jaiity
Research Triangle
:andaras
Novempef 1991
afk.NC 27711
try Cl?aninq
irouncnnformation EIS
bosed Standards
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EPA-450/3-91-020A
EMISSION STANDARDS DIVISION
U.S. ENVIRONMENTAL PROTECTION AGENCY
OFFICE OF AIR AND RADIATION
OFFICE OF AIR AND QUALITY PLANNING AND STANDARDS
RESEARCH TRIANGLE PARK, NORTH CAROLINA 27711
NOVEMBER 1991
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u. s.
ENVIRONMENTAL PROTECTION AGENCY
Background Information
and Proposed Environmental Impact Statement
ana *r v Perchloroethylene from the
Dry Cleaning Industry
Prepared by:
j//f/9t
(Date)
Director -"SCion Standards Division
Environmental Protection Agency
Triangle Park, North Carolina
1.
2.
27711
" "
given in Section 112.
-
, »IT-V » T^ *. **r ^ ^^^^ ^ I
Administrators;
parties.
For additional information contact:
Mr. Bob Rosensteel
Chemicals and Petroleum Branch (MD-13)
U. S. Environmental Protection Agency
^search Triangle Park, North Carolina 27711
Telephone: (919) 541-5608
Copies of this document may be obtained from:
U S Environmental Protection Agency
Par*, North Carolina 27711
Telephone: (919) 541-2777
National Technical Information Service
5285 Port Royal Road
Springfield, Virginia 22161
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anrved fopblication. Mention of trade names or
Road, Springfield, Virginia 22161.
111
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CONTENTS
Figures
Tables
!.o gulatory Alternatives
1 2 Environmental Impact ...... .... ^_^
i\\ ^"ected^paots of ^Proposed standard^ ; ^
in 1996 .............. '..... 1-7
1 . 5 References ..... .........
2'° ff^aSgrouAd'aAd'Aitho^y'fir'siaAdirds: '. : : l-l
22 lelertion of Pollutants and Source ^
2 3 Procfdurfior ieveiopmeni of 'NESWP \ '.'... 2-6
221 ?onlide"tiln S Svlron^ntk'^^^: i ! ! 2-10
2*.6 Residual Risk Standards .....
3.0 DRY CLEANING INDUSTRY PROCESS AHD^ EMISSIONS. .... 3-1
3.1 5*;«alD;8^ripii;n'of Dry Cleaning* 3_i
Industry ........... ...... ^^
3.1.2 Solvent Types. . . . .
3.2 The HAP Dry Cleaning Process and ^ 3_3
Its Emissions ....*« ........
3.2.1 HAP Dry Cleaning Process 3_3
Description ........ CLA~~' ' ' ' 3-3
3.2.1.1 Cleaning Process Steps. ... * »
3.2.1.2 Cleaning Equipment
Characteristics ....... * '
32.2 Solvent Recovery and Purification. . . 3-6
3.2.2.1 Filtration and
Distillation. .... ^ '
3.2.2.2 Solid Waste Treatment .... J-<*
32.3 Emissions from HAP Dry Cleaning ^
^T^entiai Mission* Soured! '. 3-10
3.2.3.2 Emission Estimates. ..... 3^ii
3-3 !a;^%^icai!eSExis;ing>;gui;tions: ! '. \ 3-18
3:3.2 National Baseline Emissions. . . . ^
3.4 References. ........ '""*.**"""*
IV
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CONTENTS, Continued
4.0 EMISSION CONTROL TECHNIQUES
4.1 Hazardous Air Pollutant Emissions
from Dry Cleaning 4 ,
4.2 Methods for Controlling HAP Emissions .' 4-2
4.2.1 Methods for Controlling Process
Emissions 4_2
4.2.1.1 Carbon Adsorption .".'.'"" 4-2
4.2.1.2 Refrigerated Condensation . .* 4-4
4.2.1.3 Current Control Status. . . . 4-3
4.2.2 Methods for Controlling Fugitive
Emissions 4-10
4.2.3 Solvent Substitution ....
4.3 References ' .' ' ' 4-13
5.0 MODIFICATIONS, CONSTRUCTIONS, AND
RECONSTRUCTIONS
5.1 Background '.".'. 5 T"
5.2 Dry Cleaner Modifications ...*.' ] .' .' ." ." * 5!^
5.2.1 Solvent Switching ..".'* 5-2
5.2.2 Equipment and Operational Changes'to
the Cleaning System. . . . 5-2
5.3 Dry Cleaner Construction and «...
Reconstruction. ... c -,
5 3
6.0 MODEL MACHINES AND REGULATORY ALTERNATIVES . 6-1
6.1 Model Machines j &_1
6.1.1 Model Machines for the Coin-Operated
Sector . £_!
6.1.2 Model Machines for the Commercial*
Sector 6_3
6.1.3 Model Machines for the Industrial*
Sector 6 3
6.2 Development of Regulatory Alternatives! .' .' .' 6-4
6.2.1 Selection of Control Options ..... 6-4
6.2.1.1 Vent Control Equipment
Options 6_6
6.2.1.2 Fugitive Control Options. . . 6-6
6.2.1.3 Replacement of Transfer
Machines 6-6
6.2.2 Regulatory Alternatives " e-7
6.2.2.1 Major Dry Cleaning
Sources 6_s
... _ 6.2.2.2 Area Dry Cleaning Sources . .' 6-10
6.3 Exemption Levels 6_13
6.4 References !*""".* e-16
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CONTENTS , Continued
7.0 ENVIRONMENTAL IMPACT .... ........... ~
7.1 Air Pollution Impacts . . . . ........
7.1.1 Baseline Emissions and
Concentrations ...... ...... ~
7.1.2 Reduction in Emissions ........ '-j*
7.2 Water Pollution Impacts . . . . . ...... -Jin '
7.2.1 Potential Wastewater Impacts ..... 78
7.2.2 Major Source Dry Cleaners ..... /-»
7.2.3 Area Source Dry Cleaners ....... ' »
7 3 Solid Waste Impacts ..... "
7.3.1 Spent Carbon from Carbon Adsorbers . . 7-12
7 '.3. 2 Solid Waste Impacts from Major
Sources. . . .............
7.3.3 Solid Waste Impacts from Area ^^^
Sources. . . ............. 7-13
7.4 Energy Jryac1Saning Energy "Requirements on a
Per Machine Basis. . .......
7.4.2 Dry Cleaning Energy Requirements of
the Regulatory Alternatives ...... 7-15
7.5 References ..................
8.0 COST ANALYSIS ................... ~-
8.1 Introduction ....... ...... ,
8.2 Model Machine- Control Cost Impacts. ..... » A
8.2.1 Hazardous Air Pollutant Emission
Reduction ......... ..... J"*
8.2.2 Control Costs for Model Machines . . . »-^
8 ".2 ".3 Coin-Operated Dry Cleaning
Machines ..... **. ..... a «
8.2.4 Commercial Dry Cleaning Machines ... 8-6
8.2.5 Industrial Dry Cleaning Machines . . . 8-3
8.3 National Cost Impacts . ......... °~J
8.4 References ..................
Appendices
A. Evolution of the Background
Information Document. ..... ..........
B. Index to Environmental Impact B_i
Considerations. . ....... .......... c -
C. Emission Source Test Data ..... .....
D. Emission Measurement and Monitoring ........
vi
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FIGURES
Number
3-1 schematic of a hazardous air pollutant dry cleaning
plant.
4-1 Carbon adsorber
4-2 A refrigerated condenser as applied to a transfer
dry cleaning machine
Page
3-4
4-3
4-7
VII
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TABLES
Page
1-1 Assessment of Environmental and Economic Impacts
for Each Regulatory Alternative Considered
3-1 Total Emissions Estimates from Hazardous Air
Pollutant Dry Cleaning Plants
3-2 Hazardous Air Pollutant Emissions from Dry Cleaning
Plants ...... « .........
3-3 Emission Factors for the Dry Cleaning Industry
(kg HAP/100 kg clothes cleaned) ...........
3-4 information for Estimating Baseline Consumption and
Emissions from HAP Dry Cleaning Industry
4-1 Summary of Carbon Adsorber Test Data
6-1 Model Machine Parameters for the Dry Cleaning
Industry ..... .....
6-2 Control Options for Dry Cleaning Machines
-4-5
6-3 The Regulatory Alternative for Major Sources Subject
to the Dry Cleaning National Emission Standard for
Hazardous Air Pollutants ..............
6-4 Regulatory Alternatives for Area Sources Subject to
the Dry Cleaning National Emission Standard for
Hazardous Air Pollutants ..............
6_5
6-5 Proposed Exemption Levels of Annual Machine
Consumption for Area Sources
7-1 Estimated National Number of Hazardous Air Pollutant
Dry Cleaners at Baseline in 1991 by Machine Type . .
7-2 Estimated National Number of Hazardous Air Pollutant
Dry Cleaners at Baseline in 1991 by Source Type. . .
7-3 Regulatory Alternatives for the Hazardous Air
Pollutant Dry Cleaning NESHAP. . ...... ....
7-2
7-4
7-5
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TABLES, Continued
7-4 Emissions for Baseline and Regulatory
Alternatives I, II, and III 7.
7-5 Secondary Environmental Impacts of Regulatory
Alternatives for the Dry Cleaning Industry 7
7-6 National Energy Requirements for Each Regulatory
Alternative
7-
7-
7-7 Energy Requirements on a Per Machine Basis
8-1 Emission Factors for the Hazardous Air Pollutant Dry
Cleaning Industry (kg HAP/100 kg clothes cleaned). . 8-
8-2 Derivation of Net Annualized Costs 5-
8-3 Summary of Control Technology Costs and Cost
Effectiveness for Uncontrolled Machines
(2nd Quarter 1989 $) 8
8-4 Summary of Control Technology Costs and Cost
Effectiveness for Refrigerated-Condenser Controlled
Transfer Machines (2nd Quarter 1989 $)..... s-7
-10
14
16
3
4
-5
8-5 National Costs Impacts of Regulatory Alternatives
for HAP Dry Cleaning ' 8_
10
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1.0 SUMMARY
National emission standards for hazardous air pollutants
(NESHAP) are established under Section 112 of the Clean Air Act
(CAA) (P.L. 101-549), as amended in 1990. Section 112(b)
contains a list of 190 hazardous air pollutants (HAP's), which
are the specific air toxics to be regulated by NESHAP.
Section 112(c) directs the Administrator to use this pollutant
list to develop and publish a list of source categories for which
NESHAP will be developed. Dry cleaning facilities are included
on this source category list and were selected by EPA for NESHAP
development based on their "threat of adverse effects to health
and the environment."
This background information document (BID) supports proposed
standards for dry cleaning facilities that use one of these
listed HAP'sperchloroethylene (PCE). In general, HAP dry
cleaning facilities can be divided into three categories:
coin-operated, commercial, and industrial. Coin-operated
facilities are usually part of a laundromat. Dry cleaning is
offered at these facilities on either a self-service or an
over-the-counter basis. Commercial facilities are the local
neighborhood shops processing suits, dresses, coats, and similar
apparel. Industrial dry cleaning facilities usually clean
articles such as uniforms, work gloves, or rags. These three
categories were used to develop the regulatory alternatives and
the costs of control.
1.1 REGULATORY ALTERNATIVES
As stated in Section 112 of the CAA, major sources (those
sources emitting greater than 10 tpy of any one HAP or greater
than 25 tpy of a combination of HAP's) may be controlled to a
different level of stringency than area sources (all other
sources).
1-1
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Section 112(d)(2) states that "emission standards. . .
applicable to new or existing sources of hazardous air pollutants
shall require the maximum degree of reduction in emissions. . .
that the Administrator, taking into consideration the cost of
achieving such emission reduction, and any other nonair quality
health and environmental impacts and energy requirements,
determines is achievable. ..." Furthermore, new major sources
must be controlled to at least a level equivalent to the best
controlled similar source. Existing major sources must be
controlled at least to a level currently achieved by the average
of the best 12 percent of existing sources. For dry cleaning
facilities that are major sources, these two control levels are
identical95 percent control of vented process emissions. This
level of control would be achieved by installing either a carbon
adsorber or a refrigerated condenser on a dry-to-dry machine or
by installing a carbon adsorber on a transfer machine. This
level of control, which is called the "MACT floor," would be the
least stringent regulatory alternative for major sources.
Because more stringent controls were not identified, this level
of control is the only regulatory alternative considered for
major source dry cleaning facilities. This alternative would
also include pollution prevention practices for the reduction of
fugitive emissions.
More flexibility is allowed when controlling HAP emissions
from area sources. For area sources, standards may be
promulgated that require "generally available control
technologies or management practices." Area sources promulgated
under this authority (GACT standards) would not be subject to the
"MACT floors" described above. Three regulatory alternatives
were considered for area sources. All of these alternatives
include pollution prevention practices for the reduction of
fugitive emissions.
Regulatory Alternative I for area sources would require
95 percent control (insrallation of either a carbon adsorber or
refrigerated condenser) on a dry-to-dry machine and 85 percent
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control (installation of a refrigerated condenser) on a transfer
machine. ,
Regulatory Alternative II for area sources would require
95 percent control (installation of either a carbon adsorber or
refrigerated condenser) on a dry-to-dry machine, 95 percent
control (installation of a carbon adsorber) on a new or
uncontrolled existing transfer machine, and 85 percent control
(installation of a refrigerated condenser) on an existing
refrigerated-condenser controlled machine.
Regulatory Alternative III for area sources, which is
equivalent to MACT for major sources, would require 95 percent
control (installation of either a carbon adsorber or a
refrigerated condenser) on a dry-to-dry machine and 95 percent
control (installation of a carbon adsorber) on a transfer
machine.
in addition to the regulatory alternatives, three
applicability cut-off levels were considered for exempting that
portion of the low income sector of the dry cleaning industry
that may experience undue hardship when implementing the level of
control required by the NESHAP. The 3 low income ranges
evaluated were: less than $25,000; from $25,000 to $50,000; and
from $50,000 to $100,000. cutoffs within these ranges would
exempt a portion of the area sources, but no major sources.
1.2 ENVIRONMENTAL IMPACT
The regulatory alternative for major sources would reduce
nationwide HAP emissions from 6,700 Mg/yr to 4,600 Mg/yr in 1991.
Regulatory Alternative I for area sources would reduce
nationwide HAP emissions from 80,300 Mg/yr to 61,400 Mg/yr in
1991. Combining this with the regulatory alternative for maDor
sources would result in total reduction in HAP emissions from
87,000 Mg/yr to 66,000 Mg/yr for Regulatory Alternative I.
Regulatory Alternative II for area sources would reduce
nationwide HAP emissions from 80,300 Mg/yr to 60,400 Mg/yr in
1991. Combining this with the regulatory alternative for ma3or
sources would result in total reduction in HAP emissions from
37,000 Mg/yr to 65,000 Mg/yr for Regulatory Alternative II.
1-3
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Regulatory Alternative III for area sources would reduce
nationwide HAP emissions from 80,300 Mg/yr to 59,800 Mg/yr.
Combining this with the regulatory alternative for major sources
would result in total reduction in HAP emissions from
87,000 Mg/yr to 64,400 Mg/yr for Regulatory Alternative III.
As shown in Table 1-1, the reduction in nationwide HAP
emissions associated with any of these regulatory alternatives
would result in minimal adverse environmental impacts. There
would be negligible increases in solid waste and HAP's in
wastewater. Adopting any of these regulatory alternatives as the
proposed standard would cause a slight increase in energy
consumption due to the operation of carbon adsorbers or
refrigerated condensers.
1.3 ECONOMIC IMPACT
A detailed economic analysis of the impact of these
regulatory alternatives can be found in an accompanying document
entitled, "Economic Impact Analysis of Regulatory Controls in the
Dry Cleaning Industry," EPA-450/3-91-021.
Regulatory Alternative I would result in an increase of
approximately 120 million dollars in industry-wide capital
investment costs in 1991. The total net annualized costs
resulting from Regulatory Alternative I would be approximately
12 million dollars. The industrial sector of the dry cleaning
industry would experience a beneficial economic impact under
Regulatory Alternative I due to HAP recovery.
For Regulatory Alternative II, total capital investment
costs of controls in 1991 would be about 110 million dollars.
This cost is lower than for Regulatory Alternative I because the
capital cost of a carbon adsorber, the more stringent control, is
slightly lower than the capital cost of a refrigerated condenser.
The total net annualized costs resulting from Regulatory
Alternative II would be approximately 25 million dollars.
For Regulatory Alternative III, total capital investment
costs of controls in 1991 would be about 130 million dollars.
The total net annualized costs resulting from Regulatory
Alternative III would be approximately 30 million dollars.
1-4
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Administrative action
Regulatory Alternative for
Major Sources
Regulatory Alternative I
for Area Sources
Regulatory Alternative II
for Area Sources
Regulatory Alternative III
for Area Sources
Delayed standards
or
No standards
AND ECONOMIC
CONSIDERED
m"
Air
impact
-
+2**
+2**
+2**
+2**
-'
Water
impact
-1**
-1"
1**
.!**
_
Solid
waste impact
-1**
-1**
-1-
.)**
^
Energy
impact
_»__
-1**
-1**
-1**
-1**
Noise
impact
0
0
0
0
Economic
impact
_
1**
-1**
-I**
-3**
+1**
.!**
KEY: + = beneficial impact
- = adverse impact
0 = no impact
1 = negligible impact
2 = small impact
3 = moderate impact
4 = large impact
* = short-term impact
** = long-term impact
*** = irreversible impact
1-5
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1.4 PROJECTED IMPACTS OF THE PROPOSED STANDARD IN 1996
Based on selection of the proposed standard (Regulatory
Alternative II), the projected maximum nationwide impacts in 1996
for facilities existing in 1991 and new facilities that begin
operation between 1991 and 1996 without regard to consumption
cutoff levels are presented below.1 Impacts that include the HAP
consumption cutoff level corresponding to annual receipts of
$100,000 are also presented to illustrate the Ipwest possible
impacts that could result from this proposed standard.
With the proposed standard, total maximum nationwide HAP
emissions from new and existing dry cleaning facilities in 1996
could be reduced from 13,000 Mg to 11,300 Mg and from 60,700 Mg
to 45,700 Mg, respectively, for a total HAP reduction of
17,100 Mg. Including the consumption cutoff, nationwide HAP
emissions from new dry cleaning facilities in 1996 could be
reduced to 12,300 Mg/yr and from existing facilities to
53,000 Mg/yr, for a total HAP reduction of 8,400 Mg/yr.
Total maximum nationwide capital costs in 1996 for the
proposed standard would be approximately $63 million. Including
the consumption cutoff, nationwide capital costs in 1996 could be
as low as $26 million.
Total maximum nationwide annualized costs in 1996 for the
proposed standard would be approximately $8.4 million. Including
the consumption cutoff, nationwide annualized costs could be as
low as $2.4 million.
1-6
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1.5 REFERENCES
1. Memorandum, from Norris, C. E., and K. S. Kepford, Radian
Corporation, to Dry Cleaning NESHAP Project File.
November 1, 1991. Projected 1996 Impacts of the Proposed
Dry Cleaning NESHAP.
1-7
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2.0 INTRODUCTION
2.1 BACKGROUND AND AUTHORITY FOR STANDARDS
According to industry estimates, more than 2.4 billion
pounds of toxic pollutants were emitted to the atmosphere in 1988
Superfund Amendments and Reauthorization Act of 1986 (SARA).
These emissions may result in a variety of adverse health
effects, including cancer, reproductive effects, birth defects,
and respiratory illnesses. Title III of the Clean Air Act
.Amendments of 1990 provides the tools for controlling emissions
of these pollutants. Emissions from both large and small
facilities that contribute to air toxics problems in urban and
other areas will be regulated. The primary consideration in
establishing national industry standards must be demonstrated
technology. Before national emission standards for hazardous air
pollutants (NESHAP) are proposed as Federal regulations, air
pollution prevention and control methods are examined in detail
with respect to their feasibility, environmental impacts, and
costs. Various control options based on different technologies
and degrees of efficiency are examined, and a determination is
made regarding whether the various control options apply to each
emissions source or if dissimilarities exist between the sources.
in most cases, regulatory alternatives are subsequently developed
that are then studied by EPA as a prospective basis for a
standard. The alternatives are investigated in terms of their
impacts on the environment, the economics and well-being of the
industry, the national economy, and energy and other impacts.
This document summarizes the information obtained through these
studies so that interested persons will be able to evaluate the
information considered by EPA in developing the proposed
standards.
National emission standards for hazardous air pollutants for
new and existing sources are established under Section 112 of the
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Clean Air Act as amended in 1990 [42 U.S.C. 7401 et seq., as
amended by PL 101-549, November 15, 1990], hereafter referred to
as the Act. Section 112 directs the EPA Administrator to
promulgate standards that "require the maximum degree of
reduction in emissions of the hazardous air pollutants subject to
this section (including a prohibition of such emissions, where
achievable) that the Administrator, taking into consideration the
cost of achieving such emission reductions, and any nonair
quality health and environmental impacts and energy requirements,
determines is achievable...." The Act allows the Administrator
to set standards that "distinguish among classes, types, and
sizes of sources within a category or subcategory."
The Act differentiates between major sources and area
sources. A major source is defined as "any stationary source or
group of stationary sources located within a contiguous area and
under common control that emits or has the potential to emit
considering controls, in the aggregate, 10 tons per year or more
of any hazardous air pollutant of 25 tons per year or more of any
combination of hazardous air pollutants." The Administrator,
however, may establish a lesser quantity cutoff to distinguish
between major and area sources. The level of the cutoff is based
on the potency, persistence, or other characteristics or factors
of the air pollutant. An area source is defined as "any
stationary source of hazardous air pollutants that is not a major
source." For new sources, the amendments state that the "maximum
degree of reduction in emissions that is deemed achievable for
new sources in a category or subcategory shall not be less
stringent than the emission control that is achieved in practice
by the best controlled similar source, as determined by the
Administrator." Emission standards for existing sources "may be
less stringent than the standards for new sources in the same
category or subcategory but shall not be less stringent, and may
be more stringent than
(A) the average emission limitation achieved by the best
performing 12 percent of the existing sources (for which the
Administrator has emissions information), excluding those sources
2-2
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that have, within 18 months before the emission standard is
proposed or within 30 months before such standard is promulgated,
whichever is later, first achieved a level of emission rate or
emission reduction which complies, or would comply if the source
is not subject to such standard, with the lowest achievable
emission rate (as defined by Section 171) applicable to the
source category and prevailing at the time, in the category or
subcategory for categories and subcategories with 30 or more
sources, or
(B) the average emission limitation achieved by the best
performing five sources (for which the Administrator has or could
reasonably obtain emissions information) in the category or
subcategory for categories or subcategories with fewer than
30 sources."
The Federal standards are also known as "MACT" standards and
are based on the maximum achievable control technology previously
discussed. The MACT standards may apply to both major and area
sources, although the existing source standards may be less
stringent than the new source standards, within the constraints
presented above. The MACT is considered to be the basis for the
standard, but the Administrator may promulgate more stringent
standards, which have several advantages. First, they may help
achieve long-term cost savings by avoiding the need for more
expensive retrofitting to meet possible future residual risk
standards, which may be more stringent (discussed in
Section 2.6). Second, Congress was clearly interested in
providing incentives for improving technology. Finally, in the
Clean Air Act Amendments of 1990, Congress gave EPA a clear
mandate to reduce the health and environmental risks of air
toxics emissions as quickly as possible.
For area sources, the Administrator may "elect to promulgate
standards or requirements applicable to sources in such
categories or subcategories which provide for the use of
generally available control technologies or management practices
by such sources to reduce emissions of hazardous air pollutants."
These area source standards are also known as "GACT" (generally
2-3
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available control technology) standards, although MACT may be
applied at the Administrator's discretion, as discussed
previously.
The standards for hazardous air pollutants (HAP's), like the
new source performance standards (NSPS) for criteria pollutants
required by Section 111 of the Act (42 U.S.C. 7411), differ from
other regulatory programs required by the Act (such as the new
source review program and the prevention of significant
deterioration program) in that NESHAP and NSPS are national in
scope (versus site-specific). Congress intended for the NESHAP
and NSPS programs to provide a degree of uniformity to state
regulations to avoid situations where some States may attract
industries by relaxing standards relative to other States.
States are free under Section 116 of the Act to establish
standards more stringent than Section 111 or 112 standards.
Although NESHAP are normally structured in terms of
numerical emissions limits, alternative approaches are sometimes
necessary. In some cases, physically measuring emissions from a
source may be impossible or at least impracticable due to the
technological and economic limitations. Section 112(h) of the
Act allows the Administrator to promulgate a design, equipment,
work practice, or operational standard, or combination thereof,
in those cases where it is not feasible to prescribe or enforce
an emissions standard. For example, emissions of volatile
organic compounds (many of which may be HAP's, such as benzene)
from storage vessels containing volatile organic liquids are
greatest during tank filling. The nature of the emissions (i.e.,
high emissions for short periods during filling and low emissions
for longer periods during storage) and the configuration of
storage tanks make direct emission measurements impractical.
Therefore, the MACT or GACT standards may be based on equipment
specifications.
Under Section 112(h)(3), the Act also allows the use of
alternative equivalent technological systems: "If, after notice
and opportunity for comment, the owner or operator of any source
establishes to the satisfaction of the Administrator that an
2-4
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alternative means of emission limitation" will reduc*
of any air pollutant at least as much as would be achieved under
the design, equipment, work practice, or operational standard,
the Administrator shall permit the use of the alternative means.
Efforts to achieve early environmental benefits are
encouraged in Title III. For example, source owners and
operators are encouraged to use the Section 112(i)(5) provisions,
which allow a 6-year compliance extension of the MACT standard in
exchange for the implementation of an early emission reduction
program. The owner or operator of an existing source must
demonstrate a 90 percent emission reduction of HAP's (or
95 percent if the HAP's are particulates) and meet an alternative
emission limitation, established by permit, in lieu of the
otherwise applicable MACT standard. This alternative limitation
must reflect the 90 (95) percent reduction and is in effect for a
period of 6 years from the compliance date for the otherwise
applicable standard. The 90 (95) percent early emission
reduction must be achieved before the otherwise applicable
standard is first proposed. However, the reduction may be
achieved after the standard's proposal (but before
January 1, 1994) if prior to the proposal of the standard the
source owner or operator makes an enforceable commitment to
achieve the reduction. The source must meet several criteria to
qualify for the early reduction standard, and
Section 112(1)(5)(A) provides that the State may require
additional reductions.
2 2 SELECTION OF POLLUTANTS AND SOURCE CATEGORIES
As amended in 1990, the Act includes a list of 190 HAP's.
Petitions to add or delete pollutants from this list may be
submitted to EPA. Using this list of pollutants, EPA will
publish a list of source categories (major and area sources) for
which emission standards will be developed. Within 2 years of
enactment (November 1992), EPA is required to publish a schedule
establishing dates for promulgating these standards. Petitions
may also be submitted to EPA to remove source categories from the
2-5
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list. The schedule for standards for source categories will be
determined according to the following criteria:
"(A) the known or anticipated adverse effects of such
pollutants on public health and the environment;
(B) the quantity and location of emissions or reasonably
anticipated emissions of hazardous air pollutants that each
category or subcategory will emit; and
(C) the efficiency of grouping categories or subcategories
according to the pollutants emitted, or the processes or
technologies used."
After the source category has been chosen, the types of
facilities within the source category to which the standard will
apply must be determined. A source category may have several
facilities that cause air pollution, and emissions from these
facilities may vary in magnitude and control costs. Economic
studies of the source category and applicable control technology
may show that air pollution control is better served by applying
standards to the more severe pollution sources. For this reason,
and because there is no adequately demonstrated system for
controlling emissions from certain facilities, standards often do
not apply to all facilities at a source. For the same reasons,
the standards may not apply to all air pollutants emitted. Thus,
although a source category may be selected to be covered by
standards, the standards may not cover all pollutants or
facilities within that source category.
2.3 PROCEDURE FOR DEVELOPMENT OF NESHAP
Standards for major and area sources must (l) realistically
reflect HACT or GACT; (2) adequately consider the cost, the
nonair quality health and environmental impacts, and the energy
requirements of such control; (3) apply to new and existing
sources; and (4) meet these conditions for all variations of
industry operating conditions anywhere in the country.
The objective of the NESHAP program is to develop standards
to protect the public health by requiring facilities to control
emissions to the level achievable according to the MACT or GACT
guidelines. The standard-setting process involves three
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principal phases of activity: (1) gathering information,
(2) analyzing the information, and (3) developing the standards.
During the information-gathering phase, industries are
questioned through telephone surveys, letters of inquiry, and
plant visits by EPA representatives. Information is also
gathered from other sources, such as a literature search. Based
on the information acquired about the industry, EPA selects
certain plants at which emissions tests are conducted to provide
reliable data that characterize the HAP emissions from
well-controlled existing facilities,
in the second phase of a project, the information about the
industry, the pollutants emitted, and the control options are
used in analytical studies. Hypothetical "model plants" are
defined to provide a common basis for analysis. The model plant
definitions, national pollutant emissions data, and existing
State regulations governing emissions from the source category
are then used to establish "regulatory alternatives." These
regulatory alternatives may be different levels of emissions
control, or different degrees of applicability, or both.
The EPA conducts studies to determine the cost, economic,
environmental, and energy impacts of each regulatory alternative.
From several alternatives, EPA selects the single most plausible
regulatory alternative as the basis for the NESHAP for the source
category under study.
in the third phase of a project, the selected regulatory
alternative is translated into standards, which, in turn, are
written in the form of a Federal regulation. The Federal
regulation limits emissions to the levels indicated in the
selected regulatory alternative.
As early as is practical in each standard-setting project,
EPA representatives discuss the possibilities of a standard and
the form it might take with members of the National Air Pollution
control Techniques Advisory Committee, which is composed of
representatives from industry, environmental groups, and State
and local air pollution control agencies. Other interested
parties also participate in these meetings.
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The information acquired in the project is summarized in the
background information document (BID). The BID, the proposed
standards, and a preamble explaining the standards are widely
circulated to the industry being considered for control,
environmental groups, other government agencies, and offices
within EPA. Through this extensive review process, the points of
view of expert reviewers are taken into consideration as changes
are made to the documentation.
A "proposal package" is assembled and sent through the
offices of EPA Assistant Administrators for concurrence before
the proposed standards are officially endorsed by the EPA
Administrator. After being approved by the EPA Administrator,
the preamble and the proposed regulation are published in the
Federal Register.
The public is invited to participate in the standard-setting
process as part of the Federal Register announcement of the
proposed regulation. The EPA invites written comrents on the
proposal and also holds a public hearing to discuss the proposed
standards with interested parties. All public comments are
summarized and incorporated into a second volume of the BID. All
information reviewed and generated in studies in support of the
standards is available to the public in a "docket" on file in
Washington, D.C. Comments from the public are evaluated, and the
standards may be altered in response to the comments.
The significant comments and EPA's position on the issues
raised are included in the preamble of a promulgation package,
which also contains the draft of the final regulation. The
regulation is then subjected to another round of internal EPA
review and refinement until it is approved by the EPA
Administrator. After the Administrator signs the regulation, it
is published as a "final rule" in the Federal Register.
2.4 CONSIDERATION OF COSTS
The requirements and guidelines for the economic analysis of
proposed NESHAP are prescribed by Presidential Executive
Order 12291 (EO 12291) and the Regulatory Flexibility Act (RFA).
The EO 12291 requires preparation of a Regulatory Impact Analysis
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(RIA) for all "major" economic impacts. An economic impact is
considered to be major if it satisfies any of the following
criteria:
1 An annual effect on the economy of $100 million or more;
2 A major increase in costs or prices for consumers;
individual industries; Federal, State, or local government
agencies; or geographic regions; or
3. significant adverse effects on competition, employment,
investment, productivity, innovation, or on the ability of
U.S.-based enterprises to compete with foreign-based enterprises
in domestic or export markets.
An RIA describes the potential benefits and costs of the
proposed regulation and explores alternative regulatory and
nonregulatory approaches to achieving the desired objectives. If
the analysis identifies less costly alternatives, the RIA
includes an explanation of the legal reasons why the less costly
alternatives could not be adopted. In addition to requiring an
analysis of the potential costs and benefits, EO 12291 specifies
that EPA, to the extent allowed by the Act and court orders,
demonstrate that the benefits of the proposed standards outweigh
the costs and that the net benefits are maximized.
The RFA requires Federal agencies to give special
consideration to the impact of regulations on small businesses,
small organizations, and small governmental units. If the
proposed regulation is expected to have a significant impact on a
substantial number of small entities, a regulatory flexibility
analysis must be prepared. In preparing this analysis, EPA takes
into consideration such factors as the availability of capital
for small entities, possible closures among small entities, the
increase in production costs due to compliance, and a comparison
of the relative compliance costs as a percent of sales for small
versus large entities.
The prime objective of the cost analysis is to identify the
incremental economic impacts associated with compliance with the
standards based on each regulatory alternative compared to
baseline. Other environmental regulatory costs may be factored
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into the analysis wherever appropriate. Air pollutant emissions
may cause water pollution problems, and captured potential air
pollutants may pose a solid waste disposal problem. The total
environmental impact of an emission source must, therefore, be
analyzed and the costs determined whenever possible.
A thorough study of the profitability and price-setting
mechanisms of the industry is essential to the analysis so that
an accurate estimate of potential adverse economic impacts can be
made for proposed standards. It is also essential to know the
capital requirements for pollution control systems already placed
on plants so that the additional capital requirements
necessitated by these Federal standards can be placed in proper
perspective. Finally, it is necessary to assess the availability
of capital to provide the addition control equipment needed to
meet the standards.
2.5 CONSIDERATION OF ENVIRONMENTAL IMPACTS
Section 102(2)(C) of the National Environmental Policy Act
(NEPA) of 1969 requires Federal agencies to prepare detailed
environmental impact statements on proposals for legislation and
other major Federal actions significantly affecting the quality
of the human environment. The objective of NEPA is to build into
the decision-making process of Federal agencies a careful
consideration of all environmental aspects of proposed actions.
In a number of legal challenges to standards for various
industries, the United States Court of Appeals for the District
of Columbia Circuit has held that environmental impact statements
need not be prepared by EPA for proposed actions under the Act.
Essentially, the Court of Appeals has determined that the best
system of emissions reduction requires the Administrator to take
into account counterproductive environmental effects of proposed
standards as well as economic costs to the industry. On this
basis, therefore, the Courts established a narrow exemption from
NEPA for EPA determinations.
In addition to these judicial determinations, the Energy
Supply and Environmental Coordination Act (ESECA) of 1974
(PL-93-319) specifically exempted proposed actions under the Act
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from NEPA requirements. According to Section 7(0(1), "No action
taken under the Clean Air Act shall be deemed a major Federal
action significantly affecting the quality of the human
environment within the meaning of the National Environmental
Policy Act of 1969" (15 U.S.C. 793(c)(l)). Nevertheless, EPA
has concluded that preparing environmental impact statements
could have beneficial effects on certain regulatory actions.
Consequently, although not legally required to do so by
Section 102(2)(C) of NEPA, EPA has adopted a policy requiring
that environmental impact statements be prepared for various
regulatory actions, including NESHAP developed under Section 112
of the Act. This voluntary preparation of environmental impact
statements, however, in no way legally subjects the EPA to NEPA
requirements.
To implement this policy, a separate section included in
this document that is devoted solely to an analysis of the
potential environmental impacts associated with the proposed
standards. Both adverse and beneficial impacts in such areas as
air and water pollution, increased solid waste disposal, and
increased energy consumption are discussed.
2.6 RESIDUAL RISK STANDARDS
Section 112 of the Act provides that 8 years after MACT
standards are established, standards to protect against the
residual health and environmental risks remaining must be
promulgated, if necessary. An exception exists for those
standards established 2 years after passage of the Act: 9 years
are allowed before promulgation. In the case of area sources
controlled under GACT standards, the Administrator is not
required to conduct a residual risk review. The standards would
be triggered if more than one source in a category or subcategory
exceeds a maximum individual risk of cancer of one in 1 million.
These residual risk regulations would be based on the concept of
providing an "ample margin of safety to protect public health."
The Administrator may also consider whether a more stringent
standard is necessaryconsidering costs, energy, safety, and
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other relevant factorsto prevent an adverse environmental
effect.
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3.0 DRY CLEANING INDUSTRY PROCESS AND EMISSIONS
This chapter describes the process and emissions of the
hazardous air pollutants (HAP's) used in the dry cleaning
industry. The solvents used by the dry cleaning industry that
are considered HAP's are perchloroethylene (PCE) and
1,1,i-trichloroethane (1,1,1-TCA). Section 3.1 presents a
general description of the dry cleaning industry; Section 3.2
describes the HAP dry cleaning process and process emissions; and
baseline HAP emissions are estimated for the dry cleaning
industry in Section 3.3. References are provided in Section 3.4.
3.1 GENERAL
3.1.1 Description of Dry Cleaning Industry
The dry cleaning industry is a service industry involved in
the cleaning and, to a small extent, renting of apparel. Other
items besides apparel are also dry cleaned, including draperies
and leather goods. In 1986, there were estimated to be over
38,000 dry cleaning plants-in the United States.1 The dry
cleaning process uses an organic-based solvent to remove dirt,
grease, and other soils from clothes, industrial goods (e.g.,
uniforms, rags), and other fabric items. The primary dry
cleaning solvents are PCE and petroleum distillates. Small
quantities of 1,1,1-TCA and trichlorotrifluoroethane (CFC-113)
solvents also are used in specialty cleaning operations.2
There are currently about 35,000 HAP dry cleaning machines
comprising three sectors that are characterized by the type of
services they offer.3'4 Using the assumption that one macbdne
per plant is found in the coin-operated and industrial sectors
and 1.25 machines are found per plant in the commercial sector.
the breakdown of dry cleaning facilities per sector is as
follows: 3,000 facilities in the coin-operated sector;
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25,000 facilities in the commercial sector; and 200 facilities in
the industrial sector.5 These are commercial dry cleaners,
industrial dry cleaners, and coin-operated facilities. The
sectors vary in amount of clothing cleaned, amount of HAP's used,
size and type of dry cleaning equipment used, and type of control
techniques used. Commercial plants (SIC 7216) are the most
common type of facilities that clean soiled apparel and other
fine goods. They include small independently operated
neighborhood shops, franchise shops, and small specialty cleaners
that clean leather and other fine goods. Industrial dry cleaners
(which are included in SIC 7218) are the largest dry cleaning
plants, and primarily supply rental services of uniforms and
other items (such as rags) to business, industrial, and
institutional customers. Coin-operated facilities (SIC 7215) are
usually part of laundromats. Dry cleaning is offered at these
facilities on either a self-service or an over-the-counter
basis. They provide low-cost dry cleaning without pressing,
spotting, or associated services.
3.1.2 Solvent Types
The solvents used in dry cleaning are categorized into two
broad groups: (1) petroleum solvents, which are mixtures of
paraffins and aromatic hydrocarbons, and (2) synthetic solvents,
which are halogenated hydrocarbons, and include PCE, CFC-113, and
1,1,1-TCA. It is estimated that 82 percent of all dry cleaning
plants use PCE, 15 percent use petroleum naphtha, 3 percent use
CFC-113, and less than 1 percent use 1,1,1-TCA.2 Factors
influencing the use of each solvent are described below.
Petroleum solvents are less expensive than synthetic
solvents, but are flammable and may form explosive mixtures.
Fire regulations often prohibit their use in areas such as
shopping center locations. Chlorinated synthetic solvents are
nonflammable, and usually no location restrictions apply to their
use. The primary synthetic solvent, PCE, has aggressive solvent
properties, which make it a desirable cleaning solvent for a
variety of fabrics.
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Other synthetic solvents are less commonly used due to
properties that make them inappropriate for some dry cleaning
applications. For example, CFC-113 is a less aggressive cleaning
solvent than PCE and is more expensive. It is well suited to
cleaning delicate articles, but may not clean other types of
clothing as effectively as PCE. By comparison, 1,1,1-TCA is a
more aggressive solvent than PCE and may damage some types of
clothing. It is also more expensive than PCE.
Because of differences in solvent properties, a different
type of dry cleaning machine is necessary when using solvents
other than PCE. For example, because 1,1,1-TCA is a more
aggressive solvent, stainless steel machines are required to
prevent corrosion of the equipment parts.6 Some plants operate
multiple machines and may use two different solvents. Other
than the use of spotting chemicals or small amounts of detergent,
solvents are not combined in the dry cleaning process.7
3.2 THE HAP DRY CLEANING PROCESS AND ITS EMISSIONS
3.2.1 HAP Dry Cleaning Process Description
The principal steps in the HAP dry cleaning process are
identical to those of laundering in water, except that HAP's are
used instead of soap and water. A typical HAP dry cleaning plant
is shown schematically in Figure 3-1. The steps and machine
types used in the cleaning process are described in the
following sections.
3.2.1.1 Cleaning Process Steps. The dry cleaning process
involves the following major process steps: charging, washing,
extraction, drying, and aeration. Before the cleaning cycle
begins, a small amount of detergent and water is added to the
cleaning solvent in the charging step. The detergent and water
remove water-soluble dirts and soils from fabrics during washing
and, thus, improve the cleaning capability of the solvent.
To begin the washing step, clothes are loaded manually into
the perforated steel drum of the washer. Charged solvent
(solvent with a small amount of soap and water added) is added
and then clothes and solvent are agitated by rotation of the
drum. After the washing step is complete, the drum spins at high
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speeds to remove the solvent through perforations in the drum.
This step is called extraction.
Next, the clothes are tumbled dry for about 12 to
24 minutes.8 Depending on the type of equipment used (as
described in more detail in Section 3.2.1.2), the drying step may
take place either in the same machine in which the clothes were
washed, or in a separate dryer. In this step, recirculating warm
air causes most of the remaining solvent in the clothes to
vaporize. To reduce wrinkling, the drying cycle is followed by a
brief cool-down cycle during which unheated air is circulated
through the clothes. After cool-down, fresh ambient axr is
passed through the machine for 1 to 7 minutes to freshen and
deodorize the clothes.9 This process is called aeration. The
HAP-laden air from this step may be vented to a control -device
or emitted directly to the atmosphere.
3212 ^o*Mna Ecr^T*"* char»^ristics. There are two
basic types of dry cleaning machines used in the HAP dry cleaning
industry: transfer and dry-to-dry. Transfer machines include
two separate units, a washer and a dryer. Because the washer is
capable only of washing and extraction, clothing must be
transferred to a separate dryer for drying. Dry-to-dry machines
are designed to wash and dry clothes in a single unit,
eliminating the need to transfer clothing to a dryer.
When compared to transfer machines, dry-to-dry systems have
one potential disadvantage: a dry-to-dry operation may handle
fewer loads per day than a transfer operation. In transfer
operations, washing and drying are performed in different pieces
of equipment so these operations can occur simultaneously on
different batches of clothes. In a dry-to-dry machine, a given
batch of clothes must be washed and dried in the same machine.
Dry-to-dry machines are increasingly popular in the
industry. Elimination of the transfer of solvent-laden clothing
between the washing and drying cycles reduces the opportunity for
HAP vapors to escape into the work area. Also, dry-to-dry
machines take up less floor space, are simpler to operate, and
require less attention by the operator during the cleaning cycle.
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Currently, both transfer and dry-to-dry machines are used in
HAP dry cleaning plants. The typical type and capacity of
machines in use are different for each dry cleaning sector.
Coin-operated facilities typically have small dry-to-dry machines
with capacities of 3.6 to 5.4 kg (8 to 12 Ibs) of clothes per
load. Both transfer and dry-to-dry machines are used in the
commercial sector. However, over the past couple of years all
new machines sold to the commercial sector have been dry-to-dry
machines.10 The most common machine capacity in the commercial
sector is 35 Ibs (16 kg) of clothes per load, but sizes range
from 25 Ibs (11 kg) to over 100 Ibs (45 kg) of clothes per load.
Industrial facilities generally use larger dry-to-dry machines
with typical capacities of 140 Ibs (64 kg) or transfer machines
with typical capacities of 250 Ibs (113 kg).
One dry cleaning trade association estimates that currently
about 33 percent of all machines used by the dry cleaning
industry are transfer machines, and about 67 percent are
dry-to-dry machines.10 Recent sales information suggests that
the industry is shifting toward the use of more dry-to-dry
machines. In 1986, equipment manufacturers reported that dry
cleaning facilities purchased about 2,000 dry-to-dry machines,
but only about 400 transfer machines.H-20 Recent vendor
discussions indicate that no new transfer machines are being
sold. Accounting for this trend, the 1991 estimates reflect that
about 30 percent of all machines are transfer machines and the
remaining 70 percent are dry-to-dry machines.4
3-2.2 Solvent Recovery and Purification
Efficient operation of dry cleaning plants necessitates at
least partial recovery and reuse of used solvent. As shown in
Figure 3-1, there are several pieces of auxiliary equipment used
at most dry cleaning plants for recovery and purification of
HAP's. These include filters that remove dirt from the HAP's
circulating through the washer, and stills that purify the HAP's
by distillation. This section describes filtration and
distillation processes and equipment, and the solid wastes
generated by these processes.
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3.2.2.1 Filtration * r^filiation. When HAP's are
removed from the washer during extraction, the solvent contains
dirt and soils removed from the clothing. If these impurities
are not removed from the solvent, with solvent reuse they may be
redeposited on clothing. Filtration and distillation are two
methods used to purify HAP's prior to reuse.
As shown in Figure 3-1, dirty HAP's from the washer are
typically passed through a filtration system. The filtration
process removes most insoluble soils, nonvolatile residue, and
loose dyes. Most dry cleaning operations use some sort of
solvent filtration, and thereby extend the useful life of the
solvent.
Two main types of filters are used: (1) tubular or
regenerative filters, and (2) cartridge filters. In tubular and
regenerative filters, diatomaceous earth and activated carbon
usually form the filter element. The filter element is removed
each day and replaced with new diatomaceous earth and activated
carbon. Cartridge filters have a filter medium of activated
carbon or activated carbon and clay. Certain types of cartridge
filters also have a filter element of pleated filter paper. All
cartridge filters are disposable. It is estimated that about
90 percent of all plants use some sort of cartridge
filtration, whereas about 10 percent use tubular or regenerative
fliters.21
Following filtration, the filtered solvent may either flow
back to the solvent base tank or to the distillation unit
(Figure 3-1). Distillation removes soluble oil, fatty acids,
greases from the solvent that are not removed by filtration. If
not removed, these residues can accumulate in the solvent, and
upon solvent reuse can cause improper cleaning of clothes.
Conseguently, solvent distillation is performed on-site by
80 percent of all cleaners to extend their solvent mileage.7
Atmospheric pressure stills are used to distill HAP's.7
Typically, the solvent and nonvolatile residue are heated with
steam to 120°C (250°F). At this temperature, the HAP is
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vaporized and mixed with the steam. The vapors then pass through
a condenser, where the HAP/water vapor mixture is condensed
and subsequently separated in a water separator. The purified
HAP's are then sent back to the solvent storage tank.
3.2.2.2 Solid Waste Treatment. Both filtration and
distillation generate solid wastes that contain HAP's. Some
plants further treat solid wastes on-site to maximize HAP
recovery and minimize solid waste disposal costs. The cost of
solid waste disposal ranges from $11 per standard waste cartridge
to $35 for a 14-gallon drum of still residue.1 The average
annual solid waste disposal costs for a typical 35-lb machine
would be about $1,500.22
Regenerative and tubular filters generate solid wastes in
the form of filter "muck". Filter muck is the sludge that builds
up on the filter as the insoluble soils, nonvolatile residue, and
loose dyes are removed from the dirty solvent.7 Solid waste also
includes the filter powder (diatomaceous earth and activated
carbon) that forms the filter element. Both the filter muck and
filter powder contain HAP's. Therefore, some HAP plants have a
still called a muck cooker that cooks the solvent out of the
solid waste prior to disposal. It is estimated that the muck
cooker can reduce the amount of solvent lost in filter material
by about 90 percent. Hazardous air pollutants recovered by the
muck cooker are condensed, separated, and then returned to the
solvent storage tank.
For plants with a cartridge filtration system, solid waste
is generated in the form of spent filter cartridges that contain
HAP's. The HAP losses from the used cartridges can be minimized
by draining the filters in their housing.23 Some plants may also
steam strip the cartridges prior to disposal to recover more
solvent.
Distillation generates solid waste in the form of
distillation bottoms. The so-called "still bottoms" consist of
the solid residue remaining in the still after the HAP's have
vaporized. This waste contains highly contaminated solvent and
nonvolatile residue. The waste may contain as much as 50 percent
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HAP by weight.7 solvent losses from distillation bottom disposal
can be reduced in oil cookers (similar to muck cookers) to levels
as low as 1 kg/100 kg (1 lb/100 Ib) of wet waste material.24 The
HAP's recovered by the cooker may be returned to the solvent
storage tank.
The HAP-laden solid wastes generated by filtration and
distillation are considered hazardous wastes under the Resource
conservation and Recovery Act (RCRA).25 Dry cleaning plants that
generate 100 kg (220 Ib) or more a month of hazardous wastes are
regulated under RCRA and must dispose of their wastes at a
licensed hazardous waste treatment or disposal facility. Most
coin-operated plants generate less than 100 kg/month
(220 Ib/month) of hazardous wastes and, therefore, are
conditionally exempt from the RCRA regulations. In contrast,
most commercial and industrial plants generate between
100 kg/month (220 Ib/month) and 1,000 kg/month (2,200 Ib/month)
of hazardous wastes; these plants are regulated as small-quantity
generators under RCRA.7
Because of the RCRA regulations, the use of contract
disposal services that recycle waste HAP's is becoming more
common. Typically, these contract disposal services pick up
HAP-contaminated solid wastes such as drained spent cartridge
filters, still bottoms, and filter muck from the dry cleaner.
The HAP's are subsequently recovered from these wastes and
purified. After the HAP's have been recovered, the solid wastes
contain less than 1,000 ppm HAP's and are landfilled in a
licensed facility. It is estimated that 85 percent of the waste
HAP solvent that is picked up by contract disposal services is
recycled back to the dry cleaning industry. (The remaining
15 percent is sold for other uses).2
3.2.3 Emissions from HAP Drv Cleaning Equipment
This section contains a brief description of the potential
HAP emission sources from transfer and dry-to-dry cleaning
equipment. Estimates of HAP emissions from dry cleaning
facilities with and without control devices are also presented.
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3.2.3.1 Potential Emission Sources. Process emissions
include vented emissions and fugitive emissions. Vented
emissions include losses during aeration and emissions ducted
through the stack during loading and unloading of clothing.
There are no vented emissions during other parts of the dry
cleaning cycle (i.e., wash cycle, dry cycle) because exhaust
gases are not
vented to the atmosphere during those operations.8
There is a high concentration of HAP's in the tumbler during
the dry cycle due to vaporization, but the HAP-laden drying air
stream is condensed by the water condenser and recycled to the
tumbler, with no exhaust gas stream vented to the atmosphere.
The aeration cycle occurs immediately after the dry cycle and
lasts between 1 and 7 minutes. During aeration, fresh air is
drawn into the tumbler, and residual HAP's are evaporated from
the clothes. The HAP-laden aeration air stream is vented to a
control device or emitted directly to the atmosphere. Thus,
there is a higher potential for HAP emissions during aeration
than during any other part of the dry cleaning process.
Other vented HAP emissions occur while clothes are being
transferred from the washer to the dryer (in the case of
facilities with transfer machines), and from the dryer to baskets
in the plant. Most machines are equipped with inductive fans
that are turned on when the washer and dryer doors are opened to
divert the HAP-laden vapors away from the dry cleaning machine
operators. The gas stream is then either vented directly through
the stack or through a control device. Finally, vented HAP
emissions may occur from distillation units and muck cookers,
when present. The HAP-laden vapors from these units pass through
a condenser, with the remaining vapors vented either into the
room, directly out the stack, or through a control device.
Fugitive emissions include HAP losses from leaky process
equipment (pumps, valves, flanges, seals, etc.) and in-plant
evaporative losses of HAP's during clothing transfer and
handling. Other potential emissions include losses from chemical
and water separators, and solid waste storage. Listed
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below are common emission areas for liquid leaks and vapor
leaks.26
Liquid leakage areas include:
Hose connections, unions, couplings, and valves;
machine door gasket and seating;
filter head gasket and seating;
pumps;
base tanks and storage containers;
water separators (lost in water due to poor
separation);
filter sludge recovery (lost in sludge by improper
recovery);
distillation unit;
divertor valves;
saturated lint from lint baskets; and
cartridge filters.
Vapor leakage areas include:
Deodorizing and aeration valves on dryers (the seals on
these valves need periodic replacement);
air and exhaust ductwork (solvent lost through tears in
duct);
doors (when left open, doors are a problemleaks in
the system should be confined to the closed washer
and/or dryer, if possible);
button traps and lint baskets (these should be opened
only as long as necessary);
open containers of solvent;
evaporation from wet wash during the transfer process;
and
removal of articles prior to complete drying.
3.2.3.2 Emission Estimates. This section presents
estimated emissions from controlled and uncontrolled HAP dry
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cleaners. The emission estimates presented in this section are
based on a limited number of emission tests conducted by EPA and
the International Fabricare Institute (IFI), and on the results
of a 1987 survey of dry cleaning solvent consumption conducted by
the Alliance of Textile Care Associations (ATCA). Tests were
conducted using PCE as a representative HAP solvent.
Emissions from a dry cleaning machine vary according to the
type and size of machine and what type of vent control (if any)
is present. In addition, variations in operating, maintenance,
and housekeeping practices can affect the amount of HAP
emissions.
The ATCA has compiled data on "solvent mileage" for 129 dry
cleaning machines.27 Solvent mileage refers to the amount of
solvent consumed by a dry cleaner to clean a given weight of
clothing. Because all of the HAP's consumed during the dry
cleaning process are eventually emitted to the atmosphere,
solvent mileage data can be used to estimate emissions of HAP's
from a dry cleaning machine in terms of kg of HAP emitted per
100 kg of clothes cleaned.
The solvent mileage data compiled by ATCA are summarized in
Table 3-1. As shown, these data represent a range of machine
types, sizes, and vent controls.
Based on the solvent mileage data presented in Table 3rl,
emissions from uncontrolled transfer machines are estimated to
range from 6.29 to 14.0 kg HAP/100 kg clothes, whereas emissions
from uncontrolled dry-to-dry machines are estimated to range from
4.38 to 14.0 kg HAP/100 kg clothes. With vent controls, transfer
machine emissions are estimated to be 5.85 to 7.0 kg HAP/100 kg
clothes (refrigerated condensers) or 3.37 to 12.48 kg HAP/100 kg
clothes (carbon adsorbers). For dry-to-dry machines with vent
controls, emissions are estimated to be 2.91 to 12.94 kg
HAP/100 kg clothes (refrigerated condensers) or 3.26 to 14.0 kg
HAP/100 kg clothes (carbon adsorbers).
3-12
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TABLE 3-1. TOTAL EMISSION ESTIMATES FROM HAZARDOUS
TABLt, J JL POLLUTANT DRY CLEANING PLANTS27
Machine description
«^-«i^^
Transfer
Uncontrolled
Refrigerated-condenser
controlled
Carbon-adsorber controlled
Dry-to-Drv
Uncontrolled
Refrigerated-condenser
controlled
Sizes of
Number of machines
machines surveyed
surveyed
6
4
23
19
53
carbon-adsorber controlled 24
30-65
30-50
30-70
25-50
25-70
30-75
Total
emissions
(kg HAP/
100 kg
clothes
cleaned)
6.29-14.00
5.85- 7.00
3.37-12,48
4.38-14.00
2.91-12.24
3.26-14.00
3-13
-------
The emission estimates based on solvent mileage data in
Table 3-1 represent total emissions from all sources within a dry
cleaning facility, including the following:
Vented emissions from washers and dryers;
solid wastes; and
miscellaneous emissions (fugitive emissions, aqueous
emissions, and vented emissions from distillation units
and muck cookers).
The relative contribution of these sources to the total HAP
emissions from a dry cleaning facility can be determined from the
results of emission tests conducted by EPA and IFI. The EPA
conducted emission tests on five dry cleaning plants, including
one industrial and four commercial facilities.24/28"34 The
emission tests measured the total HAP's consumed, the HAP's
vented from the dry cleaning machine, and the HAP's retained in
certain solid wastes. These tests are fully described in
Appendix C of this document. The IFI compiled data from an
unknown number of tests that represent average HAP losses at
various stages of the dry cleaning process for a well-operated
and well-maintained dry cleaning machine.35
Table 3-2 summarizes the results of the emission tests
conducted by EPA and IFI. Overall, the emission estimates .
suggest that vented process emissions from uncontrolled dry
cleaning machines contribute significantly to total solvent
emissions. According to the EPA test data, process emissions for
an uncontrolled machine range from 30 to 80 percent of the total
emissions. For a controlled machine, process emissions
contribute a much smaller portion of the total solvent emissions
(i.e., 0.1 to 4 percent, according to EPA test data for
carbon-adsorber controlled machines).
The amount of HAP emissions associated with solid wastes
varies considerably depending on the type of filtration and
distillation operations used by the dry cleaner. The EPA test
data indicate that solid waste emissions contribute 0.3 to
3-14
-------
TABLE 3-2. HAZARDOUS AIR POLLUTANT EMISSIONS
FROM DRY CLEANING PLANTS24,28-34
ource
asher and Dryer
Uncontrolled vented emissions
Controlled vented emissions
olid Wastes*1
Solvent emissions'1
(kg HAP/100 kg
of clothing)
3.3-23.0b
0.002-0.97°
Percent of
total Missions
30-80
0.1-4
0.3-26*
1.1-37*
Solvent emissions
(kg HAP/100 kg Percent of
of clothing total emissions
3.52
0.27
*Mh
*/*
Oil cooker residue
Muck cooker residue
Drained cartridge filter
0.26
0.96
.
paper cartridge filters
with carbon core
activated clay cartridge
filter
Miscellaneous
0.6
2.73
0.82-4.649
3-43«
39-98f
0.95-1.63
1.76
2.85
solvent losses are presented as the range of solvent lot.e, observed men, the test plants. When a single number f.
given for a solvent loss, data Mere available from only one test plant.
bAs indicated by the HAP concentration at the carbon adsorber inlet.
CThese emissions were controlled by a carbon adsorber.
dSolvent retained in discarded solid wastes.
ePercent of total uncontrolled emissions.
^Percent of total controlled emissions.
8los.es from miscellaneous sources were derived for each plant by «"btrscting "££«££«* losses Vented *re"' '***
washer and/or dryer and retained in the treated solid wastes from the total solvent losses.
hThese percentages carrot be calculated for these data because the solvent -J-JJ",^^ 'verage V8lUCS far 3"
unknowrTnumber of plants. A single plant would not gerwr.te all of the emissions listed here.
3-15
-------
26 percent of total uncontrolled emissions and 1.1 to 37 percent
of total controlled emissions.
The remaining emissions from dry cleaners occur from a
variety of miscellaneous sources including fugitive emissions,
losses from water separators, and vented emissions from
distillation units and muck cookers. According to the EPA tests,
these sources account for 3 to 43 percent of total uncontrolled
emissions and 39 to 98 percent of total controlled emissions.
Data available from the emission tests conducted by EPA and
IFI are insufficient for distinguishing between the amount of HAP
emissions contributed by transfer machines versus dry-to-dry
machines. In general, the relative contribution of emissions
from process vents and solid wastes are not expected to differ
between the two types of machines. For transfer machines,
however, a potentially large source of miscellaneous emissions is
the clothing transfer step. This step is eliminated in
dry-to-dry equipment. Occupational exposure data compiled by the
EPA Office of Pesticides and Toxic Substances and IFI have shown
that worker exposure levels are as much as 50 percent less in
facilities with dry-to-dry equipment compared to facilities with
transfer equipment.36"38 on this basis, it has been assumed that
the amount of fugitive emissions associated with dry-to-dry
machines is roughly half that emitted from transfer machines.
The test results summarized in Tables 3-1 and 3-2 were used
to develop model emission factors for the dry cleaning industry.
These factors are presented in Table 3-3, and their derivation is
described in a background technical memorandum.39 This table
does not present the solid waste factor, which was determined to
be 2.5 kg HAP/100 kg clothes cleaned.39
The emission factors found in Table 3-3 were used to
determine national baseline emissions, as described in
Section 3.3.2.
3.3 BASELINE EMISSIONS
The baseline emission level is the level of emission control
achieved by the affected industry in the absence of additional
EPA standards. The baseline emission level is established to
3-16
-------
TABLE 3-3,
EMISSION FACTORS FOR THE DRY CLEANING INDUSTRY
(kg HAP/100 kg clothes cleaned)39
M====
Dry-to-Dry
Uncontrolled
Process
Fugitive
Total
pof TI nprated Condenser Controlled
Process
Fugitive
Total
Carbon Adsorber-Controlled
Process
Fugitive
Total
3.1 4
2.5 1>
5.6 9
0.2 0.6
2.7 5.6
0.2 0.2
2.7 5.2
Note- Solid waste emissions are not shown because the wastes
Note. a^^r^^rted off site for disposal. Therefore, any
air emissions from solid waste disposal are not
attributed to a dry cleaning machine.
3-17
-------
facilitate comparison of economic, energy, and environmental
impacts of regulatory alternatives.
This section includes a summary of the existing regulations
limiting HAP emissions from dry cleaning plants and a discussion
of the logic and rationale leading to the selection of the
baseline emission level.
3.3.1 Applicable Existing Regulations
No Federal regulations limit emissions from HAP dry
cleaners, except for Occupational Safety and Health
Administration (OSHA) standards, which pertain to occupational
exposure to PCE.40 Regulations limiting PCE emissions to the
ambient air exist primarily at the State level, and occasionally
at the local level.
The rules and regulations set forth by OSHA on dry cleaning
solvent vapors were first published in August 1971; the final
rule was published in 1989 (29 CFR part 1910). The OSHA
standard only applies to levels of PCE that workers may be
-exposed to within the plant. The current OSHA standard for
occupational exposure is 23 ppm for an 8-hour, time-weighted
average.40
In 1978, EPA issued a Control Techniques Guideline (CTG)
document for PCE dry cleaners.4* This document establishes
reasonably available control technology (RACT) guidelines, which
have been used by State agencies to develop State Implementation
Plans (SIP's). Reasonably available control technology is
defined as the lowest emission limit that a particular source is
capable of meeting by applying control technology that is
reasonably available considering technological and economic
feasibility. When requested to apply RACT as outlined in the
CTG, a dry cleaning facility would have to (1) reduce the dryer
outlet concentration of PCE to less than 100 ppm, (2) vent the
entire dryer exhaust through a carbon adsorber or equally
effective control device, (3) eliminate liquid leaks, (4) limit
gaseous leaks to a specified level, (5) cook filter muck so that
the waste contains no more than 25 kg PCE per 100 kg of wet waste
3-18
-------
(25 Ib PCE per 100 Ib of wet waste), (6) operate a still so that
the residue contains no more than 60 kg PCE per 100 kg of wet
waste (60 Ib PCE per 100 Ib of wet waste), and (7) drain filter
cartridges for at least 24 hours before disposal.42
As of 1985, 23 States had adopted RACT regulations for PCE
dry cleaners.43 Normally, RACT regulations are only required in
those areas in violation of National Ambient Air Quality
Standards (NAAQS). At least 12 States, however, have adopted
RACT statewide.44 some local counties and municipalities have
also enacted ordinances to control dry cleaning emissions.
For example, in Arizona, the Maricopa County Bureau of Air
Pollution Control requires the use of a vapor adsorber or a
condensing system with an inlet temperature of less than.-296°K
(72°F) for all chlorinated hydrocarbons.43
3.3.2 National Baselin" Emissions
For the dry cleaning source category, national baseline
emissions are estimated from emission factors applied to model
machine throughputs, according to machine population data and
solvent sales information.45 The total amount of HAP's consumed
by the dry cleaning industry includes both fresh HAP's consumed
and recycled HAP's consumed. Based on information provided by a
major waste recycler, about 5 million gallons or 30,600 Mg/yr
(67,500,000 lb/yr) of HAP's are carried off site in dry cleaning
waste materials.46 several recycling firms pick up about
85 percent of this HAP waste, and charge a fee for this .service.
About 6,100 Mg/yr (13,450,000 lb/yr) of the HAP's are recovered
from this collected dry cleaning waste, purified, and then sold
back to the dry cleaning industry.46 The unrecycled waste is
disposed of as required under the RCRA.
Based on 1989 sales information from the Chemical Marketing
Reported (CMR), annual fresh solvent consumption for 1991 is
estimated to be 124,000 Mg/yr (273,370,000 lb/yr).44 when adding
this fresh solvent consumption to the 6,100 Mg (13,450,000 Ib) of
recycled HAP's indicated by the major waste recycler,45 the total
HAP's consumed by the dry cleaning industry in 1991 are estimated
to be 130,100 Mg/yr (286,820,000 lb/yr).
3-19
-------
Model machine calculations (emission factors applied to
throughputs) indicate total consumption in 1991 to be
125,250 Mg/yr (276,130,000 lb/yr).47 Because the model machine
scenario is only a simulation of actual machine populations, the
model machine value for national consumption was scaled up to the
CMR/waste recycler value by multiplying by 1.039. This same
scaling factor was applied to model machine emissions (process
vent and fugitive) and solid waste emissions to reflect current
sales information more accurately.
Table 3-4 presents the estimates of national baseline
consumption and emissions for the three different sectors of the
dry cleaning industry.45 National HAP consumption for each
sector was calculated as the sum of recycled HAP's and fresh
HAP's used by that sector. Although the total amount of recycled
HAP's used in dry cleaning is known, the amount of recycled HAP's
used by each sector is not known. Therefore, it was assumed that
the percentage of recycled HAP's used in the commercial and
industrial sectors is equivalent to the percentage of fresh HAP's
used in those sectors. Further, it was assumed that no recycled
HAP's are sold to the coin-operated sector because no HAP waste
is collected from them.
The HAP's emitted from process vents or fugitive sources, or
found in solid wastes are based on the application of the
emission factors described in Section 3.2.3.2 to model machines.
National HAP emissions from each source type were determined by
first summing the model machine estimates and then applying the
above-mentioned scaling factor.
The total HAP's in waste materials disposed of off site was
based on a solid waste HAP emission factor of 2.5 kg HAP/100 kg
clothes cleaned.39 This emission factor was based on the EPA and
IFI tests discussed in Section 3.2.3.2. The value of
2.5 kg/100 kg clothes cleaned falls within the ranges indicated
by the test data. The solid waste emission factor was applied to
model machine populations and clothing throughputs. The
resultant was then scaled up to reflect national consumption
3-20
-------
figures. The resulting national estimates for off-site HAP
disposal are shown in Table 3-4.
Baseline estimates of on»site air emissions for each sector
are calculated in a similar way, using emission factors specific
to a given machine and control type. A detailed description of
these calculations is presented in a background technical
memorandum on national baseline emissions.« For the dry
cleaning industry as a whole, the baseline emission estimates are
equivalent to the amount of HAP's consumed by that sector minus
the HAP's contained in wastes disposed of off site.
3-21
-------
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4
8
3.4 REFERENCES
i Meeting summary, meeting between Safety-Kleen, Radian
cSroSrati and U. S. Environmental Protection Agency.
Novlmblr 25, ?986. Research Triangle Park, North Carolina.
2. Ref. 1, p. 3.
3 Letter from Vitek, F., Coin Launderers Association, to Bath,
Letter "om c 'raiion. May 15, 1986. Estimates of the
D. B., Radian ^pura * coin-ooerated facilities.
B Radian Corporaton. ay , .
number or dr? coining machines at coin-operated facilities.
Memorandum from Norr is, C. E. , and K. S. Kepford, Radian
corporation, to Dry Cleaning NESHAP Project file. ^
M^rch f 9 , ?99l? Documentation of Growth Rates for the Dry
Cleaning Industry.
Memorandum from Norr is, C. E. , and K. S. Kepford, Radian
Dry Cleaning NESHAP.
Meeting summary, meeting between the International Fabricare
7. Ref. 1, Attachment 3.
Cleaning Dryer Control Techniques.
9. Ref. 8, Table 1.
10 Meeting summary, meeting between the International Fabricare
10. Meetingt;adjan corporation, and U. S. Environmental
M ,
Protection Agency. March 28, 1991. Silver Spring,
Maryland.
11 Letter with attachment from Rooney, S. D., Hoyt Corporation,
tSw^tt, S. R., EPA/CPB. October 28, 1986. Response to
Section 114 Questionnaire.
12. Letter with attachment from Cropper, P., VIC Manufacturing
Company, to Wyatt, S. R., EPA/CPB. December 10, 1986.
Response to Section 114 Questionnaire.
13 Letter with attachment from Krenmayer, R., Hoyt Corporation,
to Sjatt. S. R., EPA/CPB. December 19, 1986. Response to
Section 114 Questionnaire.
14. Letter with attachment from Scapelliti, J., Detrex
Corporation to Wyatt, S. R., EPA/CPB. December 23, 198o.
Response to Section 114 Questionnaire.
3-23
-------
15.
16.
17.
18.
19.
20.
21.
22
23.
24.
25.
26.
27.
Letter with attachment from King, C. , Kleen-Rite,
Incorporated, to Wyatt, S. R. , EPA/CPB. December 1986.
Response to Section 114 Questionnaire.
Letter with attachment from Compter, G. , Multimatic
Corporation, to Wyatt, S. R. , EPA/CPB. January 27, 1987.
Response to Section 114 Questionnaire.
Letter with attachment from Holland, A. , Wascomat of
America, to Wyatt, S. R. , EPA/CPB. February 18, 1987.
Response to Section 114 Questionnaire.
Bolton Equipment
February 19, 1987.
Letter with attachment from Petrov, W. ,
Corporation, to Wyatt, S. R. , EPA/CPB.
Response to Section 114 Questionnaire.
Letter with attachment from Cleator, H". M. , American Permac,
Incorporated, to Wyatt, S. R. , EPA/CPB. February 19, 1987.
Response to Section 114 Questionnaire.
Letter with attachment from Mitchell, B. , Miraclean/Miracle
Core, to Wyatt, S. R. , EPA/CPB. March 1987. Response to
Section 114 Questionnaire.
International Fabricare Institute, IFI's Equipment and Plant
Operations Survey. Focus on Dry Cleaning. Volume 13,
Number 1. March 1989.
Telecon. Kepford, K. S., Radian Corporation, with Bovari,
R. , Safety Kleen. June 11, 1991. Discussion of solid waste
disposal costs for a typical dry cleaner.
U. S. Environmental Protection Agency. Perchloroethylene
Dry Cleaners Background Information for Proposed Standards.
Publication No. EPA-450/3-79-029a. Research Triangle Park,
North Carolina. August 1980. p. 3-5.
Test report, from Kleeberg, C. , EPA/ISB, to Durham, J. ,
EPA/CPB. May 14, 1976. Testing of Industrial
Perchloroethylene Dry Cleaners: San Antonio, Texas report.
U. S. Environmental Protection Agency. Code of Federal
Regulations. Title 40, Parts 250-265. Washington, DC.
U. S. Government Printing Office. July l, 1990.
Dow Chemical. Poor Solvent Mileage - Professional Dry
Cleaning Plants. Enclosed in letter from Lundy, R. , Dow
Chemical to Kleeberg, C. F. , EPA/ISB. March 16, 1976.
Letter from Stoll, B. J. , Alliance of Textile Care
Associations, to Wyatt, S. R. , EPA/CPB. January 4, 1988.
3-24
-------
28.
29.
30.
31.
32.
33.
34.
35.
36.
37.
38.
39.
40.
Test report, from Kleebers, C., EPA/ISB, to Durham, J.,
EPA/CPB. March 17, 1976. Testing of Commercial Dry
Cleaners: Hershey, Pennsylvania test report.
Scott Environmental Technology, Inc., A Survey of
Perchloroethylene Emissions from a Dry Cleaning Plant:
. Hershey, Pennsylvania. Test Number 76-DRY-l. March 1976.
Midwest Research Institute. Test of Industrial Dry Cleaning
operation at Texas Industrial Services, San Antonio, Texas.
Test Number 76-Dry-2. April 28, 1976.
Test report, from Kleeberg, C., EPA/ISB, to Durham, J.,
EPA/CPB. May 17, 1976. Testing of Commercial
Perchloroethylene Dry Cleaners: Kalamazoo, Michigan test
report.
Midwest Research Institute. Source Test of Dry Cleaners.
Test Number 76-DRY-3. June 25, 1976.
Test report, from Jongleux, R. F., TRW, Inc., to EPA/EMB.
November 1979. Publication EMB 79-DRY-6. Perchloroethylene
Emissions Testing at Kleen Korner, Cortland, New York.
Test report, from Jongleux, R. F., TRW, Inc., to EPA/EMB.
Publication EMB 79-DRY-7. April 1980. Materials Balance
Test - Perchlroethylene Refrigerated Closed system,
Northvale, New Jersey.
Fisher, W. E. The IFI Special Report: The ABC's of Solvent
Mileage Part One. International Fabricare Institute:
Volume 3, Number 4. July-August 1975.
Memorandum from Burch, W. M., EPA/OPTS, to DeSantis, J.,
EPA/CSCC. August 5, 1987. Revised Dry Cleaning
Occupational Exposure Information.
Memorandum from Burch, W. M., EPA/OPTS, to DeSantis, J.,
EPA/CSCC. August 18, 1987. Revised Dry Cleaning
Occupational Exposure Information.
Memorandum from Burch, W. M., EPA/OPTS, to DeSantis, J.,
EPA/CSCC. October 16, 1987. Revised Commercial Dry
Cleaning Tables.
Memorandum from Norris, C.E., and K. S. Kepford, Radian
Corporation, to HAP Dry Cleaning Project File.
December 14, 1990. Documentation of Revised Emissions
Factors for the Dry Cleaning Industry.
U. S. Department of Labor. Code of Federal Regulations,
Title 20, Part 1910. Occupational Safety and Health
Administration. Air Contaminants; Final Rule. Washington,
D. C. U. S, Government Printing Office. January 1989.
3-25
-------
41. U. S. Environmental Protection Agency. Control of Volatile
Organic Emissions from Perchloroethylene Dry Cleaning
Systems. Publication No. EPA-450/2-78-050. Research
Triangle Park, North Carolina. December 1978. 68 p.
42. Ref. 40, p. 6-1, 6-2.
43. Meech, H. L., Shareef, S. A., and Alexander, M. W., Radian
Corporation. Source Assessment of Perchloroethylene
Emissions. Prepared for U. S. Environmental Protection
Agency. Research Triangle Park, North Carolina.
EPA Contract No. 68-02-3816. May 1985.
44. Ref. 42, p. B-2.
45. Memorandum from Norris, C. E., and K. S. Kepford, Radian
Corporation, to Dry Cleaning NESHAP File.
December 14, 1990. p. 5. Documentation of Revised Baseline
Emissions for the Dry Cleaning Source Category.
46. Telecon. Norris, C. E., Radian Corporation, with
Bovari, R., Safety Kleen. May 9, 1991. Discussion of PCE
solid waste estimates.
47. Memorandum from Norris, C. E., and K. S. Kepford, Radian
Corporation, to Dry Cleaning NESHAP Project File.
December 14, 1990. Revised Estimates of National Hazardous
Air Pollutant Consumption by the Dry Cleaning Industry.
p. A-2.
48. Ref. 44, p. A-l.
3-26
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4.0 EMISSION CONTROL TECHNIQUES
This chapter presents a summary of methods for controlling
hazardous air pollutant (HAP) emissions from the dry cleaning
process. Operating principles, emissions and solvent usage
reductions, and retrofit considerations are discussed for
various control techniques. Section 4.1 describes HAP emission
sources during the dry cleaning process; Section 4.2 describes
methods for controlling HAP dry cleaning emissions. References
are provided in Section 4.3.
4.1 HAZARDOUS AIR POLLUTANT EMISSIONS FROM DRY CLEANING
As discussed in Section 3.2.3, HAP emissions occur at a
number of different points in dry cleaning systems, and can be
characterized as either vented process emissions or fugitive
emissions. Vented process emissions include losses during
aeration, emissions ducted through the stack during clothing
transfer, and emissions vented from equipment such as muck
cookers and distillation units. There are no vented process
emissions during other parts of the dry cleaning cycle (i.e.,
wash cycle, dry cycle) because exhaust gases are not vented to
the atmosphere during those operations. Exhaust gases are also
not vented to the atmosphere from some types of no-vent
dry-to-dry machines and no-vent control devices. These are
discussed in Section 4.2.1.2. Control techniques for vented
process emissions are described in Section 4.2.1.
Fugitive emissions include HAP losses from leaky process
equipment (pumps, valves, flanges, seals, etc.), emissions of
HAP's from spent cartridge filters and HAP-laden solid waste, and
in-plant evaporative losses of HAP's during clothing transfer and
handling. Control techniques for fugitive emissions are
discussed in Section 4.2.2.
4-1
-------
4.2 METHODS FOR CONTROLLING HAP EMISSIONS
4.2.1 Methods for Controlling Process Emissions
The two demonstrated emission control techniques used by the
dry cleaning industry for vented process emissions are carbon
adsorbers and refrigerated condensers.1 These techniques are
discussed in the following sections in terms of their operating
principles, applicability, and emissions and solvent usage
reductions.
4.2.1.1 Carbon Adsorption. Activated carbon is used in
many applications for the removal, by adsorption, of organic
compounds from carrier gases (usually air). It has been used
extensively by the dry cleaning industry to recover HAP's from
vented emissions during the aeration step. The carbon adsorber
can be retrofitted to- both dry-to-dry and transfer machines.
Figure 4-1 illustrates the operating principles of a carbon
adsorber. The activated carbon used in carbon beds has a high
adsorptive capacity, or ability to retain HAP molecules that have
made contact with the activated carbon surface. Different-sized
carbon beds are used according to the vapor flowrate emitted from
the dry cleaning system. Carbon beds used in the dry cleaning
industry range in size from 60 to 450 kg (130 to 990 Ib) of
carbon and can handle gas flowrates ranging from several hundred
cubic feet per minute (cfm) to 2000 cfm.2 The working bed
capacity (weight of solvent per weight of carbon, expressed as
percent) for HAP's is about 20 percent.3
The activated carbon bed must be regenerated frequently,
often daily, by desorbing the HAP's that collect on the carbon
bed. Desorption is accomplished by passing steam through the
carbon bed. The vaporized solvent is picked up by the steam,
recovered downstream in a condenser, separated from the water,
and then returned to the solvent storage tank. Typically, dry
cleaner operators desorb carbon adsorber beds daily. Carbon
adsorbers that are not desorbed regularly are rendered
ineffective because of HAP breakthrough that occurs when all of
the adsorptive sites of the activated carbon are occupied by HAP
4-2
-------
H
J
u
SH
U
5
-------
molecules. When this happens, the activated carbon cannot adsorb
any more HAP and the outlet gas stream remains saturated.
Several emission tests conducted at dry cleaning facilities
have measured HAP concentrations at the inlet and outlet of
carbon adsorbers.4'8 Summarized in Table 4-1 are the adsorber
inlet and outlet data collected during the source tests. In each
case, vapors were drawn from at least the dryer or dry-to-dry
machine. All of the carbon adsorbers tested exhibited HAP
removal efficiencies of greater than 95 percent. In general, the
gas entering the carbon adsorber during the aeration step has a
HAP concentration of several thousand parts per million (ppm).
As shown in Table 4-1, properly designed and operated adsorbers
have been shown to reduce the HAP concentration of this stream to
less than 100 ppm, and in some cases to less than 10 ppm.4"8
Additional information on test results is presented in Chapter 3
and Appendix C.
In addition to controlling emissions from the dryer during
the aeration cycle, carbon adsorbers have been proven effective
for controlling other HAP-containing streams. Many facilities
with transfer machines have ductwork leading from the washer to
the carbon adsorber. After the wash cycle, clothes are
transferred manually to the dryer. When the washer door is
opened, a fan turns on which draws HAP vapors from the washer
through the adsorber. Also, some plants have installed floor
vents that draw fugitive vapors from around the dry cleaning
machines, filters, and stills through the adsorber. Emissions of
HAP's from distillation units and muck and oil cookers can be
minimized by ducting vents from these units directly to a carbon
adsorber.
4-2.1.2 Refrigerated Condensation. Refrigerated condensers
use refrigerants, such as chlorofluorocarbon-11 or
chlorofluorocarbon-12, to remove condensible vapors (i.e., HAP's
and water) from washer and dryer exhaust streams. Built-in
refrigerated condensers are available on most new dry-to-dry
no-vent machines. In addition, refrigerated condensers can be
retrofitted to both transfer and dry-to-dry machines.
4-4
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Figure 4-2 illustrates the operating principles of a
refrigerated condenser. The condenser shown graphically in the
figure is a retrofit unit attached to a transfer system; however,
the same operating principles also apply to a retrofit or
built-in unit associated with a dry-to-dry machine. In
Figure 4-2, the condenser is accommodating two different
HAP-laden vapor streamsone from the open door cycle and one
from the aeration cycle. Stream A is composed of the gas that is
drawn out of the washer by an inductive fan during the open door
cycle when clothes are transferred from the washer to the dryer.
The solvent-laden air is cooled to lower the temperature of the
air below the dew point of the vapor, thereby causing it to
condense. After one pass of the washer exhaust through the
refrigerated coils, the gaseous stream, Stream B, is vented from
the plant, while the condensate is sent to the HAP/water
separator to recapture the HAP's. About 30 percent recovery of
HAP's in the washer exhaust is achieved by the one-pass
configuration. For dry-to-dry systems, Streams A and B do not
exist because there are no vented emissions from the wash portion
of the cycle.
During aeration, for both transfer and dry-to-dry systems,
Stream C is discharged from the dryer. The stream enters the
refrigerated oils, where HAP's and water are condensed. The
liquid stream enters the HAP/water separator for HAP separation
and recovery. The vapor stream, Stream D, which is now at
approximately 45°F, is returned to the dryer, where it can remove
more HAP's from the clothes; then it is recirculated back through
the condenser for further HAP removal. With each successive
pass, a fraction (50 percent or less) of the total HAP's in the
vapor coming out of the dryer is removed.
Following the aeration cycle, the concentration of HAP's in
the residual vapors is approximately 8,600 ppro.9 The fate of the
residual HAP vapors following condensation depends upon the type
of condenser in use. There are two types of refrigerated
condenser designs for removing HAP's from dryer exhaust: vented
and ventless. In a vented condenser, all of the exhaust vapors
4-6
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HAP-Laden Vapors
from Washer
HAP-Laden Vapors
from Dryer
Refrigerated
Condensing Coils
stream A = HAP-laden vapors
from washer open door cycle.
stream B = Open door cycle
emissions vented after one
pass through condenser.
stream C = HAP-laden vapors
from dryer.
stream D = Air stream returned
to dryer after HAP separation
and recovery.
Figure 4-2,
A refrigerated condenser as applied to a transfe:
dry cleaning machine.
4-7
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from the condenser are vented to the atmosphere when the door is
opened at the end of the drying cycle. A ventless condenser does
not vent to the atmosphere. However, some of the residual HAP in
the dryer after the aeration cycle may spill out the door when it
is opened. With a vented system, about 85 percent control of
HAP's is achieved compared to an uncontrolled machine. With a
ventless system, control efficiency may be as high as
95 percent.^
Refrigerated condensers have both an advantage and a
disadvantage when compared to carbon adsorbers. The advantage is
that refrigerated condensers do not require frequent maintenance
and desorption as do carbon adsorbers. Refrigerated condensers
need only to have their refrigerant replaced (yearly or even less
frequently) and to have lint removed from the coils. Therefore,
they are less likely to be operated incorrectly than carbon
adsorbers (which are rendered ineffective unless frequently
desorbed).
The disadvantage of refrigerated condensers is that, unlike
carbon adsorbers, they cannot be used to control low
concentration emission streams, such as fugitive emissions or
muck cooker and distillation unit emissions (unless the muck
cooker or distillation unit is built into a dry-to-dry machine).
This is because the emissions that would be picked up by, for
example, ventilation systems, have very low HAP concentrations.
The HAP's in these streams are very difficult to condense at such
low concentrations, but they can be adsorbed on the carbon
surface. In addition, limited test data and thermodynamic
analyses indicate that refrigerated condensers are less efficient
than carbon adsorbers at reclaiming HAP vapors.9*10
4.2.1.3 Current Control Status. There has been a trend
towards the use of emission control equipment in the dry cleaning
industry during the past 10 years. This trend has been caused by
economic incentives (reduction in solvent usage and savings on
solvent purchase), growing concern over worker health and safety,
State regulations, and the possibility of Federal regulations.
In 1978, it was estimated that 35 percent of the commercial,
4-8
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50 percent of the industrial, and 5 percent of the coin-operated
sectors were controlled.11 Current industry estimates indicate
that about 50 percent of the dry cleaning machines in the
commercial and industrial sectors are equipped with control
devices12, and about 47 percent of the dry cleaning machines in
the coin-operated sector are controlled.13 Of the control
devices in place, the majority are either carbon adsorbers or
refrigerated condensers. A small percentage of the industry uses
the SolvationR system.14 This system is comprised of a tank,
partially filled with water and an anti-fearning agent, through
which PCE vapors are bubbled to form a PCE azeotrope. Based on
submitted records of solvent consumption and dry cleaning
throughput, it was concluded that although this system may
achieve improved solvent recovery, it does not constitute
equivalency with a carbon adsorber.15 In addition, one German
manufacturer makes a machine with both a refrigerated condenser
and a carbon adsorber.16 However, there is only, one machine of
this type known to be in operation in the United States, and test
data are not available to document its performance.17
Ventless refrigerated condensers have become the control
method of choice for the dry cleaning industry, especially for
the commercial sector, because this control method provides dry
cleaning with low maintenance, requirements and less solid
waste.1J*
Use of refrigerated condensers in the coin-operated and
industrial sectors is less common. Although small dry-to-dry
units with built-in refrigerated condensers are used effectively
by the coin-operated sector, refrigerated condenser manufacturers
do not currently make a retrofit unit small enough to accommodate
single, small coin-operated machines.
Use of retrofit refrigerated condensers by the industrial
sector has not been widespread because, in general, industrial
dry cleaning systems are older and have more leaks than
commercial systems. Leaks in the dry cleaning system lead to
dilution of the stream entering the condenser, which reduces the
4-9
-------
effectiveness of condensation. However, some industrial dry
cleaners are using the new dry-to-dry, no-vent systems.
Carbon adsorbers are used in varying degrees by the three
dry cleaning sectors (industrial, commercial, and coin-operated).
They have the highest market share in the industrial and
coin-operated sectors. They are attractive to industrial dry
cleaners because of their ability to handle high air flow rates.
Carbon adsorbers are the most commonly used control devices on
coin-operated units.19 Use of carbon adsorbers by self-service
coin-operated facilities is limited, however, because of the
steam necessary to desorb the carbon bed. Most coin-operated
%
facilities do not have any other steam demand and, consequently,
do not have a boiler.19
Carbon adsorbers are gradually being replaced by built-in
refrigerated condensers as the control of choice for dry-to-dry
machines in the commercial sector. This gradual changeover to
refrigerated condensers is attributed to the small wastewater
streams generated from desorption of the carbon bed and the spent
carbon that must eventually be disposed of as a hazardous waste.
In addition, carbon adsorbers require frequentoften
dailydesorption. This requires operator attention and allows a
greater opportunity for error than the low-maintenance
refrigerated condensers.
4.2.2 Methods for Controlling Fugitive Emissions
Fugitive emissions include HAP losses from leaky process
equipment, emissions of HAP's from spent cartridge filters and
HAP-laden solid waste, and in-plant evaporative losses of HAP's
during clothing transfer and handling. There are two types of
fugitive losses: liquid and vapor. Liquid losses can sometimes
be detected by sight, and vapor leaks can be detected by
screening the emission source with a portable leak detector.
Common sources of liquid leaks and vapor leaks were previously
described in Section 3.2.3.1.
Rapid detection and repair of leaks is essential to minimize
fugitive emissions and, thus, reduce solvent losses. No single
control technique is applicable to the control of all types of
4-10
-------
fugitive emissions. The techniques used to control fugitive
emissions can be classified as either equipment or work
practices. An equipment control technique means that some piece
of equipment is used to reduce or eliminate emissions. An
example of equipment control is leakless technology for valves
and pumps.
In the dry cleaning industry, work practices are more
commonly used than equipment control techniques to reduce solvent
losses due to fugitive emissions. Work practices include
periodically monitoring (surveying) sources for leaks and
initiating timely repair, and good housekeeping procedures.
Portable leak detectors are available that can be used on a
regular basis to assist in detecting leaks before they become
large enough to see or smell. Good housekeeping practices are
another type of work practice that can also reduce fugitive
emissions. These can include, but are not limited to, covering
containers of solvent and solvent-laden waste, keeping lint traps
clean, and opening the washer and/or dryer door for as short a
time as possible.
4.2.3 solvent Substitution
Theoretically, solvent substitution is also a control
technique for HAP emissions from dry cleaners. As discussed in
Section 3.1.2, two other solvents are used in dry cleaning. They
are petroleum solvents and chlorofluorocarbon-113 (CFC-113).
Substitution of one of these solvents for HAP's would eliminate
HAP emissions. However, as described in Section 3.2.1.2, other
factors influence the potential for replacement of HAP's by these
other solvents. Petroleum use is severely restricted because of
its fire potential. The CFC-113 is a less aggressive solvent
with a prohibitive cost per gallon. In addition, CFC-113 is
included in the Montreal Protocol, an international agreement
intended to phase out certain CFC's and CFC substitutes (that
contribute to stratospheric ozone depletion) by the year 2005.
Finally, different solvents require different dry cleaning
machines. These considerations are expected to limit the
4-11
-------
feasibility of solvent switching as an emission control
technique.
4-12
-------
4.3 REFERENCES
1 u. S. Environmental Protection Agency. Perchloroethylene
Drv Cleaners. Background Information for Proposed
Standards. Research Triangle Park, North Carolma.
Publication NO. EPA-450/3-79-029a. August 1980. 165p.
Telecon. Bath, D. B., Radian Corporation, with Peterson,
E., Standard Uniform Services. February 14, 1986.
Conversation about Standard Uniform's industrial dry
cleaning machines, and the carbon adsorbers used for
control.
2.
3.
4.
5.
8.
9.
10
Letter from Barber, J. W., Research Doctor, VIC
Manufacturing Company, to Kleeberg, C.F., EPA/ISB,
February 6, 1976.
Test report, from Kleeberg, C. F., EPA/ISB. Test report to
Durham? J.F., EPA/CPB. March 17, 1976. Material Balances
of a Perchloroethylene Dry Cleaning Unit: Test report on
Hershey, Pennsylvania.
Test report, from Kleeberg, C. F., EPA/ISB, to Durham,
j F., EPA/CPB. May 14, 1976. Testing of Industrial
Perchloroethylene Dry Cleaner. May 14, 1976. Test report
on San Antonio, Texas.
Test report, from Kleeberg, C. F., EPA/ISB, to Durham,
j F., EPA/CPB. May 17, 1976. Testing of Commercial
Perchloroethylene Dry Cleaner. Test report on Kalamazoo,
Michigan.
jongleux, Robert F. (TRW, Inc.). Perchloroethylene
Emissions Testing at Kleen Korner, Cortland, New York.
report to U. S. Environmental Protection Agency/EMB.
Publication No. EMB 79-DRY-6. November 1979.
Eureka Laboratories, Inc. Perchloroethylene Dry Cleaner
Inspections in San Diego County. U. S. Environmental
Protection Agency, Region IX. June 1984.
Memorandum from Moretti, E. C., Radian Corporation, to
Perchloroethylene Dry Cleaning Project File.
February 9, 1990. Documentation of Refrigerated Condenser
Control Efficiency.
Lutz, Stephen J. (Gerber Industries). Field Evaluation of
Kleen-Rite Vapor Condensers to Determine VOC Emission
Reduction Capability. May 1981.
Test
4-13
-------
11. U. S. Environmental Protection Agency. Control of Volatile
Organic Emissions from Perchloroethylene Dry Cleaning
Systems. Research Triangle Park, North Carolina.
Publication No. EPA-450/2-78-050. December 1978.
68p.
12. Technical Memorandum from Bath, D. B., Radian Corporation,
to Meech, M. L., EPA/CPB. July 1, 1986. Documentation of
Emission Control Practices Used by the Perchloroethylene
(PCE) Dry Cleaning Industry.
13. Telecon. Bath, D. B., Radian Corporation, with vitek, F.
Coin Launderers Association. March 25, 1986. Conversation
about the number of coin-operated dry cleaning machines.
14.
15.
16.
17,
18,
Meeting report, meeting between the International Fabricare
Institute, Radian Corporation, and U. S. Environmental
Protection Agency. March 5, 1986. Silver Spring, Maryland.
Test report from VOC Testing, Inc., to Netzley, A. E., South
Coast Air Quality Management District. Emission Evaluation
of the Diversitron Solvation Unit. September 18, 1982.
Letter from Franklin, A.J., Boewe Passat Dry Cleaning and
Laundry Machinery Corporation, to Norris, C. E., Radian
Corporation. February 15, 1991.
Telecon. Norris, C. E., Radian Corporation, with
Franklin, A., American Permac, Inc. November 20, 1990.
Conversation about Permac dry cleaning machines.
Ref. 14, pg. 4.
19. Telecon. Norris, C. E., Radian Corporation, with Torp, R.,
Coin Launderers Association. June 27, 1990. Discussion of
steam source for coins-operated dry cleaners.
4-14
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5.2.2 tvyUpment ar»* operational Changes tp the Cleaning System
Any changes to an existing dry cleaning facility must be
approved by the Administrator, who will also determine if the
alterations are considered modifications under 40 CFR 63.5. One
example of such a change would be disabling the damper that
prevents HAP's from leaking into the exhaust during the drying
cycle. Although this change 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. Dry cleaning
emission rates are also dependent on operational techniques.
Operational changes can increase emission rates and may,
therefore, be deemed modifications by the Administrator (unless
they are exempt according to the definition of modification in
the General Provisions [40 CFR 63.5], which is presented in
Section 5.1).
5.3 DRY CLEANER CONSTRUCTION AND RECONSTRUCTION
Some changes can be made to dry cleaning facilities that may
be deemed a reconstruction under 40 CFR 62.5. For example,
replacement of either the washer or dryer of a transfer machine
system would be considered a reconstruction, because both the
washer and the dryer are considered affected facilities in their
own right.
Concerning reconstruction, if an existing dry cleaner
installs replacement parts that exceed over 50 percent of the
fixed capital cost of the existing facility, then those changes
may be deemed a reconstruction.
5-3
-------
-------
5.0 MODIFICATIONS, CONSTRUCTIONS, AND RECONSTRUCTIONS
This chapter presents a discussion of potential
modifications, constructions, or reconstructions that a dry
cleaner may undergo and thereby potentially become subject to the
dry cleaning national emission standard for hazardous air
pollutants (NESHAP). Section 5.1 presents background information
defining these terms. Section 5.2 describes examples of
potential dry cleaner modifications, and Section 5.3 describes
examples of dry cleaner constructions and potential
reconstructions.
5.1 BACKGROUND
Under Section 112(a) of the Clean Air Act (CAA), a new
source is defined as a stationary source, the construction or
reconstruction of which is commenced after the proposal date of
the standard. An existing source is defined as any stationary
source other than a new source. The EPA is in the process of
developing procedures for ensxiring that the modification
provisions of Section 112(g) of the CAA are reflected in the
source's operating permit obtained under Title V of the CAA.
In Section 112(g) of the CAA, a modification is defined as:
A physical change in, or change in the method of
operation of, a major source which results in a greater
than de minimis increase in actual emissions of a
hazardous air pollutant shall not be considered a
modification, if such increase in the quantity of
actual emissions of any hazardous air pollutant from
such source will be offset by an equal or greater
decrease in the quantity of emissions of another
hazardous air pollutant (or pollutants) from such
source which is deemed more hazardous.
As defined in Section 63.2 of the proposed General
Provisions for 40 CFR Part 63, reconstruction means the
replacement of components of an existing source to such an extent
that (1) the fixed capital cost of the new components exceeds
50 percent of the fixed capital cost that would be required to
5-1
-------
construct a comparable, entirely new source, and (2) it is
technologically and economically feasible for the reconstructed
source to meet the relevant emission standard(s), alternative
emission limitation(s), or equivalent emission limitation(s)
established by the Administrator (or a State with an approved
permit program) pursuant to Section 112 of the Act.
Concerning reconstruction, the owner or operator of an
existing dry cleaning facility must apply for approval of any
reconstruction according to the application procedures specified
in Section 63.5 of the proposed General Provisions for 40 CFR
Part 63 to be published in the Federal Register in the near
future.
5.2 DRY CLEANER MODIFICATIONS
There are numerous equipment or process modifications that
can be made to dry cleaning facilities. If an alteration can
cause an increase in the emission rate of HAP's, then the
alteration may be deemed a modification under 40 CFR 63.5. The
following is a discussion of changes that might constitute
modifications. This is not a complete list, nor are the
changes listed always considered modifications. The
Administrator must make the final determination on a case-by-case
basis. As stated previously, EPA is in the process of developing
procedures for ensuring that the modification provisions of
Section 112(g) of the CAA are reflected in the source's operating
permit.
5.2.1 Solvent Switching
Due to the solvent-specific nature of dry cleaning equipment
design and construction materials, it is unlikely that any dry
cleaner would switch from an unregulated solvent to a HAP without
first purchasing a new machine. However, if such a switch is
made, it could be considered a modification by the Administrator.
It is also unlikely that a solvent mixture would be used in
dry cleaning equipment. If a mixture were used and the solvent
mixture were changed to contain more HAP's, the Administrator
could decide that a modification had occurred. The dry cleaner
would then be subject to new machine regulations.
5-2
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6.0 MODEL MACHINES AND REGULATORY ALTERNATIVES
This chapter describes the regulatory alternatives
considered for controlling hazardous air pollutant (HAP)
emissions from the dry cleaning industry and defines the model
machines used for assessing the impact of each alternative. A
description of the regulatory cut-off levels being considered is
also included. Section 6.1 describes the model machines for each
dry cleaning sector and Section 6.2 presents the regulatory
alternatives. Section 6.3 presents the regulatory cut-off
levels. References are provided in Section 6.4.
6.1 MODEL MACHINES
Model machines are parametric descriptions of both the types
of machines that exist and those that, in EPA's judgement, may be
constructed, modified, or reconstructed. For the dry cleaning
industry, 15 model machines have been selected.1 These machines
represent the range of machine sizes and types used in the
coin-operated, commercial, and industrial sectors. The following
parameters have been defined for each model machine: machine
capacity, machine type, loads of clothes cleaned per day, days of
operation per year, and clothing throughput per year (the product
of machine capacity, loads per day, and days of operation per
year). The model machine parameters are presented in Table 6-1
and are summarized in Sections 6.1.1 to 6.1.3. These parameters
apply to all machines, regardless of their level of control (see
Chapters 3.0 and 4.0).
6.1.1 Model Machines for the Coin-Operated Sector
Two types of machines exist in the coin-operated sector:
plant-operated and self-service. The plant-operated machine is
operated by a laundromat employee, and services such as pressing
and bagging, which are found at commercial facilities, are also
provided. The self-service machine is operated either by the
6-1
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TABLE 6-1. MODEL MACHINE PARAMETERS FOR THE DRY CLEANING INDUSTRY9
Machine
capacity (kg [lb]) Machine typeb
Coin-op
3.6 (8)
3.6 (8)
Commercial
11.3 (25)
13.6 (30)
15.9 (35)
15.9 (35)
20.4 (45)
22.7 (50)
22.7 (50)
27.2 (60)
45.4 (100)
45.4 (100)
Industrial
63.5 (140)
113.4 (250)
113.4 (250)
'Source: References 1-4.
''D/D = Dry-to-dry machines.
T = Transfer machines.
SS, D/D
PO, D/0
D/D
D/D
D/D
T
D/D
D/D
T
D/D
D/D
T
D/D
D/D
T
Loads/day
6
6
10
10
10
12
10
10
12
10
10
12
17
17
20
Operation
schedule (day»/yr)
312
312
250
250
250
250
250
250
250
250
250
250
250
250
250
Clothes
(kg/yr)
6,800
6,800
28,400
34,000
39,700
47,700
51,100
56,800
68,100
68,100
113,500
136,200
269,900
481,950
567,000
Throughout
(Ib/yr)
(15,000)
(15,000)
(62,500)
(75,000)
(87,500)
(105,000)
(112,500)
(125,000)
(150,000)
(150,000)
(250,000)
(300,000)
(595,000)
(1,062,500)
(1,250,000)
SS = Self-service machines.
PO = Plant operated machines.
6-2
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customer or by an attendant who loads the clothes and turns on
the machine. No pressing or bagging services are provided.
The coin-operated model machines are 3.6 kg (8 Ib)
dry-to-dry machines that clean 6 loads of clothes per day.1
Because coin-operated laundromats are used by the public, the
model machines are assumed to operate 6 days per week (312 days
per year).1 For each of the model machines in this sector, the
annual throughput of clothing, which is the product of machine
capacity, loads per day, and days of operation per year, is
estimated to be 6,800 kg/yr (15,000 Ib/yr).
6.1.2 Model Machines for the C9Tflm.er7Jal Sector
Ten model machines were chosen to represent the wide variety
of machines used in the commercial sector. The most widely used
commercial machines are 16 kg (35 Ib) and 23 kg (50 Ib).15 Both
transfer and dry-to-dry machines are common at these capacities
and are represented by model machines. Commercial dry-to-dry
machines smaller than 16 kg (35 Ib) are represented by 2 model
machines: 11.3 kg (25 Ib) and 13.6 kg (30 Ib). Because the
smallest transfer machine identified had a capacity of 15.9 kg
(35 Ib), no transfer model machines were chosen below this
capacity. Commercial machines larger than 23 kg (50 Ib) are
represented by a 27.3 kg (60 Ib) dry-to-dry model machine, a
45.4 kg (100 Ib) dry-to-dry model machine, and a 45.4 kg (100 Ib)
transfer model machine. In addition, a 20.4 kg (45 Ib)
dry-to-dry model machine was included to represent machine sizes
between 16 kg (35 Ib) and 23 kg (50 Ib). Each commercial model
machine operates 5 days per week (250 days per year). Dry-to-dry
model machines clean 10 loads of clothes daily, and transfer
model machines clean 12 loads of clothes daily. Annual
throughputs for the model machines in the commercial sector range
from 28,400 kg (62,500 Ib) to 136,200 kg (300,000 Ib) clothes/yr.
6.1.3 Model Machines for the Industrial Sector
For the industrial sector, three model machines were
selected. The typical capacity of existing machines in the
industrial sector is 114 kg (250 Ib).16 To represent these
machines, one 114 kg {250 Ib) transfer and one 114 kg (250 Ib)
6-3
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dry-to-dry model machine were selected. In addition, a 63.5 kg
(140 Ib) dry-to-dry model machine was used to represent machines
of a smaller size.
Each model machine for the industrial sector operates 5 days
per week (250 days per year). Each dry-to-dry model machine
cleans 17 loads of clothes daily, and each transfer model machine
cleans 20 loads of clothes daily. The annual throughput of
clothing ranges from an estimated 269,900 kg/yr (595,000 Ib/yr)
to 567,000 kg/yr (1,250,000 Ib/yr).
6.2 DEVELOPMENT OF REGULATORY ALTERNATIVES
Regulatory alternatives represent comprehensive programs for
reducing emissions from the dry cleaning industry. The
regulatory alternatives selected for analysis are based on a
combination of control equipment and pollution prevention
practices. The alternatives allow for analysis of the
environmental and economic impacts of requiring c combination of
demonstrated control equipment and pollution prevention practices
to achieve varying degrees of emission reduction.
The first step in developing the set of regulatory
alternatives is to evaluate the possible control options that
could be applied to the different sources of emissions in dry
cleaning facilities. These control options may vary according to
the type of equipment, such as a transfer or dry-to-dry machine.
Once the control options have been selected, they are combined to
form regulatory alternatives with varied levels of emission
reduction.
6.2.1 Selection of Control Options
The control options used to develop the regulatory
alternatives considered for controlling HAP emissions are based
on the application of control equipment as described in
Chapter 4. The different control options for dry-to-dry machines
and transfer machines are presented in Table 6-2. The baseline
situation for comparing control options is that no additional
control of HAP emissions from the dry cleaning machine would be
required beyond what is currently required by State and local
6-4
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TABLE 6-2. CONTROL OPTIONS FOR DRY CLEANING MACHINES
Source
Control options
Dry-to-Dry Machine
Vent Control Equipment (control of
process vent emissions only)
« refrigerated condenser (95%)
carbon adsorber (95%)
Fugitive Emissions Control
« specify pollution prevention
practices
Transfer Machine
Vent Control Equipment (control of
process vent emissions only)
refrigerated condenser (85%)
carbon adsorber (95%)
Fugitive Emissions Control
specify pollution prevention
practices
6-5
-------
regulations. The existing regulations and control levels are
described in Sections 3.3.1 and 4.2.1.3.
6.2.1.1 Vent Control Equipment Options. As shown in
Table 6-2, two equipment options are available for controlling
process vent emissions from dry-to-dry and transfer machines.
For transfer machines, the first option (refrigerated condenser)
would achieve at least 85 percent control of vented process
emissions. The more stringent equipment option for transfer
machines (carbon adsorber) would achieve at least 95 percent
control of vented process emissions. For dry-to-dry machines,
both types of control equipment provide 95 percent control of
vented process emissions.
6.2.1.2 Fugitive Control Options. As mentioned in
Section 4.2.2, fugitive emissions include HAP losses from leaky
process equipment, spent cartridge filters, HAP-laden solid
wastes, solvent storage, and in-plant evaporative losses during
clothing transfer and handling.
Methods for controlling fugitive emissions include a range
of pollution prevention practices, as specified in Section 4.2.2.
These practices include prompt detection and repair of both
liquid and vapor process equipment leaks (from places such as
gaskets, valves, hose connections); storage of solvents and
wastes containing HAP's in tightly sealed, nonreactive
containers; and minimization of the time the door of the dry
cleaning machine is open.
6.2.1.3 Replacement of Transfer Machines. In addition to
the control options described in Table 6-2, another option was
considered that would require all transfer machines to be
replaced with dry-to-dry machines immediately upon promulgation
of the regulation. As discussed in Chapter 3, fugitive emissions
from dry-to-dry machines are generally 50 percent less than the
fugitive emissions from transfer machines. However, this control
option was discounted after considering several factors.
First, transfer machines are being replaced with dry-to-dry
machines in the absence of an air emissions regulation, due to
6-6
-------
recent promulgation of more stringent worker exposure
regulations.17 Vendor information indicates that no new transfer
machines have been sold since the late 1980s, and the trend is
expected to continue.1819
Second, there are a limited number of dry-to-dry machines
being manufactured. Immediate replacement of all transfer
machines would place a sudden increase in market demand for the
available dry-to-dry machines, driving up prices. In addition,
because of the limited number of dry-to-dry machines available,
some dry cleaning facilities may not be able to obtain a new
dry-to-dry machine within the time required in the standard.
Third, requiring immediate replacement of transfer machines
may impose economic inequities. For example, one facility may be
operating a 40-year-old transfer machine that is on the verge of
breaking down, whereas another facility may have purchased a new
transfer machine in 1986 and may not have budgeted for other
major capital investments for the next 10 years. Imposing the
immediate replacement option on this second facility would cause
severe hardship and might result in closure. Immediate
replacement would be more costly for this second facility; the
cost for emission reduction would also be higher.
6.2.2 Regulatory Alternatives
This section presents the regulatory alternatives for both
major and area dry cleaning sources. A major source is defined
as a source emitting greater than 10 tons/year of any one HAP or
more than 25 tons/year of any combination of HAP's. An area
source is defined as any other source.20 Because dry cleaning
machines use only one HAP, the 10 tons/year criterion of the
major source definition is applicable for this source category.
Major and area sources include both new and existing dry cleaning
machines. Under Section 112 of the Clean Air Air (CAA), as
amended in 1990, emission standards for new and existing sources
are to require the maximum degree of HAP emission reduction that
the Administrator determines is achievable, taking into
consideration the costs of achieving such emission reduction, and
any ncnair quality health and environmental impacts and energy
6-7
-------
requirements. This is known as the maximum achievable control
technology (MACT).
The CAA further specifies that MACT may be different for new
and existing sources. A new source is required to be controlled
to a level of HAP emission reduction that is at least equal to
the level achieved by the best controlled similar source. An
existing source is required to be controlled to a level of HAP
emission reduction that is at least equal to the emission level
achieved by the average of the best 12 percent of existing
sources. This control level is known as the MACT floor.
6.2.2.1 Manor Dry Cleaning Sources. The major dry cleaning
source category includes all dry cleaning machines emitting
10 tons per year or greater of HAP's. These major sources
include the industrial dry cleaning machines and the 100-lb
commercial transfer machines. Only one regulatory alternative
for major dry cleaning sources is presented in Table 6-3. For
major source dry-to-dry and transfer machines, over 12 percent of
the existing sources are achieving 95 percent control efficiency.
This efficiency, therefore, can be considered to represent the
MACT floor for both new and existing sources. More stringent
control techniques were not identified. This regulatory
alternative also includes pollution prevention practices for the
reduction of fugitive emissions.
The regulatory alternative would require that at least
95 percent efficient vent controls (e.g., carbon adsorbers or
refrigerated condensers) be installed on all new and existing
major source dry-to-dry machines. As discussed in
Section 4.2.1.3, the carbon adsorber is the only type of control
equipment used in the industrial sector; therefore, the
regulatory alternative would require that carbon adsorbers (at
least 95 percent efficient vent control) be installed on all new
and existing industrial transfer machines. Refrigerated
condensers are used to control process emissions from transfer
machines in the commercial sector; however, these devices are
capable of achieving only 85 percent control. This decreased
6-3
-------
TABLE 6-3. THE REGULATORY ALTERNATIVE FOR MAJOR SOURCES SUBJECT
TO THE DRY CLEANING NATIONAL EMISSION STANDARD FOR
HAZARDOUS AIR POLLUTANTS
Machine type
Control option
Emission
reduction
Vented Emissions
Dry-to-dry
Transfer
Refrigerated condenser
Carbon adsorber
Carbon adsorber
95
95
95
Fugitive Emissions
Dry-to-dry and
transfer
Specify pollution
prevention practices
N/Aa
aEmission reduction for pollution prevention practices for
fugitive emissions depends on the individual operator, and is
therefore not quantifiable.
6-9
-------
efficiency is attributed to the use of a one-pass refrigerated
condenser on a transfer washer vent.21 Because 95 percent
control is achievable by major source transfer machines,
85 percent control by condensers would not be considered MACT.
Therefore, the regulatory alternative for major source commercial
transfer machines would require that carbon adsorbers (at least
95 percent vent control) be installed on all new and existing
major source transfer machines.
6.2.2.2 Area Dry Cleaning Sources. Area source dry
cleaners are smaller sized dry cleaning machines emitting less
than 10 tons/year of HAP's. There are three regulatory
alternatives for controlling emissions from area dry cleaning
sources. All of the alternatives include pollution prevention
practices for the reduction of fugitive emissions. The first two
alternatives can be considered generally available control
technology (GACT) (as discussed in Chapter 2.0) and the third is
MACT. Table 6-4 shows the proposed regulatory alternatives for
area sources.
Regulatory Alternative I is the least stringent level of
control. It allows either type of control device, carbon
adsorber or refrigerated condenser, to be applied on dry-to-dry
machines to achieve 95 percent reduction from vented process
emissions. It requires at least 85 percent reduction
(application of a refrigerated condenser) for transfer machines.
Regulatory Alternative II would require either a carbon
adsorber or a refrigerated condenser for all dry-to-dry or
existing refrigerated condenser-controlled transfer machines, but
would allow only carbon adsorbers for new and existing
uncontrolled transfer machines. This alternative would reduce
vented emissions from dry-to-dry and uncontrolled transfer
machines by 95 percent. It would reduce vented emissions from
existing refrigerated condenser-controlled transfer machines by
85 percent.
Regulatory Alternative III is the most stringent level of
control, and can be considered MACT for area sources. It would
6-10
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TABLE 6-4. REGULATORY ALTERNATIVES FOR AREA SOURCES
SUBJECT TO THE DRY CLEANING NATIONAL EMISSION
STANDARD FOR HAZARDOUS AIR POLLUTANTS
Machine type
Control option
Emission
reduction
Alternative I
Vented Emissions
Dry-to-dry
(All)
Transfer
(All)
Fugitive Emissions
Dry-to-dry and
transfer (All)
Refrigerated condenser
or carbon adsorber
Refrigerated condenser
Specify pollution
prevention practices
95
85
N/Aa
Alternative II
Vented Emissions
Dry-to-dry
(All)
Transfer
(Uncontrolled)
(Refrigerated
condenser-
controlled)
Fugitive Emissions
Dry-to-dry and
transfer (All)
Refrigerated condenser
or carbon adsorber
Carbon adsorber
Refrigerated condenser
Specify pollution
prevention practices
95
95
85
N/Aa
(continued)
6-11
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TABLE 6-4. REGULATORY ALTERNATIVES FOR AREA SOURCES
SUBJECT TO THE DRY CLEANING NATIONAL EMISSION
STANDARD FOR HAZARDOUS AIR POLLUTANTS (Concluded)
Machine type
Control option
Emission
reduction
Alternative III
Vented Emissions
Dry-to-dry
(All)
Transfer
(All)
Fugitive Emissions
Dry-to-dry and
transfer (All)
Refrigerated condenser
or carbon adsorber
Carbon adsorber
Specify pollution
prevention practices
95
95
N/Aa
aEmission reduction for pollution prevention practices for
fugitive emissions depends on the individual operator and is,
therefore, not quantifiable.
6-12
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allow the use of carbon adsorbers or refrigerated condensers for
dry-to-dry machines. However, for transfer machines, the only
available control option would be carbon adsorbers. This
alternative would reduce vented emissions from all machines by
95 percent, and this would be considered MACT. Under
Alternative III, operators of existing refrigerated
condenser-controlled transfer machines would be required to
replace the condenser with a carbon adsorber.
6.3 EXEMPTION LEVELS
Three exemption levels were considered for excluding that
portion of the low income sector of the dry cleaning industry
that may experience undue hardship when implementing the level of
HAP emission control required by the NESHAP. Undue hardship
would be defined as severe economic impact such as the inability
to afford the required control device or, at worst, plant
closure. Note that only area sources are found in this low
income sector. A low income dry cleaning establishment was
considered to be pne that grosses $100,000 or less in annual
receipts.
The modelling approach used to select the three exemption
levels was based on annual receipts information given in the
"1987 Census of Service Industries."23'24 According to the
census information, the low income dry cleaning sector is
comprised of both payroll and nonpayroll establishments.
Three low income ranges were selected for evaluating dry
cleaning establishments with payroll: less than $25,000; from
$25,000 to $50,000; and from $50,000 to $100,000. Because the
average annual receipts for dry cleaning establishments without
payroll are estimated as $21,000, these establishments were
evaluated only at the two lowest income ranges: less than
$25,000; and from $25,000 to $50,000.
At each of these annual receipts levels, machine
distribution scenarios were developed based on the estimated 1991
model machine population.1 The machines were distributed
according to size and current level of control as described in a
separate memorandum.23 Once the distributions were ccmplere, a
6-13
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corresponding annual HAP consumption per machine at each cut-off
level was estimated. These resulting exemption levels for HAP
consumption are presented in Table 6-5. For purposes of
compliance determinations, the exemption level will be based on
annual solvent consumption per machine rather than annual
receipts, because this information would be more readily
available from solvent purchase records.
6-14
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TABLE 6-5. PROPOSED EXEMPTION LEVELS OF ANNUAL
MACHINE CONSUMPTION FOR AREA SOURCES3
Annual consumption per machine
Machine type 1*9 n^/yr,
Dry-to-Dry
Transfer
Level
Level
Level
Level
Level
Level
1
2
3
1
2
3
300b
600C
l,200d
400b
800C
l,600d
aA transfer machine consumes more HAP per kg clothes cleaned
than a dry-to-dry machine. Dry cleaning accounts for
90 percent of total annual revenue from a commercial dry
cleaning establishment.
bThis consumption value corresponds to annual receipts of
$25,000.
GThis consumption value corresponds to annual receipts of
$50,000.
dThis consumption value corresponds to annual receipts of
$100,000.
6-15
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6.4 REFERENCES
1. Memorandum from C. E. Norris, and K. S. Kepford, Radian
Corporation, to Dry Cleaning NESHAP Project File.
December 14, 1990. Revised Model Machine Selection for the
Dry Cleaning NESHAP.
2. Letter with attachment from Rooney, S. D., Hoyt Corporation,
to Wyatt, S. R., EPA/CPB. October 28, 1986. Response to
Section 114 Questionnaire.
3. Letter with attachment from Cropper, P., VIC Manufacturing
Company, to Wyatt, S. R., EPA/CPB. December 10, 1986.
Response to Section 114 Questionnaire.
4. Letter with attachment from Krenmayer, R., Hoyt Corporation,
to Wyatt, S. R. , EPA/CPB. December 19, 1986. Response to
Section 114 Questionnaire.
5. Letter with attachment from Scapelliti, J., Detrex
Corporation to Wyatt, S. R., EPA/CPB. December 23, 1986.
Response to Section 114 Questionnaire.
6. Letter with attachment from King, C., Kleen- .ite,
Incorporated, to Wyatt, S. R., EPA/CPB. December 1986.
Response to Section 114 Questionnaire.
7. Letter with attachment from Compter, G., Multimatic
Corporation, to Wyatt, S. R., EPA/CPB. January 27, 1987.
Response to Section 114 Questionnaire.
8. Letter with attachment from Holland, A., Wascomat of
America, to Wyatt, S.-R., EPA/CPB. February 18, 1987.
Response to Section 114 Questionnaire.
9. Letter with attachment from Petrov, W., Bolton Equipment
Corporation, to Wyatt, S. R., EPA/CPB. February 19, 1987.
Response to Section 114 Questionnaire.
10. Letter with attachment from Cleator, H. M., American Permac,
Incorporated, to Wyatt, S. R., EPA/CPB. February 19, 1987.
Response to Section 114 Questionnaire.
11. Letter with attachment from Mitchell, B., Miraclean/Miracle
Core, to Wyatt, S. R., EPA/CPB. March 1987. Response to
Section 114 Questionnaire.
12. Telecon. Bath, D. B., Radian Corporation, with Vitek, F.,
Coin Launderers Association. March 25, 1986. Conversation
about large coin-operated dry cleaning machines.
6-16
-------
13.
14
15
16
17
18
19
20
21
22
23
24
Memorandum from Bath, D. B. and I. M. McKenzie, Radian
Corporation, to Meech, M. EPA/CPB, May 30, 1986. Cost
Analysis and Cost Effectiveness of the Control of
Perchloroethylene from Dry Cleaning Plants, p. A-l.
U. S. Environmental Protection Agency. Perchloroethylene
Dry Cleaners Background Information for Proposed Standards.
Publication No. EPA-450/3-79-029a. Research Triangle Park,
North Carolina. August 1980. 165 p.
Ref. 1, p. 3.
Ref. 1, p. 5.
U. S. Environmental Protection Agency. Occupational Safety
and Health Administration. Federal Register. Vol. 54,
page 2670. Washington, D.C. U. S. Government Printing
Office. January 19, 1989.
Telecon. Moretti, E. C., Radian Corporation, with
Garza, O., Marvel Manufacturing. November 21, 1989.
Conversation about perchloroethylene transfer dry cleaning
machine sales.
Telecon. Moretti, E. C., Radian Corporation, with Lage, A.,
Columbia Dry Cleaning Machine Corporation.
November 21, 1989. Conversation about perchloroethylene
transfer dry cleaning machine sales.
United States Congress. Clean Air Act, as Amended,
November 15, 1990. P. L. 101-549.
Memorandum from Moretti, E. C., Radian Corporation, to Dry
Cleaning Project File. February 9, 1990. Documentation of
Refrigerated Condenser Control Efficiency.
Telecon. Norris, C. E., Radian Corporation, with Torp R.,
Coin Launderers Association. June 20. 1990. Conversation
about Coin-operated Dry Cleaners.
Memorandum from Norris, C. E., and K. S. Kepford, Radian
Corporation, to the HAP Dry Cleaning Project File.
March 1, 1991. Modelling the Low Income Sector of the HAP
Dry Cleaning Industry.
U. S. Department of Commerce, Bureau of the Census.
1987 Census of Service Industries. Subject Series.
Establishment and Firm Size.
6-17
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-------
7.0 ENVIRONMENTAL IMPACTS
Air pollution, water pollution, solid waste disposal, and
energy impacts of the regulatory alternatives being considered
for controlling hazardous air pollutant (HAP) emissions from dry
cleaning machines have been assessed relative to the baseline
conditions presented in Chapters 3.0 and 4.0. Baseline
conditions represent the level of control and emissions in the
absence of a NESHAP. In quantifying and qualifying environmental
impacts, dry-to-dry and transfer dry cleaning machines have been
treated separately for each regulatory alternative under
consideration. As discussed in Chapter 6.0, three regulatory
alternatives were considered for controlling HAP emissions from
dry cleaning machines. In this chapter, the environmental
impacts of baseline control, 95 percent control for dry-to-dry
machines, and both 85 and 95 percent control for transfer
machines are examined.
As discussed in Chapter 3.0, the dry cleaning industry is
comprised of three sectors: coin-operated, commercial, and
industrial. The estimated national number of dry cleaning
machines by machine type is presented in Table 7-1.1 Some
machines are controlled at baseline due to efforts to comply with
the Occupational Safety and Health Administration's (OSHA's)
recently promulgated permissible exposure limit (PEL) of 25 ppm
for perchloroethylene (PCE) (54 FR 2679; January 19, 1989) as
well as concerns for solvent conservation. The current control
status of the three dry cleaning sectors is discussed in
Section 4.2.1.3.
In the coin-operated sector, an estimated 53 percent (1,620)
of the dry cleaning machines (all dry-to-dry machines) are
uncontrolled at baseline. The remaining 47 percent (1,430) are
controlled. All of the controlled coin-ooerated machines are
7-1
-------
TABLE 7-1. ESTIMATED NATIONAL NUMBER OF HAZARDOUS
AIR POLLUTANT DRY CLEANERS AT BASELINE
IN 1991 BY MACHINE TYPE
Sector/type
Uncontro11ed
Carbon
adsorber
Refrigerated
condenser
Coin Operated
Dry-to-dry3
1,620
1,430
Commercial
Dry-to-dry
Transfer
Industrial
Dry-to-dry
Transfer
6,890
5,250
23
42
4,260
2,530
23
42
9,980
2,530
0
0
aAll coin-operated machines are dry-to-dry.
7-2
-------
controlled with carbon adsorbers because refrigerated condensers
are not available for this size machine.
In the commercial sector, 33 percent (10,300) of all dry
cleaning machines are transfer, with the remaining 67 percent
(21,100) being dry-to-dry. Sixty-one percent of commercial
machines are controlled at baseline. It is estimated that
65 percent of the controlled machines in the commercial sector
are controlled with refrigerated condensers and 35 percent with
carbon adsorbers.
Industrial machines are comprised of 64 percent (83)
transfer and 36 percent (46) dry-to-dry. Fifty percent of
industrial machines are controlled at baseline. Essentially all
controlled industrial machines have carbon adsorbers.
Air pollution impacts, water pollution impacts, solid waste
impacts, and energy impacts are addressed in Sections 7.1, 7.2,
7.3, and 7.4, respectively. References are listed in
Section 7.5.
7.1 AIR POLLUTION IMPACTS
Emissions, emissions reduction, and ambient concentrations
were estimated relative to baseline conditions to measure air
quality impacts of the regulatory alternatives. These estimates
were conducted for two segments of the dry cleaning industry:
major and area sources. Major sources include all dry cleaners
in the industrial sector and the 100-lb transfer machines in the
commercial sector, because these types of dry cleaners would
typically emit more than 10 tpy of HAP. Area sources include all
other dry cleaning machines in the commercial sector and machines
in the coin-operated sector. The estimated national number of
dry cleaning machines by source type is shown in Table 7-2.
Baseline emissions and ambient concentrations represent the
existing conditions in the absence of a NESHAP. In addition to
this baseline level, three regulatory alternatives were examined.
As presented in Table 7-3, the level of control for major sources
corresponding to each regulatory alternative is the maximum
achievable control technology (MACT) and, therefore, remains the
same: 95 percent vent control. It is the control levels for
7-3
-------
TABLE 7-2. ESTIMATED NATIONAL NUMBER OF HAZARDOUS
AIR POLLUTANT DRY CLEANERS AT BASELINE
IN 1991 BY SOURCE TYPE
Sector/type
Uncontrolled
Carbon
adsorber
Refrigerated
condenser
Major Sources
Dry-to-dry
Transfer
TOTAL
Area Sources
Dry-to-dry
Transfer
TOTAL
65
182
65
272
0
272
247
8,500
5.070
13,570
337
9,980
2.260
12,240
272
5,690
2.260
7,950
7-4
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7-5
-------
area sources that vary: Regulatory Alternative I for area
sources requires 95 percent vent control for all dry-to-dry and
new transfer machines and 85 percent vent control for existing
uncontrolled and existing refrigerated condenser-controlled
transfer machines. Regulatory Alternative II for area sources
requires 95 percent vent control for all dry-to-dry machines and
new and existing uncontrolled transfer machines and 85 percent
vent control for existing refrigerated condenser-controlled
transfer machines. Regulatory Alternative III for area sources
requires 95 percent vent control for all dry-to-dry and transfer
machines.
7.1.1 Baseline Emissions and Concentrations
The calculation of national baseline emissions is described
in Chapter 3; the values are presented in Table 7-4. National
baseline emissions from existing dry cleaning machines total
87,000 Mg/yr.2 Major sources account for about 3 percent
(6,700 Mg/yr) of total emissions and area sources account for
about 92 percent (80,400 Mg/yr) of total emissions.
7.1.2 Reduction in Emissions
Table 7-4 presents the national air quality impacts in terms
of emission reductions and residual emissions associated with
baseline and the three regulatory alternatives. Emission
reductions and residual ambient concentration for major sources
would remain the same for all regulatory alternatives because the
95 percent control requirement for major sources is identical for
all three regulatory alternatives. Emission reductions and
residual emissions achieved with add-on controls would vary for
area sources between Regulatory Alternatives I, II, and III,
because either a carbon adsorber or refrigerated condenser would
be applied to area source transfer machines depending upon the
percent control requirement. The reduction in national annual
HAP emissions for both major and area sources is shown in
Table 7-4 along with annual emissions remaining after
implementation of the control.3
Emissions of HAP's from major sources for any of the
regulatory alternatives would be reduced by 2,100 Mg/yr.
7-6
-------
TABLE 7-4. EMISSIONS FOR BASELINE AND REGULATORY
ALTERNATIVES I, II, AND III
Regulatory alternative
Emission
reductions
(Mg/yr)
Residual
emission
(Mg/yr)
Baseline
Area sources
Major sources
Total
0
0
80,300
6.700
87,000
I. (95 Percent vent control except
85 percent vent control for
existing area source transfer
machines)
Area sources
Major sources
Total
II. (95 Percent vent control except
85 percent vent control for
existing, refriaerated-condenser
controlled area source
transfer machines)
Area sources
Major sources
Total
III. (95 Percent vent control)
18,900
2.100
21,000
19,900
2.100
22,000
61,400
4.600
66,000
60,400
4 , 600
65,000
Area sources
Major sources
Total
20,500
2.100
22,600
59,800
4.60O
64,400
7-7
-------
Implementation of Regulatory Alternative I would reduce national
HAP emissions by 21,100 Mg/yr, where HAP emissions from area
sources would account for 18,900 Mg/yr of this emission
reduction. Implementation of Regulatory Alternative II would
reduce national HAP emissions by 22,000 Mg/yr, where HAP
emissions from area sources would account for 19,900 Mg/yr of
this emission reduction. Implementation of Regulatory
Alternative III would reduce national HAP emissions by
22,600 Mg/yr, where HAP emissions from area sources would account
for 20,500 Mg/yr of this emission reduction. Under the three
alternatives, the residual emissions remaining after control
would range from 66,000 Mg/yr under Regulatory Alternative I to
64,400 Mg/yr under Regulatory Alternative III.
7.2 WATER POLLUTION IMPACTS
The vent control options would have little impact on water
quality. The principal sources of wastewater from control
operations are steam from the desorption of carbon adsorbers and
effluent from water separators connected to refrigerated
condensers. The p^cential for HAP's in wastewater is presented
in Section 7.2.1. Sections 7.2.2 and 7.2.3 present wastewater
impacts for major sources and area sources, respectively.
7.2.1 Potential Wastewater Impacts
The two control components that could potentially impact
wastewater are the carbon adsorber and the water separator used
after the refrigerated condenser. Although there are other
possible methods for complying with the two levels of process
vent controls (see Chapter 4.0), all impacts for the 85 percent
control level for transfer machines are based on refrigerated
condensers and impacts for the 95 percent control level are based
on carbon adsorbers. Dry-to-dry machines could use either a
refrigerated condenser or a carbon adsorber to achieve 95 percent
control, but impacts are calculated for the worst-case scenario.
Due to the low operating temperature of the refrigerated
condenser, water vapor in the dry cleaning system is condensed.
A typical commercial facility with a refrigerated condenser
generates about 1 gallon of wastewater per week.3 Based on PCE
7-8
-------
solubility in water (150 ppm), 0.03 kg per year are emitted into
aqueous wastes from either uncontrolled machines or refrigerated
condenser-controlled machines.
The use of a carbon adsorber to control vented ambient HAP
vapors is estimated to contribute 0.85 kg/yr for every machine
equipped with this control. This impact was calculated based on
the solubility of PCE in water and the estimated wastewater
flowrate of 1,500 gallons/year.4 There was no information to
suggest that the wastewater discharge is dependent on machine
type, so no distinction was made during the calculation of
wastewater impacts.
7.2.2 Manor Source Dry Cleaners
The level of control for major sources is identical for
Regulatory Alternatives I, II, and III. Because major sources
include only industrial machines and 100-lb commercial transfer
machines, the carbon adsorber is the only control available for
these machines to achieve the required 95 percent HAP emission
reduction level. Therefore, the national wastewater impacts are
shown in Table 7-5 for applying a carbon adsorber to all
25 uncontrolled major source dry-to-dry machines and to all
225 uncontrolled major source transfer machines. The resulting
maximum wastewater impact for all major sources would be 0.21 Mg
HAP/yr.
7.2.3 Area Source Dry Cleaners
Under all three regulatory alternatives, an area source
dry-to-dry machine can achieve 95 percent emission control by
installing either a refrigerated condenser or a carbon adsorber.
As a result, the national wastewater impacts shown in Table 7-5
are for applying either type of control to all 8,500 uncontrolled
area source dry-to-dry machines. If all 8,500 uncontrolled area
source dry-to-dry machines install carbon adsorbers, the
worst-case scenario, the maximum wastewater impact would be
7.2 Mg HAP/yr.
Under Regulatory Alternative I, all existing transfer
machines can achieve 85 percent emission control by installing a
refrigerated condenser. The maximum national wastawater impacts
7-9
-------
TABLE 7-5. SECONDARY ENVIRONMENTAL IMPACTS OF REGULATORY ALTERNATIVES
FOR THE DRY CLEANING INDUSTRY
National
wasteuater
Number of impact of National solid waste
Control level affected control impact of control
Regulatory alternative Machine type (X) facilities (Hg HAP/yr) (Hg carbon/20 years)
Major Sources
I, 11, or III Dry-to-dry
Transfer
TOTAL
Area Sources
I Dry to-dry
Transfer3
(Existing
Uncontrolled
and
Refrigerated
Condenser
Controlled)
TOTAL
II Dry- to-dry
Transfer
(Hew and Existing
Uncontrolled)
Transfer
(Existing
Refrigerated
Condenser
Controlled)
TOTAL
III Dry-to-dry
Transfer
TOTAL
(95) 25 0.02
CA
(95) 225 0.19
CA
250 0.21
(95) 8,500 7.2
CA or
(95) 0.26
RC
(85) 5,100 0.15
RC
13,600 0.41 - 7.35
(95) 8.500 7.2
CA or
(95) 0.26
RC
(95) 5,100 4.3
CA
(85) 2,500 0
RC
13,600 4.56 - 11.5
(95) 8,500 7.2
CA or
(95) 0.26
RC
(95) 7,600 6.4
CA
16,100 6.66 - 13.6
11
101
112
960
0
0
960
960
640
0
1,600
960
0
950
1,910
Regulatory Alternative I for area sources, new transfer machines would be required to install a carbon adsorber
to achieve 95 percent control.
7-10
-------
for applying refrigerated condensers to all 5,100 uncontrolled
transfer machines is 0.15 Mg HAP/yr. Therefore, the resulting
maximum wastewater impacts for all area sources if Regulatory
Alternative I is adopted is 7.35 Mg HAP/yr.
Under Regulatory Alternative II, new and existing
uncontrolled transfer machines can achieve 95 percent control by
installing a carbon adsorber. Because existing refrigerated
condenser-controlled transfer machines already have their control
equipment in place, no additional wastewater impacts would
result. The maximum national wastewater impacts for applying
carbon adsorbers to all 5,100 new and uncontrolled transfer
machines is 4.3 Mg HAP/yr. Therefore, the resulting maximum
wastewater impacts for all area sources if Regulatory
Alternative II is adopted would be 11.5 Mg HAP/yr.
Under Regulatory Alternative III, all transfer machines must
achieve 95 percent emission control by installing a carbon
adsorber. The maximum national wastewater impacts for applying
carbon adsorbers to all 7,680 area source transfer machines would
be 6.4 Mg HAP/yr. Therefore, the resulting maximum wastewater
impacts for all area sources if Regulatory Alternative III is
adopted would be 13.66 Mg HAP/yr.
7.3 SOLID WASTE IMPACTS .
The main types of solid waste generated from controlled dry
cleaning machines are spent carbon or carbon cartridges from
carbon adsorption systems, solvent sludge, and still bottoms.
The sludge, known as "muck", builds up on the cleaner filters and
contains the insoluble soils, nonvolatile residue, and loose dyes
that are removed from the dirty solvent.5 The still bottoms
result from distillation units used to purify solvents. Neither
a carbon adsorber nor a refrigerated condenser would affect muck
or still bottom generation, so no impact due to control
alternatives was calculated for these waste types. Spent carbon
from carbon adsorbers is the only type of solid waste generated
by dry cleaners that is affected by the controls. This type of
solid waste is discussed in Section 7.3.1. The national solid
7-11
-------
waste impacts for major sources and area sources are discussed in
Sections 7.3.2 and 7.3.3, respectively.
7.3.1 spent Carbon from Carbon Adsorbers
A regenerative carbon adsorber is generally more cost
effective than cartridge adsorbers (see Chapter 8.0). A carbon
adsorber uses activated carbon to remove the vaporized solvent in
the incoming air stream. As solvent builds up, the effectiveness
of the unit is reduced. Small pieces of lint and other
particulate matter may also build up on the carbon. To restore
effectiveness, the bed is regenerated with steam. Because of the
strong affinity between the solvent and activated carbon, some
solvent remains despite regeneration efforts. Eventually, the
carbon must be replaced to maintain a desired efficiency level,
generating spent carbon in need of disposal. This replacement is
generally necessary about once every 20 years. Currently, all
controlled coin-operated and industrial machines and 50 percent
of controlled commercial machines already use carbon adsorbers
and generate spent carbon wastes. These 8,281 currently
controlled machines contribute approximately 497 Mg of carbon
every 20 years. The impacts presented below are additional
impacts of the regulatory alternatives that would require more
widespread use of carbon adsorbers.
7.3.2 Solid Waste Impacts from Maior Sources
The control level for major sources is identical for all
three regulatory alternatives. Because major sources include
only industrial machines and 100 Ib commercial transfer machines,
the carbon adsorber is the only control available for these
machines to achieve the required 95 percent emission reduction
level. All of the 250 uncontrolled major sources would install
carbon adsorbers in Year 0 and discard the carbon in Year 20.
Based on the amount of carbon in each machine (0.125 Mg
carbon/commercial machine, 0.45 Mg carbon/industrial machine),
the solid waste impact occurring approximately every 20 years
would be 112 Mg for major sources.
7-12
-------
7.3.3 Solid Waste Tmnacts from Area Sources
The solid waste impacts from area sources would depend on
the regulatory alternative selected. A carbon adsorber in the
coin-operated sector contains 0.06 Mg of carbon. Under
Regulatory Alternative I, assuming the worst-case scenario where
all dry-to-dry machines install carbon adsorbers and all transfer
machines install refrigerated condensers, the maximum solid waste
impacts occurring approximately every 20 years would be 960 Mg
for the 13,600 affected area sources.
Under Regulatory Alternative II, assuming the worst-case
scenario where all dry-to-dry machines and all new and existing
transfer machines would install carbon adsorbers, the maximum
solid waste impacts occurring approximately every 20 years would
be 1,600 Mg for the 13,600 affected area sources. All
refrigerated condenser-controlled transfer machines would
continue to operate their condensers so there would be no
contributions to solid waste impacts from these machines.
Under Regulatory Alternative III, assuming the worst-case
scenario where all dry-to-dry and transfer machines install
carbon adsorbers, the maximum solid waste impacts occurring
approximately every 20 years would be 1,910 Mg for the
16,100 affected area sources.
7.4 ENERGY IMPACTS
Both the carbon adsorber and the refrigerated condenser
require additional energy to operate. A discussion of these
energy requirements on a per machine basis is presented in
Section 7.4.1. The energy requirements of the regulatory
alternatives are presented in Section 7.4.2.
7.4.1 Dry Cleaning Energy Requirements on a Per Machine Basis
Table 7-6 presents the energy requirements of the controls
in both kilowatt hour (kw-hr) and the equivalent number of
barrels of oil. The number of barrels of oil was calculated
based on 1.3 barrels of oil being required to generate
1,000 kw-hr of electricity. This calculation assumed the use of
number 6 fuel oil (150,000 Btu/gallon), 42.7 gallons per barrel,
7-13
-------
TABLE 7-6. NATIONAL ENERGY REQUIREMENTS FOR EACH REGULATORY ALTERNATIVE
Regulatory Alternative Machine type Control option
Major Sources
I Dry- to-dry CA
Transfer CA
TOTAL
Area Sources
I Dry- to-dry CA or
RC
Transfer RC
TOTAL
II Dry- to-dry CA or
RC
Transfer CA
TOTAL
III Dry-to-dry CA or
RC
Transfer CA
TOTAL
Miwber of
affected
facilities
25
-235.
250
8,500
8,500
5.100
13,600
8,500
8,500
5.100
13,600
8,500
8,500
7,600
16,100
Energy Reoui rements
-------
and a typical efficiency of 40 percent for oil-fired power
plants.6
The control that requires the most energy input is the
refrigerated condenser. As shown in Table 7-7, the energy
requirements for this device range from 604 kw-hr/machine/yr
(0.8 barrels of oil) for commercial dry-to-dry machines to
725 kw-hr/machine/yr (0.95 barrel of oil/machine/yr) for
commercial transfer machines. The carbon adsorber energy
requirements include the energy necessary to run the control as
well as the energy necessary to generate the steam for
desorption. The energy requirements for carbon adsorbers are
351 kw-hr/machine/yr (0.5 barrels of oil/machine/yr) for machines
in the coin-operated sector. For commercial dry-to-dry machines
and commercial transfer machines, the energy requirements for
carbon adsorbers are 344 and 375 kw-hr/machine/yr (0.4 and
0.5 barrels of oil/machine/yr), respectively. For industrial
dry-to-dry machines and industrial transfer machines, the energy
requirements for carbon adsorbers are 453 and
500 kw-hr/machine/yr (0.6 and 0.7 barrels of oil/machine/yr},
respectively.
Although energy is consumed to operate controls for dry
cleaning machines, solvent is also conserved. A credit was taken
in calculating national energy impacts for the reduction in
solvent consumption attributable to the control. It takes
1.25 barrels of oil to produce one barrel (42.7 gallons) of
solvent. This is equivalent to 730 kw-hr of energy savings per
barrel of solvent conserved.7
7.4.2 Dry Cleaning Energy Requirements of the Regulatory
Alternatives
The national energy requirement for major sources is
identical for all three regulatory alternatives. If all
uncontrolled major sources install carbon adsorbers, the total
national energy requirement would be 123,825 kw-hr (161 barrels
of oil/yr), an average of about 495 kw-hr/machine/yr
(0.64 barrels of oil/machine/yr).
7-15
-------
TABLE 7-7 ENERGY REQUIREMENTS
ON A PER MACHINE BASIS
Sector
Control Typea
(kw-hr/
machine/year)
CA
RC
Coin-op
Dry-to-dry
Commercial
Dry-to-dry
Transfer
Industrial
Dry-to-dry
Transfer
351
344
375
453
500
604
725
aCA = Carbon adsorber.
RC = Refrigerated condenser.
7-16
-------
Under Regulatory Alternative I, the scenario with greatest
energy impacts would be if all dry-to-dry and existing transfer
area sources install refrigerated condensers. The total national
energy requirement for this scenario would be 13,147,300 kw-hr/yr
(17,091 barrels of oil/yr), an average of 967 kw-hr/machine/yr
(1.25 barrels oil/machine/yr).
Under Regulatory Alternative II, the scenario with greatest
energy impacts would be if all dry-to-dry area source install
refrigerated condensers and all transfer area sources except for
existing refrigerated condenser-controlled transfer machines
install carbon adsorbers. The total national energy requirement
for this scenario would be 6,637,400 kw-hr/yr (8,269 barrels
oil/yr), an average of 488 kw-hr/machine/yr (0.63 barrels oil
machine/yr).
Under Regulatory Alternative III, the scenario with greatest
energy impacts would be if all dry-to-dry area sources install
refrigerated condensers and all transfer area sources install
carbon adsorbers. The total national energy requirement for this
scenario would be 5,762,400 kw-hr/yr (7,491 barrels oil/yr), an
average of 358 kw-hr/machine/yr (0.46 barrels oil/yr). Although
Regulatory Alternative III is the most stringent regulatory
alternative, the national energy requirement is lowest of the
three alternatives because the calculations include a reduction
in electricity demands resulting from 2,500 refrigerated
condenser transfer machines switching to carbon adsorber
controls.
7-17
-------
-------
7.5 REFERENCES
1. Memorandum from C. E. Norris and K. S. Kepford, Radian
Corporation, to the Dry Cleaning Project File. Revised
Estimates of National HAP Consumption by the Dry Cleaning
Industry.
2. Ref. 1.
3. Memorandum from C. E. Norris and K. S. Kepford, Radian
Corporation, to the Dry Cleaning Project File. National
Cost Impacts of the Regulatory Alternatives for HAP Dry
Cleaning. December 14, 1990.
4. Telecon. Shumaker, J., Radian Corporation with Wheless, J.,
Regency Plaza Cleaners and Laundromat. October 22, 1986.
Conversation about wastewater PCE contamination.
5. Telecon. Norris, C. E., Radian Corporation, with
Bovari, R., Safety Kleen. May 9, 1991. Conversation about
the amount of perchloroethylene in dry cleaner wastewater.
6. Meeting summary, meeting between Safety-Kleen, Radian
Corporation, and U. S. Environmental Protection Agency.
November 12, 1986. Research Triangle Park, North Carolina.
Attachment 3.
7. Combustion: Fossil Power Systems. 3rd Edition 1981
Published by Combustion Engineering, Inc., Windsor, CT.
8. U. S. Environmental Protection Agency. Organic Solvent
Cleaners-Background Information for Proposed Standards.
Publication No. EPA-450/2-78-045a. Research Triangle Park,
North Carolina. October 1979.
7-18
-------
-------
8.0 COST ANALYSIS
8.1 INTRODUCTION
The costs of implementing the regulatory alternatives for
controlling HAP emissions from dry cleaning plants are presented
in the following sections. Detailed descriptions of the model
machines and regulatory alternatives treated in this cost
analysis are presented in Chapter 6.0. Section 8.2 presents a
discussion of model machine cost impacts and Section 8.3 presents
a discussion of national cost impacts.
8.2 MODEL MACHINE CONTROL COST IMPACTS
The updated control cost estimates presented in this section
are based on information from vendors of dry cleaning equipment
and control equipment. The capital and annualized costs and cost
effectiveness associated with control options are presented on a
model machine basis for all three dry cleaning sectors.
Machines in all three dry cleaning sectors (coin-operated,
commercial, and industrial) are represented by model machines.
Installed capital costs of-control equipment and new dry-to-dry
machine equipment are obtained from costs provided by
vendors,1"10 except costs of boilers and oil tanks (used in the
coin-operated sector), which are updated from a previous
perchloroethylene dry cleaners background information document
(BID)11 using the Chemical Engineering equipment cost index.1^
All annualized costs are expressed in second quarter 1989 dollars
and were annualized with an interest rate of 10 percent.
The remainder of this section describes the approach and
presents results of the model machine cost analyses.
Section 8.2.1 presents the HAP emission reductions used to
calculate cost effectiveness. Section 8.2.2 includes a
discussion of the cost analyses and presents cost estimates for
refrigerated condensers and carbon adsorbers.
8-1
-------
8.2.1 Hazardous Air Pollutant Emission
The HAP consumption by uncontrolled model transfer machines
is estimated to be 11.5 kilograms (kg) of HAP per 100 kg of
clothes cleaned.I3 Emissions from solid waste disposal are
assumed to be approximately 2.5 kg HAP/100 kg clothes cleaned,
which is the same for both transfer and dry-to-dry machines.
Because solid waste is disposed off site, these emissions are not
included in the process emissions. Out of the total vapor
emissions from a transfer machine, process emissions account for
4 kg of HAP and fugitive emissions account for 5 kg of HAP. A
dry-to-dry machine emits 3.1 kg of HAP from process emissions and
about half the fugitive emissions of transfer machines (or
2.5 kg) due to elimination of the clothing transfer step.14-16
Thus, total emissions from dry-to-dry machines are calculated to
be 5.6 kg of HAP per 100 kg of clothes cleaned (3.1 kg + 2.5 kg).
The addition of a refrigerated condenser to a transfer
machine will reduce process emissions by 85 percent from 4 kg of
HAP per 100 kg of clothes cleaned to 0.6 kg of HAP per 100 kg of
clothes cleaned.17 The addition of a refrigerated condenser to a
dry-to-dry machine will reduce process emissions by 95 percent,
from 3.1 kg of HAP per 100 kg of clothes cleaned to 0.2 kg of HAP
per 100 kg of clothes cleaned. A carbon adsorber applied to
either a transfer or dry-to-dry machine will reduce process
emissions by 95 percent to 0.2 kg of HAP per 100 kg of clothes
cleaned.
The HAP dry cleaning model machine emissions estimates are
summarized in Table 8-1.
8.2.2 Control Costs for Model Machines
Table 8-2 shows how net annualized costs are calculated for
the model machines. Capital costs of dry cleaning machines are
obtained from machine vendors. Taxes and freight are assumed to
be 8 percent of the uninstalled purchase costs. Annualized costs
include capital recovery costs, indirect operating costs, labor
and utilities costs, and overhead. As shown, capital recovery
and indirect operating costs are derived from the total capital
investment. Table 8-3 presents the estimated costs and cost
8-2
-------
TABLE 8-1. EMISSION FACTORS FOR THE HAZARDOUS AIR POLLUTANT
DRY CLEANING INDUSTRY3
(kg HAP/100 kg clothes cleaned)
Dry-to-Dry
Uncontrolled
Process 3 . 1
Fugitive 2.5
Total 5.6
Refrigerated Condenser-Controlled
Process 0.2
Fugitive 2.5
Total 2.7
Carbon Adsorber-Controlled
Process 0.2
Fugitive 2.5
Total 2.7
Transfer
4
5
9
0.
5_
5.
0.
5_
5.
6
6
2
2
aSolid waste emissions are not shown because the wastes are
transported off site for disposal. Therefore, any air
emissions from solid waste disposal are not attributed to a-dry
cleaning plant.
8-3
-------
TABLE 8-2. DERIVATION OF NET ANNUALIZED COSTS
Capital Costs. S
Purchase Cost
Installation
Taxes and Freight
Total Capital Investment
Annualized Costs. S/vr
Capital Recovery Cost
Indirect Operating Costs
Operating Labor
Maintenance Labor
Overhead
Utilities
Electricity
Steam
Total Annualized Costs, $/yr
Emission Reduction, kg HAP/yr
Recovered Solvent Credit, $/yr
Net Annualized Cost of Control, $/yr
A
B
C (= 0.08 X A)
D (= A 4- B + C)
E (- CRFa X D)
F (= 0.04 X D)
G
H
I [= 0.6 (G + H) ]
J
K
L (=
I + J + K)
M
N (= 0.683b X M)
O (= L - N)
aCRF = Capital recovery factor.
id + i)n
MB *' _ '
where:
n = Equipment life (years).
i = Interest rate.
bPrice of perchlorpethylene is $0.683/kg (second quarter
1989 dollars).18
8-4
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effectiveness for installing both types of process vent controls
on
uncontrolled model machines. For model transfer machines
equipped with refrigerated condensers, the cost and cost
effectiveness of installing the more stringent carbon adsorbers
have also been evaluated. The control costs and
cost-effectiveness values for installing carbon adsorbers on
current refrigerated condenser-controlled transfer machines are
summarized in Table 8-4.
8.2.3 Coin-Operated Drv Cleaning Machines
The coin-operated model machines are 3.6 kg (8-lb)
dry-to-dry machines. One machine is self-service and one is
plant-operated. No transfer machines are used in the
coin-operated sector. The only vent control that was evaluated
for this sector is a carbon adsorber because the HAP-laden air
flow from coin-operated machines is too low to be controlled
efficiently by a refrigerated condenser.19 An emission reduction
of 195 kg HAP per year is obtained by applying a carbon
adsorption system to the model coin-operated machines. The net
annualized cost to control HAP emissions with a carbon adsorber
is $7,500 per year for self-service machines and $3,700 per year
for plant-operated machines. The cost-effectiveness values are
$39.00 and $19.00 per kg HAP removed, respectively.
8.2.4 Commercial Dry Cleaning Machines
Control costs for both control options were evaluated for
the 10 model machines for the commercial sector. The model
machines range in size from 11.3 kg (25 Ib) to 45.4 kg (100 Ib).
Seven of the model machines are dry-to-dry machines. The
remaining three machines are transfer machines. The costs and
cost effectiveness for vent controls on uncontrolled model
machines in the commercial sector are presented in Table 8-3.
With the exception of the transfer model machines, the capital
and annualized costs for carbon adsorbers are greater than for
refrigerated condensers for a given model machine size. In
addition, the capital costs for a refrigerated condenser on a
transfer machine are higher than for a refrigerated condenser on
8-6
-------
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the same size dry-to-dry machine due to additional duct work and
refrigerated coils necessary to efficiently control vapors from
both equipment pieces (i.e., washer and dryer) comprising the
transfer dry cleaning machine.
The HAP emission reductions due to a refrigerated condenser
range from 800 kg/yr for the 11.3 kg (25 Ib) model dry-to-dry
machine to 4,600 kg/yr for the 45.4 kg (100 Ib) model transfer
machine. The net annualized cost for the addition of a
refrigerated condenser ranges from a cost of $1,100 for the
11.3 kg (25 Ib) transfer model machine to a net cost savings for
the 45.4 kg (100 Ib) transfer model machine. Cost effectiveness
ranges from $1.00/kg for the 11.3 kg (25 Ib) model machine to a
net credit for the 45.4 kg (100 Ib) transfer model machine.
The HAP emission reduction due to a carbon adsorber ranges
from 800 kg/yr for the 11.3 kg (25 Ib) model dry-to-dry machine
to 5,200 kg/yr for the 45.4 kg (100 Ib) model transfer machine.
The net annualized cost for the addition of a carbon adsorber
ranges from a cost of $3,300 for the 11.3 kg (25 Ib) model
machine to a net cost of $300 for the 45.4 kg (100 Ib) model
transfer machine. Cost effectiveness ranges from $4.00/kg for
the 11.3 kg (25 Ib) model plant to $1.00/kg for the 45.4 kg
(100 Ib) model transfer machine.
Table 8-4 presents the estimated costs and cost
effectiveness for installing a carbon adsorber on model transfer
machines currently controlled with a refrigerated condenser. The
capital and annualized costs of carbon adsorber controls are the
same as those presented for uncontrolled model machines. The
emission reduction and corresponding solvent recovery credit are
less, however. Because a refrigerated condenser-controlled
machine already has lower emissions than an uncontrolled machine,
the emission reduction achievable by installing a carbon adsorber
is reduced. Therefore, the resulting cost effectiveness of
carbon adsorber controls on model machines already equipped with
refrigerated condensers is higher than for uncontrolled machines.
The emission reductions range from 200 kg/yr for a 15.9 kg
(35 Ib) transfer model machine to 600 kg/yr for the 45.4 kg
3-8
-------
(100-lb) transfer model machine. Net annualized costs range from
$3,700/yr to $3,500/yr for the range of commercial sector model
machines. Cost effectiveness ranges from $19.60/kg to $6.40/kg
for the commercial sector model machines.
8.2.5 Industrial Dry Cleaning Machines
The industrial sector model machines are a 63.5 kg (140-lb)
dry-to-dry machine, a 113.4 kg (250-lb) dry-to-dry machine, and a
113.4 kg (250-lb) transfer machine. The only vent control option
examined for the three industrial model machines is a carbon
adsorber because refrigerated condensers are not sold for these
size machines. Table 8-3 presents the estimated costs for vent
controls on uncontrolled model machines. The emission reduction
from the installation of a carbon adsorber is 7,800 kg/yr for a
63.5 kg (140-lb) model dry-to-dry machine, 14,000 kg/yr for a
113 kg (250-lb) model dry-to-dry machine, and 21,600 mg/yr for a
113 kg (250-lb) model transfer machine. The net annualized cost
and cost effectiveness for adding a carbon absorber will be a
net credit for all industrial sector model machines.
8.3 NATIONAL COST IMPACTS
The purpose of this section is to present the national cost
impacts of the regulatory alternatives being considered for the
HAP dry cleaning NESHAP. The national cost impacts are presented
in terms of total nationwide capital costs and annualized costs.
The cost effectiveness of each alternative in dollars per amount
of HAP emission reduction is also presented.
Table 8-5 presents a summary of the national cost impacts
for each of the regulatory alternatives. Total installed capital
costs, net annualized costs, and cost-effectiveness estimates are
shown. In addition, the total nationwide emissions reduction
achievable in the first year after promulgation of the NESHAP are
presented, as well as the number of dry cleaning machines that
would be affected by each of the regulatory alternatives.
Total installed capital costs range from approximately
90 million dollars for Regulatory Alternative II to approximately
110 million dollars for Regulatory Alternative III. Emission
reduction is lowest at approximately 21,900 Mg HA? per
8-9
-------
TABLE 8-5.
NATIONAL COST IMPACTS OF REGULATORY ALTERNATIVES
FOR HAP DRY CLEANING
Regulatory
Alternative
Nwfcer of
machines affected
Capital cost
-------
year for Alternative I and greatest at approximately 23,600 Kg
HAP per year for Alternative III.
Net annualized costs range from 17 million dollars per year
for Alternative I to 31 million dollars per year for
Alternative III.
Cost effectiveness values are presented as dollars per Mg of
HAP recovered. The average cost-effectiveness values range from
$800 per Mg of HAP for Alternative I to $1,300 per Mg of HAP for
Alternative III.
8-11
-------
-------
8.7 REFERENCES
1. Letter and attachments from Rooney, S. D., Hoyt Corporation,
to Wyatt, S. R., EPA/CPB. October 28, 1986. Response to
Section 114 letter on dry cleaners.
2. Letter and attachments from Cropper, P., VIC Manufacturing
Company, to Wyatt, S. R., EPA/CPB. December 10, 1986.
Response to Section 114 letter on dry cleaners.
3. Letter and attachments from Krenmayer, R., Hoyt Corporation,
to Wyatt, S. R., EPA/CPB. December 19, 1986. Response to
Section 114 letter on dry cleaners.
4. .Letter and attachments from Scapelliti, J., Detrex
Corporation, to Wyatt, S. R., EPA/CPB. December 23, 1986.
Response to Section 114 letter on dry cleaners.
5. Letter and attachments from King, C., Kleen-Rite,
Incorporated, to Wyatt, S. R., EPA/CPB. December 1986.
Response to Section 114 letter on dry cleaners.
6. Letter and attachments from Compter, G., Multimatic
Corporation, to Wyatt, S. R., EPA/CPB. January 27, 1987.
Response to Section 114 letter on dry cleaners.
7. Letter and attachments from Holland, A., Wascomat of
America, to Wyatt, S. R., EPA/CPB. February 18, 1987.
Response to Section 114 letter on dry cleaners.
8. Letter and attachments from Petrov, W., Bolton Equipment
Corporation, to Wyatt, S. R., EPA/CPB. February 19, 1987.
Response to Section 114 letter on dry cleaners.
9. Letter and attachments from Cleator, H. M., Bolton Equipment
Corporation to Wyatt, S. R., EPA/CPB. February 1987.
Response to Section 114 letter on dry cleaners.
10. Letter with attachments from Mitchell, B., Miraclean/Miracle
Core to Wyatt, S. R., EPA/CPB. March 1987. Response to
Section 114 letter on dry cleaners.
11. Perchloroethylene Dry Cleaners. Background Information for
Proposed Standards. U. S. Environmental Protection Agency.
Research Triangle Park, North Carolina. Publication
No. EPA-450/3-79-0293. August 1980.
12. Chemical Engineering Plant Cost Index for Equipment.
Chemical Engineering. August 1989. p. 206.
13. Memorandum from Norris, C. E. and K. S. Kepford, Radian
Corporation, to Dry Cleaning Project File.
December 14, 1990. Documentation of Revised Emission
Factors for HAP Dry Cleaning Machines.
8-12
-------
14
15,
16,
17.
18,
19.
Memorandum from Burch, W. M., EPA/OPTS, to DeSantis, J.,
EPA/CSCCO. August 5, 1987. Revised Dry Cleaning
Occupational Exposure Information.
Memorandum from Burch, W. M., EPA/OPTS, to DeSantis, J.,
EPA/CSCC. August 18, 1987. Revised Dry Cleaning
Occupational Exposure Information.
Memorandum from Burch, W. M., EPA/OPTS, to DeSantis, J.,
EPA/CSCC. October 16, 1987. Revised Commercial Dry
Cleaning Tables.
Memorandum from Moretti, E. C., Radian Corporation, to Dry
Cleaning Project File. February 9, 1990. Documentation of
Refrigerated Condenser Control Efficiency.
Memorandum from Norris, C. E. and K. S; Kepford, Radian
Corporation, to Dry Cleaning Project File.
December 14, 1990. Updated Control Costs and
Cost-Effectiveness Estimates for HAP Dry Cleaners.
Memorandum from Bath, D. B., Radian Corporation, to Meech,
M. L., EPA/CPB. July 1, 1986. Documentation of Emission
Control Practices Used by the Perchloroethylene (PCE) Dry
Cleaning Industry.
8-13
-------
APPENDIX A
EVOLUTION OF THE BACKGROUND INFORMATION DOCUMENT
-------
-------
APPENDIX A
EVOLUTION OF THE BACKGROUND INFORMATION DOCUMENT
The purpose of this study was to develop a basis for
supporting proposed national emission standards for hazardous air
pollutants (NESHAP) for the dry cleaning industry.
Chronology
The chronology which follows includes those events that have
occurred in developing the background information document (BID)
for hazardous air pollutant (HAP) dry cleaning. Events that lead
up to the proposal of the standards in the Federal Register are
also included.
Date
December 26, 1985
May 19, 1988
January 19, 1989
July 13, 1990
July 18, 1990
August 20, 1990
November 15, 1990
Activity
EPA published a Notice of Intent to
list PCE as a potentially toxic air
pollutant to be regulated under
Section 112 of the CAA (50 FR 52880)
National Air Pollution Control Technique
Advisory Committee (NAPCTAC) meeting on
dry cleaning, Research Triangle Park,
North Carolina.
Promulgation of the Occupational Health
and Safety Administration's
25 permissible exposure limit (PEL),
54 FR 2670.
Work Group meetingbackground
information.
Meeting with industry representatives,
Radian, and EPA at EPA Offices, Durham,
North Carolina.
Work Group meetingpresent control
options.
Enactment of CAA Amendments
(Title IIIHazardous Air Pollutants).
A-i
-------
December 18, 1990
January 30, 1991
March 28, 1991
July 5, 1991
September 3, 1991
October 15, 1991
November 15, 1991
November 1991
Work Group meetingstatus update.
National Air Pollution Control Technique
Advisory Committee (NAPCTAC) meeting on
dry cleaning, Research Triangle Park,
North Carolina.
Meeting with International Fabricare
Institute, Institute of Industrial
Launderers, Neighborhood Cleaners
Association, Halogenated Solvents
Industry Alliance, R.R. Street, Radian,
and EPA at International Fabricare
Institute, Silver Spring, Maryland.
Work Group meeting to select option.
Work Group closure meeting.
Notice of Proposed Rulemaking and
background information documents
submitted to OMB.
Preamble and regulation .igned by the
Administrator.
Anticipated proposal of regulation in
the Federal Register.
A-2
-------
APPENDIX B
INDEX TO ENVIRONMENTAL IMPACT CONSIDERATIONS
-------
-------
APPENDIX B
INDEX TO ENVIRONMENTAL IMPACT CONSIDERATIONS
This appendix consists of a reference system that is
cross-indexed with the October 21, 1974, Federal Register
(39 FR 37419) containing the Agency guidelines concerning the
preparation of environmental impact statements. This index can
be used to identify sections of the document that contain data
and information germane to any portion of the Federal Register
guidelines.
B-l
-------
TABLE B-l. CROSS-INDEXED REFERENCE SYSTEM TO HIGHLIGHT
ENVIRONMENTAL IMPACT PORTIONS OF THE DOCUMENT
Agency guidelines for preparing
regulatory action environmental
impact statements (39 FR 37419)
Location
within the background
information document
1. Background and Summary of Regulatory Alternatives
Summary of regulatory
alternatives
Statutory basis for
proposing standards
Relationship to other
regulatory agency actions
The regulatory alternatives
from which standards will be
chosen for proposal are
summarized in Chapter 1.0,
Section 1.1.
The statutory basis for
proposing standards is
summarized in Chapter 2.0,
Section 2.1.
The relationships between
EPA actions and other
regulatory Agency actions
are discussed in
Chapters 3.0, 7.0, and 8.0.
Industries affected by the
regulatory alternatives
Specific processes affected
by the regulatory
alternatives
A discussion of the industry
affected by the regulatory
alternatives is presented in
Chapter 3.0, Section 3.1.
Further details covering the
business and economic nature
of the industry are
presented in Chapter 9.0,
Section 9.1.
The specific processes and
facilities affected by the
regulatory alternatives are
summarized in Chapter 1.0,
Section 1.1. A detailed
technical discussion of the
processes affected by the
regulatory alternatives is
presented in Chapter 3.0,
Section 3.2.
(continued)
B-2
-------
TABLE B-l. CROSS-INDEXED REFERENCE SYSTEM TO HIGHLIGHT
ENVIRONMENTAL IMPACT PORTIONS OF THE DOCUMENT (Concluded)
Agency guidelines for preparing
regulatory action environmental
impact statements (39 FR 37419)
Location
within the background
information document
2. Regulatory Alternatives
Control techniques
Regulatory alternatives
The alternative control
techniques are discussed in
Chapter 4.0.
The various regulatory
alternatives are defined in
Chapter 6.0, Section 6.2. A
summary of the major
alternatives considered in
included in Chapter 1.0,
Section 1.1.
3. Environmental Impact of the Regulatory Alternatives
Air pollution
Water pollution
Solid waste disposal
Energy
The air pollution impact of
the regulatory alternatives
is discussed in Chapter 7.0,
Section 7.1.
The water pollution impact
of the regulatory
alternatives is discussed in
Chapter 7.0, Section 7.2.
The solid waste disposal
impact of the regulatory
alternatives is discussed in
Chapter 7.0, Section 7.3.
The energy impact of the
regulatory alternatives is
considered in Chapter 7.0,
Section 7.4.
4. Economic Impact of the Regulatory Alternatives
The economic and financial
impacts of the regulatory
alternatives on costs ara
discussed in Chapter 8.0.
S-3
-------
-------
APPENDIX C
EMISSION SOURCE TEST DATA
-------
-------
APPENDIX C
EMISSION SOURCE TEST DATA
Dry cleaning plants differ in size, control technology,
design, capacity, types of articles cleaned, geographical
location, age of equipment, housekeeping practices, and
maintenance history. These factors affect solvent emissions.
Several perchloroethylene (PCE) dry cleaning plants utilizing
representative emission control technologies have been tested in
order to determine the effectiveness of the emission control
devices in reducing hazardous air pollutants (HAP's). Five
plants were tested: four commercial plants (Plants A, C, D,
and E) and one industrial plant (Plant B). Plant A is a large
commercial plant using a transfer system with a washer capacity
of 50 kg (110 Ib). Plants C, D, and E are average-size
commercial plants using dry-to-dry machines with rated capacities
of 18 kg (40 Ib) , 20 kg (45 Ib), and 30 kg (65 Ib), respectively.
Plant B is an average-size industrial plant that operates a
"kissing machine" with a washer capacity of 136 kg (300 Ib).
Emission tests consisted of total hydrocarbon measurements at the
inlet and outlet of the control device and PCE concentration
measurements at the control device outlet. In addition,
observations of housekeeping (or pollution prevention) practices
at each plant were reported. Test results are summarized in
Tables C-l and C-2. Table C-l presents emission estimates based
on test results, and Table C-2 presents measured control device
efficiencies. The tested plants are described in the following
sections.
C.I PLANT A
Plant A is a commercial PCE dry cleaning plant in Hershey,
Pennsylvania. The transfer system operated at this facility
includes a 50-kg (110-lb) capacity SM-11 washer manufactured by
C-l
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TABLE C-2.
SUMMARY OF PERCHLOROETHYLENE DRY CLEANING CONTROL
DEVICE EFFICIENCY TEST DATAa
Plant
Dry cleaning .
system description'3
(units vented)
Control
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throughput
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Control
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-------
the Washex Machinery Corporation, two dryers, two solvent tanks,
a muck cooker, and a dual-canister carbon adsorber manufactured
by VIC Manufacturing company. The system was installed in 1967.
Testing was conducted in November 1975.* Emissions from the
washer door vent, the dryers, and the floor vents are vented to
the carbon adsorber. Figure C^l illustrates the process
equipment and emission points for Plant A. During the testing
program, the plant water-proofed and flame-proofed several loads
of materials. These operations are not typical dry cleaning
services. The addition of water-repellant and flame-retardant
solutions during the wash cycle was accounted for in material
balance calculations.
Test results indicate total solvent losses of 5.37 kg of PCE
per 100 kg of clothes (5.37 Ib PCE/100 Ib of clothes) cleaned
(refer to Table C-l). Vented emissions from the carbon adsorber
outlet averaged about 0.2 kg PCE/100 kg of clothes (0.2 Ib
PCE/100 Ib of clothes). The inlet to the carbon adsorber
measured approximately 4.6 kg PCE/100 kg of clothes. Thus, as
shown in Table C-2, the carbon adsorber was achieving a
96 percent removal efficiency.
Sludge samples from the muck cooker contained 0.96 kg
PCE/100 kg of clothes (0.96 Ib PCE/100 Ib of clothes).
Based on observations during the test, housekeeping
practices at Plant A were poor. Liquid leaks were sighted and
buckets of solvent on the outlets of the water separators were
left uncovered. The scent of PCE was prevalent throughout the
plant. These unquantified emissions, as well as aqueous
emissions from the water separators and vapor emissions during
clothing transfer from the washer to the dryer, totaled 4.21 kg
PCE/100 kg of clothes (4.21 Ib PCE/100 Ib of clothes).
C.2 PLANT B
Plant B is an industrial PCE dry cleaning plant. The plant,
located in San Antonio, Texas, began operation in 1957 and was
tested in March 1976.4 The dry cleaning system, installed
between 1970 and 1975, is an American Laundry Machinery system
that includes a washer/extractor with a capacity of 136 kg
C-4
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C-5
-------
(300 Ib), a "kissing" dryer, distillation unit, muck cooker and
single-bed carbon adsorber (refer to Figure C-2). Only emissions
from the washer and dryer are vented to the adsorber. The carbon
adsorption unit collects PCE during clothing transfer, aeration,
and dryer unloading. Figure C-2 illustrates the process
equipment and emission points for Plant B.
The "kissing" washer/dryer is uncommon in the dry cleaning
industry. At the end of the wash cycle, the dryer is
pneumatically rolled to within 0.3 meters (approximately 1 ft) of
the washer, both doors are opened, and operators pull clothes
from the washer to the dryer. This design reduces the time that
PCE-laden clothes are exposed to the workspace compared to
standard transfer systems. During the transfer operation,
exhaust fans inside both the washer/extractor and the dryer
operate to divert emissions of PCE from the room to the
atmosphere.
Test results in Table C-l show a total solvent loss of
approximately 2.35 kg of PCE per 100 kg of clothes (2.35 Ib
PCE/100 Ib of clothes) cleaned. Vented emissions from the
adsorber averaged about 0.002 kg PCE/100 kg of clothes (0.002 Ib
PCE/100 Ib of clothes). The inlet to the carbon adsorber
measured 7.7 kg PCE/100 kg of clothes (7.7 Ib PCE/100 Ib of
clothes). Thus, as shown in Table C-2, the adsorber achieved
greater than 99 percent removal efficiency. Most of the PCE
emissions were from a washer-loading exhaust, a distillation unit
vent, and a muck cooker vent. The washer-loading exhaust is
vented to the atmosphere during loading of the washer drum. The
distillation unit and muck cooker are vented through a
water-cooled condenser to the atmosphere. Samples were taken of
these sources and total average emissions were 1.25 kg PCE per
100 kg of clothes cleaned (1.25 Ib PCE/100 Ib of clothes).
Exemplary housekeeping practices were followed at the plant,
thereby reducing fugitive emissions. No solvent leaks were
detected by sight or smell. Miscellaneous solvent losses totaled
1.08 kg PCE per 100 kg of clothes cleaned (1.08 Ib PCE/100 Ib of
C-6
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C-7
-------
clothes). Of this amount, 0.026 kg PCE/100 kg of clothes
(0.026 Ib PCE/100 Ib of clothes) were aqueous emissions from
water separators, and the remainder were unquantified fugitive
emissions and muck cooker solid waste.
C.3 PLANT C
Plant C is a commercial PCE plant located in Kalamazoo,
Michigan. Testing was performed in April 1976.6 Plant C
includes a dry-to-dry VIC Model 221 Strato system with a capacity
of 18 kilograms (40 Ib). This is an average-size commercial
dry-to-dry machine. The plant also includes a dual-canister
carbon adsorber and a disposable 14-cartridge paper filter. The
dry cleaning machine vents to the carbon adsorber during the
drying cycle and open door cycle. Floor vents are connected to
the carbon adsorber, also. The cartridge filter purifies PCE
after the wash cycle. Figure C-3 illustrates the process
equipment and emission points for Plant C.
Test results yielded an emission rate of 2.12 kg of PCE per
100 kg of clothes cleaned (2.12 lb/100 Ib of clothes). Because
there is no condenser between the dryer and carbon adsorber to
collect PCE, the PCE concentration at the inlet of the carbon
adsorber averaged 23.0 kg PCE/100 kg of clothes cleaned (23.0 Ib
PCE/100 Ib of clothes). Emissions from the carbon adsorber
outlet averaged 0.7 kg PCE/100 kg of clothes cleaned (0.7 Ib
PCE/100 kg of clothes). As shown in Table C-2, the carbon
adsorber achieved an efficiency of 97 percent. Cartridge filter
losses, determined by weighing used filters before and after the
PCE had evaporated from them, amounted to 0.6 kg PCE/100 kg of
clothes cleaned (0.6 Ib PCE/100 Ib of clothes). Unquantified
fugitive emissions and aqueous emissions from the water separator
were 0.82 kg of PCE/100 kg of clothes (0.82 Ib PCE/100 Ib of
clothes).
C.4 PLANT D
Plant D is a commercial PCE dry cleaning plant located in
Cortland, New York (Figure C-4). Testing was performed in
March 1979.8 The plant uses a dry-to-dry machine with a capacity
of 20 kg (45 Ib). The machine, a Detrex Model 11-20-H, was
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installed in 1976. The dry cleaning system uses a Kleen-Rite
(model #34-1200) disposable cartridge filter system for purifying
the PCE. A 17-year-old Hoyt Model I carbon adsorber (with the
original carbon) receives emissions from the dry cleaning machine
only during the aeration and open-door cycles.
Test results (refer to Tables C-l and C-2) indicate a total
emission rate of 7.47 kg of PCE per 100 kg of clothes cleaned
(7.47 lb PCE/100 lb of clothes). Emissions from the carbon
adsorber outlet averaged about 0.1 kg PCE/100 kg of clothes
(0.1 lb PCE/100 lb of clothes). The inlet to the carbon adsorcer
averaged approximately 3.3 kg PCE/100 kg of clothes cleaned
(3.3 lb PCE/100 lb of clothes) when the carbon adsorber was
desorbed daily. Therefore, the adsorber was achieving a
97 percent removal efficiency. This system demonstrated that
carbon adsorption can achieve high removal efficiencies even with
older carbon beds, as long as the bed is desorbed frequently. In
this test, when the adsorber Figure C-3 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, carbon bed 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. Cartridge filter losses were
determined by weighing used filters before and after the PCE had
evaporated from them. The PCE loss from the cartridge filters
was 2.73 kg/100 kg throughput (2.73 lb/100 lb throughput), which
represents over one-third of the total losses.
The remainder of the emissions were attributed to fugitive
emissions, including leaks from valves in the solvent lines to
the filters. Enough PCE leaked during the night to form a small
puddle on the base tank of the machine. Fugitive losses totaled
4.64 kg PCE/100 kg of clothes (4.64 lb PCE/100 lb of clothes).
C.5 PLANT E
Plant E is a commercial PCE dry cleaning plant located in
Northvale, New Jersey. The dry cleaning equipment at this plant
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consists of a Neil and Spencer Limited dry-to-dry machine and a
refrigerated condenser. The plant was estimated to be 5 years
old, whereas the dry cleaning machine was 6 months old at the
time of testing in June 1979.9 The dry cleaning machine had a
rated capacity of 30 kg (65 Ib). The refrigerated condenser was
designed to serve up to a 30-kg (65-lb) machine.
Inlet and outlet concentrations to the dryer were measured.
However, because the system is completely closed, emissions from
the process could not be measured. Although an emissions removal
efficiency has been calculated for a single-pass control device,
this condenser is a closed system with a multi-pass
configuration, so its removal efficiency is expected to be much
higher. Net usage of PCE during the duration of the test was
3.85 kg PCE/100 kg of clothes cleaned (3.85 Ib PCE/100 Ib of
clothes cleaned).10 Thus, when fugitive and filter losses are
minimal, refrigerated condensers can achieve sol/ent loss rates
equivalent to carbon adsorber-equipped facilities.
Four documented but unquantified leaks existed at the plant.
Vapor leaks occurred at a muck drain valve, the water separator
lid, and a connecting valve between the dryer and condenser.
Liquid PCE leaked from the base of the dryer drum.
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C.6 REFERENCES
1. Test report. Kleeberg, C. F., EPA/ISB, to Durham, J. F.,
EPA/CPB, March 17, 1976. Material Balance of a
Perchloroethylene Dry Cleaning Unit: Hershey, Pennsylvania.
2. Scott Environmental Technology, Inc., A Survey of
Perchloroethylene Emissions from a Dry Cleaning Plant:
Hershey, Pennsylvania. March 1976. Test No. 76-DRY-l.
3. Watt, A. IV, and W. E. Fisher, International Fabricare
Institute. January/February 1975. Results of Membership
Survey of Dry Cleaning Operation. IFI Special Reporter
No. 3-1.
4. Test report. Kleeberg, C. F., EPA/ISB, to Durham, J. F.r
EPA/CPB, May 14, 1976. Testing of Industrial
Perchloroethylene Dry Cleaner: San Antonio, Texas.
5. Midwest Research Institute. Test of Industrial Dry Cleaning
Operation at Texas Industrial Services, San Antonio, Texas.
April 28, 1976. Test No. 76-DRY-2.
6. Test report. Kleeberg, C. F., EPA/ISB, to Durham, J. F.,
EPA/CPB, May 17, 1976. Testing of Commercial
Perchloroethylene Dry Cleaner: Kalamazoo, Michigan.
7., Midwest Research Institute. Source Test of Dry Cleaners.
June 25, 1976. Test No. 76-DRY-3.
8. Test report. Jongleux, R. F., TRW, Inc., to EPA/EMB,
November 1979. Perchloroethylene Emissions Testing at Kleen
Korner, Cortland, New York. Publication No. EMB 76-DRY-6.
9. Test report. Jongleux, R. F., TRW, Inc., to EPA/EMB,
April 1980. Material Balance Test - Perchloroethylene
Refrigerated Closed System, Northvale, New Jersey.
Publication No. EMB 79-DRY-7.
10. Ref. 9, p. 2.
C-13
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APPENDIX D
EMISSION MEASUREMENT AND MONITORING
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APPENDIX D
EMISSION MEASUREMENT AND MONITORING
D.I EMISSION MEASUREMENT METHODS
D.I.I Emission Measurement Method for Perchloroethvlene from
Exhaust Vents
The primary method used to gather perchlbroethylene
emissions data from exhaust vents has been an integrated bag
sampling procedure followed by gas chromatographic/flame
ionization detector analysis (GC/FID). Conditional Test
Method Oil (CTM-011), distributed by the Emission Measurement
Technical Information Center (EMTIC), entitled "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 GC
column is employed that has been recommended by a major
manufacturer of chromatographic equipment as useful for the
separation of chlorinated solvents.
The method was written after an initial EPA-funded study of
halogenated techniques identified the need. In particular, the
study cited leaking bags and bag containers as probable cause of
poor correlation between integrated and grab samples taken from
an emission site. In light of these findings, more rigorous
leak-check procedures were incorporated into the original method.
The subsequent test conducted by EPA with the improved method
compared both integrated bag and grab sampling techniques in
order to gather quality control data. The test showed very good
correlation between the two techniques.
In the EPA tests, all nonmethane hydrocarbon peaks were
summed to yield a total value. Since perchloroethylene was
anticipated to be the major constituent, all calibrations and
calculations were based on perchloroethylene standards. In the
three tests performed by EPA, little, if any, nonmethane
hydrocarbon other than perchloroethylene was measured.
D-l
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With slight modifications as noted in the test reports,
velocity measurements on inlet and outlet ducts were done
according to EPA Test Methods 1 and 2.
D.I.2 Pei-chloroethvlene from still Residues and Wet Waste
Material from Reaenerable Filters
The method used to determine perchloroethylene content in
the still residues and wet waste material from regenerable
filters has been a distillation procedure. Conditional Test
Method 010 (CTM-010), distributed by the EMTIC, entitled
"Determination of Perchloroethylene Content of Wet Waste
Materials from Filters and Still Bottoms," describes this
approach. A known sample mass is mixed with water and placed in
a glass still equipped with a Liebig* straight-tube type reflux
condenser and a Bidwell-Sterling* type graduated trap. Water and
perchloroethylene in the sample are separated through repeated
distillation until all the perchloroethylene has been recovered
in the trap and the volume recorded. The mass of
perchloroethylene collected is determined from the product of its
volume and specific gravity. The total weight of
perchloroethylene obtained is divided by the total weight of
sample analyzed to obtain the perchloroethylene content of the
wet waste residue.
D.2 LEAK DETECTION MONITORING
Hand-held halogen detectors are currently available for leak
monitoring in dry cleaning facilities. The detectors respond to
gases containing chloride. The TIF* detector uses a
computer-like beeping sound that increases in both speed and
frequency as the leak source is approached. The detector also
automatically recalibrates itself when turned off and on. The
cost of a monitoring instrument ranges from about $130 to $200
depending on the operating features and accessories.
*The mention of a trade name or specific product does not
constitute endorsement by the Environmental Protection Agency.
D-2
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D.3 PERFORMANCE TEST METHODS
D. 3.1 Perchloroethylene from Exhaust Vents
The CTM-011, "Determination of Halogenated Organics from
Stationary Sources," is recommended as the emission test method
for exhaust vents. An improved leak check procedure has been
added to CTM-011, at the suggestion of an EPA contractor who
studied the vinyl chloride test method. This contractor
coincidentally performed the second and third dry cleaning
emission data tests and was previously aware of the need for
exercising particular caution with respect to leak detection. No
significant problems with the use of CTM-011 are expected,
provided that strict adherence is given to the leak-check
procedures.
The costsfor conducting a CTM-011 emission test in
triplicate by a source testing contractor will depend on the
length of the process cleaning cycle and the distance travelled
by testing personnel, and are accordingly estimated at $3,000 to
$5,000 for single unit installation. The testing cost per unit
would be lower if several units at a single site were serially
tested.
D.3.2 Perchloroethvlene from Still Residues and Wet Waste
Material from Recrenerable Filters
The CTM-010 test method as described in D.I.2 is recommended
as the performance test method. No problems are anticipated with
the use of this method.
The cost for conducting the analytical portion of this test
on triplicate samples is estimated at $200.
D-3
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TECHNICAL REPORT DATA
(Please read Instructions on the reverse before completing)
REPORT NO.
EPA 450/3-91-0203
2.
I. RECIPIENT'S ACCESSION NO.
TITLE AND SUBTITLE
Dry Cleaning Facilities
for Proposed Standards
- Background Information
5. REPORT DATE
November 1991
6. PERFORMING ORGANIZATION CODE
AUTHOR(S)
8. PERFORMING ORGANIZATION REPORT NO.
PERFORMING ORGANIZATION NAME AND ADDRESS
Office of Air Quality Planning and Standards
U. S. Environmental Protection Agency
Research Triangle Park, North Carolina 27711
10. PROGRAM ELEMENT NO.
11. CONTRACT/GRANT NO.
68-01-0117
2. SPONSORING AGENCY NAME AND ADDRESS
Director
Office of Air Quality Planning and Standards
U. S. Environmental Protection Agency
Research Triangle Park, North Carolina 27711
13. TYPE OF REPORT AND PERIOD COVERED
14. SPONSORING AGENCY CODE
EPA/200/04
5. SUPPLEMENTARY NOTES
6. ABSTRACT
National emission standards for the control of hazardous air pollutant emissions
from the dry cleaning industry are being proposed under the authority of Section 112
of the Clean Air Act, as amended. These standards apply to existing and new dry
cleaning facilities, the construction or reconstruction of which began on or after
the date of proposal. This document contains a summary of the technical information
used to support development of the standards. This document also discusses the
regulatory alternatives considered during development of the proposed standards
and the environmental and cost impacts associated with each alternative. A detailed
"Economic Impact Analysis of Regulatory Controls in the Dry Cleaning Industry" is
contained in EPA-450/3-91-021 dated October 1991.
KEY WORDS AND DOCUMENT ANALYSIS
DESCRIPTORS
b.lDENTIFIERS/OPEN ENDED TERMS
c. COSATl Field/Group
Air pollution
Dry cleaning
Hazardous air pollutants
Emission controls
Air pollution control
13B
18. DISTRIBUTION STATEMENT
Unlimited
19. SECURITY CLASS (This Report I 21. NO. <
JNCLASSIFIED ! 145__
i20. SECURITY CLASS ITliis pagei
\ UNCLASSIFIED
j22. PRICS
Form 2220-1 (Rev. 4-77) PREVIOUS EDITION is OBSOLETE
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