Watch Your Perc!

The purpose of this fact sheet is to provide a general overview of the environmental regulations affecting dry cleaners which use perchloroethylene (perc) in dry-to-dry systems. It does not replace the actual regulations and does not eliminate any person's responsibility to fulfill any legal obligation under the Illinois Environmental Protection Act or the promulgated regulations.

Note: This document and the related poster insert are also available in Adobe Acrobat PDF format.

Hazardous Waste Regulations

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Nationally, dry cleaners are the largest source of perc emissions.

What is Hazardous Waste?

Some dry cleaning wastes pose a potential hazard to human health and the environment when improperly handled. The most commonly generated hazardous wastes in the dry cleaning industry include the following:

  • Spent perc
  • Used filters and filter media
  • Spent carbon and cartridges from carbon adsorbers
  • Still residues (evaporator or cooker sludge)

What Type of Hazardous Waste Generator am I?

drum.gif (2639 bytes)TIP: 30 gallons (about half of a 55 gallon drum) of special waste with a density similar to perc weighs about 400 lbs.

The hazardous waste regulations that apply to you depend upon the amount of hazardous waste you generate per month. You fall under one of the following categories of hazardous waste generators:

  • Conditionally exempt small quantity generators (CESQG) generate less than 100 kilograms (220 pounds) per month of hazardous wastes

  • Small-quantity generators (SQG) generate 100 to 1,000 kilograms (220 to 2,200 pounds) per month of hazardous wastes

  • Large-quantity generators (LQG) generate over 1,000 kilograms (2,200 pounds) per month of hazardous wastes

To determine your hazardous waste generator category, add up the weight or volume of all your hazardous wastes generated for the month. This information can be verified by comparing the amount to your waste manifests. The total gives you your generator category for the month.

What Requirements Apply to CESQGs?

  • Identify all hazardous wastes that you generate

  • Hire a licensed special waste hauler to transport your hazardous wastes to a facility permitted to receive hazardous waste.

  • Do not accumulate more than 1,000 kilograms (2,200 pounds) of hazardous wastes on your property at any time

What Requirements Apply to SQGs?

  • Accumulate hazardous wastes in containers such as 55-gallon drums or tanks

  • Do not store hazardous wastes on your property more than 180 days unless it will be transported greater than 200 miles from your business, in which case you may store the wastes for up to 270 days

  • Do not accumulate more than 6,000 kilograms (13,200 pounds) of hazardous waste on your property at any time

  • Register with the Illinois Environmental Protection Agency (Illinois EPA) using a Notification of Hazardous Waste Activity form

  • Make sure all your hazardous wastes are packaged and labeled correctly prior to transport. Although you are responsible for packaging and labeling your wastes, ask your transporter for assistance with this requirement

  • Hire a licensed special waste hauler to transport your hazardous wastes to a permitted hazardous waste facility using the Uniform Waste Manifest or sign a tolling agreement with a recycling facility.


Although a licensed transporter ships your wastes, YOU are responsible for ensuring that the transporter and the facility that accepts your waste manage your wastes properly. Call the Office of Small Business at 1-888-EPA-1996 for tips on how to make this determination.

Are There Any Requirements for the Containers I Use to Accumulate Hazardous Waste?

  • Label each container with the words "HAZARDOUS WASTE," and mark each container with the date the container becomes full

  • Use a container made of or lined with a material that is compatible with the hazardous waste stored in it

  • Keep all containers of hazardous waste closed during storage except when adding or removing waste

  • Do not open, handle, or store containers in a way that might rupture them, cause them to leak, or otherwise fail

  • Inspect areas where containers are stored at least weekly. Look for leaks and for deterioration caused by corrosion or other factors

  • Maintain the containers in good condition. If a container leaks, put the hazardous waste in another container, or contain it in some other way that complies with U.S. Environmental Protection Agency regulations.

  • Do not mix incompatible hazardous wastes or materials unless precautions are taken to prevent potential hazards

Should I be Prepared for an Emergency?

YES, all SQGs must establish safety guidelines and emergency response procedures. SQGs must also be equipped with the following:

  • An internal communication or alarm system capable of providing immediate emergency instructions to all personnel
  • A telephone or two-way radio capable for use in requesting emergency assistance from local police and fire departments
  • Portable fire extinguishers, fire control devices, spill control materials, and decontamination supplies
  • Adequate water volume and pressure to supply water hoses, foam-producing equipment, and automatic sprinklers

What Requirements Apply to LQGs?

If you are an LQG, call the Office of Small Business at 1-888-EPA-1996 to obtain a complete list of requirements that apply to you.

Air Regulations

Is My Business Affected?

As a perc dry cleaner, you are affected by the perc rule that applies to air emissions in the state of Illinois. As a dry cleaner that uses perc, you should have submitted an Initial Notification Report Form in June 1994 to Illinois EPA. If you opened your business after June 1994 and are a new dry cleaning facility, you should submit this form immediately. This form can be obtained by calling the Office of Small Business at 1-888-EPA-1996.

What Do I Need to Know?

After submitting the Initial Notification Report Form, you should answer the following questions below to determine your other perc rule requirements:

What type of dry cleaning business do I own?

Dry to Dry: Dry-to-dry systems use one machine to both wash and dry fabrics. Clothes that are cleaned go in dry and come out dry. If all of your dry cleaning machines are dry-to-dry systems, you own a dry-to-dry business.

Transfer: A transfer system has a separate washer and dryer. If all of your dry cleaning machines are transfer systems, you own a transfer business.

Combination: If the dry cleaning systems at your business are a combination of dry-to-dry and transfer systems, you own a combination business.

It is important to note that all transfer machines installed on or after September 23, 1993, should no longer be used. If you are still using transfer machines or a combination system, call the Office of Small Business at 1-888-EPA-1996 for your air requirements.

What is the total amount of perc I purchased over the last 12 months?

Add up the amount of perc that you have purchased for the last 12 months. If you do not keep perc purchase records, you can estimate this amount. However, you must keep all records of future purchases of perc, including purchase receipts, for a minimum of 5 years.

When did I install my dry cleaning systems?

For each of your dry cleaning systems, determine if:

  • Your system is existing, which means it was installed before September 23, 1993, or
  • Your system is new, which means it was installed on or after September 23, 1993

What Do I Do Next?

Now that you have answered these questions about your business, you can use this information to determine what your pollution control, monitoring, recordkeeping, pollution prevention (P2), and air permitting requirements are according to the perc rule.

Rule #1
What are My Pollution Control Requirements?

Dry-to-Dry Systems

Perc Purchased
(gallons per year)
New System
Pollution Control
Existing System
Pollution Control
Less than 140Refrigerated condenserNo control required
140 to 2,100Refrigerated condenserRefrigerated condenser or
carbon adsorber that was installed before 9/22/93
Over 2,100Refrigerated condenser and
supplemental carbon adsorber
Refrigerated condenser or
carbon adsorber that was installed before 9/22/93

Rule #2
What are My Monitoring Requirements?

If you are required to have pollution control equipment on your dry-to-dry machines, you must monitor the performance of the machines according to the poster included with this fact sheet. Be sure to record any repairs or adjustments in a logbook.

Rule #3
What are My Record-Keeping Requirements?

You must keep the following records for a minimum of 5 years:

  • A log that lists what you find when looking for leaks and any repairs or adjustments you make to your system
  • The amount of perc you purchased for the past 12 months (you should calculate the amount of perc you purchase each month)
  • All perc purchase receipts

Rule #4
What are My Pollution Prevention (P2) Requirements?

As a perc dry cleaner, you must use the following P2 practices as a requirement of the perc rule:

  • Conduct an equipment inspection program that detects leaks and necessary repairs weekly if you are required to install pollution control equipment. If you are not required to install pollution control equipment, conduct the program every 2 weeks. Keep a written log of the equipment inspection program

  • Inspect the following system components for leaks:

    • Hose and pipe connections, fittings, couplings, and valves
    • Cartridge filter housings
    • Filter gaskets and seating - Door gasket seating
    • Solvent tanks and containers
    • Water separators
    • Muck cookers
    • Stills
    • Exhaust dampers
    • Diverter valves

  • If leaks are found during the inspection, you must:

    • Repair the leaks within 24 hours
    • Order parts, if needed, within 2 days
    • Install ordered parts within 5 days of receipt of parts
    • Keep a written log of all repair work

  • Operate and maintain all dry cleaning equipment according to the manufacturer's instructions, and keep the operating manuals and design specifications at your business

  • Post the Good Housekeeping Practices poster included with this fact sheet near your machines

Do I Need an Air Permit?

If you use more than 30 gallons of perc per month, you must obtain an Illinois EPA air operating permit. For more information on air permits, please call the Office of Small Business at 1-888-EPA-1996.

Water Regulations

Generally, the process wastewater of concern at perc dry cleaners is separator water which contains small amounts of perc. If your business is connected to a septic tank, you should never discharge your process wastewater, such as separator water, to the septic tank. If your business is connected to the city sewer system, contact them to determine their requirements for your process wastewater discharges.

For additional information on YOUR hazardous waste, air, and water requirements, please call the Office of Small Business at 1-888-EPA-1996. All calls are considered confidential and the caller can remain anonymous.

See also:

  • Poster insert (Monitoring Requirements for Dry-to-Dry Systems and Good Housekeeping Practices for Perc Dry Cleaners)

Note: This document and the related poster insert are also available in Adobe Acrobat PDF format.