i:-4iloiterf States
Environmental Protection-
Agency < ' • „ .
Office of Air Quality
Planning and Standards
Research Triangle Park NC 27711
EPA-4SO/3-82-O12b
.September 1 984 :
Air
Petroleum Final
Dry Gleaners - EIS
Background
Information for
Promulgated Standards
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EPA-450/3-82-012b
Petroleum Dry Cleaners -
Background Information
for Promulgated Standards
Emission Standards and Engineering Division
U.S ENVIRONMENTAL PROTECTION AGENCY
Office of Air, Noise, and Radiation
Office of Air Quality Planning and Standards
Research Triangle Park, North Carolina 27711
September 1 984
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This report has been reviewed by the Emission Standards and Engineering Division of the Office
of Air Quality Planning and Standards, EPA, and approved for publication. Mention of trade
names or commercial products is not intended to constitute endorsement or recommendation
for use. Copies of this report are available through the Library Services Office (MD-35), U.S.
Environmental Protection Agency, Research Triangle Park, N.C. 27711, or from National
Technical Information Services, 5285 Port Royal Road, Springfield, Virginia 22161.
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. TABLE OF CONTENTS
Section Page
1 SUMMARY ..... 1-1
1.1 SUMMARY OF CHANGES SINCE PROPOSAL. . . ... . . . . 1-1
1.2 SUMMARY OF IMPACTS OF THE PROMULGATED ACTION . . . . 1-2
1.2.1 Alternatives to the Promulgated Action. . . . 1-2
1.2.2 Environmental Impacts of the
Promulgated Action ... 1-2
1.2.3 Energy and Economic Impacts of the
Promulgated Action . 1-2
1.2.4 Other Considerations 1-2
2 SUMMARY OF PUBLIC COMMENTS. 2-1
2.1 SAFETY OF SOLVENT RECOVERY DRYERS ......... 2-1
2.2 SELECTION OF THE SOURCE CATEGORY 2-5
2.3 APPLICABILITY AND SELECTION OF THE AFFECTED
FACILITY 2-7
2.4 PROJECTION OF THE NUMBER OF AFFECTED FACILITIES. . . 2-14
2.5 ECONOMIC IMPACT. . 2-16
2.6 TEST METHODS AND PROCEDURES. 2-18
LIST OF TABLES
List of Commenters on Proposed Standards for the
Petroleum Dry Cleaning Industry
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. 1, SUMMARY
On December 14, 1982, the Environmental Protection Agency (EPA)
proposed standards of performance for petroleum dry cleaners (47 FR 56118)
under authority of Section 111 of the Clean Air Act. Public comments
were requested on the proposal in the Federal Register. There were four
commenters composed mainly of industry trade association representatives
and State and local regulatory agencies. Also commenting was one equipment
manufacturer. The comments that were submitted, along with responses to
these comments, are summarized in this document. The summary of comments
and responses serves as the basis for the revisions made to the standard
between proposal and promulgation.
1.1 SUMMARY OF CHANGES SINCE PROPOSAL
In response to the public comments and as a result of reevaluation,
certain changes have been made in the proposed standards. The equipment
specifications and operating procedures determined to be the best
technological system of continuous emissions reduction have not changed.
The installation of solvent recovery dryers and the identification and
repair of solvent leaks remains the basis for the standard. However,
several changes have been made in the applicability provisions of the
standard.
First, the definition of affected facilities was changed. Small
plants are now exempted on the basis of the total manufacturers' rated
capacity of the petroleum solvent dry cleaning dryers at the plant,
rather than on the basis of the annual solvent consumption. This revised
definition is equivalent, in terms of potential impacts on the petroleum
solvent dry cleaning industry, to the definition in the proposed standard.
Only the format of the exemption was changed. The affected equipment
types (i.e., dryers, filters, stills, and settling tanks) remain the
same.
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Second, a subsection was added to the definition of affected
facilities to clarify which dryers should and should not be considered
in calculating the total manufacturers' rated dryer capacity of the
plant for the purposes of comparison with the dryer capacity exemption
level. Clarification was needed to ensure that permanently retired
dryers are not considered in determining the total dryer capacity of the
plant.
Finally, the recordkeeping requirement to document and maintain the
calculation of annual petroleum solvent consumption of the dry cleaning
plant was eliminated. The change in the definition of affected facilities
obviates the need for this requirement.
1.2 SUMMARY OF IMPACTS OF PROMULGATED ACTION
1.2.1 Alternatives to the Promulgated Action
The regulatory alternatives are discussed in Chapter 6 of Volume I
of the background information document (Volume I BID) for the proposed
standards (EPA-450/3-82-012a). These regulatory alternatives reflect
the different levels of emission control that were analyzed in determining
best demonstrated technology, considering costs, nonair quality health,
and environmental and economic impacts for petroleum dry cleaners.
These alternatives remain the same.
1.2.2 Environmental Impacts of the Promulgated Action
The environmental impacts resulting from the proposed standard are
described in Chapter 7 of the Volume I BID. No changes in these impacts
have occurred since the standard was proposed.
1.2.3 Energy and Economic Impacts of the Promulgated Action
Energy and economic impacts resulting from the standard are discussed
in Chapters 7 and 9 of Volume I of the BID, respectively. No changes in
these impacts have occurred since the standard was proposed.
1.2.4 Other Considerations
1.2.4.1 Irreversible and Irretrivable Commitment of Resources. The
regulatory alternatives defined in Chapter 6 of Volume I of the BID
would not preclude the development of future control options nor would
they curtail any beneficial use of resources. The alternatives do not
involve short-term environmental gains at the expense of long-term
environmental losses. The alternatives yield successively greater
short- and long-term environmental benefits, with the alternative upon
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which the final standards are based providing the greatest benefits.
Further, none of the alternatives result in the irreversible and
irretrievable commitment of resources. No changes in these considerations
have resulted since proposal of the standard.
1.2.4.2 Environmental and Energy Impacts of Delayed Standards. As
discussed in Chapters 1 and 7 of Volume I of the BID, delay in the
standard would cause a similar delay in realizing the beneficial impacts
associated with the standard. No changes in the potential effects of
delaying the standard have occurred since proposal.
1.2.4.3 Urban and Community Impacts. Urban and community impacts
of the proposed standard are discussed in Chapter 9 of Volume I of the
BID. No changes in these impacts have occurred since the standard was
proposed.
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2. SUMMARY OF PUBLIC COMMENTS
A total of four (4) letters commenting on the proposed standard and
the background information document were received. A public hearing was
not requested, and consequently no public hearing was held. A list of
the commenters, their affiliations, and the EPA docket numbers assigned
to their correspondence is given in Table 2-1.
For the purpose of orderly presentation the comments have been
categorized under the following topics:
1. Safety of Solvent Recovery Dryers;
2. Selection of the Source Category;
3. Applicability and Selection of the Affected Facility;
4. Projection of Affected Facilities;
5. Economic Impact; and
6. Test Methods and Procedures.
The comments, the issues they address, and responses to each comment
are discussed in the following sections of this document.
.2.1 SAFETY OF SOLVENT RECOVERY DRYERS -
2.1.1 Comment: (IV-D-3) One commenter questioned the safety of solvent
recovery dryers, which are required by the proposed standard to control
emissions of volatile organic compounds (VOC) from dryers. He acknowledged
that the question had been investigated early in the standard development
process. At that time, the safety of the recovery dryer was adequately
demonstrated by industry operating experience and Factory Mutual Research
Corporation's certification that the technology conformed to the National
Fire Protection Association's guidelines. However, since proposal of
the standard, an explosion of a solvent recovery dryer occurred. The
commenter requested, therefore, that no action to finalize the standard
be taken until this incident had been fully investigated.
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Table 2-1. LIST OF COMMENTERS ON PROPOSED STANDARDS FOR THE
PETROLEUM DRY CLEANING INDUSTRY
Docket Item Numberc
Commenter and Affiliation
IV-D-1
IV-D-2
IV-D-3
IV-D-4
Stanley Rosenthal
Washex Machinery Corporation
5000 Central Freeway
Wichita Falls, TX 76306
Date: January 6, 1983
Daniel J. Goodwin
Division of Air Pollution Control
Illinois Environmental Protection
Agency
2200 Churchill Road
Springfield, IL 62706
Date: February 10, 1983
Timothy A. Vanderver
Patton Boggs & Blow
2550 M Street, NW
Washington, D.C. 20037
Date: March 8, 1983
(Comments submitted on behalf of the
Internal Fabricare Institute,
Institute of Industrial Launderers
and the Textile Rental Services
Association of America)
Judith M. Lake
Air Pollution Control District
County of San Diego
9150 Chesapeake Drive
San Diego, CA 92123
Date: March 4, 1983
The docket number for this project is A-80-2. Dockets are on file at
EPA Headquarters in Washington, D.C. and at the Office of Air Quality
Planning and Standards in Durham, N.C.
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Response: The use of both solvent recovery and conventional dryers
presents risks of explosions or fires because petroleum solvent is a
highly flammable liquid. Petroleum dry cleaners minimize these incidents
by removing metal articles and other objects that might ignite the
solvent from clothes prior to dry cleaning. However, when the solvent
does ignite, fires tend to occur in conventional dryers while minor
explosions tend to occur in solvent recovery dryers. This latter tendency
led to a careful evaluation of solvent recovery dryer safety before the
standards of performance were proposed. The investigation identified
19 cases of solvent recovery dryer explosions. However, in each of
these cases the safety features designed into the solvent recovery dryer
had safely vented the explosion with only minor damage to the dryer
itself.
Factory Mutual Research Corporation's certification for insurance
underwriting that solvent recovery dryers complied with the National
Fire Protection Association's code in combination with industry operating
experience indicated that the safety of recovery dryers was adequately
demonstrated to consider them as a basis for standards of performance.
As discussed in the Federal Register at proposal, however, decisions
concerning safety are in the hands of safety officials, and standards of
performance will not require the use of any device safety officials
consider unsafe.
Since proposing the standard, two cases of solvent recovery dryer
explosions have occurred (see Docket Items IV-B-1 and IV-B-2). These
incidents differ from those investigated before proposal of the standards
because the force of these explosions reportedly caused the loading door
assembly panel to break away from the dryer. The detached panels,
weighing about 300 to 400 pounds, were found at a distance of 8 to
10 feet from the dryers.
The domestic recovery dryer manufacturer and Factory Mutual Research
Corporation were asked to investigate these explosions and comment on
whether their previous judgements concerning the safety of solvent
recovery dryers have changed in light of their findings. Both the
manufacturer and Factory Mutual Research Corporation agreed to do so.
The manufacturer's response maintains that solvent recovery dryers
are safe when operated in conformance with National Fire Protection
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Association (NFPA) codes (Docket Items IV-D-6 and IV-D-10). In addition,
the following comments were made:
1. Attention must be paid by operators to ensure proper maintenance
of the equipment;
2. The inspection of garments prior to cleaning to remove possible
sources of ignition (i.e. butane lighters, metal objects,
etc.) is of the utmost importance to safe operation; and
3. The manufacturer is in the process of developing a front panel
locking assembly to assure additional machine integrety in the
event of explosion due to improper maintenance or inspection
techniques.
The Factory Mutual Research Corporation also responded by re-testing
commercially available solvent recovery dryers under explosion conditions
(Docket Item IV-D-11). Unlike the solvent recovery dryers originally
tested, the dryers involved in this testing were equipped with casing
front restraining devices. Moreover, the testing procedure employed a
propane/air mixture (rather than a Stoddard solvent/air mixture) to
produce the explosion. Based on the results of the tests, Factory
Mutual concluded that the solvent recovery dryer design (including the
casing front restraining device) meets NFPA codes. Factory Mutual
further indicated that the casing front restraining device, which provides
additional strength to the front of the dryer casing, will be an approval
requirement for new solvent recovery dryers.
In light of this review of the safety of solvent recovery dryers
and the conclusions drawn by both the manufacturer of this dryer and
Factory Mutual Research Corporation regarding its safety, the basis of
the promulgated standards remains the use of solvent recovery dryers.
2.1.2 Comment: (IV-D-3) One comnienter speculated that the installation
of solvent recovery dryers in certain limited circumstances can be
prohibited by the responsible State or local safety official. Further,
the standard, which mandates the use of solvent recovery dryers to the
exclusion of conventional dryers, could place an existing facility in
the "untenable position" of having no equipment options that would
satisfy both the requirements imposed by the standard and the restraints
imposed by the safety official. To allow an existing plant that finds
itself in this situation the opportunity to expand or to replace equipment,
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the commenter requests that a variance provision be included in
Section §60.622(a) that exempts an existing facility from the solvent
recovery dryer requirement if the installation of solvent recovery
dryers is prohibited by the responsible safety official.
Response: It is unlikely that an owner or operator of a dryer
affected by the new source performance standards would be placed in the
untenable situation described by the commenter. A survey of insurance
underwriters and fire marshals conducted before the standards were
proposed, identified no incident where the installation of a solvent
recovery dryer was prohibited because it was considered to be unsafe.
Moreover, a clearly defined procedure exists for determinations of
equipment safety. In the case of dry cleaning equipment, industry and
national safety experts under the auspices of the National Fire Prevention
Association (NFPA) develop standards or codes for the purpose of ensuring
safe plant and equipment operation. These codes for dry cleaning are
set forth in NFPA standard No. 32 as revised in 1979. Actual equipment
designs are evaluated against the NFPA standards by the Factory Mutual
Research Corporation underwriters laboratory, which certifies equipment
as meeting the requirements of the NFPA codes. On a local, or case by
case basis, the enforcement of safety requirements such as the NFPA
codes are the purview of local safety officials. Because the solvent
recovery dryer has been certified as meeting the NFPA code and included
by the Factor Mutual Research Corporation on the list of equipment that
is approved for insurance underwriting, it is unlikely that local officials
would prohibit installations of the dryers.
2.2 SELECTION OF THE SOURCE CATEGORY
2.2.1 Comment: (IV-D-3) One commenter questioned the need for a
standard at all in light of the favorable economic incentives that have
been estimated to exist with the installation of solvent recovery dryers.
The commenter asserted that if the cost estimates in the Volume I BID
and preamble are correct, the "economic considerations will insure the
installation of recovery dryers in virtually every situation in which
the regulation might require it". He further asserted that the remaining
requirements of the standard (i.e., cartridge filters and leak detection)
by themselves do not have sufficient environmental impact to justify
rulemaking. On this basis, the commenter requests a review of the
entire rulemaking docket to ascertain whether rulemaking is needed.
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Response: While economic incentives for the installation of solvent
recovery dryers do exist, these incentives are not sufficient to ensure
the application of solvent recovery dryers. Although solvent recovery
dryers in most situations will produce a cost savings in comparison to
the use of a conventional dryer, their installation requires a capital
investment that is greater than that for a conventional dryer by a
margin that is significant in terms of the working capital available to
most dry cleaning establishments. Without the new source performance
standard, an owner or operator considering expansion may elect not to
make the additional investment required for a solvent recovery dryer
because of the additional financial obligation. Alternately, the rate
of return for the solvent recovery dryer may not be attractive for the
given situation or may be less attractive than that for alternate
investment opportunities. Complicating this decision process is the
fact that knowledge of the savings associated with solvent recovery
dryers is not universal among dry cleaning operators. Consequently,
many owners or operators may not be aware of the economic incentive for
selecting solvent recovery dryers. For these reasons, standards of
performance for petroleum dry cleaners are necessary to ensure reductions
in VOC emissions from petroleum dry cleaning plants.
The cartridge filter and leak detection requirements of the standard,
irrespective of the solvent recovery dryer requirement, result in
beneficial environmental impacts. Cartridge filters emit less than
diatomite filters by about 4 to 9 pounds of solvent per 100 pounds of
clothes cleaned. This compares with the 10 to 25 pounds per 100 pounds
of clothes cleaned emissions reduction obtained from the use of a solvent
recovery dryer in lieu of a conventional dryer (Reference BID, Volume I).
Emissions reductions from solvent leaks in equipment and other fugitive
emissions units covered by the leak detection and repair provisions
cannot be directly measured; however, these losses have been roughly
estimated to be 1 pound per 100 pounds of clothes cleaned. Contrary to
the assertion of the commenter, the resultant environmental benefits
from emissions reductions from the cartridge filter and leak detection
requirements are considered to be significant. For this reason, they
were and continue to be incorporated into the petroleum dry cleaning
standard.
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2.3 APPLICABILITY AND SELECTION OF THE AFFECTED FACILITY .,;
2.3.1 Comment: (IV-D-3) One commenter expressed concern that the
applicability section of the proposed standards could be interpreted to
mean that the standard applies to used equipment and that in this way
the,standard would preclude the installation ..of used equipment (namely
used conventional dryers and diatomite filters) as a low cost alternative
for small plants to replace failing equipment. In the commenter's view
"the Clean Air Act provides no basis for attempting to apply new source
standards to such used equipment." The commenter requested that used
equipment be specifically excluded from the effects of the standard and
language be included in the preamble to the promulgated standard to
clarify that equipment can be used at different locations without
triggering new source performance standard requirements.
Response: The petroleum dry cleaning standards, as with all new
source performance standards, apply only to newly constructed, modified
and reconstructed affected facilities. A piece of used equipment
constitutes an "existing facility" that is not affected by the standard
unless it is "modified" or "reconstructed" as defined in the general
provisions applicable to all new source performance standards
(Reference 40 CFR 60.14 and 60.15, respectively). The simple relocation
of existing equipment does not constitute modification or reconstruction.
Briefly, a modification is triggered by a physical change or a change in
the method of operation of an existing facility that requires a capital
expenditure and also results in an increase in emissions. Reconstruction
occurs when an existing facility is refurbished and the fixed capital
cost of the new components exceeds 50 percent of the fixed capital cost
that would be required to construct a comparable entirely new facility.
In addition, a reconstructed facility is subjected to the standards only
on a case-by-case basis depending on a judgement that it is technologically
and economically feasible to meet the standard. Applicability decisions
must be made considering the facts and circumstances of each individual
case.
2.3.2 Comment: (IV-D-2) One commenter questioned the selection of the
factor (56 gallons of solvent per pound of manufacturer's rated dryer
capacity) that is used in the definition of affected facilities to
determine if new plants are subject to the standards. He felt that the
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factor should be derived from the model plant parameter data included in
Table 6-1 of the Volume I BID by averaging the solvent use per unit of
dryer capacity estimates for the various model plant types affected by
the standard. Based on this approach, the commenter proposed a factor
of 59 gallons of solvent per pound of manufacturers' rated dryer capacity
for use in the definition of the affected facilities. He noted that the
basis for the 56 gallons of solvent per pound of dryer capacity factor
was not documented in the Volume I BID or the preamble to the proposed
regulation.
Response: The emission factor used to project the annual solvent
consumption rate for proposed new plants is based on the model plant
parameter data summarized in Table 6-1 of the Volume I BID. However,
rather than averaging the estimates of solvent use per unit of dryer
capacity over the range of model plant types potentially affected by the
standard, as suggested by the commenter, the factor is based on the
model plant parameters for the type and size of plant that is at or just
above the borderline between exempted and nonexempted plants. This
approach better insures a factor that is representative of the small
plants that will be affected by the standard. The factor will be less
representative of large plant operations, but this is of little consequence
because these plants clearly will be subject to the standard.
The methodology used in developing the factor was not laid out in
either the Volume I BID or the Preamble. Instead, it is explained in
the docket (see Docket Item II-B-50). In brief, the approach was to
calculate the factor directly from the daily and annual plant operating
data for the large commercial model plant (i.e. 9 loads per day; 250 days
per year from Table 6-1), and assumptions on the minimum average washer
load weight common to this plant size (70 percent of capacity), the
emission rate per unit of clothes cleaned (23 pounds solvent per 100 pounds
of clothes) and the solvent density (6.5 pounds per gallon).
In principle, this approach is similar to that recommended by the
commenter. The only significant difference is that the derivation
focuses on the model plant most representative of those which the small
plant exemption applies rather than the average of the range of plant
types potentially affected by the standard.
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2.3.3 Comment: (IV-D-3) One commenter expressed agreement with some
aspects of the small plant exemption that is incorporated into the
standard and disagreement with other aspects of the exemption. He
agreed that it is appropriate to have a small plant exemption and that
it is necessary to differentiate among new, replacement, and expanding
facilities in setting the exemption level. Also, he agreed with the
basic methodology employed in developing the plant size for the exemption.
However, he disagreed with other aspects of the exemption level and
felt that adjustments must be made to make it workable. Four adjustments
to the exemption level were requested.
First, the commenter suggested that the exemption level (4,700 gallons
per year based on a 132,170 pound of articles cleaned per year plant
throughput level) should be calculated using a solvent consumption rate
of 30 pounds per 100 pounds of articles cleaned instead of the 23 pound
per 100 pound rate used in the proposed standard. The resulting adjusted
exemption level (6,106 gallons of solvent per year) would be indicative
of a plant that employs a conventional dryer and a diatomite filter
rather than a plant with a conventional dryer and a cartridge filter
(the basis for the 23 pound per 100 pound solvent consumption rate).
The concern with the use of the 23 pound per 100 pound solvent consumption
rate is that it presumes the universal use of cartridge filters, which
are proposed by the standard, but not yet universally employed in the
industry. In further support of his contention that the 23 pound per
100 pound factor is inappropriate, he pointed out that cartridge filters
represent an additional capital investment not considered in the economic
analysis that determined the plant throughput level (132,170 pounds of
articles cleaned per year) used in calculating the solvent exemption
level.
Second, the commenter asked that the exemption level for new dry
cleaning plants be expressed in terms of the total manufacturer's rated
dryer capacity of the plant. This format is simpler and easier to
understand than the plant-wide solvent consumption rate format used in
the proposed standard. Further, because actual dryers are manufactured
in discrete 50 and 100 pound capacity sizes, the commenter argues that
the 4,700 gallons per year exemption level (roughly equivalent to an
84 pound dryer capacity exemption level) is only exempting the 50 pound
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capacity dryers. Consequently, the 4,700 gallons per year exemption
level is actually a 2,800 gallons per year exemption level. He requests
that the exemption level be set at a total dryer capacity of greater
than 110 pounds, based on a solvent consumption rate of 6,100 gallons
per year.
Third, the commenter requested that the exemption for existing dry
cleaning plants that are replacing dryers with dryers of the same capacity
be 110 pounds of dryer capacity. That is, only those plants that are
replacing more than 110 pounds of capacity should be affected by the new
source performance standard.
Fourth, the commenter requested that the exemption for existing
plants that are expanding their dry cleaning capacity also be 110 pounds
of capacity. That is, only those plants that are adding more than
110 pounds of capacity (i.e., the combined capacity of the proposed new
units) should be affected by the new source performance standard.
Response: The first concern raised by the commenter over the small
plant exemption level is the selection of the 23 pounds of solvent per
100 pounds of articles cleaned emission factor used in calculating the
4,700 gallons of solvent per year exemption level. The factor is actually
a total emission factor comprised of component emission factors for the
various types of dry cleaning equipment that exist at a particular
plant. Therefore, the selection of a factor implies the selection of
the equipment employed at the plant for which the factor applies.
Consequently, the selection of the most appropriate factor translates
into the selection of the particular equipment that is most representative
of a plant under consideration for exemption.
The commenter contends that diatomite filters rather than cartridge
filters should be considered because the cartridge filter is not yet
universally employed in the industry and, further, the cartridge filter
represents an additional capital investment not considered in estimating
the clothes throughput breakeven level (132,170 pounds). The emission
factor representative of a plant with a diatomite filter is 30 pounds
per 100 pounds of articles cleaned. This compares to the 23 pound per
100 pound factor used in developing the proposed exemption level.
Based on estimates received from an industry trade association
representative, the ratio of cartridge filter users to diatomite filter
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users is estimated to have been 50/50 in 1980 and is increasing with
time. Consequently, the assumed use of cartridge filters and the resulting
23 pounds of solvent per 100 pounds of articles cleaned emission factor
are the most appropriate assumptions that can be made in calculating the
small plant exemption level for new and existing plants.
The commenter's point about the capital investment of cartridge
filters not being considered in determining the exemption level requires
clarification. The exemption level determines the clothes throughput
required to generate sufficient solvent savings (due to the higher
degree of emissions control) to offset the additional annualized cost of
a solvent recovery dryer over that of a conventional dryer. The type of
filter used does not affect these cost differentials between solvent
recovery dryers and conventional dryers. For this reason, the additional
capital costs and emissions reductions associated with cartridge filters
were not considered in determining the exemption level.
The second concern raised by the commenter is that the exemption
level should be expressed in terms of dryer capacity rather than solvent
consumption because it is simpler and easier to apply. The solvent
consumption format for the exemption level was established in response
to industry comments received at the National Air Pollution Control
Techniques Advisory Committee (NAPCTAC) meeting in December 1981. As
expressed at that time, the primary concerns of the industry were that
the exemption level should be: easily understood; unambiguous; and
based on a parameter that already exists at the plants, rather than a
parameter that requires additional monitoring and recordkeeping. The
industry felt that annual solvent consumption met these requirements
and, as a result, recommended the use of an exemption expressed in terms
of annual solvent consumption.
It is clear, however, that an exemption expressed in terms of dryer
capacity is better than one expressed in terms of annual solvent
consumption. Compared with solvent consumption, dryer capacity requires
substantially fewer recordkeeping requirements. The manufacturer's
rated capacity is either stamped on the name plate of each individual
piece of equipment or readily available from the equipment specifications
provided by the manufacturer. The determination of whether the standard
applies to a particular facility is made by simple comparison of the
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rated capacity for the proposed unit (or collective capacities for
proposed multiple unit installations) to the applicability criterion.
The approach is straightforward and easily verifiable. It also is
simpler because no projection of expected future solvent use is required
as with solvent consumption. For these reasons, the exemption contained
in the final standard is structured in terms of dryer capacity.
The exemption level is now 84 pounds of manufacturer's rated dryer
capacity. This capacity is derived directly from the 132,170 pounds of
clothes cleaned per year breakeven level established in the economic
analysis (see derivation in Docket Item No. IV-B-3) and is equivalent to
the 4,700 gallon per year solvent consumption exemption level in the
proposed standard.
The derivation involves assumptions about average or typical operating
schedules and load factors (i.e., days per year, loads per day and the
ratio of actual load weight to rated capacity). However, because the
economic breakeven level analysis inherently incorporates a substantial
margin for error (i.e., at the breakeven level, the additional costs of
the solvent recovery dryer are offset by its savings), the standard will
not endanger the economic viability of affected dry cleaners. Selection
of the 84 pound manufacturers' rated dryer capacity criterion, therefore,
is reasonable and sufficient to mitigate any adverse economic impacts
that could result from the new source performance standard.
The commenter asserted that a dryer capacity exemption level of
greater than 110 pounds should be established primarily on the basis of
his suggested 6,100 gallon per year solvent consumption level derived
with the 30 pounds per 100 pounds of clothes cleaned emission factor
discussed previously. For the reasons outlined in the previous discussion
of this commenter1s first concern on the 23 vs 30 pounds per 100 pounds
factors, the 23 pounds per 100 pounds factor and the resulting
4,700 gallons of solvent or 84 pounds of dryer capacity exemption levels
are more appropriate.
The commenter further asserted that because dryers are manufactured
in discrete 50 and 100 pound capacity sizes, the 4,700 gallons of solvent
consumption exemption affects only the 50 pound dryers. The exemption,
therefore, realistically represents only a 2,800 gallon per year solvent
consumption level and should be established at the 110 pound dryer
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capacity level which is equivalent to an annual solvent consumption of
6,100 gallons. :
Decisions regarding the capacity of dryers to be sold are made by
manufacturers to address a number of changing operating and market
considerations. It may be that the capacities of dryers marketed in the
future will differ from those available today. For instance, a 75 pound
capacity dryer may be introduced into the market. Given the potential
for change in the character of the dry cleaning industry with its many
small operators, the dryer capacity exemption should be established at
whatever level the economic breakeven analysis indicates is appropriate
and not arbitrarily increased to exempt dryers larger than the analysis
indicates is reasonable. Further, an exemption level of 110 pounds
dryer capacity would exempt the majority of commercial dry cleaning
plants. Typically these plants have a total, dryer capacity of 100 pounds.
Thus, a 110 pound dryer capacity exemption level would inappropriately
exempt a large number of commercial dry cleaners that the analysis
indicates could afford the cost of controls. For these reasons, the
84 pound dryer capacity is selected as the exemption level.
The commenter also requested that the applicability of the standard
to expansions or replacement of equipment at existing facilities be
determined by comparing the capacity of the new and/or replacement
dryers to the 110 pound capacity limit. Irrespective of whether a 110
or an 84 pound dryer capacity level is selected, this approach differs
considerably from the exemption level in the proposed standard.
Applicability of the standard is based on the economic breakeven level
for the plant. The exemption, therefore, is the plant dryer capacity,.
not the capacity of an individual dryer. In other words, total existing
or projected dryer capacity of the plant is compared to the exemption
level, not the capacity of an individual dryer as suggested by the
commenter. Because the exemption is based on the ability of the plant
to afford control technology, the exemption must reflect the size and
throughput of the plant. Consequently, total plant dryer capacity is
the basis for the exemption. Recognizing, however, that plants may have
idle equipment that should not be included, provisions have been made to
exclude from consideration those units that have been retired or otherwise
permanently removed from service.
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2.3.4 Comment: (IV-D-4) One commenter suggested that the standard
should include requirements for improving vacuum still operations.
However, no suggested requirements or guidelines were identified by the
commenter.
Response: As discussed in the preamble to the proposed standard,
fugitive VOC emissions result from the storage and open-air disposal of
the waste liquid (grease, oil, solvent soluble impurities and residual
solvent) generated by vacuum still operations. Moreover, various still
operating procedures can be employed that reduce the solvent content of
still wastes and thereby reduce VOC emissions. However, still operating
procedures to minimize the solvent remaining in the still wastes vary
with solvent throughput, fabrics, soil loading and still type. As a
result, no still operating procedures have been identified that would
result in consistent reductions in the solvent content of vacuum still
wastes. Covering any containers of such wastes, however, would reduce
fugitive emissions from these wastes. In addition, the identification
and repair of leaks in the vacuum still and associated pipe work will
further reduce emissions. These types of fugitive emissions control
techniques are addressed by the facility inspection requirements of the
standard.
2.4 PROJECTION OF THE NUMBER OF AFFECTED FACILITIES
2.4.1 Comment: (IV-D-3) One commenter felt that the projections of
the numbers of dryers to be installed over the next five years are too
high and result in an overestimation of the emissions reductions to be
derived from the standard. He pointed out that supporting data for the
projections have not been documented. Further, he felt that the
projections should be revised and that the best basis for revising the
estimates is data on the number of conventional dryers sold over the
last five years. The commenter expressed the opinion that, because such
data should be an important part of the rulemaking record, the standard
should not be promulgated until the data can be gathered by the trade
associations.
Response: The projections of the number of affected facilities are
based on an anticipated one percent annual growth rate in the industrial
dry cleaning sector, zero growth in the commercial dry cleaning sector,
and the assumed replacement of existing equipment with new equipment at
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the end of a 30-year equipment life. Replacement units comprise a large
fraction of the projected affected facilities. The growth rate and
equipment life assumptions are based on conversations with about 20 dry
cleaning operators, equipment manufacturers, and trade association
representatives. These conversations are documented and contained in
the docket. The reported lifetimes for petroleum dry cleaning equipment
ranged between 10 years and 30 years or more.. Based on these estimates,
a conservative selection of 30 years was used as the average lifetime of
existing equipment.
The commenter contends that the projections are too high and
recommends that they be revised based on the number of conventional
dryers that have been sold over the last five years. Conventional dryer
sales, however, are not the most appropriate basis for the projections.
This is because sales of conventional dryers have been depressed severely
in recent years. Thus, reasonable projections of dryers that will be
affected by the new source performance standard cannot be based on
conventional dryer'sales.
Industry trade association representatives indicate that due to the
general economic conditions, operators over the last decade have been
postponing purchases of new dry cleaning equipment and opting to maintain
existing equipment (Docket Entry II-E-149). The last decade or so has
also seen a decline in the petroleum dry cleaning industry because the
public's tastes have turned towards "wash and wear" fabrics. Also,
sharp increases in the cost of petroleum solvent have contributed to the
downward trend in sales of conventional dryers that exhaust the evaporated
solvent directly to the atmosphere. However, industry analysts believe
that the attrition in the number of dry cleaners observed during the
past decade has run its course and that the industry has stabilized.
This trend, coupled with recent favorable decreases in the cost of
borrowing capital, indicates that the future outlook for the industry is
considerably brighter than the recent past.
The full effects of these influences are difficult to determine
over the short run. However, in the long run the commercial dry cleaning
sector will probably continue to operate at its present level; the
industrial dry cleaning sector will probably experience slight growth,
and purchases of new equipment cannot be postponed indefinitely.
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Consequently, over the long run, the projections of affected facilities
in the Volume I BID are reasonable.
2.5 ECONOMIC IMPACT
2.5.1 Comment: (IV-D-1) One commenter, a manufacturer of petroleum
dry cleaning equipment, stated that petroleum dry cleaning equipment
sales and prospects for future sales had declined during the last seven
years to the point where the manufacturer has discontinued production of
petroleum solvent and dual-phase washer/extractors and diatomite filters.
Accordingly, he indicated that Section 9.1.2 of the Volume I BID should
be revised to delete their company from the lists of manufacturers of
this equipment. Further, he felt that there is no longer a replacement
market for petroleum solvent dry cleaning equipment. The decline in the
equipment market was attributed by the commenter to the development of
standards of performance for petroleum dry cleaners.
Response: While the decline in petroleum dry cleaning sales
experienced by the commenter is coincident in time with the development
of standards for dry cleaners, the standards development process has not
had a significant effect on the commenter's sales.
The first major public involvement in the development of the standard
occurred at the August 10, 1976, meeting of the National Air Pollution
Control Techniques Advisory Committee (NAPCTAC) (see Docket Item IV-B-46).
At this meeting, "good housekeeping" practices for reducing petroleum
solvent losses from petroleum solvent washers and diatomite filters were
discussed. These practices focused on minimizing leaks of petroleum
solvent and recovering petroleum solvent contained in used diatomite
filters. Discussion of these practices would not have affected the sale
of the commenter's petroleum solvent dry cleaning equipment.
The new source performance standard for petroleum solvent dry
cleaners was proposed in the Federal Register on December 14, 1982. The
standards would affect new petroleum solvent dry cleaning equipment that
is manufactured after December 14, 1982. Consequently, it is not clear
how the proposed standards could have had an impact on the commenter's
sales over the preceding seven years.
The standards would preclude the use of new diatomite filters in
some cases. The standards, however, would not apply in any way to the
items of petroleum solvent dry cleaning equipment mentioned by the
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commenter. The proposed standards, therefore, would not have any impact
on the sale of these items of equipment.
The impact of the proposed standards on the sale of new diatomite
filters is mitigated by the fact that the standards would not apply to
small petroleum solvent dry cleaners. Small dry cleaners constitute
about half of the petroleum solvent dry cleaning industry and generally
use diatomite filters instead of cartridge filters. Large dry cleaners,
on the other hand, generally use cartridge filters. Due to the economic
benefits associated with the use of cartridge filters, however, the
major trade associations and many equipment manufacturers have urged all
petroleum solvent dry cleaners to purchase this type of filter instead
of diatomite filters.
As mentioned previously in responding to the comment in Section 2.4.1,
the petroleum drycleaning industry has declined during the last decade
due to the combined influence of the public's increased use of "wash and
wear" fabrics and a sharp increase (about 500 percent) in the cost of
petroleum solvent. The number of petroleum dry cleaners has steadily
declined, and the market for replacement equipment during this period
has been impacted by hesitancy on the part of operators about the future
of the industry. In the last five years, the high cost of borrowing
funds for capital improvements also has restricted the market for
replacement equipment. While petroleum solvent dry cleaners are now
recovering to some extent from these impacts, the recovery is not without
change within the industry. The number of petroleum solvent dry cleaners
has steadily declined, with a consequent reduction in the replacement
market for new petroleum solvent dry cleaning equipment.
In such circumstances, sales of new petroleum solvent dry cleaning
equipment would be expected to decline sharply. The commenter1s decline
in sales is the result of the influences described above and the general
decline in the petroleum dry cleaning industry, rather than the direct
result of the new source performance standard as he asserts.
It is also not true that there is no longer a replacement market
for petroleum dry cleaning equipment. Although sales during the last
few years are down, the indication from the industry trade association
representatives is that the purchase of new equipment has been delayed
because of the declining petroleum dry cleaning market conditions. As
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documented in the Volume I BID and expressed in the response to the
comment in Section 2.4.1, the commercial dry cleaning sector will probably
maintain itself at the current level; the industrial dry cleaning sector
will probably experience slight growth; and existing dry cleaning equipment
cannot last indefinitely. Consequently, a market will exist for new dry
cleaning equipment in replacement situations and to a lesser extent in
new or expanding industrial plant situations.
2.6 TEST METHODS AND PROCEDURES
2.6.1 Comment: (IV-D-4) One commenter felt that the initial, one-time-
only test requirement to determine the dryer cycle time necessary to
achieve a 0.05 liter per minute recovered solvent flow rate is inadequate
to provide proof of long-term efficient operation. The test method does
not detect mechanical malfunctions that influence the solvent recovery
efficiency and the emission rate. Second, in the opinion of the commenter,
the test should be repeated annually, at a minimum, to ensure the continued
performance of the solvent recovery equipment. Also, the commenter
pointed out that no maintenance procedures are specified to ensure the
continued efficient operation of the dry cleaning equipment.
Response: More frequent and thorough testing and reporting
requirements and enforcement provisions could be incorporated into the
proposed petroleum dry cleaning standards. However, an increase in the
testing and reporting requirements also increases the burden on the
owner or operator of the dry cleaner. Because the dry cleaning industry
by and large is made up of small businesses that do not have the resources
to conduct and record tests, this burden on the owner or operator has
been minimized. The 0.05 liter per minute recovered solvent flow rate
test for the recovery dryer is designed to determine the most cost
effective and emissions reduction effective dryer cycle time. Once the
equipment is installed and the optimum dryer cycle time is determined,
the operator has an economic incentive to operate the equipment in the
most solvent-efficient manner.
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TECHNICAL REPORT DATA
(Please read Instructions on the reverse before completing) -
1. REPORT NO. . . - " 2. ,
EPA'-450/3-82-012b
4. TITLE AND SUBTITLE
Petroleum Dry Cleaners -
Background Information for Proposed Standards
Volume 2 - Final EIS
7. AUTHOR(S)
.'•••••'- :
9. PERFORMING ORGANIZATION NAME AND ADDRESS
Director, Emission Standards and Engineering Division
Office of Air Quality Planning and Standards
Environmental Protection Agency
Research Triangle Park, North Carolina 27711
12. SPONSORING AGENCY NAME AND ADDRESS
Director, Air Quality Planning and Standards
Office of Air, Noise, and Radiation
U.S. Environmental Protection Agency
Research Triangle Park, North Carolina 27711
3. RECIPIENT'S ACCESSION NO.
5. REPORT DATE
September 1984
6, PERFORMING ORGANIZATION CODE
8. PERFORMING ORGANIZATION REPORT NO.
10. PROGRAM ELEMENT NO.
11. CONTRACT/GRANT NO.
68-02-3063
13. TYPE OF REPORT AND PERIOD COVERED
Final
14. SPONSORING AGENCY CODE
EPA/ 200/04
15. SUPPLEMENTARY NOTES
16. ABSTRACT
Standards of Performance for the control of VOC emissions from petroleum dry
cleaning facilities have been proposed under the authority of Section lll(b)
of the Clean Air Act. These standards apply to new, modified, or reconstructed
petroleum dry cleaning facilities, the construction or modification of which
began on or after the date of proposal. This draft document contains response
to comments received on the proposed standard and a summary of the changes
made in the standard prior to promulgation.
17. , KEY WORDS AND DOCUMENT ANALYSIS ~~
a. DESCRIPTORS
Air Pollution
Pollution
Standards of Performance
Petroleum Dry Cleaners
Petroleum Solvents
;18. DISTRIBUTION STATEMENT
Unlimited
b. IDENTIFIERS/OPEN ENDED TERMS
Air Pollution Control
Organic Chemicals
Solvents
19. SECURITY CLASS (This Report)
Unclassified
20. SECURITY CLASS (This page)
Unclassified
c. COSATI Field/Group
13 B
21. NO. OF PAGES
26
22. PRICE
EPA Form 2220-1 (Rev. 4-77) PREVIOUS EDITION is OBSOLETE
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