DSHW-2015-005570 - 0901a06880529561

cl010-00?57D
SQG/CESQG
COMPLIANCE EVALUATION INSPECTION
Date of Inspection:
Facility:
Facility Address:
County:
EPAID#
Latitude I Longitude:
Generator Status:
Number of Employees:
Arrival I Departure Time:
Weather Conditions:
Report Prepared By:
Names of Inspectors:
LHD Notifications I Date:
Facility Notification I Date:
Applicable Rules:
CREDENTIALS
March 23,2015
Superior Cleaners
24 West 100 North
Logan Utah, 84321
Bear River
UT0000326801
41.733272-111.835538
CESQG
10
1:25 p.m. to 2:30p.m.
4SOF, Raining
Alex Pashley
Patrick Sheehan
Alex Pashley
Patrick Sheehan
Bear River Health
Department by voice
Message
Unannounced
R315: R315-5, R315-13,
R315-16 and R315-9 of the
Utah Administrative Code
On March 23, 2015 the inspection team (team) met with and presented credentials to Steve
Wheeler.
Page 1 of9
PURPOSE AND SCOPE
The purpose of this Compliance Evaluation Inspection (CEI) was to evaluate the Facility's
waste management practices for compliance with R315 of the Utah Administrative Code
(the Rules), Utah Solid and Hazardous Waste Act 19-6-101.
FACILITY DESCRIPTION AND WASTE MANAGEMENT OPERATIONS
Superior Cleaners (Superior) is a dry cleaning and laundry facility. Superior has been at
its current location for approximately 90 years. Superior has an EPA ID number and is
notified as a CESQG.
Superior has two dry cleaning machines. One machine uses perchloroethylene (PERC)
and the other uses petroleum distillates for cleaning solvents. The petroleum based
cleaning machine is original equipment and may be 90 years old.
Mr. Wheeler stated that the petroleum based cleaning machine uses soap to clean clothes
and petroleum to rinse the clothes. The petroleum based cleaning machine generates no
waste solvent or sludge because, the washed clothes, which are damp with the petroleum
cleaner, are removed from the washer and placed into the drying room (see photo), where
the petroleum is evaporated and vented outside.
The PERC machine generates about 15 gallons of waste sludge per month from the built
in PERC recycling still. The recycled PERC is reused over and over. New PERC is added
to the system, as it is lost during the washing and recycling process.
The waste sludge contaminated with PERC is transferred and accumulated in a 55-gallon
hazardous waste drum, and later picked up AET Environmental for disposal.
Spent filters from the recycler are replaced about monthly. After removal, they are placed
into the drier and the PERC is evaporated from them. Once dried, Mr. Wheeler tears them
apart, places them outside to dry some more, and eventually throws them into the
garbage. The inspectors recommended that he place the filters into his hazardous waste
drum.
The PERC machine also generates a PERC recycling still separator water. It is
accumulated in a 5-gallon plastic bucket. Once full, the separator water is placed in a
drying room located at the back of the facility. The drying room is a heated and enclosed
room which is vented to the outside. The inspectors recommended that he look into
purchasing an evaporator/mister with carbon filters for his separator water.
Mr. Wheeler indicated that he had some hazardous waste manifest, but they were at his
home. He was requested to find them and send copies to the Division.
He was also requested, to obtain a copy of the SDS for the petroleum based dry cleaning
solvent and send to the Division.
Page2 of9
If only the waste sludge and filters are counted in the monthly generation rate, Superior is
a CESQG; however, if the separator water is counted in the monthly generation rate, it
might put Superior into the SQG category. However, based on letters from EPA (see
attached), the separator water should not be counted in the generation status.
COMPLIANCE STATUS:
R315-5 Hazardous Waste Generator Requirements
5- 1. I I Determination of Whether a Waste is a Hazardous Waste Filters,
separator water, and petroleum from clothes may be a hazardous waste.
5-1.12 EPA Identification Numbers UT0000326801
5-2.20 Manifest Not required of CESQG, however, Mr. Wheeler indicated that he
had them at his home. They were not reviewed during the inspection.
5-3.30-3.33 Packaging. Labeling. Marking. and Placarding
5.3.34 Accumulation Time AET Environmental picks up his wastes after he has
filled his 55- gallon drum.
Container Management OK
Tank Management N/A
Preparedness and Prevention N/A
5-4.40 Recordkeeping No records were reviewed as they were not
available during the inspection.
5-4.41 Biennial Reporting N/A
5-4.42 Exception Reporting N/A
5-4.43.1 Additional Reporting
R315-13-l LandDisposalRestrictions
13-1 Land Disposal Restrictions N/A
Standards for Universal WasteR315-16
Page 3 of 9
R315-9 Spill Response N/A
FOLLOW.UP ACTIONS:
Inspector Signature:
lnspector Signature:
ATTACHMENTS:
l. Photos
2. SQG Checklist
SQG Evaluation Form
March25.2015
Superior Cleaners- Front of the Store
Page 4 of 9
S,olid waste dumpsters located behind Superior Cleaners
Solid waste dumpsters located behind Superior Cleaners
Page 5 of 9
Hazardous waste PERC container
Page 6 of 9
Petroleum Cleaning Machine
-
rrytrf.rt
PERC Dry Cleaning Machine
PageT of9
Waste Sludge Cleanout Tray.
Drying room used to dry clothes washed with the Petroleum machine, and to evaporate
the separator water, and recycler filters.
Page 8 of 9
Inside view of drying room.
Page 9 of 9
Le4R)aeJ Fnou'
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5-pe,r lorr Cle*ate-v!
Lq ftu. t {r 6r >J h ftvl bl{
Material Safety Data Sheet
CHEMICAL PRODUCT & COMPANY IDENTIFICATION
24-Hour Emergency Phone Number 989-636-440O
PrOdUct: DOWPER* SOLVENT
Product. Code: 25202
Effective Datet 04/1,2/02 Date Printedt 12/26/02
The Dow Chemical Company, Midland, MI 48674
CusLomer Information Center: 800-258-2436
2. COMPOSITION/INFORMATION ON INGREDIENTS
Tetrachl-oroethvlene
3. HAZARDS IDENTIFICATION
EMERGENCY OVERVIEW************************************************************************
* Col-orless liquid. Irritatinq odor. Toxic fumes are rel-eased in ** fire situations. Causes skin irritation. Harmful- if inhaled. ** Can cause death if too much is breat.hed. Clear all personnel ** from area. Wear ful} protected equipment. Contain liquid to ** prevent. contamination of soi1, surface water or ground water. *************************************************************************
POTENTIAL HEALTH EFFECTS (See Section 11 for toxicological data. )
EYE: May cause pain. May cause slight transient (temporary) eyeirritation. Vapors may irriEaLe the eyes at about 100 ppm
perchloroethylene .
SKfN: Short single exposure may cause skin irritation. prolonged
or repeated exposure may cause severe skin irritaLion,
even a burn. Repeated contact may cause drying or flakingof skin. A single prolonged exposure is not like1y to resultin the material being absorbed through skin in harmfulamounts. Did not cause allergic skin reactions when testedin guinea pigs.
INGESTION: Single dose oral toxicity is considered to beextremely 1ow. Sma11 amounts swallowed incidental t.o normal
(Continued on page* OR (R) TNDICATES
, over)
TRADEMARK OF THE DOW CHEMICAL COMPA}JY
Page: 1
MSD: 000190
cAS# 000127 -]-8-4 99.92
2
A
MATERTAL SAFETY
Product: DOWPER* SOLVENT
Product Code: 25202
Effective Date : O4/L2/OZ
DATA SHEET PAGE: 2
Date Printedz 72/26/02 MSD: 000190
handling operations are not likely to cause injury; swallowing
amounts larger than that may cause injury. If aspirated(liquid enters the lung), may be rapidly absorbed t.hroughthe lungs and result in injury to other body systems.
INHALATION: In confined or poorly ventilated areas vapors canreadily accumul-ate and can cause unconsciousness and death.Dizziness may occur at 200 ppm perchloroethylene; progressively
higher levels may also cause nasal irritation, nausea, incoordi-naEion, drunkenness; and over 1000 ppm, unconsciousness anddeath. A single brief (minutes) inhalation exposure to l-evels
above 5000 ppm perchloroethylene may be immediately fat.aI.
Based on structural anal-ogy and/or equivocal data in animals,
excessive exposure may potentially increase sensitivity t-oepinephrine and increase myocardial irritability (irregular
heartbeats) . Alcoho} consumed before or after exposure mayincrease adverse effects.
SYSTEMIC (OTHER TARGET ORGAN) EFFECTS: Signs and symptoms ofexcessive exposure may be central nervous system effect.s andanest.hetic or narcotic ef f ects. Observations in animals incl-udel-iver and kidnev ef f ects.
CANCER INFORMATION: For hazard communication purposes under OSHA
Standard 29 CFR Part 1910.1200, this chemical- is listed as apotential carcinogen by IARC and NTP. Perchloroethylene has
been shown to increase t.he incidence of tumors in certain
st.rains of mice and rats. Ot.her long-term inhalation st.udiesin raLs failed to show tumorigenic response. Human data arelimited and have not est.ablished an association betweenperchloroethylene exposure and cancer. Perchloroethyleneis not beliewed Lo pose a measurable carcinogenic risk to
man when handled as recommended.
TERATOLOGY (BfRTH DEFECTS): Birth defects are unlikely.
Exposures having no effect on t,he mother should have no effecton the fetus. Did not. cause birth defects in animals; other
effects were seen in the fetus only at doses which caused toxic
effects to the mother.
REPRODUCTIVE EFFECTS: In laboratory animal studies, effects onreproduction have been seen only at doses that produced
significant toxicity to the parent animals. In animal studies,
has been shown not to interfere with fertility.
4. FIRST AID
(Continued on page 3)* OR (R) INDICATES A TRADEMARK OF THE DOW CHEMICAL COMPA}IY
MATERIAL SAFETY DATA SHEET PAGE:3
Product: DOWPER* SOLVENT
Product. Code: 25202
Effective Date: o4/12/Oz Date Printed:- 12/26/02 MSD: 000190
EYE: Flush eyes wit.h plenty of water.
SKIN: Wash off in flowing water or shower.
INGESTION: Do not induce vomiting. Call a physician and/ortransport to emergency facility immediately.
fNHALATION: Remove to fresh air. If not breathing, give
artificial respiration. If breathing is difficult, oxygen
should be administered by qualified personnel. Call a physician
or transport to a medical facility..
NOTE TO PHYSICIAN: Because rapid absorption may occur t.hroughIungs if aspirated and cause systemic effects, the decision of
whether t.o induce vomiting or not should be made by aphysician. If lavage is performed, suggest endotracheal and/or
esophageal conLrol-. Danger from lung aspiration must be
weighed against toxicity when considering emptying t.he stomach.If burn is present, treat as any thermal burn, after
decontaminat.ion. Exposure may inerease "myocardialirritability". Do not administer s)rmpathomimetic drugs unlessabsolutely necessary. No specific antidote. Supportive care.
Treatment based on judgmenE of the physician in response toreactions of the patient.
5. FIRE FIGHTING MEASURES
FLAMMABLE PROPERTIES
FLASH POINT: None
METHOD USED: TCC, TOC, COC
AUTOIGNITION TEMPERATURE: None available.
FLAMMABLE LIM]TS
LFL: None.
UFL: None.
HAZARDOUS COMBUSTION PRODUCTS: Hazardous combustion products mayinclude and are not limited to hydrogen chloride. Hazardous
combustion products may include tsrace amounts of phosgene,
chlorine.
OTHER FLAMMABILITY INFORMATION: This material does not burn.Container may vent and/or rupture due to fire. Vapors'are
heavier than air and may travel a long distance and accumulatein low lying ares. Violent steam generation or eruption may
(Continued on page 4 , over)* OR (R) INDICATES A TRADEMARK OF THE DOW CHEMICAL COMPAIIY
MATERIAL SAFETY
PrOduCt: DOWPER* SOLVENT
Product Code 25202
Effective Date : 04/L2/OZ
DATA SHEET PAGE: 4
Date Printed: 12/26/02 MSD:000190
occur upon application of direct waEer stream.
EXTINGUISHING MEDIA: This material- does not burn. ff exposedto fire from another source, use suitable ext.inguishing agentfor t.hat f ire.
MEDIA TO BE AVOIDED: Do not use direct water stream.
FIRE FIGHTING INSTRUCTIONS: Keep people away. IsolaTe firearea and deny unnecessary entry. Contain fire run-off ifpossible. Fire water run-off, if not contained may causeenvironmental damage. Do not use direct water sLream- Thismaterial does not burn. Fight. fire for other material thaE. isburninq.
PROTECTIU" ,OUTPMENT FOR FIRE FIGHTERS: Wear positive-pressuresel-f-contained breathing apparatus (SCBA) and protective fire
f ighting clothing (incl-udes fire f ighting hel_met, coat, pants,boots, and gloves. If protection equipment is not avail-ab1eor not. used, fight fire from a protected l_ocation or safedistance. For protection equipment in post-fire or non-fireclean up situations, refer to t.he rel-evant sections.
6 - ACCIDENTAL RELEASE MEASURES (See Section 15 for RegulatoryInformation)
PROTECT PEOPLE: Clear all personnel from area. Do not breathe' vapors. Ventilate area of leak or spilI. Wear proE.ective
equipment incl-uding positive pressure self contained or airsupplied breathing apparatus. Fol1ow confined space entryprocedures: ASTM D-4276 and OSHA (29 CFR 1910.146).
PROTECT ENVIRONMENT: Cont.ain liquid to prevent contamination ofsoil-, surface water or ground water. Material is heavier thanwater and has limit.ed water solubiIit.y. ft will collect on thelowest surface.
CLEAI'IUP: For large spills: cont,ain liquid; transfer to properlyIabeled closed metal containers. For small spills: mop or soakup immediately. Place in properly labeled metal containers.
7 . HANDLING AI{D STORAGE
HANDLING: To avoid uncont.rolled emissions vent vapor fromcontainer to storage tank. Do not eat, drink, or smoke inworking area. Refer to Exposure Controls/Persona1 Protection,
(Continued on page 5)* OR (R) INDICATES A TRADEMARK OF THE DOW CHEMICAL COMPANY
MATERIAL SAFETY
Product: DOWPER* SOLVENT
Product Code: 252O2
Effective Date : o4/L2/02
DATA SHEET PAGE: 5
Date Printed: 12/26/02 MSD:000190
Section 8, of the MSDS. Containers, even those t.hat have been
emptied, can contain vapors. Do not cut, dri}l, grind, we1d, ornarfnrpl similar operations on or near empty containers. Vapors
of this product are heavier than air and will collect in l-ow
areas such as pits, degreasers, sLorage tanks, and oEher
confined areas. Do not. enter these areas where vapors of thisproduct are suspected unless special breathing apparatus is used
and an observer is present for assistance.
STORAGE: Keep containers tightly cl-osed when not in use. For
more Storage and Handling information refer to bulletin
#100-06170. Store in a dry place. Do not store in aluminum,
zinc, aluminum afloys and plastics. Product shoul-d not be
packaged in aluminum aerosol cans or with finely divided
aluminum or its alloys in an aerosol can. Product is denser
than water. Design storage containers appropriately.
8. EXPOSURE CONTROLS/PERSONAL PROTECTION
ENGINEERING CONTROLS: Provide general and/or loca1 exhaust.
ventilation to control airborne l-eveLs below Ehe exposure
guidelines - Lethaf concenLrations may exist in areas with poor
ventil-ation.
PERSONAL PROTECT]VE EQUIPMENT
EYE/FACE PROTECTION: Use safety glasses. If wapor exposure
causes eye discomfort, use a fuII-face respirator.
SKIN PROTECTION: Use protective clothing impervious to this
material. Sel-ection of specific items such as faceshield,
gloves, boots, apron, or full body suit will depend on
operation.
RESPIRATORY PROTECTION: Atmospheric levels should be maintained
below the exposure guideline. When respiratory protection is
required, use an approved air-purifying or positive-pressure
supplied-air respirator depending on the potential airborne
concentration. For emergency and other conditions where the
exposure guideline may be greatly exceeded, use an approvedpositive-pressure self-contained breathing apparatus or
positive-pressure airline with auxiliary self-contained air
supply. In confined or poorly ventilated areas, use an
approved positive-pressure supplied-air respirator.
EXPOSURE GUIDELINE(S) : Perchloroethylene (tetrachoroethylene) :
ACGIH TLV is 25 ppm TWA, 1-00 ppm STEL, A3. OSHA PEL is 25 ppm.
(Continued on page* OR (R) INDICATES
5
A
, over)
TRADEMARK OF THE DOW CHEMICAL COMPANY
MATERTAL SAFETY
Product: DOWPER* SOLVENT
Product Code 25202
Effective Date. 04/12/02
DATA SHEET PAGE: 6
Date Printed. L2/26/02 MSD: 0001-90
PELs are in accord with t.hose recommended by OSHA, as in the1989 revision of PELs.
9. PHYSICAL AND CHEMICAL PROPERTIES
APPEARANCE: Colorl_ess Iiquid.
ODOR: Irritating odor
VAPOR PRESSURE: 13 mmHg @ 2OC
VAPOR DENSITY: 5.76
BOILING POINT: 250F (121.1C)
soLUBrLrTy rN WATER: 0.Or5 g/ 1009 25C
SPECIFIC GRAVITY: 1.519 @ 25/ZSC
10. STABILITY AND REACTIVTTY
CHEMICAL STABILITY: Stable under recommended storage conditions.See storage section.
CONDITIONS TO AVOID: Awoid direct sunl-ight. or ulLravioletsources. Awoid open flames, werding arcs, or other hightemperature sources which induce thermal decomposicion. Highenergy sources such as welding arcs can cause degradationgenerating chlorine, hydrogen chloride and possiUfe phosgene,and should be avoided.
INCOMPATIBILITY WITH OTHER MATERIALS: Awoid contact with metalssuch as: aruminum powders, magnesium powders, potassium,sodium, and zinc powder. A-void unintended contact with amines.Avoid contact. with strong based and strong oxidizers. Avoidprolonged contact with or storage in al-uminum or its alloys.
HAZARDOUS DECOMPOSITION PRODUCTS : Hazardous decompositionproducts may include and are not Iimited to hydrogen chlorideand trace amounts of chlorine and phosgene.
HAZARDOUS POLYMERIZATfON: WilI not occur.
11. TOXICOLOGICAL INFORMATION (See Section 3 for potentiat HealthEffects. For detailed toxicologicat data, write or call theaddress or non-emergency number shown in section i-)
sKrN: The LD50 for skin absorption in rabbits is > Lo g/kg.
INGESTION: The oral LD50 for rats is > 5OOO mg/kg.
(Continued on page* OR (R) INDICATES
7)
A TRADEIVIARK OF THE DOW CHEMICAL COMPAIVY
MATERIAL SAFETY DATA SHEET PAGE:7
Product: DOWPER* SOLVENT
Product Code: 25202
Effective DaLe o4/I2/02 Date Printed: 12/26/02 MSD: 000190
MUTAGENICITY (EFFECTS ON GENETIC MATERIAL): In viITo muLagenicity
studies were negative. Animal- mutagenicity studies were
negative.
12. ECOLOGICAL INFORMATION (For detailed Ecological data, write or cal-1
the address or non-emergency number shown in Section 1)
ENVIRONMENTAL FATE
MOVEMENT & PARTITIONING: Bioconcentration potential is low (eCf
l-ess than 100 or Log Pow l-ess than 3). BioconcentraLion
factor (BCF) is 49 in the bluegill. Bioconcentration factor(BCF) is 38.9 in the trout. Log octanol-/water partition
coefficient (log Pow) is 3.4. Potential- for mobility in soilis medium (Koc between 150 and 500). Log soil organic carbonpartition coef ficient (1og Koc) is estimated to be 2.I-3.2.
Henry's Law ConsLanL (H) is L.49E-O2 atm-m3/mol. Log
air/water parti-tion coefficient (1og Kaw) is estimated to be
-0.30 tp 0.37.
DEGRADATION & PERSISTENCE: Biodegradation under aerobic
conditions is below detectabLe limits. Theoretical oxygen
demand (ThOD) is calculated to be 0.1-9 p/p. Biodegradation
may occur under anaerobic conditions (in the absence of
oxygen). Degradation is expected in the atmospheric
environment within days to weeks. Biodegradation rate mayincrease in soil and/or wat.er with acclimation.
ECOTOXICOLOGY: Material is moderately toxic t.o aquat.ic organisms
on an acute basis (LC50 between 1 and 10 mg/L in most sensitive
species). Acute LC50 for 'Japanese medaka or rice fish(Oryzias latipes) is I.6 mg/L. Acute LC50 for water flea(Daphnia magna) is 3.2-123 mg/L. Acute LC50 for rainbow trout
(Oncorhynchus mykiss) is 4.8-5.8 mg/L. AcuLe LC50 for
sheepshead minnow (Clprinodon variegatus) is 8.0-52 .2 mg/t .
Acute LC50 for American flagfish 'Jordenell-a floridae is 8.4-
2a mg/L. Acute LC50 for bLuegill (Lepomis macrochirus) is
13 mg/L. Acute LC50 for fathead minnow (Pimephales promelas)
is 1,3.4-23-8 mg/1,. Maximum acceptable toxicant. concentrat.ion
(MATC) is 3.1 mg/L in American flagfish.
1-3, DISPOSAL CONSIDERATIONS (See Section 15 for Regulatory Information)
DISPOSAL: DO NOT DUMP INTO AliY SEWERS, ON THE GROUND, OR INTO AM
BODY OF WATER. A11 disposal methods must be in compliance with
all Federal, State/Provincial and loca1 laws and regulations.
(Continued on page I , over)* OR (R) INDICATES A TRADEMARK OF THE DOW CHEMICAL COMPA}IY
MATERIAL SAFETY
Product: DOWPER* SOLVENT
Product Code: 25202
Effective Date : os/tz/02
DATA SHEET PAGE: 8
Dat.e Printed : L2 / 26 / 02 MSD:000L90
Regulations may vary in different locatj-ons. Waste character-izations and compliance with applicable laws are the responsi-bility solely of the waste generator. THE DOW CHEMICAL COttpaNy
HAS NO CONTROL OVER THE MANAGEMENT PRACT]CES OR MANUFACTURING
PROCESSES OF PART]ES HANDLING OR USING THIS MATERIAL. THE
INFORMATION PRESENTED HERE PERTAINS ONLY TO THE PRODUCT ASSHIPPED IN ITS INTENDED CONDITION AS DESCRIBED TN MSDS SECTION 2(Composition/tnformation On Ingredients) .
FOR UNUSED & UNCONTAMINATED PRODUCT, the preferred options in-cl-ude sending to a ricensed, permit.ted recycl_er, reclaimer,incinerator or other t.hermal destruction device.
For additional information, refer to Dow Technical BuIletindiscussing considerations for t.his product. Burk Lit. No
100- 05170 .
As a service to its customers, Dow can provide names ofinformation resources t.o help identify waste managementrcompanies and other facilities which recycJ-e, reprocess ormanage chemicars or prastics, and that manage used. drums.Telephone Dow's Customer fnformation Center at800-258-2435 or 989-832-1556 for further details.
14. TRANSPORT INFORMATION
DEPARTMENT OF TRANSPORTATION (O.O-T. ) : For D.O.T. regulatoryinformation, if required, consult transportation regulatioirs,product shipping papers or contact your Dow representative.
CANADTAN TDG TNFORMATTON: For TDG regulatory information, ifrequired, consult transportation regulations, product shippingpapers or cont.act your Dow representative.
15- REGULATORY INFORMATION (Not meant to be all-inclusive--select.edregulations represented)
NorrcE: The information herein is presented in good faith andbelieved to be accurate as of the effective date shown above. However,no warranty, express or implied is giwen. Regulatory reguirementsare. subject to change and may differ from one location fo another;i! ]" the buyer's responsibility to ensure that its activities complywith federal, state or provincial, and Local laws. The folrowingspecific information is made for the purpose of complying with -
numerous federal, state or provincial, and local laws-and regulations.See other sections for health and safety information.
l=l==il3Y-:1:::====
MATERIAL SAFETY
ProduCT: DOWPER* SOLVENT
Product Code: 25202
Effective Date : o4/L2/02
DATA SHEET PAGE: 9
Date Printed: 72/26/02 MSD: 000190
REGULATORY INFORMATION (CONTINUED)
SARA 313 INFORMATION: This product contains the fol-Iowing substances
subject to the reporLing requirements of Section 313 of Title III of
the Superfund Amendments and Reauthorization Act of 1986 and 40 CFR
Part 312:
CHEMICAL NAME CAS NUMBER CONCENTRATION
PERCHLOROETHYLENE 000L27 -78-4 99 -9
SARA HAZARD CATEGORY: This product has been reviewed according to the
EPA 'tHazard CaEegories" promulgated under Sections 311 and 3L2 of the
Superfund Amendment and Reauthorization Act of 1985 (SARA Title III) and
is considered, under applicable definitions, Lo meet the following
categories:
An immediate health hazard
A delayed healt.h hazard
CALIFORNIA PROPOSITION 65: The
comply with the California Safe
of 1986:
WARNING: This product contains
California to cause cancer.
following statemenL
Drinking Water and
chemical (s) known
is made in order to
Toxic Enforcement Act.
Lo the State of
TOXIC SUBSTANCES CONTROL ACT (TSCA):
A11 ingredients are on the TSCA inventory or are noL reguired to be
listed on the TSCA inventory.
STATE RIGHT-TO-KNOW: The following product components are cited on
certain state lists as mentioned. Non-listed components may be shown
in the composition section of the MSDS-
CHEMICAL NAME CAS NUMBER LIST
(Continued on page 10) , over)* OR (R) INDICATES A TRADEMARK OF THE DOW CHEMICAL COMPAI{Y
MATERIAL SAFETY
ProduCt: DOWPER* SOLVENT
Product Code 252O2
Effective Date : 04/12/02
DATA SHEET PAGE: 10
Date Printed . 1,2 / 26 / 02 MSD: 000190
REGULATORY INFORMATION (CONTINUED)
PERCHLOROETHYLENE 000127-18-4 NJ1 N.I2 N,J3
PA1 PA2 PA3
N,J1=New rlersey Special Health Hazard Substance (present at greater thanor equal to 0.1?) .
N.J2=New ,Jersey Environmental Hazardous Substance (present at. greaterthan or equal to 1.0?) .
NJ3=New rlersey Workplace Hazardous Substance (present at greater thanor equal to 1.0?).
PA1=Pennsylvania Hazardous Substance (present at greater than or equalto 1.0?) .
PA2=Pennsylvania Special Hazardous Substance (present at greater thanor equal to 0.01?) .
PA3=Pennsylvania Environmental Hazardous Subst.ance (present at. greaterthan or equal to 1.0?) .
OSHA HAZARD COMMIINICATTON STANDARD :
This product is a "Hazardous Chemical-rr as defined by the OSHA HazardCommunication Standard, 29 CFR 191-0.1200.
COMPREHENSIVE ENV]RONMENTAL RESPONSE COMPENSATION A}TD LIABIL]TY ACT(CERCLA, or SUPERFUND) :
This product contains t.he following substance (s) Listed as rHazardous
Substances'r under CERCLA which may require reporting of releases:
CaLegory:
Chemical Name cAs#RQ ? in Product
Perchloroet.hylene
CANADIAIV REGULATIONS
000127-18-4 100 oo o
wHMrs TNFoRMATToN: The canadian workprace Hazardous Materialsrnformation system (wHMrs) classification for this product is:
Dl-B - poisonous substance defined by TDG regulations
D2A - possible, probable or known human carcinogen according toclassifications by IARC or ACGfH
(Continued on page 11)* OR (R) INDICATES A TRADEMARK OF THE DOW CHEMICAL COMPAI{Y
MATERIAL SAFETY DATA SHEET PAGE:11.
Product: DOWPER* SOLVENT
Product. Code: 25202
Ef fective Dat.e I 04/12/02 Date Printed. L2/26/02 MSD: 000190
REGULATORY INFORMATION (CONTINUED)
D2B - eye or skin irritant
Refer elsewhere in the MSDS for specific warnings and
safe handling information. Refer to the employer's
workplace education_progrl*.
_
CPR STATEMENT: This product has been cfassified in accordance with t.he
hazard criteria of the Canadian Control-l-ed Products Regulations (CPR)
and the MSDS contains al-l- the information required by the CPR.
HAZARDOUS PRODUCTS ACT fNFOnf,leffON, fhis product contains the following
ingredients which are Control-l-ed Products and/or on the IngredienL
Disciosure List (Canadian HPA section 13 and l-4):
COMPONENTS: CAS # AMOUNT (Zw/w)
TETRACHLOROETHYLENE OOO1,27 _18-4 99.9>"
16. OTHER INFORMATION
HAZARD RATING SYSTEM:
NATIONAL FIRE PROTECTION ASSOCIATION (NFPA) RATINGS:
Health 2
Flammability 0
Reactivitv 0
DISPOSAL OF CONTACT WATER:
Process water in contact with solvent and/or water separators of
cleaning or distillation equipment should be treated as hazardous
wast.e. Do not discharge water from water separators to drain-
GENERAL APPLICATION GUIDELINES :
Dow does NOT recommend the use of this product in applications
where:
- soil or ground water contamination is likely (direct
applications to the ground, sink drains, sewers, or septic
tanks).
- where over exposure is likely (small rooms or confined space,or where there woul-d be inadequate ventilation).
- where skin contact is 1ike1y (adhesive tape remowal from skin
or as hand cleaner to remove oils and greases).
- where there i-s direct food contact.
- where vapor concentrations would be in the flammable range.
(Cont,inued on page 12) , over)* OR (R) INDICATES A TRADEMARK OF THE DOW CHEMICAL COMPANY
MATERIAL SAFETY
Product: DOWPER* SOLVENT
Product Code: 25202
Effective Date : 04/IZ/02
DATA SHEET PAGE: 12
Date Printed: 12/26/02 MSD: 0001-90
- where disposal of wast.e would pose an enwironmental or healthrisk.
- where chemicaL reactivity poses a danger (contact with strongalkali, or in areas where welding is done).
MSDS STATUS: No revisions. Reviewed for canadian regulations.
* OR (R) INDICATES A TRADEMARK OF THE DOW CHEMICAL COMPANY
The rnformation Herein rs Given rn Good Faith, But No warranty,Express or rmpried, Is Made. consult rhe Dow chemicar companyFor Further Information.
Utah Department of Environmental Quality
Division of Solid and Hazardous Waste
P.0. Box f44880
Salt Lake City, Utah 841144880
Phone [phone]
Fax [phone]
SMALL BUSINESS ASSISTANCE PROGRAM
FACILITY INFORMATION FORM
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Other Personnel:
Waste Stream/Generation Process Estimated Generation Rate Per
Month
Hazardous Waste Gode
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Date:)Lt ,bt{
RECEIVED BY:
Name:
Signature:
Title:
DSHW REPRESENTATIVE:
Name: (Pdnted)
Signature:
Title: Environmentalscientist
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON. D.C 2046A
JUNE 2.1993
Mr. Wrlliam E. Fisher
Intemational Fabricare Institute
12251 Tech Road
Silver Spring, MD 20904
Dear Mr. Fisher,
Thank you for your letter dated September 2, 1992, conceming separator water and the use of
evaporators at dry-cleaning facilities. I apologize for not replying to your letter sooner. We appreciated
the opportunity to exchange information at the meeting held on July 2, 1992. We leamed a great deal
about this issue from the Intemational Fabricare Institute (IFI), and representatives of the Neighborhood
Cleaners Association and the Textile Care Allied Trade Association (TCATA). Our staffalso benefited
tom followup phone conversations with Mr. Manfred Wentz ofthe TCATA.
In your letter, you inquired about the status under the Resource Conservation and Recovery Act
(RCRA) of orrsite evaporators for separator water generated at dry-cleaning facilities. In general, EPA
Regions and authorized states answer inquiries about the implementation of the hazardous waste
regulations, particularly questions pertaining to specific facilities. However, because this issue potentially
affects dry cleaners nationwide, we believe that it is appropriate for us to address your questron.
Based upon the information received from you, as well as other urterested parties, we feel that the
separator water evaporators meet the defurition of "wastewater heatrnent unit" under RCRA. Tanks that
meet the definition of wastewater treatonent unit are exempt from RCRA permitting under 40 CFR
Sections 26a.l$)(6) and270.1(c)(2)(v). Therefore, these units would not require RCRA permits,
provided the criteria forqualifymg as a wastewater teatonent unit ouflined rn 40 CFR Section 26AJ0
are met (see discussion below).
The definition of wastewater treatnent unit corsists ofthree parts enumerated at 40 CFR Section
264.n. Firs! the evaporator unit must meet the definition of "tank" or "tank system" also found in
Section 260.10. The descriptions you provided indicate these units are tanks. Second, the evaporator
must be receiving and featrng or storing an tnfluent wastewater (or wastewater treatrnent sludge) that is
a hazardous waste. We me assuming the separator water is hazardous waste either by application of the
derived-from rule (e.g., derived-from F002), or the toxicity characteristic (e.g., perchloroethylene).
Finally, the dry-cleaning facility must be subject to Sections 307(b) or 402 of the Clean Water Act; this
includes wastewater teatrneff writs at facilities that l) discharge teated wastewater effuent into surface
waters or into a Publicly-Owned Treatnent Works (POTW) sewer system, or 2) produce no treated
wastewater effluent as a direct result of such requirements. We understand that some dry cleaners are
FaxBack # 11749
ehminatrng discharges due to concerns over sewer pipe leakage, not CWA discharge limis per se.
However, given the relatively small amounts of wastewater involved, we have concluded that this
situation is similar enough to warrant eqml consideration under the wastewater heatnent unit
exemptron.
Please note that the wastewater treatnent unit exemption applies to the storage and/or treatnent of
wastewater. not concenhated wastes. This exemption would not be available to anyone placing free-
phase perchloioethylene, for example, rnto an evaporator.
Thank you for your interest in solid and hazardous waste management. If you need fixther information,
please contact Ross Elliott of my staffat [phone].
Sincerely,
Sylvia K. Lowrance, Director
Office of Solid Waste
cc: William SeiU
Neighborhood Cleaners Association
Manfred Wentz
Textile Care Allied Trade Association
FaxBack # 11749
e431.1ee4(01)
United States Environmental Protection Agency
Washington, D.C. 20460
Office of Solid Waste and Emergenry Response
June2,1994
Mr. Tony M. Margiotta
Kleen-Rite, Lrc.
4444custine Avenue
St. Louis, MO 63116
Dear Mr. Margiotta:
Thank you for your letter dated February'18,1994, concerning
the Hydro-Mist unit used in the treatment of wastewater at
drycleaning facilities. I apologize f.or the delay in responding to
your letter. In your letter you specifically requested a "letter of
approval" from the U.S. EPA for the Hydro-Mist process. Let me
begrn by clarifying that our office is not able to certify,
endorse, or otherwise "approve" specific technologies, but we
sometimes are able to provide information on how your technology
would be regulated under the hazardous waste regulations, and I
hope this will be helpful to you.
The Office of Solid Waste (OSW) responded in writing to an
inquiry last June regarding evaporator units and the applicability
of the hazardous waste regulations under the Resource Conservation
and Recovery Act (RCRA). In that letter dated June2,1993, ftorn
Sylvia Lowrance to Mr. William Fischer (of the International
Fabricare Institute), we stated that the evaporator units described
to us by the drycleaning industry representatives met the
definition of wastewater treatment unit WWru) in40 CFR 260.'1.0,
and as such were exempt from federal hazardous waste permitting
requirements per 40 CFR 2A.aG)$). Based uPon the information you
provided to Mr. Ross Elliott of my staff over the telephone, it
appears that you are interested in a determination as to whether or
not the operation of the Hydro-Mist unit is comparable to other
types of evaporator units, with respect to the federal hazardous
waste regulations under RCRA. The principal issue requiring
clarification is the mechanism by which the wastewater is
eliminated: the Hydro-Mist unit uses an atomization or misting
technique to eliminate drycleaning wastewater, while other types of
RO 11840
wastewater evaporators use heat to evaporate the water.
One of the conditions of the WWTU exemption is that
wastewater meeting the definition of hazardous waste is "treated"
in a tank. EPA defines "treatment" rather broadly under RCRA (40
CFR 260.10), but "evaporation" is not specifically defined.
According to the information you provided, after treating the
perchlorethylene-contaminated wastewater with carbon adsorptiory
the Hydro-Mist unit uses an atomization process that releases the
treated water into the ambient air in very small droplets, where
evaporation of these droplets occurs. With respect to the
definition of "treatment" as it would apply under the WWTU
exemption/ we see no difference between the evaporation of water
from a tank using elevated temperatures, and the evaporation of
very small water droplets at ambient temperatures using an
atomization technique. Therefore, provided the unit meets the other
criteria for the WWTU exemption as outlined in S 260.10, the use of
atomization would not preclude the unit from being eligible for the
WWru exemption.
Finally,I would like to point out that under Section 3006 of
RCRA (42 U.S.C. Section 6926), individual States can be authorized
to administer and enforce their own hazardous waste programs in
lieu of the federal program. Please also note that under Section
3009 of RCRA (42 U.S.C. Section 6929) States retain authority to
promulgate regulatory requirements that are more stringent than
federal regulatory requirements. If a State agency authorized to
implement the RCRA hazardous waste program does not recognize the
wastewater treatment unit exemptiory or is regulating wwTUs more
stringently or broader in scope than the federal program, the
authority exists for that State to deal with the situation
directly.
I hope this information helps to clarify the issue you raised
concerning your Hydro-Mist unit. If you have any questions, please
call Ross Elliott of my staff at 202-260-8551. Thank you for your
interest in the safe management of solid and hazariorr, **tu.
Sincerely,
Michael J. Peska, Chief
Regulatory Development Branch
Office of Solid Waste
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