Dry Cleaning Facilities

Even for regulators who read rules constantly, the Federal NESHAP rules for Dry Cleaners using perchloroethylene (PERC) are difficult to read and apply. The Forsyth County Office of Environmental Assistance and Protection has consolidated the applicable rules into a set of conditions for owners and operators of Dry Cleaners using PERC in Forsyth County. View the Summary of NESHAP Conditions.

These conditions were created in a manner similar to what would be seen in a permit and were carefully done to help insure that they were comprehensive for facilities in Forsyth County. However, should these conditions be incomplete or inaccurate, Dry Cleaning facility operators are still liable for compliance with the Federal Regulations and subject to enforcement action by EAP. Should you have any questions about the rules, Click here to read the Federal NESHAP rules in their entirety. You may also call your EAP agent at 703-2440 for clarification of any of the conditions or rules concerning NESHAP.

FACILITY CATEGORIES

NESHAP divides dry cleaners into three categories based on the amount of PERC purchased per year:

1. SMALL – purchase less than 140 gallons of PERC per year
2. LARGE – purchase between 140 and 2,100 gallons of PERC per year
3. MAJOR – purchase more than 2,100 gallons of PERC per year (none in Forsyth County)

Once the usage of PERC at a facility reaches or exceeds the thresholds stated in these categories, requirements applicable to the highest threshold will apply until the facility makes a written request to the Office of Environmental Assistance and Protection that they expect to remain at a lower threshold for a considerable length of time.

INSTALLATION DATES

NESHAP rules also sort machines into categories based on the date of their installation. As of January 2008, important dates to remember for facilities in Forsyth County are:

• December 9, 1991 – machines installed before this date are considered Existing under the initial rule. Machines installed after this date are referred to as New under the initial rule.
• December 21, 2005 – machines installed on or after this date must have the addition of a carbon adsorber to vent exhaust air from the dry cleaning drum prior to the door opening. As of July 27, 2006, machines in this category must be using the halogenated leak detector at least once per month to do leak checks while the machine is in operation. This can replace the required visual inspection for that week. The visual inspections must still be done all other weeks when the halogenated leak detector is not used. These requirements are set forth in the Summary of NESHAP Conditions.
• July 28, 2008 – All machines installed in Forsyth County must be using the halogenated leak detector as described in the December 21, 2005 statement above. Additionally by this date, the Federal rule requires that all dry cleaning facilities in Forsyth County must have sent the Forsyth County Office of Environmental Assistance and Protection a Notification of Compliance Status as described in condition 14 of the Summary of NESHAP Conditions.

Forms and Instructions

All dry cleaning facilities in Forsyth County using PERC must register their facilities with the Forsyth County Office of Environmental Assistance and Protection (EAP).

• Print a registration form
• Print the instructions for completing a registration form.

Dry Cleaning facility owners should strive to provide the safest environment for workers and a clean environment around the facility (land, air, and water). To learn more, see OSHA’s Reducing Worker Exposure to PERC in Dry Cleaning. Compliance with Federal rules and regulations governing the dry cleaning industry will reduce exposure of workers and customers to PERC. It will also save the owners money since proper maintenance and preventing leaks and spills leaves more PERC to be reused in the machines.

In Forsyth County, our agents inspect Dry Cleaning facilities for compliance with NESHAP, the air quality rules under the Federal Clean Air Act governing dry cleaning facilities using PERC. We enforce the rules through issuance of violations, civil penalties, and by providing educational assistance when requested and/or needed. The Dry Cleaning Solvent Cleanup Act (DSCA) program, operated by the State of North Carolina’s Division of Waste Management, inspects Dry Cleaning facilities for compliance with waste management rules and housekeeping requirements under the DSCA program. Occasionally, our agents will operate joint inspections with agents from the DSCA program, allowing us to become more familiar with State waste management and DSCA requirements. When schedules or frequency of inspections do not allow for joint inspections, our Office directs waste management and DSCA related problems to the State if our inspectors find them during annual air quality inspections.