EPA-450/3-79-029a
Perchloroethylene Dry Cleaners
     Background Information
      for Proposed Standards
        • Emission Standards and Engineering 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

                 August 1980

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This report has been reviewed by the Emission Standards and Engineering Division of the Office of
Ai  QuaS Planning and Standards, EPA, and approved for publication. Ment.on o trade names or
commercial products is not intended to constitute endorsement or recommendation for use^Copies of
thi?report a?e available through the Library Services Office (MD-35), US Environmental Rejection
Agency, Research Triangle Park, N.C. 27711, or from National Techmcal Information Serv.ces, 5285
Port Royal Road, Springfield, Virginia 22161.
                            Publication No. EPA-450/3-79-029a

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                         Background  Information
                                and  Draft
                     Environmental Impact Statement
                   for Perch!oroethylene Dry Cleaners

                     Type of Action:  Administrative

                             Prepared by:
Don R. Goodwin /
            n'ssio
Director,  Emission Standards and Engineering Division
Environmental  Protection Agency
Research Triangle Park, N. C.  27711
                                                              (Date)
                            Approved by:
4,
  y
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                              TABLE OF CONTENTS
                                                                       Page
 LIST  OF FIGURES  .  .  .	v1i
 LIST  OF TABLES.  .  .  .	            vi1i
 CHAPTER 1.   SUMMARY	-,_-|
           1.1  Regulatory  Alternatives   	1-1
           1.2  Environmental  Impact	   1-2
           1.3  Economic  Impact.  .	1_2
 CHAPTER 2.   INTRODUCTION	   2-1
           2.1  Background  and Authority  for Standards  	   2-1
           2.2  Selection of Categories of Stationary
               Sources	           2-5
           2.3  Procedure for Development of Standards  of
               Performance	     2-6
           2.4  Consideration of Costs	     2-8
           2.5  Consideration of Environmental Impacts  	   2-9
           2.6  Impact on Existing Sources 	   2-10
           2.7  Revision  of Standards of Performance 	   2-11
CHAPTER 3.  THE PERCHLOROETHYLENE DRY CLEANING INDUSTRY.. 	   3-1
          3.1  General Industry Description 	     3-1
          3.2  Dry Cleaning Processes	3-2
          3.3  Baseline  Emissions .	   3-7
               References for Chapter 3	3-14
CHAPTER 4.  EMISSION CONTROL TECHNIQUES 	   	 .    4-]
          4.1  Use of Control  Techniques	4-1
          4.2  Types of Control  Techniques	4-1
               References for Chapter 4	  4-12
CHAPTER 5.  MODIFICATION AND RECONSTRUCTION .  	  5-1
          5.1  40 CFR Part 60  Provisions for Modification
               and Reconstruction	5-2
          5.2  Applicability to  Perchloroethylene Dry
               Cleaning Facilities	,	5-3

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                       TABLE OF CONTENTS (continued)
                                                                      Page
CHAPTER 6.  MODEL PLANTS AND REGULATORY ALTERNATIVES	6-1
          6.1  Model Plants	6-1
          6.2  Regulatory Alternatives	6-3
          6.3  Rationale for Ranking of Regulatory Alternatives .  .  .   6-7
               References for Chapter 6	,.	6-10
CHAPTER 7.  ENVIRONMENTAL IMPACT	   7-1
          7.1  Air Pollution Impact .................   7-1
          7.2  Water Pollution Impacts.	   7-6
          7.3  Solid Waste Impact	   7-TO
          7.4  Energy Impact	7-11
               References for Chapter 7	7-13
CHAPTER 8.  ECONOMIC IMPACT	...........   8-1
          8.1  Industry Characterization	,	8-1
          8.2  Cost Analysis of Control Options	8-23
          8.3  Other Cost Considerations.	   8-42
          8.4  Economic Impact	   8-44
          8.5  Socioeconomic Effects		   8-58
               References for Chapter 8 ......... 	   8-62
APPENDIX A  EVOLUTION OF PROPOSED STANDARDS ...  	   A-l
APPENDIX B  INDEX TO ENVIRONMENTAL IMPACT CONSIDERATIONS  .  	   B-l
APPENDIX C  EMISSION SOURCE TEST DATA	...........   C-l
APPENDIX D  EMISSION MEASUREMENT AND CONTINUOUS MONITORING.  .....   D-l
                                      vi

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                              LIST OF FIGURES
Figure
3-1

5-1

8-1

8-2

8-3
Perchloroethylene Dry Cleaning Plant Flow
  Diagram .... 	
Plant Configurations Encountered in the
  Dry Cleaning Industry	
Trends in Number of Establishments and
  Employees for SIC 7215.  	
Trends in Number of Establishments and
  Employees for SIC 7216	
Trends in Number of Establishments and
  Employees for SIC 7218	
                                                          Page
3-4
5-4
8-10
8-12
                                                                       8-14
                                    vn

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                              LIST OF TABLES
3-1

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

6-1

6-2
6-3

7-1

7-2

7-3

7-4

7-5

7-6

7-7
8-1

8-2

8-3

8-4
                                                            Page
Assessment of Environmental and Economic Impacts for
  Each Regulatory Alernative Considered. .  .	   1-3
Perchloroethylene Emissions from Professional Dry
  Cleaning Plants	   3-8
Baseline Perchloroethylene Emission Levels	   3-10
Summary of Perchloroethylene Dry Cleaning Test Data  .  .  .   4-4
Summary of Carbon Adsorber Test Data	   4-5
Filter and Distillation Wastes from Well-Operated
  Facilities	   4-11
Model Plant Parameters for the Perc Dry Cleaning
  Industry	   6-2
Control Options	   6-4
Perchloroethylene Emission Rate after Applying the Air
  Pollution Control Options to Model Plants	   6-8
Projected Emission Reduction from Applying the Control
  Options to Coin-Ops	   7-3
Projected Emission Reduction from Applying the Control
  Options to Commercial Dry Cleaning Plants	   7-4
Projected Emission Reduction from Applying the Control
  Options to Industrial Dry Cleaning Plants	   7-5
Increases in F-113 Emissions for Option 1 from the Coin-Op
  Segment	   7-7
Increases in F-113 Emissions for Option 1 from the
  Commercial Segment 	  	   7-8
Perchloroethylene Dry Cleaning Solvent  in Effluent Water
  as a Result of Carbon Adsorption	   7-9
Energy Impact of Control Options on Model Plants 	   7-12
Statistical Profile of Coin-Op Dry  Cleaners and
  Laundries (SIC 7215), 1972	8-3
Statistical Profile of Dry Cleaning Plants, Except Rug
  Cleaning (SIC 7216), 1972	   8-5
Statistical Profile of Industrial Launderers (SIC 7218),
  1972	   8-7
Trends in Number of Establishments  and  Employees in the
  Dry Cleaning Industry	   8-9

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                         LIST OF TABLES (continued)
 TABLE
 8-5
 8-6

 8-7

 8-8

 8-9

 8-10

 8-11

 8-12

 8-13
 8-14

 8-15
 8-16

 8-17
 8-18

 8-19

 8-20

8-21
8-22
8-23
8-24

8-25
 8-26
                                                             PAGE
 Consumer  Price  Index  .	    8-13
 Coin-Operated Dry  Cleaners  and  Laundries,  SIC  7215,
   Regional Trends  for Number  of Establishments 	    8-16
 Dry  Cleaning Plants Except  Rug  Cleaning  SIC  7216,  Regional
   Trends  for Number of Establishments.	    8-17
 Industrial Launderers,  SIC  7218,  Regional  Trends for
   Number  of Establishments  	    8-18
 Ratio of  Market Value of  Perchloroethylene Production
   to Total Sales in 1977  for  Perc-Producing  Companies.  .  .    8-19
 Estimated New Sources in  the  Unregulated Perchloroethylene
   Coin-Op Dry Cleaning Industry	    8-20
 Estimated New Sources in  the  Unregulated Commercial
   Perchl oroethylene Dry Cleaning  Industry	    8-21
 Estimated New Sources in  the  Unregulated Perchloroethylene
   Industrial Dry Cleaning Industry	    8-22
 Cost of Control Technology, Coin  Operated, Option  1  ...    8-25
 Cost of Control Technology, Evaluation of  Applying Carbon
  Adsorption to Coin-Ops  	    8-27
 Approximate Capital Costs of  Dry  Cleaning  Machines ....    8-30
 Cost of Control, Commercial Dry Cleaners,  Option 1 and
  Option  2	    8-31
 Cost of Control Technology, Industrial 	    8-33
 Control  Costs for Modifying Commercial Perc Dry
  Cleaners		    8-35
 Control  Costs for Modifying Industrial Perc Dry
  Cleaners	   8-36
 Cost (Profit) Effectiveness of Controls for the
  Perchloroethylene Dry Cleaning  Industry.  ... 	   8-39
Aggregate Costs of Controls on Dry Cleaning Industry ...   8-40
Model Plant Financial  Profile   	   8-48
Summary of Control  Costs	,  .	 .   8-51
Effects  of Control  Options on Profit and  Return on
  Investment for Model Plants.  .	 .....   8-53
 Effects  of Control  Options on Number of New Plants ....   8-57
Maximum Price Increases Resulting from Alternative
  Control  Options on Dry Cleaning Model Plants 	   8-60

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                                1.  SUMMARY

     Standards of performance for new stationary sources are established
under section 111 of the Clean Air Act  (42 U.S.C. 7411), as amended  in
1977.  Section 111 directs the Administrator to establish standards  of
performance for any category of new stationary source of air pollution
which ". . . causes or contributes significantly to, air pollution which
may reasonably be anticipated to endanger public health or welfare."
     This Background Information Document (BID) supports proposed standards
for tetrachloroethylene, more commonly  known as perch!oroethylene (perc)
dry cleaners.  Perc dry cleaners can generally be divided into three
categories:  coin-operated, commercial, and industrial.  Coin-operated
dry cleaners are usually part of a coin-operated laundry.  The equipment
is operated by the customer, with the cost of the cleaning usually being
deposited directly into the dry cleaning machine.  Commercial dry cleaners
are the local stores processing men's suits, women's dresses and similar
apparel.  Industrial dry cleaners usually clean such articles as uniforms,
work gloves, or dust mops.   Some commercial facilities may process
uniforms or other industrial type work, hence, there may not be an absolute
distinction between commercial and industrial  facilities.  These three
categories were used to develop the regulatory alternatives and the cost
of control for each industry category.
1.1  REGULATORY ALTERNATIVES
     There are two regulatory alternatives, each of which vary according
to industry category.   Alternative I for the coin-operated and commercial
categories calls for the use of a solvent such as trichlorotrifluoroethane
(F-113*),  which will not contribute significantly to oxidant formation.
In the industrial  category, alternative I calls for the use of carbon
 Registered trademark.
                                  1-1

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adsorption to control perc emissions from dryers, the elimination of
perceptible solvent leaks by proper maintenance, and the treatment of
waste solvent to lower the perc content in the waste.  Alternative II for
the coin-operated category requires that the facility be well maintained,
well operated, and all perceptible solvent leaks be repaired with waste
solvent minimized by proper treatment.  For the commercial and industrial
categories, alternative II is the same as for the coin-operated category
with the addition of carbon adsorption to control emissions from dryers
or dry-to-dry machines.
1.2  ENVIRONMENTAL IMPACT
     Regulatory alternative I would reduce nationwide emissions of perc
from 55,000 Mg/yr to 47,000 Mg/yr (8,000 Mg/yr) by 1984.  This decrease
in perc emissions would be accompanied by an increase of 3,100 megagrams
in total F-113 emissions.  As shown in Table 1-1 the environmental impacts
of alternative I on water pollution,  solid waste, and energy would be
minimal.
     Regulatory alternative II would  reduce nationwide  perc  emissions
from-55,000 Mg/yr to  51,000 Mg/yr  (4,000 Mg/yr)  by 1984.  The reduction
in  nationwide perc emissions would  result in minimal adverse environmental
impacts.   There would be  negligible increases  in solid  waste and  perc  in
wastewater.   Compliance with the proposed standard would  also cause  a
slight increase  in energy consumption due to the use of carbon adsorbers.
1.3 ECONOMIC IMPACT
     Regulatory  alternative  I would result  in  an increase of approximately
23  million dollars in industrywide capital  investment  costs  by 1984.   In
1984,  the  total  annualized  costs  resulting  from alternative  I would be
approximately 7.2  million dollars.  The industrial  sector,  however,  may
actually experience  a beneficial  economic impact under alternative I due
to  the recovery of solvents.
      For regulatory  alternative II, total  capital  investment costs of
 controls by 1984 would be about 7.2 million dollars.  The 1984 total
 annualized costs resulting  from controls would be-less than 0.8  million
 dollars.
                                   1-2

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     There is not expected to be any consumer price increase incurred by
any regulatory action on new sources.  This is due to the competitiveness
of the market, and to the fact that a new source locating in an area
could not charge higher prices and still attract customers.   Regulatory
action which would result in a need for significantly increased costs to
the consumer to make the facility profitable would result in the
pre-emption of construction of the facility.
                                   1-4

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                             2.   INTRODUCTION

2.1  BACKGROUND AND AUTHORITY FOR STANDARDS
     Before standards of performance are proposed as a Federal regulation,
air pollution control methods available to the affected industry and the
associated costs of installing and maintaining the control equipment are
examined in detail.  Various levels of control based on different techno-
logies and degrees of efficiency are expressed as regulatory alternatives.
Each of these alternatives is studied by EPA as a prospective basis for a
standard.  The alternatives are investigated in terms of their impacts on
the economics and well-being of the industry, the impacts on the national
economy, and the impacts on the environment.  This document summarizes the
information obtained through these studies so that interested persons will
be able to see to the information considered by EPA in the development of
the proposed standard.
     Standards of performance for new stationary sources are established
under section 111 of the Clean Air Act (42 U.S.C. 7411) as amended, herein-
after referred to as the Act.  Section 111 directs the Administrator to
establish standards of performance for any category of new stationary
source of air pollution which ".  . .  causes, or contributes significantly
to air pollution which may reasonably be anticipated to endanger public
health or welfare."
     The Act requires that standards of performance for stationary sources
reflect, ".  .  .  the degree of emission reduction achievable which (taking
into consideration the cost of achieving such emission reduction, and any
nonair quality health and environmental impact and energy requirements) the
Administrator determines has been adequately demonstrated for that category
of sources."  The standards apply only to stationary sources,  the construc-
tion or modification of which commences after regulations are  proposed by
publication in the Federal  Register.
                                  2-1

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     The 1977 amendments to the Act altered or added numerous provisions
that apply to the process of establishing standards of performance.
     1.  EPA is required to list the categories of major stationary sources
that have not already been listed and regulated under standards of perfor-
mance.   Regulations must be promulgated for these new categories on the
following schedule:
     a.   25 percent of the listed categories by August 7, 1980.
     b.   75 percent of the listed categories by August 7, 1981.
     c.   100 percent of the listed categories by August 7, 1982.
A governor of a State may apply to the Administrator to add a category not
on the list or may apply to the Administrator to have a standard of perfor-
mance revised.
     2.  EPA is required to review the standards of performance every
4 years and, if appropriate, revise them.
     3.  EPA is authorized to promulgate a standard based on design,
equipment, work practice, or operational procedures when a standard based
on emission levels is not feasible.
     4.  The term  "standards of performance"  is  redefined, and  a new term
"technological system of continuous emission  reduction" is defined. The new
definitions clarify  that the control  system must be continuous  and may
include a  low- or  non-polluting process  or operation.
     5.  The time  between the proposal and promulgation of a  standard under
Section 111 of the Act  may be extended to 6 months.
     Standards of  performance, by themselves,  do not  guarantee  protection
of  health  or welfare because they are not designed to achieve  any  specific
air quality levels.  Rather, they are designed to  reflect the  degree of
emission  limitation  achievable through application of the best adequately
demonstrated  technological  system of  continuous emission  reduction, taking
into consideration the  cost  of  achieving such emission reduction,  any
non-air-quality  health  and environmental impacts,  and energy requirements.
     Congress  had  several  reasons for including these requirements.  First,
standards with a degree of uniformity are  needed to avoid situations where
some States may attract industries by relaxing standards  relative to other
States.   Second,  stringent standards  enhance the potential  for long-term
                                   2-2

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growth.  Third,  stringent  standards may  help achieve  long-term cost savings
by avoiding the  need for more expensive  retrofitting  when pollution ceilings
may be reduced in the future. Fourth, certain types of standards for coal-
burning sources  can adversely affect the coal market  by driving up the
price of low-sulfur coal or effectively  excluding certain coals from the
reserve base because their untreated pollution potentials are high.  Con-
gress does not intend that new source performance standards contribute to
these problems.  Fifth, the standard-setting process  should create incen-
tives for improved technology.
     Promulgation of standards of performance does not prevent State or
local agencies from adopting more stringent emission  limitations for the
same sources.  States are free under section 116 of the Act to establish
even more stringent emission limits than those established under section 111
or those necessary to attain or maintain the National Ambient Air Quality
Standards (NAAQS) under section 110.  Thus, new sources may in some cases
be subject to limitations more stringent than standards of performance
under section 111, and prospective owners and operators of new sources
should be aware of this possibility in planning for such facilities.
     A similar situation may arise when a major emitting facility is to be
constructed in a geographic area that falls under the prevention of signi-
ficant deterioration of air quality provisions of Part C of the Act.   These
provisions require,  among other things,  that major emitting facilities to
be constructed in such areas are to be subject to best available control
technology.   The term Best Available Control Technology (BACT),  as  defined
in the Act,  means
          ...  an emission limitation based on the maximum degree  of
          reduction  of each pollutant subject to regulation under this Act
          emitted from,  or which results from,  any major emitting facility,
          which the  permitting authority, on a case-by-case basis,  taking
          into account energy,  environmental,  and economic impacts  and
          other costs,  determines is achievable for such facility through
          application of production processes  and available methods,  systems,
          and techniques,  including fuel  cleaning or treatment or innovative0
          fuel  combustion techniques for control  of each such  pollutant.
                                  2-3

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          In no event shall application of 'best available control  techno-
          logy1 result in emissions of any pollutants which will  exceed the
          emissions allowed by any applicable standard established pursuant
          to sections 111 or 112 of this Act.  (Section 169(3))
     Although standards of performance are normally structured in terms of
numerical emission limits where feasible, alternative approaches are some-
times necessary.  In some cases physical measurement of emissions from a
new source may be impractical or exorbitantly expensive.  Section lll(h)
provides that the Administrator may promulgate a design or equipment stan-
dard in those cases where it is not feasible to prescribe or enforce a
standard of performance.  For example, emissions of hydrocarbons from
storage vessels for petroleum liquids are greatest during tank filling.
The nature of the emissions, high concentrations for short periods during
filling and low concentrations for longer periods during storage, and the
configuration,of storage tanks make direct emission measurement impractical.
Therefore, a more practical approach to  standards of performance for storage
vessels has been equipment specification.
     In addition, section lll(i) authorizes  the Administrator to grant
waivers of compliance to permit a source to  use innovative continuous
emission control technology.  In order to grant the waiver, the
Administrator must find:   (1) a substantial  likelihood  that the technology
will produce greater emission reductions than the standards require or an
equivalent reduction at  lower economic energy or environmental cost; (2) the
proposed system has not  been adequately  demonstrated;  (3) the  technology
will not cause  or contribute to an unreasonable risk to the public health,
welfare, or safety; (4)  the  governor  of  the  State where the source is
located  consents; and  (5)  the waiver  will  not prevent  the attainment or
maintenance of any ambient standard.   A  waiver  may  have conditions attached
to assure the  source will  not prevent attainment of any NAAQS.  Any such
condition will  have the force of  a performance  standard.   Finally, waivers
have definite  end dates and may be terminated earlier  if  the conditions are
not met or  if  the system fails  to perform as expected.  In  such a case, the
source may  be given  up to 3 years to  meet the standards with a mandatory
progress schedule.
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 2.2  SELECTION OF CATEGORIES OF STATIONARY SOURCES
      Section 111  of the Act directs the Adminstrator to list categories of
 stationary sources/  The Administrator ".  .  .  shall  include a category  of
 sources in such list if in his  judgement it causes,  or contributes  signifi-
 cantly to, air pollution which  may reasonably  be  anticipated to  endanger
 public,health or  welfare."  Proposal  and promulgation of standards  of
 performance are to follow.
      Since passage of the Clean A-ir Amendments  of 1970,  considerable
 attention  has been given to the-development of  a  system for assigning
 priorities to various source categories.   The approach specifies areas  of
 interest by considering the broad  strategy of the Agency for implementing
 the Clean  Air Act.   Often,  these "areas"  are actually pollutants emitted by
 stationary sources.   Source categories  that  emit  these pollutants are
 evaluated  and ranked by a process  involving  such  factors  as:  (1)  the
 level  of emission  control  (if any)  already required by State  regulations,
 (2) estimated levels  of control  that might be required  from  standards of
 performance  for the  source  category, (3) projections  of  growth and  replace-
 ment  of existing facilities  for  the source category,  and  (4) the estimated
 incremental  amount of air pollution that could be prevented  in a preselected
 future year  by standards  of  performance for the source category.   Sources
 for which  new source  performance standards were promulgated or under
 development  during 1977, or  earlier, were  selected on  these criteria.
     The Act  amendments of August 1977 establish specific criteria to be
 used  in determining priorities for all major source categories not yet
 listed by  EPA.  These are:   (1) the quantity of air pollutant emissions
 that each  such category will emit,  or will be designed to emit; (2) the
extent to which each  such pollutant may reasonably be anticipated to
endanger public health or welfare;  and (3) the mobility and competitive
nature of each such category of sources and the consequent need for
nationally applicable new source standards of performance.
     The Administrator is to promulgate standards  for these categories
according tg the schedule referred  to earlier.
                                        .                         ฉ          .
     In some cases it may not be feasible immediately to develop  a  standard
for a source category with a high priority.  This  might happen when  a
                                  2-5

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program of research is needed to develop control techniques or because
techniques for sampling and measuring emissions may require refinement.   In
the developing of standards, differences in the time required to complete
the necessary investigation for different source categories must also be
considered.  For example, substantially more time may be necessary if
numerous pollutants must be investigated from a single source category.
Further, even late in the development process the schedule for completion
of a standard may change.  For example, inablility to obtain emission data
from well-controlled sources in time to pursue the development process in a
systematic fashion may force a change in scheduling.  Nevertheless, priority
ranking is, and will continue to be, used to establish the order in which
projects are initiated and resources assigned.
     After the source category has been chosen, the types of facilities
within the source category to which the standard will apply must be deter-
mined.  A  source category may have several facilities that cause air pollu-
tion, and  emissions from some of these facilities may vary from insignificant
to very expensive to control.  Economic studies of the source category and
of applicable control technology may show that  air pollution control  is
better  served by-applying  standards to the more severe pollution sources.
For this  reason, and because there  is  no adequately demonstrated system  for
controlling  emissions from certain  facilities,  standards  often  do  not apply
to all  facilities at a  source. For  the same  reasons,  the  standards may  not
apply to  all air pollutants emitted.   Thus,  although  a  source category  may
be selected  to  be covered  by a standard  of performance, not  all pollutants
or facilities within that  source  category may be  covered  by  the standards.
2.3   PROCEDURE  FOR  DEVELOPMENT OF STANDARDS  OF PERFORMANCE
      Standards  of performance must (1) realistically  reflect best
demonstrated control practice;  (2)  adequately consider  the cost,  the non-air-
quality health  and  environmental  impacts,  and the energy  requirements of
such  control;  (3)  be applicable  to existing sources that  are modified or
reconstructed as well  as new installations;  and (4) meet  these  conditions
for all variations  of operating conditions being considered anywhere in the
country.
                                   2-6

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      The  objective  of  a program  for  developing  standards  is  to  identify  the
 best  technological  system  of  continuous emission  reduction that has  been
 adequately  demonstrated.   The standard-setting  process  involves three
 principal phases of activity:  (1) information  gathering, (2) analysis of
 the information, and (3) development of the standard  of performance.
      During the information-gathering phase,  industries are  queried  through
 a telephone survey, letters of inquiry, and plant visits  by  EPA representa-
 tives.  Information is also gathered from many  other  sources, and a  litera-
 ture  search is conducted.  From  the  knowledge acquired  about the industry,
 EPA selects certain plants at which  emission tests are  conducted to  provide
 reliable  data that  characterize  the  pollutant emissions from well-controlled
 existing  facilities.
      In the second  phase of a project, the information  about the industry
 and the pollutants  emitted is  used in analytical  studies.  Hypothetical
 "model plants" are  defined to  provide a common  basis  for  analysis.   The
 model plant definitions, national pollutant emission  data, and  existing
 State regulations governing emissions from the  source category  are then
 used  in establishing "regulatory alternatives."   These  regulatory alterna-
 tives are essentially different  levels of emission control.
      EPA  conducts studies to  determine the impact of  each regulatory
 alternative on the  economics  of the  industry and  on the national economy,
 on the environment, and on energy consumption.  From  several  possibly
 applicable  alternatives, EPA  selects the single most plausible  regulatory
 alternative as the basis for a standard of performance  for the  source
 category under study.
     In the third phase of a project, the selected regulatory alternative
 is translated into a standard of performance,  which,  in turn, is written in
 the form of a Federal  regulation.  The Federal regulation, when applied to
 newly constructed plants,  will limit emissions to the levels  indicated in
 the selected regulatory alternative.
     As early as is practical  in each standard-setting project,  EPA
 representatives discuss the possibilities of a standard and the form it
might take with members of the National  Air Pollution Control Techniques
 Advisory Committee.   Industry representatives  and other interested parties
 also participate in these meetings.
                                  2-7

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     The information acquired in the project is  summarized in  the  Background
Information Document (BID).   The BID, the standard,  and a preamble explain-
ing the standard are widely circulated to the industry being considered for
control, environmental groups, other government agencies, and offices
within EPA.  Through this extensive review process, the points of view of
expert reviewers are taken into consideration as changes are made to the
documentation.
     A "proposal package" is assembled and  sent through the offices of EPA
Assistant Administrators for concurrence before the proposed  standard is
officially endorsed by the EPA Administrator.  After being approved by the
EPA  Administrator, the preamble and the proposed regulation are published
in the  Federal  Register.
     As  a  part  of the Federal Register announcement of the proposed
regulation,  the public  is  invited to participate in the standard-setting
process.   EPA invites written comments on  the proposal and  also  holds  a
public hearing to  discuss  the proposed standard with  interested  parties.
All  public comments are summarized and incorporated into a  second volume  of
the BID.   All information  reviewed and generated  in studies  in support of
the standard of performance is  available to the public in a "docket"  on
 file in Washington, D.  C.
      Comments from the public are evaluated, and  the standard of performance
 may be altered in response to the comments.
      The significant comments and EPA's  position  on the issues raised are
 included in the "preamble" of a promulgation package," which also contains
 the draft of the final regulation.  The regulation is then subjected to
 another round of review and refinement until it is approved by the EPA
 Administrator.  After the Administrator signs the regulation, it is published
 as  a "final  rule" in the Federal  Register.
 2.4 CONSIDERATION OF COSTS
      Section 317 of  the Act  requires an economic impact  assessment with
 respect to  any  standard of performance established under Section 111 of the
 Act.   The assessment is required .to contain an analysis  of:  (1)  the costs
 of  compliance  with the regulation,  including the extent  to which the cost
 of  compliance  varies depending on the effective date  of  the  regulation and
 the development of less expensive or more efficient methods  of  compliance;

                                    2-8

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(2) the potential inflationary or recessionary effects of the regulation;
(3) the effects the regulation might have on small business with respect to
competition; (4) the effects of the regulation on consumer costs; and
(5) the effects of the regulation on energy use.  Section 317 also requires
that the economic impact assessment be as extensive as practicable.
     The economic impact of a proposed standard upon an industry is usually
addressed both in absolute terms and in terms of the control costs that
would be incurred as a result of compliance with typical, existing State
control regulations.  An incremental approach is necessary because both new
and existing plants would be required to comply with State regulations in
the absence of a Federal standard of performance.   This approach requires a
detailed analysis of the economic impact from the cost differential that
would exist between a proposed standard of performance and the typical
State standard.
     Air pollutant emissions may cause water pollution problems, and
captured potential air pollutants may pose a solid waste disposal problem.
The total environmental impact of an emission source must, therefore, be
analyzed and the costs determined whenever possible.
     A thorough study of the profitability and price-setting mechanisms of
the industry is essential to the analysis so that an accurate estimate of
potential adverse economic impacts can be made for proposed standards.  It
is also essential to know the capital  requirements for pollution control
systems already placed on plants so that the additional capital  requirements
necessitated by these Federal standards can be placed in proper perspective.
Finally, it is necessary to assess the availability of capital  to provide
the additional control  equipment needed to meet the standards of performance.
2.5  CONSIDERATION OF ENVIRONMENTAL IMPACTS
     Section 102(2)(C)  of the National  Environmental  Policy Act (NEPA) of
1969 requires Federal  agencies to prepare detailed environmental impact
statements on proposals for legislation and other  major Federal  actions
significantly affecting the quality of the human environment.   The objec-
tive of NEPA is to build into the decisionmaking process of Federal  agencies
a careful consideration of all environmental  aspects  of proposed actions.
                                  2-9

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     In a number of legal challenges to standards of performance for various
industries, the United States Court of Appeals for the District of Columbia
Circuit has held that environmental impact statements need not be prepared
by the Agency for proposed actions under section 111 of the Clean Air Act.
Essentially, the Court of Appeals has determined that the best system of
emission reduction requires the Administrator to take into account counter-
productive environmental effects of a proposed standard, as well as economic
costs to the industry.  On this basis, therefore, the Court established a
narrow exemption from NEPA for EPA determination under section 111.
     In addition to these judicial determinations, the Energy Supply and
Environmental Coordination Act (ESECA) of 1974 (PL-93-319) specifically
exempted proposed actions under the Clean Air Act from NEPA requirements.
According to section 7(c)(l), "No  action taken under the Clean Air Act
shall be deemed a major  Federal action significantly affecting the quality
of the human environment within the meaning of the National Environmental
Policy Act  of 1969."  (15 U.S.C. 793(c)(l))
     Nevertheless, the Agency has  concluded that the preparation of
environmental impact  statements could  have beneficial  effects  on certain
regulatory  actions.   Consequently, although not  legally  required to  do  so
by section  102(2)(C)  of  NEPA, EPA  has  adopted a  policy requiring that
environmental impact  statements be prepared for  various  regulatory actions,
including  standards of  performance developed  under  section 111 of  the Act.
This voluntary  preparation  of environmental  impact  statements,  however,  in
no way legally  subjects  the Agency to  NEPA requirements.
      To  implement this  policy,  a  separate section  in this  document is
devoted solely  to an  analysis  of the potential  environmental  impacts asso-
ciated with the proposed standards.   Both adverse  and beneficial  impacts in
such areas as  air and water pollution, increased solid waste  disposal,  and
 increased energy consumption are discussed.
2.6   IMPACT ON EXISTING SOURCES
      Section 111 of the Act defines a new source as "... any stationary
 source,  the construction or modification of  which is commenced ..." after
 the  proposed -standards  are published.   An existing source is  redefined as a
 new source if "modified" or "reconstructed"  as defined in amendments to the
                                   2-10

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general provisions of Subpart A of 40 CFR Part 60, which were promulgated
in the Federal Register on December 16,  1975 (40 FR 58416).
     Any physical or operational change  to an existing facility which
results in an increase in the emission rate of any pollutant for which a
standard applies is considered a modification.   Reconstruction, on the
other hand, means the replacement of components of an existing facility to
the extent that the fixed capital cost exceeds 50 percent of the cost of
constructing a comparable entirely new source and that it be technically
and economically feasible to meet the applicable standards.   In such cases,
reconstruction is equivalent to a new construction.
     Promulgation of a standard of performance requires States to establish
standards of performance for existing sources in the same industry under
Section lll(d) of the Act if the standard for new sources limits emissions
of a designated pollutant (i.e., a pollutant for which air quality criteria
have not been issued under Section 108 or which has not been listed as a
hazardous pollutant under Section 112).   If a State does not act, EPA must
establish such standards.  General provisions outlining procedures for
control of existing sources under Section lll(d) were promulgated on
November 17, 1975, as Subpart B of 40 CFR Part 60 (40 FR 53340).
2.7  REVISION OF STANDARDS OF PERFORMANCE
     Congress was aware that the level of air pollution control achievable
by any industry may improve with technological advances.  Accordingly,
Section 111 of the Act provides that the Administrator ". .  . shall, at
least every 4 years, review and, if appropriate, revise ..." the
standards.  Revisions are made to assure that the standards continue to
reflect the best systems that become available in the future.  Such
revisions will not be retroactive but will apply to stationary sources
constructed or modified after the proposal of the revised standards.
                                  2-11

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           3.   THE PERCHLOROETHYLENE DRY CLEANING INDUSTRY

     This section provides a brief background description of the domestic
dry cleaning industry.  The dry cleaning process and its emissions are
described.
3.1  GENERAL INDUSTRY DESCRIPTION
     The dry cleaning industry is a service industry involved in the
cleaning and renting of apparel.   The industry is basically composed of
three categories that are segregated by the type of services they offer.
These are (1) coin-operated facilities, (2) commercial dry cleaners, and
(3) industrial dry cleaners.
     Coin-operated perch!oroethylene (perc) dry cleaning facilities are
usually, but not necessarily, part of a "laundromat" facility and operate
on either an independent or franchise basis.  They provide low-cost,
self-service dry cleaning without pressing, spotting, or other associated
services.  Since all coin-operated laundromat facilities do not contain.
dry cleaning equipment, there is.some variation in coin-operated dry
cleaning population estimates.  Bureau of Census data for 1976 indicated
a coin-operated dry cleaning facility population of 11,804 facilities
(County Business Patterns, 1976).  An industry source estimated the 1979
population of coin-operated laundromat facilities at 40,000 with 15,000
to 18,000 having dry cleaning machines (Gill, W., 18 January 1979).  The
difference between the two estimates is due primarily to different methods
of measurement.  Coin-operated dry cleaning facilities usually have two
or three dry cleaning machines and an approximate annual throughput of
8,986 kg (19,811 Ibs) of clothes (County Business Patterns, 1976).
Approximately 97.5 percent of the coin-operated machines use perc.
     Commercial perc dry cleaning plants are the most familiar type of
facilities, offering the normal services of cleaning soiled apparel or
                                  3-1

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other fine goods.  They include small neighborhood dry cleaning shops
operating on an independent basis ("Mom and Pop" dry cleaners), the fran-
chise dry cleaning shops ("One Hour Martinizing"), and the specialty
cleaners which handle leather and other fine goods.   Bureau of Census
data indicated a 1976 commercial dry cleaner population of 19,953 facilities
(County Business Patterns, 1976).  An industry source estimated the 1979
commercial dry cleaning population at 25,000 facilities (Fisher, W.,
19 January 1979).  Again these differences are probably due to different
methods of measurement (for further explanation see Section 8.1.2).
Commercial installations usually have one dry cleaning system and have an
annual throughput of less than 23,000 to 113,000 kg-(<50,000-250,000 Ibs)
of clothes according to IF! data (Watt, A., January-February 1975).
Approximately 73 percent of the dry cleaning equipment found in commercial
facilities uses perc; of the remaining commercial facilities, 24 percent
use petroleum and 3 percent use trichlorotrifluoroethane (F-113) (Fisher,
W., 19 January 1979).
     The industrial dry cleaners are the largest dry cleaning plants,
predominantly supplying rental services of uniforms or other items to
business, industrial, or institutional customers.  Bureau of Census data
indicated a 1976 population of 913 industrial laundry facilities (County
Business Patterns, 1976).  However, all industrial laundry facilities do
not have dry cleaning equipment.  An industry spokesman has estimated
that 40 to 45 percent have dry cleaning equipment (Dees, E., 7 May 1979).
The typical industrial dry cleaning facility has one dry cleaning system
with an annual throughput of 240,000 to 700,000 kg (530,000 to 1,500,000  Ibs)
of clothes (Sluizer, M., 1 March 1979).  Approximately 50 percent of the
dry cleaning equipment found in  the  industrial  facility sector uses perc
(Sluizer, M., 1  March 1979).
                                                               *
3.2  DRY CLEANING PROCESSES
3.2.1  The Basic Process
     Dry cleaning is essentially a waterless process in which  clothes are
cleaned with an  organic solvent  rather than with  soap and water.  The
principal steps  in the process  are identical to those of laundering  in
water.  In the first step, clothes are loaded into the washer, and  solvent
is added.  The clothes and solvent are then agitated by the turning
                                   3-2

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motion of a paddle or wheel.  After washing is completed, the clothes are
spun as in a conventional washer spin cycle to remove the solvent.  This
part of the process is called extraction.  After extraction, the used
solvent is filtered and distilled to remove impurities and is then returned
to the system.   The filtered solids, or "muck," contain solvent which is
removed and returned to the system.   After solvent wash and extraction,
the clothes are tumbled dry.  During the drying cycle, much of the eva-
porated solvent is recovered in a condenser and returned to the system.
Remaining solvent in the clothes is reduced by venting ambient air thru
the clothes.   This process is called aeration or deodorization.
     The solvents used are categorized into two broad groups--(l) petroleum
solvents, which are mixtures of paraffins and aromatic hydrocarbons
similar to kerosene and (2) synthetic solvents, which are halogenated
hydrocarbons, perc, and F-113.   Differences between the dry cleaning
procedures for these two groups of solvents are due to the following
factors:
     0    Synthetic solvents are more expensive than petroleum solvents.
     0    Petroleum solvents are combustible while synthetic solvents are
          nonflammable.
     •    The densities of synthetic solvents are about twice those of
          petroleum solvents.
     0    OSHA standards for perc are more stringent than those for
          petroleum solvents.   OSHA standards for F-113 are considerably
          less strict than those for perc or petroleum solvents.
Figure 3-1 is a schematic of a synthetic solvent-based plant.
3.2.2  Perch!oroethylene Plants
     As explained in section 3.1, the perc system population as a percentage
of total  dry cleaning machines comprises 97.5 percent of coin-operated
facilities, 73 percent of commercial facilities, and 50 percent of industrial
facilities for totals in each industry sector of 11,804, 15,060,  and 239,
respectively.  In order to classify and quantify perc dry cleaning equipment
and emissions,  EPA tested a large commercial plant, four average  commercial
plants, and a large industrial  plant (plants A-E as described in  appendix C).
No emission tests were performed on coin-operated machines.
                                  3-3

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     3-2.2.1   Equipment Characteristics.  There are two basic types of
dry cleaning machines:
     •    Transfer machines are those  in which washing and drying are
          performed  in different machines.  After washing and extraction,
          the  fabrics must be transferred to the dryer.
     •    Dry-to-dry machines are those in which washing and drying occur
          in a single unit.  In the past, these were termed "hot" machines
          because they were hot at the end of the complete cycle.  In
          view of technological advancements in the field of room and low
          temperature drying, this name is no longer applicable.
     Perc systems use either type of operation.  In the commercial and
industrial sectors the majority of perc systems are transfer systems
(Victor, Irving, 1 November 1978), whereas all coin-ops are dry-to-dry
systems.  Dry-to-dry systems have the following disadvantages:
     e    A dry-to-dry operation can handle about half as many loads per
          day as a transfer operation.   Because washing and drying are
          performed in different pieces of equipment in transfer operations,
          these operations can occur simultaneously on different cleaning
          batches.   In a dry-to-dry machine a given load must be washed
          and dried in the same machine.
     •    Because the dry-to-dry machine is hot at the end of the drying
          cycle, the incoming solvent for the next cycle picks  up a large
          amount of heat.   This can adversely affect the machine seals
          and some delicate fabrics as  well  as increase solvent vapor
          losses.   It should be noted that advancement is being made in
          the field of low temperature  dry-to-dry machines.   This
          advancement would nullify the disadvantage.
     In spite of these disadvantages,  dry-to-dry machines are of increasing
interest to the industry as a result of the following advantages:
     •    Because there is no transfer  of solvent-laden clothing between
          the washing and drying cycles,  there is  little chance,for perc
          vapors to escape into the work area.   For this reason, dry-to-dry
          units will  comply more easily with Occupational  Safety and
          Health Administration (OSHA)  requirements for maximum  perc
          concentrations  in the work area than transfer units will.
                                  3-5

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     t    The machines are simple to operate and require little attention
          by the operator during the cleaning cycle.
     3.2.2.2  Solvent Characteristics.   Though one other halogenated
hydrocarbon solvent, F-113 (trichlorotrifluoroethane), is used for dry
cleaning in the United States, perc (tetrachloroethylene) is the most
common dry cleaning solvent, accounting for 97.5, 73, and 50 percent of
the dry cleaning systems in the coin-operateef, commercial, and industrial
sections, respectively.  An estimated 167 million kg of perc (Laundry and
Cleaners Allied Trades Association, Inc., December 1978) are used annually
for dry cleaning purposes.  Characteristics of perc include:
     •    Nonflammability
     •    High vapor density
     •    High cost ($0.49/kg, ($3.00/gal.)) (Fisher, W. E., 21 September 1978)
     •    Aggressive solvent properties
     3.2.2.3  Solvent Treatment.  Because of the expense of perc, economic
operation necessitates at least partial  recovery and  reuse  of  used solvent.
To accomplish this, some solvent conditioning  steps are  required to
prevent  solvent degradation and to  otherwise enhance  the cleaning opera-
tion.  These steps  include  filtration,  distillation,  and charging.
      Filtration -
      Some  of the soils  removed from fabrics are not  soluble and must  be
filtered from the  solvent.  The  filters may contain  activated carbon  for
the  removal of  dye  from the solvent.   The solids  or  "muck"  which  are
removed  from the filters contain  solvent that  is  recovered by distillation
in perc  plants, except in the case of  cartridge filters.   Cartridge
filters  are normally just drained in their housing and are then  discarded
with trash.
      Distillation  -
      In  addition to the insoluble residue,  which is  removed by filtration,
a buildup  of soluble nonvolatile residue (NVR) occurs in the solvent.
NVR  is composed primarily of oils, fats, and greases cleaned from fabrics.
 It is eliminated from the used solvent by distillation.   In some perc
 plants,  a single unit serves  for distillation of both the used solvent
 and the filter muck.
                                   3-6

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     Charging -
     To remove water-soluble materials from fabric during dry cleaning, a
small amount of detergent and water must be added to the solvent in a
step known as charging.  Because these additives are removed during
distillation, they must be replaced prior to solvent reuse.
3.3  BASELINE EMISSIONS
3.3.1  Plant Emissions
     Table 3-1 shows solvent losses for both controlled and uncontrolled
professional perc dry cleaning systems.  These estimates are based on
well-operated commercial and industrial plants as reported by IFI
(Fisher, W. E., July-August 1975).  EPA data are also given in Table 3-1
from the testing of one industrial and four commercial dry cleaning plants.
It should be noted that total perc emissions from dry cleaning facilities
can vary greatly with operational, maintenance, and housekeeping procedures.
The data presented in Table 3-1 are from well-operated and well-controlled
facilities and do not represent the norm in the industry.  As shown here,
uncontrolled systems have high emission rates from filter muck and dryer
exhaust. The figures for dryer emissions assume that a reclaiming dryer
with a vapor condenser is in use.  After wash and extraction, dry-cleaned
materials contain approximately 20 to 25 percent solvent by weight. The
condenser on the reclaiming dryer reduces these potential perc losses to
3 to 6 percent.
     Other sources of vapor losses include evaporation at the washer,
distillation unit residue disposal, and miscellaneous sources.   The
miscellaneous sources include losses from pumps, valves, flanges, and
seals; chemical  and water separators; and inefficiencies in handling
solvent materials.
     According to IFI data (Fisher, W.  E., July-August 1975), the usual
commercial plant has a regenerative filter with a muck cooker.   This can
result in a total emission rate of about 8.1 kg of solvent per 100 kg of
clothing.   For an adsorber-equipped system, the emission rate is esti-
mated at approximately 4.9 kg per 100 kg of clothing.   This represents a
reduction of about 40 percent.   It should be noted that these figures are
based on industry-generated statistics which do not necessarily agree
with EPA's test data.
                                  3-7

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   Table 3-1.   PERCHLOROETHYLENE  EMISSIONS  FROM PROFESSIONAL DRY
               CLEANING  PLANTS
                              :a-e
          Source
Emissions, kg/100 kg of clothing
Plants without       Plants with
vapor adsorber     vapor adsorber
Evaporation @ washer
Evaporation @ dryer
Vapor adsorber exhaust
(Properly operated)
Retention in filter much
• 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
TOTAL
0.54
3.
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aFisher,  W.  E.,  July-August 1975.
DKleeberg,  Charles F.,  17 March 1976.
:Kleeberg,  Charles F.,  14 May 1976.
%leeberg,  Charles F.,  17 May 1976.
eIFI data (EPA data).
fNo EPA test data, 1 assumed.
                               3-8

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     EPA data show that a commercial or industrial plant that has a
regenerative filter with a muck cooker yields a total emission rate of
about 10.6 kg per 100 kg of clothing and that an adsorber-equipped system
yields an emission rate of 3.9 kg per 100 kg of clothing.  This represents
a 63 percent reduction in the emission rate (Kleeberg, G. F., 17 March 1976)
(Kleeberg, C. F., 14 May 1976) (Kleeberg, C. F., 17 May 1976).
     Carbon adsorbers are now being used by about 35 percent of the
commercial systems (Matthews, Stanley, 5 November 1978) and 50 percent of
the industrial systems (Victor, Irving, 1 November 1978).  Carbon adsor-
bers are not considered feasible for use in coin-op systems because there
is usually not enough space for a boiler on the premises to supply the
steam necessary to desorb the carbon bed. According to a Dow Survey
(Cunniff, Joseph, 3 March 1977), about 5 percent of coin-op machines use
carbon adsorbers.   In Table 3-2 the baseline emission levels are deter-
mined for each of the industry sectors accounting for plants already
equipped with controls.
     Note that the Dow Survey also gives data on the proporation of dry
cleaners meetings given solvent mileages.  For the coin-op segment of the
industry, the average mileage gives a perc loss of about 16 kilograms per
100 kilograms of clothing.   The most efficient 20 percent, however, have
a perc loss rate of about 12 kilograms per 100 kilograms.  Better control
is achieved by proper maintenance and proper waste solvent treatment.

            DATA FOR DETERMINING BASELINE EMISSION LEVELS

     As noted in section 3.3.1, the emission test data in Table 3-1
represent well-controlled facilities in the industry.  In order to deter-
mine actual baseline emission levels, however, it is necessary to quantify
perc emissions from typical or average plants in the industry.  The
following discussion explain the derivation of the baseline emission
levels for each industry sector.  Table 3-2 summarizes the baseline
emission levels.
Coin-Op
Assumptions:   5 percent of coin-op machines have carbon adsorbers.
     Emission Rate with Carbon Adsorption = 11.3 kg of solvent per 100 kg
          of clothes cleaned
                                  3-9

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          Table 3-^2.   BASELINE PERCHLOROETHYLENE EMISSION LEVELS
                                                                a,b
      Industry
       sector
                                  Emissions, kg/100 kg of clothing
Uncontrolled
Controlled
Sector average
Coin-operated sector
Commercial sector
    15.9
    10.1
   11.3


    8.4
     15.7


      9.5
Industrial sector
    11.4
    9.5
     10.4
aCuniff, Joseph, 3 March 1977.

bKleeberg, C. F., 14 May 1976.

ฐBased on percentage of controlled plants (coin-operated - 5%; commercial -
 35%, and industrial - 50%).
                                    3-10

-------
     Emission Rate without Carbon Adsorption = 15.9 kg of solvent per
          100 kg of clothes cleaned
     Baseline Emission Rate = (0.95)(15.9) + (0.05)(11.3) = 15.7 kg of
          solvent per 100 kg of clothes cleaned
Commercial
Assumptions:  35 percent of commercial machines have carbon adsorbers.
     Emission Rate with Carbon Adsorption = 8.4 kg of solvent per 100 kg
          of clothes cleaned
     Emission Rate without Carbon Adsorption = 10.1 kg of solvent per
          100 kg of clothes cleaned
     Baseline Emission Rate = (0.35)(8.4) + (0.65)(10.1) = 9.5 kg of
          solvent per 100 kg of clothes cleaned
Industrial
Assumptions:  50 percent of industrial machines have carbon adsorbers.
     Emission Rate with Carbon Adsorption = 9.5 kg of solvent per 100 kg
          of clothes cleaned
     Emission Rate without Carbon Adsorption = 11.4 kg of solvent per
          100 kg of clothes cleaned
     Baseline Emission Rate = (9.5)(0.5) + (11.4)(0.5) = 10.4 kg of
          solvent per 100 kg of clothes cleaned
All assumptions and emission rates are based on data from Dow Survey (Dow
     Chemical, 3 March 1977) and on EPA stack test data (Kleeberg,  C.  F.,
     14 May 1976).
3.3.2  Existing and Future Regulations
     The baseline emission level is the level  of emission control that is
achieved by the affected industry in the absence of additional EPA stan-
dards.   Existing regulations limiting emissions from facilities within
the dry cleaning industry are the Federal regulations promulgated by OSHA
concerning worker exposure protection, the State Implementation Plans
(SIP's), and some local regulations specifically addressing dry cleaning
emissions.  These regulations now have limited, if any, effect on the
baseline emissions.   The effects of water and solid waste regulations
proposed by EPA on the dry cleaning industry will  also be discussed.
     3.3.2.1  Existing Regulations.  The rules and regulations set by
OSHA on dry cleaning solvent vapors were first published in the Federal
                                  3-11

-------
Register in August 1971 and have not changed since their original  publi-
cation.   The National Institute for Occupational  Safety and Health (NIOSH)
supplies OSHA with the information for setting standards to control
health hazards in the work place.  The current OSHA standards for occupa-
tional exposure to perchloroethylene are as follows:
     •    100 ppm - 8-hour Time Weighted Average (TWA)
     •    200 ppm - Ceiling (may not be exceeded for more than 5 minutes
          every 3 hours).
     •    300 ppm - Peak (never to be exceeded).
OSHA standards could change if more information becomes available on any
of the health effects of perc.
     3.3.2.2  Future Regulations.  In December 1978, a  control techniques
document  (CTG) on Control of Volatile Organic Emissions from Perchloro-
ethylene  Dry Cleaning Systems was  issued by EPA.  This  document provides
information to State and local  air pollution control agencies on  reasonably
available control technology (RACT) that can be applied to  existing
perchloroethylene 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.  As specified  in the perc CTG, a
dry  cleaning facility required  to meet RACT for perc would  have to vent
the  entire  dryer exhaust to a carbon  adsorber or  equally effective control
device.   In addition, the  facility would be required to eliminate liquid
leakage of perc  from their system and limit gaseous leakage to a  level
specified by their  State or local  air pollution  control agency.   RACT
would limit the  perc concentration in the vent  from the dryer control
device  to a maximum of  100 ppm  before dilution.   Based on  CTG guidelines,
the  facility would  also be required to control  filter  and  distillation
waste as follows:
      (1)  Cook or treat the residue from  any  diatomaceous  earth  filter  so
that wastes would not contain more than  25  kg of solvent per  100  kg  of
wet  waste material.
      (2)  Operate a solvent still so that the residue  would not  contain
 more than 60  kg of solvent per 100 kg of wet waste material.
                                   3-12

-------
     (3)  Drain filtration cartridges in the filter housing for at least
24 hours before being discarded.
     (4)  Any other filtration or distillation system could be used if
equivalency to these guidelines is demonstrated.   For purposes of equiva-
lency demonstration, any system reducing waste losses below 1 kg solvent
per 100 kg clothes cleaned would be considered equivalent under the CTG
guidelines.
     Revised SIP's for perc dry cleaners are only required in those areas
that are in violation of the National Ambient Air Quality Standard (NAAQS)
for photochemical oxidants that cannot demonstrate compliance with the
NAAQS without applying RACT by July 1982.   However, some local counties
and municipalities that do not meet EPA's air quality standards or that
otherwise believe they have just cause to control solvent emissions have
enacted local ordinances.   In Arizona, the Maricopa County Bureau of Air
Pollution Control requires the use of a vapor adsorber or a condensing
system with an inlet temperature of less than 296 K (72ฐF) for all
chlorinated hydrocarbons.
                                  3-13

-------
                         REFERENCES FOR CHAPTER 3


County Business Patterns 1976, United States Department of Commerce, United
     States Bureau of the Census, Washington, D.C.,  U.S.  Government Printing
     Office, September 1977.

Cunniff, Joseph, Puritan Filters, letter to Kleeberg, Charles F., US EPA,
     3 March 1977.  Dow Chemical Survey, Anonymous.

Dees, Edie, TRW, letter to Sluizer, Bud confirming telephone conversation
     of 19 January 1979, 7 May 1979.

Fisher, William E., IFI Director of Research, telephone conversation with
     Dees, Edith, TRW, 19 January 1979.

Fisher, William E., International Fabricare Institute, "The ABCs of Solvent
     Mileage" Part One, IFI Special Reporter, No. 3-4, July-August 1975.

Fisher, William E., IFI Director of Research, telephone conversation with
     Nunn, Arthur B., TRW, 21 September 1978.

Gill, Ward, President of National Automatic Laundry and Cleaning Council
     telephone conversation with Buckwalter, Mary K., TRW, 18 January 1979.

Kleeberg, Charles F., US EPA, "Material Balance of Industrial
     Perch!oroethylene Dry Cleaner", test report to James F. Durham on test
     in San Antonio, Texas, 14 May 1976.

Kleeberg, Charles F., US EPA, "Material Balance of Perchloroethylene Dry
     Cleaning Unit", test report to James F. Durham on test in  Hershey,
     Pennsylvania, 17 March 1976.

Kleeberg, Charles F., US EPA, "Material Balance of a Small Commercial
     Perchloroethylene Dry Cleaner", test report to James F. Durham on test
     in Kalamazoo, Michigan,  17 May 1976.

Laundry and Cleaners Allied Trades Association,  Inc., letter to Goodwin, D.
     R.,  Director, ESED, EPA, 30 November 1978.

Matthew,  Stanley, R. R. Street,  Inc.,  telephone conversation with
     Buckwalter,  Mary K., TRW,  5 November 1978.

Sluizer,  Mervyn,  Technical  Director of Institute of  Industrial  Launderers,
     telephone  conversation with Young, Dexter E., TRW, 1 March 1979.

Victor, Irving,  Executive Vice  President of VIC Manufacturing Co.,  telephone
     conversation with Buckwalter, Mary K., TRW, 1 November 1978.

Watt,  Andrew,  IV, and William E. Fisher, "Results of Membership Survey  of
     Dry  Cleaning Operation."  IFI  Special  Reporter  No. 3-1,
    - January-February 1975.
                                   3-14

-------
                     4.  EMISSION CONTROL TECHNIQUES

     This chapter discusses control technologies applicable to perc dry
cleaners.  All possible emission control technologies are evaluated and
ranked from the highest to the lowest level of control.
4.1  USE OF CONTROL TECHNIQUES
     To a great extent, solvent emissions from perc dry cleaning plants
are already controlled through economic necessity.  To compete with, less
expensive petroleum solvents, a substantial degree of solvent recovery is
necessary during the drying operation.  This is the reason for the use of
reclaiming dryers in most perc cleaning establishments.  For the same
reason, many perc systems are equipped with carbon adsorbers.  Carbon
adsorbers are now being used by about 35 percent (5,300 facilities) of
the commercial systems (Matthews, Stanley, 5 November 1978) and 50 percent
(120 facilities) of the industrial systems (Victor, Irving, 1 November 1978).
4.2  TYPES OF CONTROL TECHNIQUES
4.2.1  Solvent Change to a Nonphotochemically Reactive Compound
     The greatest reduction of perc emissions would be achieved by
eliminating perc completely by changing to another solvent.  The only
readily available alternative solvents for the first option are trichloro-
trifluoroethane (F-113) and petroleum solvents.   Petroleum solvents are
photochemically reactive, so their use in place of perc would not reduce
ozone formation.  Research to develop a new source standard for petroleum
dry cleaning is now underway.  However, petroleum solvents are flammable
and are, therefore, regulated by fire codes and insurance regulations.
Petroleum solvents may not be allowed in shopping centers due to their
flammability.  For these reasons, few dry cleaners are expected to use
petroleum solvents instead of perc.  At present, at least one dry cleaning
                                  4-1

-------
solvent, F-113, is not believed to be photochemically active.   However,
there is some indication that F-113, along with other fluorocarbons,  may
cause depletion of the upper atmospheric ozone layer.  This solvent does
not have the same cleaning characteristics as perc and, according to
industry spokesmen, may be unsuitable for heavily soiled articles.  Also,
this solvent, as is the case with petroleum solvent, cannot be used in
existing perc equipment.  Thus modified and reconstructed perc equipment
would have to be replaced with trichlorotrifluoroethane equipment if this
control option were promulgated.  Trichlorotrifluoroethane equipment is
also more expensive than perc equipment, and the solvent itself is three
to four times as expensive as perc.
     Current fluorocarbon machines  are dry-to-dry units.   Because fluoro-
carbons are by far the  most  expensive of the dry cleaning  solvents at
$1.60-$2.00/kg ($10-$12/gal), fluorocarbon machines  must show  that low
solvent consumption is  cost-competitive with perc or petroleum machines.
Therefore, all fluorocarbon  machines have a built-in control device, a
refrigeration/condensation system.   The fluorocarbon machine recirculates
dryer  air over a  refrigerated condenser (255 K, -18ฐC), then over electric
reheat coils.  Expansions or contractions in the  stream volumes  caused by
temperature  changes are accommodated by an elastomeric expansion bag on
top  of the unit.  This bag inflates  with solvent-laden air  as the tempera-
ture in the  machine increases  and collapses  as the  temperature decreases.
Condensed solvent is  filtered  and distilled  for reuse.
4.2.2  Carbon  Adsorption
      Activated carbon has been used in a  variety  of applications for the
 removal of organic compounds from gaseous streams by adsorption.   Adsorp-
 tion is the  property  of a surface to retain  molecules of  a fluid with
 which it has .come in  contact.   The adsorption capacity of a given quantity
 of carbon varies with different organic compounds and the type of carbon
 used.  Perc can be retained on carbon very easily.   The bed capacity
 (weight of solvent per weight of carbon,  expressed as percent) for perc
 is approximately 20 percent by weight (Barber, J. N., 6 February 1976).
      A typical commercial carbon adsorption unit has one carbon canister
 which is usually desorbed once a day.
                                   4-2

-------
     A large industrial adsorption unit usually contains multiple canisters
so that one can be used while the other is being regenerated.  A blower
forces the sol vent-laden air through one of the adsorbers.  Prior to
reaching the point of saturation, the flow of air is switched, and the
first is desorbed.  Desorption is accomplished by passing steam through
the carbon bed.  The vaporized solvent is picked up by the steam, recovered
downstream in a condenser, separated from the water, and then returned to
the storage tank.
     Carbon adsorption has been used in the perc dry cleaning industry
for some time out of economic necessity.   Almost all perc systems use
condensers to recover losses from the dryer.
     Summarized in Table 4-1 are the adsorber inlet and outlet data
collected during the source tests.  Also in Table 4-2 is a list of the
sources controlled by carbon adsorption at each test site.  In each case,
vapors were drawn from at least the dryer or dry-to-dry machine..
     For perc-based units, carbon adsorption can be used to achieve
100 ppm or less outlet concentration.   Space requirements vary with the
size of the unit.  For the three plants tested, the adsorber floor space
is shown in Table 4-2.   These area estimates include piping, canister,
and ductwork.   More information on test results is presented in Appendix C.
     For a transfer operation, OSHA requires that a current of fresh air
be provided at the operator's face while unloading solvent-laden clothes
from the washer.  This can be accomplished by a fan which draws air
through a duct at the machine door lip or by venting through the machine
door itself.   This sol vent-laden airstream is then vented to the carbon
adsorber.
     Dryers generally vent only at the end of the drying cycle.   Dryers
may aiso vent when a thermostat causes cool  air to enter an overheated
dryer.   There is at least one system design in which the dryer vents to
an adsorber continuously.
     Floor vents are usually installed around the machines and next to
storage tank filters in order to collect fugitive emissions and vapors
from solvent spills.   These vents can  be directed to the carbon adsorber
                                  4-3

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from solvent spills.  These vents can be directed to the carbon adsorber
as was the case with test plants A and C.   There is evidence that these
vents are more effective if they are located at the same level  as the
solvent emissions; perc vapors do not necessarily drop to the floor
because the vapor density of the mixture of perc in air is, at most, only
about 1.1 times the vapor density of pure air.
     There is no technical reason why all perc sources in dry cleaning
plants that are currently vented through a stack or duct to the atmos-
phere cannot be directed to a carbon adsorber.  This would include
distillation unit vents, washer loading vents, storage tank vents, chemical
separators, and floor vents.
     As can be seen in Table 4-2, carbon adsorption can result in better
then 96 percent emission reduction applied to gas streams seen by the
adsorber.
     Carbon adsorption presents a special problem for coin-operated
systems. 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 facilities, and necessary space for an adsorber is not
avaiTable. In order to desorb a carbon bed, a boiler would have to be
installed on site for regeneration.
4.2.3  Refri geratfon/Condensation
     A refrigerated condenser solvent recovery unit provides an alternative
to the carbon recovery system.  Whereas the carbon system is usually
exhausted to the atmosphere, the refrigerated condenser is normally
operated as a closed circuit and eliminates the need for external venti-
lating ducts.
     As previously  discussed, emissions from a dryer are usually limited
to the aeration cycle.  A refrigerated condenser works during this cycle
as follows:  the solvent-laden air from the cleaning machine is cooled  to
a very low temperature to strip it of solvent and  is then recirculated  to
the air  inlet port  of the machine.  The cooling effect is obtained from a
refrigeration unit  and is required only during the aeration cycle.  This
effect drops the temperature of the air below the  dew point of the vapor
thereby  causing it  to condense and drain to a water separator.  The
                                   4-6

-------
 recovered  solvent  is  then  fed  to  a  storage  tank.   Test  data  from  one
 source  indicate  that  refrigeration  units  on dry-to-dry  units can  achieve
 emission rates comparable  to a well-operated carbon  adsorber equipped
 facility (Jongleux, R.  F., April  1980).   Net solvent usage during the
 test was 10.2 liters,  and  the  plant throughput was 427  kg.   Based on
 these figures, the mass  loss rate from the  dry cleaning unit was
 3.85 kilograms of perc per 100 kilograms  of clothes  cleaned  based on the
 actual weight of articles  cleaned.   Based on the machine capacity, the
 solvent loss rate was  2.6  kilograms  per 100 kilograms of articles cleaned.
 However, it should be  understood.that these figures  are based upon a
 limited amount of data.
     Also, this does not mean  that  refrigeration units  necessarily achieve
 control equivalent to  carbon adsorption units.  There are emission points
 that might be ducted to carbon adsorbers, but that would not  be controlled
 by the refrigeration units.  For instance,  floor vents  that would normally
 be ducted to a carbon  adsorber cannot be  vented to a refrigeration system
 because the bed of packed stoneware  used  as  a heat sink in the system
would be heated by the ambient air entering  the floor vent.   This stoneware
 is usually cooled during the drying  cycle and only exposed to elevated
temperatures during aeration.   System efficiency would  be adversely
affected if the stoneware was  not at a sufficiently  low temperature.
4.2.4  Solvation  Unit
     Another possible alternative to the  carbon adsorber is the Solvation*
unit.   This unit has been in use in  Europe  for approximately 3 years and
has been available in the United States for approximately 6 months.
     Available information indicates that this unit operates as a closed
loop sysem.  The dryer exhaust is ducted to the Solvation unit where perc
is condensed and then passes over the cooling coils of  its associated
dryer before being returned to a solvent storage  tank (Weissler,  Bill,
22 May 1980).   The exact mechanism of operation is  not currently  known,
but one possible explanation for the unit's operation is the use  of
direct contact condensation when gaseous perc emissions  are passed through
 Registered trademark.
                                  4-7

-------
water.  The unit is guaranteed by the U.S. manufacturer to double the dry
cleaner's solvent mileage (Weissler, Bill, 22 May 1980).
 4.2.5  Housekeeping
     Fugitive emissions caused by poor maintenance of equipment are
difficult to quantify.  There are two types of fugitive losses, liquid
and vapor. Liquid losses can be detected by sight.  Vapor leaks above
50 ppm can be detected by smell (Wentz, Manfred, August-September 1973).
Below is a list of common emission areas that should be checked periodi-
cally to control these losses.  This checklist is similar to those used
by knowledgeable sources (Hooker Industrial Chemicals, Bulletin Number
185) (Reeves, H. E., January 1969) (VIC Manufacturing Company, Installation
and Operation Instruction for VIC Models 221 and 222) to advise perc
users on how to maintain equipment.
     Liquid leakage areas include:
     a)   Hose connections, unions, coupling, 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 baskets.
     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  (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.  These should  be opened only as
          long  as  necessary.
      e)   Open  containers of solvent.
                                   4-8

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      f)   Evaporation from wet wash during transfer process.
      g)   Removal of articles prior to complete drying.
      Other areas include:
      a)   Lint screens and bags, fan blades,  and condensers.   These areas
           can adversely affect capture systems if they are clogged or
           caked with lint.
      b)   Overloading and  underloading dryer  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
           overload the dryer.
      Rapid detection and repair of leaks is essential  in  order to  minimize
 solvent losses.   Low and moderately priced leak detectors are available
 and could be  used on a regular basis to assist in detecting leaks  before
 they become large enough to  see or smell.  Monitors are addressed  in
 Appendix D.
 4.2.6  Waste  Solvent Treatment
      Waste solvent is  generated by filters in  the form of filter muck  and
 by  solvent stills  in the form  of distillation  bottoms.  The perc content
 of  these  wastes  can  be minimized before  disposal  by proper treatment.   In
 perc  systems,  solvent may be "cooked"  out of regenerate  filter materials
 in  muck cookers.   These  muck cookers can reduce the  amount of  solvent
 lost  in filter material  by 89  percent  (see Table  3-1).  Solvent losses
 from  distillation  bottom disposal  can  also be reduced  in  oil cookers
 (similar  to muck cookers) to levels of about 1 kg/100  kg  of wet waste
material  by proper operation of  existing equipment  (Kleeberg,  C. F.,
14  May 1976).
     Another option for  filtration is cartridge filters.   Cartridge
filters are applicable to low  soil loadings and are used by most coin-op
machines and many commercial  operations.  There are many types of car-
tridge filters as shown in  Table 4-3.  In the  test data,  plant C had a
paper cartridge filter with a carbon core.   This filter achieved a low
emission rate of 0.6 kg of  solvent/100 kg of articles cleaned  when exposed
to  the atmosphere.  Plant D had a low-pressure-type activated  clay cartridge
                                  4-9

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filter.  This filter had an emission rate of 2.7 kg of solvent/100 kg
of articles cleaned when exposed to the atmosphere.
     Generally, cartridge filters can achieve low emission factors if the
manufacturer's recommendations are followed on when to dispose and replace
the cartridges.  Before disposal these filters should be drained in their
housing a minimum of 24 hours to reduce emissions.
     There are several filter and still system configurations commonly in
use.  Filter units and solvent stills are process equipment at cleaners
and, therefore, impose no additional space requirements on dry cleaners.
Possible configurations are:  regenerable filter with a solvent still;
disposable filter with a solvent still; disposable filter without a
solvent still; and oil cooker with a solvent still.  Table 4-3 shows the
amount of solvent per 100 kg of wet waste material.  These numbers repre-
sent well-operated filter and distillation systems as demonstrated by EPA
tests.
     Centrifugal separation might be an alternative to filtration for
recovery of the waste solvent.  Although such systems have been utilized
for petroleum  solvent dry cleaning, there are no  data presently available
on their applicability to perc dry cleaning.
                                   4-10

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          Table 4-3.  FILTER AND DISTILLATION WASTES FROM
                      WELL-OPERATED FACILITIES
     Source
kg of solvent/100 kg
of wet waste material
     Filter System
          Regeneration Tube
          Cartridge
     Distillation
     Oil  Cooker
25 kg/100 kgc
Wide range
60 kg/100 kgc
1 kg/100 kgd
 Kleeberg,  C.  F.,  17 March 1976.
3Too many types of cartridge filters
     e.g.,  Clay -  24.5 kg solvent/100 kg of wet waste material
           Carbon  Core - 2 kg solvent/100 kg of wet waste material
           Activated Clay - 2.7 kg solvent/100 kg of wet waste material
'Fisher,  William,  10 May 1979.
Kleeberg,  C.  F.,  14 May 1976.
                              4-11

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                      REFERENCES FOR CHAPTER 4


Barber, J. N., Research Director, VIC Manufacturing Company, Minneapolis,
     Minnesota, letter to Kleeberg, C.  F.,  US EPA, 6 February 1976.

Fisher, W. E. Director of Research of Internal Fabricare Institute,  telephone
     conversation with Young, Dexter E., TRW, 10 May 1979.

Fisher, W. E., Director of Research, International Fabricare Institute.
     Valclene Project Started.  Fabricare News.  September 1978.

Hooker Industrial Chemicals, Bulletin Number 185, "Hooker Handbook for Dry
     Cleaners", Anonymous, p. 10.

Jongleux, Robert F., "Perchloroethylene Emission Testing at Kleen Korner,
     New York", TRW, EMB 79-DRY-6, December 1979.

Jongleux, Robert F., "Material Balance Test Perchloroethylene Refrigerated
     Closed System, Northvale, New Jersey," TRW, EMB 79-DRY-7, April 1980.

Kleeberg, Charles F., US EPA, "Material Balance of Industrial Perchloroethylene
     Dry Cleaner", test report to James F. Durham on test in San Antonio,
     Texas, 14 May 1976.

Kleeberg, Charles F., US EPA, "Material Balance of Perchloroethylene Dry
     Cleaning Unit", test report to James F.  Durham on test in  Hershey,
     Pennsylvania, 17 March  1976.

Kleeberg, Charles F., US EPA, "Material Balance of a Small  Commercial
     Perchloroethylene Dry Cleaner", test report  to James F. Durham on test
     in Kalamazoo, Michigan,  17 May 1976.

Lundy, Robert, Dow Chemical,  letter to  Kleeberg,  C. F., US  EPA, 16 March  1976.
     Paper entitled "Poor Solvent  Mileage -  Professional Dry Cleaning
     Plant".

Matthews, Stanley, R.  R.  Street, telephone  conversation with Buckwalter,
     Mary K.,  TRW, 5  November 1978.

Reeves, H. E., International Fabricare  Institute,  "Causes of Excess  Loss  of
     Perchloroethylene,"  IFI Practical  Operating Trips  Bulletin,  p.  91,
     January 1969.

VIC Manufacturing Company,  "Installation  and Operating Instruction  for  VIC
     Models  221  and 222," VMC 1195.

Victor  Irving,  Executive Vice  President of VIC Manufacturing,  telephone
     conversation with Buckwalter, Mary K., TRW,  1 November 1978.
                                   4-12

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Weissler, Bill, Diversitron Corporation, letter to Young, D. E., TRW,
     22 May 1980.

Wentz, Manfred, International Fabricare Institute, "Dry Cleaning Solvent
     Vapors and OSHA," IFI Technical Bulletin No. T-421, August-September
     1973.
                                   4-13

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                    5.   MODIFICATION AND RECONSTRUCTION

     In accordance with Section 111 of the Clean Air Act, standards of
performance shall be established for new sources within a stationary
source category which ". .  .  may contribute significantly to air
pollution . .  ."  Standards apply to operations or apparatus (facilities)
within a stationary source, selected as "affected facilities," that is,
facilities for which applicable standards of performance have been
promulgated and the construction or modification of which commenced after
the proposal of said standards.
     On December 16, 1975,  the Agency promulgated amendments to the
general provisions of 40 CFR Part 60, including additions and revisions
to clarify modification and the addition of a reconstruction provision.
Under the, provisions of 40 CFR 60.14 and 60.15, an "existing facility"
may become subject to standards of performance if deemed modified or
reconstructed.  An "existing facility" defined in 40 CFR 60.2(aa) is an
apparatus of the type for which a standard of performance is promulgated
and the construction or modification of which was commenced before the
date of proposal of that standard.  The following discussion examines the
applicability of these provisions to perc dry cleaning facilities and
details conditions under which existing facilities could become subject
to standards of performance.   It is important to stress that since stan-
dards of performance apply to  affected facilities, which combined with
existing and other facilities  comprise a stationary source, the addition
of an affected facility to a stationary source through any mechanism, new
construction, modification, or reconstruction, does not make the entire
stationary  source subject to standards of performance; but rather only
the added  affected facilities  are subject to these standards.
                                  5-1

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5.1  40 CFR PART 60 PROVISIONS FOR MODIFICATION AND RECONSTRUCTION
5.1.1  Modification
     It is important that these provisions be fully understood prior to
investigating their applicability.
     Section 60.14 defines modification as follows:
          "Except as provided under paragraphs (d),  (e) and (f) of  this
     section, any physical or operational  changes to an existing facility
     which result in an increase in emission rate to the atmosphere of
     any pollutant to which a standard applies shall be a modification.
     Upon modification, an existing facility shall become an affected
     facility for each pollutant to which a standard applies and for
     which there is an increase in the emission rate."
     The exception in paragraph (d), as interpreted by the Court in the
case of ASARCO vs. EPA in January 1978, is limited by the ruling that any
operational change which results in an increase in emissions from an
individual unit or facility would be considered a modification and would
be subject to NSPS.
     Paragraph (e) lists certain physical or operational changes which
will not be considered as modifications, irrespective of any change in
the emission rate.  These changes include:
     1.   Routine maintenance, repair, and replacement;
     2.   An increase in the production rate not requiring a capital
          expenditure as defined in Section 60.2(bb);
     3.   An increase in the hours of operation;
     4.   Use of an alternative fuel or raw material if, prior to the
          standard, the existing facility were designed to accommodate
          that alternate fuel  or raw material; and
     5.   The addition or use  of any system or device whose primary
          function  is the reduction of air pollutants, except when an
          emission  control system  is removed or  replaced by a system
          considered to be less efficient.
     Paragraph (b)  clarifies what  constitutes an  increase  in emissions in
kilograms per hour  and the methods for determining  the increase, including
the  use of  emission factors, material balances,  continuous monitoring
                                   5-2

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systems, and manual emission tests.   Paragraph (c) affirms that the
addition of an affected facility to a stationary source does not make any
other facility within that source subject to standards of performance.
Paragraph (f) simply provides for superseding any conflicting provisions.
5.1.2  Reconstruction                             '
     Section 60.15 regarding reconstruction states:
        :  "If an owner or operator of an existing facility proposes*to
     replace components, and the fixed capital cost of the new components
     exceeds 50 percent of the fixed capital cost that would be required
   .  to construct a comparable entirely new facility, he shall notify the
     Administrator of the proposed replacements.  The notice must be
     postmarked 60 days (or as soon as practicable) before construction
     of the replacements is commenced .  . .."
     The purpose of this provision is to ensure that an owner or operator
does not perpetuate an existing facility by replacing all but vestigial
components, support structures, frames,  housing, etc., rather than totally
replacing it in order to avoid subjugation to applicable standards of
performance.  As noted, upon request, EPA will determine if the proposed
replacement of an existing facility's components constitutes reconstruction.
5.2  APPLICABILITY TO PERCHLOROETHYLENE DRY CLEANING FACILITIES
     The purpose of this section is to outline some of the most probable
types of "modifications" to existing plants and to describe the applica-
bility of the term "reconstruction" to this industry.
     Typical dry cleaning plant equipment configurations are shown in
Figure 5-1.  These are parallel systems, single systems, and interdependent
systems.  Almost all coin-operated plants are parallel systems.  Most
commercial and industrial plants would be of the single system configuration.
The third configuration, an interdependent system, occasionally occurs in
the industrial and commercial sectors of the industry.  Multiple washers
are used with multiple dryers without having particular dryers necessarily
dedicated to any particular washer.  Because of difference  in solvent
characteristics, however, such a plant would use only one type of solvent.
5.2.1  Modification                             •
     Modification  of an existing facility that would cause  an increase in
emissions  is deemed  unlikely,  however, some possible changes"to the  dryer
                                   5-3

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or dry-to-dry machine could result in an increased emission rate.  For
instance, disabling the damper that prevents perc leaking into the exhaust
during the reclaim cycle could result in increased emissions.   Similarly,
either reducing cooling water flow to the condenser in a reclaiming dryer
or replacing the cooling coils with less efficient coils could increase
the emission rate.  Reducing the drying temperature without increasing
the drying time could also result in an increased emission rate.   Although
these changes could result in increased emission rates, the actual
designation of any such change as a modification would be made on a
case-by-case basis.
5.2.2  Reconstruction
     Replacement of a dryer or dry-to-dry machine constitutes  establishment
of a new facility.  Therefore, reconstruction would consist of major
repairs or modifications which would exceed 50 percent of the  fixed
capital cost of a new dryer or dry-to-dry machine.   However, such changes
are not usually undertaken in this industry.  Although dryers  last about
30 years, the replacement of the dryer drum or condensers coils could
possibly exceed 50 percent of the total cost.  Such reconstructed dryers
would be subject to the standard.
                                  5-5

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               6.  MODEL PLANTS AND REGULATORY ALTERNATIVES

     The purpose of this chapter is to define the model plants and
regulatory alternatives.  Model plants defined in this chapter are para-
metric descriptions of the type of plants that in EPA's judgment will be
constructed, modified, or reconstructed.  Model plant parameters are used
as a basis to estimate the environmental, economic, and energy impacts
associated with the application of the regulatory alternatives defined in
section 6.2 of this chapter.
6.1  MODEL PLANTS
     Model plants have been designated for each of the three industry
categories to facilitate the estimation of control costs for the industry.
For commercial operations, two sizes of plants were costed to show the
range ' " c^sts in that category.  The model plants are specified by their
major characteristics; machine capacity, the number of loads cleaned per
day, cycle time, number of days of operation per year, and the number of
machines per plant.   The model plant parameters chosen for this study are
tabulated in Table 6-1.
6.1.1  Coin-Op
     The  parameters for the model coin-operated dry cleaning plant are
based on information obtained from industry comments and equipment vendors.
An average number of loads per day was calculated from the total receipt,
(County Business Patterns 1976, September 1977) for this section of the
industry, the number of plants (County Business Patterns 1976, September 1977),
the average cost per pound of clothes (Gill, Ward A., 18 January 1979),
the usual machine size, and the actual number of machines per plant
(Gill, Ward A., 2 March 1977).  The cycle time.is taken from equipment
vendors literature (Multimatic Corporation, undated).  Since the equipment
is used by the public, 312 days of operation per year was used.
                                  6-1

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           Table 6-1.  MODEL PLANT PARAMETERS FOR THE
                       PERC DRY CLEANING INDUSTRY

Machine capacity
Cycle time, minutes
Loads per day
Days of operation/
year
Number of machines/
plant

Kilogram clothes/
year (Ibs/yr)
Co in- op
3.6 kg
(8 Ibs)
23
4.0b
312

2


8,986
(19,811)
Commerci al
11 kg
(25 Ibs)
57a
4.9C
250

1


13,475
(29,707)
23 kg
(50 Ibs)
57a
4.9C
250

1 •


28,175
(62,116)
Industrial
113 kg
(250 Ibs)
35
16.6
250

1

•I
468,950
(1,034,000)
aFor dry-to-dry machines, transfer operation can cycle in
 35 minutes.
bFor each of two (2) machines in a plant.
cAverage for transfer and dry-to-dry operations.
                                6-2

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6.1.2  Commercial
     About 25 percent of commercial machines are dry-to-dry type machines
and the remaining 75 percent are transfer machines.  Two machine sizes,
11 kg (25 IDS) and 23 kg (50 Ibs), were chosen to cover the range of
plants in this sector of the industry. The average number of loads (4.9)
was calculated from data on the number of plants and the total throughput.
The cycle time given (57 min) is based on the time needed for good quality
cleaning (Landon, Steve, 25 February 1977) and an average work year of
250 days was assumed.                            •
6.1.3  Industrial
     The average number of loads per day (16.6) for the industrial sector
of the industry was calculated in a manner similar to the other two
sectors of the industry.  Throughput was divided by the number of plants
(County Business Patterns 1976, September 1977) to obtain an average
throughput per plant of 468,950 Kg of clothes per year.  An average
machine size of 250 Ibs was taken from industry comments (Sluizer, Mervyn,
4 May 1977).  An average work year of 250 days per year was. assumed.
6.2  REGULATORY ALTERNATIVES         ,            ,
     The purpose of this section is to define various regulatory
alternatives or possible courses of action EPA could take to abate perc
emissions from dry cleaning operations.  Within each regulatory alternative,
the control technique for each industry category was chosen based on the
appropriateness of the cost of control and the emission reduction potential
for each category.  The base case, no additional regulations, is also
included to show the effects of existing regulations and market forces.
     Table 6-2 presents these control options and specifies the control
techniques to be used for each segment of the industry.  The projected
emissions from each segment of the industry after the application of the
control options, the rationale for their choice, and the derivation of
emissions are given below.
6.2.1  Control Option 1
     This option is technically the highest level of emission control for
the coin-op and commercial industries, no emissions of perc would be
                                  6-3

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CO


6-4

-------
permitted.  Other solvents that would be used are petroleum solvents and
F-113.  For this option, it was assumed that F-113 would be used since
petroleum solvents may be regulated as a VOC in the future while F-113
does not contribute significantly to oxidant formation.  The rapid, low
temperature drying characteristics of F-113, together with its gentle
solvent properties, make it useful for cleaning such delicate items as
leather.  There is some indication that F-113, along with other fluorocar-
bons, may cause depletion of the upper atmospheric ozone layer.   This
reduction in the capacity of the ozone layer to filter ultraviolet rays
from the sun could lead to an increase in the occurence of skin cancer.
However, F-113 currently has the highest Threshold Limit Value (1000 ppm)
of any of the common dry cleaning solvents (indicating lowest health
hazard), which makes it applicable to non-professional operators, such as
coin-operated cleaners.  As a consequence of these principal areas of
use, most fluorocarbon machines are of relatively small capacity.  The
most common size appear to be 5.5 kg (12 Ib) and 11.5 kg (25 Ib).  There
does not appear to be any reason why units could not be built for larger
capacity, but use in certain commercial operations and most industrial
operations has been questioned principally because of the necessity to
remove water soluble soils and larger quantities of grease and oil.  It
is asserted that F-113 and water are incompatible (Lester, R.E.,
24 March 1977).'  For these reasons, F-113 was not chosen as a control
option for the industrial  segment.
     For the industrial sector, carbon adsorption would be required for
all affected facilities.   The carbon adsorber would be required to collect
emissions from dryer or dry-to-dry machines.   The industrial sector would
be required to eliminate all significant leaks of solvent.   Facilities
would be forced to repair or replace malfunctioning equipment.   Industry
sources and EPA tests have,  however, established that a well maintained
plant will control its fugitive emissions to 1  to 2 kg of perc per 100 kg
of clothes cleaned.   This is approximately 25 percent of the projected
emissions from a regulated commercial  or industrial  dry cleaner.   Vapor
leaks would be controlled by inspection and maintenance.
     The industrial sector would be required to reduce the air emissions
associated with their regenerable filter wastes by cooking or treating so
                                  6-5

-------
that these wastes shall not contain more than 25 kg of solvent per 100  kg
of wet waste material.  The residue from a solvent still  shall not contain
more than 60 kg of solvent per 100 kg of wet waste material.   Longer
cooking times for filter muck and longer distillation times for distilla-
tion units should ensure meeting these waste solvent levels.  Any other
filtration or distillation system can be used if equivalency to these
levels is demonstrated.  Any system reducing waste losses below 1 kg
solvent per 100 kg clothes cleaned will be considered equivalent. For a
large industrial operation oil cookers (similar to muck cookers) are
sometimes used.  Solvent losses from distillation bottom disposal can be
reduced in oil 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 (Kleeberg, Charles F., 14 May 1976).
6.2.2  Control Option 2
     For the coin-op  industry, option 2 would require that the plant be
well maintained and well operated,  i.e., good housekeeping.   For  the
commercial and industrial sectors,  carbon adsorption or an equivalent
control technology would be  required for affected facilities  whether they
are dry-to-dry or transfer operations.  The carbon adsorber or an equiva-
lent technology would collect emissions from the  washer and dryer or
dry-to-dry machine.   All industrial and commercial sectors would  be
required to eliminate all significant  leaks of  solvent. Facilities would
be required to repair or replace malfunctioning equipment within  3 working
days or have a purchase order on hand within 3  working days showing the
required  replacement  parts  have been ordered.
     All  industry sectors would be required  to  reduce the  air emissions
associated with  their filter and distillation wastes.  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.  The residue from a solvent  still  shall not contain more  than
60  kg  of  solvent per  100  kg of wet waste material.   Longer cooking times
for filter muck and longer distillation times for distillation units
should ensure meeting these waste solvent levels.  Cartridge  filters  must
 be drained in their filter house  for at least 24 hours before being
 discarded.
                                   6-6

-------
6.2.3  Control Option 3
     This option would require no further control than that being established
by state or local agencies.  At present there are few regulations for
perc dry cleaners, however, carbon adsorbers are being used for economic
reasons, as stated previously.   Also, state agencies with regions of
noncompliance with the National Ambient Air Quality Standard (NAAQS) for
photochemical oxidants may propose regulations based on the Control
Techniques Guideline (CTG) for perc dry cleaners published in December
1978.  Any regulations based on the CTG are due for submission to EPA by
July 1, 1980.  These regulations, if similar to the model regulation in
the CTG, would result in emission reductions similar to those anticipated
for option 2.
6.3  RATIONALE FOR RANKING OF REGULATORY ALTERNATIVES
     The two control options were ranked in order of emission reduction
effectiveness.  Table 6-3 shows the projected emission rates for the
various control options and the percentage reduction for each option.
These projected emission rates were developed based on emission test data
(Kleeberg, Charles F., 17 May 1976) (Kleeberg, Charles F.,  17 March 1976)
(Kleeberg Charles F., 14 May 1976) and industry surveys (Cunniff, Joseph,
3 March 1977).
6.3.1  Development of Emission Rates For Coin-op Plants
     The perc emission rate for option 1 is, of course, zero, as
non-photochemically reactive solvents are required for this option.  The
projected perc emission rate for option 2 is 12 kg/100 kg of articles
cleaned.  This estimate is based on achieving the same reduction from the
baseline emissions as was obtained by the best 20 percent of existing
facilities in an industry report (Cunniff, Joseph, 3 March 1977).
6.3.2  Development of Emission Rates for Commercial Plants
     The perc emission rate for control option 1, requiring the use of a
non-photochemically reactive solvent, is zero.
     Control option 2 has a projected emission rate of 5.0 kg of solvent
per 100 kg of articles cleaned.  This value was developed based on emission
test data (Kleeberg, Charles F., 17 May 1976) (Kleeberg, Charles F.,
17 March 1976).  The carbon adsorber was assumed to be 95 percent efficient
in estimating the overall control.
                                  6-7

-------
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-------
6.3.3  Development of Emission Rates for Industrial Plants
     The projected emission rate for control option 1 is 5.0 kg of solvent
per 100 kg of articles cleaned.  This value was developed based on emission
test data (Kleeberg, Charles F., 14 May 1976).   The carbon adsorber was
assumed to be 95 percent efficient in estimating the overall control.
     Option 2 is the same as option 1.
                                  6-9

-------
                         REFERENCES FOR CHAPTER 6
County Business Patterns,. United States Department of Commerce,.United
     States Bureau of the Census.  Washington, D. C., U.S. Government
     Printing Office, September 1977.

Cunniff, Joseph, Puritan Filters, letter to Kleeberg, Charles F., EPA,
     3 March 1977.  Dow Chemical Survey, Anonymous.

Gill, Ward A., President of the National Automatic  Laundry and Cleaning
     Council, letter to EPA regarding coin-operated dry cleaners, 2 March 1977.

Gill, Ward A., President of the National Automatic  Laundry and Cleaning
     Council, telephone conversation with Dees, Edith, TRW, 18 January 1979.

Jongleux, Robert F., "Perch!oroethylene Emission Testing  at Kleen Korner",
     New York, N.Y., Test Report, TRW, December 1979.

Jongleux, Robert F., "Perch!oroethylene Emission Testing  at Plaza Cleaners,"
     Northvale, N.J., (Draft) TRW, February 1980.

Kleeberg, Charles  F., US EPA, "Material Balance of  Industrial  Perch!oroethylene
     Dry Cleaner",  test report to James F. Durham on test in San Antonio,
     Texas, 14- May 1976.

Kleeberg, Charles  F., US EPA, "Material Balance of  Perchloroethylene  Dry
     Cleaning Unit", test report to James F.  Durham on test in Hershey,
     Pennsylvania,  17 March 1976.

Kleeberg, Charles  F., US EPA. "Material Balance of  a Small Commercial
     Perch!oroethylene Dry Cleaner", test report to James F, Durham on test
     in Kalamazoo,  Michigan, 17 May  1976.

Landon, Steve,  President, Washex Machinery Corp.,  letter  to Mr. John  H. Haines,
     U.S. Environmental Protection Agency, 25 February 1977.

Lester, R. E.,  Dry Cleaning Manager, American Laundry Machinery, letter to
     John Haines,  EPA, 24 March  1977.

Multimatic Corporation brochure  on Multimatic-solo.

Sluizer, Mervyn,  Technical Director, Institute of  Industrial Launderers,
     letter  to  Walsh,  Robert T., U.S.  Environmental Protection Agency,
     4 May 1977.
                                   6-10

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             :             7.   ENVIRONMENTAL  IMPACT       '.-•'..''.'

     The air pollution  impacts  and  other environmental consequences  of
applying the control options  presented  in Chapter 6  are discussed  in this
chapter.  For the purpose of  this analysis, the control options will  be
evaluated in terms of being applied to  the model plants developed  in
Chapter 6.  A comparison will be made between baseline emissions from a
typical plant and controlled  emissions  from plants using the control
options.  The discussion will be based  on the estimate of energy usage
and environmental concerns associated with each system considered.
Specific environmental  impact areas to  be considered include air
pollution, water pollution, solid waste disposal, energy impacts,  and
other impacts as applicable.
     Primary potential  impacts, those attributed directly to the use  of a
control system, will be identified  and  discussed such as air emissions,
water consumption, and energy demand resulting from requiring a carbon
adsorption recovery system.   Secondary  impacts, indirect or induced, will
also be identified and discussed.  An example would be incremental increases
in emissions from a boiler used to  supply additional steam to the adsorber.
7.1  AIR POLLUTION IMPACT
7.1.1  Photochemical Compound Increases
     The baseline and controlled pollutant emission factors shown in
Table 6-3 for the model  plants are based on EPA test data (discussed  in
Chapter 4 and Appendix C) for the industrial and commercial  sectors and
the Dow Chemical Survey (Cunniff, Joseph,  3 March 1977) for the coin-up
sector.   The emission reduction percentages are also shown in Table 6-3.
These reduction percentages  were used in determining controlled emission
levels from the baseline emission levels for each of the industry
categories.   The logic and rationale leading to the selection of the
baseline emission levels can be found in Chapter 3,  Section  3.3.

                                  7-1

-------
     The new sources estimated in Chapter 8 (Section 8.1.5) for each
industry sector were used in calculating the total industry baseline and
controlled emissions.   Industry representatives have supplied total  sales
figures for perc which were three times the values from mass emission
estimates based on average industry statistics.  The variation in values
is accounted for by the use of a range of emission values in estimating
adverse environmental  impacts.  Emission reductions, however, are based
on the lower, more conservative figure.  Therefore, the calculated emission
reduction attributed to this proposed standard is conservative.
     Tables 7-1, 7-2,  and 7-3 show the national emission reduction for
each of the three industry sectors from applying the control options for
the years 1980 through 1989.  These nationwide emission estimates would
be affected by any emission reduction attributable to State or local
regulations.  Revised State Implementation Plans  (SIPs) that may incor-
porate the recommendations in the CTG on perc dry cleaners are due to be
submitted to the Administrator by July 1, 1980.   Not all States are
required to submit SIP revisions, nor are all  regions in each  State
necessarily affected by SIP revisions.  Changes in  baseline perc emissions
caused by the SIP revisions would lower the  emission reduction.  SIP
revisions for controlling perc dry cleaners  will  be required  only from
photochemical oxidant  nonattainment areas that cannot demonstrate compliance
with  the NAAQS  for photochemical oxidants by 1982 without  controlling
perc  dry cleaners.
      From Tables  7-1,  7-2,  and 7-3, it can  be  seen  that control  option  1
 is the  highest  level  of  control, reducing  total perc baseline emissions
 by 7,706 megagrams  in 1984 if imposed in  1980.  This option requires
 nonphotocheraically  reactive solvent equipment  for all  affected facilities
 in the commercial  and coin-op sectors and requires carbon  adsorption,
 housekeeping,  and solid  waste control for the  industrial  sector.
      Control  option 2 is a lower level of control with carbon adsorption,
 housekeeping,  and solid  waste control being required for the commercial
 and industrial  categories and housekeeping with solid waste control being
 required for the coin-op industry.   Option 2 would reduce total perc
 baseline emissions by 4,095 megagrams in 1984 if imposed in 1980.
                                   7-2

-------
Table 7-1.   PROJECTED EMISSION REDUCTION FROM APPLYING
            THE CONTROL OPTIONS TO COIN-OPS
              f(megagrams of perc/year)
Year

1980
1981
1982
1983
1984
1985
1986
1987
1988
1989

1980
1981
1982
1983
1984
1985
1986
1987
1988
1989
Emissions after
Baseline emissions control
Option 1
216
431
647
863
1,078
1,294
1,510
1,725
1,941
2,156
Option 2
216
431
647
863
1,078
1,294
1,510
1,725
1,941
2,156

0
0
0
0
0
0
0
0
0
0

162
323
485
647
808
960
1,132
1,293
1,455
1,616
Emission
reduction

216
431
647
863
1,078
1,294
1,510
1,725
1,941
2,156

54
108
162
216
270
334
378
432
486
540
                           7-3

-------
Table 7-2.  PROJECTED EMISSION REDUCTION FROM APPLYING THE
            CONTROL OPTIONS TO COMMERCIAL DRY CLEANING PLANTS
                 (megagrams of perc/year)
Year

1980
1981
1982
1983
1984
1985
1986
1987
1988
1989

1980
1981
1982
1983
1984
1985
1986
1987
1988
1989
Emissions after
Baseline emissions control
Option 1
1,099
2,210
3,334
4,465
5,605
6,756
7,921
9,093
10,275
11,779
Option 2
1,099
2,210
3,334
4,465
5,605
6,756
7,921
9,093
10,275
11,779

0
0
0
0
0
0
0
0
0
0

549
1,105
1,667
2,232
2,802
3,378
3,960
4,545
5,142
5,743
Emission
reduction

1,099
2,210
3,334
4,465
5,605
6,756
7,921
9,093
10,275
11,779

549
1,105
1,667
2,232
2,802
3,378
3,960
4,545
5,142
5,743
                              7-4

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Table 7-3.  PROJECTED EMISSION REDUCTION FROM APPLYING THE
            CONTROL OPTIONS TO INDUSTRIAL DRY CLEANING PLANTS
              \.  (megagrams of perc/year)

Emissions after
Year Baseline emissions control

1980
1981
1982
1983
1984
1985
1986
1987
1988
1989

1980
1981
1982
1983
1984
1985
1986
1987
1988
1989
Option 1
410
818
1,226
1,636
2,046
2,456
2,861
3,314
3,764
4,214
Option 2
410
818
1,226
1,636
2,046
2,456
2,861
3,314
3,764
4,214

205
409
613
818
1,023
1,228
1,431
1,657
1,882
2,107

205
409
613
818
1,023
1,228
1,431
1,657
1,882
2,107
Emission
reduction

205
409
613
818
1,023
1,228
1,431
1,657
1,882
2,107

205
409
613
818
1,023
1,228
1,431
1,657
1,882
2,107
                             7-5

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7.1.2  Nonphotochemical Compound Increases
     The air quality impact resulting from the imposition of option 1
includes an increase in emissions from use of alternative nonphotochemically
reactive solvents.  At present, this implies the use of F-113.   Though
F-113 is not now considered a precursor to lower atmospheric photochemical
oxidant pollution, there is a possibility that F-113 emissions will be
regulated.  Such regulation could result from the fact that F-113, along
with other f1uorocarbons, may contribute to the depletion of the upper
atmospheric ozone layer.  However, insufficient data are available for
the establishment of standards for F-113 or other dry cleaning solvents.
The increased F-113 emissions resulting from the coin-op and commercial
segments of the perc dry cleaning industry are given in Tables 7-4 and
7-5, respectively.
7.2  WATER POLLUTION IMPACTS
     The only potential water pollutants created by applying carbon
adsorption to perc dry cleaners occur during the desorption of carbon
adsorbers when condensed steam and perc become mixed.  This mixture is
separated into water and perc by a water separator.
     Table 7-6 shows the effluent from perc dry cleaners resulting from
the use of carbon adsorbers.  The number of desorptions/year were calcu-
lated from information in a manufacturer's equipment brochure (VIC Manufac-
turing Co., September 1976) and were varied for each of the different
model plant sizes.  The water condensed from the carbon desorption process
is generally disposed of by sewer.  EPA has analyzed water samples of
this effluent from the separator and has found them to contain less than
100 ppm perc by weight.  The total perc sewered nationally in 1984 as  a
result of the NSPS being imposed in 1980 is expected to be about  1.5 to 4
megagrams and is  expected to increase to about 3 to 9 megagrams by 1989
nationwide.  These figures represent a 15 percent  increase in the total
perc sewered above the amount  of perc sewered without the NSPS.   These
ranges have been  referenced in section 7.1.1.
     Under the Clean Water Act, perc is one of the 65 pollutants  listed
as toxic.  Water  quality criteria levels for the protection of aquatic
life and  human health  in ambient waters have been  established for perc.
To protect fresh  water  aquatic life, a 24-hour concentration  level of
                                   7-6

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              Table 7-4.   INCREASES IN F-113 EMISSIONS FOR
                     -     OPTION 1 FROM THE COIN-OP SEGMENT
Year
  Number of
coin-op units
   New F-113*
   emissions
(megagrams/year)
   Cumulative
 F-113 emissions
(megagrams/year)
1980
1981
1982
1983
1984
1985
1986
1987
1988
1989
300
300
300
300
300
300
300
300
300
300
67
67
67
67
67
67
67
67
67
67
67
134
201
268
335
402
469
536
603
670
Because of the solvent switching requirement of Option 1.  The
increase in F-113 emissions results from modification and/or
reconstruction of existing coin-op facilities.
                                  7-7

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Table 7-5.  INCREASES IN F-113 EMISSIONS FOR
            OPTION 1 FROM THE COMMERCIAL SEGMENT
Year
1980
1981
1982
1983
1984
1985
1986
1987
1988
1989
Number of new
commercial units
641
648
655
659
665
671
678
683
689
695
New F-113
emissions
(megagrams/year)
549
556
562
565
570
576
582
585
597
601
Cumulative
F-113 emissions
(megagrams/year)
549
1,105
1,667
2,232
2,802
3,378
3,960
4, 545
5,142
5,743
                    7-8

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        Table 7-6.   PERCHLOROETHYLENE DRY CLEANING SOLVENT IN
                    EFFLUENT WATER AS A RESULT OF CARBON ADSORPTION
                            (MODEL PLANTS)
Model plants
   Steam
   usage
   kg/yr
  (Ibs/yr)
  Solvent
disposed of
   kg/yr
  (Ibs/yr)
Commercial
         11 kg
         (25 Ib)

         23 kg
         (50 Ib)
Industrial
         113 kg
         (250 Ib)
   2,345
  (5 ,169)

   4,883
 (10,764)
 105,750
(233,139)
   0.2
  (0.5)

   0.5
  (1.1)
  10.5
 (23.3)
Model plant data found in Chapter 6.  Based on Recovery of
Perch!oroethylene.

aSteam Usage:  Commercial and Industrial 70.5 kg (155 Ibs) steam/desorb


[Steam usage from equipment brochure - the original VIC Mileage Booster
 Vapor Adsorption System]
                                  7-9

-------
310 ppb should not be exceeded, while a 700 ppb concentration level
should never be exceeded.  This concentration level should not affect the
dry cleaner using perc, because, although most perc dry cleaners discharge
waste water containing about 100 ppm perc by weight into the sewage
system, by the time this water would reach the receiving waters, it would
be sufficiently diluted so as to meet the 310 ppb level.  The resulting
effect on water quality would be insignificant.
7.3  SOLID WASTE IMPACT
     There is little solid waste associated with the air pollution control
technique, carbon adsorption.  Carbon in adsorbers eventually must be
replaced because of blinding of the bed by small pieces of lint, other
particulate matter, and some organic compounds that are difficult to
desorb.  The carbon can be regenerated, but eventually must be discarded,
about every 15 years.  A carbon adsorber in a typical commercial perc
plant uses around 125 kilograms (275 Ibs) of carbon.  Carbon adsorbers
for industrial perc plants may use up to 450 kilograms  (990 Ibs) of
carbon.  The solid waste impact from the entire industry is estimated to
be about 120 megagrams (132 tons) by 1995.
     The techniques used to reduce emissions from solvent filters and
distillation units do not increase solid waste at all;  they do reduce the
amount of solvent in discarded muck and filters and in  still residue.
The emission reduction from control of filter disposal  is part of the
total emission reduction.
     Under the Solid Waste Disposal Act as amended by the Resource
Conservation and Recovery Act (RCRA) of 1976, perc is listed specifically
as a hazardous waste under the category "halogenated solvent and solvent
recovery still bottoms."  There are no existing Federal regulations  for
the dry cleaning industry specifically concerning solid wastes at this
time; however, facilities producing greater than 1,000  kg of solvent/month
may be regulated by RCRA.  An industrial dry cleaner could be affected by
RCRA.  This act generally states that hazardous wastes  must be controlled
from the time of their generation to the time of their  storage treatment
and or disposal.  The smaller dry cleaning facilities producing less than
                                  7-10

-------
1,000 kg of solvent waste/month would be regulated by a State-approved
solid waste plan.
7.4  ENERGY IMPACT
     Control option I requiring nonphotochemically reactive solvent
equipment for new and modified sources for the coin-op and commercial
industry requires the most electricity, as can be seen in Table.7-7.  No
additional steam would be needed for this option as a carbon adsorber is
not required; therefore, there would be no fuel usage.  Option 2 for the
commercial category and options 1 and 2 for the industrial category would
both have increased fuel and electricity usage for the carbon adsorber.
The fuel and electricity usage values for the model plants found in
Table 7-7 were calculated using the annualized operating cost of steam
and electricity for each of the control options (see section 8.2) along
with $7.28/Mg of steam to obtain fuel usage and $0.0126/MJ to obtain
electricity usage.
                                  7-11

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Table 7-7.  ENERGY IMPACT OF CONTROL
            OPTIONS ON MODEL PLANTS
Plant
Co in- op
3.6 kg (8 Ib)
machine
Commercial
11 kg (25 Ib)
machine
23 kg (50 Ib)
machine
Industrial
113 kg (250 Ib)
machine
Control
option

1
2

1
2
1
2

1
2
Fuel usage
GJ/yr
(MBtu/yr)

	

7 (7)
14 (13)

273 (260)
273 (260)
Electricity
(GJ/yr)

13

5
4
10
5

14
14
                  7-12

-------
                         REFERENCES FOR CHAPTER 7
Cunniff, Joseph, Puritan Filters, letter to Kleeberg, Charles F. , US EPA,
     3 March 1977.   Dow Chemical Survey.  Anonymous.

VIC Manufacturing Co.  Brochure on Mileage Boosters, September 1976.
                                 : 7-13

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                             8.   ECONOMIC  IMPACT

 8.1   INDUSTRY  CHARACTERIZATION
 8.1.1  Introduction
      According to  the  classification  system  of  the  U.S. Department  of
 Commerce,  the  dry  cleaning  industry consists  of the following  three
 Standard Industrial Classification categories:
      SIC 7215   Coin-operated dry cleaners and laundries;
      SIC 7216   Dry cleaning plants, except rug  cleaning;
      SIC 7218   Industrial launderers.
 Because of the nature  of the classification system,  not all firms in
 these SIC  groups are involved in dry  cleaning,  nor  are all the reported
 receipts derived from  dry cleaning operations.  Where possible, indications
 are made as to the extent of dry cleaning involvement of each  sector
 based on Census Bureau data.  These include not only perc dry cleaners,
 but also petroleum and fluorocarbon (F-113) facilities.  In addition,
 industry sources have provided estimates of similar  information.
 8.1.2  The Three Sectors:   The Present Situation
     8.1.2.1   Coin-Op Sector.  A coin-operated laundry facility generally
 has a number of coin-op washing machines and dryers.  These facilities
 are typically  located in urban areas and are patronized by apartment
 dwellers and others who do not have immediate access to washing machines
 and dryers.
     Census data tend to understate figures for the coin-op sector because
of the "50 percent" rule.   This rule causes a business to be classified
 in a particular SIC code based on the source of 50 percent or more of its
revenues.   Many coin-ops are part of commercial  dry cleaners or other
types of businesses and as a result do not appear in SIC 7215.
                                  8-1

-------
     The Census of Manufacturers reported on 31 642 total  coin-op
establishments in 1972 and on 17,550 with payroll  (Census  of Selected
Services, 1972).  In 1976, County Business Patterns, another Census
document, showed 11,804 establishments with payroll (County Business
Patterns, 1976).  An industry spokesman states that the actual number of
coin-op facilities is currently around 40,000, disregarding the 50 percent
rule and any payroll distinction (Gill, Ward, 18 January 1979).
     Estimates of total receipts for the sector show a similar variance,
but are consistent when expressed on a per-establishment basis.  The
Census shows receipts for all establishments in 1972 to be $878.641 million
($28,000+ per establishment) and for those with payroll to be $673.361
million ($38,000+ per establishment) (Census of Selected Services, 1972).
The industry source states that total annual receipts are currently $1.5
billion or $37,500 per establishment (Gill, Ward, 18 January 1979).  The
first observation that can be made from these figures is that establish-
ments with payroll tend to be larger operations than those without payroll,
as would be expected.  It also seems evident that average receipts of all
establishments  have increased between 1972 and the  present.  According to
the industry source, this increase is due both to inflation and to an
increase in the volume of clothes washed or cleaned in coin-op facilities
(Gill, Ward, 18 January 1979).
     The disparity between the number of total coin-op establishments and
those with payroll shows that many are run by one person or a family.
Even those establishments with payroll most frequently have only one
employee (see Table 8-1).  Coin-ops are predominantly single-unit
establishments, though store chains do exist  (Table 8-1).
     Census data  show that 18.8 percent of coin-op  receipts in 1972 were
from dry cleaning (Census of Selected Services, 1972).  For coin-operated
laundries and dry cleaning stores,  laundry  (store)  work receipts are
$420.895 million  and dry  cleaning  (store) work receipts are $96.819
million.  The  industry spokesman puts that  number at 25 percent, but
because  of the  distorting effect of the 50 percent  rule,  it is probably
incorrect to  assume that  the actual percentage has  increased  between 1972
and  the  present (Gill, Ward, 18 January 1979).  The industry  source
                                   8-2

-------
        Table  8-1.    STATISTICAL  PROFILE  OF  COIN-OP  DRY
                  CLEANERS  AND  LAUNDRIES  (SIC  7215),  19723
           RECEIPTS SIZE OF ESTABLISHMENTS
                                                                    EMPLOYMENT SIZE OF ESTABLISHMENTS
     ESTABLISHMENTS. TOTAL
                      ?'
ESTABLISHMENTS OPERATED ENTIRE YEAR, TOTAL	
  ESTABLISHMENTS MITH PAYROLL. TOTAL	
   WITH ANNUAL RECEIPTS OF — $1.000.000 OR MORE  ..
                           $500,000 to $999,000.
                           $300,000 to $499,000.
                           $100.000 to $299,000.
                           $50.000 to $99.000  ..
                           $30.000 to $49.000  ..
                           $20.000 to $29,000  ..
                           $10.000 to $19,000  ..
                           LESS THAN $10,000 ...
  ESTABLISHMENTS WITHOUT PAYROLL. TOTAL 	
   WITH ANNUAL RECEIPTS OF — $50,000 or MORE 	
                           $20.000 to $49,000
                           $5.000 to $19,000 ...
                           LESS THAN $5,000 ....

ESTABLISHMENTS NOT OPERATED ENTIRE YEAR. TOTAL *J	
  IN BUSINESS AT END OF YEA#	
  NOT IN BUStlESS AT END OF YEAR	
31,642
28,697
16,161
   25
   30
   46
   561
 1,891
 3.627
 3,321
 4,691
 1,969

12.536
   263
 2,699
 7,454
 2,120

 2,945
 2,945
 3,386
                                                               ESTABLISHMENTS, TOTAI?	.'	   31.6ซ
                                                          ESTABLISHMENTS OPERATED ENTIRE YEAR. TOTAL
                                                            WITH NO PAID EMPLOYEES	
                                                            WITH PAID EMPLOYEES 	
                                                              NO EMPLOYEES 	
                                                              1  EMPLOYEE 	
                                                              2  EMPLOYEES :	
                                                              3  EMPLOYEES 	
                                                              4  or 5 EMPLOYEES 	
                                                              6  or 7 EMPLOYEES 	
                                                              8  or 9 EMPLOYEES 	
                                                              10 to 14 EMPLOYEES	
                                                              15 to 19 EMPLOYEES 	
                                                              20 to 49 EMPLOYEES 	
                                                              50 to 99 EMPLOYEES 	
                                                              100 EMPLOYEES or MORE	
                                                          ESTABLISHMENTS NOT OPERArEO ENTIRE YEAR. TOTAL
                                                            IS BUSINESS AT END OF YEARC.	
                                                              NOT IN BUSINESS AT END OF YEAR	„
28,697
12,536
16.161
  995
 6,284
 3,413
 2,191
 1,906.
  699
  261
  '249
   71
   80
   10
    2

 2,945.
 2.945
 3,336
           SINGLE UNITS AND MULTI-UNITS

TOTAL". 	
FIRMS IN BUSINESS AT END OF YEAR 	 	
SINGLE UNITS. TOTAL 	
OPERArEO BY 1 -ESTABLISHMENT FIRMS 	
WITH NO PAID EMPLOYEES 	
WITH PAID EMPLOYEES 	
OPERATED BY MULTIESTA8LISHHENT FIRMS . .
HULTIUNITS, TOTAL 	
2-ESTA3LI5HMEHT MULTIUNITS 	
3-ESTABLISHNENT MULTIUNITS 	
4-or 5-ESrASLISHMENTMULTIUHlrS 	
6-to 10-ESTA3LISHME.fr MULTIUHITS 	
11-or-More-ESTA8LISHMฃNT HULTIUNITS ...
FIRMS NOT IN BUSINESS AT END OF YEAR. TOTAL
Firms

28,249

26.09Z
14 092
12,000
617
1 540
811
380
245
79
25
3.056
Emblotimwm

31 642

26,092
14 092
12 000
617

1 140
1 068
572
531
3,259
                                                                       LEGAL FORM OF ORGANIZATION

TOTAL . 	 ป 	
INDIVIDUAL PROPRIETORSHIPS 	 	
PARTNERSHIPS 	
CORPORATIONS 	 ..... 	 	
OTHER OR LEGAL FORM UNKNOWN

Alt
Eitjfelih-
31 ,642
18,607
3,815
5.968
3,252

tซtปfe'iป*HTปTป.
With PryroT
., -17,550
" 6,752
2 341
5 M6
3 041 "

aU.S. Department of  Commerce,  Census of  Selected Services, 1972. U.S.  Government Printing Office.
  Washington, D.  C.   1976.    •
DIn business at year end.
Businesses opened during the  year and remained open at  year end.
                                                 8-3

-------
estimates that of the 40,000 facilities counted by his organization,
15,000 to 18,000 have dry cleaning machines (Gill, Ward, 18 January 1979).
     The typical coin-op store that offers dry cleaning has two or three
dry cleaning machines, though some have as many as eight (Gill, Ward,
January 1979).  Of total revenue in such an establishment, 35 percent
typically comes from dry cleaning machines (Gill, Ward, 18 January 1979).
The average revenue for a coin-op dry cleaning machine is $1.10/kg ($0.50/lb)
of clothes with $0.22 ($0.10/lb) of that amount representing pretax
profit (Gill, Ward, 18 January 1979).  Most machines have a 3.6 kg (8 Ib)
capacity (Gill, Ward, 18 January 1979).  Solvent use in coin-op dry
cleaning machines is heavily weighted towards perchloroethylene (perc),
with F-113 being used in only 2.5 percent of all establishments (Gill,
Ward, 18 January 1979).
     8.1.1.2  The Commercial Sector.  The commercial sector consists of
dry cleaning plants that primarily clean clothes for retail consumers.
The plant may be located on the premises of a store where customers bring
their clothes or at a remote location to which a number of stores may
send clothes.
     As in the coin-op sector, estimates of the number of establishments
and the amount of receipts vary, though not as widely.  In 1972, the
Census Bureau reported on 28,422 establishments with payroll and put
total receipts at $1,759 million.  This indicates an average per-plant
revenue of about $62,000 (Census of Selected Services, 1972).  In 1976,
County Business Patterns counted 19,953 establishments with payroll
(County Business Patterns, 1976).  An industry spokesman says there are
presently 25,000 plants with total receipts of $1,773 million (Fisher,
William, 19 January 1979).  These numbers yield a per-plant revenue
figure of $69,000.  The same source estimates that 85 to 90 percent of
total revenues arise from dry cleaning operations, whereas the 1972
Census put the ratio at 83 percent (Fisher, William, 19 January 1979).
Again, the differences in government and industry estimates suggest that
they have different methods of measurement, rather than indicating any
sort of trend.
     Along with higher revenues per plant than in the coin-op sector,
commercial establishments employ more people; in 1972, they most
frequently had four or five employees (see Table 8-2).
                                  8-4

-------
    Table 8-2.    STATISTICAL  PROFILE OF  DRY CLEANING  PLANTS,
                  EXCEPT  RUG  CLEANING  (SIC 7216),  19723
      RECEIPTS SIZE Of ESTABLISHMENTS WITH PAYROLL
      ESTABLISHMENTS. TOTAL0
  ESTABLISHMENTS OPERATED ENTIRE YEAR. TOTAL 	
   WITH ANNUAL RECEIPTS OF — $],000,000 or WIRE...
                        $500.000. to $399,000
                        4300,000 to 5499,000
                        $100,000 to $299,000
                        $50,000 to $99,000
                        $30,000 to $49,000
                        $20,000 to $29,000
                        $10,000 to $19,000
                        LESS THAN $10.000

  ESTABLISHMENTS SOT OPERATED ENTIRE YEAR, TOTAlb	
   IN BUSINESS AT ENO OF YEAR6	
   NOT IN BUSINESS AT END OF YEAR 	
28.422

27,006
   37
   119
   269
 3.121
 7,459
 6,ฃ36
 4i042
1 3,784
 1,539

 1,416
 1.416
 1.812
       SINGLE ONI TS AND MULTI-UN ITS WITH PAYROLL

TOTAL''... 	
FIR.1S IN BUSINESS AT END OF YEAR 	 ..
SINGLE UNITS, TOTAL 	 ,
1.,'EHATED BY 1-ESTA81ISHMENT FIRMS 	
WITH MO PAID EMPLOYEES
WITH PAID EMPLOYEES 	 	
OPERATED BY MULTIESTABLISHMENT FIRMS .
Huiriuxirs, TOTAL
2-ESTABLISHMENT HULTIUNITS 	
3-ESrAOtliHMENT MULTIUNITS 	
4- or 5-E5rABUSHHENT MULT1UNITS 	
6- to 10-ESTABLlSKMENT HUITIUNITS 	
11-or-MORE-ESTADLISHMENT HULTIUNITS ..
FIRMS NOT IN BUSINESS AT END OF YEAR. TOTAL
Firiro


24 315
23.593
?3 593
723
848
247
148
67
28
1.531
EMabluItrnwih)


24*316
23.593 '
23 593
723
1 696

637
484
543
1.731
                                                           EMPLOYMENT SIZE OF ESTABLISHMENTS WITH PAYROLL
ESTABLISHMENTS, TOTALH, 	
ESTABLISHMENTS OPERATED- ENTIRE YEAR TOTAL 	
WITH SO PAID EMPLOYEES 	 	
WITH PAID EMPLOYEES 	 	 	
NO EMPLOYEES 	 	 ..... , 	
1 EMPLOYEE 	 	 	 	 	
2 EMPLOYEES 	 	 .. 	
3 EMPLOYEES 	 	 	 ;
4 or 5 EMPLOYEES 	 	 	
6 or 7 EMPLOYEES 	 .' 	
B or 9 EMPLOYEES . 	 	 	 ..
' 10 to 14 EMPLOYEES 	 	 	
15 to 19 fMPLOYEES 	 	 	 	 	 '
20 to 49 EMPLOYEES .. . ... 	 .' 	 	
50 to 99 EMPLOYEES 	 	
100 EMPLOYEES OR HORE 	 	 ; 	
ESTABLISHMENTS NOT OPERATED ENTIRE YEAR, TOTAL*5 	
IN BUSINESS AT ENO OF YEAR 	 	 	 	
NOT IN BUSINESS AT ENO OF YEAR 	 	






•1.475.









1,416
1,116
1*812

                                                                 LEGAL FORM OF ORGANIZATION
                                                                (ESTABLISHMENTSWITH PAYROLL)
TOTAL k... „...,...., 	 ,._".., 	 .„_. .
INDIVIDUAL PROPRIETORSHIPS 	 	 	 	
PARTNERSH IPS 	 ; 	
CORPORATIONS 	 , 	 	 	 	 	 	 	
OTHฃft C3 LEGAL FORM UNKNOWN . 	

EftaMbtimanu
- "28,432
10 613
2 861
9.936


aU.S. Department of Commerce, Census of  Selected Services, 1972, U.S. Government Printing Office,
 Washington, D.  C.
bln business at  year  end.
Businesses opened  during  the year  and remained open at year end.
                                             8-5

-------
     The average revenue for commercial dry cleaning plants is $2.91/kg
($1.32/lb) (Faig, Ken, October 1979).   The pretax, preowner's-salary
profit averages 21.3 percent with 18.1 percent being the average owner's
salary.  This leaves 3.2 percent profit.  This profit margin varies,
according to the base price and plant efficiency, from 0 to about 6 per-
cent.
     The types of solvent used in dry cleaning establishments break down
as follows:  73 percent perc, 24 percent petroleum, and 3 percent F-113
(Fisher, William, 19 January 1979).
     8.1.1.3  Industrial Sector.  The industrial sector of the laundry
business supplies laundered uniforms, wiping towels, etc. to industrial
or commercial users.  The laundry may or may not own the uniforms and
other materials that it cleans.  SIC code 7218 makes no distinction
between operations that have their own  laundry and dry cleaning equipment
and those that do not.
     Census data for 1972, summarized  in Table 8-3, show that there are
many times fewer establishments in the  industrial sector (1 020 with
payroll) than in either of the other two.  These are, in general, larger
operations, with annual receipts most often over $1 million and with 20
to 49 employees.  There is more of a tendency for one company to own
several plants in this sector.  Most of the businesses are incorporated.
     For 1972, Census data show that 50 percent of industrial launderers
with payroll had dry cleaning equipment (Census of Selected Services,
1972).  An industry spokesman, however, estimated that currently only 40
to 45 percent of industrial launderers  in the trade association have dry
cleaning capability (Dees, E., 7 May 1979).  The  involvement of these
businesses with dry cleaning  is limited, even though they  have equipment;
a member survey of the Institute of Industrial Launderers  indicated that
of the total throughput handled by industrial launderers with dry cleaning
equipment, only about 15 to 19 percent  is dry cleaned (Dees, E., 7 May 1979).
This amount is represented in large part by "better" uniforms, such as
those worn by airline employees, which  must be dry cleaned.  In addition,
some types of industrial soil are removed more effectively by dry cleaning;
In general, the majority of the work done by industrial launderers continues
to be  laundry (Dees,  E., 7 May 1979).
                                  8-6

-------
                   Table  8-3.   STATISTICAL  PROFILE  OF
                INDUSTRIAL  LAUNDERERS  (SIC  7218),  1972a
      RECEIPTS SIZE OF ESTABLISHMENTS WITH PAYROLL
                                                          EMPLOYMENT SIZE OF ESTABLISHMENTS WITH PAYROLL
     ESTABUSHMEHTS. TOTALS
 ESTABLISHMENTS OPERATED ENTIRE YEAR, TOTAL  .
  WITH ANNUAL RECEIPTS OF — $1,000,000 OR MORE .'.
                        $500.000 to S999.000.
                        $300,000 to $499,000
                        $100,000 to $299,000
                        $50.000 to $99.000
                        $30,000 to $49,000
                        $20.000 Co $29,000
                        $10,000 to $19.000
                        LESS THAN $10,000 .

 ESTABLISHMENTS NOT OPERATED ENTIRE YEAR, TOTAL
  IN BUSINESS AT END OF YEAR1-.	
  NOT IN BUSINESS AT END OF YEAR	'.'..'.
1.020

 974
 238
 225
 111
 204
  94
  42
  25
  18
  17
  46
  46
  30
      SINGLE UNITS AND MULTI-UNITS WITH PAYROLL

TOTALb 	 	 	

SIimtE UNITS, TOTAL 	
OPERATED BY 1-ESTA8LISHMENT FIRMS 	
WITH NO PAID EMPLOYEES 	
WITH PAID EWLOfEES 	
OPERATED BY HULTIESTABLISHMENT FIRMS ..
HULTIUMITS, TOTAL 	
2-E$rABUSHME:iT HULTIUNITS 	
3-ESTABLISHMENT HULTIUNITS 	
4-or 5-ฃSiy>LIShME.1T HULTIUNITS . ...
6-to 10-ESTSlLISHMENT WLTIUNITS 	
ll-or-KORฃ-ESTA8LISH'!E:)T HULTIUNITS ...
FIRMS NOr IN BUSINESS AT END OF YEAR, TOTAL
Fhm>


612
532
532
80
83
34
33
12
17
7
: 23
Eซt*MMtnMnra



532

80



124
126
23
ESTABLISHMENTS, TOTAL'1. 	
ESTABLISHMENTS OPERATED ENTIRE YEAR, TOTAL 	 '..
WITH NO PAID EMPLOYEES 	
WITH PAID EMPLOYEES ....; 	
NO EMPLOYEES 	
1 EMPLOYEE 	
2 EMPLOYEES 	
3 EMPLOYEES 	
4 o 5 EMPLOYEES 	
60 7 EMPLOYEES 	
8 0 9 EMPLOYEES 	 	 ;;.
10 0 14 EMPLOYEES 	
15 0 19 EMPLOYEES 	
20 to 49 EMPLOYEES 	
50 to 99 EMPLOYEES 	
100 EMPLOYEES OR KORE 	
ESTABLISHMENTS NOT OPERATED ENTIRE YEAR, TOTAL . 	
IN BUSINESS AT END OF YEAR- 	
NOT IN BUSINESS AT END OF YEAR 	

1,020
974

• 974
10
41

35
52
45
38
' 81
55
260
188
129
46
46
30-

LEGAL FORM OF ORGANIZATION
(ESTABLISHMENTS WITH PAYROLL)
TOTAL k. 	 mrm* 	 ffff
INDIVIDUAL PROPRIETORSHIPS ...'... 	 .,"... ~~
PARTNERSHIPS . 	
CORPORATIONS 	
-0!HฃR OR tEGAt FORM UNKNOWN 	

ฃ*tปbtlซhimซnir
1 020
80

80S
78

          ntmDntC0f fg;gerce'  Census  of Selected  Services.  1972. U.S. -tovsrnnent Printing Office,

bln business *t year end.
Businesses opened during  the  year and  remained open at year end.
                                            8-7

-------
     The revenue per kilogram for dry cleaning in this sector ranges from
$0.90 to $6.60 ($0.40 to $3.00 per pound), with the average falling
around $1.50 to $2.00 ($0.70 to $0.90 per pound) (Dees, Edie, 7 May 1979).
8.1.3  Industry Trends
     8.1.3.1  Coin-Op Sector.   The historical trend in number of
establishments for the coin-op sector shows that this industry is quite
volatile.  Year-to-year changes are between minus four and minus nine
percent during the years shown in Figure 8-1 plotted from Table 8-4.
This figure also shows that the number of establishments seems to shrink
and expand with general economic conditions.  Thus, the number of establish-
ments increased between 1967 and 1972, decreased during the recession of
1973 to 1975, and then increased again as the economy recovered in 1976.
     The vulnerability of the sector to the rest of the economy, at least
in terms of number of establishments, can be explained on several bases.
First, the fixed investment required to enter the business is small.  It
can range between $35,000 and $100,000 depending on the number of machines
in the facility (Gill, Ward, 26 April 1979).  Moreover, during a period
of expansion, private investment increases.  Combined with ease of entry,
this factor accounts to some extent for the correlation between number of
coin-ops and the strength of the economy.
     The second controlling factor is the tendency for coin-ops to be
largely one-unit, individually owned businesses, as shown in Table 8-1.
Multi-unit ownership tends to engender a  greater commitment to a business
on the part of owners because more money  is tied up in fixed assets
(Atha, Lou, 29 May 1979).  In addition, operating  losses may be localized
in one or two of several outlets, so that the profitable facilities can
carry the losers temporarily  (Atha, Lou,  29 May 1979).  This broader base
allows operating losses to be endured for longer periods of time than  in
the case of a single-unit operation (Atha,  Lou, 29 May 1979).
     For a single-unit business, the situation may be  quite different.
Losses cannot be spread among other units.  As a result, negative  cash
flows cannot be tolerated for as long (Atha,  Lou,  29 May 1979).  The same
low investment that  facilitated entry into  the business may  tend to
encourage exits in the event  of prolonged operating losses (Atha,  Lou,
                                   8-8

-------













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19
18 -
                                                                 m
                                                                 o
                                                                 m
                                                                 m
                                                                 O
                                                                 en
                                                                 o
                                                                 V)
  1967   1968  1969   1970   1971   1972   1973   1974   1975   1976
   SOURCE: SEE TABLE 8-4.
Figure 8-1.  Trends  in  number of establishments and employees
    for SIC 7215  (coin  operated laundries and dry cleaners).
                               8-10

-------
29 May 1979).  Therefore, the single-unit dominated coin-op sector tends
to show a decrease in establishments when the economy slumps.
     8.1.3.2  The Commercial Sector.  Table 8-4, plotted in Figure 8-2,
shows that the number.of establishments and of employees has been falling
since 1967.  The drop shows some indication of slowing by 1976.  The
trend can be explained partly by the use of larger capacity dry cleaning
machines.  Also, the years depicted cover a period during which washable
synthetic fabrics were popular.
     The demand for dry cleaning services, whether coin-op or commercial,
depends on a number of factors.   First, because dry cleaning is more a
luxury or convenience than a necessity, demand for it will be affected by
general economic conditions.  When incomes or purchasing power declines,
consumers will hand wash where possible and dry clean less often.  In
addition, it is generally the more expensive garments that require dry
cleaning, and fewer of these are sold in bad times.
     Clothing styles also affect demand for dry cleaning.  During the
past several years, a resurgence of natural fabrics such as wool, silk,
and fine cottons has occurred.  Even "designer" blue jeans are being dry
cleaned to prevent fading and shrinkage.  This trend is expected to
increase dry cleaning demand in both the coin-op and commercial sectors
(Gill, Ward, 26 April 1979) (Fisher, William, 26 April 1979).
     The likelihood of consumers switching from commercial dry cleaning
to less expensive coin-op dry cleaning during a recession is difficult to
assess on a historical basis.  The recession of the early 1970's coin-
cided with the popularity of washable synthetic fabrics.  As a result,
dry cleaning revenues dropped in both sectors because of both factors.
The effect of a recession alone cannot be measured.  There is no evidence
to suggest whether switching would result should a recession occur while
natural fiber fabrics were prevalent.  Industry sources in both sectors
indicate, however, that it is their impression that such switching is
unlikely (Gill, Ward, 26 April 1979) (Fisher, William, 26 April 1979).
     Because both the economy and fashions are difficult to predict, no
definitive growth rate can be attached to the commercial sector.  It is
relatively safe to assume that there will be no dramatic surge in number
of establishments, employees or total receipts in the next 5 to 10 years.
                                  8-11

-------
                                                          - 300
 1967  1968   1969   1970   1971   1972   1973  1974   1975   1976
   SOURCE: SEE TABLE 8-4.
                             l
Figure 8-2.  Trends  in  number of establishments and employees
   for SIC 7216  (dry cleaning plants, except rug cleaners)..
                               8-12

-------
     The consumer price index, a guide for determining relative prices
based on a fixed reference price, reflects the rising cost of dry cleaning
services.  Shown below is the consumer price index, referenced to the
1967 dollar, for "dry cleaning, suits and dresses" from 1973 through
1977.
     1973
     122.0
 TABLE 8-5,
1974
135.9
  CONSUMER PRICE INDEX
    1975           1976
    150.6
(1967 =100)
160.6
1977
171.0
Source:  U.S. Industrial Outlook, 1978. U.S. Department of Commerce,
         Washington, D. C., U.S. Government Printing Office, 1978,
         p. 461.
     8.1.3.3  The Industrial Sector..  The historical trends in the industrial
sector show less dramatic changes than the other sectors.  Total establish-
ments have decreased overall between 1967 and 1976 (Figure 8-3), but
annual changes in their number have never exceeded 5 percent and have
averaged around 2 percent.  This relative sluggishness is explained in
part by the large initial investment required for the plant, the equipment,
and, often, for the stock of uniforms, towels, or whatever else is being
supplied.  Again, the economy affects  this part of the laundry industry.
If expenses must be cut, a business that has previously had its uniforms
professionally laundered may have employees wash the uniforms themselves.
Alternatively the business may discontinue use of uniforms.
     Recent trends in the sector include moves toward increased multi-plant
ownership by single corporations.  The industry has also felt competition
from the commercial sector as some commercial businesses have expanded
into industrial-type operations (Dees, E., 7 May 1979).
     In the future, trends in the sector will probably occur slowly and
remain small in magnitude.  Any growth in receipts or number of
establishments will be minimal.
                                  8-13

-------
I
111
5
I
to
_j
CD



Ul
1400
1300
1200
1100
1000
 900
 800
 700
 600
           EMPLOYEES
' ESTABLISHMENTS
          J	L
I      I	L
                                    1
                                                               70
                                                               60
                                                               50
                                                               40
                                                               30
                                                               20
                                                               10
                                                                   m
                                     O

                                     m
                                     m
                                     en



                                     O

                                     in
   1967   1968  1969   1970  1971   1972   1973   1974   1975  1976
     SOURCE: SEE TABLE 8-4.
Figure 8-3.   Trends in number of establishments  and employees

             for SIC 7218  (industrial launderers).
                                8-14

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     8.1.3.4  Geographic Trends.   For the most part, geographic trends in
the number of establishments in each sector mirror nationwide trends.
Tables 8-6, 8-7, and 8-8 show figures for 1967, 1972, and 1976..
     In the coin-op sector, compounded growth rates between 1972 and 1976
for various regions range between -8.4 percent and -12.4 percent.   The
same figure for the nation is -9.9 percent.
     In the commercial sector, compounded growth rates between 1972 and
1976 range between -7.3 percent and -10.7 percent, and the national
figure is -8.8 percent.
     The industrial sector shows slower shrinkage, with most divisions
experiencing growth for the same years as above in the range of -3.0 percent.
The East South Central division actually gained two establishments whereas,
the Mountain division showed a less than normal compounded growth of
-9.1 percent.
8.1.4  Effect of Standard on Perch!oroethylene Manufacturers
     It is conceivable that the cost of meeting a standard on the use of
perc could cause some dry cleaners to switch to another solvent.  One
result would be reduced perc sales.
     Table 8-9  lists the eight perc manufacturers and their perc
capabilities and shows the value of dry cleaning  industry perc sales as a
percentage of total sales.  These results  indicate that perc used for dry
cleaning could  represent no more than 3.4  percent of any company's sales,
assuming its entire perc production was used for  dry cleaning purposes.
A drop in  sales of perc would not be expected  to  impair any one company's
performance appreciably.
8.1.5  Estimated New Sources for Each Industry Category
     All new sources for the years 1977-1985 for  the unregulated dry
cleaning industry are  estimated in Tables  8-10, 8-11, and 8-12.  Though
there are  conflicting  data on the growth rates for  each segment of the
industry,  there does appear to be a small  growth  trend in the commercial
and  industrial  sectors of  the industry based on recent equipment manufac-
turers data  (Quarterly Machinery Market Report, 30  September 1978).
These data show an  increase of about 12 percent per year  in the number of
dry  cleaning machines  being manufactured over  the period  1974-1978.  For
                                  8-15

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Table 8-6.  COIN-OPERATED DRY CLEANERS AND LAUNDRIES, SIC 7215
            REGIONAL TRENDS FOR NUMBER OF ESTABLISHMENTS
Region3
UNITED STATES
New England
Middle Atlantic
East North Central
West North Central
South Atlantic
East South Central
West South Central
Mountai n
Pacific
aU.S. Census Regions
bSource: 1972 Census of
1967b
15 ,981
717
2,559
3,606
1,449
2,445
1,091
2,052
653
1,409

Selected Services,
1972b
17,550
782
2,554
3,981
1,488
2,998
1,412
2,130
797
1,408

U.S. Department of
1976C
11,804
558
1,625
2,774
910
2,054
899
1,413
699
962


Commerce, Bureau of the Census
ฐSource: County Business
Patterns, 1976, U.
S. Department of

  Commerce
                             8-16

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Table 8-7.   DRY CLEANING PLANTS EXCEPT RUG CLEANING, SIC 7216
            REGIONAL TRENDS FOR NUMBER OF ESTABLISHMENTS
Region9
UNITED STATES
New England
Middle Atlantic
East North Central ,
West North Central
South Atlantic
East South Central
West South Central
Mountain
Pacific
aU.S. Census Regions
Source: 1972 Census of
1967b
30,625
1,621
6,188
5,195
2,347
4,779
2,163
3,908
1,140
3,285

Selected Services, U.
Commerce, Bureau of the Census
ฐSource: County Business
Patterns, 1976, U.S.
1972b
28,422
1,525
5,625
4,924
2,074
4,715
1,977
3,218
1,097
3,267

S. Department of
Department of
1976C
19, 953
1,092
3,848
3,426
1,348
3,481
1,370
2, 204
820
2,326



 Commerce
                            8-17

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             Table 8-8.   INDUSTRIAL LAUNDERERS, SIC 7218 REGIONAL
                         TRENDS FOR NUMBER OF ESTABLISHMENTS
      Region1
19671
1972L
19761
UNITED STATES
New England
Middle Atlantic
East North Central
West North Central
South Atlantic
East South Central
West South Central
Mountain
Pacific
918
58
167
197
64
128
61
101
32
110
1,020
54
154
196
73
156
73
122
49
143
913
69
133
181
64
148
75
107
34
124
 U.S. Census Regions

 Source:  1972 Census of Selected Services, U.S. Department of
          Commerce, Bureau of the Census

ฐSource:  County Business Patterns, 1976, U.S. Department of
          Commerce
                                     8-18

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       Table 8-9.  RATIO OF MARKET VALUE OF PERCHLOROETHYLENE PRODUCTION
                   TO TOTAL SALES IN 1977 FOR PERC-PRODUCING COMPANIES
Plant Market value
capacity of perc sold
1976 for.dry clean-
ing
(Gigagrams/yr) (million $)
Diamond Shamrock
Corp.
Dow Chemical, USA
E.I. duPont de
Nemours & Co. , Inc.
Ethyl Corp.
Occidental Petroleum
Corp.
PPG Industries, Inc.
Stauffer Chemical Co.
Vulcan Materials Co.
90
131
72
23
18
90
32
90
17.29
25.16
13.83
4.42
3.46
17.29
6.15
17.29
Total sales
1977C
(million $)
1530.4
6234. 3
9434.8
1282.1
6017.5
2505.8
1232.8
510.6
Value of
perc pro-
duction as
a % of total
sales
1.13
0.40
0.15
0.34
0.06
0.69
0.50
3.39
Stanford Research Institute, 1977, Director of Chemical Producers,
 Menlo Park, CA.   1978.

 This column derived as  follows:

 Plant capacity x percent capacity utilization x percent of perc
 production used for dry cleaning x market value of perc.   Capacity
 utilization assumed to  be 80 percent.   Ratio of perc produced for
 dry cleaning to total perc production = 65 percent, based on 145.8
 thousand megagrams dry  cleaning per sales (Shame!, R.  E., J. K.  O'Neill,
 and R.  Williams, 1975)  (Chemical & Engineering News, June 12, 1978,
 p.  49).   Market value of perc assumed to be $0.49 per kg.

 From published company  records.
                                    8-19

-------
             Table 8-10.   ESTIMATED NEW SOURCES IN THE UNREGULATED
                          PERCHLOROETHYLENE COIN-OP DRYCLEANING  INDUSTRY
 Year     Total  plants3    Total  machines'3     Replacements0    All  new sources'
1974
1975
1976
1977
1978
1979
1980
1981
1982
1983
1984
1985
1986
1987
1988
1989
1990
a!974-1976
13,558
12,358
11,804
11,804
11,804
11,804
11,804
11,804
11,804
11,804
11,804
11,804
11,804
11,804
11,804
11,804
11,804
data from
27,116
24,716
23,608
23,608
23,608
23,608
23,608
23,608
23,608
23,608
23,608
23,608
23,608
23,608
23,608
23,608
23,608
County Business Patterns,
1,355
1,235
300
300
300
. 300
300
300
300
300
300
300
300
300
300
300
300
U.S. Dept.
1,355
1, 235
300
300
300
300
300
300
300
300
300
300
300
300
300
300
300
of Commerce.
 No growth projected for this industry sector

 2 machines/plant.

Estimates from R. R. Street, 1 November 1979 (Young, Dexter, 1 November 1979).

dAll new sources include machines from growth and replacement, and are
 assumed to be "affected facilities" as defined in Chapter 5.
                                     8-20

-------
            Table 8-11.   ESTIMATED NEW SOURCES IN THE UNREGULATED
                         COMMERCIAL PERCHLOROETHYLENE DRY CLEANING INDUSTRY
Year
1974
1975
1976
1977
1978
1979
1980
1981
1982
1983
1984
1985
1986
1987
1988
1989
1990
Total plants3 R^|
15,634
14,437
13,911
14,792
14,925
15 ,060
15,195
15,332
15,471
15,610
15,750
15,891
16,035
16,179
16,324
16,470
16,619
a!974-1976 data from County
^chines8* AT1 new sourcesc 
-------
          Table 8-12.  ESTIMATED NEW SOURCES IN THE UNREGULATED
                       PERCHLOROETHYLENE INDUSTRIAL DRYCLEANING INDUSTRY
Year
1974
1975
1976
1977
1978
1979
1980
1981
1982
1983
1984
1985
1986
1987
1988
1989
1990
a!974-1976
Total plants3
237
233
233
235
237
239
241
243
, 245
247
249
251
253
256
258
260
262
data from County
Replacement
machines
8
8
8
8
8
8
8
8
8
8
8
8
8
9
9
9
9
Business Patterns, U.S.
All new sources0
8
8
8
10
10
10
10
10
10
10
10
10
10
11
11
11
11
Department of Commerce.
 1974-1976 years averaged - 234 (base number).   1977-1985 data based on
 0.9% growth from base number.  A 0.9% growth is the expected population
 growth according to the Argonne National Laboratory report prepared for
 EPA-450/3-78-019.

Economic life of plant = 30 years.
 100% depreciation in 30 years.
 Replacement rate = 100%/30 = 3.33%

ฐA11 new sources include machines from growth and replacement and are
 assumed to be "affected facilities" as defined in Chapter 5.
                                  8-22

-------
this analysis, an overall growth rate of 0.9 percent was assumed for
commercial and industrial dry cleaners.   Coin-op dry cleaners were assumed
to have a zero growth rate.  A replacement rate of 300 units per year was
used, based on industry data (Young, Dexter, 1 November 1979).  A replace-
ment rate for the commercial and industrial sectors of 3:.3 percent was
assumed using an economic plant life of 30 years with 100 percent deprecia-
tion after 30 years.  The growth rate was assumed based on the Argonne
National Laboratory report (Monarch, M.  R. et al., April 1978).  The
heading "All new sources" in Tables 8-10, 8-11, and 8-12 includes machines
from both growth and replacement.   It will be assumed that "all new
sources" are subject to the NSPS as described in Chapter 5.
8.2  COST ANALYSIS OF CONTROL OPTIONS
8.2.1  Introduction
     The estimated costs of applying the control techniques specified for
each industry category for each control  option have been developed and
are given in this section.  These costs are based on the model plant
parameters given in Chapter 6 and include both capital expenses and
annualized costs.  Section 8.2.2 gives the estimated costs for new affected
facilities and section 8.2.3 gives the costs for modified or reconstructed
facilities.                                                     ;
     In developing these costs for the model plants, cost data on the
equipment specified were obtained from equipment vendors or manufacturers
and were combined with estimates of installation costs from the same
sources to obtain the estimates of capital expenditures for each control
option.  Note that these capital costs are in fourth quarter 1978 dollars
and should be adjusted for inflation when necessary.
     Annualized costs are composed of amortized capital costs and operated
costs.  The amortization of capital costs is accounted for by using a
capital recovery factor of 17.15 percent.  This factor was computed by
using an interest rate of 10 percent for the 15-year life of the equipment
with an additional 4 percent added for taxes, insurance, and administration
costs.  For higher interest rates, the capital recovery factors would
vary (e.g., at 12 percent interest, it would be 18.68 percent, and, at
15 percent interest, it would be 21.10 percent).  Capital costs include
                                  8-23

-------
the costs of control equipment and its installation.  Operating cost for
the controlled model plants have been estimated from data obtained from
the equipment vendors and/or manufacturers.  These costs include the cost
of electricity, maintenance of the control system, and the cost of steam.
Estimates of the unit cost for electricity, steam, and operating labor
were taken as $0.0126/106 J, $7.30/1000 kg ($3.30/1000 Ibs) and $8.00/hour,
respectively.  Maintenance costs were estimated by equipment vendors
(Hansen, Lyle, 5 December 1978).
     In addition to these costs, the use of carbon adsorbers also produces
a credit for solvent recovered.  Credit for recovered solvent is deducted
from the annualized costs at the rate of $0.50/kg ($3.00/gal).
8.2.2  New Facilities
     8.2.2.1  Coin-Operated Dry Cleaners.  For coin-operated dry cleaners,
option 1 would essentially require the use of a nonphotochemically reactive
solvent.  At present, this means that F-113 machines would have to be
used instead of perc machines.
     Costs for this option were developed  as follows.
     Equipment vendors were contacted for  costs of  F-113 machines that
could be used instead of the model coin-operated perc operation
(McHonagle,  Ray, 20 August 1979) (Davis, Durwood, 19 August 1979).  Since
machines in  the 3.5-kg size are not available, a 5.4-kg/load machine was
costed.
     Though  two 5.4-kg F-113 machines have a higher throughput capability
than the 3.6-kg perc machines, two machines will  still be  used, since,
for these customer-operated machines, availability  will be as important
as capacity.  The  costs given  in Table 8-13 show  the additional costs
that would be  incurred by a plant owner  purchasing  and using two F-113
dry cleaning machines versus two perc machines.
     Under control  option 2, coin-operated dry cleaners would not be
required to  install any additional equipment.  Only proper solid waste
treatment and good operating and maintenance practices would  have to be
followed for this  option.   No  incremental  costs for housekeeping controls
have been developed since these costs are apparently negligible.
     Although not  a control option for perc coin-op dry cleaners, carbon
adsorption was  also costed  to  establish  any economic advantage  to that
                                   8-24

-------
     Table 8-13.  COST OF CONTROL TECHNOLOGY COIN-OPERATED, OPTION 1
                    (1000's of fourth quarter 1978 $)
                                        3.6 kg perc
                5.4 kg F-113
Capital cost
Cost of two dry cleaning machines
Installation cost

Annualized cost
Capital Recovery
Operating Costs:
  Steam
8.9
0.2
9.1
1.56
27.4
 0.2
27.6
 4.73
Electricity
Maintenance
Labor5
Solvent0
Net Annual ize'd Cost
Difference in Cost for F-113 Machines
0.05
0.05
1. 00
0.53
3.2

0.23
0.05
1.00
0.91
6.9
3.7
aBased on the model plant throughout with 4.1 MJ load for 3.6 kg perc
 machines and 7.2 MJ for 5.4 kg F-113 machines.
 Estimated.
 Extra cost of F-113 solvent versus baseline perc usage rate.
                               8-25

-------
type of control.   From the following analysis,  it was concluded that this
control technique was not economically feasible for this industry category.
However, to ensure completeness, this analysis is included here as a
reference.
     First, using manufacturer's literature (VIC Brochure, "Mileage
Boosters," December 1978), a carbon adsorber was chosen for minimum
capital cost commensurate with the requirements for controlling emissions.
Since these carbon adsorbers must be desorbed with steam, a boiler of
sufficient capacity was also included in the capital costs (Blythe, Bob,
5 December 1978).  The requirements for steam and cooling water were
taken from the manufacturer's brochure (VIC Brochure, "Mileage Booster",
December 1978) though the cost of the cooling water requirements was
considered negligible.  Table 8-14 gives the individual costs for this
application of carbon adsorption.  Note that labor costs are taken as
2 hours per desorb cycle (i.e., once per 5 days).  Through the desorb
should take only about one hour, the boiler at such an  installation would
not normally be in operation, therefore, an extra hour  is needed to allow
for boiler start-up and shut-down.
     The net annualized cost of control is about $2,100 per year.  For
the model plant the annual profit, at $0.22 per kg ($0.10/lb), is less
than $2,000 per year.  Therefore, this control technique is not considered
feasible.
     Another possible approach to applying carbon adsorption to coin-ops
is the use of off-site regeneration of the carbon in the adsorber.
Canisters containing carbon are presently available for odor control
applications that could possibly be used at coin-operated facilities.
This would eliminate the requirement for a boiler at coin-operated
facilities thereby reducing the capital costs of control.  However,
additional annual costs would be incurred for pick-up and delivery of
canisters to be regenerated.  The actual desorption of  the carbon would
be more expensive than on-site regeneration, since the  canisters would
have to be opened, the carbon removed, desorbed, then the carbon would
have to be replaced and the canisters resealed before reuse.  At present,
few facilities for the desorption of carbon in bulk are available; hence,
                                  8-26

-------
   Table 8-14.  COST OF CONTROL TECHNOLOGY EVALUATION
                OF APPLYING CARBON ADSORPTION TO COIN-OPS
            (1000's of fourth quarter 1978 $)
Capital costs
Carbon Adsorber
Carbon Adsorber Installation
Boiler and Oil Tanks
Installation
Total Capital Costs
 2.5
 0.4
 3.4
 0.3
 6.6
Annualized costs
Capital Recovery
Operating Costs:
     Steam
     Electricity
     Maintenance
     Labor
Annualized Costs
Credit for Recovered Solvent
Net Annualized Costs
 1.13

 0.03
 0.02
 0.05
 1.17
 2.40
(0.31)
 2.1
                          8-27

-------
actual costs are not known.  However, at least one manufacturer (Manzone,
21 December 1978) believes that a dry cleaner would find economic advantage
in installing a boiler for on-site desorption and supplying additional
services made possible by the availability of steam.   Because of these
considerations, off-site regeneration will not be considered further.
     8.2.2.2  Commercial Dry Cleaners.  Two control options have been
considered for the commercial segment of the dry cleaning industry.
Option 1 would require the use of nonphotochemically reactive solvents
for dry cleaning while option 2 would require the use of a carbon adsorber
on all perc operations in this industry category.
     Capital costs for the dry cleaning machines themselves are available
from vendors and manufacturers.  However, to provide an accurate comparison
of model plant capital costs, the equipment costs must be adjusted to a
common production capability for each model plant.  For instance, an
F-113 machine of a given load capacity would have a higher production
capability than a perc dry-to-dry unit of the same capacity because of
the F-113 machine's shorter cycle time.  Similarly, a perc transfer
system of the same load capacity would have a higher production capability
than either the F-113 or the perc dry-to-dry machine since the separate
transfer machines can be used simultaneously for washing and drying.  Due
to these differences in production capability and to the fact that costs
for each type of machine were not available in the load capacities specified
for the model plants, adjustments to these costs were necessary to develop
the model plant costs for the control options considered.
     These adjustments to the capital cost of the dry cleaning equipment
were obtained by normalizing the capital cost of each type of equipment
to the capital cost of a perc transfer operation.  Perc transfer equipment
was chosen as the basis for these adjustments since it represents the
lowest cost-per-unit production capability.
     The comparisons between these capital costs, then, is based on the
cost of equivalent production capability.  In practice, this adjustment
of capital cost can be made by using  the  following equation:
Adjusted Capital Cost = Actual Capital Cost x
                                                          MacMneapacity
                                                                           x
                                   8-28

-------
                            Actual Cycle Time
                         Perc Transfer Cycle Time                   .
     As an example of the use of this equation, consider the costs for an
11-kg dry-to-dry machine.  From Table 8-15, the actual cost of an 11-kg
dry-to-dry machine is approximately $17,000, and, from Table 6-1, the
cycle time of commercial dry-to-dry machines is 57 minutes and for commercial
transfer systems is 35 minutes.  Using the above equation, the adjusted
capital cost of the 11 kg, dry-to-dry perc system is found as follows:

     Adjusted Capital Cost = $17,000 JH^ x 'H mi!nu^es                    ,
                                '    11 kg   35 minutes
                          .= $28,000 (to the nearest thousand dollars),
     Use of the above equation gives adjusted costs for the individual
types of equipment.  However, to establish a cost for the perc machines
in a representative model plant, an average of the adjusted capital costs
for the dry-to-dry and transfer systems is needed.  The approach used
here is to weight the costs according to the percentage of the industry .
category now serviced by each type of equipment.  The weighted average,
then, is 25 percent of the cost of dry-to-dry equipment ($28,000) from
the above calculation plus 75 percent of the cost of the transfer system
($19,000 from Table 8-15 for 11 kg transfer).
     These adjusted model plant capital costs are listed in Table 8-16.
Estimates of capital costs for the carbon adsorber were taken from contacts
with vendors and equipment manufacturers (Hansen, Lyle, 5 December 1978).
     The annualized costs for these two control options are composed of
the capital recovery and the operating costs.   Capital recovery is a
percentage of the capital costs for the system plus control equipment
taken as 17.15 percent from the combination of 10 percent interest on a
loan over the 15-year life of the equipment plus 4 percent for taxes,
administration, and insurance.
     Operating costs are the costs for operation and maintenance of the
control system only.  Steam is required for carbon adsorbers to desorb
captured perc and thus is not required for option 1 or for the uncontrolled
system.  Electricity costs for option 1 are the costs of extra electricity
                                  8-29

-------
  Table 8-15.  APPROXIMATE CAPITAL COSTS OF
               DRY CLEANING MACHINES
Type of machine
Approximate costs
(1000's of fourth
 quarter 1978 $)
11 kg transfer
11 kg dry-to-dry
23 kg transfer
23 kg dry-to-dry
14 kg F-113
        19
        17
        21
        24
        17
                     8-30

-------
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8-31

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usage by F-113 equipment compared to the average of perc dry-to-dry and
transfer operations processing the amount of clothes given in the model
plant parameters (Table 6-1).  Maintenance estimates were extrapolated
from estimates obtained from equipment vendors (Blythe, Bob, 5 December 1978).
Labor costs were estimated as requiring 0.2 hours for each desorb.  The
time allotted for each desorb for this industry category is less than
that required for the coin-op category since the boiler would normally be
in operation and the operator would not have to give his entire attention
to the desorb operation.  Cooling water for the condenser on carbon
adsorbers would also be an operating cost, however; in this case the cost
is considered negligible.
     In addition to the cost of operation, carbon adsorbers also produce
an operating credit for solvent recovered during the desorption process.
For these estimates, an average of 5 kg of perc is assumed to be recovered
for each 100 kg of clothes processed, based on plant test data summarized
in Table 3-1.
     8.2.2.3  Industrial Dry Cleaners.  Options 1 and 2 would apply the
same regulations on the industrial category.  Therefore, for both options 1
and 2, the cost data is given in Table 8-17.  As can be seen in that
table, the value of the recovered perc exceeds the cost of the carbon
absorber system by a substantial margin.  These cost numbers are based on
recovering 8.1 kg of perc for each 100 kg of clothes processed as was the
case in an EPA test of an industrial dry cleaner (Kleeberg, C. F.,
17 March 1976).  For the model plant, this amount of recovered solvent
would require six desorbs of carbon canisters having a maximum of 4
gallons of perc in each.  The required labor is 0.2 hours per desorb at
$8.00 per hour, since boiler operations are normally required for the dry
cleaning plant, and the desorb cycle would require only minimal additional
attention from the operator.
8.2.3  Modifications and Reconstructions
     8.2.3.1  Introduction.  Since regulations promulgated for new sources
also affect sources that are modified or reconstructed, this section
describes the costs of control for sources covered by these provisions of
the regulations.  Assumptions used in developing the annualized costs for
the-sources are the same as  for new facilities described in section 8.2.1.
                                  8-32

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   Table 8-17.  COST OF CONTROL TECHNOLOGY INDUSTRIAL
                       (1000's of $)
Capital Costs
Carbon Adsorber
Installation
Total Capital Costs
 11.1.
  0.6
 11.7
Annualized Costs
Capital Recovery
Operating Costs:
     Steam
     Electricity
     Maintenance
     Labor
  2.0

  0.77
  0.18
  0.10
  2.40
Annual Costs
Credit for Recovered Solvent
Net Annual Cost (Profit)
  5.5
(18.6)
(13.1)
                          8-33

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     Note that modfications and reconstruction do not exist for the
coin-op segment of the industry because each dry cleaning machine can
only be a separate system.  Thus, additional dryers or larger individual
components cannot be used.
     8.2.3.2  Modifications.  The modifications described in Chapter 5
have been costed in the same manner as for new sources.  Under option 1,
no modifications, as defined in Chapter 5, are possible due to the required
change in solvent.  Under option 2,, two possibilities were discussed.
Those modifications are costed as follows.
     Adding a dryer to an existing dry-to-dry operation was the first
type of modification discussed, and the cost for controlling that type of
modification to a commercial plant is given in Table 8-18.  Note that
these costs are the same  as for new commercial facilities with the excep-
tion of a slight additional cost for installation to account for retrofit
expenses.
     Though these annualized costs of control are similar to the costs of
control for new facilities, the capital costs of the new dry cleaning
equipment used to modify  an existing facility is, of course, much less
than the cost of an entirely new dry cleaning plant.   For instance,  in
this case the capital cost  of  a  new dryer would be  in  the range  of $3,000
to  $4,500.  The cost of the carbon adsorber at $4,100  then would nearly
double the capital  expenditure required for this type  of modification.
Capital costs of  control  of new  facilities, on the  other hand,  represent
less than 10 percent of the capital cost  of a new plant.
     Similarly, for the industrial segment  of the  industry, Table 8-19
shows  the additional expense of  controlling an  industrial plant modified
to  use a dryer with a dry-to-dry machine.   The capital  cost of the .equip-
ment used to modify the facility,  a 113 kg  (250  Ib) dryer, would be  in
the vicinity of $40,000 (TRW,  7  May 1976).  Therefore,  capital  expenditures
for controlling a modified facility in this industry category  are not as
great  a  percentage  of the capital  cost of modifying the facility as  was
the case  for the  commercial category.
     Another possible modification to  existing plants  could occur if an
existing washer  or  dryer  were  replaced with a larger model.  The estimated
                                   8-34

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        Table 8-18.  CONTROL COSTS FOR MODIFYING COMMERCIAL
                     PERC DRY CLEANER
                 (1000's of fourth quarter 1978 $)
                                      11 kg (25 lb)  23 kg (50 lb>
Capital costs
Cost of Carbon Adsorber plus
  •Installation
Total Capital Cost
 4.1
 4.1
 4.1
 4.1
AnnuaTized costs
Capital Recovery
Operating Costs:
     Steam
     Electricity
     Maintenance
     Labor

Gross Annualized Cost
Credit for Recovered Solvent
Net Annualized Cost
 0.7

 0.02
 0.07
 0.08
 0.06

 0.9
(0.32)
(0.6 )
 0.7

 0.04
 0.07
 0.08
 0.12

 1.0
(0.64)
(0.4 )
                               8-35

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   Table 8-19.   CONTROL COSTS FOR MODIFYING INDUSTRIAL
                PERC DRY CLEANERS
                      (1000's of $)
Capital costs
Carbon Adsorber
Installation
Total Capital Cost

Annualized costs
Capital Recovery
Operating Costs:
     Steam
     Electricity
     Labor
     Maintenance
Gross Annualized Cost
Credit for Recovered Solvent
Net  Annualized  Cost
 11.1
  0.7
 ll.'S
  2.0

  0.77
  0.18
  2.40
  0.10
  5.5
(18.6)
(13.1)
                          8-36

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costs for this type of modification are similar to the previous example
for adding a dryer to an existing dry-to-dry installation (see Tables 8-18
and 8-19).  This estimate is based on the fact that both installations
would be transfer operations and, due to retrofit considerations,
installation costs are expected to be slightly greater than for a new
installation.
    .8.2.3.3  Reconstructions.  Cost for reconstruction under option 1
for the coin-op and commercial categories cannot be calculated because
under this option reconstruction as a perc system is not allowed.  Recon-
struction of these plants would require the conversion to non-photochemi-
cally reactive solvent usage which would then be considered a new plant.
These costs are then the same for similar new sources and are given in
Table 8-16 for commercial facilities.   For the industrial category under
option 1, the cost of control for a reconstructed plant will be similar
to the costs for a modified facility as given in Table 8-19.
     Reconstruction of coin-ops under option 2 does not apply to any
additional costs since this option requires only improved housekeeping
procedures.   For the commercial and industrial categories, two types of
reconstruction were identified in Chapter 5; they were the replacement of
a dry-to-dry machine without replacing peripheral equipment and the
replacement of a sufficient quantity of equipment in a transfer operation
to exceed the 50" percent of capital cost requirement in the definition of
reconstruction.
     The cost of control for reconstructions will be similar to the costs
given for modifications in Table 8-18 for commercial facilities and in
Table 8-19 for industrial facilities.   Since the capital costs of the dry
cleaning equipment being replaced at a reconstructed facility must, by
definition,  exceed 50 percent of the capital cost of an equivalent new
facility, the capital burden for a reconstructed facility will be at
worst only twice the capital burden for a new facility.
8.2.4  Cost Effectiveness of Controls
     The cost effectiveness of the controls specified for each industry
category under each control option has been calculated to show the cost
per unit of emission reduction.  These cost effectiveness numbers were
                                  8-37

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obtained by dividing the cost of control by the emission reduction obtained.
For option 1 in coin-op and commercial facilities, the emission reduction
was the total baseline emissions since option 1 required the use of a
non-photochemically reactive solvent.  Cost effectiveness for options
requiring the use of a carbon adsorber was calculated by dividing the
cost of control by the emission reduction from baseline.
     In general, the cost effectiveness for option 2 shows that the costs
for operating a carbon adsorber decrease as production capacity increases.
Industrial dry cleaners actually show a profit from the use of carbon
adsorbers (option 1 and option 2 are the same for industrial dry cleaners).
Profits are generated by the credit for reclaimed solvent at the usual
cost of $0.50/kg of perc ($3.00/gal), in dollars per unit of emission
reduction.  Table 8-20 shows the cost effectiveness for the control
options given for perc dry cleaning.
     Option 1 for the coin-op and commercial categories shows that the
costs for coin-op and large commercial  facilities are almost the same,
while the small commercial facilities show a profit from applying control.
Greater costs are incurred for the large commercial facility in this case
due to the use of two F-113 machines  instead of one perc machine.  For
the smaller commercial facility, only one F-113 machine was necessary to
maintain the production of the perc equipment.  Thus, the economies of
scale that would be expected in going from a small to a large commercial
facility do not apply.
     The 1984 cost effectiveness for  each control option can be calculated
by dividing the 1984 annualized cost  resulting from regulation found in
section 8.2.5 by the emission reduction for 1984  found  in Table 7-1.  The
cost effectiveness for option 1 and option 2 is $933 per unit of emission
reduction and $192 per unit of emission reduction, respectively.
8.2.5  Total Cost of Controls
     The total cost of the control alternatives is presented in Table 8-21.
This provides an estimate of the additional capital burden  imposed on new
plants from 1980 to 1984.  (Total capital costs are found by multiplying
the number of new plants by the capital cost per  plant  for  each sector.)
Annualized cost totals represent those  payments incurred in the fifth
                                   8-38

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       Table 8-20.  COST (PROFIT) EFFECTIVENESS OF CONTROLS
                    FOR THE PERCHLOROETHYLENE DRY CLEANING INDUSTRY
                  ($ per unit emission reduction)
                               Option 1
                          megagram      ton
                                       Option 2
                                   megagram  ..,  ton
Coin-op
Commercial

Industrial
11 kg
23 kg
2,570
  445
1,420
 (321)
2,331
  404
1,288
579
138
                          (291)   (321)
 525
 125
(291)
                               8-39

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   Table 8-21.  AGGREGATE COSTS OF CONTROLS ON DRY CLEANING INDUSTRY
               Costs (Profits) in 1000's of 1978 Dollars


Total no. of model
plants
No. of model plants
with control
baseline case
No. of model plants
incurring costs as
result of standard
Total capital costs
resulting from
regulation
1984 Annual ized Cost
resulting from
regulation
Total no& of model
plants
No. of model plants
with control
baseline case
No. of model plants
incurring costs as
result of standard
Total capital costs
resulting from
regulation
1984 Annual ized Cost
resulting from
regulation
Coin-op Commercial Industrial
11 kg 23 kg
Option 1
750 2,451 817 50
0 0 0 25
750 2,451 817 25
13,875 (2,451) 11,438 293
2,775 1,471 3,268 (328)
Option 2
750 2,451 817 50
0 858 286 25
750 1,593 531 25
0 4,779 2,124 293
0 956 159 (328)
Total

4,068
25
4,043
23, 155
7,186
4,068
1,169
2,899
7,196
787
 Cumulative number of plants 1980-1984.
 Incremental capital expense imposed on all  plants 1980-1984 as
-result of controls.
                               8-40

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year, 1984.  Pre-tax annualized costs are used here to reflect the total
cost to the economy.
     In calculating the total costs associated with option 2 for commercial,
and options 1 and 2 for industrial plants, it was assumed that under
baseline conditions 35 percent of the commercial and 50 percent of the
industrial plants would use controls.  Thus, the incremental cost is
applied only to the remaining 65 percent and 50 percent of the expected
plants that would normally use the carbon adsorber.
     In the coin-op sector, the sale of 1,500 new machines is expected
between 1980 and 1984.   With two machines per plant, this represents 750
new plants.  The 1984 annualized cost is about $2.7 million.  Option 2
imposes no additional capital or annualized costs.
     In the commercial  sector, 2,451 plants of 11 kg capacity and 817
plants of 23 kg capacity are expected between 1980 and 1984.  With option 1,
the 11 kg machine group incurs a total capital savings of $2.4 million,
while the 23 kg machine group incurs a total capital cost of $11.4 million.
This option creates an incremental capital cost of $9.0 million to the
commercial sector.  The 1984 annualized cost of option 1 is $3.2 million
for the 23 kg group, plus $1.5 million for the 11 kg group, or about $4.7
million total cost for the commercial sector.
     With option 2, capital costs increase by $4.8 million for the 11 kg
group, and $2.1'mi 11 ion for the 23 kg group, giving a total capital cost
of $6.9 million for the commercial sector.  This is less expensive than
option 1.   The 1984 annualized costs for option 2 increased $1.0 million
for the 11 kg group and $0.2 million for the 23 kg group, resulting in a
1984 annualized cost increase of $1.2 million for the commercial sector.
Again, this is less than the $4.7 million annualized cost imposed by
option 1 during that period.
     Option 1 and option 2 impose the same costs on the industrial sector.
The incremental capital cost of these controls totals $0.3 million.  The
annualized savings, due to solvent recovery credits, would total $0.3
million for 1984.
     In summary, option 1 imposes a total capital cost of $23.2 million
on the dry cleaning industry between 1980 and 1984.  The 1984 annualized
                                  8-41

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costs (which include capital recovery) are $7.2 million.  This is clearly
belov/ the regulatory action criterion of $100 million in the first five
years.
     With option 2, total, industry costs are somewhat lower.  Total
capital costs are $7.2 million and 1984 annuzlied costs are $0.8 million.
8.3  OTHER COST CONSIDERATIONS
     In this section, three things are discussed:  the  costs currently
imposed on the perch!oroethylene dry cleaning industry  to satisfy other
regulatory requirements, the impact of new source standards promulgation
on state and local  regulatory and enforcement agencies, and the costs for
compliance testing  if a concentration type standard  had been chosen.
     In December 1978, a Control Techniques Guideline Document on Control
of Volatile Organic Emissions from Perchloroethylene Dry Cleaning Systems
was  issued by EPA.  This document provides information  to state and  local
air  pollution control agencies on reasonable available, control technology
(RACT) that can be  applied  to existing perchloroethylene 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.  Control techniques guidelines would mainly be used by
states in those areas where National  Ambient Air  Quality Standards  (NAAQS)
are  not being attained.  Some State solvent emission regulations covering
dry  cleaning plants are based on the  Los Angeles  AQMD  Rule 442,  "Usage  of
Solvents" (formerly Rule 66), or on the control  of  hydrocarbons  alone.
Under this type of  regulation, perc is an  exempt  solvent since  it was  not
considered to be photochemically reactive; therefore,  there are  few
emission  limitations.  Hence, existing State  solvent emission  regulations
create only  a minimal  impact  for perc dry  cleaning  establishments.
      Also affecting these  nationwide  emissions  estimates would  be  any
emission  reduction  attributable  to  State  or  local regulations.   Revised
State Implementation  Plans  (SIP) that may  incorporate  the  recommendations
 in the CT6  on perc  dry  cleaners  are due  to be  submitted to  the  Administrator
 by July 1,  1980.   Not all  States are  required  to  submit SIP  revisions,
 nor are  all  regions in  each State  necessarily  affected by  SIP  revisions.
                                   8-42

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Changes in baseline perc emissions due to the SIP revisions would lower
the emission reduction attributable to the New Source Performance Standard,
thereby, apparently reducing the necessity for the New Source Performance
Standard.   However, this CTG for perc dry cleaners would be required only
in those areas with a population of 200,000 or more that cannot achieve
the National Ambient Air Quality Standard (NAAQS) for photochemical
oxidants by 1987.  Therefore, no alteration to baseline emissions due to
State regulations has been made.
     Perc plants have little potential for causing water pollution, and
are currently under no water pollution control guidelines.
     Similarly, there are relatively small amounts of solid waste resulting
from the dry cleaning process so disposal costs are minimal.  Therefore,
no significant cost impacts would be expected from either water quality
or solid waste regulations.
     The principle controls currently being imposed on perc plants are
the Occupational Safety and Health Administration (OSHA) restrictions for
solvent vapors in the working environment.  The allowable time-weighted
average (TWA) perc levels in working areas are as follows:
     •    100 ppm - 8 hour TWA
     •    200 ppm - Ceiling (may be exceeded only once every 3 hours for
          no more than 5 minutes)
     •    300 ppm - Peak; never to be exceeded.
     Solvent emission controls for perc dry cleaning establishments
already exist to a large extent.  This emission control has developed out
of economic necessity rather than environmental regulation.  Perchloro-
ethylene is an expensive solvent, and its recovery is necessary for the
most economical operation.  It is for this reason that reclaiming dryers
are used on most perc machines.  Also many perc systems are equipped with
carbon adsorbers.  Carbon adsorbers are now being utilized by about
35 percent of the commercial systems and 50 percent of the industrial
systems.  Carbon adsorbers are not considered feasible for use in coin-op
systems because usually there is no boiler on the premises to supply the
steam necessary to desorb the carbon bed.
     The burden of enforcement for new source standard falls on State and
local agencies.  States must adopt regulations for the pollutant and
                                  8-43

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secure EPA approval of an enforcement plan.  The ongoing responsibilities
of State and local agencies include permit issuance and compliance verifi-
cation for new sources.  The agencies must also periodically provide
reports on the compliance status of new sources and on legal matters
pertaining to them.
     Many costs would be incurred on a dry cleaner if a dryer exhaust
concentration standard, rather than an equipment standard, were chosen.
In order to ascertain compliance with such a concentration limit, an
initial performance test to determine the dryer exhaust concentration
would be required costing $2,000-$4,000.  The concentration standard was
not chosen because of the high cost of this initial performance test.
     No recordkeeping of solvent mileage will be required by the draft
standard since the manpower cost for enforcing such a recordkeeping
system is too high.  This would also not be in the spirit of regulatory
reforms, and mileage records alone do not indicate compliance with a
requirement to install a carbon adsorber.
8.4  ECONOMIC IMPACT
8.4.1  Introduction
     The economic effect of the two alternative control options will be
discussed in the following sections.  The primary aim of these discussions
will be to show the effect of perchloroethylene controls on plant
profitability, capital requirements, and return on investment (ROI)  in
order to evaluate whether new perchloroethylene plants would be pre-empted
from entering the industry.
     Section 8.4.2 provides supplemental industry profile data and model
plant financial characteristics which are derived primarily from industry
sources and Bureau of the Census data.  Section 8.4.3 describes the
economic impacts of controls on the four model plants.  This section
addresses both new and modified/reconstructed plants.  Capital availability
issues are described in section 8.4.3.2.  Effects of controls on profita-
bility and ROI are explored in sections 8.4.3.3.  Finally,  section 8.4.3.4
provides an estimate of the changes in  industry growth which would result
from the controls.
                                  8-44

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      The analysis is centered on the characteristics of the four model
 plants.   Although these model plants are representative of the industry
 and serve to reflect the typical condition of new plants,  it is important
 to recognize that variation does occur.   Prices may vary regionally and
 capital  investment can be reduced in some cases by using old equipment.
 Thus,  some plants would have more favorable economics than shown here,
 while  some would have greater constraints.   While limitations of the data
 prevent  the estimation of the distribution of real  conditions,  it is
 important to remember that a variety of  conditions  do occur.   The figures
 presented here  are thought to be representative,  but an individual  investor
 could  find substantially different conditions.
     The data presented here are based on figures reported by Bureau of
 the Census,  dry cleaning associations, and IRS  publications.   Since  not
 all  figures  are reported on the  same basis,  there was some inconsistency.
 The most current and reliable source of  data was  used wherever  possible.
     This  study does not attempt to estimate the  amount of solvent switching
 which  might  result from the standards.   The  cost  analysis  and economic
 analysis present only the effects  on perch!oroethylene plants.   At the
 present  time, regulatory requirements associated  with controlling emissions
 in  plants  utilizing  the petroleum  solvent process are minimal.   It may be
 that in  response to  regulation of  perc plants,  new  cleaners will select
 an  alternative  solvent.   This may  be economically advantageous  as long as
 there  is minimum control  required  for petroleum plants, but fire code
 regulations would  prevent substantial switching.  However, it is likely
 that new petroleum plants  will be  regulated with a  new source performance
 standard in the  future.   Thus, the  economic advantage  of switching is
 uncertain  since  the  control  costs of alternative solvents  have  not been
 estimated.  This study  does  not attempt to project  the possibility of
 solvent  switching  from perc  to petroleum.
     The primary focus  of  this analysis is the effect of controls on
profitability and  return on  investment.   Changes in these parameters due
 to control requirements were evaluated to determine the influence of the
 controls on growth in the various industry sectors.   Costs of controls
 are assumed to remain constant in constant dollars.   It is possible that
                                  8-45

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solvent costs will actually rise more rapidly than inflation.   Thus,  the
economic impacts of the carbon adsorber options (commercial, option 2;
industrial, options 1 and 2) may be slightly overstated since rising
solvent recovery credits may reduce actual control costs.  This is not
thought to have a substantial affect on the conclusions of this analysis.
8.4.2  Supplemental Industry Profile Data
     8.4.2.1  Model Plant Economics.  Table 8-22 provides a summary of
the pertinent financial characteristics of the model plants considered in
this study.  Dry cleaning plant capital, total annual revenues and dry
cleaning revenues, total plant profit and dry cleaning profit, and profit
margins before and after taxes are  shown.  These figures are derived from
various sources including Census data, industry sources, and earlier
studies of the dry cleaning  industry.  The derivation of specific data
elements is described  in the following text.
     8.4.2.1.1  Tax structure.  In  the following analysis the tax structure
utilized is as follows:  (Internal  Revenue Code, 1979)
          Net Taxable  Income                           Tax  Rate (%)
          1st $25,000                                       17
          2nd $25,000                                       20
          3rd $25,000                                       30
          4th $25,000                                       40
          All above $100,000                                46
     From this structure the average  and  marginal  tax rates were determined.
For both coin-ops  and  commercial plants,  net  taxable income falls  in the
first  category.   Federal tax is therefore 17  percent to  which 4 percent
is added for  state and other taxes, giving a  tax  rate of 21 percent.
Marginal and  average tax rates  are  the  same  in these sectors.  Federal
tax rate for  the  industrial  sector  averages  35 percent,  but the marginal
tax rate is 46 percent.  Adding in  state  and  other taxes gives an  average
tax rate of 39 percent and  a marginal tax rate of 50 percent  for the
industrial sector.  The average tax rate  is  used  to reflect the present
condition  of  the  model plants.  In  considering the effects  of  controls,
the marginal  tax  rate  will  be  applied to  control  costs  or credits.
                                   8-46

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     8.4.2.1.2  Coin-op sector.  As Table 8-22 shows, the capital investment
in dry cleaning equipment for a coin-op plant with two dry cleaning
machines is about $12,000 (Clement, Bob, 22 March 1979).  Total, annual
revenues for the coin-op plant averages $23,810, with about $7,500, or
31 percent of the total attributable to dry cleaning services (Gill, Ward,
January 1979).  Although this figure is lower than that based on throughput,
it is used so as not to understate the economic impacts.  Thus, while dry
cleaning may be an important source of revenue to the coin-op plant, it
is clear that the majority of plant revenues accrue from laundering
services.  The before-tax profit rate is estimated at 20 percent, based
on conversations with industry representatives (Gill, Ward, January 1979).
After tax profit margin (including owner's salary) is 15.8 percent.  In
this way, total annual plant profits before tax were estimated at $4,762
and the after-tax profit from dry cleaning was estimated as $1,185.
     8.4.2.1.3  Commercial sector.   The capital investment in dry cleaning
plant and equipment for a commercial facility with an 11 kg machine is
estimated at $54,900.  This is derived from a 1976 value of $75,000 which
is adjusted for plant size (TRW, 7 May 1976).   Dry cleaning revenues for
this model  plant are estimated by multiplying the annual throughput
(13,475 kg) by average price ($3.02/kg), yielding $40,695.   This is taken
to be 85 percent of total annual revenues for the plant, (Fisher, William,
23 January 1979; Census, 1972) which are estimated at $47,876.  In the
commercial  sector, the dry cleaning service is the most important
contributor to plant revenues and profits.
     Industry sources indicate that pre-tax profit margins in the commercial
sector average 3 percent with a range of 0-6 percent of sales (Karash, Susan,
17 September 1979).   Although this value is lower than figures prepared
by Robert Morris Associates and Bureau of Census, it is reasonable since
it reflects profit margin before tax but after owners'  salary has been
subtracted.  It is important to recall  the nature of the industry.   Many
commercial  dry cleaners are family run businesses.   The principal goal of
operations would be providing a livelihood and income for various family
members.   The business is often entered into to provide stable employment
and reasonable income rather than high after-tax profits.   Using the
                                  8-47

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                  Table  8-22.   MODEL  PLANT  FINANCIAL  PROFILE
                                (1978 dollars)
, 	 — 	 • 	

Plant capital ($)a
Annual revenues ($/yr)
Dry cleaning revenues ($/yr)
Net orofit marqin before
Co in- op

12,000
23,810
7,500
20
Commercial
11 kg
54,900
47,876
40,695
3d
23 kg
90,200
100,104
85,089
3d
Industrial

394,000
4,965,353
844,100
6d
  taxes (%)

Total before tax
  profit ($/yr)c

Average tax rate (%)

Total profitafter
  tax ($/yr)c

After tax profit
  margin (%)

Dry  cleaning after tax
  profit ($/yr)
4,762
1,436
   21        21

3,762     1,134
3,003     297,921


   21          39

2,372     181,732
  15.8*
1,185
  2.4
  977
  2.4
2,042
  3.7
31,232
 alnitial  investment  in  dry cleaning portion of plant.

 Revenues from  all plant  operations.

 GNet profit  from all  operations.
 dRanges  in pre-tax profit margin:  commercial plants 0-6% of sales,  industrial
  3-12% of sales.
 elncludes owner's salary  - commercial  and  industrial after tax profit
  margins are after owner's salary  is  deducted.
                                      8-48

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average pre-tax margin of 3 percent, plant profits are $1,436 before tax
and $1,134 after tax with $977 of the after tax profit attributable to
dry cleaning.
     The second model plant for the commercial sector utilizes a 23 kg
machine.  Capital investment for the dry cleaning portion of the plant is
approximately $90,200.
     Revenues were derived as described for the 11 kg machine group.  Dry
cleaning revenues in this group are $85,089 per year and total plant
revenues are $100,104.  The after-tax profit rate is 2.4 percent resulting
in estimates of a total annual profit of $2,372 after taxes, which includes
a dry cleaning profit of $2,042.
     8.4.2.1.4  Industrial sector.  Capital investment in dry cleaning in
the industrial sector is estimated as $394,000.  Annual dry cleaning
revenues are estimated by multiplying throughput 468,950 kg by an average
price of $1.80/kg.  This yields annual dry cleaning revenues of $844,100.
This represents about 17 percent of total revenues for the plant.  In the
industrial sector, other services, such as linen supply, garment rental,
etc., account for a significant proportion of total plant revenues.  The
pre-tax profit margin in this sector average 6 percent with a range of
3-12 percent (Karash, Susan, 17 September 1979).  With an average tax
rate of 39 percent the after-tax profit margin averages 3.7 percent.
After tax profits for the plant average $181,732 of which $31,232 is from
dry cleaning operations.
     8.4.2.2  Competition and Pricing.  The extent to which the costs of
emission controls can be passed on through increased consumer prices will
depend largely on price sensitivity.  Whether these costs will be borne
by the dry cleaner or by the consumer will depend on the price elasticity
of demand for the dry cleaning industry.  Price elasticity of demand is
defined as the percentage change in quantity demanded, divided by the
percentage change in price.
     Since price levels are known, price elasticity can be calculated
using sales data to approximate demand.  Changes in the consumer price
index for dry cleaning services were compared, with throughput figures
which were derived from revenues.  In this way, price elasticity of
                                  8-49

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demand for dry cleaning from 1969 to 1975 is estimated at approximately
-2.3.  This means that for every 1 percent increase in price,  the .quantity
demanded will decrease by 2.3 percent.  Therefore, price increases  cannot
be accomplished without hurting revenues.
     In addition, it would not be feasible for new plants to charge
higher prices than those prevailing in a community for comparable dry
cleaning services.  New plants would not attract customers if their
prices were noticeably higher.  This is another constraint which restricts
new plants from passing through costs.  Of course, new plants in new
communities without any dry cleaning service would not have this competi-
tive pressure and might be able to pass through costs.  In most cases,
however, price increases would be strictly limited by local competition.
8.4.3  Economic Effects on New and Modified/Reconstructed Facilities
     8.4.3.1  Introduction.  New and modified/reconstructed facilities
are treated together in this analysis for several reasons.  As shown in
section 8.2, the control costs for modified/reconstructed facilities are
quite similar to those for new plants.  For this  reason, it is likely
that the regulatory requirements would influence  investors in new plants
and owners with modification plans in a similar way.  The owner of a
plant considering major modifications would go through an analysis similar
to that of a new investor.  The effects on profitability and return on
investment would be as shown below.   In addition, the estimate of new
sources, which is presented in section 8.1, includes sales for both new
and  replacement facilities.  There is no evidence from which to determine
the proportions of new and modified/reconstructed plants within this
total.  Thus, separate analysis would be complicated and subjective.  The
aggregate figures presented in section 8.2.5 include costs incurred by
both new and modified/reconstructed facilities.
     Table 8-23 provides a summary of the control technologies and costs
for  option 1 and option 2.  Capital costs and annualized costs as shown
in section 8.2 are reviewed.  Capital requirements are shown as a percent
of dry cleaning plant investment.  Annualized costs are adjusted for
taxes.  These adjusted annualized costs will be used throughout the
discussion of plant profitability and ROI.
                                   8-50

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                     Table 8-23.  SUMMARY -OF CONTROL COSTS
                                (1978 Dollars)
                              Coin-op         Commercial   .-•    '  Industrial
                                     .   11 kg           23 kg
Capital cost ($)a
As % of plant
  capital
Annualized cost~
  pre-tax ($/yr.)c
Annualized cost
"  C$yr.) with
                d
  tax adjustment
Capital cost ($)a
As % of plant
  capital
Annualized cost.
  ($/yr.)c
Annualized cost
  ($/yr.) with
  tax  adjustment
        -'"-.''  Option 1  .  ,  .  -
18,500    (1,000)    '    14,000     11,700
   154        (2)            16          3
 3 ,700
 2,923
600"
474
4i0'00-.   (13,100)
3,160     (6,550)
                Option 2
     0  .    4,000  .       4,000     11,700
     0          7             4          3
              600
              474
               300    (13,100)
               237     (6,550)
  Initial capital  investment  in  controls.
 Percent of capital  investment  of  dry  cleaning plant.
 "As  described  in  Section  8.2.
  Calculated as  (annualized cost) x (l~t) where t  is marginal tax  rate.
                     Coin-op  Commercial:  t =  0.21
                     Industrial:  t = 0.50
                                     8-51

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     8.4.3.2  Capital Availability.  For coin-op plants, option 1 imposes
a capital cost of $18,500 which represents 154 percent of the average
coin-op investment in uncontrolled dry cleaning equipment.   This substantial
capital requirement would impose a considerable hardship on new investors.
The additional capital needed to install the dry cleaning process would
probably deter investors from including the dry cleaning process in a new
coin-op.  Option 2 imposes no extra cost on this sector and therefore
causes no capital availability problems.
     For commercial plants with an 11 kg machine, option 1 creates a
capital savings of $1,000, compared to the pre-NSPS plant, which is about
2 percent of plant capital.  For option 2, the control devices impose a
capital cost of $4,000, which is about 7 percent of plant capital
requirements.  Neither option is likely to discourage investment to any
great extent.
     For the larger commercial plant (23 kg machine), option 1 imposes
capital costs of $14,000.  This represents 16 percent of dry cleaning
plant capital.  This increment could pose capital availability problems
for some investors.  Option 2 is less severe, raising the capital
requirement by only $4,000, or 4 percent of dry cleaning plant capital.
Again, this is unlikely to pose a  serious threat to investors.
     In the industrial sector both option 1 and option 2 require the use
of a carbon adsorber.  This imposes a capital cost of $11,700, which is
3 percent of plant capital.  This  is unlikely to discourage investment,
especially since the investment generates annual savings of $6,550 after
tax.  In fact, many plants have adopted this measure even without regulatory
pressure.
     8.4.3.3  Effects on Profit Margin and Return on Investment.  In
evaluating the economic impact of  regulatory alternatives, it is necessary
to consider the effect of the controls on the profitability of the industry
and its return on  investment (ROI).  Table 8-24 summarizes the effects of
control options 1  and 2 on profit  and ROJ for the model plants for each
sector.  For this  analysis, it is  assumed that the full cost of controls
is absorbed with no price  increase.  This seems likely due to the competitive
nature  of the industry.  Profit margins are after taxes and are derived
                                   8-52

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               Table 8-24.  EFFECTS OF CONTROL OPTIONS ON PROFIT
                            AND RETURN ON INVESTMENT FOR MODEL PLANTS
                                (1978 dollars)

Effects
PROFIT EFFECTS
Dry cleaning profit
before control ($/yr)
Profit margin
before controls (%)c

Cost of controls ($/yr)
Dry cl earn" ng prof i t
after controls ($/yr)
Profit margin after
control s (%)c

Cost of controls ($/yr)
Dry cleaning profit
after control ($/yr)
Profit margin
after control (%)c
ROI EFFECTS*1
ROI before control (%)
ROI after option 1 (%)
ROI after option 2 (%)
Coin-op

1 ,185

15.8


2 ,923
1,738

23


0
1,185

15.8


9.9
(5.7)
9.9
Commercial
11 kg 23 kg

977 2,042

2,4 2.4

OPTION 1 ;
474 3 ,160
503 (1,118)

1.2 (1.3)
•. ,
OPTION 2
474 237
503 1^805

1.2 2.1


1.8 2.3
0.9 (1.1)
0.9 1.9
Industrial

/•' .
31,232

3.7

. • .
(6,550)
, 37,782 .--_

4.5


(6,550)
37,782

4.5


7.9
9.3
9.3
.Assumes full absorption of control costs.
 Annualized after tax costs.
 .After tax.
 ROI shown as percent calculated as (net profit after tax) -f (plant invest-
 ment in dry cleaning + capital cost of controls)
                                     8-53

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as dry cleaning profit divided by the revenues attributable to  the  dry
cleaning process.
     An important determinant of the level of new investment in the
industry is the expected return on investment (ROI).   In this study,  ROI
is derived as net income (profit) after taxes divided by capital investment
in the plant.  Only dry cleaning process income and investment are considered
and the ratios presented reflect ROI for the dry cleaning process.   The
ROI after controls is calculated using capital investment with controls,
which is baseline plant investment plus capital investment for controls.
The changes in ROI resulting from controls are shown in Table 8-24.
     Without controls, the coin-op sector is estimated to have an after-tax
profit margin of 15.8 percent.  Option 1 eliminates profits and creates a
$1,738 loss.  Thus, the profit margin after tax drops from a +15.8 percent
to -23 percent.  This would essentially preclude entry of new coin-op
cleaners.  ROI under option 1 drops from 9.9 percent to a 5.7 percent
loss which would surely limit investment in dry cleaning in this sector.
Option 2, which imposes no additional costs, would not affect either
profit margin or ROI for the coin-op model plant.
     Without controls, the profit margin after taxes for the commercial
sector is 2.4 percent.  Under option 1, the profit margin declines to
1.2 percent for the 11 kg machine plant and ROI drops from 1.8 percent to
0.9 percent.  This drop in ROI is very small and probably would not deter
firms from offering dry cleaning services.  Option 2 causes the same
relative declines in profit margin.  These changes probably would not
deter investment.  Profit margins and ROI for the industry are very low
in absence of controls.  Minor declines might have little effect on plant
openings since the major purpose of operations is often to provide family
jobs and income.  As long as the after tax profit and ROI remain positive,
controls would not be expected to deter individual small investors.
     For the 23 kg machine plant, option 1 erodes the profit margin from
2.4 percent to a loss of 1.3 percent.  ROI declines from 2.3 percent to
-1.1 percent.  Under this option, the smaller plant has better economics
suggesting that growth in the larger plant might be discouraged.  Option 2
is less stringent, causing the profit margin to decline only to 2.1 percent
                                  8-54

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 and ROI  to drop to 1.9 percent.   This latter option would probably not
 discourage investment.   However,  the development of larger plants might
 be favored slightly.
      Since the annualized cost of controls  for industrial plants  is a
 credit,  the regulation would obviously not  discourage the entrance of new
 plants.   The after-tax margin increases from 3.7 percent to 4.5 percent
 under either option.   ROI also increases, from 7.9 percent to 9.3 percent.
      8.4.3,.4  Effects  of Controls on Growth and Entry of New Plants.   The
 proceeding discussions of profit, ROI,  and  industry financial characteristics
 provide  the basis  for  an evaluation of the  effects of the control options
 on growth in the industry.   Significant changes in either profit  margins
 or ROI caused by the control  options may discourage investment and strictly
 limit the construction of new sources.   This section discusses the potential
 effects  of control  options 1 and  2 on Investment in new dry cleaning
 piants.
      Within the constraints of the model plant analysis,  an investor
 either builds a plant  or he does  not.   The  analysis can only accommodate
 the evaluation of  an average plant under static conditions.   The  model
 plant represents a single average level of  profitability, investment,
 throughput,  and ROI.   Since all new plants  are considered to have the
 same financial  parameters, all new investors would make the same  decision
.about the commitment of new resources to the dry cleaning industry.   Data
 limitations make it difficult to  quantitatively determine the number of
 plants which are more  profitable  than the model plant,  although it is
 acknowledged that  some plants operate in financial conditions more favorable
 than those described here.   Based on a single data point, the investment
 is either advantageous or not worthwhile.   One would conclude then,  that
 either all  or none of  the expected plants would be built.
      However, in reality these plants exist under varying economic
 conditions.   In some regions prices may be  higher and,  hence, profits may
 be higher.   Capital investment costs may vary substantially depending on
 the type and age of equipment installed. Plants may be opened more
 profitably in conjunction with the grassroots development of new  communities.
 In these advantageous  situations, growth may continue even though conditions
                                   8-55

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of the typical model plant indicate otherwise.  Thus, if the changes in
profit or ROI for the model plant indicate that none of the plants would
be built, it is important to recognize that the variation in actual
conditions would buffer the extreme conclusions.  However, there is
little data to support an objective estimate of the number of plants
which exist in more advantageous circumstances.
     Since the industry is highly competitive a new plant could not
operate with higher prices than existing plants in the community.   Hence,
control costs would result in reduced profits for new plants.  Table 8-25
summarizes the changes in industry growth for each control option.  As
the table indicates, there are some adverse impacts with option 1.  As a
general statement, these should not constrain the total supply of dry
cleaning facilities within the existing industry or cause price increases
since model plants in these sectors operate dry cleaning at relatively
low utilization rates implicit in the model plant paramters shown in
Table 6-1.  Throughput per machine could increase substantially before a
100 percent utilization level would be approached.
     Option 1 has a very severe effect on certain segments of the dry
cleaning industry in terms of sharply reduced replacement and growth.
For example, option 1 seriously erodes coin-op profit and ROI and would
probably preclude investment.  It is estimated that, of the projected 750
new plants, none would be built.  Although this will virtually preclude
new coin-op dry cleaning, it would not eliminate the coin-op niche for
small business investors.  It is highly probable that coin-op laundromats
would continue to be built; they would just not include the dry cleaning
machines.  It is important to recall here that dry cleaning is not the
dominant portion of the coin-op business.
     As a second example of a possible adverse effect, option 1 is more
costly for large-commercial model plants than for the smaller model
plant.  Capital availability could pose some difficulty and both profit
margin and ROI become negative.  In this situation, growth in large
plants would diminish, but growth in smaller plants might actually be
larger than the baseline estimate.  Controls would not contribute to
closures of smaller plants under option 1.
                                  8-56

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        Table  8-25.   EFFECTS  OF  CONTROL  OPTIONS  ON  NUMBER  OF  NEW  PLANTS



Baseline growth3
Number pre-empted
L -
Option 1 growth
Number pre-empted
Option 2 growth
Co in- op
750
750
0
0
750
Commercial
11 kg 23
2,451
OPTION 1
0
2,451
OPTION 2
0
2,451
kg
817
817
0
0
817
Industrial
50
0
50
0
50
 Number of new plants  1980-1984 in  absence  of controls.
3Number of new plants  1980-1984 under specified control  requirements.
                                     8-57

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     Option 2 imposes less stringent controls  on the coin-operated and
commercial sectors of the industry.   It is unlikely that construction of
any projected new sources would be pre-empted. .  In the commercial  sector,
option 2 is more costly to the smaller machine plant than to the larger
machine plant.  Although investment in this sector is not likely to  be
reduced, it is possible that this option would encourage use of the
larger machines.
     It must be emphasized again that this behavior is based on all
plants having similar financial conditions.  There will be a range of
actual conditions, but there is no data to support objective estimates  of
the number of plants for which economic conditions may be more favorable.
8.5  SOCIOECONOMIC EFFECTS
8.5.1  Industry Structure
     Option 1 could  create some changes in the  structure of the dry
cleaning  industry.   It would virtually eliminate  new growth in coin-op
dry cleaning, .until  such time as capacity limitations caused prices to
rise and  enabled  profitable operation.  This might  seem a severe threat
to small  business enterprises.  However,  it would not necessarily preclude
the opening of  new laundromats; rather, it would  discourage investors
from including  dry cleaning machines  in their plants.  Dry cleaning is
not the dominant  revenue stream in  coin-op plants.  Thus, it is likely
that a  laundromat could operate profitably without  the dry cleaning
process in most situations.
     The  second effect of  option 1  results from its different  impacts  on
the two commercial model plants.  Because profit  and  ROI are eliminated
for the larger  plant,  it  is probable  that option  1 would cause shifting
in the  commercial sector.  New investors  might  opt for  smaller plants
(11  kg  machine) with better economic  prospects.  The  end result could  be
higher-than-expected growth in the  use of 11  kg machines, and  no  growth
in the  use of 23  kg  machines.
      Option 2 would  probably  not  affect the overall industry structure.
8.5.2  Employment                          .            .
      Option 1 would  reduce employment from baseline conditions.   About
 3,800 plant openings might be precluded in this case.   The  jobs associated
                                   8-58

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with these plants would be eliminated.  Currently employed people would
not become unemployed as a result of the regulation.  Anticipated jobs
simply would not be filled.  This is fairly minor since dry cleaners,
especially coin-ops, usually have few employees other than the owner.
Assuming 4 employees per establishment, this would represent about 15,200
jobs in the U.S. economy.
     Option 2 would not influence employment.
8.5.3  Balance of Trade
     Neither option 1 nor option 2 would affect the balance of trade
situation.
8.5.4  Community Effects
     There are no community effects arising from either option 1 or
option 2.   The closure of 3,800 plants nationwide would not be expected
to significantly influence any single community.  This might involve 4 -
8 jobs in a typical community.
8.5.5  Price Level
     Table 8-26 shows the cost of annualized dry cleaning controls as a
percentage of dry cleaning revenues, which is the percentage change in
price if costs were fully passed through.   If this could occur, new
coin-ops might operate profitably under option 1 by raising prices
39 percent.  Under option 1, the 23 kg machine commercial plant would
raise prices by 3.7 percent to maintain the same profit margin.  An 11 kg
machine plant would increase prices by 1.2 percent.
     However, the competitive character of the industry precludes new
plants from charging more than the existing population.  Thus, price
increases would usually be zero, and some plants would not be built.  In
the long run, prices could rise if retired capacity were not replaced.
As this occurred, new plants would be built.  In new communities where
new demand centers arise, new growth would be unaffected by the controls.
8.5.6  Total Costs of Controls
     The total cost of the control alternatives is presented in Table 8-21.
This provides an estimate of the additional capital burden imposed on new
plants from 1980-1984.  (Total capital costs are found by multiplying the
number of new plants by the capital cost per plant for each sector.)  The
                                  8-59

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        Table 8-26.   MAXIMUM PRICE INCREASES RESULTING FROM ALTERNATIVE
                     CONTROL OPTIONS ON DRY CLEANING MODEL PLANTS
                     Coin-op
                Commercial
             11 kg      23  kg
                        Industrial
                                        OPTION 1
Percent price
  increase due
  to controls3
39
1.2
3.7
(0.8)
Percent price
  increase due
  to controls3
                                        OPTION 2
             1.2
                                                 0.3
                           (0.8)
aDerived as follows:  (annualized costs after tax) -f (dry cleaning
 revenues); price change assumes full passthrough of control costs
 by dry cleaning plant.
                                      8-60

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annualized cost figures shown represent the cumulative totals of annualized
costs for new plants opening during the period from 1980 through 1984.
Pre-tax annualized costs are used to reflect the total cost to the economy.
Other assumptions made in the calculations are covered in section 8.2.
     In summary, option 1 imposes a total capital cost of $23.2 million
on the dry cleaning industry between 1980 and 1984.  The 1984 annualized
cost (which includes capital recovery) is $7.2 million.  This is clearly
below the regulatory action criterion of $100 million in the first five
years.
     With option 2, total industry costs are somewhat lower.  Total
capital costs are $7.2 million and 1984 annualized costs are $0.8 million.
                                  8-61

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Census of Selected Services, 1972, United States Department of Commerce,
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Clement, Robert, Sterling Supply Co., telephone conversation with
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County Business  Patterns, 1976, United  States  Department of Commerce,
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                                  8-62

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Gill, Ward,  President  of the  National  Automatic Laundry and Cleaning Council,
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Gill, Ward,  President  of the  National  Automatic Laundry and Cleaning Council,
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Internal Revenue Code, Commerce Clearing  House, Chicago,  Illinois, January  1979.

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McMonagle, Ray, VIC Manufacturing, telephone conversation  with  Young, Dexter E
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Monarch, M.   R., et al.    Priorities for New  Source Performance Standards
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     April 1978.

Quarterly Machinery Market Report for the Quarter Ended September 30, 1978
     of the  Laundry and  Cleaners Allied Trades  Association  (LACATA),
     30 September 1978.

Sluizer, Mervyn, Technical Director of Institute of Industrial  Launderers,
     telephone conversation with Dees', Edith, TRW, 17 January 1979.

Sluizer, Mervyn, Technical Director of Institute of Industrial  Launderers,
     telephone conversation with Browne, Renee, Energy and  Environmental
     Analysis, 23 January 1979.

Shame!,  R.E., J. K.  O'Neill, and R.  Williams, Preliminary Economic Impact
     Assessment of Possible Regulatory Action to Control Atmospheric  Emissions
     of Selected Halocarbons.   EPA-450/3-75-073.  US EPA, Research Triangle
     Park, N.C., 1975.

TRW.  Study to Support New Source Performance Standards for  the Dry Cleaning
     Industry.  Final  Report.   U.S.  Environmental Protection Agency.
     Research Triangle Park, N.C.   Publication  No.  EPA-450/3-76-029,  May 1976.
                                 8-63

-------
VIC Brochure, "Mileage Booster", December 1978.

Young, Dexter E., Trip Report of visit to R. R. Street and Company, Inc.,
     on 1 November 1979, 1 November 1979.
                                  8-64

-------
APPENDIX A.  EVOLUTION OF THE BACKGROUND INFORMATION DOCUMENT

-------

-------
       APPENDIX A.  EVOLUTION OF THE BACKGROUND INFORMATION DOCUMENT
     EPA presented a draft standard to the National Air Pollution Control
Techniques Advisory Committee (NAPCTAC) in August 1976.  Comments received
there resulted in the separation of the different dry cleaning solvents for
further study.  EPA published a Control Techniques Guideline (CTG) Document
in December 1978.  The CTG is a guide to the States for controlling perc
emissions from existing perc dry cleaners in non-attainment areas.  In
October 1978, EPA began working on the development of an NSPS for perc dry
cleaners.  A draft standard was presented to NAPCTAC in August 1979.
A.I  Chronology
     The chronology which follows includes those events which have occurred
in developing the BID for perch!oroethylene dry cleaning.   Anticipated
events which lead up to the proposal of the standard in the Federal Register
are also included.
     Date
November 3-20, 1975
January 15-27, 1976
           Activity
Plant test at Hershey Dry Cleaners and
Laundry, Hershey, Pennsylvania, of the
fluorocarbon machines and the perc
machine.
Plant test at Hershey Dry Cleaners and
Laundry, Hershey, Pennsylvania, of the
fluorocarbon machines.
                                  A-l

-------
     Date

March 1-29, 1976



April 7-20, 1976




August 10-11, 1976




August 31, 1978



December 7, 1978



December,  1978



March 14,  1979


March 26-30,  1979



June 4-7,  1979




June 29,  1979



August 21, 1979


August 28,29, 1979
           Activity

Plant test at Texas Industrial Services,
San Antonio, Texas, of a large industrial
perchloroethylene dry cleaning plant.

Plant test at Westwood Cleaners,
Kalamazoo, Michigan, of a small dry-to-
dry perchloroethylene dry cleaning
plant.

First National Air Pollution Control
Technique Advisory Committee (NAPCTAC)
meeting on dry cleaning, Chicago,
Illinois.

EPA proposed a list (including perc
dry cleaners) of stationary sources
for which NSPS would be written.

Meeting with industry representatives,
TRW,  and  EPA at EPA Offices, Durham,
N. C.

EPA published "Control of Volatile
Organic  Emissions  from Perchloroethylene
Dry Cleaning Systems," EPA-450/2-78-050.

Plant visit to Plaza Cleaners,  Shop-Rite
Shopping Center, Northvale, New Jersey.

Plant test  at Kleen Korner, Cortland,
New York, of  an average  size  dry-to-dry
perchloroethylene  dry cleaning plant.

Plant test  at Plaza Cleaners,  Shop-Rite
Shopping Center, Northvale, New Jersey,
of a  refrigerated  condenser at a
perchloroethylene  dry  cleaning plant.

Meeting with  industry  representatives,
TRW,  and EPA  at  EPA Offices,  Durham,
 N. C.

 EPA promulgated  the list of stationary
 sources for which  NSPS would  be written.

 Second NAPCTAC  meeting on perc dry
 cleaning, Raleigh, North Carolina.
                                   A-2

-------
     Date

September 17, 1979
October 2, 1979
November 1, 1979
December 18, 1979
January 11, 1980

June 18, 1980




July 1, 1980



July 14, 1980



October 1980
           Activity

Meeting with International Fabricare
Institute, Institute of Industrial
Launderers, Neighborhood Cleaners
Association, EEA, TRW, and EPA at EEA
Offices, Arlington, Virginia.

Meeting with VIC Manufacturing in
Minneapolis, Minnesota.

Meeting with R.R. Street in Oak Brook,
Illinois.

Meeting with representatives of the
International Fabricare Institute,
Institute of Industrial Launderers;
National Automatic Laundry and Cleaning
Council; Patton, Boggs, and Blow; and
Textile Rental Services Association,
in Durham, N.C.  to obtain comments on
the Steering Committee Review Package.

Steering Committee Meeting.

Presentation of preamble, regulation,
and advanced information and action
memos for Assistant Administrator
concurrence.

First Meeting of the Science Advisory
Board's Subcommittee on Airborne
Carcinogens.

Preamble and Regulation signed into AA
Review by the Assistant Administrator
for Air, Noise,  and Radiation.

Anticipated proposal of regulation in
the Federal Register.
                                  A-3

-------

-------
APPENDIX B.  INDEX TO ENVIRONMENTAL IMPACT CONSIDERATIONS

-------

-------
           APPENDIX B.   INDEX TO ENVIRONMENTAL IMPACT CONSIDERATIONS
    Agency Guidelines for Preparing
    Regulatory Action Environmental
    Impact Statements 39 FR 37419


(1) Background and Summary of
    Regulatory Alternatives
Location within the Background
Information Document
The regulatory alternatives are
summarized in Chapter 1,
Section 1.1.
    Statutory Basis for Proposing
    Standards
    Relationship to other Regulatory
    Agency Actions
    Industry Affected by the Regulatory
    Alternatives
    Specific Processes Affected by the
    Regulatory Alternatives
    Availability of Control  Technology
    Existing Regulations
The statutory basis for the regula-
tory alternatives is summarized in
Chapter 2.

The various relationships between the
regulatory alternatives and other
regulatory agency actions are sum-
marized in Chapters 3, 7, and 8.

A discussion of the industry
affected by the regulatory alter-
natives is presented in Chapter 3,
Section 3.1.  Further details
covering the "business/economic"
nature of the industry is presented
in Chapter 8, Section 8.1.

The specific processes and facili-
ties affected by the regulatory
alternatives are summarized in
Chapter 1, Section 1.1.   A detailed
technical  discussion of the sources
and processes affected by the pro-
posed standards is presented in
Chapter 3, Section 3.2.

Information on the availability of
control technology is given in
Chapter 4.

A discussion of existing regula-
tions on the industry to be
affected by the regulatory alterna-
tives are included in Chapter 3,
Section 3.3.2 and Chapter 8,
Section 8.3.
                                    B-l

-------
     APPENDIX B.  'INDEX TO ENVIRONMENTAL IMPACT CONSIDERATIONS  (Continued)
    Agency Guidelines for Preparing
    Regulatory Action Environmental
    Impact Statements 39 FR 37419

(2) Alternatives to the Regulatory Alter-
    natives

    Environmental Impacts
    Costs
(3) Environmental Impact of the Regulatory
    Alternatives

    Air Pollution
    Water Pollution
    Solid Waste Disposal
     Energy
 (4)  Economic  Impact  of the  Regulatory
     Alternatives
Location within the Background
Information Document
Environmental effects of not imple-
menting the regulatory alternatives
are discussed in Chapters 3 and 7.

The costs of alternative control
techniques are discussed in
Chapter 8, Sections 2, 3, and 4.
The air pollution impact of the
regulatory alternatives is dis-
cussed in Chapter 7, Section 1.

The water pollution impact of the
regulatory alternatives is discussed
in Chapter 7, Section 2.

The solid waste disposal impact
of the regulatory alternatives is
discussed in Chapter 7, Section 3.

The energy impact of the regulatory
alternatives is considered in
Chapter 7, Section 4.

The economic impact of  the regula-
tory  alternatives on costs is  dis-
cussed in Chapter 8, Section 2.
                                     B-2

-------
APPENDIX C.  EMISSION SOURCE TEST DATA

-------

-------
                  APPENDIX C.   EMISSION SOURCE TEST DATA

     Dry cleaning plants differ in size, control techniques, design, capacity,
types of articles cleaned, climate of locality, soil composition of clothes,
age of equipment, and maintenance history.   These parameters can, to some
extent, affect emissions.   Several perch!oroethylene plants utilizing
current emission control technologies have been tested in order to determine
the effects of best available control in the dry cleaning industry.  Five
plants were tested - four commercial plants (Plants A, C, D, and E) and one
industrial plant (Plant B).  Plant A was a large commercial plant with a
machine capacity of 50 kg (110 Ib).  This can be compared with the average
commercial plant as established in Chapter 5, which has a capacity of 18 kg
(40 Ib).  Plant C was an average size commercial plant with a dry-to-dry
machine having a capacity of 19 kg (40 Ib).  Plants D and E were also
average size dry-to-dry commercial plants with rated capacities of 18-20 kg
(40-45 Ibs).  Plant B was an average size industrial plant with a machine
capacity of 113 kg (250 Ib).  Tests involved material balance calculations
and adsorber outlet measurements.  Test results are displayed in Table C-1.
Descriptions of these plants can be found in the following text.
C.I  PLANT A
     Plant A is a commercial operation using perch!oroethylene  in a 50 kg
capacity machine.  The machine, a  SM-11 washer manufactured by  the Washex
Machinery Corporation, was  installed in  1967 in Hershey, Pennsylvania, and
was tested  in November of  1975.  The system consists of a washer/extractor,
regenerative filter muck cooker/still and two  solvent tanks, all in one
unit (refer to Figure C-1).  The  system  also has two reclaiming dryers, and
a  VIC  dual  canister carbon  adsorber.  The adsorber  collects emissions from
the washer  door  vent, the  dryer,  floor  vents,  and the distillation  (muck
cooker) unit.  The  plant  conducted two  operations which  are not normally
                                   C-1

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used in dry cleaning services; fire proofing, and water repelling applica-
tions.   The addition of these materials was accounted for in the material
balance.
     Test results indicate a total emission rate of 4.1 kg of solvent per
100 kg of clothes cleaned (refer to Table C-l).   Emissions from the adsorber
averaged about 0.2 kg/100 kg of clothes.  The inlet to the adsorber measured
approximately 4.6 kg/100 kg of clothes, thus, the adsorber was achieving a
96 percent removal efficiency.  The test of this system demonstrated the
performance of carbon adsorption as a control technique.  The carbon in
this carbon bed was over 15 years old and could still be used to achieve a
96 percent removal efficiency (refer to Table C-2).  Overall plant emis-
sions would be more than double the present rate without an adsorber.
     This dry cleaning system suffered from inadequate housekeeping.
Liquid  leaks were sighted and buckets of solvent on the outlets of the
water separators were left uncovered.  These containers should be closed
and vented to the adsorber.  The scent of perch!oroethylene was prevalent
throughout the plant.  The amount of solvent vapors emitted to the atmos-
phere from any dry cleaning plant is dependent upon the type of equipment
used, the amount of cleaning performed, and the precautions practiced by
the operating personnel.  In this plant, housekeeping  practices were poor.
Liquid  losses were detected visually as brown residue  associated with a
solvent leak.  Because of the volatility of the solvents, these liquid
leaks are eventually evaporated to the  atmosphere.  These losses occur at
evaporative points and tears  in ductwork.
     The emission factor of 4.1 kg/100  kg  for Plant A  can be compared to
the emission rate of 4.9 kg/100 kg estimated by an IFI survey  (Watt, Andrew,  IV,
and Fisher, W. E., January-February  1975)  for a usual  plant which  has a
regenerative filter with a muck cooker  and which  is also  equipped  with a
carbon  adsorber.  The emission factor  of 4.9 kg/100  kg was  an  average for
well-operated commercial plants.   In Plant A, the adsorber  collects  emis-
sions from the washer door vent,  the dryers, floor vents, and  the  distilla-
tion  (muck cooker) unit whereas in the  plants examined by the  IFI  survey,
the adsorber collects emissions only from  the washer  and  dryer.
                                   C-4

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C.2  PLANT B
     Plant B is an industrial dry cleaning plant using perchloroethylene
solvent, which began operation in 1957 and was tested in March of 1976.   It
is an Amercian Laundry Machinery system which includes washer/extractor,
"kissing" dryer, distillation unit, chemical separator, oil cooker and
single bed carbon adsorber (refer to Figure C-2).  The adsorber collects
emissions from the washer and dryer only.  The carbon adsorption unit
collects solvent during the day from clothes transfer, deodorizing and
dryer unloading.  The capacity of the washer is about 113 kg per load but
shirts are loaded at 90 kg per load because of the number of articles per
kilogram.  Pants are loaded at capacity.
     The "kissing" washer/dryer is unique in the industry.  At the end of
the wash cycle, the dryer is pneumatically rolled to within 0.3 meters of
the washer, both doors and opened and the clothes are transferred by tumbling.
This design greatly reduces the time that solvent laden clothes are exposed
to the atmosphere.  During the transfer  operation, exhaust fans inside both
the washer/extractor and the reclaiming  tumbler  remain on to minimize
escape of perchloroethylene vapors.
     Test results showed an emission rate of approximately 2.5 kg of solvent
per 100  kg of clothes cleaned (refer to  Table C-l).  Emissions from the
adsorber averaged about 0.002 kg/100 kg  of clothes, thus, the adsorber
achieved a 99+ percent removal efficiency (refer to Table C-2).  Most of
the losses were accounted for in a special washer loading exhaust and in a
distillation unit vent.  The washer loading exhaust was vented to the
atmosphere during loading of the washer  drum.  Samples were taken of both
these discharges.  The average total emissions from these two sources was
1.35 kg  per 100 kg of clothes cleaned.
     Exemplary  housekeeping  practices were  followed at the plant, thus
reducing fugitive emissions.  No solvent leaks were detected by sight or
smell.   The equipment in this plant was  installed between  1970 and 1975
(Kleeberg, Charles F., 14 May 1976).
C.3  PLANT C
     Plant C  consists of a dry-to-dry Vic Model  221 Strate System with a
capacity of 18  kilograms.  This  is an average size commercial dry-to-dry
                                   C-6

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machine.  The system vents to a dual canister carbon adsorber from the
dry-to-dry machine (during the entirety of the drying cycle), from floor
vents, and from the dry-to-dry machine door (refer to Figure C-3).   Each
carbon bed operates for one cycle of the dry-to-dry machine and is then
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 its cycle.
The solvent purification device used in the system is a 14 cartridge paper
filter.
     Test results yielded an emission rate of 2.1 kg of solvent used per
100 kg of clothes cleaned.  The total system lost approximately 3.5 kg of
solvent per day.  Of this total amount, the carbon adsorber  lost 1.5 kg at
an average outlet concentration of  100 ppm (Kleeberg, Charles F., 17 March
1976).  The average outlet  concentration was high because breakthrough
occurred during each cycle.  The cartridge filter accounted  for an
estimated 1.0 kg of solvent lost per day.
      Plant C is a continuously venting perch!oroethylene dry-to-dry system.
It does not recirculate the exhaust gas from the drying operation through a
solvent condenser but the vapor passes directly  into a carbon adsorption
unit.  The exhaust gas from the adsorber  is continuously vented to the
atmosphere.
C.4   PLANT D
      Plant D (Figure C-4)  is  a dry-to-dry commercial dry cleaning plant
with  a rated capacity of  18-20 kg  (40-45  Tbs).   This dry-to-dry machine,
model  11-20-H,  manufactured by Detrex was installed  in 1976 in  Cortland,
New York,  and was  tested  in March  of .1979 (Jongleux, R.F.,  December  1979).
The dry cleaning  system utilized  a Kleen-Rite  (model #34-1200)  cartridge
filter system  for purifying the  dry cleaning  solvent.  A  17 year  old Hpyt
Model I carbon  adsorber (with the  original  carbon) was used to  recover perc
from  the  dry cleaning machine.   The carbon adsorber  was connected only to
the dry cleaning  machine  with one  additional  opening,  a 3/4 inch  pipe,
opening to the  ambient  air.  At  one time, the  cartridge filters  had  vented
to the adsorber by means  of this  pipe but have since been  disconnected.
                                   C-8

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     Test  results  (refer  to Tables  C-l  and  C-2)  indicate  a  total  emission
 rate of 6.6  kg of  solvent per  100 kg of clothes  cleaned.  Emissions  from
 the outlet of the  adsorber averaged about 0.1  kg/100  kg of  clothes.   The
 inlet to the adsorber averaged approximately 3.3 kg/100 kg  of clothes
 cleaned, thus the  adsorber was achieving a  97  percent removal efficiency.
 The test of this system demonstrated that carbon adsorption can achieve
 high removal efficiencies as long as the carbon  bed was desorbed  at  the end
 of every day.  In  this test, when the adsorber was desorbed the day  before,
 the efficiency was 97 percent  and the adsorber outlet concentration  never
 exceeded 25 ppm.  When the bed was  not  desorbed  the day before, breakthrough
 occurred.  The efficiency dropped to 83 percent  and the adsorber  outlet
 concentration reached 100 ppm.
     The majority of losses from this dry cleaning system came from  the
 cartridge  filters.   The perc loss due to changing the  cartridge filters was
 calculated as 2.74 kg/100 kg throughput which  represents almost half  of the
 total losses.  The carbon adsorber  average  loss  was 0.1 kg/100 kg throughput.
     The remainder of the emissions were attributable  to fugitive losses.
 Fugitive losses are vapor leaks or  liquid leaks.   The  major leaks appeared
 to be from valves in the solvent lines to the  filters  where perc  leaked
 enough during the night to form a small puddle on the  base tank of the
 machine.   Damper leaks were also suspected  since there was a measurable
 concentration of perc at all times  at the inlet  sampling location, despite
 the fact that the damper to the carbon bed  from  the machine was closed.
These losses measured represented about 3.8 kg/100 kg  of clothes processed.
     The total  losses of 6.6 kg/100 kg of clothes cleaned is equivalent to
 about 10 600 pounds of cleaning per drum of solvent.
 C.5  PLANT E
     The perchloroethylene dry cleaning equipment at this plant consisted
of two pieces of equipment;  a commercial dry-to-dry perchloroethylene dry
cleaning machine and a refrigerated condenser.   The dry cleaning machine
 had a rated capacity of 30 kg (65 Ibs).   The refrigerated condenser relaimer,
                 ฎ
called a Resolver  by the manufacturer, was designed to serve up to a 30 kg
 (65 Ib)  machine.  -Because the system was completely closed,  actual emissions
 from the process could not be measured.   However, inlet and  outlet
                                  C-ll

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concentrations to the dryer were measured.   Because the condenser is a
multi-pass type of control device, efficiency data for a single pass through
are not indicative of the actual machine performance.   In this case, the
test data that are most useful are the material balance numbers.   This data
indicated 2.6 kg of solvent was lost per 100 kg of clothes processed
(Jongleux, R.F., April 1980).  Therefore, for installations such as this
one, when fugitive and filters losses are minimal, refrigerated condensers
can achieve solvent loss rates equivalent to carbon adsorber equipped
facilities.
                                   C-12

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                          REFERENCES FOR APPENDIX C
 Jongleux,  Robert  F.,  "Emission  Test  Report,  Leaks  from Perch!oroethylene
      Dry Cleaners," TRW,  EMB  76-DRY-6,  December 1979.

 Jongleux,  Robert  F.,  "Material  Balance  Test  Perch!oroethylene  Refrigerated
      Closed System at Plaza Cleaners, Northvale, New Jersey,"  EMB  79-DRY-7
      TRW,  April 1980.

 Kleeberg,  Charles F.,  US  EPA, "Material Balance of  a Perchloroethylene Dry
      Cleaning Unit,"  test report to  James  F.  Durham on test  in Hershey,
      Pennsylvania, March  17,  1976.

 Kleeberg,  Charles F.,  US  EPA, "Material Balance of  an  Industrial,
      Perchloroethylene Dry Cleaners," test report to James F.  Durham on
      test  in San Antonio, Texas, May 14, 1976.

 Kleeberg,  Charles F.,  US  EPA, "Material Balance of  a Small Commercial
      Perchloroethylene Dry Cleaner," test  report to James F. Durham on test
      in Kalamazoo, Michigan, May 17, 1976.

 Midwest Research Institute, "Test of Industrial Dry-Cleaning Operation at
      Texas Industrial  Services, San  Antonia, Texas," No. 76-DRY-2
      April 28, 1976.

 Midwest Research Institute, "Source  Test of Dry Cleaners," No.  76-DRY-3
      June 25, 1976.

 Scott Environmental  Technology, Inc., "A Survey of  Perchloroethylene
      Emissions from a  Drycleaning Plant," No. 76-DRY-l, March  1976.

Watt, Andrew, IV,  and William E. Fisher, "Results of Membership Survey of
     Dry Cleaning Operation." IFI Special Reporter No.  3-1,
     January-February  1975.
                                  C-13

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APPENDIX D.  EMISSION MEASUREMENT AND CONTINUOUS MONITORING

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                                APPENDIX D
              EMISSION MEASUREMENT AND CONTINUOUS MONITORING

D.I  EMISSION MEASUREMENT METHODS
D.1.1  Emission Measurement Method for Perch!oroethylene From Adsorber Vent
     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, EPA Method 23:  "Determination of 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:  (1) less uncertainty 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
technio'ie 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.
     In the EPA tests, all non-methane hydrocarbon peaks were summed to
yield a total value.  Since perch!oroethylene was anticipated to be the
major constituent, all calculations were based on perch!oroethylene stan-
dards.  In the three tests performed by EPA, little, if any, non-methane
hydrocarbon other than perch!oroethylene was found.
     With slight modifications as noted in the test reports, velocity
measurements on inlet and outlet ducts were done according to Methods 1
and 2 of the Federal Register, Vol. 36, No. 247, December 23, 1971.
                                  D-l

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0.1.2  Perchloroethylene from Stm Residues and Wet Waste Material  from
       Regenerable Filters
     The method used to determine perchloroethylene content in the still
residues and wet waste material from regenerable filters has been a distil-
lation procedure similar to the test method described by the American
Society for Testing and Materials  (ASTM), designation D322-67, "Standard
Method of Test for Dilution of Gasoline Engine Crankcase Oils."  Two minor
modifications to that procedure were required:  (1) because perchloroethylene
is heavier than water, the Liebig  condenser was modified to collect the
perchloroethylene on the bottom of the calibrated trap and allow the water
to overflow  from the top, (2)  instead of determining a volumetric percentage,
a weight percent was determined by adding a known mass of sample to the
flask instead of known volume  of sample.  The mass  of perchloroethylene
collected was calculated from  the  volume of perchloroethylene  collected and
the  specific gravity of perchloroethylene.
D.2  MONITORING  SYSTEMS AND  DEVICES
D.2.1   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  instrument can  be  calibrated with that  compound and the results will  be
on that basis.   Examples  are some  manufacturer's  reported ranges for perchloro-
ethylene 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 $4,000,
 depending  on the detection principle, operating features,  and required
 accessories  associated with the  different instrument types  and vendors.
 EPA contracted to examine several  less expensive systems  than discussed
 above at a dry cleaning plant in New York,  however, they  were determined  to
 be inadequate because of erratic response.
                                   D-2

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D.2.2  Continuous Monitoring for Perchloroethylene from Adsorber Vents
     One continuous monitoring instrument that would be useful for.the low
concentration levels of perch!oroethylene present in well-controlled sources
is a continuous flame ionization detector.   However, due to the necessity
for an analysis that does not include methane, this device would not be
acceptable unless some provision could be made for subtracting the response
due to methane.  This response would normally be limited to the ambient
concentration of methane.
     EPA has contracted with an instrument manufacturer to develop a
continuous monitor for perchloroethylene.  The instrument is a form of gas
filter correlation infrared analyzer, and its projected unit acquisition
cost is $3,000-$5,000, provided that a minimum initial production of 50 units
could be justified.  While operational experience is limited, annual main-
tenance cost is estimated to be no greater than that for other infrared
analyzers.  This figure has been estimated at $1,000 for maintenance by
in-plant personnel, and $2,000 to $3,000 if performed by a service contract.
D.3  PERFORMANCE TEST METHODS
D.3.1  Perchloroethylene from Adsorber Vent
     If it is deemed necessary to conduct an emission test on the adsorber
vent the Method 23:  "Determination of Halogenated Organics from Stationary
Sources" is recommended as the performance test method.  In the final draft
of this method, further leak checks were added as additional precautions
against erroneous data.  These additions were suggested by an EPA contractor
that was studying the vinyl chloride test method.  This contractor coinciden-
tally 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.  No particular problems with the use of Method 23
should occur, provided that strict adherence is made to the leak check
procedures.
     The costs for conducting a Method 23 emission test in triplicate by a
source testing contractor will depend on the length of the cleaning cycle
and the distance to be travelled by testing personnel, and are accordingly
estimated at $2,000 to $4,000 for a single unit installation.  The testing
costs per unit would be lower if several units at a single site were serially
tested.
                                  D-3

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0.3.2  Perch!oroethylene from Still Residues and Wet Waste Material from
       Regenerate Filters
     The ASTM test method as described in D.I.2 is recommended as the
performance test method.  No problems with the use of this method with the
minor modifications described in D.I.2 are anticipated.
     The costs for conducting the analytical portion of this test on a
triplicate sample is estimated at $300 to $500.
                                   D-4

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                                    TECHNICAL REPORT DATA
                             (Please read Instructions on the reverse before completing)
  . REPORT NO.
     EPA-450/ 3- 79-029a
                                                             3. RECIPIENT'S ACCESSION NO.
 4. TITLE AND SUBTITLE
    Perchloroethylene Dry Cleaners
    Background Information for  Proposed Standards
                                                        5. REPORT DATE
                                                          August 1980
                                                        6. PERFORMING ORGANIZATION CODE
                                                             8. PERFORMING ORGANIZATION REPORT NO.
                        NAME AND ADDRESS
TRW Environmental  Engineering Division
Energy Systems  Group of TRW, Inc.
Research Triangle  Park,  North Carolina  27711
                                                             10. PROGRAM ELEMENT NO.
                                                              . CONTRACT/GRANT NO.
                                                               68-02-3063
 12. SPONSORING AGENCY NAME AND ADDRESS
    U.S. Environmental Protection Agency
    Office of  Air Quality Planning  and Standards
    Research Triangle Park, North Carolina  27711
                                                        13. TYPE OF REPORT AND PERIOD COVERED
                                                           Draft
                                                        14. SPONSORING AGENCY CODE
                                                           EPA/200/04
      'LEMENTARY NOTES
    Standards of  Performance for the control  of emission from perch!oroethylene dry
    cleaning facilities are being proposed  under the authority of section lll(b) of
    the Clean Air Act.   These standards  apply to new, modified, or reconstructed
    perch!oroethylene  dry cleaning facilities, the construction or modification of
    which began on  or  after the date of  proposal.   This draft document contains
    background information, environmental and economic impact assessments, and the
    rationale for the  standards as proposed under 40 CFR Part 60,  Subpart 00.
                                KEY WORDS AND DOCUMENT ANALYSIS
                  DESCRIPTORS
                                              b.lDENTIFIERS/OPEN ENDED TERMS
                                                                          c. cOSATI Field/Group
   Air Pollution
   Pollution
   Standards of Performance
   Perch!oroethylene Dry  Cleaners
   Perc
                                           Air Pollution Control
                                           Organic Chemicals
                                           Solvents
   Unlimited
                                              19. SECURITY CLASS (ThisReport)'
                                               Unclassified
                                                                     21. NO. OF PAGES
                                                                        165
                                               !0. SECURITY CLASS (Thispage)
                                               Unclassified
                                                                     22. PRICE
EPA Form 2220-1 (Rev. 4-77)   PREVIOUS EDITION is
                                      OBSOLETE

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