Self-Audit Checklist

Dry Cleaning ERP Inspector Checklist

Company Name:	Establishment No.:
Inspector Name:	Date:

PART 1: Perc Dry Cleaning Machine

General Requirements for All Perc Dry Cleaning Machines
Is the Machine operated according to manufacturers’ specifications?	Yes	No (OC)
Are machine operating manuals kept on site?	Yes	No (OC)
Is the dry cleaning machine door kept closed, except for loading and unloading?	Yes	No (OC)
Does facility keep a log of the gallons of perc purchased each month?	Yes	No (OC)
Are all perc purchase logs kept on file for five years?	Yes	No (OC)
Are all cartridge filters drained 24 hours before removal?	Yes	No (OC)
Does facility inspect the following components of the machine weekly for leaks? All hose and pipe connections, fittings, couplings, and valves Door gaskets Filter gaskets Pumps Solvent tanks and containers Muck cookers, stills Water separator Exhaust dampers Diverter valves Cartridge filter housing	Yes	No (OC)
If a leak is detected, is it repaired in 24 hours or if it cannot be repaired in 24 hours are parts ordered within 2 working days and installed within 5 days of receiving them?	Yes	No (OC)
Does facility keep a log of the date of any necessary repairs made to the machine?	Yes	No (OC)
Does facility keep a log of machine inspections that identifies any components that are leaking?	Yes	No (OC)

OC = Out of Compliance

PART 1: Perc Dry Cleaning Machine (continued)

Was the machine installed before 12/9/91 AND did facility purchase less than 140 gallons of perc per month during the previous 12-month period?		Yes Skip to 1.24 (existing small area source, exempt from control requirements)			No
Small and Large Dry-to-Dry Machine Control Requirements
Do all dry to dry machines installed before 12/9/91 have a refrigerated condenser OR a carbon adsorber that was installed prior to 9/22/93?	Yes		No (OC)	N/A machine installed after 12/9/91
Do all dry to dry machines installed after 12/9/91 have a refrigerated condenser?	Yes		No (OC)	N/A machine installed before 12/9/91
Are the refrigerated condensers on a vented machine routed properly so that the air-perc stream is not vented to atmosphere?	Yes		No (OC)	N/A no refrigerated condenser or non vented machine
Is the outlet temperature of the cooling coil (refrigerated condenser) read weekly and is it equal to or less than 45 F (±2 F) or 7.2 C (±1.1 C).	Yes		No (OC)	N/A
Is the date and temperature sensor monitoring results recorded weekly?	Yes		No (OC)	N/A
Are the date and temperature sensor monitoring results kept on file for five years?	Yes		No (OC)	N/A
If an external carbon adsorbor is installed on a vented machine, is none of the air-perchloroethylene gas-vapor stream allowed to bypass the carbon adsorber to the atmosphere?	Yes		No (OC)	N/A no carbon adsorber or non vented machine
Is the concentration of perc in the exhaust of the carbon adsorber measured weekly using a colorimetric detector tube?	Yes		No (OC)	N/A
Is the concentration of perc in the exhaust of the carbon adsorber less than 100 parts per million per volume?	Yes		No (OC)	N/A
Is the date and colorimetric detector tube monitoring results recorded weekly?	Yes		No (OC)	N/A
Is the date and colorimetric detector tube monitoring results kept on file for 5 years?	Yes		No (OC)	N/A
Are necessary repairs made to the refrigerated condenser and/or carbon adsorber?	Yes		No (OC)

OC = Out of Compliance

PART 1: Perc Dry Cleaning Machine (continued)

Fees and Licensing
Has the facility paid their air quality fee?	Yes	No (OC)
Has the facility paid their MDEQ Dry Cleaning License Fee?	Yes	No (OC)

PART 2: Petroleum Solvent Machine

Does facility have a dry cleaning machine that uses a petroleum solvent?	Yes	No - Go to Part 3
Is the TOTAL manufacturers’ rated dryer capacity for the entire plant equal to or greater than 84 pounds (38 kilograms)? (see explanation below) AND Was the equipment installed after December 14, 1982.	Yes	No - Go to Part 3
Is the filter a cartridge filter?	Yes	No (OC)
Are cartridge filters drained in their sealed housings for at least eight hours prior to their removal.	Yes	No (OC)
Is leak inspection and leak repair cycle information in the operating manual and on a clearly visible label posted on the dryer.	Yes	No (OC)
Was the dryer installed between December 14, 1982 and September 21,1984	Yes	No - Skip to 2.8
Does facility use more than 4,700 gallons (17,791 liters) of solvent per year?	Yes	No - Go to Part 3
Is the dryer a solvent recovery dryer?	Yes	No (OC)
Was an initial test conducted to verify that the flow rate of recovered solvent from the solvent recovery dryer at the termination of the recovery cycle is no greater than 0.05 liters per minute.	Yes	No (OC)
Does facility have a copy of the initial performance test?	Yes	No (OC)

* Manufacturer’s rated dryer capacity is the dryer’s rated capacity of articles, in pounds or kilograms of clothing articles per load, dry basis that is typically found on each dryer on the manufacturer’s name-plate or in the manufacturer’s equipment specifications. If the manufacturer’s rated dryer capacity for all the dryers at the plant combined is equal to or greater than 84 pounds, then the source is subject to the requirements in this section.

PART 3: Waste

Does facility generate less than 220 pounds of hazardous waste per month?		Yes		No
Does facility have a site identification number? The Site ID number should appear on all Uniform Hazardous Waste Manifests. Site ID will begin with MIK, MIR, MID MIT, MIE, MI0, MIG, MIH, or MIP prefix.		Yes		No (OC)
Manifests and Shipping Records
Does each shipment of hazardous waste or liquid industrial waste have a manifest or receipt from the waste hauler that identifies manifest number and the type and quantity of waste shipped?		Yes		No (OC)
Is the waste properly listed on the manifest form (e.g., F-002) and is the quantity shipped entered on the manifest form?		Yes		No (OC)
Has a copy of each manifest been signed by the waste hauler and submitted to the MDEQ WHMD?		Yes		No (OC)
Are all copies of the manifest that are signed by the hauler and disposal facility kept on file for at least 3 years?		Yes		No (OC)
Hazardous Waste Storage
Is each storage container labeled with the name of the contents (e.g., perc waste, filters) and is the label readable? Container may be labeled using purchased labels, a stencil, or the completed shipping label.	Yes		No (OC)
Is each container that is being shipped labeled according to the US DOT Shipping requirements? (e.g. does it have a completed US DOT shipping label).	Yes		No (OC)
Is less than 2,200 pounds (5 drums) of hazardous waste accumulated on site?	Yes		No (OC)
Are containers in good condition and kept closed except when adding or removing waste?	Yes		No (OC)
Is the exterior of the storage containers kept free of the liquid waste and its residue.	Yes		No (OC)
Are containers protected from the weather? If storing containers outdoors, they are placed on an impervious surface and protected them from the elements.	Yes		No (OC)
Are containers protected from fire and secure from vandalism and physical damage such as that caused by fork lifts or other equipment.	Yes		No (OC)
Are the containers compatible with the type of waste being stored in them and are containers that have wastes that could react with each other separated by a physical barrier, like a dike, berm, or wall, or by a safe distance?	Yes		No (OC)

PART 3: Waste (continued)

Is there adequate aisle space for unobstructed movement of emergency equipment and personnel?		Yes	No (OC)
If contents have a flashpoint below 200° F, are they isolated according to local fire department recommendations.		Yes	No (OC)
If a leak or spill occurs does facility immediately stop and contain the leak and repair or replace the container.		Yes	No (OC)
Have employees been trained on how to properly manage fluids.		Yes	No (OC)
Does hazardous waste storage area have secondary containment such as a curb, ramped pad, dike, or containment room?	Yes	No - Recommended
Is facility doing any of the best management practices listed in Table 3.1 of the Self Audit Workbook?	Yes	No - Recommended
Liquid and Hazardous Waste Disposal
Are hazardous wastes that are a liquid shipped to a licensed recycling, treatment, storage, or disposal facility?		Yes	No (OC)
Is facility complying with the following requirements: Liquid hazardous wastes are never disposed of in a dumpster, solid waste landfill, or incinerator. Waste is not put into the municipal sanitary sewer system without authorization from local wastewater treatment plant. Hazardous waste is not flushed into a septic tank, down a storm drain, into a stream, or on the ground.		Yes	No (OC)
Is facility doing any of the following best management practices? Hazardous wastes that are solids are disposed of in one of the following ways: shipped to a licensed recycling, treatment, storage, or disposal facility taken to a household hazardous waste collection site that is willing to accept your hazardous waste. “Solid” hazardous wastes are not disposed of in a solid waste landfill, municipal waste incinerator, or in a dumpster.	Yes	No - Recommended
Fluorescent Tubes, Lamps, and Batteries
Does facility recycle fluorescent tubes, incandescent lamps, and/or dry cell batteries? Only put this waste in your trash (dumpster) with permission from waste hauler and/or landfill (Some haulers and landfills may no longer accept these wastes.)	Yes	No – Recommended Skip to 3.27

PART 3: Waste (continued)

Are fluorescent tubes, incandescent lamps, dry cell batteries, stored for recycling according to the following requirements? Stored up to one year after generation. Records are kept that show how long they have been stored using a method that clearly demonstrates how long they have been accumulated. Waste is labeled or the container holding the waste is labeled with the following: “universal waste electric lamps,” “waste electric lamps,” “used electric lamps,” or “universal waste battery(ies),” “waste battery(ies),” “used battery(ies).” Waste must be stored in a way that prevents any spills or releases. Containers must be kept closed, in good condition, and be compatible with the type of waste stored in the containers. No more than 11,000 pounds of these wastes can be accumulated at any one time.		Yes		No (OC)
Have employees who handle fluorescent tubes, incandescent lamps, and dry cell batteries, been Informed about proper handling of these waste materials and any emergency procedures?		Yes		No (OC)
Does facility do any of the following: Recharge and use batteries that are still rechargeable. Use low-mercury, energy-efficient fluorescent/HID light bulbs. Keep recycling or disposal receipts for at least 3 years, and know who takes them to be recycled or disposed.	Yes	No - Recommended
Solid Waste Requirements
Is all solid waste hauled to a recycling center or a licensed disposal facility, which includes: a landfill, incinerator, or a transfer/processing facility?		Yes	No (OC)
Is waste stored in leak-proof, covered containers (e.g. covered dumpster)?		Yes	No (OC)
Does facility recycle or reuse office paper, corrugated cardboard, wood pallets, 55-gallon clean drums, other containers, or scrap metal?	Yes	No - Recommended

PART 4: Tanks

Does facility store fuel, solvents, or other material in an aboveground storage tank?	Yes	No – Go to Part 5
Does the storage tank have secondary containment?	Yes	No (OC)
Is the tank any of the following: Used to supply flammable or combustible liquid with a storage capacity of more than 1,100 gallons. This includes drycleaning solvents and/or fuel oil. A flammable compressed gas or LPG container filling location. An LPG tank with a water capacity of more than 2,000 gallons, or two or more tanks with an aggregate water capacity of more than 4,000 gallons?	Yes	No – Skip to 4.5

PART 4: Tanks (continued)

Has the tank been certified by the Michigan Department of Environmental Quality Waste and Hazardous Materials Division	Yes	No (OC)
Does the tank meet the requirements below?	Yes	No (OC)
A single- or double-bottom shop-manufactured tank that has an external mastic-coated bottom can only be installed on a concrete or asphalt pad that is higher than the surrounding dike floor. Cathodic protection that is properly engineered and maintained must be used for the exterior of single- or double-bottom tanks that are installed on earth and gravel. Cathodic protection can be used on single- or double-bottom tanks that are installed on a concrete or asphalt pad at the same level as the rest of the dike floor. Precautions must be taken to prevent the ignition of flammable vapors. Sources of ignition include but are not limited to: open flames, cutting and welding, thermal heat, spontaneous ignition, stray currents, smoking. The tank should be bonded or otherwise connected to the ground to prevent static electricity? Releases or suspected releases of a regulated substance from the storage tank must be reported. Contact the Michigan Department of Environmental Quality, Remediation and Redevelopment Division district office (see Appendix C for phone numbers) and the local fire department, or the Pollution Emergency Alerting System at 800-292-4706. Some signs that a release has occurred are visibly stained soils, holes in the AST, and odoriferous soils. An emergency action plan must be available and made known to employees to respond to fire or other emergencies. (Alternate fire safety measures on-site must be in place while any fire safety equipment is shut down.) This emergency plan should be coordinated with your local emergency response agencies, such as fire, police, etc. In most cases, your local agencies will respond to your alarm or call.

PART 5: Boiler

Does facility have a boiler?	Yes			No – Go to Part 6
Does facility keep a record of the amount of fuel the boiler uses per month (e.g., monthly bill from utility company)?		Yes			No (OC)
Does the boiler stack discharge vertically upwards and are all devices used to prevent precipitation from entering the sack not restricting the vertical flow of the exhaust gas stream?		Yes			No (OC)
Does boiler comply with the requirements below?		Yes			No (OC)
The boiler must not smoke or cause a nuisance when operated. Boiler must be operated and maintained according to the manufacturer’s instructions. Tune-ups, including efficiency testing, are considered crucial to efficient, clean operation. Boiler blowdown MAY NOT be discharged to a septic system. If discharge to a sewer is not possible, facility must obtain a groundwater or surface water discharge permit, or store boiler blowdown in a holding tank or container. An evaporator may be reduce the volume of boiler blowdown before having it hauled offsite.
Is Facility doing any of the following best management practices for boilers?	Yes		No – Recommended
There should be no fresh air intakes near the stack. The flue gas exit velocity should be at least 40 feet per second. Replace stack when boiler is replaced. The construction material can affect the acid dew point and ultimately the life of the stack. Therefore, it is wise in invest in a new stack at the time the boiler is being replaced, if the existing stack does not meet the general standards listed above.

PART 6: Wastewater

Is facility connected to a sewer system that goes to a wastewater treatment plant?		Yes		No – Skip to 6.6
Does facility empty wastewater from dry cleaning machine into a drain, toilet, or sink?		Yes		No - Skip to 6.4
Does facility have permission from the wastewater treatment plant to dispose of wastewater from dry cleaning machine into the sewer system? (e.g., permit, letter, or written authorization from WWTP)		Yes		No (OC)
Does facility empty wastewater from laundry area, air compressor, boiler, vacuum, or floor cleaning into a drain, toilet, or sink?		Yes		No - Skip to 6.6
Does facility have permission from the wastewater treatment plant to dispose of wastewater from laundry area, air compressor, boiler, vacuum, or floor cleaning into the sewer system? (e.g., permit, letter, or written authorization from WWTP)		Yes		No (OC)
Does facility use an evaporator device to dispose of wastewater?		Yes		No
Is any wastewater collected in a holding tank?		Yes		No - Skip to 6.9
Is wastewater that is collected in holding tank disposed of by a licensed and registered hauler?		Yes		No (OC)
Does any wastewater from facility go to a septic system?		Yes		No
Does facility empty wastewater from dry cleaning machine, laundry area, air compressor, boiler, vacuum, or floor cleaning onto the ground, storm sewer, steam, or ditch?		Yes		No
Are there any floor drains in facility?	Yes		No - Go to Part 7
Do they empty to the sewer system or a holding tank?	Yes Go to Part 7		No
Have the drains been plugged with concrete or a locked down cement cap so that they are inaccessible and unusable?		Yes		No (OC)

PART 7: Safety

Are there at least two portable fire extinguishers with at least a 2a,10bc rating at the facility and is one of those fire extinguishers mounted near the dry cleaning machine?	Yes	No (OC)
Does facility have an approved organic vapor respirator?	Yes	No (OC)

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