2004 Dry Cleaner ERP Final Report

Final Report
Michigan Environmental Results Program
for the
Dry Cleaning Sector

Prepared by:
James A. Ostrowski
Office of Pollution Prevention and Compliance Assistance
Michigan Department of Environmental Quality
517.241.8057
ostrowskij2@michigan.gov

October 2009

Final Report for State Innovation Grant (SIG) PI96572-01
Project Title:

Michigan Environmental Results Program (MERP) – Dry Cleaning Sector
(PI96572-01)

Grant Amount:

$199,200

Grant Period:

January 2005 through March 2009

Geographic Focus: Michigan - Statewide
Lead Agency:

Michigan Department of Environmental Quality (MDEQ)
Office of Pollution Prevention and Compliance Assistance
P.O. Box 30457
Lansing, Michigan 48909-7957

Project Contact:

James A. Ostrowski
Office of Pollution Prevention and Compliance Assistance
Michigan Department of Environmental Quality
525 W. Allegan Street, 1N
Lansing, Michigan 48933
517.241.8057
ostrowskij2@michigan.gov

QA Manager:

Marcia Horan
Office of Pollution Prevention and Compliance Assistance
Michigan Department of Environmental Quality
525 W. Allegan Street, 1N
Lansing, Michigan 48933
517.373.9122
horanm@michigan.gov

EXECUTIVE SUMMARY
In 2005, the Michigan Department of Environmental Quality (MDEQ) was awarded a State Innovation
Grant (SIG) from U.S. Environmental Protection Agency (EPA) to develop and implement an
Environmental Results Program (ERP) for Michigan’s dry cleaning sector. The grant funding was to
be used for this project’s two major components: (1) the implementation of a pilot ERP for Michigan’s
Dry Cleaning Sector, which would incorporate the relevant air, water, and waste requirements into a
multi-media, self-certification, compliance assistance package; and (2) the development of an
electronic data collection tool that could be used to manage data collected from the ERP. This tool
was to be made transferrable to other interested states.
A full ERP cycle, including baseline inspections, facility assistance, self-certification, and postcertification inspections were completed from 2006 to 2008. Data analysis of the results showed little
improvement in compliance with air quality requirements, but significant improvements in compliance
in several of the waste and wastewater requirements.
The MDEQ worked with a contractor to develop a data management system that could be used to
collect and manage data from ERP related activities. The functional aspects of this program were
completed in March 2009 1 . The program includes a web based administrative component and a field
application that is used to collect inspection data.
Dry cleaners in Michigan have been inspected for years using traditional inspection methods. The
ERP for dry cleaners was a first-of-its-kind endeavor for Michigan and allowed the MDEQ to
experiment with an alternative method of managing dry cleaning compliance. While it is still unclear as
to what the future holds for ERP in Michigan, this project has demonstrated Michigan’s ability to
successfully implement an ERP. It will serve as a model for our state and others that wish to use
alternative means to manage small business sectors where it may not be feasible using traditional
methods. Thanks to the SIG and the resulting pilot project, Michigan stands ready to use ERP as a
management tool for small business sectors throughout the state when the time is ready and
opportunity presents itself.

1

While the functional components of the ERP data management program were complete in March 2009, the
MDEQ continued to work with the consultant to resolve several issues associated with migrating existing data
into the new system. This issue took much longer than expected to fully resolve. The system was placed into the
MDEQ production environment in August 2009.

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3

TABLE OF CONTENTS
Purpose and Goals of Project.......................................................................................................... 5
Background...................................................................................................................................... 5
ERP Implementation........................................................................................................................ 7
Summary of Project Milestones/Tasks................................................................................. 7
Baseline Inspections ............................................................................................................ 7
Facility Assistance ............................................................................................................. 10
Self-Certification................................................................................................................ 12
Post-Certification Inspection .............................................................................................. 14
Statistical Analysis ............................................................................................................. 15
Data Input and Management (Development of ERP software tool) ................................... 15
Michigan ERP Project Results....................................................................................................... 16
Air Quality .......................................................................................................................... 16
Waste................................................................................................................................. 18
Wastewater ........................................................................................................................ 21
Self-Certification................................................................................................................. 24
Observation and Recommendations ............................................................................................. 26
Future of Dry Cleaning ERP in Michigan ....................................................................................... 29
Financial Summary ........................................................................................................................ 30
Appendix A ......................................................................................................... Statistical Analysis
Appendix B .......................................................................... Data Management Software Overview

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Michigan SIG Final Report

PURPOSE AND GOALS OF PROJECT
The Michgian Department of Enivronmental Quality (MDEQ) developed the
Environmental Results Program (ERP) for dry cleaners to aid
owner/operator understanding of all applicable environmental regulations in
the dry cleaning sector, to improve facility compliance with these
regulations, and to enhance sector-wide use of pollution prevention
activities and best management practices. The MDEQ expected to aid in
the development and transfer of useful template ERP materials to other
sectors and states as it builds on similar materials and experiences shared
by the Massachusetts’s Department of Environmental Protection dry
cleaning ERP. Through Michigan’s ERP, MDEQ leveraged internal and
external resources, including partnerships with the local dry cleaning trade associations, dry cleaning
equipment vendors, and dry cleaning businesses.

BACKGROUND
The dry cleaning industry is a service industry for the cleaning of garments, draperies, leather goods,
and other fabric items. The number and size of dry cleaning firms varies. Commercial facilities are by
far the most prevalent and include full service, retail operations located in shopping centers and near
densely populated areas. Industrial dry cleaners operate the largest facilities which are often part of a
business that rents uniforms, towels or other garments.
Two general types of cleaning fluids are used in the industry: petroleum solvents and synthetic
solvents. Petroleum solvents are combustible hydrocarbon mixtures similar to kerosene. Operations
using petroleum solvents are known as petroleum plants. Synthetic solvents, the most common of
which is Perchloroethylene (PERC) are nonflammable halogenated hydrocarbons. PERC and other
solvents may be emitted from dry cleaning machines during operation of the units or during the
solvent reclamation processes. The dry cleaning industry is the most significant emission source of
PERC in the United States. In Michigan, the vast majority of the cleaners use perchloroethytlene
solvent in their dry cleaning operations; however, there are also some that use petroleum solvents
and alternative solvents. At the start of Michigan’s ERP project, there were 858 dry cleaners identified
as using perc throughout the state. At the time the Post-certification sample was developed, there
were only 767 PERC cleaners.
The National Emission Standard for Hazardous Air Pollutants (NESHAP) for Perchloroethylene Dry
Cleaning Facilities and the New Source Performance Standards (NSPS) for petroleum solvent dry
cleaning facilities are two federal standards established under the Clean Air Act Amendments of 1990
to control air emissions of PERC and petroleum solvents from new and existing dry cleaning
facilities. Each standard contains a variety of emission control, monitoring, operation and
maintenance, recordkeeping, reporting and compliance requirements,
depending on the emission source type.
The Dry Cleaners are monitored by the Dry Cleaning Program of the Air Quality
Division, Michigan Department of Environmental Quality. The MDEQ Dry
Cleaning Program is unique in that they inspect every Class IV
(perchloroethylene) establishment annually. Before a new dry cleaning plant is
established or equipment is installed, or an existing establishment is modified,
prior approval must be obtained from the Dry Cleaning Program. The
inspectors in the MDEQ Dry Cleaning Program have a thorough knowledge of
the dry cleaning process and the rules that apply to this activity. When
Dry Cleaning Inspector

Michigan SIG Final Report

5

Michigan’s dry cleaning ERP began in 2005, there were four inspectors assigned to various regions of
the state. These inspectors assisted the MDEQ with the development of the guidance materials and
conducting baseline and post-certification inspections for the ERP. At the time the post-certification
inspections were conducted in 2008, there were three inspectors.
There are two organizations that represent the dry cleaners in the state: the Michigan Association of
Laundering and Drycleaning (MILD) and the Korean Drycleaning Association (KDA). Both of these
organizations were instrumental in reviewing the guidance developed by the DEQ, and implementing
the ERP. Both associations were very supportive of the ERP concept and hosted several events to
assist with the education of facilities.
In 2005, the MDEQ was awarded a $199,200.00 State Innovation Grant (SIG) from U.S. EPA to
develop and implement its dry cleaning ERP. The state of Michigan was required to provide a match
of $100,000.00. Essentially, there were two components funded by the grant:
(1) The implementation of a pilot ERP for Michigan’s Dry Cleaning Sector, which would incorporate
the relevant air, water, and waste requirements into a multi-media, self-certification, compliance
assistance package.
(2) The development of an electronic data collection tool that could be used to manage data collect
from the ERP. This tool was to be made transferrable to other interested states.

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Michigan SIG Final Report

ERP IMPLEMENTATION
The major tasks and timeline associated with the Michigan Environmental Results Program (MERP)
are outlined in Table 1. A detailed description of how each of these tasks was executed in provided in
the sections following the table.
Table 1: Schedule of Major Project Tasks
Task Name

Task Description

Start Date

Baseline
Inspections

Inspections at facilities to establish a baseline for performance
measures. Facilities selected at random from the entire targeted
population based upon sample design from statistical methodology.

July 2006

Dec 2006

Baseline Analysis

Analysis of inspection data to establish a baseline for the project's
performance measures.

Dec 2006

Feb 2007

Facility
Assistance

Development and delivery of compliance/technical assistance to
facilities, which is expected to take the form of workbooks, fact
sheets, and/or workshops.

Jan 2007

Sept 2007

Self-certification

Implementation of a voluntary facility self-certification approach. Selfcertification refers to the submission of a record of a facility’s
compliance and beyond-compliance practices.

Aug 2007

Sept 2007

Analysis of self-certification data.

Sept 2007

Oct 2007

Post-Certification
Inspections

Inspections at facilities to establish whether sector performance
measures (and other measures) have changed since the baseline.
Inspection data also used to cross-check self-certification data at
inspected facilities. Facilities selected at random from the entire
universe of facilities, based upon sample design from statistical
methodology.

June 2008

Nov 2008

Data Analysis

Analysis of baseline, self-certification, and post-certification data to
understand change in facility performance and overall outcomes of
interest. Assessment of project efficiency.

Dec 2008

April 2008

Data Input and
Management

Development and implementation of an approach to cost-effectively
input and manage the MERP data, including primary and secondary
data. Primary data consists of data from inspection reports and
facility forms (including self-certification forms). Secondary data
sources include lists of facilities from regulatory and private-sector
databases.

Analysis of
Self-certification
Results

End Date

March 2009
(functional)
Nov 2005
Aug 2009
(Production)

Baseline Inspections
In a random sample, over 300 facilities were identified using statistical methodology developed by
Cadmus Group, Inc. (methodology developed 12/23/2005). Four inspectors from the Dry Cleaning
Program were available to collect the baseline inspection data. Each of these inspectors was
responsible for a specific geographical region in Michigan; therefore, the sample was stratified by
inspectors to ensure that a proportional amount of facilities were sampled in each region by each
inspector. Table 2 shows the stratified sample.

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Table 2: Baseline Sample
Staff
Jack
Karl
Jong
Joe
Total

Number of
Establishments
138
123
298
299
858

Sample

Proportion

48
43
104
105
300

34.8%
35.0%
34.9%
35.1%
35.0%

Baseline Inspection Audit Form: The baseline inspection questions were finalized before all
baseline inspections began. It was important that the questions that appeared in the baseline
inspections matched the questions that were to be used during the self-audit period. We worked
extensively with the MDEQ Dry Cleaning Program, the dry cleaning trade associations, and dry
cleaning establishments to ensure that the questions in the audit were accurate, simple, and
applicable to the types of dry cleaners in Michigan (i.e. some requirements from the federal NESHAP
were not included because they are not applicable to dry cleaners in Michigan). The questions were
used to develop an electronic data collection tool to be used during the baseline inspections (see next
item).
Baseline Inspection Data Collection Tool: To make the collection of baseline data more efficient
and consistent, MDEQ developed an access database tool that could be used to collect the data. This
tool contained all the audit questions for each facility that was to be audited. Inspectors installed the
program onto their pen tablets and completed all applicable questions when at the facility. At the end
of each month the inspectors submitted a copy of their database, which included the audits for all the
facilities they inspected over the previous month. This data was compiled into a master database.

ERP Baseline
Inspection Data
Collection Tool

Inspector Training: Inspectors from the MDEQ Dry Cleaning Program were trained on how to use
the electronic version of the audit forms and collect the baseline data. In July 2006 all inspectors
accompanied two staff from the MDEQ’s Waste and Hazardous Materials Division on an on-site
training visit to two dry cleaning facilities. The purpose of these visits was to familiarize inspectors with
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Michigan SIG Final Report

some of the waste issues encountered at a dry cleaning facility and to familiarize them with the
associated waste questions in the audit.
Inspections: Statewide baseline inspections at 311 facilities were conducted from August to
December 2006. Data was collected electronically using the tool identified above and reported on a
monthly basis. Inspection data was added to a master database. Several meetings were held with the
inspectors to discuss the status of the inspections and to answer questions pertaining to data
collection.
The inspectors conducting the baseline inspections did not encounter any major set backs; however,
the following items were discovered and were subsequently addressed:
•

It was discovered that several of the facilities identified for baseline inspection had gone out of
business. This decrease in the number of dry cleaners is a statewide trend and was noted in
the development of the sample for the post-certification inspections.

•

During inspections, the inspectors identified many changes that needed to be made to the
audit based on their field testing of the questions in the audit. These suggestions were later
incorporated into the self-certification audit and post-certification inspection. Every effort was
made to ensure that the intent of each question remained consistent so that data from the
baseline sample and subsequent samples could be compared easily.

Data Analysis: The analysis of the baseline data did not provide any major revelations as to this
sectors compliance with air quality requirements. The baseline data identified that a significant
number of dry cleaners were not keeping the appropriate records necessary to demonstrate
compliance with the NEHSAP. However, this deficiency was already well know by the program and
has been a problem ever since the NESHAP went into effect. Since our inspectors had not been
collecting data on waste and wastewater requirements, the data did point out some compliance issues
that the MDEQ was not aware of. The baseline data showed that many of the cleaners sampled
generated more that 220 lbs of hazardous waste per month, making them small quantity generators.
While this number was higher than expected, it was most likely due to poor recordkeeping. In reality,
many of these sources generate less than 220 lbs of hazardous waste per month; however, they lack
sufficient records to justify their claim. Due to this revelation, MDEQ included a detailed explanation of
how to calculate monthly waste generation in the self-audit workbook and associated training. Other
data points of interest were related to wastewater disposal. Our data showed that very few sources
had permission or authorization to dispose of their wastewater through the sewer to their wastewater
treatment plant. While the MDEQ does not regulate discharges to the sewer system, it is important
that sources are informed of this requirement. The follow up guidance to the sector addressed the
details on this requirement.
In November 2007, an issue with MDEQ’s baseline data was discovered. The issue pertained to
inconsistencies of when certain inspections were carried out. MDEQ established the window for
conducting the baseline inspections from July – December 2006; however, some inspections were
conducted outside of the baseline inspection window. This was discovered during review of the data
with U.S. EPA and an ERP consultant, while compiling information for the 2008 ERP States Produce
Results Report. Ultimately, MDEQ decided to remove a significant amount of data from the baseline
sample to ensure statistical validity. The number of valid inspections was reduced to 262 sources as
opposed to 300 sources as a result of this mishap. Fortunately, the problem was discovered soon
enough so we could make the necessary adjustments to our data and better prepare our inspectors
for the post-certification inspections.

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9

Facility Assistance
The development of the compliance assistance materials was a coordinated effort that involved
inspectors from the MDEQ Dry Cleaning Program, the Michigan Institute of Laundering and
Drycleaning (MILD), the Korean Dry Cleaning Association (KDA), and individual dry cleaning
establishments. Drafts of the checklist and workbook were prepared and then reviewed by these
stakeholders.
In July 2007, the Self-Certification Workbook and forms were finalized.
Fortunately, the Michigan Dry Cleaning Program has an inspector fluent in
Korean and as a result, a Korean version of the certification forms and cover
letter were developed. A Korean version of the workbook, however, was not
created due to time constraints and the availability of the inspector to do the
translation. Future revisions of the workbook will most likely include a Korean
version. The Korean Drycleaning Association expressed their appreciation for
the MDEQ’s willingness to address the language barrier by providing a
Korean version of the certification. The printing of the workbook and audit
forms were funded under the SIG. The MDEQ printed 1,100 copies of each
Self-Certification Workbook
item, which was enough to provide each dry cleaner in the state with a copy
of the materials as well as some extras to have available for the associations,
inspectors, and workshops. An electronic version of all the self-certification material was posted at
www.michigan.gov/deqenvassistance (click on “Dry Cleaning Workbook”) including a template version
of the audit forms, which facilities could use to electronically complete the forms and return via e-mail.
The printing/mailing costs associated with the self-certification are detailed in the Table 3.
Table 3: Costs for Printing and Mailing

Item Printed/Mailed
Self-Certification Workbook
Self-Audit Form (English)
Self-Audit Form (Korean)
Return envelope
Mailing envelope
Cover letter
Reminder Card
Packet Mailing to Cleaner
Reminder Card Mailing
Submittal Postage Paid Return
Total

Number
Printed/Mailed
1,100
1,100
1,100
1,000
1,000
870
900
870
870
# returned
through 9/30/07

Cost
$2,164.14
$716.05
$716.05
$246.21
$139.08
$100.83
$67.13
$1,781.51
$10.80
$187.94
$6,129.74

It was decided that the MDEQ would not organize any formal workshops to accompany the
self-certification. This decision was made based on our experience with conducting workshops with
this sector in the past. During past attempts at outreach through workshops, a lot of time and money
was invested in attempting to provide training only to have few facilities participate. As an alternative,
the MDEQ developed an on-line training program that facilities could view at their leisure, at no cost,
and anonymously. The on-line training can be viewed at www.michigan.gov/deqenvassistance (click
on “Dry Cleaning Workbook” then “Self-Audit On-line Training”). The on-line training was completed
and posted on the internet in September 2007 (half-way through the certification window). The
availability of the on-line training was advertised in a reminder card that was mailed to all facilities
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Michigan SIG Final Report

during the first week of September as well as through the MILD Web site. Although we were not able
to provide the training until September, we believe that facilities still had ample time to view the
information. Unfortunately, we were not able to track how many facilities actually used the on-line
training. Future on-line training will include a function that allows tracking of the number of users and
even include an on-line survey that users can complete. In addition to the on-line training, MILD
volunteered to organize two training workshops on the audit, which was our hope when we had initial
discussions about the project with them. Workshops hosted by MILD
were held in Grand Rapids and Farmington Hills. At each of these
sessions we walked attendees through the self-certification forms and
answered any questions that came up. Many of the issues discussed at
these sessions have been summarized in the OBSERVATIONS AND
RECOMMENDATIONS section of this report. In addition to these two
sessions, the MDEQ conducted a presentation at MILD's Annual Meeting
in Port Huron on July 27, 2007 and one of the inspectors was present at
two of the KDA meetings to answer questions about the audit in
September 2007. Another meeting was held with a major drycleaning
supply distributor in August 2007. The purpose of this meeting was to
educate sales representatives about ERP and how it will impact their
customers. This meeting was recommended and arranged through one of
the MILD members.
MILD Meeting Announcement

Article in KDA Newsletter about MDEQ-KDA Meeting on ERP

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11

Self-Certification
The self-certification period began on August 1, 2007. All dry cleaners in the state were mailed a
packet of material that included a cover letter, workbook, forms, and a self-addressed, postage paid
return envelope (see audit materials on the following page). Facilities were asked to submit their
completed self-certification forms by September 30, 2007. This date gave the cleaners exactly two
months to review the material and submit the forms. We believed that the two-month window would
allow enough time to provide outreach to the sector while also giving some amount of urgency to the
response (i.e., we felt that giving cleaners more than two months would increase the likelihood that
they would lose the material or put off doing it indefinitely). During the self-certification period, MDEQ
staff responded to numerous phone calls from facilities. At the beginning of September, a post card
was sent to facilities to remind them of the deadline for submission and availability of on-line training.
Many more audits were returned than anticipated. Approximately 323 were returned by the deadline
and another 173 were received in the two weeks following the deadline. The final count was 496
self-certification forms returned, which was approximately 58% of the dry cleaners in Michigan. Data
from each submittal was entered manually into a Microsoft Access database. The database not only
captured the response to each question but also the information provided on the return to compliance
plan and makeup of the self-certification pool (e.g., location, Korean or English version completed,
etc.), and when the certifications were submitted to address the question, “Did most wait until the last
week to submit or were they evenly dispersed throughout the certification window?”
When the self-certification packages were sent out to facilities,
they were told that the MDEQ would send them a certificate
recognizing their participation in this program if they completed
and returned the forms. In October 2007, we sent a thank you
letter and certificate to all facilities that completed and returned
self-certification forms.
In general, the MDEQ received positive comments about the
self-certification questions (i.e., easy to understand and follow);
however, we also discovered some certification questions that
needed to be improved/changed as a result of discussions we had
with drycleaners and the association.

ERP Certificate

All data that was collected from facilities was entered into a database system by two staff members.
The results from the self-certification can be found in Appendix A. Below are some of the main data
points from the results:
•

A total of 496 self-certification forms were returned, which is approximately 58% of the dry
cleaners in Michigan.

•

The vast majority of sources felt they were in compliance with all or most of the air and waste
requirements they are subject to. This was in direct contrast to the data that was gathered
during the baseline and post-certification inspections.

•

200 Return-to-Compliance Plans were received.

•

27 sources used the Korean version of the self-audit.

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Michigan SIG Final Report

Self-Certification Documents

Self-Certification Letter from DEQ (English)

Workbook

Self-Certification Letter from DEQ (Korean)

Self-Certification Forms (English)

Self-Certification Forms (Korean)

Click on picture above to view actual document

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Post-Certification Inspection
Working with an ERP consultant in 2007, it was decided that it would be best to conduct the postcertification inspections as close to the time that we conducted the baseline inspections as possible,
which would be summer/fall 2008. It was decided that an inspection window of June-October 2008
would be sufficient. Since our dry cleaning inspectors set their inspection schedule for the year by
December 31, it was necessary that the random sample be developed by December 31 so that the
inspectors could be provided with a list of sources they should and should not visit prior to the postcertification window. Developing the sampling methodology for the post-certification inspections was
somewhat complicated due to several factors: a significant reduction in the number of dry cleaners
since the baseline sample, one less inspector, and the reassignment of the remaining three inspectors
to territories different than what they covered during the baseline sample. Taking all these factors into
consideration, we were able to develop a good sample of 250 sources, which were then divided up
amongst the inspectors. The sample was stratified to account for changes in inspector facility
assignment (i.e. facilities that were assigned to a particular inspector during the baseline sample may
have changed during the post-certification sample). The stratified sample is shown in Table 4. A
detailed explanation of the MDEQ’s sampling methodology can be found in Appendix A.
Table 4: Post-Certification Inspection Sample
‘08
inspector
Jack
Jack
Joe
Joe
Jong
Jong
Jong
Jong

‘06
inspector
Jack
Karl
Joe
Jong
Jong
Jack
Joe
Karl

# of
inspections
106
75
220
74
193
10
60
29
767

switched
inspections
0
75
0
74
0
10
60
29
248

inspector
subtotal
switched

switched/
inspector
total

75

41%

74

25%

99

34%

32%

08 by 06
proportional
sample
35
24
72
24
63
3
20
9
250

Sample Size
Recommended,
by Stratum
35
24
72
24
50
10
20
15
250

Soon after the post-certification sample was developed, a
meeting with the inspectors was held to explain the sampling
methodology and provide them each with a list of all their
sources including those that were to be included in the
sample. Inspectors were briefed on the importance of waiting
to visit the facilities identified as part of the sample until
between June-October 2008. The inspectors made changes
to their yearly inspection schedules to accommodate the postcertification inspection window.
Three inspectors from the MDEQ, Air Quality Division’s Dry
Cleaning Program completed post-certification inspections at
272 randomly selected facilities from June 2008 to November
2008. Data from each inspection was gathered on hard-copy
forms or electronic templates of the forms. Inspectors were
instructed to submit them periodically as they completed a
batch. A Microsoft Access database was created to input the
inspection results. No major problems or set backs were
reported during this task.
Post-Certification Inspection Form

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Michigan SIG Final Report

Statistical Analysis
In December 2008, data collected from baseline inspections, self-certification, and post-certification
inspections were submitted to The Cadmus Group, Inc. for review and analysis. A detailed analysis of
results was provided to the MDEQ in March 2009. The results from the analysis are summarized in
the MICHIGAN ERP PROJECT RESULTS section of this report. The actual detailed analysis of the
data is contained in Appendix A of this report.

Data Input and Management (Development of ERP software tool)
A major financial component of the SIG was dedicated to the
development of a software program that could be used to collect and
manage data from the ERP. A stipulation of the funding was that the
program developed had to be transferable, meaning that the code is not
proprietary and could be shared with other states for use in the
development of their own program. In early 2006, enfoTech Consulting
was selected as the contractor to develop the program. However, the
contract was not finalized until October 2006.

Field Assistant Collection Tool

It was decided that the system would be divided into two components: a web-based administrative
component and a field assistant program to be used to gather data in the field. Data gathered via the
field assistant would then be synced to the administrative system using a data sync function.
The development of this system took much longer that expected due to a number of set backs that
occurred throughout the grant period. Most of these setbacks can be attributed to the limited number
of staff available to test the system, and a number changes the contractor made to the staff managing
the program, as well as internal problems related to coordinating upgrades and changes to the beta
application with our Department of Information Technology. The system was considered functionally
complete in March 2009; however the MDEQ was not able to put the new software into production
until August 2009. This delay was due to several complications that occurred with migrating existing
dry cleaning data into the new system. The software is transferable to any state that wishes to use it.
Many components are specific to Michigan’s program; however, the software can be altered and
manipulated to fit another state’s program needs. Appendix B provides a detailed overview of the
system and how it works.
The MDEQ developed a video tutorial that provides an overview of the
system. The video is approximately 12 minutes. View the video by going to
http://www.screencast.com/t/ujjEkUnUvt9 or click HERE.
Note: Headphones or speakers should be used to hear the audio. If you
experience problems please contact James Ostrowski at
ostrowskij2@michigan.gov or 517.241.8057

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MICHIGAN ERP PROJECT RESULTS
Michigan’s Drycleaning ERP contained compliance questions related to perchloroethylene
drycleaning machines, petroleum solvent drycleaning machines, waste, storage tanks, wastewater,
and safety. The primary focus of the ERP was on three media – air, waste, and wastewater. Below is
a summary of results for the air quality, waste, and wastewater media covered in the ERP. This data
compares the baseline and post-certification results, which were collected and verified by MDEQ Dry
Cleaning Inspectors. A summary of the data collected from the self-certification is provided on page
24. Detailed analysis of the results for each of the questions in the ERP can be found in Appendix A of
this report.
Air Quality
There were 31 questions included in the air compliance portion of the Michigan Dry Cleaning ERP.
MDEQ identified 3 questions as environmental business practice indicators (EBPIs). EBPIs are
industry-specific performance measures used to provide a snapshot of facilities' environmental
performance before and after certification, and to track facility and sector performance over time.The
air related questions and possible answers are identified in Table 5, with the EBPIs highlighted.
Table 5: Air Quality Questions
1.1.

Machine operated according to manufacturers’ specifications?

Yes

No*

1.2.

Machine operating manuals kept on site?

Yes

No*

1.3.

Dry cleaning machine door kept closed, except for loading and unloading?

Yes

No*

1.4.

Does facility keep a log of the gallons of perc purchased each month?

Yes

No*

1.5.

Perc purchase logs kept on file for five years?

Yes

No*

1.6.

Cartridge filters drained 24 hours before removal?

Yes

No*

1.7.

Are specified components of the machine inspected weekly/bi-weekly for perceptible leaks?

Yes

No*

1.8.

Are specified components inspected monthly for vapor leaks while in operation with a
halogenated hydrocarbon detector PCE gas analyzer?

Yes

No

1.9.

If a leak 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*

1.10. Does facility keep a log of the date of any necessary repairs made to the machine?

Yes

No*

1.11. Does facility keep a log of machine inspections that identifies any components that are
leaking?

Yes

No*

1.12. Small Area Source? Dry-to-dry machine installed before 12/9/91 AND did facility purchase
less than 140 gallons of perc per year during all previous 12-month periods?

Yes
Skip to
1.31

No

1.13. Dry-to-dry machines installed before 12/9/91 have an external refrigerated condenser
OR a carbon adsorber that was installed prior to 9/22/93? (Choose N/A if machine
installed after 12/9/91)

Yes

No*

N/A

1.14. Dry-to-dry machines installed after 12/9/91 have an internal refrigerated condenser?
(Choose N/A if machine installed before 12/9/91)

Yes

No*

N/A

1.15. Dry-to-dry machines initially installed after 12/21/05 have an internal carbon adsorber
AND refrigerated condenser? (Choose N/A if machine installed before 12/21/05)

Yes

No*

N/A

1.16. If major source, is the concentration of the perc in the dry cleaning machine drum at
the end of the cycle measured weekly with a colorimetric detector tube or PCE gas
analyzer? (Choose N/A if not major source)

Yes

No*

N/A
Skip to
1.18

Yes

No*

1.17. Is the concentration of perc less than 300 ppm?

16

Michigan SIG Final Report

Table 5: Air Quality Questions (continued)
1.18. External refrigerated condensers on a vented machine routed properly so that the airperc stream is not vented directly to atmosphere while drum is rotating? (Choose N/A
if machine has no refrigerated condenser or is a non vented machine)

Yes

No*

N/A

1.19. Outlet temperature of the vapor stream passing through the cooling coil read weekly
and equal to or less than 45° F (±2° F) or 7.2° C (±1.1° C)? (Choose N/A if reading
pressure gauge to comply, see question 1.20)

Yes

No*

N/A

1.20. High and low pressures of the refrigeration system read and recorded on a weekly
basis? (Choose N/A if no pressure gauges)

Yes

No*

N/A

1.21. Pressures within those specified by the manufacturer? (Choose N/A if no pressure
gauges)

Yes

No*

N/A

1.22. Date, temperature sensor or pressure gauge monitoring results recorded weekly?

Yes*

No

1.23. Date, temperature sensor or pressure gauge monitoring results kept on file for five years?

Yes*

No

1.24. Is machine equipped with an external carbon adsorber?

Yes

No
Skip to
1.30

1.25. If an external carbon adsorber is installed on a vented machine, is none of the airperchloroethylene gas-vapor stream allowed to bypass the carbon adsorber to the atmosphere?

Yes

No*

1.26. Is the concentration of perc in the exhaust of the external carbon adsorber measured weekly
using a colorimetric detector tube or PCE gas analyzer?

Yes

No*

1.27. Is the concentration of perc in the exhaust of the external carbon adsorber less than 100 parts
per million per volume?

Yes

No*

1.28. Are the date and colorimetric detector tube monitoring results recorded weekly?

Yes

No*

1.29. Are the date and colorimetric detector tube monitoring results kept on file for 5 years?

Yes

No*

1.30. Are necessary repairs made to the refrigerated condenser and/or carbon adsorber?

Yes

No*

1.31. Was a Notification of Compliance Status Form submitted to the MDEQ?

Yes

No*

Analysis of the results from both the baseline and post certificate inspections showed no statistically
significant change for any of the EBPIs. However, there were some, non-EBPI, air related compliance
questions for which a statistically significant change in compliance appeared. These questions and
associated results data are shown in Table 6.
Table 6: Air Quality Significant Changes in Compliance
Post-Certification minus Baseline Designed based estimates
Question

1.5
1.22
1.23

1.9

1.13

Perc purchase logs kept on file for five years?
Date, temperature sensor or pressure gauge
monitoring results recorded weekly?
Date, temperature sensor or pressure gauge
monitoring results kept on file for five years?
If a leak 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?
Dry-to-dry machines installed before 12/9/91
have an external refrigerated condenser OR a
carbon adsorber that was installed prior to
9/22/93?

Michigan SIG Final Report

Change in
Proportion

90% Confidence
Interval

Change Between
Rounds

10.2

5.6 – 14.8

Significant Increase ×

9.1

3.6 – 14.6

Significant Increase ×

10.6

5.2 – 15.9

Significant Increase ×

-1.6

-2.9 - -0.2

Significant Decrease Ø

-30.0

-40.8 - -19.2

Significant Decrease Ø

17

The lack of significant change of compliance from the baseline to post-certification inspections is most
likely due to this sector’s on-going familiarity with the air related regulations. As stated previously, dry
cleaners in Michigan are inspected annually for compliance with air regulations. For years the MDEQ
has provided education and outreach to dry cleaners on the air related requirements. Therefore, it is
no surprise that the compliance levels showed little change from baseline to post-certification
inspections. The compliance questions that showed marked improvement can most likely be
attributed to new federal regulations that came into effect during the implementation of this ERP
and/or increased education that was provided to the sector on these requirements and existing
requirements via the ERP. Specifically, the significant change seen in questions 1.5 and 1.23 may be
correlated to the self-certification, since a large number a large number of Return to Compliance
Plans that were submitted identified corrective action that was being taken on these specific items
(see page 25 of this report).
Waste
There were 30 questions included in the waste component of the ERP. MDEQ identified three
questions as EBPIs. The waste related questions and possible answers are identified in Table 7, with
the EBPIs highlighted.
Table 7: Waste Management Questions
3.1.

Does facility generate less than 220 pounds of hazardous waste per month?

Yes

3.2.

Does facility have a site ID number when needed for waste shipment? (Choose N/A if
waste not shipped off-site) TIP: Site ID should appear on all Uniform Hazardous Waste
Manifests with MIK, MIR, MID MIT, MIE, MI0, or MIG prefix.

Yes

3.3.

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*

3.4.

Is the waste properly listed on the manifest form (e.g., F002) and is the quantity shipped entered
on the manifest form?

Yes

No*

3.5.

Has a copy of each manifest been signed by the waste hauler and submitted to the MDEQ by the
10th of the month following the shipment?

Yes

No*

3.6.

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*

3.7.

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

3.8.

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*

3.9.

Is less than 2,200 pounds (5 drums) of hazardous waste accumulated on site?

Yes

No*

3.10. Are containers in good condition and kept closed except when adding or removing waste?

Yes

No*

3.11. Is the exterior of the storage containers kept free of the liquid waste and its residue?

Yes

No*

3.12. Are containers protected from the weather? If storing containers outdoors, they are placed on an

Yes

No*

Yes

No*

Yes

No*

Yes

No

No Go to
Part 4
No

N/A
Skip to
3.7

impervious surface and protected from the elements.

3.13. Are containers protected from fire and secure from vandalism and physical damage such as that
caused by fork lifts or other equipment?

3.14. 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?

3.15. Is there adequate aisle space for unobstructed movement of emergency equipment and
personnel?

18

Michigan SIG Final Report

Table 7: Waste Management Questions (continued)

3.16. If contents have a FP below 200° F, are they isolated according to local F.D. recommendations?

Yes

No*

3.17. If a leak or spill occurs does facility immediately stop and contain the leak and repair or replace

Yes

No*

3.18. Have employees been trained on how to properly manage waste?

Yes

No

3.19. Does hazardous waste storage area have secondary containment such as a curb, ramped pad,

Yes

No

3.20. Doing any of the best management practices listed in Table 3.1 of the Self Audit Workbook?

Yes

No

3.21. Are hazardous wastes that are a liquid shipped to a licensed recycling, treatment, storage, or

Yes

No*

Yes

No*

Yes

No

the container?

dike, or containment room?

disposal facility?

3.22. 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.

3.23. 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.

3.24. Does facility recycle fluorescent tubes, incandescent lamps, and/or dry cell batteries?

Yes

3.25. Are fluorescent tubes, incandescent lamps, dry cell batteries, stored for recycling according

No Skip to
3.27
Yes

No*

Yes

No*

Yes

No

Yes

No*

3.29. Is waste stored in leak-proof, covered containers (e.g. covered dumpster)?

Yes

No*

3.30. Does facility recycle or reuse office paper, corrugated cardboard, wood pallets, 55-gallon

Yes

No

to the following requirements?
• Stored not over 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 batteries,” “waste batteries,” “used batteries.”
• 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.

3.26. 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?

3.27. 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.

3.28. Is all solid waste hauled to a recycling center or a licensed disposal facility, which includes: a
landfill, incinerator, or a transfer/processing facility?

clean drums, other containers, or scrap metal?

Michigan SIG Final Report

19

Analysis of the results from the baseline and post-certification inspections showed significant
increases in compliance for several of the requirements. There was a significant increase in
compliance for one EBPI (question 3.3) and several other non-EBPI questions. Not only were there
marked improvements in compliance with the regulatory requirements but also with most of the best
management practices (BMPs) that were included as part of the ERP. Table 8 identifies the
requirements and BMPs that showed a significant increase in compliance.
The vast majority of dry cleaning establishments are conditional exempt small quantity generators;
therefore, they are rarely inspected by the MDEQ for compliance with waste related questions.
Historically, the MDEQ’s Dry Cleaning Program has not verified compliance with waste related
requirements. While it is not conclusive, we might assume that the increased outreach to this sector
on waste related requirements may have led to these improvements in compliance.
Table 8: Waste Management Significant Changes in Compliance
Post-Certification minus Baseline Designed based estimates
Question

3.1

3.3

Does facility generate less than 220 pounds
of hazardous waste per month?
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?

Change in
Proportion

90% Confidence
Interval

Change Between Rounds

15.1

11.9 – 18.3

Significant Increase ×

8.2

3.8 – 12.6

Significant Increase ×

3.4

Is the waste properly listed on the manifest
form (e.g., F002) and is the quantity shipped
entered on the manifest form?

13.5

9.8 – 17.2

Significant Increase ×

3.5

Has a copy of each manifest been signed by
the waste hauler and submitted to the
MDEQ by the 10th of the month following the
shipment?

11.6

7.0 – 16.2

Significant Increase ×

3.6

Are all copies of the manifest that are signed
by the hauler and disposal facility kept on
file for at least 3 years?

5.4

0.3 – 10.5

Significant Increase ×

3.7

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.

10.9

6.3 – 15.6

Significant Increase ×

3.8

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?)

13.7

9.7 – 17.7

Significant Increase ×

3.15

Is there adequate aisle space for
unobstructed movement of emergency
equipment and personnel?

0.8

0.0 – 1.6

Significant Increase ×

3.18

Have employees been trained on how to
properly manage waste?

18.9

14.9 – 22.9

Significant Increase ×

3.20

Doing any of the best management
practices listed in Table 3.1 of the Self Audit
Workbook?

12.2

8.1 – 16.3

Significant Increase ×

20

Michigan SIG Final Report

Table 8: Waste Management Significant Changes in Compliance (continued)
Post-Certification minus Baseline Designed based estimates
Question

Change in
Proportion

90% Confidence
Interval

Change Between Rounds

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.

11.0

8.7 – 13.4

Significant Increase ×

3.24

Does facility recycle fluorescent tubes,
incandescent lamps, and/or dry cell
batteries?

12.3

9.1 – 15.5

Significant Increase ×

3.26

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?

30.9

2.9 – 58.8

Significant Increase ×

3.30

Does facility recycle or reuse office paper,
corrugated cardboard, wood pallets, 55gallon clean drums, other containers, or
scrap metal?

24.8

20.8 – 28.8

Significant Increase ×

3.23

Wastewater
There were 13 questions pertaining to compliance with the wastewater requirements. MDEQ identified
one question as an EBPI. This EBPI was actually a combination of several questions 5.01 – 5.03 to
determine if the wastewater that was generated by the facility was disposed of properly. The
wastewater related questions and possible answers are identified in Table 9 (the EBPI is highlighted).
Table 9: Wastewater Questions
5.1.

Is facility connected to a sewer system that goes to a wastewater treatment plant?

Yes

No Skip to 5.6

5.2.

Facility empty wastewater from any dry cleaning machine into a drain, toilet, or
sink?

Yes

No Skip to 5.4

5.3.

Does facility have permission from the wastewater treatment plant to dispose of
wastewater from dry cleaning machine into the sewer system?

Yes

No

Does facility dispose of wastewater from dry cleaning machine properly? This
question was not asked in surveys but is a based on a combination of questions
5.2 and 5.3 to serve as an EBPI to determine if wastewater that is sent to sewer is
disposed of properly (see note at the end of this table).

Yes

No

5.4.

Facility empty wastewater from laundry area, air compressor, boiler, vacuum,
or floor cleaning into a drain, toilet, or sink?

Yes

No Skip to 5.6

5.5.

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

Michigan SIG Final Report

21

Table 9: Wastewater Questions (continued)
5.6.

Does facility use an evaporator device to dispose of wastewater?

Yes

No

5.7.

Is any wastewater collected in a holding tank?

Yes

No Skip to 5.9

5.8.

Is wastewater that is collected in holding tank disposed of by a licensed and
registered hauler?

Yes

No

5.9.

Does any wastewater from facility go to a septic system?

Yes

No

Yes

No

5.10. 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?
5.11. Are there any floor drains in facility?

Yes

No Go to Part 6

5.12. Do they empty to the sewer system that goes to a WWTP or a holding tank?

Yes Go
to Part 6

No

5.13. Have floor drains that empty to a storm sewer, stream, or ditch been plugged
with concrete or a locked down cement cap so that they are inaccessible and
unusable?

Yes

No

Questions 5.1, 5.2, and 5.3 determine whether establishments are improperly emptying wastewater into drains that flow
to wastewater treatment plants. Establishments that are connected to a sewer system (i.e., they answered "Yes" to 5.1)
are considered in compliance if (1) they do not empty wastewater in a drain (they responded "No" to 5.2) or (2) for those
that do empty wastewater in a drain, they have permission to do so (they answered "Yes" to 5.03). The combination of
5.2 and 5.3 is "Yes" if they answered "No" to 5.2 or if they answered "Yes" to both 5.2 and 5.3. It applies only to
establishments with drains connected to sanitary sewers (i.e., that answered "Yes" to 5.1).

Historically this sector has not been questioned on their wastewater disposal practices nor do they
have much knowledge of what is allowed and prohibited. Wastewater that is disposed of from a
business to a sewer system is not regulated by the MDEQ but rather the local wastewater treatment
plant (WWTP). Awareness of wastewater disposal requirements is largely dependent on the outreach
and enforcement efforts of the WWTP. The compliance assistance provided via the ERP most likely
increased awareness of these requirements. Analysis of the data collected showed significant
increases and decreases between rounds for several of the questions. Table 10 shows for which
questions a significant change between rounds was observed.
Table 10: Wastewater Significant Changes in Compliance
Post-Certification minus Baseline Designed based estimates
Question

Change in
Proportion

90% Confidence
Interval

Change Between Rounds

5.2

Facility empty wastewater from any dry
cleaning machine into a drain, toilet, or
sink?

-9.9

-14.5 – -5.3

Significant Decrease Ø

5.3

Does facility have permission from the
wastewater treatment plant to dispose of
wastewater from dry cleaning machine into
the sewer system?

-17.0

-27.3 – -6.7

Significant Decrease Ø

5.2
&
5.3

Does facility dispose of wastewater from dry
cleaning machine properly? This question
was not asked in surveys but is a based on
a combination of questions 5.2 and 5.3 to
serve as an EBPI to determine if wastewater
that is sent to sewer is disposed of properly
(see note at the bottom of this table).

4.3

0.3 – 8.3

Significant Increase ×

22

Michigan SIG Final Report

Table 10: Wastewater Significant Changes in Compliance (continued)
Post-Certification minus Baseline Designed based estimates
Question

5.4

Facility empty wastewater from laundry
area, air compressor, boiler, vacuum, or
floor cleaning into a drain, toilet, or sink?

5.7

Change in
Proportion

90% Confidence
Interval

Change Between Rounds

9.5

6.7 – 12.3

Significant Increase ×

Is any wastewater collected in a holding
tank?

-35.1

-36.8 – -33.4

Significant Decrease Ø

5.8

Is wastewater that is collected in holding
tank disposed of by a licensed and
registered hauler?

-41.2

-51.8 – -30.6

Significant Decrease Ø

5.9

Does any wastewater from facility go to a
septic system?

-2.6

-4.5 – -0.6

Significant Decrease Ø

5.10

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?

-4.3

-6.8 – -1.8

Significant Decrease Ø

5.11

Are there any floor drains in facility?

16.4

11.9 – 21.0

Significant Increase ×

5.12

Do they empty to the sewer system that
goes to a WWTP or a holding tank?

3.6

1.3 – 5.9

Significant Increase ×

The mix of increased and decreased change is primarily due to the design of the questions in this part
of the audit. For many of the wastewater questions, the correct or “good” answer was “No” as
opposed to “Yes,” which is the case throughout the rest of the survey. This means a significant
decrease is actually good or desired for questions 5.2, 5.4, 5.9, 5.10, and 5.11. For example, question
5.2 asks if the facility empties wastewater from their drycleaning machine to a drain, toilet, or sink.
The desired answer is “No” so a significant decrease between the baseline and post-certification
inspections is good because it means that there was a decrease in the number of facilities that
disposed of wastewater in this manner, which is not desired.
Some of the questions do not relate to compliance but rather are exclusionary questions such as 5.11,
which asks whether or not there are floor drains in the facility. It is preferred that the facility does not
have floor drains so “No” is the desired answer; however, if a facility answers “Yes” it doesn’t mean
they are not in compliance. It simply identifies that they should answer the next two questions related
to floor drains. So, if a facility answers “Yes” to question 5.11 and “Yes” to questions 5.12 to 5.13 that
is desired and is the “good” response (i.e., they have floor drains but they are operating properly).
The decrease in the number of sources that did not have permission to dispose of wastewater from
their drycleaning machine to their WWTP (question 5.3) may be attributed to increased awareness of
this requirement after the baseline assessment. Prior to the ERP few, if any, sources had ever
considered this requirement. As a result, many sources did not realize they did not have the required
permissions. It should be noted that several of the return to compliance plans submitted to the MDEQ
identified this requirement as a non-compliance issue and subsequently contacted their WWTP to
obtain permission. Looking at the combined EBPI, it does appear that there was ultimately a
significant increase in the number of sources that disposed of their wastewater properly. This may be
because, upon learning about the requirements, a number of sources either stopped disposing of
waste water from their machine to the sewer or sought out and received the required approval.
According to question 5.4, there was an increase in the number of facilities that reported they empty
wastewater from laundry area, air compressor, boiler, vacuum, or floor cleaning into a drain, toilet, or
sink. This was rather unexpected; however, it could be due to increased awareness by both the
Michigan SIG Final Report

23

facilities and inspectors with regards to the numerous emission points in the facility and the methods
of disposal that are allowed. A number of facilities may have obtained permission from their WWTP to
dispose of this wastewater as a result of the audit and then began disposing of wastewater to the
sewer system that may have not been disposed of there before. This change could also simply be due
to the sample selected and the resulting differences in operating practices between those in the
baseline and post-certification samples.
Self-Certification
Of all the self-certification packages that were sent to all facilities in August 2007, 496 certifications
were returned, which is approximately 58% of the drycleaners in the state. Results from each of the
questions are shown on page A-22 of Appendix A.
Based on the results submitted, it appears that facilities believed themselves to be achieving a very
high level of compliance with almost all of the requirements identified in the certification. In fact,
according to the facility results, over 95% of the facilities judged themselves to be in compliance with
37 of the 95 questions. These results are significantly different than those observed by the inspectors
in the baseline and post-certification inspections, which showed the compliance levels to be much
lower for all the questions. Table 11 identifies each of the EBPIs and compares the percentage of
facilities identified as in compliance during the facility-scored self-certifications and the inspector
observed post-certifications.
Table 11: Comparison of Self-Certification and Post-Certification EBPI Results
EBPI

Self-Certification

Post-Certification

Proportion in
Compliance

Proportion in
compliance

1.4

Does facility keep a log of the gallons of perc purchased each month?

98.7

62.7

1.7

Are specified components of the machine inspected weekly/bi-weekly
for perceptible leaks?

98.3

75.8

1.19

Is the outlet temperature of the vapor stream passing through the
cooling coil (refrigerated condenser) read weekly and is it equal to or
less than 45deg F (±2 F) or 7.2deg C (±1.1degC)?

98.7

77.0

3.3

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?

98.1

87.7

3.10

Are containers in good condition and kept closed except when adding
or removing waste?

100.0

94.5

3.22

Is facility complying with the following?
-Liquid haz waste not disposed of in dumpster, landfill, incinerator
-Waste not put into municipal sanitary sewer without WWTP
authorization
-Haz waste not into septic tank, storm drain, into stream or ground

99.3

97.6

5.2
&
5.3

Does facility dispose of wastewater from dry cleaning machine
properly? This question was not asked in surveys but is a based on a
combination of questions 5.2 and 5.3 to serve as an EBPI to determine
if wastewater that is sent to sewer is disposed of properly

97.6

88.0

This disparity may be due to several factors, including the likelihood that the facility interpreted a
question differently or less strictly than an inspector; misunderstood a question; or feared that showing
non compliance would result in enforcement. While it may be expected that a facility would judge itself
easier than a trained inspector, this disparity is something that should not be ignored. Regulators

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Michigan SIG Final Report

should be aware that the results from self-certifications may not be as accurate as what may be
observed by trained inspectors. This reinforces the importance of conducting targeted inspections of
self-certifiers to verify submitted data, in addition to random inspections of non-certifiers. Of course,
this was the first time this sector was ever given the opportunity to self-certify compliance. It might be
assumed that as facilities become more comfortable
with the self-certification process and more
200 Returned RTC Plans
knowledgeable of the requirements, facility and
Other
inspector scored results will be more closely aligned.
5%
Regardless of the difference in results, corrective
action was taken at several facilities after completing
the self-certification. A total of 200 Return to
Compliance (RTC) plans were submitted to the
MDEQ to correct various violations cited throughout
the certifications. The majority of RTC plans
submitted were to correct air quality related violations
(104). The chart to the right shows the percentage of
air, waste, wastewater related RTC plans submitted.

Wastewater
28%
Air
(Perc Machine)
51%

Waste
16%

Table 12 identifies for which requirements the largest number of RTC plans were returned.
Table 12: Most Common RTC Submissions
Number of
RTC Plans
Returned

Question
1.5 Are all perc purchase logs kept on file for five years?

18

1.10 does facility keep a log of the date of any necessary repairs made to the machine?

11

1.23 Is the date, temperature sensor or pressure gauge monitoring results kept on file for
five years?

14

3.5 Has a copy of each manifest been signed by the waste hauler and submitted to the
MDEQ by the 10th of the month following the shipment?

11

5.5 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)

44

Most common RTC submissions

Q.1.5
Q.1.10
18
11
Q.1.23
14
Other
102

Q.3.5
11

Q.5.5
44
Michigan SIG Final Report

25

OBSERVATION AND RECOMMENDATIONS
During the implementation of Michigan’s Drycleaning ERP, we made several observations that we feel
contributed to the overall outcome of this project. The observations below are not only interesting but
also fairly common among ERPs. Unfortunately, there is probably no way to measure the compliance
changes associated with them.
Problems with baseline inspection protocol: We conducted baseline inspections in 2006. Our
sampling strategy identified the facilities that were supposed to be inspected within a specified
window of time (July – December). Normally, the dry cleaning inspectors visit every facility annually.
Facilities are selected based on the length of time since their last inspection (i.e. if a facility was
inspected the previous year in March the inspector will try to conduct the next year inspection in
March). The baseline inspection protocol required that the inspectors hold off conducting inspections
of those selected for ERP baseline inspections until the window opened. Unfortunately, the
importance of this “inspection window” was not communicated clearly to the inspectors and as a result
a number of the facilities that were supposed to be inspected as part of the baseline were conducted
early (before the window opened). This error was not discovered until reviewing the data with EPA’s
ERP consultant, while compiling data for the 2008 ERP States Produce Results Report. Ultimately,
we decided to remove a significant amount of data from the baseline sample to ensure statistical
validity. What was once a sample of 311 sources became 262. Fortunately, the problem was
discovered soon enough so we could make the necessary adjustments to our data and better prepare
our inspectors for the post-certification inspections.
Change Data Collection Method: One of the biggest lessons learned was in regards to how we
collected the self-certification data. We spent a great deal of time developing the forms so that they
could be read by an optical scanner. We had anticipated that this portion of our new software would
be complete by that time. Unfortunately, the software program was not yet available so it wasn’t
necessary that we do this. Also, after we received the first few responses back we discovered that
using an optical scanner would be a lost cause anyway due to the fact that many respondents wrote
all over the forms and had numerous stray marks, even though we provided detailed instructions on
how to complete the forms. If we were to choose to use a scanning device, we would have to provide
even more explicit instructions or use a bubble sheet to record answers so as to limit any stray marks.
During meetings with our Department of Information Technology, we also learned of a new tool they
had available that would allow us to collect the self-certification data over the internet using
Web-based survey software. We were unaware of the availability of this software during the early
development stages of the certification forms. If we are to do another self-certification, I would
recommend collecting the data using the web-based software.
Capturing Improvements by Non-Responders: During the self-certification period, a drycleaner
contacted MDEQ and asked if submitting the audit was mandatory. When he was told that it was
voluntary, he explained that he didn’t think he was complying with one of the air requirements related
to air pollution control equipment and therefore didn’t want to submit the form. Even if the cleaner did
not submit the form, he became aware of the requirements and will hopefully make changes. This is
believed to be a very common scenario. When a facility does not submit the form or chooses to not
answer truthfully, there is no way of capturing whether or not a change was actually made due to their
findings. I assume that if any changes were made it would be positive (i.e. a person would not choose
to start not complying with a requirement if they were already complying with it).
Better Understanding of Regulations: Some facilities needed to be walked through the self audit.
For the most part, these were people that were new to the business and had very little knowledge of
the requirements they were subject to or why they were doing some of the recordkeeping they have
always done (many establishments are handed down to different family members who do not know
very much about dry cleaning regulations). In doing the audit, they learned more about their
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Michigan SIG Final Report

requirements and were able to do so anonymously. The self-certification does not capture how much
additional knowledge is gained by the respondent, just whether or not they are complying. We don’t
ask for their knowledge level of the requirements or dry cleaning system prior to completing the selfcertification nor do we capture what additional things they may have learned as a result of completing
the forms, such as what a halogenated hydrocarbon detector is or why they have to check certain
gauges on their machine.
A couple inquiries came in regarding question 1.19, which is a requirement to do a weekly
temperature reading of refrigerated condenser. One of the cleaners had been doing readings but
didn’t know why and wasn’t keeping the records in a log. The other cleaner hadn’t been doing it at all
and wanted to know more. I sent both a recordkeeping guidance form that explained the requirements
and how to keep the log. The self-audit introduced the requirement to them and provided them with
the opportunity to ask for more information anonymously.
Synergy between Agency, Trade, and Facilities: During a presentation, a picture of a secondary
containment pad was displayed to illustrate an example of good containment. One attendee asked
what it was and where he could get one of those pads. Several people in the audience provided some
resources. MILD volunteered to help to help locate information on the unit and get the details to
members. Here, the ERP provided an opportunity for some unexpected synergy between the MDEQ,
facilities, and the trade association, not to mention the potential implementation of a best
management practice.
Improvement in Multi-Media Compliance Assistance: Prior to the self-certification, almost all
sources were unaware that to be considered a conditionally exempt small quantity generator
(CESQG), and consequently subject to less regulation, you had to be able to show that your monthly
hazardous waste generation is below 220 lbs. After doing the audit or attending a presentation,
facilities learned how to demonstrate their waste generation in a way that would be satisfactory to
inspectors.
Several questions came in regarding getting approval to dispose of process wastewater to the sewer
system. Discharges to sewer system are regulated by local wastewater treatment plants, not MDEQ,
so very few knew about this requirement. Because of the audit, dry cleaners have initiated contact
with their local sewer authority to verify if any permits or authorizations are required to dispose of
wastewater.
The revised federal NESHAP requires that all cleaners conduct monthly leak detection using a
halogenated hydrocarbon detector. While some cleaners knew about this upcoming requirement,
many did not. The workbook and training sessions (on-line and live) provided cleaners with
information on this new requirement.
Unintended Negative Outcomes to Compliance Assistance: During the meetings with facilities, we
experienced some possible unintended negative outcomes that may have resulted from educating
facilities. Specifically, many facilities are unaware that legally they are allowed to dispose of their
“solid” hazardous waste in their dumpster if they generate less than 220 lbs hazardous waste/month.
A lot of facilities assumed that all hazardous wastes from their dry cleaning process must be disposed
of by a hazardous waste hauler, which is a best management practice (recommended). We explained
the particulars of what was considered a “solid” hazardous waste and that some landfills may still not
except it; however, we felt that some facilities still left with the impression that this was a cheaper
(better) disposal option. As a result of educating them on the regulations, we may have actually
deterred some facilities away from a best management practice they were unknowingly doing already.
Misinterpretation of Questions: One facility noted during a phone call for assistance that he did not
understand what we meant when we stated “recommended” under the response to some of the
Michigan SIG Final Report

27

questions. He asked if this meant that we recommend the activity or recommend the facility answer
“No” to the question (see below). This was a great observation that I had not considered. I will most
likely change this in future versions.

3.31. Are you doing any of the best management practices listed in Table 3.1 of the Self
Audit Workbook?

Yes

No
Recommended

Are we recommending
they choose “No” for this
question?

Better than Expected Return Rate of Self-Certification Forms: The MDEQ received selfcertification data from approximately 58% of the dry cleaning establishments in Michigan. This far
exceeded our expectations considering the self-certification was voluntary. There are a few factors
which we believe contributed to this high rate of return:
•

Successful partnership between MDEQ and dry cleaning associations. MILD and KDA
encouraged members to complete and submit the forms to MDEQ. Both associations
advertised the program in there publications, included information during meetings, and
organized several workshops to assist members with the completion of the audit forms.

•

Development of a Korean version of the form. A significant number of dry cleaning
establishments in Michigan are Korean owned/operated. MDEQ believes that the availability of
a Korean version of the audit form made these individuals more likely to complete the forms
and also improved our relationship with this community through our willingness to
accommodate their needs by addressing the language barrier.

•

Inclusion of a self addressed, postage-paid envelope with the self-audit package. This industry
has been hard hit by Michigan’s economic downturn and most establishment owners/operators
have very little time to complete the audit. We believe that including this envelope made it
much easier for users to submit the audit materials.

•

Sector’s familiarity and trust of MDEQ Dry Cleaning Program. As stated previously, Michigan
drycleaners are inspected regularly for compliance with air quality regulations by the MDEQ. In
most cases the interactions between facility and inspector is positive and helpful. This
relationship most likely played a big role in this sector’s willingness to complete and submit the
self-certifications.

Postage Paid Return Envelope

28

Michigan SIG Final Report

FUTURE OF DRY CLEANING ERP IN MICHIGAN
The MDEQ Dry Cleaning Program was vital to the success of this project and they contributed
significantly to the development of the guidance materials and collection of data in the field. The
inspectors involved were able to quickly learn and incorporate the multi-media aspects of the ERP into
their inspections. It is evident that the multi-media element incorporated as a result of the ERP may
have increased this sectors knowledge and compliance with waste and wastewater regulations. As a
result, the inspectors in this program have incorporated waste and wastewater compliance questions
into their traditional air quality inspections.
At this time, the use of ERP to manage this sector or others in Michigan remains uncertain. Currently,
there is not sufficient support at the upper level of management to extend this program to other
sectors or programs within the department. Severe economic strains on the department have made it
difficult to incorporate new methods of compliance verification that are not as tried and trusted as
traditional approaches. The MDEQ currently inspects sources by media (air, waste, water). The
implementation of an ERP requires that some inspection resources be shifted to a multi-media
protocol. As with other states, management in MDEQ must be convinced that this shift in resources
and inspection protocol is cost effective and ultimately the best use of the limited inspection resources
available. While support is currently weak, we are confident that the Michigan dry cleaning ERP pilot
serves as a model for how to successfully manage a sector or program with limited resources. As
programs are cut and reduced and inspection priorities change, the dry cleaning ERP model will
remain as an alternative approach to providing compliance assurance. Michigan now knows what it
takes to implement a successful ERP, as we have a model on which to base our assumptions.
However, it is going to take a vested interest by management and field staff to make this approach a
reality. We plan to share our results from this program with department management in the coming
months in hopes that further support and interest will be generated.
On a larger scale, Michigan is actively participating in a Regional ERP targeted to auto body facilities
in the U.S. EPA’s Region 5. Michigan is using it practical experience in ERP to assist in the planning
and implementation of this first-of-its-kind endeavor. The work by states and the region to implement a
number of pilot ERP programs will hopefully prove the effectiveness of this tool and result in increased
interest at both the state and federal level.

Michigan SIG Final Report

29

FINANCIAL SUMMARY
The MDEQ received the SIG from the US EPA in 2005 to implement an Environmental Results
Program for the Dry Cleaning Sector. The grant awarded was $199,200. The state of Michigan was
obligated to match 33% of the awarded amount awarded - $100,000. Michigan chose to allocate
personal and fringe expenses to the match as well as some costs identified under “Other,” which are
also personnel related but for information technology services.
The MDEQ did not use the entire awarded grant amount of $199,200 to fulfill the grant obligations.
Efficiencies were achieved in several areas such as supplies, which accounted for a significant
budgetary savings. $125,870 was allocated for the development of the data management system
described earlier in this report and in Appendix B of this report. The costs associated with this task
were also less than expected ($121,670), which also accounted for significant savings.
The MDEQ funded portions of the project did exceed expected costs. The biggest unexpected
expenditure came from the charges incurred upon us by our Department of Information Technology
for the assistance they provided in managing and coordinating the data management system. The
majority of these charges were incurred by the MDEQ and were more than expected due to the
complicated nature of the project and several unexpected delays. The state was required to provide a
match of 34% or $100,000. The match was met and exceed through the personal and fringe benefits
and expenditures for IT services listed under “Other.” Table 5 shows actual expenditure incurred by
MDEQ even after match was met.
Table 11: MERP Financial Summary
Item

Approved Grant
Amount

MDEQ
Expenditure

SIG
Expenditure

Actual Total

Personnel

78,000

61,366.61

9,009.44

70,376.05

Fringe

34,000

33,290.67

4,627.97

37,918.64

Travel

4,200

7.25

4,048.88

4,056.13

Supplies

29,500

4.41

27,642.78

27,647.19

Contractor

125,870

0

121,670.00

121,670.00

Other

6,545

20,863.29

10,494.51

31,357.80

Total Direct

278,115

115,532.23

177,493.58

293,025.81

Indirect

21,085

13,973.81

2,066.07

16,039.88

Total Federal
share (66%)

199,200

179,559.65

179,559.65

Total State
Share (34%)

100,000

129,506.04

Total

299,200

129,506.04

30

-

179,559.65

129,506.04
309,065.69

Michigan SIG Final Report