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          Research Triangle
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      Novempef 1991
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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
                               Vlll

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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's—perchloroethylene  (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
 identical—95 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
                               1-2

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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
                                2-1

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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

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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
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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

                               2-8

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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

                               2-10

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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 necessary—considering costs, energy, safety, and
                                2-11

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other relevant factors—to prevent an adverse environmental
effect.
                              2-12

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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;
                                3-1

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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.
                               3-2

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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

                                3-3

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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.

                                 3-5

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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.

                               3-6

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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

                               3-8

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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.
                                 3-9

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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

                              3-10

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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 problem—leaks 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
                                3-11

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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

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      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

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                    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

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 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

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   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

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 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

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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

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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

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 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 streams—one 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

-------
                                        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

-------
 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

-------
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 frequent—often
daily—desorption.  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

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feasibility of solvent switching as an emission control
technique.
                              4-12

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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

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 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

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      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
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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.
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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)

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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
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 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
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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.18•19
     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

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 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
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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.
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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
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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

-------
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

-------
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

-------
         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

-------
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

-------

-------
                   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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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

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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

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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

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    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

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                        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

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 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

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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

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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

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                   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 meeting—background
information.

Meeting with industry representatives,
Radian, and EPA at EPA Offices,  Durham,
North Carolina.

Work Group meeting—present control
options.

Enactment of CAA Amendments
(Title III—Hazardous Air Pollutants).
                               A-i

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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 meeting—status 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

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                 APPENDIX B




INDEX TO ENVIRONMENTAL IMPACT CONSIDERATIONS

-------

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                           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

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     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

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       APPENDIX C




EMISSION SOURCE TEST DATA

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-------
                            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
device
throughput
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Control
device inlet
concentration


Control
outlet
concentration

-------
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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Figure  C-2.   Flow diagram of Plant  B,
                                 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

                                C-8

-------
                                T'l
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                                 C-9

-------
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
 gep.003
                                C-10

-------
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Figure C-4.  Flow diagram of Plant D,
gep.003
C-ll

-------
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.
 gep.003
                               C-12

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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 costs•for 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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