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National Clothesline
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No runs, no drips, no errors
Practical environmental compliance
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By Aaron Getchell and Mike Lodato
As a geologist working as an environmental consultant who completes site
assessments at drycleaning facilities, I can honestly tell you that nobody
likes seeing me pull up to their store in my company vehicle.
I start my visit by taking some notes on my clipboard, make sure my batteries
are charged in my digital camera and start walking towards the door with an
executed access agreement in-hand.
When tasked with performing a site assessment at a drycleaning facility, I first
observe current operations for evidence of environmental compliance, which will
help reduce the risk of a release of drycleaning solvents (typically
tetrachloroethylene (PCE or perc) or petroleum distillate solvent (Stoddard
solvent).
Environmental compliance is practical. Environmental compliance has been
promulgated to reduce the risk of chemical mismanagement. When drycleaning
solvents are mismanaged, they have a high potential to be released into the
environment (air, soil, surface water and ground water).
Once in the soil, the drycleaning solvent can cause vapor intrusion issues and
potentially pose health-risks to building tenants or facility workers.
Once in the surface or groundwater, drycleaning solvent can contaminate private
or public drinking water wells, or impact natural resources like springs and
surface water bodies used for drinking water and recreational purposes.
Environmental compliance with local and federal environmental regulations can
also save costs to a drycleaning facility operator; savings could be realized
in reduced solvent purchase or not paying costly environmental fines.
Guidance documents
Numerous guidance documents are available that describe drycleaning facility
compliance. One resource can be obtained from the U.S. Environmental Protection
Agency’s website (www.epa.gov), including the “Plain English Guide for the Dry Cleaners”(pdf file). A “Drycleaning Facility Compliance Assistance Brochure” is also available on the Florida Department of Environmental Protection’s website (www.floridadrycleaners.org).
Both documents are informational and easy to read. The purpose of this article
is not to replace the guidance documents found at these resources or to replace
local or federal regulations. This article provides owners and operators with
an idea of what an environmental consultant (such as myself) would be looking
for when tasked with completing a site assessment at a drycleaning facility.
The following is a list of items that can be cost-effective and time-efficient
to address, and help prevent releases of drycleaning solvent to soil and
groundwater.
Good housekeeping
Many different chemicals are used at a drycleaning facility on a regular basis
such as supplies for operational use, machinery maintenance, or excess waste
chemicals. These chemicals could include paint, lubricating oil, bleach, soap,
spotting agents, pre-cleaning agents, drycleaning solvents, spent solvent, and
drycleaning residues.
Chemical containers located indoors in one central storage area within secondary
containment is a sign of good housekeeping. Other signs include keeping this
indoor central area clean and free of drips or obvious signs of leaks or
overfilling; keeping containers labeled for contents; and keeping containers
sealed when not in use.
Paperwork and documentation
Drycleaning facilities are often registered with the state or other local
municipality (proof of regulatory inspections on a regular basis). Registration
paperwork and inspection forms should be kept in a central location along with
other paperwork. Other paperwork should include waste disposal manifests (proof
of proper manifested offsite disposal of chemical waste), Material Safety Data
Sheets (evidence of proper chemical inventory), and facility inspection records
(evidence of well-maintained drycleaning machinery).
Seal floors
Floor-space in drycleaning facilities is often limited and subject to
high-traffic. The concrete floor-space in the immediate vicinity of drycleaning
operations should be free of cracks and seams that could act as a direct
conduit to soil and groundwater if an accidental chemical release were to
occur.
Cracks and seams should be patched with pre-mixed concrete patch available at
any big-box home improvement store. Once cracks and seams are patched, an
application of a two-part epoxy (available at a specialty paint supply store)
will help reduce the chance of impacting soil or groundwater by an accidental
chemical release.
Secondary containment
Secondary containment is designed to provide a barrier between a chemical
container and soil and groundwater in the event of an accidental release.
Secondary containment can be a solvent-resistant plastic or metal and is usually
placed beneath drycleaning machines, supporting machinery (such as spotting
areas and solvent reclamation units), chemical storage areas, and chemical
waste storage areas.
Displaying orderly and clean secondary containment units (free of drips, spills,
other containers or supplies) is evidence of proper chemical management.
The goal of this article was to provide drycleaner operators and industry
professionals a practical view of environmental compliance, resources for
regulatory guidance, and a practical view of a few prominent items of what an
environmental consultant would observe at a drycleaning facility for evaluating
the potential for a chemical release.
Aaron Getchell and Mike Lodato are consultants with Geosyntec, a specialized consulting and engineering firm that works with private and
public sector clients to address problems involving the environment, natural
resources, and our civil infrastructure. Geosyntec has a staff of 600
engineers, scientists, and related technical and project support staff located
in more than 30 offices throughout the U.S. and in Canada, Malaysia, and the
United Kingdom. For more information or questions about drycleaning facility
assessment, contact Getchell, (561) 995-0900 or
agetchell@geosyntec.com, or Lodato (813) 955-0990 or mlodato@geosyntec.com.
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