-------
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
-------
-------
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
-------
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
-------
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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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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6-8
-------
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
-------
: 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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
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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
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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
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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
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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
-------
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
-------
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.
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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.
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REFERENCES FOR CHAPTER 8
Atha, Lou, Public Accountant specializing in small businesses, telephone
conversation with Dees, Edith, TRW, 29 May 1979.
Blythe, Bob, Virginia Carolina Laundry Supply, telephone conversation with ,
Young, Dexter E., TRW, 5 December 1978.
Census of Selected Services, 1972, United States Department of Commerce,
United States Bureau of the Census, Washington, D. C. U.S. Government
Printing Office, 1976. p. 8-7, 8-19 to 8-21.
Clement, Robert, Sterling Supply Co., telephone conversation with
Karash, Susan, Energy and Environmental Analysis, Inc., 22 March iy/y.
County Business Patterns, 1976, United States Department of Commerce,
United States Bureau of the Census, Washington, D. C. U.S. Government
Printing Office, 1978.
Dees, Edie, TRW, letter to Sluizer, Bud, confirming telephone conversation
of 19 January 1979, 7 May 1979.
Davis, Durwood, Star Distribution Company, letter to Young, Dexter E., TRW,
19 August 1979.
Directory of Chemical Producers, 1977, Stanford Research Institue. Menlo
Park, California, 1978.
Faig Ken IFI Fabricare News, International Fabricare Institute, "Results
'of IFI Survey of 1978 Operating Costs," October 1979.
Fisher William E., Director of Research International Fabricare Institute,
telephone conversation with Dees, Edith, TRW, 19 January 1979.
Fisher William E., Director of Research International Fabricare Institute,
telephone conversation with Browne, Renee, Energy and Environmental
Analysis, Inc., 23 January 1979.
Fisher William E., Director of Research International Fabricare Institute,
telephone conversation with Young, Dexter E., TRW, 26 April 1979.
Fisher William E., Director of Research International Fabricare Institute,
telephone conversation with Browne, Renee, Energy and Environmental
Analysis, Inc., 17 May 1979.
Gill Ward President of the National Automatic Laundry and Cleaning Council,
'telephone conversation with Dees, Edith, TRW, 18 January 1979.
8-62
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Gill, Ward, President of the National Automatic Laundry and Cleaning Council,
telephone conversation with Browne, Renee, Energy and Environmental
Analysis, Inc., January 1979.
Gill, Ward, President of the National Automatic Laundry and Cleaning Council,
telephone conversation with Young, Dexter E., TRW, 26 April 1979.
Hansen, Lyle, VIC Manufacturing, telephone conversation with Young, Dexter E.,
TRW, 5 December 1978.
Internal Revenue Code, Commerce Clearing House, Chicago, Illinois, January 1979.
Karash, Susan, Energy and Environmental Analysis, Inc., memorandum to
Tuttle, Dan, on meeting on Perch!oroethylene Drycleaning, 17 September 1979.
Kleeberg, Charles F., US EPA, "Material Balance of Industrial Perchloro-
ethylene Dry Cleaner", test report to James F. Durham on test in
San Antonia, Texas, 17 March 1976.
Manzone, Richard, Hoyt Manufacturing, telephone conversation with Young,
Dexter E., TRW, 21 December 1978.
McMonagle, Ray, VIC Manufacturing, telephone conversation with Young, Dexter E
TRW, 20 August 1979.
Monarch, M. R., et al. Priorities for New Source Performance Standards
Under the Clean Air Act Amendments of 1977. U.S. Environmental Protection
Agency. Research Triangle Park, N.C. Publication No. EPA-450/3-78-019,
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
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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.
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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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