EPA Hazardous Waste Rules and Solvent Waste Management

Why Solvent Waste Regulation Matters

Dry cleaning operations generate waste streams that can seriously harm groundwater, soil, and human health if mishandled. The U.S. Environmental Protection Agency (EPA) regulates these wastes under the Resource Conservation and Recovery Act (RCRA), a federal law that governs the generation, storage, transportation, treatment, and disposal of hazardous waste. Every person working in a dry cleaning or laundry facility needs a working knowledge of RCRA, because violations can result in significant fines, facility closure, and personal liability.

What Makes a Waste Hazardous Under RCRA

RCRA defines hazardous waste in two broad ways: characteristic wastes and listed wastes.

Characteristic wastes display one or more of four properties:

• Ignitability – catches fire easily (flash point below 140 °F for liquids)
• Corrosivity – strongly acidic or alkaline (pH ≤ 2 or ≥ 12.5)
• Reactivity – unstable, explosive, or generates toxic gases
• Toxicity – leaches harmful metals or organics above regulatory thresholds (tested by the Toxicity Characteristic Leaching Procedure, or TCLP)

Listed wastes appear on specific EPA lists because they are known to be dangerous regardless of concentration. The lists most relevant to dry cleaning are the F-list (wastes from non-specific industrial sources) and the U-list (discarded commercial chemical products). Tetrachloroethylene (PERC, also called perchloroethylene) appears on the F-list as F002 when it is a spent halogenated solvent. PERC still bottoms—the concentrated residue left in the distillation unit after solvent recovery—are therefore listed hazardous waste.

Dry Cleaning Waste Streams: Hazardous or Not?

Understanding each waste stream in your shop is the first step toward compliance.

• Spent PERC solvent – Listed hazardous waste (F002). Must be managed as hazardous waste.
• Still bottoms (distillation residue) – Listed hazardous waste (F002). High concentration of PERC and other contaminants; requires disposal as hazardous waste.
• Contaminated cartridge/button trap filters – Listed hazardous waste when saturated with PERC (F002). Must not be placed in regular trash.
• Distilled water separator water (separator water) – May contain dissolved PERC. Typically regulated as hazardous; check your state program for specific thresholds and discharge permits before disposing to drain.
• Lint from dry cleaning machines – Generally non-hazardous if it contains only fiber and minimal solvent residue; however, lint that is visibly saturated with solvent must be treated as hazardous.
• Empty solvent drums – RCRA provides a specific empty container rule. A container that held a hazardous material is considered empty if all waste has been removed using the practical means available (pumping, scraping) and no more than one inch of residue or 3% by weight remains. Properly emptied drums may be managed as non-hazardous, but drums that fail this standard are still regulated hazardous waste.

Generator Categories and Storage Time Limits

RCRA classifies facilities by how much hazardous waste they generate per calendar month. The three categories currently recognized by EPA are:

• Very Small Quantity Generator (VSQG): generates no more than 100 kilograms (about 220 lb) of hazardous waste per month. No time limit on on-site storage, but quantity on-site must never exceed 1,000 kg. Waste must be sent to a permitted facility.
• Small Quantity Generator (SQG): generates more than 100 kg but no more than 1,000 kg per month. May store hazardous waste on-site for up to 270 days in compliant containers.
• Large Quantity Generator (LQG): generates more than 1,000 kg of hazardous waste per month. May store hazardous waste on-site for up to 90 days in compliant containers.

Most small dry cleaning shops fall into the VSQG or SQG category, but always calculate your actual generation rate; generator status can change month to month.

Proper Storage: Containers and Labels

Hazardous waste must be stored in closed, compatible containers in good condition—no leaks, no corrosion that could cause failure. Containers holding PERC waste must be compatible with chlorinated solvents (typically polyethylene, steel, or fluorinated HDPE). Each container must be clearly labeled with:

• The words "Hazardous Waste"
• A description of the waste contents
• The accumulation start date (for SQG and LQG)
• Required EPA hazard information

Containers must be kept closed except when adding or removing waste, and storage areas must have secondary containment.

The EPA Uniform Hazardous Waste Manifest

Whenever a SQG or LQG ships hazardous waste off-site, federal law requires use of the EPA Uniform Hazardous Waste Manifest (EPA Form 8700-22). This multi-copy shipping document travels with the waste from generator to transporter to the designated treatment, storage, or disposal facility (TSDF). Key sections include:

• Generator information – name, address, EPA ID number, generator category
• Waste description – proper shipping name, hazard class, UN/NA number, waste code (e.g., F002)
• Quantity – weight or volume in the units specified
• Transporter information – name and EPA ID number of each licensed transporter
• Designated facility – name and EPA ID number of the receiving TSDF
• Signatures – generator must sign certifying the waste has been properly characterized and minimized

The generator retains a copy; if a signed copy from the TSDF does not return within the required timeframe, the generator must investigate and may need to file an exception report.

Safety Points

When handling PERC waste containers, always wear appropriate PPE: nitrile or neoprene gloves, splash goggles, and a chemical-resistant apron. Work in a well-ventilated area. PERC is a suspected human carcinogen; avoid breathing vapors and skin contact. Follow your facility's lockout/tagout procedures before accessing the distillation unit to remove still bottoms. Never mix PERC waste with ignitable solvents—mixing can change the waste's hazard classification and create additional regulatory and safety problems.