EPA-450/2-78-050

                                OAQPS No. 1.2-117
     Control of Volatile Organic
Emissions  from Perchloroethylene
        Dry Cleaning Systems
              Emission Standards and Engineering Division

               Strategies and Air Standards Division
             U.S. ENVIRONMENTAL PROTECTION AGENCY
                Office of Air, Noise, and Radiation
              Office of Air Quality Planning and Standards
             Research Triangle Park, North Carolina 27711

                    December 1978

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                                     OAQPS GUIDELINE SERIES   ,                                             j
                                                                                                            -1
The guideline series of reports is being issued by the Office of Air Quality Planning and Standards (OAQPS) to
provide information to state and local air pollution control agencies; for example, to provide guidance on the
acquisition and processing of air quality data and on the'planning and analysis requisite for the maintenance of
air quality. Reports published in this series will be available - as supplies permit -from the Library Services Office
(MD-35). U.S. Environmental Protection Agency, Research Triangle  Park,  North Carolina 2771 1; or,  for a
nominal fee from the National Technical Information Service, 5285 Port Royal Road, Springfield, Virginia    ^~
22161.                                                                                               W

                                 Publication No. EPA-450/2-78-050

                                        (OAQPS No. 1.2-117)

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                              TABLE OF CONTENTS
 Chapter 1.0
         1.1
         1.2
     ,    1.3
 Chapter 2.0
         2.1
         2.2
         2.3
 Chapter 3.0
         3.1
         3.2
         3.3
         3.4
 Chapter  4.0
         4.1
         4.2
        4.3
Chapter  5.0
        5.1
        5.2
        5.3
                                                  Page
 Introduction	  .  1-1
 Need to Regulate	       1_1
 Sources and Control  of VOC  ,   .   .      .      „   i _2
 Regulatory Approach	.   .  1-3
 Sources and types of Emissions  ...   .   .  .  2-1
                                            i
 Industry Description  	   .   2-1
 Dry Cleaning Processes and Emissions  .   .   .  .   2-2
 References	^     2_s
 Emission Control  Technology  .......   3-1
 Use of  Control Techniques	  .     3-1
 Types of Control  Techniques .-.  .  .   .  •.  1 .   .   3.2
 Suimiary	,i       %_]$
 References	.*  .   .  3-12
 Cost Analysis  	   .....  4-1
 Introduction	   .   4_1
 Perch!oroethylene Solvent  Plant Cost Analysis   .   4-3
 References	>  t     4.3
 Effects of Applying the Technology   .  .  .   .  .5-1
 Impacts on VOC Emissions	   .   5-1
    .
Other Air Pollution Impacts	   .   5-4
Water Pollution Impacts  	       5.4
                                   111

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                                                                 Page
Chapter 5.4   Solid Waste Impact  	    5-7
        5.5   Energy Impact	5-7
        5.6   References	5-9
Chapter 6.0   Enforcement Aspects	  .   .   .  .   6-1
        6.1   Affected Facilities	   6-1
        6.2   Suggested Regulation	,  .         6-1
        6.3   Discussion	6-4
Appendix A    Emission Source Test Data  	   A-T
         A.I  Plant A	   A-2
         A.2  Plant B	A-3
         A.3  Plant C	A-4
         A. 4  References	A-7
Appendix B    Compliance Test Methods and Leak Detection
              Equipment	    B-V
         B.I  Compliance Test Methods  .........  B-l
         B.2' Leak Detection Methods	  .   B-7
         B.3  Summary	  .   B-8
                                      iv

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LIST OF TABLES

Table 2-1
Table 3-1

Table 3-2
Table 3-3
Table 3-4
Table 4-1

Table 4-2
Table 4-3
Table 5-1
Table 5-2

Table 5-3
Table 5-4
Table 5-5
Table A-l
Table A-2

Solvent Losses in Perchloroethylene Plants .
i'
Potential and Applied Control Techniques for
Dry Cleaning Plants 	 	 .
Carbon Adsorber Test Summary 	 	
Effect of Housekeeping Practices . . . i, .
Control Techniques and Solvent Emission Levels
Cost Parameters for Model Perchl oroethylena
Plants 	 	
Costs for Carbon Adsorption 	 . .
Cost Effectiveness 	
Hydrocarbon Emission Factors (Uncontrolled); .
Effect of Applying Available Air Pollution
Control Techniques 	 .
Impact of Control Systems on Water Usage . .
Perchloroethylene Solvent in Effluent Water, .
Energy Imoact . 	 .
Plants Tested by EPA . . 	 	
Dry Cleaning Test Data 	 	
Page
. . 2-6

. . 3-1
. . 3-3
3-8
. . 3-11

. . 4-4
. . 4-5
. . 4-7
. . 5-2

, . 5-3
. . 5-5
. . 5-6
5-8
A-l
. , A-6

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                           LIST OF FIGURES
                                                                 Page
Figure 2-1    Perch!oroethylene Dry Cleaning Plant Flow
              Diagram  ..............   2-4
                                    vi

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                          1.0   INTRODUCTION             i.

      This document is related to the control of volatile organic compounds
(VOC), specifically perchloroethylene (perc), from all dry cleaning systems
which use this solvent.  Other solvents used in the dry cleaning industry,
petroleum distillate (Stoddard Solvent) and trichlorotrifluoroethane
(fluorocarbon), may be discussed in later documents.
      Methodology described  in this document represents  the presumptive
norm  or reasonably available control technology  (RACT) that can be applied
to existing perch!oroethylene dry cleaning systems.   RACT is defined as the
lowest emission limit  that a particular source is capable of meeting by the
application of control technology that is reasonably  available considering
technological and economic feasibility.  It may require  technology that has
been  applied to similar, but not necessarily identical,  source categories.
It is not intended that extensive research and development be conducted before
a given control technology can be applied to the source.  This does not,
however, preclude requiring  a short term evaluation program to permit the
application of a given technology to a particular source.'  The latter effort
is an appropriate technology forcing aspect of RACT.
1.1   NEED TO REGULATE                                   \   .
      Control techniques guidelines concerning RACT are Being prepared for
those industries that emit significant quantities of air'pollutants in areas
of the country where National Ambient Air Quality Standards (NAAQS) are not
                                     1-1

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being attained.  Perch!oroethylene dry cleaning systems are a significant
source of VOC and are predominantly found  in urban areas.
    Annual nationwide emissions from perch!oroethylene dry cleaning systems
are estimated to be 158,000 metric tons per year or about 0.9 percent of
total stationary source emissions.
    The other two solvents used in the industry are not as significant as
perch!oroethylene.  Petroleum solvent systems emit 68,000 metric tons per
year and trichlorotrifluoroethane (not considered a photochemically reactive
VOC) emissions are estimated to be only 820 metric tons.
1.2  SOURCES AND CONTROL OF VOLATILE ORGANIC COMPOUNDS FROM PERCHLOROETHYLENE
     DRY CLEANING SYSTEMS
    Dry cleaning systems have several sources of emissions.  The major source
is the dryer (known as the recovery tumbler or reclaimer).  While every
perch!oroethylene dryer is equipped with a condenser, significant quantities
(about 50 percent) of emissions occur from this source.  The disposal of waste
materials is the second most significant source followed by the losses from
liquid and vapor leaks.
    Control techniques are available and have been widely applied in this
industry.  It is estimated that about 35 percent of all commercial and
industrial perch!oroethylene system dryers are equipped with carbon adsorbers.
Emissions from waste material disposal can be reduced by several methods,             %
among them the proper operation of cookers and cartridge filters.  Finally,
                                                                                      V
leaks can be prevented by visual inspection and by periodic monitoring with
a leak detection instrument.
    Capital costs of carbon adsorbers are $4500 for a large commercial plant
of 46,000 kg (100,000 pounds) of clothes throughput per year.   Cost
                                                                                   41
                                    1-2

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  effectiveness of controls in this perch!oroethylene system is $90 savings
  per metric ton of perchloroethylene removed.
  1.3  REGULATORY APPROACH                                ,;
      The application of RACT will reduce dryer outlet concentration
  to less than 100 ppm; reduce emissions from filter waste and still
  bottoms; and eliminate liquid and vapor leaks.  A study is underway to
  determine the significance of vapor leaks.  A test procedure to define
 a "leak tight system" is being developed and will  be available in the
 near future 1f vaP°r leaks are shown to be a problem.
     The following  sample regulation, discussed in  Chapter  6.0,  incorporates
 all  of the  above recommendations:                        ;
     Sec-  1*   Solvent emissions  from  perchloroethylene  dry  cleaning systems
     must  be  limited  in  accordance with  the  provisions  of this Rule..
     Sec-  2-   Compliance  with  this Rule  requires the  following:
         (a)   There shall  be no  liquid leakage  of organic solvent  from the
        system.
        (b)   Gaseous  leakage  shall not  exceed	ppm. -^
        (c)   The entire dryer exhaust must be vented through a carbon
        adsorber or equally effective control device.
1   if H^mJ  9""™"*,Assessing the significance of vapor leaks.
    If deemed significant, a test method for detecting leaks will
    be developed and issued to interested parties
                                 1-3

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       (d)  The maximum organic solvent concentration in the vent from
                                                                         2/
       the dryer control device shall not exceed 100 ppm before dilution.—'
       (e)  Filter and distillation wastes.
            (1)  The residue from any diatomaceous earth filter shall be
       cooked or treated so that wastes shall not contain more than 25 kg
       of solvent per 100 kg of wet waste material.
            (2)  The residue from a solvent still shall not contain more than
       60 kg of solvent per 100 kg of wet waste material.
            (3)  Filtration cartridges must be drained in the filter housing
       for at least 24 hours before being discarded.  The drained cartridges
       should be dried in the dryer tumbler if at all possible.
            (4)  Any other filtration or distillation system can be  used if
       equivalency to these guidelines is demonstrated.  For purposes of
       equivalency demonstration any system reducing waste  losses below
       1  kg solvent per 100 kg clothes cleaned will be considered equivalent.
    Sec. 3.  Sections 2(c) and  (d) are not applicable to plants where an
    an  adsorber cannot be accommodated because of  inadequate space or to
    plants where no or insufficient steam capacity is available to desorb
    adsorbers.  The District may exclude other plants from the scope  of
    Sections 2(c) and  (d) if it  is  demonstrated  that other  hardships  justify
    such  an exclusion.
2/   Enforcement of these provisions is dependent on the development
     of a satisfactory detection instrument and test method.
                                 1-4

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   Sec. 4.  Compliance Procedures
       (a)  Liquid leakage shall be determined by visual inspection of the
       following sources:
            (1)  Hose connections, unions, couplings and valves;
            (2)  Machine door gasket and seating;
            (3)  Filter head gasket and seating;
            (4)  Pumps;              '                  ;
            (5)  Base tanks and storage containers;
            (6)  Water separators;
            (7)  Filter sludge recovery;
            (8)  Distillation unit;
            (9)  Divertor valves;
            (10) Saturated lint from lint basket; and
            (11) Cartridge filters.
       (b)  Vaporaleakage shall be determined by        .-•
       (c)  Dryer exhaust concentration shall be determined by	.—'
       (d)  The amount of solvent in earth filter (2.e.'l)  and distillation
       wastes (2.e.2) shall be determined by utilizing the test method
       described by the American National Standards Institute in the paper,
       "Standard Method of Test for Dilution of Gasoline-Engine Crankcase
       Oils."

3/   See footnote 1, above.
4/   See footnote 2, above.
                                                       i
                                    1-5

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                     2.0  SOURCES AND TYPES OF EMISSIONS    i
 2.1  INDUSTRY DESCRIPTION
      Dry cleaning is a service industry, involved in the cleaning of apparel
 or renting of apparel.  Basically, the industry is segregated into three
 areas based on customers and types of services offered.  These services
 are:  (1) coin-operated, (2) commercial, and (3) industrial.
      Coin-operated dry cleaning facilities are usually part of a "laundromat"
 facility (although there are separate installations), and are operated on
 either an independent or a franchise basis.  They provide a low cost "self-
 service" type of dry cleaning without pressing,  spotting, or  other services.
 Processing is generally about 7200 kilograms (16,000 pounds)  of clothes per
 year per store (two systems per store).   Commercial  dry cleaning plants are
 the most familiar type of facilities, offering the normal services of cleaning
 soiled  apparel and other fine goods.   They include:   small  neighborhood dry
 cleaning shops operating on an independent basis ("Mom and  Pop"  dry cleaners),
 franchised  shops  (e.g.,  "One Hour  Martinizing")  and  specialty cleaners,
 handling leather  and other  fine goods.   Neighborhood  dry cleaners  generally
 process  about 23,000 kilograms (60,000 pounds) of  clothes per year.   The
 industrial  cleaners  are  the largest dry  cleaning plants  predominantly supplying
 rental  services of uniforms or other  items  to business,  industrial, or
 institutional  consumers.  A typical industrial cleaner processes 240,000 to
 700,000  kilograms  (600,000 to  1,500,000 pounds) of clothes per year.  They
 are generally associated with  large water laundry services.   Nationwide perc
 emissions are 21,400 metric tons for coin-op, 123,000 metric tons for
commercial and 13,600 metric tons for industrial  dry cleaners.
                                                            ,i
                                    2-1

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2.2  DRY CLEANING PROCESSES AND EMISSIONS                                          £K
2.2.1  The Basic Process
     Dry cleaning is the cleaning of fabrics in an essentially non-aqueous
solvent.  The principal steps in the process are identical  to those of
ordinary laundering in water:  (1) one or more washes (baths) in solvent;
(2) extraction of excess solvent by spinning; and (3) drying by tumbling
in an air stream.  The solvents used are categorized into two broad groups:
(1)  petroleum solvents which are mixtures of paraffins and aromatic hydrocarbons
similar—but not identical—to kerosene, and (2) synthetic solvents which  are
halogenated hydrocarbons—perchloroethylene and trichlorotrifluoroethane.
Differences between the dry cleaning procedures for these two groups of
solvents are due primarily to three factors:
     • Synthetic solvents are much more expensive than petroleum solvents.
     • Petroleum solvents are combustible, while synthetic solvents are             tf|))
       nonflammable.
     • The densities of synthetic solvents are about twice that of petroleum
       solvents.
This document discusses one synthetic solvent, perchloroethylene, only, as it
is by far the most prevalent solvent type.  The other synthetic solvent,
trichlorotrifluoroethane, is not considered to be a  photochemically reactive
VOC.  Petroleum  solvent systems as discussed in Chapter  1 are being examined           *
in a separate EPA study at present.  By way of illustration, Figure 2-1 is a
                                                                                       >f
schematic of a perchloroethylene plant.
2.2.2   Perchloroethylene  Systems and Emissions
     Perchloroethylene  machines find their major use  in commercial dry cleaning
plants  (about 74 percent  of  systems).  The  typical neighborhood dry cleaner uses

                                     2-2

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a perch!oroethylene based process.  However, perch!oroethylene-based equipment
is also used in the industrial sector (EPA tested one in their test program -
See Appendix A), making up about 50 percent of the systems and is used in the
coin-op sector where it is the predominant solvent by far (fluorocarbon
machines account for about 3 percent of the market; petroleum, none).
2.2.2.1  Solvent Characteristics - Although other chlorinated hydrocarbon
solvents have been used for dry cleaning in the United States, perch!oro-
ethylene is the only chlorinated solvent seeing significant; use at this time.
An estimated 160 million  kilograms (346 million pounds) of "perc" is used
annually for dry cleaning purposes.   The solvent may be generally
characterized as follows:                           '       ;      •
        .  Non-flammable,
        .  Very high vapor density,                        ,    •       .• -
        .  High cost ($.49/kg)                           -  ;
        .  Aggressive  solvent properties.
In spite of the higher cost per gallon of perc, solvent costs for perc plants
are quite competitive  with those  for petroleum solvent plants, its chief competitor,
because the former are always used with solvent recovery equipment.  Stricter
fire codes, increases  in  petroleum solvent  costs,  and environmental considerations
have resulted in the use  of perc-based equipment for many new plants.
2.2.2.2 Equipment Characteristics - Perc machines may be Cither transfer or
dry-to-dry types.  This refers to the method of drying the clothes.  In a dry-
to-dry  system,  the drying is  done in the same tumbler as the washing.  Clothes
are put in dry  and come out dry.  For transfer systems, the dryer is separate and
clothes are transferred from  washer to dryer.  The great majority of perc machines
are transfer units.                                        ',      '
                                     2-3                   '

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     A typical commercial perc plant has a 14-27 kg (30-60 Ib) capacity
washer-extractor with a reclaiming tumbler of equivalent size.  According
to one survey about half the plants have carbon adsorption units to reduce
                    ?                                                        q
solvent consumption.c  A more complete survey puts this figure at 35 percent.
Apparently many large perc plants in the industrial sector use adsorption
whereas the majority of commercial plants do not.  These control devices
are discussed in Chapter 3.0, Emission Control Technology. ;
2.2.2.3 Emission Characteristics (see Table 2-1 for summary of emissions) -
As stated above, perc plants frequently have vapor adsorbers to reduce solvent
usage.  Typical solvent losses for both controlled and uncontrolled perchloroethylene
dry cleaning plants are shown in Table 2-1  as reported by IFI.4  These are
for well-operated plants.  Table 2-1 also gives average emissions from three
EPA tests discussed in Appendix A. 5'6'7                   ;
                                                           I
     Table 2-1 shows that the uncontrolled plant can have high emission rates
from filter muck and the dryer exhaust.  The figure for evaporation at the
dryer assumes that a condenser is used to recover a certain portion of the
stream.  Actually, after wash and extraction, dry cleaned materials contain
about 20-25 kilograms of solvent per 100 kilograms of clothes.  All of this
solvent is vented to the condenser.  A well-operated condenser reduces this
level to 3-6 kg per 100 kg.
     Other sources include evaporation at the washer (from transfer operations
generally), distillation and filter waste disposal, and miscellaneous emission
 sources.   These miscellaneous  emission sources  include:  losses  from  pumps,  valves,
flanges, and seals; evaporative leak losses from storage vessels; chemical
and water separators; and minor inefficiencies in handling solvent and material.
                                   2-5

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    Table  2-1.   SOLVENT  LOSSES  FROM WELL  OPERATED  PERCHLOROETHYLENE  PLANTS
                 (kilograms  of solvent  per 100  kilograms  of clothing)
                                                                           8,9,10,11
Source
Evaporation @ washer
Evaporation @ dryer
Vapor adsorber exhaust
(properly operated)
Retention in filter muck
• Rigid tube filter-no cooker
• Rigid tube filter-muck cooker
• Regenerative filter-muck cooker
Retention in paper cartridges
• Drained
• Dried in cabinet vented to
adsorber
Retention in still residue
Miscellaneous losses (leaks)
Average Total Loss
IFI data .
(EPA data)b
Plants without
vapor adsorber
0.54 (1)
3 (6)
-

14
1.6
1 (1)

1.8 (0.6)
-
1 .6 (no data)
2 (1)
8-21 c
IFI data ,
(EPA data)0
Plants with
vapor adsorber
0
0
0.3 (0.3)

14
1.6
1. (1)

1.8 (0.6)
1.2
1.6
2 (1)
6-18c (3-5)
a  Figures represent well-operated systems.  Average emission rates
   by industry survey estimated at 12 kg/100 kg.

b  EPA data in parenthesis.          •

c  These ranges are high because plants could not operate economically
   without a muck cooker if filter is used.
                                                                                  o
                                   2-6

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    According to IFI data, the usual plant has a regenerative filter with
a muck cooker, and this results in a total consumption rate of about 8 kg
of solvent per 100 kg of clothing.  (According to one vendor, more and more
plants are using cartridge filters-, now in about 55 percent of commercial
        12
plants.)   For an adsorber-equipped plant, the corresponding solvent usage
is less than 5 kg per 100 kg of clothing, which is equivalent to a 40 percent
loss reduction.   It should be emphasized that these usage levels are for
well-operated commercial and industrial plants; average losses--including
controlled and uncontrolled plants—are estimated to be about 10-12 kg of
solvent per 100 kg of clothes cleaned    and 20 kg per 100 kg for coin-op.14
Coin-op stores generally have higher emission rates because of underloading
of equipment, lack of carbon adsorption technology, and unattended systems.
                                    2-7

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2.3   REFERENCES
    1.  Data supplied by industry representatives—compiled by Ernst & Ernst,
December 14, 1976.  Eight percent added as estimate of imported perc.
    2.  Watt, Andrew, IV, and William E. Fisher, "Results of Membership Survey
of Dry Cleaning Operations," IFI Special Reporter No.3-1, January-February 1975.
    3.  Mayberry, J.L., President, R.R. Streets and Company, Inc., letter
to John H. Haines, EPA, March 2, 1977.
    4.  Fisher, William E., "The ABC's of Solvent Mileage," Part One, IFI
Special Reporter, No.3-4, July-August, 1975.
    5.  Kleeberg, Charles F., "Material Balance of a Perchloroethylene Dry
Cleaner Unit," test report to James F. Durham, on test in Hershey, Pennsylvania,
March 17, 1976.
    6.  Kleeberg, Charles F., "Material Balance of an Industrial
Perchloroethylene Dry Cleaner," test report to James F. Durham on test
in San Antonio, Texas, May 14, 1976.
    7.  Kleeberg, Charles F., "Material Balance of a Small Commercial
Perchloroethylene Dry Cleaner," test report to James F. Durham on test in
Kalamazoo, Michigan, May  17, 1976.
    8.  Ibid, Reference 4.
    9.  Ibid, Reference 5.
   10.  Ibid, Reference 6.
   11.  Ibid, Reference 7.
   12.  Cunniff, Joseph L., Vice  President of Puritan Division, letter to
Robert T. Walsh, EPA, November 21,  1978.

                                    2-8

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13.  Ibid, Reference 2.
14.  Anonymous Dow Chemical Survey submitted by Joseph Qunniff, Puritan
Filters, to EPA on March 3, 1977.
                                   2-9

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                        3.0   EMISSION CONTROL TECHNOLOGY



     The purpose of this chapter is to discuss control techniques for both


existing and new perchloroethylene dry cleaning plants and to define emission


levels that can be achieved with available control technology.  Chapter 4.0


is an assessment of the costs of applying the technology.


3.7  USE OF CONTROL TECHNIQUES


     For the most part, solvent emission controls for dry cleaning plants


have developed out of economic necessity.  In order for  a  more costly
                                                         ?

synthetic solvent like perchloroethylene to compete with inexpensive


petroleum solvents, a substantial degree of solvent recovery is necessary


during the drying operation.  Solvent is recovered by condensation on all


perc solvent dryers; many are equipped with adsorbers.  Table 3-1 shows


the extent of controls on perchloroethylene systems in the three industry


sectors.

         Table 3-1.  POTENTIAL AND APPLIED CONTROL TECHNIQUES
                             FOR DRY CLEANING PLANTS     ,

Carbon adsorption
Housekeeping
Incineration
Minimize solvent loss
in wastes
Industry Sector
Coin-Op
N/U
Very limited
N/A
To a degree
Commercial
35%
To a degree
N/A
To a degree
Industrial
50% (est.)
To a degree
N/A
To a degree
 N/A  -  Not applicable

 N/U  -  None used
                                      3-1

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3.2  TYPES OF CONTROL TECHNIQUES
3.2.1  Carbon Adsorption
    Activated carbon is used in many applications for the removal of organic
compounds from carrier gases (usually air) by adsorption.  It has been used
extensively to recover perch!oroethylene from dry cleaning systems.  Adsorption
is the property of a surface to retain molecules of a fluid which have con-
tacted the surface.  Perch!oroethylene can be retained on carbon very easily.
The working bed capacity (weight of solvent per weight of carbon, expressed
as percent) for perch!oroethylene is about 20 percent.
    The cost of perch!oroethylene solvent has encouraged and necessitated
recovery of some kind.  The earliest units used water cooled or refrigerated
condensers to control 85-90 percent of losses from the dryer.  Rising solvent
costs made adsorption of the remaining 10-15 percent attractive.  Carbon
adsorption has been used on perch!oroethylene units for years.
     EPA collected data during plant tests on three carbon adsorption units
used with perch!oroethylene systems.  Appendix A of this report details the
results of those tests.  Table 3-2 summarizes the data and shows inlet and
outlet concentrations associated with each of the three tests.  Outlet
concentrations ranged from 2 to 100 ppm as perch!oroethylene.  Collection
efficiencies ranged from 96 percent to 99.6 percent.
     Also seen in Table 3-2 is a list of the sources controlled.  In each
case, vapors were drawn off at the dryer and washer, at least.  Generally,
a current of fresh air is required for occupational safety at the operator's
face when loading and unloading.  This is usually accomplished by an
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a duct at the machine door lip.   The air, laden with solvent vapor, is then
passed to the carbon adsorber.
     Dryers usually vent during specific points in the drying process.  The
dryer exhaust is generally chilled to remove solvent and then reheated and
recirculated to the dryer.  At the end of the drying cycle, the clothes are
hot and must be cooled gradually to avoid wrinkles.  Fresh air is drawn in
(in a process called deodorizing) and is vented to the adsorber (since
condensation would not be effective on the low concentration stream).   Dryers
also vent to the adsorber whenever the overheat thermostat is actuated causing
cool air to enter an overheated dryer.  At least one system design vents
dryer exhaust to the adsorber continuously (Plant C was an example) for
system simplification.
     Floor vents are installed to control fugitive vapors around the machines
and to draw vapors from solvent spills.  These vents have been located on
the floor next to the front of machines and next to filter systems.  There
is some evidence that these vents are more effective if they are located
at the same level as the solvent emission; perchloroethylene vapors do not
                                                               2
necessarily drop to the floor because of the solvent's density.
     There is no technical reason why all sources in dry cleaners vented
through a stack or duct to atmosphere cannot be directed to a carbon adsorber.
This includes distillation units, washer loading vents, storage tanks, and
chemical separators.  None of these vents has an extremely high volume of
vapor to be treated.  Emissions from these sources and other pertinent data
are described in Appendix A.
     For perch!oroethylene based units, carbon adsorption can be used to
achieve 100 ppni or less outlet concentration on the sources discussed above.
                                   3-4

-------
 Space requirements  vary with the size of the unit.   For the three plants
 tested the adsorber floor  space is  shown in  Table 3-2.   These area estimates
 include piping,  canister,  and ductwork.
      Coin-operated  perch!oroethylene  systems have special ^problems.   There
 is  generally  no  steam  demand at coin-ops and thus no  steam  boiler.   In most
 cases,  the steam necessary to desorb  a carbon bed does  not  exist  at  these
 plants  and necessary space for an adsorber is not available.   Either the
 carbon  bed must  be  portable and taken  off-site for regeneration or a steam
 boiler  must be added at  each site.  EPA  examined  the  feasibility  of
 regenerating  carbon  beds off-site and  found  space requirements and costs
 high.   (The capacity of  the bed must be  large to  accommodate  solvent
 recovered  over long  periods  of time or else  the carbon must be regenerated
 often.)  While coin-operated perch!oroethylene dry cleaners have  had  only limited
 use of  carbon adsorbers, the technology  for  perchloroethylene recovery is
 certainly  demonstrated.  Costs  are evaluated  in Chapter 4.b and include boiler
 installation costs.   EPA will  continue to evaluate methods! of controlling
 coin-operated systems.
 3.2.2   Housekeeping
     The losses associated with  poor maintenance of equipment are difficult
 to quantify.  A few devices, however, control major emission sources in dry
cleaning plants; neglect of these devices can significantly contribute to
high solvent loss.  Other sources of emissions—fugitive or miscellaneous--
are not associated with "point losses" or losses from obvious areas such  as
venting of dryers or disposal  of filter wastes.   Fugitive emission points
 include leaks from valves, flanges, seals, and covers on storage tanks.
                                     3-5

-------
     There are two types of losses from both point and fugitive emission
sources—liquid and vapor.  Liquid losses can be detected by sight—the
brown residue associated with a solvent leak is familiar to any operator.
                                 3
One solvent manufacturing company  estimates that a leak of one drip per
second equates to as much as four litres of solvent per day.  Because of
the volatility of the solvents, these liquid leaks are eventually evaporated
to atmosphere.  Vapor leaks can be detected by smell, application of soap and
water to sources, or hydrocarbon detectors.  EPA is currently evaluating the
significance of vapor leaks and also a number of methods of detecting vapor
leaks and will advise at a later date on the optimum approach.  Our objective
is to develop an inexpensive monitor which can be used to detect major vapor
leak sources.  Vapor losses usually occur at evaporative points and tears in
ductwork.  The solvent manufacturer has submitted a list of common emission
areas4 which should be checked periodically to control these losses.  The
                                                             c c -j
following checklist is similar to those used by other vendors  »  '  to advise
customers on how to maintain equipment.
 Liquid leakage areas  include:
     a)  Hose connections,  unions,  couplings and valves.
     b)  Machine door  gasket  and  seating.
     c)  Filter head gasket and seating.
     d)  Pumps.                                                                          "
     e)  Base tanks  and  storage containers.
                                                                                        *.
     f)  Water separators (lost in  water due to poor  separation).
     g)  Filter sludge recovery (lost  in sludge by improper recovery).
     h)  Distillation  unit.
     i)  Divertor valves.                                                             ^
     j)  Saturated lint  from lint basket.
                                     3-6

-------
           k)  Cartridge filters.
       Vapor leakage areas include:
           a)  Deodorizing and aeration valves on dryers (the seals on these
 valves need periodic replacement).
           b)  Air and exhaust ductwork (solvent lost through tears in duct).
           c)  Doors left open are problems.  Leaks in the system should be
 confined to the closed washer and/or dryer if possible.
           d)  Button traps and lint baskets should be opened only as long
 as necessary.
       Other areas include:                               ,
           a)  Lint screens and bags, fan  blades and condensers  can adversely
 affect capture systems if they are clogged or caked with ,lint.
           b)  Overloading and underloading can increase losses.   Overloading
 makes drying difficult.   Underloading is  self-defeating since most losses
 are fixed in the system.
           c)  Inefficient extraction; due  to overloading or  loose  belts can
 cause poor drying.
      Rapid detection and  repair  of leaks  is essential to minimize solvent
 losses.   Table 3-3  shows  how  neglect of certain  pieces  of equipment can
 increase  solvent  consumption  from  the well-controlled plant usage of 3-5 kg
 per  100 kg of clothes cleaned to the  neglected plant losssof greater than
 15 kg per  100 kg.  These data were derived  from  plant tests, vendors,
 industry data,  and estimates.  In one solvent company survey, plants reported
 solvent usages  from less than 2 kg per 100 kg to above 35 kg per  100 kg.
Average use was around 12 kg per 100 kg.8   Good housekeeping practices
require very little additional effort in existing plants. I No new equipment
is  needed  and little cost is incurred.
                                    3-7

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 3.2.3  Incineration
      Incineration, while technically feasible for control  of perch!oroethylene
 is impractical  for halocarbons.
      Perch!oroethylene is virtually inflammable and large  quantities  of
 supplemental  fuel  must be used to combust it.   Incineration can  produce
 hydrogen chloride  (HC1), chlorine (Cl)  and phosgene (COCK).9 All  of these
 compounds can be removed by scrubbing exhaust  gases with water.   However,
 some  water treatment  would  likely be required.           ;
 3.2.4  Waste  Solvent  Treatment
       Solvent is recovered  from  filter muck (diatomaceous  earth,  carbon,
 lint, detergents,  oils,  and solvent) and from distillation bottoms.   In many
 perch!oroethylene  systems solvent is "cooked"  out of filter materials.   EPA
 data   '   show  that well controlled plants can make this potentially  large
 emission source an insignificant one by direct and indirect steam distillation.
      Other options for  disposal  include  recovery  off site  by a solvent
disposal  vendor and cartridge filtration.  Cartridge filters have inherent
design  advantages  (they  are  confined and  contained) which give them a low
emission  factor (1  kg/100 kg) when properly drained and dried and are
 applicable to low  soil  loadings  such as commercial operations.12
      Solvent losses from distillation bottom disposal can  be reduced in
oil cookers (similar to muck cookers) to levels well below  1 kg/100  kg of
clothes cleaned by  proper operation of existing equipment according  to a
test conducted by EPA.13  Operators should avoid premature  shutdown  of the
distillation unit.
                                    3-9                  '

-------
    There would be no additional  space requirements  for filter  units  in
perch!oroethylene systems and, of course, no additional  space would be
required to improve the "cooking" of existing distillation systems.'
3.3  SUMMARY
    This chapter has discussed control techniques for both existing and
new perch!oroethylene dry cleaning plants.  Carbon adsorption  can be  used
to control perc vapor vented from the washer, dryer, storage tanks,
distillation systems, and chemical separators to less than 100 ppm.
    Incineration does not appear applicable to synthetic solvent plants
because of associated environmental penalties.
    Muck cookers are generally used in perch!oroethylene plants and,  if
operated properly, maintain losses at less than 1 kg/100 kg of clothes
cleaned.  Drained and dried cartridge filters achieve less than 1 kg  per
100 kg of clothes cleaned based on EPA tests and thus are another effective
means of control of this source.
    Miscellaneous emissions can be controlled through the use of better
housekeeping—aided by portable,  inexpensive monitors (to be developed
by EPA).
    In short,  the emissions from  dryers,  washers, distillation units,
                                                                                      *s
holding tanks,  filter systems, and fugitive  emission sources can all  be
controlled  by  the above  named systems.   Table 3-4 summarizes sources,
applicable  control  techniques, and achievable emission  levels.
                                  3-10

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3.4   REFERENCES
      1.  Barber, J.W., Research Director, Vic Manufacturing Company,
Minneapolis, Minnesota, letter to C.F. Kleeberg, EPA, February 6, 1976.
      2.  Discussion with William Fisher, IFI, Silver Spring, Maryland,
August 7, 1975.
      3.  Anonymous, Dow Chemical U.S.A., "Poor Solvent Mileage - Professional
Dry Cleaning Plants," submitted by Bob Lundy, Dow Chemical to Charles F. Kleeberg,
EPA, March 16, 1976.
      4.  Reference 3, Op. Cit.
      5.  Anonymous, Hooker  Industrial Chemicals, Bulletin Number 185,
"Hooker Handbook for Dry Cleaners," p.10.
      6.  Vic  Manufacturing  Company,  "Installation  and Operation Instruction
for Vic Models 221 and 222," VMC  1195.
      7.  Reeves, H.E., "Causes of Excessive  Loss of Perch!oroethylene,"
IFI Practical  Operating Trips  Bulletin,  p.91, January, 1969.
      8.  Anonymous,  Dow Chemical USA, "Dow Customer Survey," submitted by
Bob Lundy,  Dow Chemical to Billy  C. McCoy, TRW  Services.
      9.  "Chlorinated Solvents:  Toxicity, Handling Precautions,  First-Aid,"
Dow Chemical,  U.S.A.,  Form No.lOO-5449-74R.
      10.   Kleeberg,  C.F.,  "Testing  of Commercial  Perch!oroethylene  Dry
 Cleaner," test report on  Hershey, Pennsylvania, test, to James  F.  Durham,
 EPA,  May 14, 1976.
      11.   Kleeberg,  C.F.,  "Testing  of Industrial  Perchloroethylene  Dry
 Cleaner»" test report on  San Antonio, Texas,  test,  to James  F.  Durham, EPA,
 May 14, 1976.
                 !                     3-12

-------
      12.  Kleeberg, Charles F., "Testing of Commercial Perch!oroethylene
                                                         .1
Dry Cleaner," test report on Kalamazoo, Michigan,  test, to James F. Durham

EPA, May 17,  1976.                                       ;


      13.  Ibid, Reference 11.
                                      3-13

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                          4.0  COST ANALYSIS            i
4.1   INTRODUCTION                                       ,
4.1.1  Purpose
      The purpose of this chapter is to present estimated costs for applying
emission control techniques to perchloroethylene dry cleaning systems.
Cost  data will be supplied for hydrocarbon control at perchloroethylene
solvent plants.
4.1.2  Scope                                ,            '   ,
      Control cost estimates will be presented for three types of facilities
using perchloroethylene solvents:  coin-operated plants, industrial plants,
and commercial dry cleaners.  These estimates will reflect the retrofit
control cost of carbon adsorption for control of washer and dryer emissions.
No incremental costs fpr housekeeping controls are presented.
4.1.3  Use of Model Plants
      Control cost estimates are presented for typical model plants in the
dry cleaning industry.  Specific model plant parameters will be presented in
subsequent portions of this chapter.  It is admitted that control costs at
actual installations may vary, sometimes appreciably, from the costs
described for the model plants.  However, the difficulty of obtaining
actual plant control cost information makes the use of model plants a
necessity.  To the extent possible, EPA has incorporated: actual plant cost
information into the cost analysis.
     Cost information is presented for typical existing model facilities.
                                                        i
In some cases, model plants of varying sizes have been developed.  The
purpose of this is to show the relative variation in control equipment
                               4-1

-------
costs with plant size.  Whereas the plant sizes chosen for analysis are  ,          W
believed to be representative of plants in the industry, no attempt has
been made to span the range of existing plant sizes.
4.1.4  Bases for Capital Cost Estimates
     Control cost estimates are comprised of installed capital costs and
annualized operating costs.  The installed capital cost estimates reflect
the cost of designing, purchasing, and installing a particular control
device.  These estimates include costs for both major and auxiliary equip-
ment, removal of any existing equipment, site preparation, equipment
installation, and design engineering.  No attempt has been made to include
costs for lost production during equipment installation or start-up.  All
capital costs reflect first quarter 1978 costs.  In general,  information
on capital costs for alternative control systems has been developed through
UUHUW^;. ni»ii «,«,,„,«, v^M.^...-..- ,^,.~~.*.  „..	, 	  	
from EPA files has been used along with data from previous contractor
studies of the dry cleaning industry.
4.1.5  Bases for Annualized Cost Estimates
     Annualized cost estimates include costs for operating labor, mainte-
nance, utilities, credits for solvent recovery, costs for waste disposal,
and charges for depreciation, interest, administrative overhead, property
taxes, and  insurance.  A return on the pollution control investment is
not included in the annual cost estimate.  All annualized costs reflect
                                                                                      *•.
second quarter 1978 costs.  Operating cost estimates  have been developed
by EPA from in-house files.  Credits for solvent recovery have been calcu-
lated based on emission factors presented in Chapter  3 and the current
market price of $0.49/Kg for perchloroethylene solvent.   It  is estimated          ^
                                   4-2

-------
 that  this  solvent  price  could  vary  2Q%  depending  on  location  and
 quantities purchased.  Estimates  of depreciation  and  interest costs
 have  been  calculated by  EPA by using a  capital  recovery  factor based
 on the assumptions of  an  interest rate  of  10  percent  and a  depreciable
 equipment  life of  10 years.  In addition to costs for depreciation and
 interest,  an additional  charge of 4 percent of  total  capital  has been
 added for  administrative  overhead,  property taxes, and  insurance.
 4.2   PERCHLQROETHYLENE SOLVENT PLANT COST  ANALYSIS
 4.2.1  Model Plant Parameters
      Control costs have  been developed  for three  types of perchloroethylene
 solvent dry cleaning plants.   These are coin-operated plants,  commercial "
 plants, and industrial plants.  The model  plant parameters  that were
 developed for these facilities  are  displayed  in Table 4--1.  The model
 perchloroethylene plant parameters  are  based  upon industry  contacts and
 EPA studies of the industry.   Typical plant sizes for perchloroethylene
 solvent plants are two 3.6 Kg  unit  in a coin-op store, one  11  Kg unit in
 a commercial plant and one 93  Kg  unit in an industrial plant.
 4.2.2  Control Costs - Perchloroethylene Plants        ;,
     Costs for control  of washer and dryer emissions from coin-operated,
commercial, and industrial perchloroethylene solvent plants have been
calculated.
     Table 4-2 presents costs for carbon adsorber controls for five sizes
 of model new and existing perchloroethylene plants - 3.6 Kg/load, 11 Kg/load,
 23 Kg/load, 91 Kg/load, and 114 Kg/load.  Costs are presented  in terms of
 installed capital costs,  annualized costs* and the cost per kilogram of
                                   4-3

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hydrocarbon controlled for the different sizes.  Note that for carbon
adsorption that not only are total capital costs and total annual ized
costs presented but also presented is information on the cost-effectiveness
of each size plant.  For example, for the model 11 Kg/load commercial
plant the total installed capital cost from Table 4-2 for a carbon adsorber
is estimated to be $3,200, the net annual ized cost is estimated to be
$500/year, and the cost per kilogram of hydrocarbon controlled is estimated
to be $0.31 /Kg.
     This estimate of $0.31/Kg is determined by dividing the net annual ized
cost of $500/year by the controlled emissions of 1600 Kg/year.  The
controlled emissions were determined from Table 3-4.  Table 4-3, which
shows that control option #1 for perch! oroethylene solvent plants
combines carbon adsorption, waste solvent disposal, and good housekeeping
practices.  The recovered emissions are 6.5 Kg/100 Kg (11.5 Kg-5 Kg).  An
11 Kg load system doing 2210 loads per year (Ref. Table 4-1) cleans
24,300 Kg/year of clothes.  Multiplying this figure by 6.5 Kg/100 Kg results
in controlled emissions of approximately 1600 Kg/year.
     It should be noted that emission reductions attributable to housekeeping
controls have been included in some control options.  As stated before,
however, no costs for housekeeping controls have been included since they
are believed to be adequately accounted for by the charge of four percent
of total capital that is allocated to all control systems to cover adminis-
trative overhead  taxes, and insurance and the 6 percent of total capital
allocated to cover operating and maintenance.  Also note that costs for a
carbon adsorber for 3.6 Kg plants are larger than carbon adsorber costs for
                                    4-6

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either an 11 Kg plant or a 23 Kg plant.  This is because it was assumed
that the 3.6 Kg plants would not have steam available for regeneration
of the carbon but the larger plants would have such capacity.  Therefore,
it was necessary to include the cost of a small steam boiler in with
the cost of the carbon adsorber for the 3.6 Kg plants.  In the case of
the larger perch!oroethylene plants it was assumed that steam was available
and no costs were included for purchase of a boiler.
4.2.3  Cost Effectiveness
     Summary costs in terms of the cost per kilogram of solvent emissions
controlled is presented in Table 4-3 for different size perch!oroethylene
plants.  Control costs decrease rapidly as the size of the unit controlled
increases.  For example, carbon adsorber controls cost $7.33/Kg in a 3.6
Kg/load facility but decrease to a net credit of ($.41/Kg) for a 114 Kg/
load facility.

4.3  REFERENCES FOR CHAPTER 4.0
(1)  Cost data and equipment brochures furnished by Mrs. Pat King, Executive
     Assistant, HOYT Manufacturing .Corporation, and Mr. Peter Zizzi, Sales
     and Service Engineer, Fulton Boiler Works, Incorporated.
(2)  Information furnished fay Mr. A_ C. Cullins, Laundry and Dry Cleaning
     Consultant, Standard Laundry Machine Company, Inc.
(3)  Virginia-Carolina Laundry Supply Company, 639 Junction Road,
     Durham, North Carolina.
(4)  Operating cost based on projections of equipment brochures and
     specifications furnished by Vic Manufacturing Company, 1620 Central Ave
     N.E., Minneapolis, Minnesota 5541.
                                                                                    O
                                  4-8

-------
                  5.0   EFFECTS OF APPLYING THE TECHNOLOGY

       The air pollution impacts and the other environmental consequences of
 applying the control technology presented in Chapter 3.0;are discussed in
 this section.  A comparison will be made between emissions from a typical
 uncontrolled plant and those from plants using alternative control techniques.
 Beneficial -and adverse impacts which may be directly or Indirectly attributed
 to the operation of these systems will be assessed.
       Both direct and indirect impacts are involved in the control
 of dry cleaning plants.  For example, reduced air emissions, increased water
 consumption, and increased energy demand are all impacts directly related to
 the use of carbon adsorption recovery systems.  Incremental emissions from
 a boiler used to supply additional steam to the adsorber are an indirect impact.
 5.1  IMPACTS ON VOC EMISSIONS
       Pollutant emission  factors  for the individual  uncontrolled plant
 are shown in Table  5-1.   They are based.upon  data  from  the  literature
 (including trade associations,   '2 equipment  vendors,3  and  solvent
 companies4)  and from stack  test data5'6'7  obtained  during this  study.
      Table 5-2 shows the individual sources of emission within the plant
and the achievable level with applicable control technology for each source.
The methods include carbon adsorption for washers and dryers;; longer dis-
tillation times for distillation units; longer cooking times or cartridge filter
substitution for filter muck;  and  leak prevention measures for miscellaneous
losses.
                                5-1

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5.2  OTHER AIR POLLUTION IMPACTS
     There are no other air pollution impacts associated with any of the
control techniques.
5.3  WATER POLLUTION  IMPACTS
                                                                      ]
     Dry cleaning processes usually discharge some water to sewage facilities.
Perch!oroethylene plants use water cooled condensers.  Some plants have water
washes to remove soluble soils.  Many perchloroethylene plants use steam for
heating dryer air, presses and finishing equipment, and for distillation or
muck cooking purposes.  The air pollution control systems envisioned for
dry cleaning facilities will add to the amount of water used as indicated
                                            8 9 10                       11
in Table 5-3.  Data are based on plant tests *y*tv and vendor submittals.
It should be noted that increased water usage is estimated only for those
sources where water may come in contact with solvent.  This does not include
condenser water which will total about 750 liters per day for a commercial
system.                            	
     The primary addition would be the steam required to regenerate the
carbon.   Typically about 45 kg of steam is required per 100 kg of clothes
cleaned.  Condensate is generally disposed of by sewer (about 55 liters per day).
     Also shown in Table 5-3 is the steam (and thus water) required for a
muck cooker or distillation unit.  These units are generally present in
perchloroethylene plants.
     EPA has not promulgated or proposed effluent guidelines for dry cleaning
solvent content in waste water streams.  During plant tests for this project,
EPA took water samples of streams from carbon adsorbers and found them to
contain less than 100 ppm perchloroethylene by weight.  The effluent was
disposed of in sanitary sewers.
                                     5-4

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                                            5-5

-------
              Table 5-4.   PERCHLOROETHYLENE  SOLVENT  IN  EFFLUENT WATER
                          AS A RESULT OF CARBON ADSORPTION  (MODEL PLANTS)
                                  Increased water usage        Solvent disposed of
                                    .(kg/year)                      (kg/year)
Coin-Op                                1,600                        0.2

Commercial                            13,500                        1.4

Industrial                           135,000                        13.4



   Assumes 100 ppm in effluent
                                                                                     4ft

-------
     Using the figure of TOO ppm in water for perch!oroethylene plants,
Table 5-5 shows that 13.5 kilograms of solvent per year will be added to
effluent from typical industrial plants; less from coin-op arid commercial
establishments.                                           ;
5.4  SOLID WASTE IMPACT
     There is little solid waste impact associated with afr pollution control
techniques.  Carbon in adsorbers eventually must be replaced because of
"blinding" of the bed by small pieces of lint and other particulate.  Vendors
and users have estimated the life of carbon at up to 30 years.  The carbon can
be regenerated, but may be discarded every 15 years.  Each commercial perch!oro-
ethylene plant uses around 100 kilograms of carbon.  Large industrial perc
plants use up to 450 kilograms.  The solid waste impact from the entire industry
is estimated to be insignificant—even if all plants used carbon adsorbers.
     The techniques used to reduce emissions from solvent .filters do not
increase solid waste at all; they do reduce the amount of solvent in discarded
muck .and filters.  The emission reduction from control of filter disposal is
part of the total emission reduction shown in Table 5-2.
5.5  ENERGY IMPACT
     Certain control techniques require additional energy..  Carbon adsorbers
require steam for desorption.   Muck cookers and distillation oil cookers both
require steam, but in many plants already equipped with boilers the energy
increment is small.
5.5.1  Impact on Model Plant
       Table 5-5 shows the energy impact of the above alternatives on model
plants.  There is also the possibility of an energy credit from the decreased
use of solvent which would be a result of these alternatives if implemented
in the plants.  It is estimated that at least one kilogram of fuel would be
                                 5-7

-------
                     Table 5-5.   ENERGY IMPACT OF ALTERNATIVE CONTROL
                                       LEVELS ON TYPICAL PLANT
Plant
                         Control
               10  BTU/yr
                  Usage
            10  BTU/yr
             Savings
  Net Energy
Usage (savings)

  106,BTU/yr
Coin-Op

Perch!oroethylene


Commercial
Perch!oroethylene

Industrial

Perch!oroethylene
Carbon adsorber
Muck cooker
6.6
Carbon adsorber     27
Carbon adsorber     270
                                                          (25)
              (45)
              (430)
     (18).
                                                                          (18)-
                                                                           (160)
                                          5-8

-------
required to produce one kilogram of solvent.  Table 5-5 shows this solvent
savings as an energy credit for each plant.  (Actually, the energy savings
would be creditable to the solvent producer.)  Net energy consumption is shown
as a savings.
5.5.2  Impact on Indirect Air'Pollution"         ~
      Increases or decreases in steam demand as a result of applying the
                                                         i
control techniques will influence emissions from the boiler plant.  These
emissions are considered insignificant.                  \
5.6   REFERENCES
      1.   Watt, Andrew, IV, and William E. Fisher, "Results of Membership
Survey of Dry Cleaning Operation," IFI Special  Reporter #3-1, January-
February, 1975.
      2,   Fisher, William E., "The ABC's of Solvent Mileage," Part One,
IFI Special Reporter #3-4, July-August, 1975.
      3.   Barber, J.W., Research Director, Vic Manufacturing Company,
Minneapolis, Minnesota, letter to C.F.  Kleeberg, U.S.  EPA, February 6, 1976.
      4.   Anonymous, "Dry Cleaning Industry Statistics," submitted by
Robert Lundy of Dow Chemical from Dow Survey.            <
      5.   Kleeberg, Charles F., "Material Balance of a Perch!oroethylene
Dry Cleaner Unit," test report to James F. Durham on test in Hershey,
Pennsylvania, March 17, 1976.
      6.   Kleeberg, Charles F., "Material Balance of an Industrial,
Perch!oroethylene Dry Cleaner," test report to  James F. Durham,  on test
in San Antonio, Texas, May 14, 1976.
      7.   Kleeberg, Charles F., "Material Balance of Small  Commercial
Perchloroethylene Dry Cleaner," test report to  James F. Durham on test
in Kalamazoo, Michigan, May 17, 1976.
                                    5-9

-------
      8.   Ibid,  Reference 5.
      9.   Ibid,  Reference 6.
     10.   Ibid,  Reference 7.
     11.   Vic Manufacturing Company, "Model  221  Strato Dry to Dry Series
Specifications," Form Number 221-1083, June, 1971.
                                       5-10

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                          6.0   ENFORCEMENT ASPECTS


 6.1   AFFECTED FACILITY
                                                         l

      In formulating regulations it is suggested that the affected facility

 be defined as the dry cleaning system which includes:  washer, dryer, filter

 and purification systems, waste disposal systems, holding tanks, pumps, and

 attendant piping and valves.  This definition would cover all significant

 VOC sources of emissions  in perch!oroethylene plants.

 6.2  SUGGESTED REGULATION                                i

     The ease of determining compliance is the most important consideration

 in development of regulations for such a prevalent source as perchloro-
                                                         i    ~
 ethylene dry cleaning.  The following example regulation ^outlines the

method deemed to be optimum for reducing emissions.          •

     Rule             of	^Air Pollution Control District

     Sec-  1»  Solvent emissions from perchloroethylene dry cleaning systems

     must be limited in accordance with the provisions of this  Rule.

     Sec.  2.  Compliance with this Rule requires the following:
                   .                                      I1
         (a)  There shall be no liquid leakage of organic solvent from

         the system.                                .  ..   ;   .

         (b)  Gaseous  leakage shall  not exceed           ppm.-/
V   The EPA is currently assessing the significance of vapor leaks.   If
     deemed significant, a test method for detecting leaks  will  be developed
     and issued to interested parties.                                    '
                                   6-1

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                                                                                          I !
                                                                                          5
       (c)   The entire dryer exhaust must  be vented through a carbon
       adsorber or equally effective control device.
       (d)   The maximum organic solvent concentration in  the vent  from
       the dryer control device shall  not  exceed 100  ppm  before dilution.-
       (e)   Filter and distillation wastes.
           (1)  The residue from any diatomaceous earth filter shall  be
       cooked or treated so that wastes shall  not contain more than 25 kg
       of solvent per 100 kg of wet waste material.
            (2)  The residue from a solvent still shall not contain more than
       60  kg  of solvent per  100 kg of  wet waste material.
            (3)  Filtration  cartridges  must be drained in  the filter housing
       for at least  24 hours  before being discarded.   The drained cartridges
       should be  dried in the dryer tumbler after  draining if  at  all  possible.
            (4) Any  other filtration  or distillation system can be used  if
        equivalency to these guidelines is demonstrated.   For  purposes of
        equivalency demonstration, any system reducing waste losses below
        1 kg solvent per 100 kg clothes cleaned will  be considered equivalent.
    Sec.  3.  Sections 2(c) and (d) are not applicable to plants where an
    adsorber  cannot be  accommodated because of inadequate space or to
    plants where  no or  insufficient steam capacity is available to desorb
    adsorbers.  The District may exclude  other plants  from the  scope  of
    Sections  2(c) and (d)  if it appears that other hardships justify  such  ^
    an exclusion.
2/   Enforcement of these provisions  is dependent on  the  development  of a
     satisfactory detector and of test methods.
 1
1
 i
                                  6-2

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      Sec. 4.  Compliance Procedures                     -
          (a)  Liquid leakage shall be determined by visual inspection of
          the following sources:
              (l)  Hose connections, unions,  couplings and valves;
              (2)  Machine door gasket and seating;
              (3)  Filter head gasket and seating;
              (4)  Pumps;
              (5)  Base tanks  and  storage containers;
              (6)  Water separators;
              (7)  Filter sludge recovery;
              (8)  Distillation  unit;                   .
              (9)  Divertor valves;                       '.
              (10)  Saturated lint  from  lint basket; and
              (11)  Cartridge filters.
          (b)  Vapor leakage shall  be determined by __	.-/
          (c)  Dryer exhaust concentration shall be determined by           j/
          (d)  The amount of solvent in filter and distillation wastes shall
          be determined by utilizing the test method described by the
          American National Standards Institute in the paper, "Standard
         Method  of Test for Dilution of Gasoline-Engine Crankcase Oils."
3_/   See footnote 1, above.
4/   See footnote 2, above.
                                     6-3

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6.3   DISCUSSION
     (Sec. 2.b)  As noted, the EPA is now assessing the significance of
vapor leaks in perc dry cleaning systems.  If deemed significant, then an
inexpensive monitor will be developed which can be used by operators and
enforcement personnel to locate major vapor leaks.  If deemed insignificant,
Section 2.b can be deleted.  The study of vapor leaks should be completed
by May 1979.
     (Sec. 2.d)  Carbon adsorbers tested  by the EPA have achieved much
better control than 100 ppm outlet concentration.  This figure was chosen
because it is  high enough  to  indicate "breakthrough" of the carbon bed.
Breakthrough  is a good  indicator to  enforcement officials of improper
maintenance or operation  of the adsorber.
      (Sec. 2.e)  Figures  given for filter  and  distillation waste disposal
 are based on  limited  data and thus include margins  of  safety.  A more
 stringent standard may be achievable.   For purposes  of equivalency,  waste
 losses  should be  less than 1  kg of solvent per 100 kg  of  clothes cleaned.
      (Sec.  3)  Most  coin-op cleaners are expected to fall  under  this exemption
 clause  since  space and steam capacity are not  usually  available.   While some
 small commercial  plants may fall  under this  exemption  clause,  most commercial
 and industrial perchloroethylene  cleaners should be able  to  comply with
 Section 2 (c) and (d).
      It is expected  that because  of  the limited number of carbon adsorption
 equipment vendors, there may be problems in obtaining delivery of control
 equipment in the time frame outlined by State regulations.   Regulatory agencies
 should be sensitive to this problem and provide extensions to compliance
 schedules where deemed necessary.
                                   6-4

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                APPENDIX A.  EMISSION SOURCE TEST DATA

      EPA planned to test only as many plants as necessary to represent
 best available control in the dry cleaning industry.  A number of
 parameters which affect emissions presented themselves for consideration.
 Dry cleaning plants differ in size, control techniques, design, capacity,
 types of clothes cleaned, climate of locality,  soil  composition, age of
 equipment, and maintenance history.  The effect on emissions that some
 parameters have is small.  EPA tested typical plants in two  of the three
 industry sectors (commercial  and industrial)  as shown in Table A-l.
                                                          ;|
                    TABLE  A-l.   PLANTS TESTED  BY EPA
              (kg capacity of  washers  given  in parentheses)
                                          Perchloroethylene
              Coin-Op                        None          j

              Commercial                     X (50,18)
              Industrial                     X (140)

     A small  and  a  large  commercial perchToroethylene unit were tested.
A description of  these tests can be found in Sections A.I;and A.2.  The
difference between dry-to-dry and transfer units was explored in these
tests.
     A large industrial perchloroethylene unit was tested.  The test is
discussed in Section A.3.   The unit was a relatively new design of transfer
machine in which the washer and dryer nearly touch during transfer, thus
reducing exposure time of the damp clothes to  atmosphere.
                                  A-l

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       No coin-operated perchloroethylene machines were tested.  No
adsorption systems in use on perc coin-ops in the United States were located.
     All systems were tested by the methods discussed in Appendix B of this
document.
     All  systems were tested by the methods discussed in Appendix B of this
document.
A.I  PLANT A
     Plant A's  commercial operation, which uses perchloroethylene solvent in
a 50 kg  capacity machine, was tested by material balance (November 3-Npvember 20,
1975).  The machine is a Washex SM-11 and was installed in 1967.  The system
consists  of a washer/extractor, muck cooker, two dryers, a regenerative filter
and a Vic dual  canister carbon adsorber.  The carbon adsorber collects emissions
from the  washer door vent, the dryers, floor vents, and the distillation (muck
cooker)  unit.   EPA not only performed a material balance of the unit, but also
stack tested the carbon adsorber for perchloroethylene  (by test methods also
described in Appendix B).
     The  plant  used two operations which are not normally used in dry cleaning
services—fire-proofing and water repelling applications.  The addition of these
materials was accounted for in the material balance.
     Table A-2  summarizes data from each test in the dry cleaning test program.
It can be seen  that emissions from this unit were about 4.1 kg of solvent per
100 kg of clothes cleaned.  Outlet concentrations of perchloroethylene averaged
about 25  ppm.   This means that solvent consumption in the whole process was
about 19  kg per day of which 1 kg was from the adsorber.  Without an adsorber,
total emissions would have more than doubled.
                                  A-2

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      The adsorber was installed at least 15 years ago and the unit has had
 one major "overhaul" since that date (due tovcojqrosion).  It requires
 approximately 9 cubic meters or about 4 square meters of floor space.  The
 original washer dryer system which the unit serviced was replaced in 1967.
      This system demonstrated the performance of carbon  adsorption as a
 control  technique.   The  carbon in this carbon bed is over 15 years old
 and outlet concentrations  are only 25 ppnfwhen tested",  The^stenTsuffeFet from"
 inadequate housekeeping, however.  Liquid leaks were sighted and  buckets
 of perchloroethylene draining from water separators  were left uncovered.
 The scent of  perchloroethylene was prevalent.   EPA feels ;that operation
 of this  plant could  have been improved by better housekeeping.
 A.2  PLANT B
      During the period April  7-20,  1976,  a material  balance  was conducted
 on  a small, commercial dry  cleaning  operation  using  percKloroethylene
 solvent  (Plant  B).   A stack  test  of  a  carbon  adsorber  on the  plant was
 conducted  during one day of  testing  by Midwest  Research  Institute.  The
 stack test involved  integrated  samples  analyzed  for  total non-methane hydro-
 carbons.
     Plant  B  consists of a dry-to-dry  Vic Model  221  Strato System of 18 kg
 (40  pounds) capacity.  During the course of the  test,  approximately 170 kg
 (370 pounds)  of material were cleaned  per day.  Table A-2 summarizes the
 emission data taken from the material balance and stack test.
     The system vents to a dual canister carbon adsorber from the dryer
 (during the entirety of the drying cycle), from floor vents, and from the
washer door.  Each carbon bed operates for one cycle of the washer/dryer
and then is desorbed during the next cycle.  There were some indications
that the carbon beds were undersized.  Limited data taken;from a semi-
continuous monitor indicate that breakthrough occurred on each bed during

                                 A-3                     '

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its cycle.  Average non-methane hydrocarbon concentration in the exhaust
stream was 100 ppm.                .
                               *   \
     A 14 cartridge (paper) filter was used to" purrfy solvent in the systems.
It was the only such purification device used in the system.
     According to material balance and accounting for cartridge filter loss
prorated to the course of this test, the dry cleaning system at Plant B had
an emission factor of 2.1 kilograms of solvent used per 100 kilograms of
clothes cleaned (based on machine capacity).  Approximately 3.6"klT6grams(7,"9
pounds) of solvent were lost from the system per day.  Of this 3.6 kilograms,
the carbon adsorber lost 1.2 kilograms (2.6 pounds) at an average outlet
concentration of 100 ppm.  The cartridge filter accounted for an estimated
0.7 kilograms (1.5 pounds) loss per day.
     The adsorber was built in as an integral part of the unit.  It requires
about 1.4 cubic meters of space or about 1 square meter of floor space.
A.3  PLANT C
     Plant C is an industrial dry cleaning plant using perchloroethylene
solvent.  It is an American Laundry Machinery system which includes washer/
extractor, a "kissing" dryer, distillation unit, chemical separator, oil
cooker and single  bed carbon adsorber.  The adsorber collects emissions from
the washer and dryer.  The capacity of the washer is about 140 kg per load
but shirts are loaded at  about 90 kg per load because of the number of articles
per kilogram.  Pants are  loaded at capacity.
     The  "kissing" washer/dryer is a relatively new innovation in the industry.
At the conclusion  of washing, the dryer is pneumatically rolled to within 0.3
meters of the washer, both doors are opened and the clothes  are transferred
by tumbling.  This design  greatly reduces the time that  solvent laden clothes
are exposed to the atmosphere.
                                   A-4

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     EPA performed a material balance on the system and also tested the
carbon adsorber.  Results of the test are shown along with other tests
in Table A-2.  The table shows that solvent usage was a very low 2.5 kg
of solvent per 100 kg of clothes cleaned.  The entire systeim lost about
40 kilograms of solvent per day of which about 0.1 kilograms were emitted
from the adsorber.  Most of the losses were accounted for in a special
washer loading exhaust and in a distillation unit vent.  Both were vented
to atmosphere and emitted approximately 24 kilograms of solvent per day.
System changes were being initiated to vent these two sources to the adsorber.
The outlet to the carbon adsorber averaged around 3 ppm.
     Both the material balance and the adsorber test demonstrated the
efficiency of this system.  Exemplary housekeeping practices were followed at
                                                           [
the plant and attention was paid to methods of improving performance.  The
equipment was installed from 1970 (washer, distillation unit, and oil cooker)
to 1975 (kissing dryer in early 1974 and the carbon adsorber in May, 1975).
No solvent leaks were detected by sight or smell.
     The adsorber required about 20 cubic meters of space and about 6 square
meters of floor space.  It was retrofitted in 1975.
                                     A-5

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                                   A-6

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  A.4    REFERENCES
                                                           i
        1.   Kleeberg,  C.F.,  "Testing  of  Commercial  Perch!oroethylene Dry
  Cleaner,"  test report on Hershey, Pennsylvania test to James F. Durham,
  EPA, May 14, 1976.
       2.   Kleeberg, C.F., "Testing of  Industrial  Perch!oroethylene Dry
 Cleaner,"  test report on San Antonio, Texas, test to James F. Durham,
 EPA, May 14, 1976.
       3.  Kleeberg, C.F., "Testing of Commercial  Perch!oroethylene Dry
 Cleaner," test report on Kalamazoo,  Michigan, test to James F.  Durham,
 EPA,  May 17, 1976.                                         :
      4.   Scott  Environmental  Technology,  Inc., "Air  Pollution  Emission
 Test  -  Hershey Dry Cleaners  and  Laundry, Hershey,  Pennsylvania," Report
 No.76-Dry-l  to EPA, March,  1976.
      5.  Midwest  Research  Institute, "Test of Industry Dry Cleaning
 Operations  at Texas Industrial Services, San Antonio, Texas," Report
 No.76-Dry-2 for EPA, April,  1976.
      6.  Midwest Research Institute, "Air Pollution Emission Test,
Westwood Cleaners, Kalamazoo, Michigan," Report No.76-Dry-3, for EPA,
June, 1976.
                                 A-7

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                             APPENDIX B                  ;
         COMPLIANCE TEST METHODS AND LEAK DETECTION EQUIPMENT
                 FOR PERCHLOROETHYLENE DRY CLEANERS

B.I   COMPLIANCE TEST METHODS                            !
     An emission measurement can be made by several methods, all of which
were analyzed as possible compliance test methods before choosing the
equipment performance criteria discussed in Chapter 6.0.
         a)  Material balance                            i
         b)  VOC concentration limit on dryer exhausts
         c)  Total mass limit for all emission points    i
         d)  Equipment performance specification
     While the material balance was determined to be the best method of
truly measuring solvent losses, equipment performance specifications are
preferred for enforcement of a standard.  Still, the material balance test
method was used to develop background data for this document and is
therefore discussed.  The method has the following advantages:
         a)  Total system emissions can be checked.  This is not the case
for a dryer exhaust limit where only one emission point wpuld be monitored.
         b)  A material balance is more direct and simple than the test
equipment and procedures associated with a stack test.
         c)  Many existing plants keep records of clothes and solvent
throughput.  These records could be used to assist and check the material
balance.
                                    B-l

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                                                                                   •I
          d)  The material balance method, which determines emissions on a
mass per mass basis, does not distinguish between large and small plants as
a mass per day limit does.  This means that best control technology is applied
across the board to all plants.                                                       v
      The primary disadvantage of the material balance is that it is very time
                                                                                      w
consuming.  While the material balance is optimum for determining exact emissions
it is suggested that other methods, specifically equipment performance require-
ments, should be used  for enforcement.
      The following sections of this chapter detail the material  balance,
stack test, and-solvent sampling techniques.  In addition, leak  detection devices
are discussed in Section  B.2 in terms of availability and cost.
B.I.I  Material Balance Methods
      A material balance  requires measurement of clothes and solvent over a         ™**
number of loads in addition to solvent levels in the system before and after
testing.  All significant sources of solvent must be accounted for.  The
following method was developed by EPA with the assistance of an  EPA contractor
and the  International  Fabricare Institute.  The method outlined  here should
be considered flexible for the different processes in the industry.
A.    Before the test  begins, solvent in the system should be accounted .for
by the following methods:
      1.  Drain entire filter contents (powder, soil, and solvent) to muck
cooker or to holding tank (if cooker is not used).
      2.  Begin distillation/cooking or other treatment of muck.  Dry cartridge
filters,  if applicable.
                                     B-2                                            III

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       3.   Begin desorbing vapor absorber.
       4.   On completion of cooking or drying,  remove and  discard  dry
 residue.   Replace cartridge filters with new filters.     \
       5.   Dry out adsorber bed.   Put desorbed  solvent  into  cleaning  machine
 base tank.
       6.   Start up wash pump to  fill  filter  housing  (ideally, machine should
 be on continuous recirculation—solvent circulating  between base  tank and
 filter and  returning).
       7.  Add any detergent needed.   (Take solvent sample,  if needed—see
 below for description  of analysis  methods.)
       8.  Measure solvent  level  by dip stick or gauge  in  base tank.
 (Account  for  residue volume in bottom of tank.)
       9.  Put in  filter and carbon.   (Samples and total weights of this
material  can  be  taken upon  each  removal from the cooker to determine losses
associated with  the filter  system.)
B.     During  the  test:         	
       Record  weight of  all  loads.
C.     After the test period, recreate conditions of first! sol vent measurement by
repeating Steps A.I through A.7.  Another sample is taken to determine
detergent concentration in the "charged" solvent, if needed (see below).
      The solvent loss  in cartridge filters is  a fixed loss for the number
of loads recommended for use.  In other words,  if a filter vendor recommends
200 loads of solvent as the filter life, the loss from filter  change is the
same as the 200 load whether there are 50 loads or 300 loads.   The loss from
filters for a test of less than the recommended filter life should be prorated
to the life of the filter.   A loss of 1  kilogram after 50  loads  on a  filter of
                                   B-3

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200 load life should be considered in the calculation as a loss of 0.25
kilograms.
      Fixed losses are a significant factor in small  machines.   A 5 kilogram
load in a 12 kilogram capacity machine will have nearly the same loss as a
12 kilogram load in the same machine.  In calculating kilograms of clothes
throughput in machines, the vendor capacity times the number of loads should           *
be used instead of the actual load.  The IFI and other organizations can
relate cubic feet of washer volume to capacity by available factors too
extensive to list here.
      To determine solvent consumption, the solvent level  (minus detergent,
sizing, etc.) of the initial measurement (Step A.8) is compared to the
solvent level (minus detergent, sizing, etc.) of the final measurement
(Step C.2).  All solvent  added during the  test period should be accounted            {|]|}
for.
      To  determine  the system  emission  factor for  the test period  (which
 should.be for at least one work week),  the solvent consumption is  divided
 by'the clothes  TihrougnoUT-the  system.   Stnce  the test site need orrfy ber	
 prepared by an  enforcement official and not attended,  total  manhours
 required per test is_less than _10.           	          	
      The following discusses sample analyses for solvent taken from the                ^
 system.  A 0.5 liter sample is sufficient for analysis.
                                    B-4

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      According to the  IFI, samples should  be analyzed for detergent
concentration, moisture, non-volatiles, dry sizing, and  insoluble materials.
A Hyamine 1622 or Aerosol OT Titration should be used for detergent concen-
tration reported on a volume/volume percent basis.  The moisture content
is determined by a Karl-Fischer titration procedure and reported as grains
of water/100 millilitres of solution.  Non-volatile residue is determined
gravimetrically by a steam bath evaporation of a measured volume of solvent
and weighing the residue.  Dry sizing content is determined by extracting
the non-volatile residue with boiling ethyl alcohol.  Insoluble material
content is to be determined gravimetrically after filtration of a volume of
solvent through a 0.20 micrometer membrane.
      For determining the amount of solvent in filter materials (muck and
distillation waste) the test method described by the American National
Standards Institute in the paper "Standard  Method of Test for Dilution of
Gasoline-Engine Crankcase Oils," should be  used.  To be derived are the
kilograms of VOC per kilogram of discarded  filter muck.  This method can
be used for the enforcement of the performance requirements of RACT.
      EPA found that results were consistently 8-10 percent different when
these accounts for material other than solvent were not made.  It is felt
that after determining total system solvent volume consumed during the course
of the test 9 percent can be subtracted out as other materials.  The
remaining 91 percent can be considered pure solvent emitted to the atmosphere.
The test methods are described here for reference only.
                                     B-5

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B.I.2  Emission Measurement Method for Perch!oroethylene From Adsorber Vent         W
      The primary method used to gather emission data has been the integrated
bag sampling procedure followed by gas chromatographic/flame ionization
detector analysis.  Appendix B, Draft EPA Method 23: '"Determination of Total
Halogenated Organics from Stationary Sources," describes this approach.
For this method, the integrated bag sampling technique was_chosen
over charcoal adsorption tubes for Two "reasons:""Tf)~Tess~uhcertafnty""
about sample recovery efficiency, and (2) only one sample portion to analyze per
sample run.  A column identified by a major manufacturer of chromatographic
equipment as useful for the separation of chlorinated solvents is employed.
      The method was written after an initial EPA funded study of halogenated
hydrocarbon testing revealed areas where improvements in the bag sampling
technique were needed.  In particular, leaking bags  and bag containers were
cited as a probable cause of poor correlation between integrated and grab
samples taken at an emission site by  that contractor.   In light of  these
findings, more rigorous leak check procedures were  incorporated.  The  first
test conducted by  EPA with the improved method to gather emission data
utilized both  integrated bag and grab sampling techniques as a form of
quality control.   For the three days  during  which tests were made,  very good
correlation  between the two techniques was obtained.  Subsequent to these
                                                                                        R-
tests, a final draft of this method was  prepared that incorporates  further
leak checks  as an  additional precaution  against  erroneous data.  These                 *
additions  were suggested by an EPA contractor that  was  studying  the vinyl
chloride test method.  This contractor coincidentally performed  the second
and third  dry cleaning  emission data  tests,  and  was previously aware  of the
 need for  exercising  particular caution with  respect to  leak detection.              ||||
                                  B-6

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     The costs for conducting a Method 23 emission test in triplicate will
depend on the length of the cleaning cycle and are accordingly estimated at
$5000 to $10,000 per unit.  A simplified version of this test may run as
low as $200.  The testing costs per unit would be lower if several units
at a single site were serially tested.  The high cost of this test
precludes its use on a day-to-day enforcement of RACT.  It is expected
that compliance with the 100 ppm RACT definition will be demonstrated
with inexpensive portable analyzers.
B.2  Leak Detection Methods
      There are several types of portable, self-contained instruments currently
available for leak monitoring in dry cleaning facilities.!  The principles of
operation are catalytic-oxidation., flame ionization, and infrared energy
absorption.  All three types of detection will respond to practically all types
of organic materials although the relative responses to the different types
will vary.
      For halogenated solvent operations where a single compound is predominant,
the instruments can be calibrated with that compound and the results will be on
that basis.  Examples of some manufacturer's reported ranges for perchloroethylene
are:  (1) catalytic-oxidation, 27-13,000 ppmv; (2) flame ionization, 2-20,000 ppmv;
and (3) infrared, 0.5-200 ppm +, depending on configuration.
     The cost of a monitoring instrument ranges from about $900 to $4000,
depending on the detection principle, operating features, and required
accessories associated with the different instrument types and vendors.
          EPA has contracted to examine several of these alternatives,
          including less expensive systems than discussed above, the
          object of the study being to develop an easy to use,
          inexpensive monitor for vapor leak detection.
                                 B-7

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B.3  SUMMARY
     This chapter has detailed the methods used to develop background
information for this study.  For the most part these methods are too
expensive and cumbersome to be used as effective enforcement tools.
It is suggested that portable detectors, to be analyzed and developed
by EPA in the near future, be used to determine the extent of vapor
leaks in a system and also be used to determine compliance with dryer
control requirements.  Solvent in filter and distillation system wastes
can be determined'by methods discussed  in this chapter.
                                       B-8

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                                    TECHNICAL REPORT DATA
                             (Please read Instructions on the reverse before completing)
 1. REPORT NO.
       EPA-450/2-78-050
2.
                               3. RECIPIENT'S ACCESSION NO.
4. TITLE AND SUBTITLE
      Control of Volatile Organic Emissions From
      Perchloroethylene  Dry Cleaning  Systems
                               5. REPORT DATE
                                 December, 1978
                               6. PE-RFORMING ORGANIZATION CODE
7. AUTHOR(S)
      Charles F. Kleeberg,  ESED
      Jack G. Wright, SASD
                               8. PE-RFORMING ORGANIZATION REPORT NO
9. PERFORMING ORGANIZATION NAME AND ADDRESS
      U.S.  Environmental  Protection Agency
      Office of Air Quality Planning and Standards
      Emission Standards  and Engineering Division
      Research Triangle Park, N.C. 27711
                                OAQPS No. 1.2-117
                               1O. F'ROGRAM ELEMENT NO.
                               11. CONTRACT/GRANT NO.
12. SPONSORING AGENCY NAME AND ADDRESS
                                                              13. TYPE OF REPORT AND PERIOD COVERED
                                                              14. SPONSORING AGENCY CODE
15. SUPPLEMENTARY NOTES
16. ABSTRACT
            This report provides the necessary guidance  for development of regulations
      limiting  emissions of  Volatile Organic Compounds (VOC) from perchloroethylene
      dry cleaning systems.   Reasonably Available Control  Technology  (RACT) is
      defined and a costjanalysis of RACT  is included in order that cost effectiveness
      may be evaluated fjbr these systems.
 7.
                                 KEY WORDS AND DOCUMENT ANALYSIS
                  DESCRIPTORS
      Air Pollution
      Regulatory  Guidance
      Dry Cleaning
 8. DISTRIBUTION STATEMENT
      Unlimited
                                               b. IDENTIFIERS/OPEN ENDED TERMS
                  Air Pollution Control
                  Stationary  Sources
                  Organic Vapors
                                               19. SECURITY CLASS (ThisReport)'
                                                 Unclassified
EPA Form 2220-1 (Rev. 4-77)   PREVIOUS EDITION is OBSOLETE
                 20. SECURITY CLASS (Thispage)

                   Unclassified	
                                                                           c.  COSATI Field/Group
                                             21. NO. OF PAGES

                                                  68
                                                                           22. PRICE

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