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Dry Cleaning Environmental Compliance Workbook

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Dry Cleaning Environmental Compliance Workbook Michigan Dry Cleaning Environmental Compliance Workbook Jennifer M. Granholm, Governor Steven E. Chester, Director www.michigan.gov/deq (800) 662-9278 Michigan Department of Environmental Quality Environmental Science and Services Division January 2004 Clean Air Assistance Program AUTHORITY: PA 451 of 1994, as amended TOTAL COPIES: 200 TOTAL COST: $2,361.68 COST PER COPY: $11.81 PRINTED ON Michigan Department of Environmental Quality RECYCLED PAPER The Michigan Department of Environmental Quality (MDEQ) will not discriminate against any individual or group on the basis of race, sex, religion, age, national origin, color, marital status, disability or political beliefs. Questions or concerns should be directed to the MDEQ Office of Personnel Services, P.O. Box 30473, Lansing, MI 48909. INTRODUCTION We know that environmental laws and regulations are complex and difficult to understand. Most regulations are not written for any one particular industry. Rather, they are written to apply to a diverse group of businesses and industries. As a result, drycleaners must understand and comply with the same rules as large corporations. The problem is, most large corporations have staff trained specifically to work in compliance matters, and most small businesses, like dry cleaners, do not. We wrote this Workbook to help Michigan dry cleaners understand their regulatory obligations. The regulations discussed in this book have been written in plain English, making them easier to understand and implement. The Workbook is one of a two-part compliance assistance package. Part 1: Michigan Dry Cleaner Environmental Compliance Audit Checklist This checklist contains a series of compliance questions, which generally require “yes” or “no” answers about whether or not your facility is following the applicable environmental requirements. You will use the Workbook to help you answer these questions. After completing the checklist, you will know your facility’s compliance status with environmental regulations. Part 2: Michigan Dry Cleaner Environmental Compliance Workbook (this Workbook) This Workbook explains the environmental protection standards that apply to your business. The Workbook also includes best management practices and pollution prevention techniques that go beyond what is required by regulations. These practices and techniques can help your business minimize health risks and environmental impacts while saving money. This Workbook should be used in conjunction with the accompanying Compliance Audit Checklist and can also be used as a reference for your facility. The information in this manual is offered only as guidance. Specific requirements may vary with individual processes and/or businesses. Business owners are responsible for obtaining complete information about all applicable regulations. The Michigan Department of Environmental Quality (DEQ) is not authorized to relieve any person from any requirement of federal regulations or Michigan law through this Workbook. WHERE TO GO FOR HELP Questions or requests for additional information about the regulations discussed in this Workbook should be directed to the following agencies: • Michigan Department of Environmental Quality (DEQ), Clean Air Assistance Program www.michigan.gov/deq (select “Assistance & Support Services,” “Technical Assistance,” then “Clean Air Assistance”) 800-662-9278 OR • DEQ, Dry Cleaning Program www.michigan.gov/deq (select “Air,” “Air Compliance & Enforcement,” then “Michigan Dry Cleaning Program”) 517-241-1324 TABLE OF CONTENTS CHAPTER 1: Air Quality Regulations NESHAP for Perchloroethylene Dry Cleaners............................................................1-1 New Source Performance Standard for Petroleum Dry Cleaners ...........................1-14 Permit to Install...........................................................................................................1-16 Renewable Operating Permit Program .....................................................................1-17 Michigan Air Emissions Reporting System (MAERS) .............................................1-19 Where To Go For Help ..............................................................................................1-20 DEQ, Air Quality Division Dry Cleaning Recordkeeping Forms ..............................1-21 CHAPTER 2: Waste Management Regulations Best Management Practices – Waste Reduction Opportunities ................................2-1 Solid Waste ..................................................................................................................2-3 Liquid Industrial Waste.................................................................................................2-5 Hazardous Waste ........................................................................................................2-7 Conditionally Exempt Small Quantity Generator Requirements........................2-14 Small Quantity Generator Requirements............................................................2-25 Selecting a Transporter and Treatment, Storage, or Disposal Facility ..............2-38 Where To Go For Help ..............................................................................................2-40 Hazardous Waste Management Forms ....................................................................2-43 CHAPTER 3: Wastewater Management Regulations Do You Discharge Wastewater? .................................................................................3-1 Where Does Your Wastewater Go?............................................................................3-1 Disposal Requirements................................................................................................3-2 Municipal Sewer System .......................................................................................3-2 Septic System ........................................................................................................3-4 Holding Tanks ........................................................................................................3-5 Surface Water Discharge ......................................................................................3-6 Best Management Practices for Wastewater Discharge............................................3-7 Spills .............................................................................................................................3-7 Annual Wastewater Reporting.....................................................................................3-8 Where To Go For Help ................................................................................................3-9 CHAPTER 4: Material Storage Regulations Secondary Containment ..............................................................................................4-1 Underground Storage Tanks .......................................................................................4-4 Aboveground Storage Tanks.....................................................................................4-10 Where To Go For Help ..............................................................................................4-12 CHAPTER 5: Environmental Reporting, Planning, and Release Response Hazardous Chemical Reporting ..................................................................................5-1 Pollution Incident Prevention Plan (PIPP)...................................................................5-3 Spill Prevention, Control and Countermeasure (SPCC) Plans ..................................5-6 Contingency Plans for Hazardous Waste Generators................................................5-6 Release Reporting .......................................................................................................5-8 Release Response and Cleanup ..............................................................................5-10 Where To Go For Help ..............................................................................................5-12 CHAPTER 6: Michigan Dry Cleaning Program Regulations A Brief History ..............................................................................................................6-1 Primary Function of the Dry Cleaning Program..........................................................6-1 Duties Performed by a Dry Cleaning Inspector ..........................................................6-2 When to Notify the Dry Cleaning Program..................................................................6-2 Dry Cleaning Licensing and Fees ...............................................................................6-3 Inspecting Dry Cleaning Equipment............................................................................6-4 Safety Equipment.........................................................................................................6-5 Where To Go For Help ................................................................................................6-6 APPENDICES APPENDIX A: Acronyms ................................................................................................1 APPENDIX B: Chemicals Used in Dry Cleaning Operations........................................3 APPENDIX C: DEQ Contacts.......................................................................................13 CChhaapptteerr 11 AAiirr QQuuaalliittyy RReegguullaattiioonnss Compliance Audit Questions A1 through A16 CHAPTER 1: Air Quality Regulations The dry cleaning industry operates equipment that emits air contaminants. Perchloroethylene (perc)
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