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Compliance Guide for Dry Cleaners

IV.  Frequently Asked Questions

The following questions and answers are ordered by the sections in the Regulations. Each question below only addresses a specific issue or requirement in the Regulations. Dry cleaners must comply with all applicable requirements in the Regulations.

Part 1 - Tetrachloroethylene Used in Dry Cleaning

Part 2 - Tetrachloroethylene Reporting - Importation, Recycling, Sale and Use

Section 1 - Interpretation

Section 1 provides the definitions that are used in the Regulations. The Regulations do not define some commonly used industry terms such as transfer machine, second/third-generation machine and carbon adsorber. For the purpose of this Compliance Guide, these commonly used terms are defined below:

1.1. What is a transfer machine?

For the purpose of this Compliance Guide, a transfer (or first-generation) machine is a machine that uses separate machines (or drums) for the washing/extraction and drying/aeration cycles.

1.2. What is a second-generation machine?

For the purpose of this Compliance Guide, a second-generation (or dry-to-dry vented) machine is a machine that:

  • uses the same machine (or drum) for the washing/extraction and drying/aeration cycles;

  • introduces fresh air into the drum during the aeration (or deodourizing) cycle;

  • exhausts PERC-laden air to the atmosphere, either directly or through a carbon adsorber.

1.3. What is a third-generation machine?

For the purpose of this Compliance Guide, a third-generation (or dry-to-dry closed) machine is a machine that:

  • uses the same machine (or drum) for the washing/extraction and drying/deodourizing cycles;

  • re-cirulates PERC vapour and PERC-laden air through a refrigerated condenser with no exhaust to the atmosphere during the drying/deodourizing cycle.

1.4. What is a carbon adsorber?

For the purpose of this Compliance Guide, a carbon adsorber (or sniffer) is  a vapour control device for a dry-cleaning machine. When used as the primary vapour control device for a dry-cleaning machine, the PERC-laden air from the drying/aeration cycle is passed through a bed of activated carbon in the carbon absorber. The PERC is adsorbed on the surfaces of the activated carbon and the remaining air is exhausted to the atmosphere (normally outside the dry-cleaning facility). When the carbon adsorber is saturated with PERC, it must be regenerated (desorbed) by using steam and/or hot air. Waste water is generated during desorption of a carbon adsorber.

Part 1 - Tetrachloroethylene Used in Dry Cleaning

Section 2 – Applications

2.1.   Do the Regulations apply to all dry cleaners?

The Regulations apply to all dry cleaners that use PERC in Canada. 

The Regulations do not apply to dry cleaners that exclusively use solvents other than PERC. The Regulations also do not apply to the use of PERC in a textile mill.

The Regulations generally do not apply to store-front only or drop-off facilities where PERC or spotting agents containing PERC are not used.

2.2.  Do the Regulations apply to anyone else other than dry cleaners?

Yes.  The Regulations also apply to those who sell PERC to an owner or operator of a dry-cleaning machine/facility. The reporting requirements of the Regulations also apply to recyclers of PERC in Canada and to importers of PERC for any use. Separate fact sheets have been prepared to inform these persons of their obligations under the Regulations.

Section 3 – Prohibitions – Spotting Agents

3.1.  Are PERC spotting agents prohibited for use in a household?

No.  The Regulations prohibit the use of PERC spotting agents by all commercial and institutional dry cleaners beginning January 1, 2004. 

3.2.    What are commercial and institutional dry cleaners?

Commercial dry cleaners are for-profit operations and include industrial dry cleaners. Institutional dry cleaners are non-profit operations.

3.3.  Can pure PERC be used as a spotting agent by commercial and institutional dry cleaners?

No. Pure PERC cannot be used as a spotting agent beginning January 1, 2004.

3.4.  Can store-front only operations use PERC as a spotting agent?

No. Beginning January 1, 2004, all dry-cleaning facilities, including store-front only operations, are prohibited from using a spotting agent that is formulated with any amount of PERC.

Section 4 – Prohibitions – Closed Containers

4.1.  Do the doors to the button trap, lint trap and still have to be kept closed?

Button trap, lint trap and the still are parts of a dry-cleaning machine that may contain ‘residue’. As such, they must be closed at all times except when access is required for proper operation or maintenance (for example, for removal of the residue).  

4.2.  Does the drum door of the dry-cleaning machine have to be kept closed for a specified period of time after the drying cycle?

No. The Regulations do not specify a time period after the drying cycle before the drum door can be opened. The machine manufacturer’s recommended time period should be followed.

Section 5 – Prohibitions – Use of PERC in Dry-cleaning Machines

5.1.  Are transfer machines allowed under the Regulations?

Beginning January 1, 2004, PERC can no longer be used in transfer machines.

5.2.  Are second-generation machines allowed under the Regulations?

Beginning January 1, 2004, PERC can no longer be used in second-generation machines unless the machine is equipped with an existing (that is, installed before February 27, 2003) carbon adsorber as the primary vapour control device. PERC cannot be used in a second-generation machine after January 1, 2004 if the carbon adsorber was installed after February 27, 2003.

Beginning August 1, 2005, PERC can no longer be used in any second-generation machines. 

5.3.   Can a transfer or second-generation machine be retrofitted to comply with the Regulations?

Technically, it is virtually impossible and it would be economically unfeasible to retrofit a transfer machine to comply with the Regulations.  

A second-generation machine that does not have a carbon adsorber installed before February 27, 2003 cannot be retrofitted with a carbon adsorber in an effort to continue its use after January 1, 2004.

A second-generation machine that has a carbon adsorber installed before February 27, 2003 could be retrofitted with a refrigerated condenser in order to continue its use after August 1, 2005 but it may not be economically feasible to do so.  

5.4.  Do dry cleaners have to meet the specified PERC consumption rating?

No. The specified PERC consumption rating (that is, equal to or less than 10 kilograms or 6.2 litres of PERC per 1,000 kilograms of clothing cleaned) is a dry-cleaning machine manufacturer’s design rating. Dry cleaners are not required to meet the specified PERC consumption rating in their day-to-day operations.

5.5.   Can dry cleaners use machines that do not meet the specified PERC consumption rating?

Beginning August 1, 2003, dry cleaners cannot use PERC in a new dry-cleaning machine unless it meets the specified PERC consumption rating. A new dry-cleaning machine is a brand new machine that is installed on or after August 1, 2003.

5.6.   How would dry cleaners know whether a new machine can meet the specified PERC consumption rating or not?

Machine manufacturers, distributors and/or sellers generally specify the PERC consumption design rating of their machines on the name plate of a machine, the owner’s manual or other literature/correspondence from the manufacturers. 

5.7.  Can dry cleaners install and use an old machine that does not meet the specified PERC consumption rating after August 1, 2003?

Yes. The Regulations do not prohibit the resell, re-installation, use or reuse of a dry-cleaning machine that does not meet the specified PERC consumption rating provided that machine was previously installed or in use prior to August 1, 2003 and other applicable requirements of the Regulations are met.

5.8.  Is a containment pan required underneath the dry-cleaning machine?

The Regulations require a PERC-impermeable secondary containment system. A containment pan with the specified capacity meets this requirement.  

5.9. What is PERC-impermeable containment?

PERC-impermeable containment is constructed of material that would not allow the passage of PERC through the containment system. Contact the supplier(s) regarding the available PERC-impermeable systems/materials that can be used. The PERC Material Safety Data Sheets may also have information on chemical resistance. 

5.10.  Is concrete considered PERC-impermeable?

No. Bare concrete is not PERC-impermeable. 

5.11. Is a coating or sealant on the concrete acceptable as PERC-impermeable?

This depends on the type of coating/sealant used and whether it is properly applied and maintained. Epoxy-based sealant, phenolic floor topping and vinyl ester products have been used but their long-term effectiveness is not proven and they require proper application, periodic maintenance and re-coating. The dry-cleaning machine or container must still be lifted up in order to apply the coating/sealant under the machine or container. The anchoring of the dry-cleaning machine, tank or other container within the secondary containment system may also result in damages to the floor sealant/coating layer or the underlying concrete and subsequent seepage of PERC through the cracks and crevices along the anchoring points. Contact the supplier(s) for advice and warranty regarding the use of coating/sealant.

5.12. Is steel considered PERC-impermeable?

Although ordinary steel is considered to be PERC-impermeable, the build-up of moisture in the PERC will lead to acid formation and corrosion which could ultimately result in the failure of the containment system. Equipment used in handling or storing PERC should not contain aluminum, magnesium, zinc or any alloys of these materials such as bronze because the possibility of a reaction between these metals and the solvent may cause corrosion and could ultimately result in failure of the containment system. Containment pans are typically constructed from corrosion resistant steel. 

5.13. Is a berm considered an adequate secondary containment system?

No. The installation of a PERC-impermeable berm around a dry-cleaning machine, tank or other container does not constitute a secondary containment system encompassing at least the entire surface under the machine, tank or other container. Regardless of whether a containment pan or some other barrier system is used, the dry-cleaning machine, tank or other container within the containment area will still have to be lifted up in order to properly install the PERC-impermeable secondary containment system under the entire surface of the machine, tank or other container. 

5.14. Does the volume occupied by the foot-print of the machine count for the containment system?

If the dry-cleaning machine, tank or other container is placed directly on top of the secondary containment system, the footprint of the machine, tank or other container will take up part of the containment capacity within the containment system. Therefore, the true containment capacity must exclude the volume occupied by the footprint of the machine, tank or other container within the containment system.  This is important when determining the required minimum 110% capacity of the largest tank or container within the containment system.

5.15. Does the containment system have to be factory-installed?

No. The Regulations do not specify an installer for the secondary containment system.

5.16. How many PERC-resistant drain plugs are required for each facility?

The Regulations require PERC-resistant drain plugs to be readily available to seal all floor drains that PERC, wastewater or residue may enter in the event of a spill. Sufficient numbers of PERC-resistant drain plugs must be readily available to seal all floor drains at a dry-cleaning facility so that any spilled PERC, wastewater or residue will not enter the environment. . 

5.17. What does a PERC-resistant drain plug look like?

PERC-resistant drain plugs come in various shapes (from round plugs to mats), forms (from inflatable to solid), sizes and materials. Specially designed drain plugs may have to be used in floor drains where there are pipes or other structures running into the drain.  Contact the supplier(s) regarding available PERC-resistant drain plugs. 

Section 6 – Prohibitions – Use of Carbon Adsorbers

6.1.   How long can dry cleaners continue to use a carbon adsorber as the primary vapour control device?

If the carbon adsorber was installed on the second-generation machine prior to February 27, 2003, it can be used until July 31, 2005. Beginning August 1, 2005, the carbon adsorber must be replaced with a refrigerated condenser as the primary vapour control device for a dry-cleaning machine.

6.2.   Can multiple dry cleaning machines be vented to a single carbon adsorber?

Yes. However, the carbon adsorber should have sufficient capacity to handle the maximum volume of PERC-laden air generated from all machines that are vented to the carbon adsorber at any one time.

6.3.   Must a carbon adsorber be used for fugitive PERC vapour control when the drum door is open?

No. The Regulations do not require the use of a secondary vapour control device to reduce fugitive PERC vapour emissions when the drum door is open after the drying/aeration cycle is completed. 

However, the Regulations do not prohibit the use of secondary control devices, such as a carbon adsorber, that will further reduce PERC emissions into the work place.

Section 7 – Prohibitions – Self-service Dry-cleaning Machines

7.1.   What about coin-operated dry-cleaning machines?

A coin-operated machine is a self-service machine.

7.2.   Are coin-operated machine prohibited for use at a dry-cleaning facility?

The customer of the dry-cleaning facility cannot use PERC in a coin-operated PERC dry-cleaning machine. However, the owner or operator of a dry-cleaning facility can continue to personally use the coin-operated machine provided the machines meets the requirements of the Regulations. 

Section 8 – Waste Water and Residue – Waste Water

8.1.   What about the contaminated water generated during the desorption of carbon adsorbers?

The Regulations define waste water as “water containing PERC that is produced by a dry-cleaning machine or during the regeneration of a carbon adsorber”.

8.2.  Do all dry cleaners have to install a waste water treatment system?

Not necessarily. The Regulations provide an option to either install an on-site waste water treatment system or transport the waste water to a waste management facility.

8.3.   What is a waste water treatment system?

A schematic diagram of a waste water treatment system as defined by the Regulations is illustrated below. A waste water treatment system is connected to the integral (that is, the first separator shown in the diagram below) PERC-water separator in the dry-cleaning machine or the carbon adsorber (sniffer).  A waste water treatment system must have the following minimum equipment:

  1. a second PERC-water separator following the first (integral) PERC-water separator of the dry-cleaning machine;

  2. a first filter containing activated carbon following the second PERC-water separator;

  3. a second filter containing activated carbon following the first filter containing activated carbon;

  4. a monitor or alarm located between the first and second filters that will automatically shut down the waste water treatment system when the first filter is saturated with PERC.

Waste water treatement sysetm (ref: Section 8(1) of the Regulations). Reading the diagram from left to right: 1) Arrow 1, labeled "from the first PERC-water separator" and have two triangles labeled "valve" attached, is pointed to the right to connect to Box A labeled "(a) second PERC-water separator"; 2) Box A is connected to Box B "(b) activated carbon filter #1" by Arrow 2; 3) Box B is connected to Box C "(c) activated carbon filter #2" by Arrow 3; 4) A dot labeled "(d) monitor/alarm" is attached to Arrow 3, which has a dashed-arrow pointing to the "valve" on Arrow 1; and 5) Box C is then connected to text "treated effluent" by Arrow 4.

8.4.   Which brands or models of waste water treatment system are recommended?

Environment Canada does not endorse or certify any commercial products including waste water treatment system. Contact the supplier(s) for information regarding commercially available waste water treatment systems. When purchasing a waste water treatment system, be aware that there may be mandatory provincial, municipal or other local requirements such as a limit on the concentration of PERC in effluent entering a storm/sewer collection system.

8.5.   What is an activated carbon filter?

An activated carbon filter is a filter containing activated carbon. Activated carbon can be made from many materials containing a high carbon content such as coal, wood and coconut shells. Activation refers to the development of the adsorption properties of carbon, including the ability to adsorb chlorinated organic compounds such as PERC.

8.6. What are some of the things to look for in an activated carbon filter?

Loosely packed activated carbon in a filter will result in channeling, reduced contact time and greatly reduce the filter’s PERC removal capability. A smaller activated carbon filter will have lower PERC removal capacity than a larger filter of the same type.

8.7. Are hybrid filters allowed?

Yes. A filter can be used as long as the filter media contain activated carbon as one component. A hybrid filter contains activated carbon and some other media (for example, ceramic, other adsorbents or absorbents). 

8.8.  What procedures should be followed when the monitor-alarm shuts down the waste water treatment system?

If the monitor-alarm shuts down the waste water treatment system, both activated carbon filters should be replaced before using the waste water treatment system again.  The recommended filter replacement procedure is to either:

  1. replace the first and second activated carbon filters with new activated carbon filters; or

  2. replace the initial activated carbon filter with the used second activated carbon filter, and installing a new second activated carbon filter.

8.9.  What if the manufacturer’s recommended filter replacement schedule occurs prior to the monitor-alarm shutting down the waste water treatment system?

In such situations, follow the manufacturer’s recommendations. 

8.10. What should be done with the spent (used) activated carbon filters?

An activated carbon filter is spent when there is a break-through of PERC in the effluent from the filter.  The adsorption capacity of the filter is reached when this break-through occurs. 

Spent activated carbon filters are considered as ‘residue’ under the Regulations and must be transported to a waste management facility no less than once every 12 months.

8.11. Can dry cleaners regenerate or reactivate spent activated carbon filters themselves?

Reactivation is the process of restoring a spent activated carbon filter to its full adsorption capacity. Reactivation requires the use special furnace operating at over 800°C and this is only practiced at specialized hazardous waste treatment facilities. 

Regeneration is the process of using steam or hot dry air to desorb most of the PERC from the spent activated carbon filters. Regenerated activated carbon filters will eventually require reactivation to restore its full adsorption capacity. Regeneration will result in the generation and possible release of PERC vapour and/or waste water. Steam stripping of the spent activated carbon filters is not recommended because a large volume of PERC contaminated waste water will be generated and must be sent through the waste water treatment system again. Authorization from provincial, municipal or  local health, environmental and occupational health & safety authorities may be required for on-site regeneration of the spent activated carbon filters.

8.12. Can multiple dry-cleaning machines be connected to a single waste water treatment system?

Yes. An on-site waste water treatment system can be used to treat the wastewater generated from multiple machines located at the same dry-cleaning plant provided the treatment system has the capacity to handle the quantity of waste water from all the machines.

8.13. What PERC concentration is allowed in the treated effluent from the waste water treatment system?

The Regulations do not specify a PERC concentration in the treated effluent. However, there may be mandatory provincial,  municipal or other local requirements that limit the concentration of PERC in effluent entering a storm/sewer collection system.  

8.14. Can a mister or an evaporator be used to get rid of the treated effluent from the waste water treatment system?

The Regulations do not require the use of a mister or an evaporator. Authorization from provincial, municipal or local health, environmental and occupational health & safety authorities may be required to dispose of the treated effluent using an evaporator or mister.

8.15. Can treated effluent be dumped into the floor drain, toilet or other places?

The Regulations do not supersede other requirements of provincial, municipal or local authorities concerning the disposal of the treated effluent. For example, authorization from municipal sewer authorities or provincial governments may be required to dispose of the treated effluent. Some municipalities (for example, Toronto, Ontario and Capital Regional District, BCB.C.) have specified PERC concentrations that can be discharged into their sanitary sewers. 

Section 9 – Waste Water and Residue – Residue

9.1.   Can residue and waste water be mixed together for transport to a waste management facility?

The Regulations do not prohibit the mixing of residue with waste water. Item 4(e) in Schedule 4 of the Regulations provides the option to report the transport of waste water and residue mixed together.

The practice of mixing residue and waste water together is generally not practiced because PERC concentrations in waste water are typically much lower than in most residues. The disposal/treatment cost of residue at a waste management facility may be much higher than for waste water. 

Section 10 – Transfer Requirements

10.1. Can dry cleaners continue to add PERC to the dry-cleaning machine by pouring it through the button/lint traps?

Beginning January 1, 2004, PERC can only be transferred into a dry-cleaning machine, tank or other containers at a dry-cleaning facility by using a closed direct-coupled PERC delivery system.

10.2. Are closed direct-couple PERC delivery systems available at isolated communities?

Two major suppliers of PERC in Canada have instituted their own closed loop direct-coupled delivery system since the mid-1990’s. These two standard systems are available to PERC sellers and dry cleaners whether they are located in urban or rural communities. The two major suppliers have also developed an alternative system for use by PERC sellers that make infrequent deliveries and for dry cleaners located in isolated communities. Contact the PERC supplier(s) for additional information.

Part 2 - Tetrachloroethylene Reporting - Importation, Recycling, Sale and Use

Sections 11 to 13 – PERC Reporting - Importation, Recycling and Sale of PERC

11-13.1.  Do Sections 11 to 13 of the Regulations apply to the dry cleaners?

Sections 11 to 13 of the Regulations are applicable to dry cleaners that have imported or recycled PERC for any use or sold PERC for use in dry cleaning beginning on January 1, 2004.

11-13.2.  Is the use of a muck cooker to recover PERC from spent filters considered as recycling?

No. A muck cooker - that is, a still of a dry-cleaning machine, used for heating PERC-laden residue to volatilize and recover PERC is considered as a part of the dry-cleaning machine.  The recovery of PERC in a dry-cleaning machine for reuse in the machine is not considered as recycling.  It is not necessary to report this on-site activity at a dry-cleaning facility. 

The use of a muck cooker to recover PERC from spent filters may require specific authorization by the provincial, municipal and/or local authorities.

Section 14 – PERC Reporting - Reporting on Use of PERC in Dry Cleaning

14.1. Can dry cleaners make-up and use their own reporting form?

No. Dry cleaners must use the standard reporting form provided by Environment Canada to submit the information required under Schedule 4 of the Regulations

14.2. Are standard reporting forms available?

The blank standard reporting form, Annual Report for Dry Cleaners, for owners or operators of dry-cleaning facilities is enclosed with this compliance promotion package. Additional forms for future use can also be obtained from the appropriate regional Environment Canada contact listed in Appendix A or by making copies of the enclosed form.

14.3. Where and when do dry cleaners submit their annual reports?

The last page of the standard reporting form includes the address of the appropriate regional Environment Canada office that the annual report should be mailed to. The first annual reports for the 2004 calendar year must be submitted by April 30, 2005.  Subsequent reports must be submitted by April 30th of each year. 

14.4. Do dry cleaners have to keep records of their activities involving PERC?

Yes. Beginning on January 1, 2004, dry cleaners must maintain books and records on their purchases of PERC, the transport of waste water or residue to a waste management facility and the on-site treatment of waste water for each of the dry-cleaning facilities that they own or operate. Such books, records and other supporting documents must be kept for five years after the end of year in which the annual report was made.

There are other records keeping requirements if a dry cleaner sold PERC for use in dry cleaning, imported or recycled PERC for any other use. Separate fact sheets have been prepared to inform the sellers, importers and recyclers of their obligations under the Regulations.

Section 15 – PERC Reporting – Authorized Person

15.1. Can an employee sign the standard reporting form?

Each report must be signed by an authorized person and dated. An employee can sign the form if the he or she is authorized to do so by the corporation or by the owner or operator of the dry-cleaning facility.

Section 16 – PERC Reporting - Maintenance of Books and Records

16.1. Who can ask dry cleaners for their records of activities involving PERC?

Dry cleaners must make this information available for review by an Environment Canada Enforcement Officer in the course of their functions or provide it to the Minister upon request.

Section 17 – Coming into Force

17.1. When did the Regulations become law??

The Regulations became law on February 27, 2003.

17.2. Does this mean all provisions of the Regulations came into force on February 27, 2003?

No. Section 17 of the Regulations specifies when each provision of the Regulations comes into force. Section III (Page 2) of this Compliance Guide provides a summary of the important coming-into-force dates for the various provisions in the Regulations.

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