. Part 236 requires dry cleaners to carefully consider how they will dispose of their used Perc machines.
Basically there are three different options for dealing with used Perc Dry-cleaning machines which are being taken out of service. Each option has its own requirements.
OPTION 1: The Machine is Taken out of Service in New York State, is Sold and Subsequently Used for Perchloroethlene Dry Cleaning in Another State.
If the Perc dry cleaning machine is to be sold and subsequently used again for perchoroethylene dry cleaning, the machines themselves would never actually become solid waste and would not require any special permitting before being relocated to the new owner. However, all the drainings and spent wash solution from the machine must be managed and disposed as a hazardous waste. It is essential to note that since June 26, 2003 Part 232 expressly forbids the installation of anything but a brand-new, just out-of-the-box New York State CERTIFIED DEC Fourth Generation dry cleaning machine. Therefore, in this case the used machine MUST be sold to an out-of-state dry-cleaner, as the installation of any used Perc dry-cleaning machine in New York State is forbidden.
OPTION 2: The Used Machine is to be Disposed of as a "Non-Hazardous Waste"
If the Perc dry cleaning machines are to be disposed of as non-hazardous waste, New York State's Part 376 requires that the machine be cleaned using a cleaning or destruction method such as water washing as described in the regulation [Part 376.4(g)]. The cleaning can be done at the dry cleaners site without needing a Part 373 Hazardous Waste Treatment Permit provided that the cleaning operation and removal of the machine from the dry cleaner's site takes place within 90 days from when the machine was taken out of service. It is very important that all cleaning and machine removal take place within this 90 day period. Failure to do so forfeits the cleaners ability to have onsite cleaning performed and would require the cleaner to be responsible for the added expense of having the cleaning done at a facility with a valid Part 373 hazardous waste treatment facility.
OPTION 3: The Machine is Disposed of as "Scrap Metal"
If the Perc machine is to be sent for scrap metal reclamation instead of disposal there are two possibilities:
- The dry-cleaner can clean the machine as proscribed in option two and then turn the machine over to a scrap metal reclaimer. This means that the machine would not be considered as hazardous waste and that the scrap metal dealer does not have any responsibility for the hazardous waste.
- The machine can be sent to a scrap metal reclaimer without cleaning however, the dry-cleaner must be aware that the scrap metal reclaimer must possess the proper permit and facilities to handle the hazardous waste. The dry-cleaner must be aware that even though the scrap metal reclaimer takes possession of the machine and is resposible for the claeaning, the ultimate legal responsibility for the proper handling of the hazardous waste (i.e.. the Perc contaminated machine) always remains with the cleaner. For this reason it is very important that the dry-cleaner deal with a reputable hazardous waste handler/recycler. Additionally, if the cleaner decides to let the scrap metal reclaimer handle the removal of the uncleaned machine as hazardous waste, the cleaner must file a "C7" Notification for Hazardous Waste Generators". This notification which documents the name, date and waste hauler and waste generator should be sent to the appropriate Department of Environmental Conservation regional office.
Remember that no matter which option you choose, all Perc and Perc-contaminated washing solutions and drainings from the machine must be handled as hazardous waste. In most cases your regular hazardous waste hauler can handle the extra volume. If you have any questions about disposal of your drycleaning machine you can call the SBEO at 1-800-STATE-NY.