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About NDEP's Hazardous Waste Program & the dry cleaning industry: The Nevada Division of Environmental Protection (NDEP) enforces both state and federal hazardous waste regulations authorized under the Resource Conservation and Recover Act (RCRA). Compliance is accomplished through site inspections, enforcement actions, and technical assistance. As potential generators of hazardous waste, dry cleaning facilities are inspected by NDEP and/or local officials. Inspections conducted by local officials follow state procedures.

About RCRA: RCRA was instituted by Congress in 1976. Regulations implementing the Act were promulgated by U.S EPA in 1980. In 1981 and in lieu of EPA, the State of Nevada was granted interim status to enforce RCRA (i.e., cradle-to-grave management of hazardous and solid waste). Nevada acquired final RCRA authorization in 1985. (See more about RCRA from US EPA —and/or — the University of Nevada's Business Environmental Program.)

Regulation of Dry Cleaners: For regulatory purposes, dry cleaners are categorized by the amount of hazardous wastes including waste solvent (PCE) they generate each month. NDEP inspects large quantity generators annually and small quantity generators every two years.

Inspections consist of an unannounced on-site evaluation to determine compliance with all applicable RCRA regulations and permits. Container management regulations (such as labeling, compatibility and leaks) and record review (such as disposal records, emergency contact information and container inspection records) are the primary focus of an on-site evaluation.

Large Quantity Generators (LQGs) are defined as facilities that generate more than 2,200 pounds of hazardous waste per month -- NDEP inspects LQGs annually. Facilities that generate more than 220 pounds per month, but less than 2,200 are classified as Small Quantity Generators (SQGs). NDEP and/or local county officials inspect all SQGs once every two years.

Facilities that generate less than 220 pounds of hazardous waste per month are classified as Conditionally Exempt Small Quantity Generators (CESQG). CESQG are usually inspected by local county officials. Of note, 220 pounds of PCE is equivalent to about 20 gallons of liquid mass.


Regulations under the Clean Water Act (CWA): Publicly Owned Treatment Works (POTWs) commonly known as sewage treatment plants, collect wastewater from homes, commercial buildings, and industrial facilities. Through a series of pipes, known as the collection system, wastewater is transported from the point of origin to the [sewage] treatment plant. At the treatment plant, harmful organisms and other contaminants are removed from the sewage, so the effluent can be discharged safely to the receiving water. In the Reno metro area, the receiving water is the Truckee River; for the Las Vegas Valley, the receiving water is Lake Mead.

Reno Sparks POTW Through a permitting process, the Division of Environmental Protection regulates POTWs with permits covering the collection system, the treatment process, and the effluent discharge from the treatment plants.

Generally, POTWs are designed to treat domestic sewage. However, POTWs also receive wastewater from commercial and industrial users, and these users (such as dry cleaners) are required by the respective POTWs to ensure hazardous wastes like PCE are not disposed in the sewer system. It's worth noting, however, that trace amounts of PCE are often found in sewer systems.

As way of background, under the Clean Water Act (CWA), a commercial or industrial user must obtain authorization to discharge to a POTW collection system under a pretreatment program. The CWA requires implementation of pretreatment standards to control pollutants from the commercial and industrial users that may pass through the plant or interfere with POTW treatment processes.

In the State of Nevada, the communities of Carson City, Clark County, Elko, Henderson, Las Vegas, Lyon County, Reno, and Sparks have received authorization from the US EPA to administer local pretreatment programs. These local governments have adopted pretreatment ordinances that govern permitting programs, inspections, enforcement, etc., of non-domestic discharges (such as PCE) to their collection systems.


Non Regulatory Business Assistance Program: NDEP has implemented a business assistance program which offers free and confidential counseling on environmental compliance and technical assistance issues to business in Nevada including dry cleaners. The program is operated for NDEP through a longstanding contract with the University of Nevada's Business Environmental Program (BEP).

BEP assistance includes and environmental information phone line (800 882-3233), onsite consultations, publications and training seminars which target various industries. Seminars covering regulatory compliance and best management practices for dry cleaning facilities have been conducted in both Reno and Las Vegas. For more information about activities undertaken to assist dry cleaners see the section on this website titled NDEP Initiatives.


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