^^%i|.j^4»&;|wi^^
......
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ERRATA SHEET FOR
Cleaner Technologies Substitutes Assessment for Professional
Fabricare Processes, EPA 744-B-98-001, June 1998
On page F-4: Deborah Wallace is incorrectly identified as a member
of the peer review panel for this document.
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EPA 744-B-98-001
June 1998
Cleaner Technologies Substitutes Assessment:
Professional Fabricare Processes
<^e %.
US. EPA
U. S. Environmental Protection Agency
Office of Pollution Prevention and Toxics
Economics, Exposure and Technology Division (7406)
401 M Street SW
Washington, DC 20460
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DISCLAIMER
This document has been subject to U.S. Environmental Protection Agency (USEPA) internal
review and external technical peer review and has been approved for publication. Mention of trade names,
products, or services does not convey, and should not be interpreted as conveying, official USEPA
approval, endorsement, or recommendation.
Information on sales, cost, performance, and product usage was provided by individual product
vendors, or by USEPA Garment and Textile Care Program stakeholders, and was not independently
corroborated by USEPA.
Discussion of federal environmental statutes is intended for information purposes only; this is not
an official regulatory guidance document and should not be relied upon by companies to determine
applicable regulations.
11
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ACKNOWLEDGMENTS
The overall Project Manager is Lynne Blake-Hedges. In addition to being responsible for the
f production of this document, Ms. Blake-Hedges functions as the technical lead for the economic analyses
* contained in the document.
Lynne received excellent support from the EPA/OPPT Technical Workgroup:
Lynne Blake-Hedges, Workgroup Chair
Andrea Blaschka
Lois Dicker, Ph.D.
Elizabeth Margosches, Ph.D.
Fred Metz, Ph.D.
Ossi Meyn, Ph.D.
Mary {Catherine Powers
Scott Prothero
Management support and other general assistance was provided by:
David Lai, Ph.D.
Robert E. Lee, Ph.D.
Cindy Stroup
Mary Ellen Weber, Ph.D.
Vanessa Vu, Ph.D.
This document was prepared under EPA Contract numbers 68-W-9805 and 68-W6-0021, by Abt
Associates Incorporated of Cambridge, MA, under the direction of Alice Tome. The EPA Work
Assignment Manager is Lynne Blake-Hedges.
The independent technical peer review was conducted by Battelle Columbus Laboratories of
Columbus, OH, under the direction of Bruce Buxton (EPA Contract number 68-D5-0008). Technical
editing and general support to final document preparation was provided by Westat, Incorporated, of
Rockville, MD, under the direction of Karen Delia Torre (EPA Contract number 68-D7-0025). The EPA
Work Assignment Manager for both Battelle and Westat is Cindy Stroup.
To obtain a copy of this or other EPA/Design for the Environment Program publications, contact:
EPA's Pollution Prevention Information Clearinghouse (PPIC)
401 M Street SW (3404)
Washington, DC 20460
202-260-1023
fax: 202-260-4659
Any questions or comments regarding this document should be addressed to:
Lynne Blake-Hedges
Economics, Exposure and Technology Division (7406)
U.S. EPA/OPPT
401 M Street SW
Washington, DC 20460
111
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IV
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CONTENTS
ACKNOWLEDGEMENTS jjj
ACRONYMS AND ABBREVIATIONS xv
EXECUTIVE SUMMARY
INTRODUCTION ES-1
DESIGN FOR THE ENVIRONMENT GARMENT AND TEXTILE CARE PROGRAM . ES-1
CTSA RESULTS ES-2
Effects ES-3
Releases ES-3
Exposures ES-4
Risk Estimates ES-5
Perchloroethylene Solvent ES-5
Hydrocarbon Solvents ES-5
Machine Wet Cleaning ES-6
SELECTED FEDERAL REGULATORY REQUIREMENTS ES-6
COSTS ES-7
PERFORMANCE CHARACTERISTICS ES-7
OTHER FACTORS.,.,,,-, ,„.,_ _, ES-9
SUMMARY OF TRADE-OFF CONSIDERATIONS ES-9
EMERGING TECHNOLOGIES ES-10
CONCLUSIONS ES-10
CHAPTER 1. INTRODUCTION
1.1 PROJECT BACKGROUND \.\
1.2 CTSA APPROACH .' ' 1_3
1.2.1 Coverage of Fabricare Alternatives 1-4
1.2.2 Description of Health and Environmental Risks 1-5
1.2.3 Performance Data 1 _6
1.2.4 Analysis of the Costs of the Alternative Clothes Cleaning Technologies .... 1-7
1.2.5 Selected Federal Regulations 1-7
1.2.6 Environmental Improvements 1-7
1.2.7 Evaluation of Trade-Off Issues 1-7
1.2.8 Emerging Technologies 1-8
1.2.9 Additional Information 1-8
1.3 HOW TO USETHIS-DOCUMENT ..................... . \-8
1.3.1 Clothes Cleaners ]_8
1.3.2 Other Readers ] _8
CHAPTER 2. OVERVIEW OF PROFESSIONAL FABRICARE TECHNOLOGIES
2.1 TECHNOLOGIES EVALUATED IN THE CTSA 2-1
2.2 CLOTHES CLEANING PROCESS 2-2
2.3 PROCESS EQUIPMENT DESCRIPTIONS 2-2
2.3.1 Perchloroethylene Processes Equipment 2-2
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2.3.2 Hydrocarbon Processes Equipment 2- '0
2.3.3 Machine Wetcleaning Process Equipment 2-13
2.4 CHEMICAL CHARACTERIZATION OF TECHNOLOGIES 2-14
2.4.1 Drycleaning—Solvents 2-15
2.4.2 Machine Wetcleaning—Detergents 2-15
2.5 COMMERCIAL FABRICARE INDUSTRY MARKET PROFILE 2-17
2.5.1 Introduction 2'17
2.5.2 Perchloroethylene Market Share and Volume 2-17
2.5.3 Hydrocarbon Solvents Market Share and Volume 2-19
2.5.4 Machine Wetcleaning 2-21
2.5.5 Fabricare Industry Trends 2-22
CHAPTERS. HAZARD SUMMARY
3.1 INTRODUCTION 3']
3.2 OVERALL SUMMARY 3'-
3.2.1 Human Health Hazard 3'2
3.2.2 Environmental Hazard 3'4
3.3 HAZARD SUMMARIES BY TECHNOLOGY 3-7
3.3.1 Drycleaning Technologies 3"7
3.3.2 Machine Wetcleaning Technology 3'1!
CHAPTER 4. RELEASE AND EXPOSURE
4.1 INTRODUCTION • 4']
4.2 ENVIRONMENTAL RELEASE ASSESSMENTS 4-1
4.2.1 Drycleaning Technologies 4-3
4.2.2 Machine Wetcleaning Release Assessment 4-10
4.3 EXPOSURE OVERVIEW 4~1 l
4.3.1 Background and Definitions 4-11
4.3.2 Exposure Descriptors 4-13
4.3.3 Exposure Comparisons 4-14
4.4 EXPOSURE ASSESSMENTS 4-14
4.4.1 Drycleaning Technologies: Perchloroethylene Processes 4-14
4.4.2 Drycleaning: Hydrocarbon Solvents 4-37
4.4.3 Machine Wetcleaning Process 4-43
CHAPTERS. RISK
5.1 RISK CHARACTERIZATION—INTRODUCTION 5-1
5.1.1 Scope of the CTSA Risk Assessments 5-1
5.1.2 Background Information on Human Risk Assessment Methodology 5-1
5.2 DRYCLEANING USING PERCHLOROETHYLENE (PCE) 5-7
5.2.1 Human Health 5'7
5.2.2 Human Health Risks 5'8
5.2.3 Occupational Risks—Drycleaning Workers 5-9
5.2.4 Risks to Residents Co-Located with Drycleaning Establishments 5-14
5.2.5 General Population Risks 5~19
5.2.6 Special Sub-populations 5-23
5.2.7 Environmental Risk 5~25
VI
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5.2.8 Human and Environmental Risks—Overall Summary and Conclusions .... 5-26
5.3 DRYCLEANING USING HYDROCARBON (HC) SOLVENTS 5-28
5.3.1 Human Health 5-28
5.3.2 Human Health Risks 5-28
5.3.3 Occupational Risks—Drycleaning Workers 5-29
5.3.4 General Population Risks—Residents Co-Located with Drycleaning
Establishments 5-32
5.3.5 General Population Risks 5-32
5.3.6 Special Sub-populations 5.33
5.3.7 Environmental Risk—Summary and Conclusions 5-34
5.4 MACHINE WETCLEANING PROCESS '.'. 5.35
5.4.1 Human Health 5.35
5.4.2 Human Health Risks 5-36
5.4.3 Occupational Risks—Wetcleaning Workers 5-36
5.4.4 General Population Risks 5-38
5.4.5 Environmental Risk—Summary and Conclusions 5-38
CHAPTER 6. PERFORMANCE DATA ANALYSIS
6.1 PERFORMANCE EVALUATION OF PROFESSIONAL FABRICARE 6-1
6.1.1 Performance Assessment Protocol 6-2
6.1.2 Subjective Measures of Cleaning Performance 6-2
6.1.3 Physical and Chemical Characteristics of Clothes Cleaning 6-3
6.1.4 Clothes Cleaning and Textile Damage Potential 6-4
6.2 REVIEW OF PERFORMANCE STUDIES FOR FABRICARE OPTIONS 6-4
6.2.1 Summary of Findings 6-4
6.2.2 Alternative Clothes Cleaning Demonstration Shop (The Greener Cleaner) . . 6-6
6.2.3 Final Report for the Green Clean Project 6-15
6.2.4 Pollution Prevention in the Garment Care Industry: Assessing the
Viability of Professional Wetcleaning, Final Report (Cleaner by Nature) . . 6-26
6.2.5 Alternative Textile Care Technologies: Part I 6-40
6.2.6 Alternative Textile Care Technologies: Part II 6-41
6.2.7 University of Guelph Fabric Swatch Study 6-42
CHAPTER 7. PROCESS COST ESTIMATES
7.1 SUMMARY OF TECHNOLOGIES AND COST ELEMENTS MODELED 7-1
7.2 ASSUMPTIONS AND COST ESTIMATION METHODOLOGY 7-4
7.2.1 Clothes Cleaning Plant Capacity 7.4
7.2.2 Equipment Capacity 7.5
7.2.3 Capital Equipment Costs 7.5
7.2.4 Equipment Maintenance Costs 7-6
7.2.5 Energy Costs 7_6
7.2.6 Installation Costs 7_6
7.2.7 Solvent and Other Material Costs 7.7
7.2.8 Filters/Cleaning Supplies 7.7
7.2.9 Hazardous Waste Disposal Costs 7.7
7.2.10 Regulatory Compliance 7_8
7.2.11 Labor Costs 7.9
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7.3 COST ESTIMATES FOR PCE MACHINE CONFIGURATIONS 7-9
7.3.1 PCE Transfer with No Carbon Adsorption or Refrigerated
Condenser (PCE-A1) 7'9
7.3.2 PCE Transfer with Carbon Adsorber (PCE-A2) 7-10
7.3.3 PCE Transfer with Refrigerated Condenser (PCE-A3) 7-13
7.3.4 PCE Dry-to-Dry with No Carbon Adsorber or Refrigerated
Condenser (PCE-B1) 7'14
7.3.5 PCE Dry-to-Dry with Carbon Adsorber (PCE-B2) 7-14
7.3.6 PCE Dry-to-Dry Converted to Closed-Loop (PCE-B3) 7-15
7.3.7 PCE Dry-to-Dry Closed-Loop with no Carbon Adsorber or with Door Fan
and Small Carbon Adsorber (PCE-C) 7-16
7.3.8 PCE Dry-to-Dry Closed-Loop with Unvented Integral Secondary Carbon
Adsorber (PCE-D) 7"17
7.4 COST ESTIMATES FOR HYDROCARBON SOLVENT MACHINE
CONFIGURATIONS 7'18
7.4.1 HC Transfer Machine with Standard Dryer and No Condenser (HC-A1) ... 7-18
7.4.2 HC Transfer Machine with Recovery Dryer (HC-A2) 7-20
7.4.3 HC Dry-to-Dry Closed-Loop with Refrigerated Condenser (HC-B) 7-20
7.5 COST ESTIMATES FOR MACHINE WETCLEANING 7-21
CHAPTER 8. SELECTED FEDERAL RECITATIONS
8.1 CLEAN AIR ACT 8'2
8.1.1 Perchloroethylene Cleaning 8"3
8.1.2 Hydrocarbon Solvent Cleaning 8"6
8.1.3 Machine Wetcleaning 8"7
8.2 CLEAN WATER ACT 8'7
8.2.1 National Pollutant Discharge Elimination System Program 8-7
8.2.2 Wastewater Discharges to Publicly-owned Treatment Works 8-8
8.2.3 Perchloroethylene Cleaning 8'10
8.2.4 Hydrocarbon Solvent Cleaning 8-11
8.2.5 Machine Wetcleaning 8-1'
8.3 SAFE DRINKING WATER ACT - UNDERGROUND INJECTION CONTROL
REGULATIONS 8'12
8.3.1 Perchloroethylene Cleaning 8"13
8.3.2 Hydrocarbon Solvent Cleaning 8"14
8.3.3 Machine Wetcleaning . 8'14
8.4 RESOURCE CONSERVATION AND RECOVERY ACT 8-14
8.4.1 Classification of Hazardous Wastes 8-15
8.4.2 Classification of Hazardous Waste Generators 8-16
8.4.3 Underground Storage Tanks 8-18
8.4.4 Perchloroethylene Cleaning 8-19
8.4.5 Hydrocarbon Solvent Cleaning 8-2°
8.4.6 Machine Wetcleaning 8-21
8.5 COMPREHENSIVE ENVIRONMENTAL RESPONSE, COMPENSATION AND
LIABILITY ACT 8'21
8.5.1 Perchloroethylene Cleaning 8-22
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8.5.2 Hydrocarbon Solvent Cleaning 8-23
8.5.3 Machine Wetcleaning 8-23
8.6 OCCUPATIONAL SAFETY AND HEALTH ACT 8-24
8.6.1 Perchloroethylene Cleaning 8-25
8.6.2 Hydrocarbon Solvent Cleaning 8-25
8.6.3 Machine Wetcleaning 8-25
8.7 CARE LABELING RULE 8-25
8.8 OTHER APPLICABLE REGULATIONS 8-26
CHAPTER 9. ADDITIONAL ENVIRONMENTAL IMPROVEMENT APPROACHES
9.1 PCE AND HC DRYCLEANING FACILITIES 9-1
9.1.1 Recommended Operating and Maintenance Procedures 9-1
9.1.2 Impact of Facility Conditions and Remedial Actions on PCE
Concentrations in Co-located Residences 9-15
9.2 MACHINE WETCLEANING FACILITIES 9-17
9.3 TRADE ASSOCIATION CONTACTS FOR FURTHER INFORMATION 9-17
CHAPTER 10. TRADE-OFF ISSUES
10.1 SUMMARY OF TRADE-OFF FACTORS 10-1
10.1.1 Potential Health and Environmental Risks 10-1
10.1.2 Federal Regulatory Environment 10-5
10.1.3 Costs 10-6
10.1.4 Performance Characteristics 10-8
10.1.5 Other Factors 10-12
10.1.6 Summary of Trade-Off Considerations 10-12
10.2 APPROACHES FOR CONSIDERING TRADE-OFFS 10-13
10.2.1 Benefit/Cost Analysis 10-13
10.2.2 Cost-Effectiveness Analysis 10-18
10.2.3 Comparison of Alternative PCE-Based Machine Configurations 10-18
10.2.4 A Comparison of Alternative Hydrocarbon Solvent-Based Technologies . 10-24
CHAPTER 11. EMERGING TECHNOLOGIES
11.1 LIQUID CARBON DIOXIDE PROCESS 11-1
11.2 ULTRASONIC CLEANING PROCESS 11-3
11.3 RYNEX SOLVENT 11_4
11.4 BIOTEX SOLVENT [ ] 1.5
APPENDIX A. CHEMISTRY AND FATE
A.I CHEMICAL PROPERTIES AND INFORMATION A-l
A.2 PERCHLOROETHYLENE ENVIRONMENTAL FATE SUMMARY A-l 5
A.3 HYDROCARBON ENVIRONMENTAL FATE SUMMARY A-15
A.4 MACHINE WETCLEANING ENVIRONMENTAL FATE SUMMARIES A-16
APPENDIX B. ECOLOGICAL HAZARD METHODOLOGY
B.I DEVELOPMENT OF HAZARD PROFILE B-l
B.2 DETERMINATION OF CONCERN CONCENTRATION B-l
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APPENDIX C. HEALTH HAZARD SUMMARIES
C.I DRYCLEANING £-
C.I.I Perchloroethylene C"1
C.1.2 Hydrocarbon Solvents c'14
C.2 MACHINE WETCLEANING EXAMPLE DETERGENT CHEMICALS C-19
C.2.1 Surfactants C"19
C.2.2 Surfactant Aids C'37
APPENDIX D. DOSE-RESPONSE ASSESSMENTS
D.I DRYCLEANING D'1
D.I.I Perchloroethylene D"'
D.1.2 Hydrocarbon Solvents D"7
D.2 MACHINE WETCLEANING CHEMICALS D-8
APPENDIX E. RELEASE AND EXPOSURE METHODOLOGY AND DATA
APPENDIX F. SUMMARY OF EXTERNAL TECHNICAL PEER REVIEW
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LIST OF EXHIBITS
Exhibit ES-1. Summary of Regulations Related to Fabricare Technologies . ES-6
Exhibit ES-2. Summary of Estimated Process-Dependent Cost Components for Selected
Fabricare Technologies ES-S
Exhibit ES-3. An Overview of Alternative Cleaning Technologies' Trade-Off Factors ES-11
Exhibit 2-1. Simplified Process Flow Diagrams for PCE Machinery 2-4
Exhibit 2-2. Simplified Process Flow Diagrams for Hydrocarbon Solvent Machinery 2-11
Exhibit 2-3. Simplified Process Flow Diagram for Machine Wetcleaning 2-14
Exhibit 2-4. Example Detergent Chemicals Included in the CTSA 2-15
Exhibit 2-5. Example Wetcleaning Detergent Formulations 2-16
Exhibit 2-6. Solvent Usage in the Commercial Sector of the Drycleaning Industry 2-18
Exhibit 2-7. Total Volume of PCE (in million kg) . . i 2-18
Exhibit 2-8. Perchloroethylene Use (Domestic and Import) in the U.S. Drycleaning Industry ... 2-19
Exhibit 3-1. Human Health Hazard Summary 3.3
Exhibit 3-2. Estimated Aquatic Toxicity Values of Dry and Wetcleaning Chemicals Based on
Measured Data and Struture Activity Relationship (SAR) Analysis (mg/L) 3-6
Exhibit 3-3. Estimated Chronic Toxicity Values (mg/L) for Linear, Branched, and Cyclic
Hydrocarbon Solvents 3. ] ]
Exhibit 4-1. Estimated Releases from PCE Model Facilities with Various Machine
Types and Emission Controls 4.5
Exhibit 4-2. Estimated Releases from HC Model Facilities with Various Machine
Types and Emission Controls 4.9
Exhibit 4-3. Pathways Covered in the CTSA 4_12
Exhibit 4-4. Summary of TWA ECs Based on OSHA Personal Monitoring for
PCE Drycleaning 4. j g
Exhibit 4-5. Central Tendencies of TWA Concentrations of PCE Reported in Some US
Occupational Studies for Drycleaning Workers by Job Type and Machine Type ... 4-17
Exhibit 4-6. Passive Air Monitoring Results for PCE Drycleaning Workers by Machine
Type Collected by the International Fabricare Institute 4-18
Exhibit 4-7. TWA ECs for PCE Drycleaning Workers by Machine Type and Control and
Job Title Collected by the National Institute for Occupational Safety and Health ... 4-19
Exhibit 4-8. Summary Statistics for PCE Concentrations in Air in Co-located Residences 4-26
Exhibit 4-9. Estimated Exposures Received by Co-located Residents- 4-28
Exhibit 4-10. Consumers Union Inhalation Exposure Estimates From Wearing
Drycleaned Clothes 4.33
Exhibit 4-11. Summary of TWA Exposure Concentrations (ECs) for Inhalation of
Stoddard Solvent by Job Title Based on OSHA Personal Monitoring Data . 4-39
Exhibit 4-12. Summary of TWA ECs for Inhalation of Petroleum Solvents by Job
Title Based on NIOSH Data 4.40
Exhibit 4-13. Hydrocarbon LADCs by Distance from a Hypothetical Facility (mg/m3) 4-42
Exhibit 5-1. Exposure Scenarios Evaluated for Human Health Effects 5-6
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Exhibit 5-2 Toxicity Comparison Values for PCE Risk Assessment >7
Exhibit 5-3. Occupational Health Risks Via Inhalation to Workers Based on Post-1990
OSHA Monitoring Data for PCE Drycleaning 5-'u
Exhibit 5-4. Occupational Health Risks to Drycleaning Workers From PCE Inhalation -
by Job Title and Machine Type • • 5~ ~
Exhibit 5-5. Cancer and Non-Cancer Risks from PCE Associated with Co-located Residences . . 5-16
Exhibit 5-6. General Population Cancer and Non-Cancer Risks from Inhalation of PCE i--u
Exhibit 5-7. Cancer and Non-Cancer Risks from Exposure to PCE-Contaminated ^
Drinking Water ~~
Exhibit 5-8. PCE Hazards and Inhalation Exposures i"'-
Exhibit 5-9. Summary of Occupational Risk to Example Detergent Constituents
Via Dermal Exposure
Exhibit 6-1. The Greener Cleaner Demonstration Shop Profile 6-7
Exhibit 6-2. Fiber Types Machine Wetcleaned at The Greener Cleaner 0-8
Exhibit 6-3. Garment Types Machine Wetcleaned at The Greener Cleaner 6-8
Exhibit 6-4. Telephone Survey Questions and Results • • °-
Exhibit 6-5. Results of Panel Evaluation of Wetcleaned Clothes at The Greener Cleaner 6-1.1
Exhibit 6-6. Side-by-Side Evaluations of Identical Wet and Drycleaned Garments 6-1-
Exhibit 6-7a. Maximum Dimensional Change for Woven Garments 6-13
Exhibit 6-7b. Maximum Dimensional Change for Woven Fabrics 6-13
Exhibit 6-8a. Maximum Dimensional Change for Knit Garments 6-4
Exhibit 6-8b. Maximum Dimensional Change for Knit Fabrics 6-4
Exhibit 6-9. Wetcleaning Shop Profile for the Green Clean Project 6-6
Exhibit 6-10. Garment Profile Summary for the Green Clean Depot 6-17
Exhibit 6-11. Summary of Customer Satisfaction Surveys 6-8
Exhibit 6-12. Summary of Customer Satisfaction Surveys with Negative Responses 6-19
Exhibit 6-13. Percent Warp Shrinkage of Undyed Fabrics After One Cleaning 6-20
Exhibit 6-14. Percent Shrinkage Results for Consumer Fabric Swatches 6-2^
Exhibit 6-15. Percent Soil Removal from Standard Soil Test Fabrics 6-~
Exhibit 6-16. Percent Garment Shrinkage Results Before and After Pressing 6--J
Exhibit 6-17. Garment Pressing Quality 6-
Exhibit 6-18. Garment Pressing Time °"~
Exhibit 6-19. Demonstration Shop Profile for Cleaner by Nature o-z /
Exhibit 6-20. Garment Types Cleaned at Cleaner by Nature 6--8
Exhibit6-21. Fiber Types Cleaned at Cleaner by Nature 6-29
Exhibit 6-22. Dimensional Change for Identical "Dry Clean Only" Garments Repeatedly
Wetcleaned and Drycleaned 6-31
Exhibit 6-23. Performance Quality and Acceptability of General Appearance Evaluations 6-32
Exhibit 6-24. Color Change Evaluation 6-32
Exhibit 6-25. Gray Scale for Color Change and Chromatic Transference Scale
for Color Migration 6-33
Exhibit 6-26. Odor Evaluation • • • • ™
Exhibit 6-27. Positive and Negative Performance Qualities: Distribution of Wearer Responses . . 6-J4
Exhibit 6-28. Percent with Preference for Wearing One Garment Pair 6-35
Exhibit 6-29. Preference for Wearing Wetcleaned or Drycleaned Garments '. 6-35
Exhibit 6-30. Positive Performance Qualities Experienced by Cleaner by Nature Customers .... 6-36
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Exhibit 6-31. Negative Performance Qualities Experienced by Cleaner by Nature Customers .... 6-36
Exhibit 6-32. Customer Rating of Cleaner by Nature as a Professional Cleaner 6-37
Exhibit 6-33. Positive Performance Qualities Experienced by Cleaner by Nature Customers
and Drycleaner Customers 6-38
Exhibit 6-34. Negative Performance Qualities Experienced by Cleaner by Nature Customers
and Drycleaning Customers 6-39
Exhibit 6-35. Primary Reason Customers Stopped Using Professional Cleaner: Cleaner by Nature
and Drycleaning Customers 6-39
Exhibit 7-1. Potential Operating Factors Associated with Fabricare Facilities 7-2
Exhibit 7-2. Summary of Estimated Process-Dependent Cost Components for Selected
Fabricare Technologies 7.3-
Exhibit 7-3. Producer Price Index for Machines and Equipment (PPI-CE) and Chemicals
and Allied Products (PPI-Chem) 7.4
Exhibit 7-4. Estimated Process-dependent Cost Components of Selected PCE Machine
Configurations 7.11
Exhibit 7-5. Estimated Process-dependent Cost Components of Selected HC Solvent
Machine Configurations 7-19
Exhibit 7-6. Estimated Process-dependent Cost Components for Machine Wetcleaning 7-22
Exhibit 8-1. Summary of Regulations Related to Fabricare Technologies 8-2
Exhibit 8-2. Air Control Requirements for Drycleaners with New and Existing Machines
Based on PCE Purchase Volume 8-4
Exhibit 8-3. PCE NESHAP Compliance Requirements for Drycleaners 8-5
Exhibit 8-4. RCRA Requirements for Hazardous Waste Generators 8-17
Exhibit 8-5. State Fees for Reduced Liability Exposures 8-28
Exhibit 8-6. State Legislative Provisions for Reduced Liability 8-29
Exhibit 9-1. Maintenance Schedule for Drycleaning Equipment 9-3
Exhibit 10-1. Risk Considerations 10-3
Exhibit 10-2. Summary of Federal Regulations Applicable to Fabricare Technologies 10-6
Exhibit 10-3. Summary of Estimated Process-Dependent Cost Components for
Selected Fabricare Technologies 1Q-7
Exhibit 10-4. Estimated Process-dependent Cost Components of Selected PCE
Machine Configurations 1Q-9
Exhibit 10-5. Estimated Process-Dependent Cost Components of Selected Hydrocarbon
Solvent Machine Configurations 10-11
Exhibit 10-6. An Overview of Alternative Cleaning Technologies' Trade-Off Factors 10-14
Exhibit 10-7. Glossary of Benefit/Cost Analysis Terms 10-15
Exhibit 10-8. An Overview of Benefits and Costs of Alternative Cleaning Technologies 10-17
Exhibit 10-9. Estimated Release Reduction Performance and Cost Characteristics
of PCE Drycleaning Machine Configurations 10-20
Exhibit 10-10. Estimated Cost Effectiveness of PCE Transfer Drycleaning Alternatives
Compared with PCE Transfer with No Vent Control (PCE-A1) 10-23
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Exhibit 10-11. Estimated Cost Effectiveness of PCE Dry-to-Dry Cleaning Alternatives
Compared with PCE Dry-to-Dry with No Vent Control (PCE-B1) 10--J
Exhibit 10-12. Estimated Release Reduction, Performance, and Cost Characteristics of
HC Drycleaning Machine Configurations 10'25
Exhibit 10-13. Estimated Cost Effectiveness of HC Cleaning Alternatives Compared with
HC Transfer with Standard Dryer 10~^6
Exhibit A-l. Glossary of Chemical and Physical Properties A-2
Exhibit A-2. Chemicals Utilized in Dry and Machine Wetcleaning Operations A-4
Exhibit A-3. Environmental Fate Information for Machine Wetcleaning Chemicals A-16
Exhibit E-l. PCE Emissions by Machine Type E"1
Exhibit E-2. Emission Factors Used to Estimate Releases of Solvent from Hydrocarbon
Drycleaning Facilities
Exhibit E-3. Environmental Release Estimates of Example Detergent #1 Constituents b-J
Exhibit E-4. Environmental Release Estimates of Example Detergent #2 Constituents E-4
Exhibit E-5. Summary of American Business Information (ABI) 1994 Drycleaning
Worker Population Data E~^
Exhibit E-6. Summary of Estimated Drycleaning Worker Population Data b-6
Exhibit E-7. Drycleaning Worker Subpopulation Estimation • • • E"7
Exhibit E-8. Determination of Estimated Dermal Exposure Durations for Potential Liquid
PCE Contact E"®
Exhibit E-9. Exposure Assessment Methodology- Background on Worker Exposure _b-y
Exhibit E-10. Worker Exposure - Inhalation ^°
Exhibit E-l 1. Worker Exposure - Dermal ^~}}
Exhibit E-l2. Exposure Assessment Methodology - Non Worker Populations b-1-
Exhibit E-l 3. Estimates of Workers' Dermal Exposures to Example Detergent #1 Constituents . . E-l 3
Exhibit E-l 4. Estimates of Workers' Dermal Exposures to Example Detergent #2 Constituents . . E-l 4
Exhibit E-l5. Exposure to Co-located Residents: Information on Monitoring Studies -
Capital District Survey E~'5
Exhibit E-l6. Exposure to Co-located Residents: Information on Monitoring Studies -
Consumers Union
Exhibit E-l 7. Exposure to Co-located Residents: Information on Monitoring Studies -
New York State Health Department Data, Unpublished E-l9
Exhibit E-l 8. Exposure to Co-located Residents: Information on Monitoring Studies -
San Francisco Bay Area E~20
Exhibit E-l9. Exposure to Co-located Residents: Information on Monitoring Studies -
Concentrations Measured in Germany and Netherlands E-21
Exhibit E-20. Inhalation Exposure From a Hypothetical Hydrocarbon Facility E-22
Exhibit E-21. Estimating Concentrations in Surface Water E"24
Exhibit E-22. Description of the Storage and Retrieval of U.S. Waterways Parametric Data
System (STORET) E'25
Exhibit F-l. Final CTSA Peer Review Panel F'3
Exhibit F-2. Teleconference Attendees for CTSA Announcement - Held July 24, 1997 F-5
Exhibit F-3. Summary Statistics on CTSA Comments from CTSA Peer Review Panel F-7
xiv
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ACRONYMS AND ABBREVIATIONS
AATCC
ABD
ACGIH
ADC
AFCEE
ALP
ALT
API
AQUIRE
AST
ASTM
ATSDR
AU
AWWA
BAAQMD
BCF
BLS
CA
CAA
CAPB
CARB
CAS
CBH
CC
CCRIS
CEB
CEC
CED
CEPA
CERCLA
CESQG
CFC
CFR
CG
CGA
CIR
CMC
CNT
CO2
CRWQCB
CTFA
CTSA
CU
CWA
American Association of Textile Chemists and Colorists
American Business Directory
American Conference of Government Industrial Hygienists
Average Daily Concentration
Air Force Center for Environmental Excellence
Alkaline Phosphatase
Alanine Aminotransferase
American Petroleum Institute
Aquatic Toxicity Information Retrieval Database
Aspartate Aminotransferase
American Society for Testing and Materials
Agency for Toxic Substances and Disease Registry
Azeotropic Unit
American Water Works Association
Bay Area Air Quality Management District
Bioconcentration Factor
Bureau of Labor Statistics
Carbon Adsorber
Clean Air Act
Cocoamidopropyl Betaine
California EPA's Air Resources Board
Chemical Abstracts Service
City of Beverly Hills
Concern concentration
Chemical Carcinogenesis Research Information System
Chemical Engineering Branch. OPPT. USEPA
Center for Emissions Control
Certified Environmental Drycleaner
California Environmental Protection Agency
Comprehensive Environmental Response, Compensation and Liability Act
Conditionally Exempt Small Quantity Generator
Chlorofluorocarbon
Code of Federal Regulations
Cellulose Gum
Compressed Gas Association
Cosmetic Ingredient Review
Carboxymethylcellulose
Center for Neighborhood Technologies
Carbon Dioxide
California Regional Water Quality Control Board
Cosmetic, Toiletry and Fragrance Association
Cleaner Technologies Substitutes Assessment
Consumers Union
Clean Water Act
xv
-------
DC
DCA
DDT
DBA
DfE
DL
DMBA
DO/PU
EC
ED
ED10
EEC
EIA
EPI
EWCC
FDA
PEL
FKDA
FTC
GEMS
GOT
GRAS
GSD
HAP
HC
HCFC
HEC
HPC
HPMC
HQ
HSDB
HSIA
IARC
IDEM
IDLH
IFI
IRIS
ISCLT
KSBEAP
LADC
LADD
LAE
LC
LD
LDH
LEL
Drycleaning
Dichioroacetic acid
Dichlorodiphenyltrichloroethane
Diethanolamide
Design for the Environment
Detection Limit
Dimethylbenz[a]anthracene
Drop-off/Pick-up
Effective Concentration
Exposure Duration
Expected Dose at which 10% of the group will respond
Electroencephalogram
Energy Information Administration
Estimation Programs Interface
European Wetcleaning Committee
Food and Drug Administration
Frank Effect Level
Federation of Korean Drycleaners Associations
Federal Trade Commission
Graphical Exposure Modeling System
Gamma Glutamyltransferase
Generally Recognized As Safe
Geometric Standard Deviation
Hazardous Air Pollutant
Hydrocarbon
Hydroch lorofl uorocarbon
Hydroxyethylcellulose
Hydroxypropylcellulose
Hydroxypropylmethylcellulose
Hazard Quotient
Hazardous Substances Data Bank
Halogenated Solvents Industries Alliance
International Agency for Research on Cancer
Indiana Department of Environmental Management
Immediately Dangerous to Life and Health
International Fabricare Institute
Integrated Risk Information System
Industrial Source Complex Long Term
Kansas Small Business Environmental Assistance Program
Lifetime Average Daily Concentration
Lifetime Average Daily Dose
Linear Alcohol Ethoxylate
Lethal Concentration
Lethal Dose
Lactic Acid Dehydrogenase
Lower Explosive Limit
xvi
-------
LOAEL
LOWWT
LQG
LT
MACT
MC
MCL
MDEQ
MHS
MNNG
MOE
MPBPVP
MWC
NAG
NCAI
NCI
NCP
NESCAUM
NESHAP
NFPA
NHOU
NIOSH
NMRI
NOAEL
NOEC
NOES
NPDES
NSPS
NTP
NU
NYCDOH
NYSDEC
NYSDOH
OAQPS
OCIS
ODEM
ODEQ
OPPT
ORD
OSH
OSHA
PCE
PDR
PEL
PGME
POTW
Lowest-Observed-Adverse-Effect Level
Low Weight
Large Quantity Generator
Lifetime
Maximum Available Control Technology
Methylcellulose
Maximum Contaminant Level
Michigan Department of Environmental Quality
Municipal Health Service
N-methyl-N'-nitro-N-nitrosoguanidine
Margin of Exposure
Melting Point, Boiling Point, Vapor Pressure
Machine Wetcleaning
n-acetyl-glucosaminidase
Neighborhood Cleaners Association International
National Cancer Institute
National Oil and Hazardous Substance Pollution Contingency Plan
Northeast States for Coordinated Air Use Management
National Emission Standard for Hazardous Air Pollutants
National Fire Protection Association
North Hollywood Operable Unit
National Institute for Occupational Safety and Health
Strain of mouse (U.S. Naval Medical Research Institution)
No-Observed-Adverse-Effect Level
No-Observed-Effect Concentration
National Occupational Exposure Survey
National Pollutant Discharge Elimination System
New source performance standard
National Toxicology Program
Nucleotidase
New York City Department of Health
New York State Department of Environmental Conservation
New York State Department of Health
Office of Air Quality Planning and Standards, USEPA
OSHA Computerized Information System
Occupational Dermal Exposure Model
Oregon Department of Environmental Quality
Office of Pollution Prevention and Toxics, USEPA
Office of Research and Development, USEPA
Occupational Safety and Health Act
Occupational Safety and Health Administration
Perchloroethylene
Potential Dose Rate
Permissible Exposure Limit
Propylene Glycol Monomethyl Ether
Publicly Owned Treatment Works
xvn
-------
ppb
PPERC
PPI-CE
PPI-Chem
ppm
PRP
QA
QC
QSAR
RC
RCRA
REL
RfC
RfD
RTECS
RTL
SAB
SAR
SARA
SBAP
SD
SDWA
SCOT
SGPT
SI AM
SIAR
SIC
SIDS
SID
SL1
SQG
SRC
SRI
SRRP
SSD
STEL
STORET
STP
SWDA
TCA
TCE
TCLP
TCVC
TCVG
TEAM
TLV
parts per billion
Pollution Prevention Education and Research Center
Producer Price Index for Capital Equipment
Producer Price Index for Chemicals and Allied Products
parts per million
Potentially Responsible Party
Quality Assurance
Quality Control
Quantitative Structure-Activity Relationship
Refrigerated Condenser
Resource Conservation and Recovery Act
Recommended Exposure Limit
Reference Concentration
Reference Dose
Registry of Toxic Effects of Chemical Substances
Research Testing Laboratories
Science Advisory Board
Structure-Activity Relationship
Superfund Amendments and Reauthorization Act
Small Business Assistance Program
Standard Deviation
Safe Drinking Water Act
Serum Glutamate Oxaloacetate Transaminase
Serum Glutamate Pyrurate Transaminase
SIDS Information Assessment Meeting
SIDS Initial Assessment Report
Standard Industrial Classification
Screening Information Data Set
Significant Industrial User
Sodium Lauryl Isethionate
Small Quantity Generator
Syracuse Research Corporation
Stanford Research Institute
Source Reduction Research Partnership
Statistically Significant Difference
Short-term Exposure Limit
Storage and Retrieval of U.S. Waterways Parametric Data System
Sewage Treatment Plant
Solid Waste Disposal Act
Trichloroacetic Acid
Trichloroethylene
Toxicity Characteristic Leaching Procedure
Trichlorovinylcysteine
Trichlorovinylglutathione
Total Exposure Assessment Methodology
Threshold Limit Value
xviu
-------
TSCA
TSDF
TURI
TWA
UCLA
UEL
UF
UIC
USDHHS
USEPA
UST
uv
voc
we
WEF
WHO
Toxic Substances Control Act
Treatment, Storage, and Disposal Facility
Toxic Use Reduction Institute
Time-Weighted Average
University of California at Los Angeles
Upper Explosive Limit
Uncertainty Factor
Underground Injection Control
United States Department of Health and Human Services
United States Environmental Protection Agency
Underground Storage Tank
Ultraviolet
Volatile Organic Chemical
Wetcleaning
Water Environment Federation
World Health Organization
xix
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-------
EXECUTIVE SUMMARY
INTRODUCTION
Chemical solvents have been used for cleaning clothes since the mid-19th century.
Perchloroethylene (PCE) has been the solvent of choice for commercial clothes cleaning applications
since the 1960s, although the volume used by drycleaners has declined significantly over the last decade.
Despite this decline, a variety of health and safety issues associated with PCE use and increased
regulation of the chemical have compelled the U.S. Environmental Protection Agency (USEPA),
industry, and environmental groups to address concerns about PCE emissions. As part of an effort to
explore opportunities for pollution prevention and reduce exposure to traditional drycleaning chemicals,
the EPA's Design for the Environment (DfE) Garment and Textile Care Program has developed the
Cleaner Technologies Substitutes Assessment (CTSA).' Professional Fabricare Processes.
The goal of the CTSA is to provide comparative cost, risk, and performance information on
professional fabricare technologies. The audience for the CTSA is technically informed and might
consist of individuals such as environmental health and safety personnel, owners, equipment
manufacturers, and other decision makers. It is expected to be used as a technical supplement by USEPA
and stakeholders to develop information products suitable for a broad audience. These products will help
professional cleaners make informed technology choices that incorporate environmental concerns.
The CTSA is based upon readily available information and uses simplifying assumptions and
conventional models to provide general conclusions about various cleaning technologies. It is not a
rigorous risk assessment of chemicals used in the fabricare industry and should not be used to describe
the absolute level of risk associated with a particular clothes cleaning operation to specific populations or
individuals. Results often represent case studies, however, these case study scenarios may not be
representative of or generalizable to common practices. For instance, data on performance are reported
from real world performance demonstrations conducted in model clothes cleaning facilities that may or
may not be representative of a cleaner's specific operation. Additionally, there is not a consistent level
of performance information available across all technologies. Cost information, developed from
literature and through contact with industry representatives, is generalized and may overestimate or
underestimate costs for a specific operation. Exposure, hazard, and risk assessments for the chemical
components of the cleaning technologies were made by USEPA based on available data and/or modeling.
Assumptions used in developing the information in the CTSA are presented throughout to assist users in
determining the applicability of the information to various clothes cleaning operations. It is reasonable
to expect that actual risks, costs, and performance may vary for specific clothes cleaning operations.
DESIGN FOR THE ENVIRONMENT GARMENT AND TEXTILE CARE
PROGRAM
The CTSA is a small part of DfE's Garment and Textile Care Program. The Program's mission
is to assist in providing the professional garment and textile cleaner with a wider range of
environmentally friendly options which they can offer to their customers, while maintaining or
increasing economic viability. The objective is to promote not only cleaner production in the
ES-1
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Executive Summary
manufacture of garments and textiles, but also to promote production of garments and textiles that will
facilitate the use of clean technologies by the professional fabricare provider in meeting consumer needs.
USEPA's interest in PCE exposures from drycleaning developed after learning about air
emissions and water releases of the chemical. PCE has been documented in air, soil, and sediments and
has been found in 771 out of 1,190 National Priorities List sites (ATSDR, 1995). In May 1992, USEPA
convened the International Roundtable on Pollution Prevention and Control in the drycleaning Industry.
One of the outcomes of the International Roundtable on Drycleaning was recognition of the need to both
prevent pollution and reduce exposures to PCE in the drycleaning industry. USEPA has published some
materials that examine pollution prevention in the drycleaning industry. Included is The Product Side of
Pollution Prevention: Evaluating the Potential for Safe Substitutes, which evaluates the "...possibility of
dramatic reductions in toxic chemical releases by focussing on safe substitutes..." (USEPA, 1994) and
which contains sections specific to PCE. In this document, CTSA builds on that approach and introduces
additional information on PCE and alternative technologies that is useful for examining alternatives for
pollution, exposure, and risk reduction in a business environment.
CTSA RESULTS
Several technology alternatives to PCE drycleaning are available for commercial fabricare
(generally referred to as clothes cleaning throughout). They are categorized as dry and wet cleaning
processes, distinguished by the type of solvent used. Drycleaning refers to technologies based on non-
aqueous solvents, while wetcleaning refers to processes based on water as a solvent. The CTSA covers
PCE, hydrocarbon (HC) (including Stoddard, 140°F, and DF-2000 solvents), and machine wetcleaning
(MWC) processes.
Several alternative modifications and machine configurations for the most prevalent
technologies, PCE and HC dry cleaning, are also examined in the CTSA. They are compared on the
basis of relative releases of solvent and costs to provide information to current PCE or HC users on the
trade-offs associated with reducing solvent emissions, and possibly exposure, through process
modifications.
The information in the CTSA is primarily focused on the use of chemicals in the various
cleaning processes. Therefore, lifecyle considerations are not a part of the CTSA. Spotting chemicals,
although used in many commercial clothes cleaning operations, are not included in this document, nor
are chemicals in other formulations, such as fabric finishes and water softeners. An exception is
coverage of detergents used in the machine wetcleaning process. USEPA has developed example
formulations for which individual chemical components are examined in the CTSA. These formulations
and component chemicals are presented for illustrative purposes. Numerous detergent formulations are
currently available, and it is not clear how representative USEPA's sample may be.
ES-2
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Executive Summary
Effects
Possible health, environmental, and safety concerns are described for each of the clothes
cleaning processes. These possible effects range from cancer for PCE to a variety of noncancer effects,
such as neurotoxicity for HC, and skin irritation for the several components of the sample detergent. The
CTSA does not, nor is it intended to, represent the full range of hazards that could be associated with
clothes cleaning technologies. These effects have been associated with these chemicals in laboratory
tests and they may not occur in humans.
Environmental effects data are reviewed, and an environmental hazard ranking for aquatic
toxicity of the individual solvents and detergent chemicals is included where data allow. The rankings
range from low to high concern. Those of high concern include the HC solvents (Stoddard, 140°F, and
DF-2000 solvents). While water, the primary solvent in machine wetcleaning, is not of concern for
aquatic toxicity, there is concern for the detergents used. While used in small amounts (e.g.
approximately 1% of total volume of solvent and additives [Industry Contacts, 1998]) relative to the
process solvent, water, based upon EPA's sample formulation, some detergent components of the
example detergents may be associated with aquatic toxicity. Some characteristics of detergent
components, such as ability to biodegrade and chemical persistence, will affect whether actual detergents
are associated with aquatic toxicity.
Three chemicals are of additional concern due to fire hazard. These chemicals are Stoddard
solvent, 140°F solvent, and DF-2000, although the concern is lessened for 140°F solvent and DF-2000
due to their high flashpoints.
Releases
The CTSA presents estimated environmental releases of CTSA covered chemicals from facilities
that clean clothes. These estimates are used in evaluating health and environmental impacts of the
chemicals released and in examining the costs of the the processes. The CTSA relies heavily upon
information in published literature to generate release estimates. However, published literature contains
very limited information on most factors affecting chemical releases, including process type and
operating procedures. Therefore, it was not possible to examine the relative impact that many of these
factors have on releases. As a basis for comparing processes, theoretical "model facilities" were
developed. Releases were estimated for eight PCE, three HC, and two machine wetcleaning model
facilities.
The HC model facilities generally release the highest average volumes of solvent and solvent-
containing wastes, followed by the PCE model facilities'. The PCE and HC model facilities with the
fewest pollution control technologies release the highest volumes of chemicals to the air. These PCE and
HC model facilities also generate solid wastes that in many cases are considered to be hazardous. PCE
and HC model facilities release very small volumes of solvent into water. MWC model facilities
generally release the lowest average volume of chemicals, and almost all of these releases are into water.
Releases for machine wetcleaning cover only detergent chemicals, not solvent (i.e. water).
__
-------
Executive Summary
Exposures
There are a number of ways that people and the environment can be exposed to the chemicals
from clothes cleaning processes. Exposed populations include workers, co-located residents, and the
general population.
Workers in PCE and HC drycleaning facilities are exposed to solvents primarily by inhalation
and dermal (skin) pathways. Workers in MWC facilities are exposed to detergents primarily by the
dermal pathway. To characterize drycleaning worker inhalation exposures to the solvents, the CTSA has
relied heavily upon personal monitoring data in published literature. Published literature contains
limited information on most of the factors that affect exposure, including process type and operating
procedures. Therefore, it was not possible to examine the relative impact that all factors have on worker
exposures. All dermal exposures were modeled.
The inhalation data for PCE workers show several trends. There appears to be a general
decreasing trend in exposure levels and PEL excursions over time. As expected, operators in facilities
with transfer machines tend to have higher exposures than workers in facilities with dry-to-dry machines,
and increases in the number of machines increases exposure levels. Closed-loop machines with integral
carbon adsorbers (fifth generation) result in statistically significantly lower worker exposures than all
other machine configurations currently available. Finally, the inhalation data for HC workers support the
PCE data in showing that operators in drycleaning facilities generally receive higher average exposures
than non-operators.
Workers in drycleaning facilities who transfer wet garments generally have higher dermal
exposure potential than other workers, although PCE evaporates from the skin relatively quickly,
limiting the potential dermal doses. HC evaporates from the skin more slowly than PCE, and the dermal
doses of HC that drycleaning workers receive are potentially greater. MWC workers receive lower and
less frequent potential dermal doses of detergents relative to potential dermal doses of solvents received
by drycleaning workers.
Within the non-worker population, those most highly exposed to PCE are persons living in the
same building as a drycleaner that cleans clothes on the premises (i.e., co-located residents). Monitoring
studies show that the machine type and condition are important factors in the level of exposure.
Generally, more sophisticated machines, with associated controls, produce lower fugitive emissions.
However, even relatively advanced dry-to-dry machines can produce moderate to high PCE
concentrations in co-located apartments (Wallace et al., 1995). PCE emissions from drycleaners are not
expected to substantially increase exposures to the general population. Other types of general population
exposure to PCE can occur from ingestion of contaminated drinking water and from wearing drycleaned
clothes.
Monitoring data on HCs were not available, so exposures were modeled. The general
population's exposure to HCs is expected to be low. General population dermal (skin) exposure to
machine wet cleaning detergents was also modelled, and significant exposure is not expected.
ES-4
-------
Executive Summarv
Risk Estimates
The risk assessments were conducted at a "screening level" of review, using readily available
information and standard analyses for completion. The risk assessments and characterizations give an
idea of the potential risks to human health and the environment associated with each of the processes,
however, careful interpretation is necessary given that the extent and type of hazard and exposure data
and uncertainties associated with each process differ widely.
Perchloroethylene Solvent
There is a reasonable basis to conclude that there can be a health risk for cancer and some non-
cancer effects to workers from the relatively high PCE exposures observed on average in the drycleaning
industry. Based upon upper bound estimates, cancer concerns may also extend to residents living in co-
location with drycleaning establishments, particularly if they live in such dwellings for more than several
years. Non-cancer effects may also be a concern for co-located residents. In addition to their exposures
related to co-location with drycleaning facilities, co-located residents are also at risk through a variety of
PCE exposures that the general public experience, such as drinking PCE-contaminated water, or wearing
dry-cleaned clothes. Adult risk does not translate directly to infants, children, and the elderly, although
in scenarios where high risk levels have been determined for adults, there should be a concern for
sub-populations exposed by similar routes at similar levels.
Given the release estimates developed in the CTSA, it does not appear that there is a concern for
risk to aquatic species for the majority of dry cleaners who send their wastewater effluents to a publicly-
owned treatment work.
Hydrocarbon Solvents
A major hazard identified with the HC solvents considered in the CTSA is their potential
flammability. The National Fire Protection Association (NFPA) gives them a grading of "2" for
flammability indicating that they must be moderately heated or exposed to relatively high ambient
temperatures before ignition can occur. For comparison, PCE receives a grade of "0" for flammability
which indicates that it will not burn. Data are not available to evaluate the risks of fire in drycleaning
facilities due to use of these HC solvents. However, based on the NFPA's low flammability ranking,
the risk of fire from HC use can be considered greater than the risk of fire due to PCE. In addition, the
varying flashpoints of the three HC solvents examined suggests that the fire potential is lessened as one
employs a higher flashpoint HC solvent. Of the HC chemicals examined in the CTSA, DF-2000 has the
highest flashpoint, followed by 140°F solvent, and Stoddard solvent.
The health risk conclusions for the HC solvents in the CTSA are based upon findings for
Stoddard solvent, however, there are no data suitable for drawing conclusions concerning carcinogenic
potential. Worker exposures to HC solvents, especially the high end exposures, are indicative of a
concern for non-cancer risk for workers. Although HCs can be toxic to aquatic organisms, they are not
expected to be released in quantities that would pose a risk.
ES-5
-------
Executive Summary
Machine Wetcleaning
Based upon the example detergent, there may be a risk to aquatic organisms from some of the
constituents in detergents used in machine wetcleaning formulations. Potential risks are dependent on
the local streamflow and water treatment conditions, as well as the specific chemicals used in actual
detergent formulations. There is no expected health risk to the general public based on low expected
exposures. Risk estimates could not be developed for workers due to lack of sufficient toxicity data.
SELECTED FEDERAL REGULATORY REQUIREMENTS
Professional clothes cleaners may be subject to numerous federal requirements. In addition,
cities and municipalities have enacted numerous zoning restrictions that may affect all types of fabricare
operations, and many localities have adopted some, or all, of the National Fire Protection Association's
standards for drycleaning equipment and operations (NFPA-32). These restrictions and requirements
have the potential to affect costs and liabilities of cleaning operations.
Exhibit ES-1 summarizes the federal regulations that may affect clothes cleaning operations
covered in the CTSA. State and other requirements are not included. Requirements that pertain to the
use of spotting chemicals and chemicals such as fabric finish and water softeners are not included,
however, they should not be overlooked for their impact on a fabricare operation's regulatory
compliance activities. Absence of regulatory requirements identified within the CTSA does not mean
that federal, state, and local regulations are not applicable or will not apply in the future.
Exhibit ES-1. Summary of Regulations Related to Fabricare Technologies3
Fabricate
Option
PCE
cleaning
HC cleaning
Machine
wetcleaning
CAA
/
/
NA
CWA
/
/
/
RCRA
/
/
NA
CERCLA
^
/
NA
OSH
/
/
NA
Care Labeling
Rule
/
/
/
Other
NFPA 32
NFPA 32
NA
v Indicates that a technology is regulated specifically in statute.
NA Indicates that although the statutes apply to the technology there are no specific regulatory requirements.
* The list of regulations covered in this exhibit should not be considered exhaustive and may not cover all regulated aspects of the
fabricare industry.
The two most prevalent technologies, PCE and HC drycleaning, are most affected by provisions
of federal regulations. Machine wetcleaning currently has fewer requirements that are directly
applicable. It is unclear how requirements may change as industry use of these technologies changes.
The Care Labeling Rule relates to all cleaning methods, although it does not contain specific
requirements for cleaning garments. The rule requires manufacturers to label garments identifying
acceptable cleaning methods. Garments that are cleaned in a manner other than that specified by the
ES-6
-------
Executive Summary
manufacturer and are subsequently damaged, are the responsibility of the cleaner. Manufacturers may
cautiously label garments as "dryclean only" (Wentz, 1996; Riggs, 1998). In effect, this may constrain
the cleaner interested in avoiding liability from utilizing wetcleaning processes.
Under the Comprehensive Environmental Response Compensation and Liability Act (CERCLA),
potentially responsible parties that contribute to chemical contamination of a particular site, regardless of
the intent or involvement of that party, are held strictly liable. Many sites with past and present PCE
drycleaning operations are already contaminated to levels that will limit future uses of the property
leading to liability considerations that may affect decisions regarding technology choices. Other liability
concerns could result from worker claims for health effects resulting from chemicals used in clothes
cleaning processes or from garment damage resulting from the various cleaning processes.
COSTS
The costs of running a professional clothes cleaning business include rent, basic operating
expenses, and equipment. The equipment capacity, equipment type, and the location of the facility will
also affect the costs and economic viability of a professional cleaning operation. The CTSA has focused
on a subset of costs associated with operating clothes cleaning facilities.
Exhibit ES-2 summarizes the estimated process dependent cost components for the cleaning
technologies covered in the CTSA. Cost figures are presented in constant 1997 dollars in order to allow
direct comparisons among the process options.
Machine wetcleaning equipment, on average, is expected to cost less to purchase that PCE or HC
drycleaning equipment. The average total operating cost per pound is expected to be higher for PCE and
HC than for machine wetcleaning. One of the more significant operating costs for the drycleaning
technologies is the cost of hazardous waste disposal. These costs are estimated to be highest for HC
because of the volume of hazardous wastes released. However, wastes from certain HC processes,
particularly those using the higher flashpoint solvents such as DF-2000 and 140°F solvents, are less
likely to have significant amounts of hazardous waste generated from the cleaning process. Therefore,
HC costs, on average, are likely to be close to those for PCE. No hazardous waste costs are assumed for
machine wetcleaning, however, certain components of detergents or spotting chemicals may be
hazardous waste in actual machine wetcleaning facilities.
PERFORMANCE CHARACTERISTICS
Several factors may affect the performance of a cleaning process, including soil chemistry,
textile fiber type, transport medium (aqueous vs. non-aqueous), chemistry of additives (e.g., detergents)
use of spotting agents, and process controls (time, temperature, and mechanical actions). These factors
work interactively to provide a range of cleaning abilities for all clothes cleaning processes. In addition,
customer perceptions of a "clean" garment will vary. Finally, variations in technology and the
knowledge base of operators may also affect performance of the clothes cleaning process.
-------
Executive Summary
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ES-8
-------
Executive Summary
Although there is insufficient information to characterize the cleaning performance of each of
the cleaning technologies considered in this document, some general comparisons are possible between
drycleaning and wetcleaning processes. Drycleaning processes are more effective at dissolving oils and
fatty stains (non-polar soils), while wetcleaning processes tend to dissolve sugar, salt, and perspiration
(polar stains) with greater success. It is unclear whether particulate soils are better handled by one
process type or the other. The cleaning ability of both wet and drycleaning processes may be enhanced
with the use of spotting agents, detergents, surfactant additives, and other process modifications (time,
temperature, mechanical action).
These two types of cleaning processes also excel at cleaning different kinds of materials.
Drycleaning processes are most effectively used with textiles that contain water-loving (hydrophilic)
fibers (such as wool), low twist yarns, low count fabrics, and polar colorants. Wetcleaning processes are
effective with textiles containing water-hating (hydrophobic) fibers (such as polyester and nylon), high
twist yarns, high count fabrics, and non-polar colorants. Wetcleaning methods tend to cause expansion
of natural and cellulose fibers, leading to a loss of strength, wrinkling, color loss, and dimensional
change (shrinkage, stretching). However, textile manufacturers have developed a number of fiber
treatments and modifications (resin preparation, shrink prevention preparation, wool felt prevention) that
may minimize such cleaning impacts on clothing. Such alterations are not necessarily apparent when
synthetic fibers are subjected to similar water-based cleaning methods. Drycleaning methods, however,
may not be appropriate for synthetic fibers due to potential fiber deterioration.
OTHER FACTORS
Because different cleaning processes are more effective with certain types of materials and/or
certain types of soils, and because the effectiveness of all cleaning processes may be enhanced by certain
process modifications, it is difficult to draw any general conclusions concerning the relative performance
of the cleaning technologies considered in this document.
There are several other factors that may affect a clothes cleaner's decision. These may include
consumer issues beyond performance, such as odor in clothing, liability concerns, and the current state
and availability of alternatives. These factors can affect the costs faced by the cleaner, customer
satisfaction, or ability to select alternatives.
PCE has been known to leave an odor in drycleaned clothing. Similar odor concerns exist for
several of the HCs, however; the manufacturer of DF-2000 claims that it leaves no odor. Machine
wetcleaning processes do not have odor problems associated with them.
SUMMARY OF TRADE-OFF CONSIDERATIONS
Each of the factors summarized above may affect the technology choices made by clothes
cleaners. Cleaners must consider the costs of running an operation and the service that they can provide
to consumers. Choices may be limited by regulatory requirements and levels of necessary capital
investment. The effects of technology choice on the health and well-being of the environment and
-------
Executive Summary
individuals exposed to the chemicals and to the cleaning process are also important factors. Many of
these considerations are summarized in the CTSA and are organized and presented in Exhibit ES-4. ,
EMERGING TECHNOLOGIES
Several fabricare processes are currently under various stages of commercial development. As a
result of their emerging status, information on them ranges from anectdotal study to results. The CTSA
presents some information on these technologies, describing processes, estimated capital costs, and
claims about technology performance. However, the developmental nature of these process alternatives
does not allow for comparison with the existing technologies. The emerging technologies covered
include liquid carbon dioxide (CO2) drycleaning, propylene glycol ether (Rynex) solvent, ultrasonic
wetcleaning, and Biotex solvent. Much of the information comes from vendors and can not be
independently verified at this time; however, it is useful in providing an indication of fabricare
technologies that may become viable alternatives for drycleaners.
CONCLUSIONS
During the time that this CTSA has been under development, the fabricare industry has gone
through major changes. Drycleaners have significantly reduced PCE consumption, established a new
commercially viable cleaning process, machine wetcleaning, developed lower flashpoint hydrocarbon
solvents, and witnessed the development of a number of emerging technologies. As would be expected,
the CTSA, which is based on available information, includes a significant amount of information on PCE
and HC technologies, less on machine wetcleaning, and almost nothing on the emerging technologies.
As new information becomes available, EPA will make it publicly available through case studies and fact
sheets from its DFE Garment and Textile Care Program.
The CTSA demonstrates that each of the fabricare processes may have health and environmental
implications associated with their use. It does not provide estimates of risks from individual fabricare
operations, but identifies the most significant health and environmental concerns associated with each
process. Clearly identified are the possibility of risks of cancer to individuals highly exposed to PCE,
flammability hazards from some of the HC solvents, and possible considerations for the environmental
release of detergents from machine wetcleaning (depending upon the actual chemical components). Cost
data in the CTSA show which factors may contribute most to the costs of a particular technology choice,
and how these costs may compare relative to the costs of other technologies. The CTSA relates the
results of performance studies that describe customer satisfaction and effectiveness of the Machine
Wetcleaning process. The information on emerging technologies is general, reflecting what is known at
this time about liquid CO2 and ultrasonic cleaning, and Rynex and Biotex solvents.
ES-10
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Executive Summarv
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-------
Executive Summary
The CTSA offers guidance on the most important factors for comparing technologies.
Individual cleaners would need to apply these general considerations to the specifics of their operation in
order to make reasoned technology choices. Since the information contained in the CTSA is highly
technical, additional information products are expected to be developed to assist in dissemination of the
results. "Currently, DfE's Garment and Textile Care Program is developing a condensed version of the
CTSA.
Through its DfE Garment and Textile Care Program, EPA also plans to continue work in the
fabricare industry. Plans are to expand the Program's core base of stakeholders by increasing
representation from upstream industries such as textile and garment designers and manufacturers. The
broader circle of stakeholders will continue to work collaboratively to further integrate pollution
practices into the fabricare industry. EPA hopes that the CTSA, as well as future efforts, will encourage
improvement and expansion of new fabricare choices and remove barriers that prevention adoption of
economically competitive and environmentally sound processes.
ES-12
_
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Executive Summary
REFERENCES
ATDSR, 1995. "Toxicological Profile for Tetrachloroethylene Draft for Public Comment," the U.S.
Department of Health and Human Services, Public Health Service, Agency for Toxic Substances
and Disease Registry.
Beedle, L. 1998. Personal communication between Lee Beedle, Safety-Kleen of Grand Junction, CO, and
Jonathan Greene, Abt Associates Inc. March 19.
BLS. 1997. Bureau of Labor Statistics. Downloaded from the BLS Information Bulletin Composite File
of the Producer Price Index for Capital Equipment and Chemicals and Allied Products. U.S.
Department of Labor, Bureau of Labor Statistics, Office of Prices and Consumer Living
Conditions.
Gottlieb, R., J. Goodheart, P. Sinsheimer, C. Tranby, and L. Bechtel. 1997. Pollution Prevention in the
Garment Care Industry: Assessing the Viability of Professional Wet Cleaning. UCLA/Occidental
College Pollution Prevention Education and Research Center. Los Angeles, CA. December.
Hill, J., Jr. 1994. Personal communications between Jim Hill, Jr., Hill Equipment Company, and
Cassandra De Young, Abt Associates Inc. June and August.
Industry Contacts, 1998. Personal communication between EPA and several industry contacts.
Murphy, M. 1994. Personal communication between Mike Murphy, Unimac, and Cassandra De Young,
Abt Associates Inc. August 26.
NCAI. 1998. Neighborhood Cleaners Association International. NCAI Bulletin: Cost Comparison Chart
for 1998. March.
Riggs, C. 1998. Personal communication between Charles Riggs, Texas Women's University
Department of Fashion and Textiles, and Jonathan Greene, Abt Associates Inc. March 2.
USEPA. 1991a. U.S. Environmental Protection Agency. Dry cleaning facilities - background information
for proposed facilities. Draft environmental impact statement. EPA-450/3-91-020a. Office of Air
Quality, Planning and Standards. Washington, DC. November.
USEPA. 1993a. U.S. Environmental Protection Agency. Multiprocess wet cleaning cost and
performance comparison of conventional dry cleaning and an alternative process. EPA 744-R-93-
004. Office of Pollution Prevention and Toxics. Washington, DC.
USEPA, 1994. The Product Side of Pollution: Evaluating the Potential for Safe Substitutes.
EPA600-R-94-178.
Wallace, D. et al. 1995. Perchloroethylene in the air in apartments above New York City dry cleaners:
A special report from Consumers Union.
Wentz, M. 1996. The status of wet cleaning in Canada: the concept of textile care process spectra.
Presented at Conf. On Global Experience and New Developments in Wet Cleaning Technology.
Schloss Hohenstein, Boennigheim. June. p. 20-25.
ES-13
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CHAPTER 1
INTRODUCTION
This chapter introduces the Design for
the Environment (DfE) Cleaner Technologies
Substitutes Assessment (CTSA) for
Professional Fabricare Processes. Section 1.1
describes the background for the CTSA and its
relationship to the broader Garment and Textile
Care Program. Section 1.2 discusses the
CTSA's approach, including scope of
coverage, focus on certain technologies, and why particular information may be relevant. A brief
description of the intended use of this document concludes this chapter.
1.1
1.2
1.3
CHAPTER CONTENTS
Project Background
CTSA Approach
How To Use This Document
1.1 PROJECT BACKGROUND
The use of chemical solvents for cleaning clothes began in France in the mid-19th century. In
1925, a petroleum solvent (Stoddard) was developed and used for this purpose, and in the 1960's
perchloroethylene (PCE) became the solvent of choice for commercial clothes cleaning because it was
considered less flammable than petroleum. PCE is now used by a majority of clothes cleaners and has
since been shown to have a variety of health and safety issues associated with it. As a result, it has been
subject to increased regulation, taxation, and liability costs. While drycleaners have significantly reduced
the use of PCE over the last decade (Rissoto, 1997), it is still released to the environment. For example,
PCE has been found in 38% of 9,232 surface water sampling sites throughout the United States. It has
also been documented in air, soil, and sediments (ATSDR, 1995). PCE has been found in at least 771
National Priorities List (NPL) sites. The NPL consists of 1,416 hazardous waste sites identified by
USEPA as the most serious in the nation (ATSDR, 1995) and they are targeted for long-term federal clean-
up. It is unknown how many NPL sites have been evaluated for this compound. As USEPA looks at more
sites, the number of sites known to have PCE contamination may increase (ATSDR, 1995).
In May 1992, the Office of Pollution Prevention and Toxics of the U.S. Environmental Protection
Agency (USEPA) convened the International Roundtable on Pollution Prevention and Control in the
Drycleaning Industry. Researchers, industry representatives, and government officials met to exchange
information on the drycleaning industry. Issues discussed included exposure reduction, regulation, and
information dissemination. Numerous other topics, such as potential health and environmental
considerations related to exposure from drycleaning solvents, were also discussed.
USEPA created the DfE Program the following year and selected drycleaning as the subject of a
pilot project. USEPA made this selection in consideration of concerns identified at the Roundtable and
based on discussions with the Neighborhood Cleaners Association-International, Greenpeace, the New
York State Department of Health, the Fabricare Legislative and Regulatory Education organization, and
EcoClean. Dow Chemical, the Center for Emissions Control (currently the Halogenated Solvents
Industries Alliance), American Clothing and Textiles Workers Union (now the Union of Needletrades,
Industrial, and Textile Employees), the Center for Neighborhood Technologies (CNT), the International
Fabricare Institute (IFI), the Federation of Korean Drycleaners Associations (FKDA), and the Toxic Use
Reduction Institute at the University of Massachusetts also became active stakeholders. Alliance members
1-1
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Chapter 1
Introduction
What is Design for the Environment?
"Design for the Environment" means building in pollution prevention aspects when industry is
developing a product or process. The Design for the Environment (DfE) Program harnesses USEPA's
expertise and leadership to facilitate information exchange and research on risk reduction and
pollution prevention efforts. DfE works with businesses on a voluntary basis, and its wide-ranging
projects include:
• Encouraging businesses to incorporate environmental concerns into decision-making processes in
their general business practices.
• Working with specific industries to evaluate the risks, performance, and costs of alternative
chemicals, processes, and technologies.
» Helping individual businesses undertake environmental design efforts through the application of
specific tools and methods.
DfE partners often include:
Industry • Professional Institutions • Academia • Labor
Environmental Groups • Public Interest Groups • Other Government Agencies
were committed to exploring ways to prevent pollution, choose safer substitutes, and reduce exposure to
traditional drycleaning chemicals.
The fabricare industry is characterized by small companies that rarely have the time or resources to
gather information on alternatives to their current processes. As a result, few companies have access to
sufficient information to choose safer or lower risk chemicals, work practices, or technologies. DfE
prepared the CTSA to help fill this information gap. Specifically, the CTSAfor Professional Fabricare
Processes is a compilation of information on the relative risks, costs, and performance of clothes cleaning
operations. USEPA anticipates that this information will be used to develop information products for
cleaners so that they may be better equipped to examine trade-offs and incorporate environmental concerns
into their day-to-day and long-term business decisions.
What is a Cleaner Technologies Substitutes Assessment!
This technical document, referred to as a Cleaner Technologies Substitutes Assessment (CTSA), is
intended to develop and compile the information needed to systematically compare the trade-offs
associated with traditional and alternative products, processes, and technologies. Specifically, these
trade-offs include the cost, performance, and environmental concerns (such as risk and environmental
releases) associated with a product or technology. This CTSA addresses fabricare alternatives and
serves as the repository for technical information developed by the DfE Garment and Textile Care
Project on clothes cleaning technologies. It is only one of the products developed for use as part of
the Project, including those that may be suitable for a wider audience such as pamphlets and cost
accounting worksheets, and those that may pertain to other segments of the textile and garment care
industries.
1-2
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Chapter 1
Introduction
The CTSA is a small part of DfE's Garment and Textile Care Program. The Program's mission is
to assist in providing professional garment and textile cleaners with a wide range of environmentally
friendly options that they can offer to their customers, while maintaining or increasing economic viability.
The core of the Program stems from the fact that drycleaning is at the terminal end of an elaborate chain of
industries in the garment and textile industry sectors. Thus, so-called "upstream" industries, such as fabric
and garment manufacturing, directly affect the options available to garment and textile care providers.
Whether a garment or textile product can be cleaned by a particular method or alternative technology
depends largely on decisions made by the upstream industries regarding garment, fabric, and textile design
and construction.
As a result, the Garment and Textile Care Program is taking a "systems" or industrial ecology
approach to pollution prevention and is soliciting participation from a wider group of stakeholders than is
involved in the CTSA. Recent efforts of the Program have focused on expanding the core stakeholder
group to include representatives from the upstream industries and beginning development of a long-term
plan for change and increased incorporation of pollution prevention practices along the entire value chain.
The objective is to promote not only cleaner production in the manufacture of garments and textiles, but
also production of garments and textiles that will facilitate the use of clean technologies by the professional
fabricare provider.
1.2 CTSA APPROACH
An outcome of the International Roundtable on Drycleaning was the recognition of the need to
prevent pollution and reduce exposures to perchloroethylene (PCE) in the drycleaning industry. USEPA
has already published materials that examine pollution prevention in the drycleaning industry, including
"The Product Side of Pollution Prevention: Evaluating the Potential for Safe Substitutes." This report
evaluates the "...possibility of dramatic reductions in toxic chemical releases by focusing on safe
substitutes..." (USEPA, 1994) and contains sections specific to PCE.
"The Product Side of Pollution Prevention" identifies existing substitutes for PCE in drycleaning
and examines their efficiency and impact on reducing the generation of hazardous waste and the release of
toxic chemicals. The report describes priority toxic chemicals generally, as those chemicals that are part of
USEPA's 33/50 Program. The report concludes that safe substitute approaches for reducing PCE releases
from drycleaning include reducing the use of garments requiring drycleaning, reducing the use of water-
sensitive fabrics, altering the drycleaning process to eliminate or reduce organic solvent use, and
substituting a safe solvent for PCE (USEPA, 1994).
The CTSA builds on this approach and introduces additional information on PCE and substitute
processes that is useful in business decision making. Many of the approaches identified in "The Product
Side of Pollution. Prevention" such as the reduction in numbers of garments requiring drycleaning and the
use of water-sensitive fabrics in garment manufacture, are not within the CTSA's scope. However, the
CTSA takes a broad view of the substitutes for PCE, within the context of factors controllable by the
drycleaner. Rather than focusing only on reducing hazardous waste generation and release of toxic
chemicals, which is the approach of "The Product Side of Pollution Prevention," the CTSA incorporates
additional considerations of risk, cost, regulatory environment, and performance.
T3
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Chapter 1 Introduction
For instance with "The Produce Side of Pollution Prevention" looks at reducing toxic releases, the CTSA
incorporates information on the risks of chemical releases. Therefore, possible substitutes may differ
between documents.
1.2.1 Coverage of Fabricare Alternatives
Several technology alternatives are available for commercial fabricare. The CTSA generally
categorizes these as dry and wetcleaning alternatives. These categories are distinguished by the primary
solvent used. Drycleaning refers to those technologies using non-aqueous solvents, although it is
recognized that water may be a part of these processes. The CTSA covers PCE and hydrocarbon (HC)
drycleaning alternatives. The other process covered uses water as a solvent and is referred to as machine
wetcleaning in the CTSA. The extent to which each technology is covered in the CTSA is a function of
the amount of data available.
The CTSA includes evaluations on a subset of chemicals used in fabricare processes, for instance,
solvents and detergents (in the case of wetcleaning). Spotting chemicals and chemicals in other
formulations, such as fabric finishes and water softeners, are not covered in the CTSA. Also, the report
does not take an industrial ecology approach and evaluate lifecycle issues surrounding the chemicals and
does not fully consider issues related to garment labeling. These important issues may be evaluated
outside of this document and will likely be mentioned as considerations in the information products
developed from the CTSA for use by cleaners. Finally, the CTSA compiles much of the known
information on the cleaning technologies but does not generally develop new conclusions based upon that
information. For instance, the CTSA adopts USEPA's current classification of the carcinogenicity of PCE,
although USEPA is due to reassess this finding in the near future. Thus, most of what is found in this
document will be familiar to the studied reader.
The information in the CTSA shows a range of alternative processes for reducing exposures to
drycleaning solvents, (primarily PCE). These range from minor equipment modifications or changes (e.g.,
adding an emission control) to complete adoption of a new cleaning technology. For the PCE and HC
drycleaning technologies, the CTSA evaluates a set of alternative equipment modifications (e.g., changing
from a transfer to a dry-to-dry machine). This information is intended to provide a comparison of
alternatives that move toward a greater reduction in drycleaning solvent use, recognizing that a complete
technology change-over may not be an economically viable alternative for many of the businesses in the
short-run.
The evaluation of machine wetcleaning risks focuses mainly on the detergents used in this process.
Within the process, detergents are small percentage of the total volume of the solvent (i.e. water) and
additive mix, accounting for approximately 1% (Industry Representatives, 1998). Numerous detergent
formulations are currently available (Mains, 1996; Starr, 1998), complicating the review of this
technology. Therefore, in preparing the CTSA, USEPA contacted wetcleaning product formulators to
obtain information (chemical constituents and their weight percentages) on detergent formulations used.
As expected, much of this information was deemed proprietary by the manufacturers. Based upon the
information received, USEPA constructed an example formulation composed of chemicals (and their
weight percentages) that may reasonably represent the chemicals (and percentages in formulation) found in
actual formulations. It is not known how representative the selected chemicals and their concentrations are
of those found in the myriad detergents available. Therefore, information reported for specific detergent
J74
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Chapter 1
Introduction
components is intended only to illustrate the range of effects that could be associated with detergents in
general. To account for the variety of constituents that could be found in a detergent product, the CTSA
attempts, where possible, to identify the functions of chemicals found in detergents (e.g., surfactants) and
to generally identify considerations related to chemicals that can be used in those functions.
The CTSA contains a general section in Chapter 2 describing the market status of each technology.
The evolution of some of the technologies is briefly covered. Although some of the material covered in the
CTSA addresses older equipment (e.g., transfer machines), the information will provide perspective and be
useful to those cleaners who may currently be using this equipment or may be more familiar with it.
Process descriptions of the various technologies are also provided. These descriptions are useful
as background information and are general in nature. The reader should understand that specific machine
configurations within a given facility may differ.
To present information that is useful for comparison, the CTSA establishes a baseline against
which alternatives can be compared. Since the CTSA stakeholders are committed to pollution prevention
and solvent exposure reduction and because PCE is the dominant solvent used in the clothes cleaning
industry, the PCE technologies are used as the baseline.
1.2.2 Description of Health and Environmental Risks
The CTSA organizes information on the health and environmental risks of clothes cleaning
processes so that they can be compared. Characterizing these risks involves gathering a variety of
information. This process, known as risk assessment, generally requires the following components of an
analysis: hazard assessment, dose-response assessment, exposure assessment, and risk characterization.
As a first step in risk assessment, the CTSA provides a review of the human health, environmental,
and other (e.g., flammability) hazards (effects) of various fabricare technologies. This step provides a
basic description of the potential effects of exposure to the chemicals and processes. Effects can relate to
health and well-being, such as the ability of a chemical to cause cancer, respiratory illness, or injury such
as repetitive stress injury. They can also be environmental in nature, such as the ability of a chemical to
cause harm to aquatic organisms. Additionally, the CTSA describes effects related to flammability
resulting from chemical use. In its description of the hazards of individual chemicals, the CTSA generally
maintains the findings of USEPA, when available, and thus, does not present additional analysis of hazard
data. It does, however, provide a reasonable summary of relevant literature on hazards. Hazard
descriptions are summarized in Chapter 3, and a more detailed summary is found in Appendix C.
In addition to the hazards associated with the various cleaning technologies, it is also important to
identify who is exposed to the chemicals used in the various processes and thus, who may experience the
effects related to the chemical or process. This is the next stage in risk assessment. There are a number of
ways in which people and the environment can be subjected to the effects of the processes or individual
chemicals used therein. The CTSA limits its coverage of these exposures to those most relevant for the.
specific technologies and presents these in Chapter 4.
In evaluating exposures, the CTSA primarily uses the results of existing studies as a basis of
exposure estimates. These studies include monitoring data, where available, on chemical concentrations in
1-5
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Chapter 1
Introduction
air and water. These concentration data are then incorporated into models typically used by USEPA with
standard assumptions, in order to present ranges of estimates for chemical exposures. The CTSA also
describes reported exposure estimates from studies that use modeling.
In some cases, reported concentration data or modeled estimates of exposures are not available. In
these cases, it is necessary to develop estimates of chemical releases from various processes to serve as a
basis for estimating exposures. The CTSA presents release estimates for multiple media, air, water, and
solid waste, depending on the chemical and exposure pathways and populations of concern. Release
estimates are primarily developed for the analysis of exposures from wetcleaning operations and are based
upon the example detergent formulation developed by USEPA.
The CTSA also presents solvent release estimates from 11 PCE and HC machine configurations.
These estimates are intended to illustrate the relative differences in releases due to alternative machine
configurations and control technologies. They are not used in risk assessments; however, they are
presented in Chapter 10 to provide some information on how PCE and HC solvent reductions can be made.
The health and environmental risks associated with the cleaning technologies and the chemicals
used within them are characterized in Chapter 5. Information on the hazards of the chemicals or associated
with the technologies is combined with exposure and dose-response information to provide assessments of
potential risks. The risk characterization is conducted at a "screening level" and developed using standard
approaches. Estimated risks are not meant to predict actual risks to a particular individual; rather, they are
meant to give a sense of the significance of the risk. Particular attention is paid to characterizing the
uncertainty of the information. Similar to other information collected for this document, the extent of
information presented on risk of the individual technologies is a function of the amount of information
available on the technologies. Absence of information on a technology does not mean that risks are not
associated with it.
The CTSA presents both cancer and non-cancer health risks for humans. It also evaluates
environmental effects to aquatic species. Risks to terrestrial species are not considered. Quantitative
measures are presented, in some cases, to provide a sense of the magnitude of potential risks. However,
since the assessments for the individual technologies vary in the amount and type of hazard and exposure
information, type of health concern, and uncertainties, the information is not directly comparable across
technologies. Therefore, the comparison of risks is limited to a qualitative presentation in Chapter 10.
1.2.3 Performance Data
In addition to providing information on risks, in Chapter 6 the CTSA aims to provide information
on the performance characteristics of alternative clothes cleaning processes. Several performance
demonstrations and laboratory studies have been conducted to assess wetcleaning technologies in both the
U.S. and Canada. While independent of the CTSA, these demonstrations and studies have provided useful
information comparing wetcleaning to more traditional drycleaning technologies. Several studies have
been summarized and incorporated into the CTSA. These studies contain information on consumer
perceptions of the cleaning process (as it pertains to garments they have had cleaned) as well as
information on the costs to run the performance demonstration sites. The CTSA, however, does not derive
conclusions about the suitability for individual drycleaners of the alternatives that have undergone the
performance testing.
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1.2.4 Analysis of the Costs of the Alternative Clothes Cleaning Technologies
A cost analysis was developed for the alternative technologies by using data supplied by industry
and publicly available information. Cost information from the performance demonstrations was not
incorporated into the cost analysis. The cost information in the performance studies was not developed for
machine configurations similar to the model plant configurations in the CTSA and could not therefore, be
applied in the cost analysis. The cost analysis considers a subset of the costs of running a professional
clothes cleaning business: the private costs to the business. The CTSA includes estimates of some of these
costs, including capital equipment, solvent, energy, hazardous waste disposal, filters, and maintenance
costs. The CTSA uses this information to assess the relative costs of alternatives for a cleaning
technology.
The concept of social costs is introduced in Chapter 10. These costs could include the costs to.
human and environmental health resulting from various technology choices. These costs are not quantified
in the same manner as the private or business costs in this document, but are presented qualitatively.
1.2.5 Selected Federal Regulations
Professional clothes cleaners are affected by the requirements of many federal air, water, waste
management, and occupational health and safety regulations. State, local, and other requriements may also
pertain to clothes cleaning operations, however, are not covered in detail in the CTSA. Compliance with
regulatory requirements can affect the choice of technology by limiting available alternatives or by
increasing costs through compliance or liability. Chapter 6 summarizes many of the requirements faced by
cleaners, and encourages them to investigate additional federal, state, and other requirements that may
affect their operation. However, due to the variation in requirements across localities and operations,
specific cost estimates are not included.
1.2.6 Environmental Improvements
Individual drycleaning shops have unique circumstances that impinge upon their ability to make
certain process and technology changes. Therefore, in Chapter 9 the CTSA provides a listing of
management practices and improvements that can be used at drycleaning shops to prevent pollution,
reduce chemical consumption (and possibly exposure), and minimize waste. These opportunities can
contribute to a facility's ability to reduce drycleaning solvent use.
1.2.7 Evaluation of Trade-Off Issues
For alternative technologies, the CTSA considers private costs (costs to the cleaner), such as
operating and regulatory costs. It also considers external costs, including environmental damage and the
risk of illness to the general public or workers. These are described qualitatively in the CTSA in Chapter
10. In addition, other factors such as performance and state-of-the-art technology are included as factors
necessary in comparing alternatives. This material is presented in several frameworks that demonstrate
how useful comparisons can be made, including cost-benefit and cost-effectiveness analyses.
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1.2.8 Emerging Technologies
Chapter 11 of the CTSA provides some information on emerging technologies, liquid carbon
dioxide (C02), and ultrasonic processes, in addition to Rynex and Biotex solvents. Information is '
generally limited due to the pre-commercial status of most, and they have therefore not been compared to
existing technologies.
1.2.9 Additional Information
Several appendices are added to the CTSA to provide detailed information on various aspects.
Appendix A details chemical and physical properties of chemicals evaluated in the CTSA. Appendices •
providing more technical coverage of hazard and dose-response (Appendices B, C, and D) are included.
Release and exposure methodology and data are found in Appendix E. Finally, a description of the peer
review process that the CTSA underwent is included in Appendix F.
1.3 HOW TO USE THIS DOCUMENT
1.3.1 Clothes Cleaners
While a CTSA contains the technical information developed about a use cluster (in this case,
professional fabricare processes), it is not intended to guide the small business in making decisions. This
document should be used by technically informed decision makers. USEPA will develop user-friendly
information products based on the technical information in the CTSA and disseminate them to interested
parties. After reviewing these more targeted information products, clothes cleaners may choose to return to
the CTSA to obtain technical details on a specific alternative that is of interest to their operation.
The methods used to evaluate the technologies in this project may also be of interest to clothes
cleaners. These individuals may use the methodologies described in this document to conduct their own
evaluations of alternative projects or processes specific to their operation.
1.3.2 Other Readers
For technical assistance programs, the CTSA can provide background information on fabricare,
the applicable technologies, and the DfE Garment and Textile Care Project. The comparative information
on the cost, risk, and performance of alternative clothes cleaning technologies can be useful when working
with cleaners to move toward reducing risks or pollution. Comparative risk information in the CTSA can
be disseminated to workers and the general public so that they can better understand the risks associated
with the various cleaning technologies.
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REFERENCES
ATSDR. 1995, "lexicological Profile for Tetrachloroethylene Draft for Public Comment," the U.S.
Department of Health and Human Services, Public Health Service, Agency for Toxic Substances
and Disease Registry. August.
Industry Representatives, 1998. Personal Communication between USEPA and several industry
representatives.
Mains, H. 1996. Personal communication between Hardel Mains, Fabritek International, and Jonathan
Greene, Abt Associates Inc.
Risotto, S. 1997. Personal communication between Steve Risotto, Center for Emission Control, and Steve
Latham, Westat. December.
Starr, A. 1998. Personal communication between Anthony Starr, Center for Neighborhood Technologies,
and Erica Shingara, Abt Associates Inc. April.
USEPA. 1994. U.S. Environmental Protection Agency. The Product Side of Pollution Prevention:
Evaluating the Potential for Safe Substitutes. EP-600-R-94-178.
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CHAPTER 2
OVERVIEW OF PROFESSIONAL
FABRICARE TECHNOLOGIES
This chapter provides an overview of
the professional fabricare technologies covered
in the Cleaner Technologies Substitutes
Assessment (CTSA). The technologies
evaluated in the CTSA are listed in Section
2.1.1. Section 2.2 gives background
information on clothes cleaning. Section 2.3
describes the clothes cleaning processes
equipment. Section 2.4 gives the chemical
characterization of the technologies evaluated
in the CTSA. The chapter closes with Section
2.5, a market profile of the commercial fabricare industry.
2.1
2.2
2.3
2.4
2.5
CHAPTER CONTENTS
Technologies Evaluated in the CTSA
Clothes Cleaning Process
Process Equipment Descriptions
Chemical Characterization of
Technologies
Commercial Fabricare Industry Market
Profile
2.1 TECHNOLOGIES EVALUATED IN THE CTSA
Several technology alternatives are available for clothes cleaning, and can generally be
categorized into dry and wetcleaning alternatives. These categories are distinguished by the primary
type of solvent used. Drycleaning refers to processes that use predominately non-aqueous solvents. The
term "drycleaning" is a misnomer because clothes are actually immersed in a liquid solvent, and some
water may be included in the solution. Wetcleaning processes are those that use predominately water as
a solvent.
Drycleaning chemicals are chosen for their ability to dissolve organic materials that soil fabrics.
Two drycleaning solvents currently dominate the market in the United States, perchloroethylene (PCE)
and hydrocarbon solvents, which include Stoddard solvent. 140°F solvent and DF-2000. These are
generally referred to as hydrocarbon (HC) solvents throughout the document. The CTSA discusses the
risks associated with these solvents. PCE drycleaning is prevalent in the industry, and there are
numerous machine configurations that can affect costs, risks, and other considerations. The CTSA
examines several alternative modifications and machine configurations for PCE and HC cleaning,
primarily for the difference in releases and costs.
In addition to drycleaning, "wet" or aqueous-based cleaning is a possible process substitute that
may accomplish many of the same functions as drycleaning. The term "wet" refers to the use of a
quantity of water during the process, but garments may never be fully immersed or saturated with water
in some processes. Certain aqueous-based processes can be used on many garments, and are potential
substitutes for drycleaning. Others are designed only for certain types of garments, and may become an
alternative for a part of the total clothes cleaning volume.
USEPA originally sponsored testing of an approach to wetcleaning called "multiprocess
wetcleaning"; however, this technique is no longer practiced in the commercial field. It has been
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Overview of Professional Fabricare Technologies
replaced by a variety of combinations of machine wetcleaning and, therefore, machine wetcleaning is
included in the CTSA. For this process, the CTSA discusses the risks associated with sample detergents.
2.2 CLOTHES CLEANING PROCESS
Clothes go through several steps at professional fabricare facilities. The following steps
generally apply to cleaners using dry or wetcleaning processes. However, steps and procedures may vary
Considerably depending upon the facility, and there are some distinctions between dry and wetcleaning
processes The professional cleaning process begins with the sorting of clothes into similar fabric
weights colors, and finishes. Clothes are examined for stains. When stains are found, spotting agents
are applied to remove stains from the clothes. Clothes are then loaded into the cleaning machine (CARS,
1993; Gottlieb, 1997; NIOSH, 1997).
The clothes are washed in the machine by immersion and spin-agitation in a solvent-detergent
solution The machine then drains and spin-extracts the solution from the clothes. Cleaners occasionally
add second washing and extraction steps for better cleaning (CARB, 1993). After the final solvent
extraction from the clothes, the clothes are tumble-dried using heated air. The dry clothes are then
removed from the cleaning machine (CARB, 1993; Gottlieb, 1997; NIOSH, 1997). The equipment used
to clean clothes is discussed in Section 2.3.
After cleaning, clothes are rechecked for stains. If stains are found, spotting agents will be
applied The final major step in the clothes cleaning process is pressing. Pressing uses steam and
physical pressure to remove wrinkles and reshape clothes as needed (CARB, 1993). A variety of
pressing equipment is available (NIOSH, 1997). Wetcleaners who process 100% of garments may be
more inclined to purchase specially-designed pressing equipment that uses tension (Gottlieb, 1997).
However, pressing equipment is not covered in this CTSA.
2.3 PROCESS EQUIPMENT DESCRIPTIONS
This section describes the primary equipment used to clean garments for the technologies
covered in this CTSA. This equipment and their functions affect the environmental releases, human and
environmental exposures, and economic assessments within the CTSA.
The description is not a complete listing and description of all cleaning equipment but, is
intended to generally cover many of the important aspects of much of the cleaning equipment.
2.3.1 Perchloroethylene Processes Equipment
PCE use in drycleaning became prevalent in the 1960s, and several of PCE's desirable
characteristics have helped it to become the most common drycleaning solvent in the United States. As
the use of PCE in drycleaning has proliferated, a combination of financial factors, regulations, and
environmental concerns have given drycleaners incentives to reduce the loss of PCE. As a result, PCE
drycleaning equipment has evolved considerably. With the variety of drycleaning equipment has come a
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variety of terms to describe it. This CTSA attempts to describe the equipment using the most commonly-
used terminology, although specific terms may have different meanings to various people.
The following equipment comprises most PCE drycleaning machines: rotating cylinders or
drums for washing, extracting, and drying; condensers; charged and pure solvent tanks; a still; filters: a
lint trap; a water separator; and solvent vapor recovery devices, including carbon adsorbers, refrigerated
condensers, .and/or other devices. Some facilities have other equipment. Some PCE equipment
variations, features, and functions are described below. Special emphasis is given to equipment that
particularly affects exposures and releases of PCE. .
Machine Types
Machines used to clean garments and other articles may be classified into two types: transfer and
dry-to-dry. Like home clothes washing equipment, transfer machines have a unit for washing/extracting
and another unit for drying. .Following PCE extraction, articles which had been immersed in PCE are
transferred by a worker from the washer/extractor to the dryer, sometimes called a reclaimer. Dry-to-dry
machines wash, extract, and dry the articles in the same cylinder in a single machine, so the articles enter
and exit the machine dry. Transfer machines are sometimes called "first generation" machines. Dry-to-
dry machines may be called "second", "third", "fourth", or "fifth" "generation", and each machine's
designation depends upon its internal PCE vapor recovery machinery. Exhibit 2-1 presents process flow
diagrams for dry-to-dry and transfer machines.
Equipment for Vapor Recovery in the Machine
Vapor recovery of PCE, in the drycleaning machine occurs during the drying of the articles.
During the drying cycle, heated air is forced into the cylinder containing the wet articles and PCE
vaporizes into the heated air. The heated air containing PCE vapor passes through a lint bag and enters a
condenser. The condenser cools the air and condenses some of the PCE, which is recovered. The air
from the condenser is reheated and cycled back to the cylinder until the condenser no longer condenses
much PCE from the heated air stream. Some machines have drying sensors, that control the drying cycle
duration (CEPA, 1993).
Two types of condensers are used to perform this initial PCE vapor recovery: conventional and
refrigerated. Conventional condensers are usually cooled using water. This cooling water may be
circulated or once-through. Circulated water would pass through a cooling circuit such as a cooling
tower or a water chiller. Some conventional condensers may use air for cooling rather than water.
Refrigerated condensers (RCs) usually operate at lower temperatures than conventional condensers, and
the lower the condenser's operating temperature, the more PCE the condenser will recover from the air.
USEPA's PCE drycleaning National Emission Standard for Hazardous Air Pollutants (NESHAP)
requires an RC exhaust-side temperature of no more than 45°F. At the end of the cool-down cycle,
conventional water-cooled condensers can reduce PCE concentrations in the cylinder to 25,000 to 75,000
parts per million (ppm), while RCs can reduce PCE concentrations in the cylinder to 2,000 to 8 600 p'pm
(CEPA, 1993; NIOSH, 1997). ' F
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Exhibit 2-1 Simplified Process Flow Diagram for PCE Dry-to-Dry Closed-Loop Machinery with
Integral Carbon Adsorber ("Fifth Generation")8
EXHIBIT 1: Simplified Process Flow Diagram for PCE Dry-to-Dry Closed Loop
Machinery with Integral Carbon Adsorber ("Fifth Generation")
Source: Adapted from NIOSH, 1997,
Witti consultation from HHIJr., 1998.
Simplified Process Flow Diagram for PCE Transfer Machinery ("First Generation")
EXHIBIT 2
Simplified Process Flow Diagram for PCE Transfer Machinery ("First Generation")
Source: Adapted from USEPA. 1'Mlb for the U.S. Environmental Protection Agency's Office ofPollulion Prevention and Toxics.
With consultation from Hill. Jr.. 1998
• The simplified process flow diagrams in this CTSA have been developed from various sources These diagrams
have differences in appearance, components, and flows. The reader is cautioned not to interpret all these differences as having
signfficartSd^e to the issues presented in this CTSA. These diagrams are intended to show some of the major equipment
components and flows. Some equipment components and flows may not be shown, and some facilities may have vanations which
are not represented on these diagrams.
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Machines with conventional condensers have an aeration cycle following the drying cycle. Dry-
to-dry machines with conventional condensers are sometimes called "second generation" machines.
During the aeration step, fresh air is forced into the cylinder containing the clean, dry clothes to remove
the odor of residual PCE from the clothes. The aeration air leaving the cylinder contains PCE and may
be vented to atmosphere or may enter another vapor recovery device. When vented to the atmosphere,
the aeration air is a primary source of "vented emissions" from drycleaning machines, subject to the
NESHAP.
A device that can either recover PCE from vented aeration air or eliminate the aeration step from
first and second generation machines is sometimes called a "primary control." RCs and carbon adsorbers
(CAs) are the most commonly used primary controls. Once the CA reaches its capacity for adsorbing
PCE from the aeration stream (e.g., daily), the PCE is usually removed (desorbed) from the CA by
passing steam through the CA. Steam containing PCE exits from the CA and is routed to a condenser,
which liquefies the PCE and water vapors. The liquid PCE and water mixture from the condenser is
routed to the water separator. The CA must dry thoroughly before it is ready for reuse.
An azeotropic device is another device for recovering PCE from aeration air. An azeotrope is a
mixture of liquids with a boiling point that is lower or higher than any of its components. PCE and water
can be mixed to form a low boiling azeotrope. In azeotropic devices used in PCE drycleaning, the
aeration air containing PCE is bubbled through water, forming an azeotrope in the aeration air. This
azeotrope condenses at a lower temperature than PCE itself would condense, so more PCE can be
recovered using the azeotropic device than could be recovered without it. The aeration air circulates in
the machine until the condenser can no longer recover the PCE/water azeotrope. The condensed PCE
and water are routed to the water separator. Because azeotropic units are not widely used, they will not
be discussed further.
Machines with RCs do not have an aeration step since they remove more PCE from the drying
air than machines with conventional condensers do. The dry-to-dry machines with RCs are sometimes
called "closed-loop" machines because they do not vent aeration air. Machines with RCs have a cool-
down cycle following the drying cycle. Air is no longer heated, but continues to circulate between the
cylinder containing the clothes and the condenser, which cools the air and recovers more PCE. At the
end of the cool-down cycle, the condenser no longer recovers much PCE from the unheated air stream.
Some machines with RCs have no additional equipment for emission or exposure reduction at
the end of the drying cycle although significant PCE concentrations remain in the cylinder of the
machine. Other machines with RCs may have a fan that is intended to reduce worker exposures by
drawing air into the cleaning cylinder when the door is opened at the end of the drying cycle. The air
brought into the cylinder by this "door fan" or "OSHA fan" may be vented into the facility, outside the
facility, or to a small (one- or two-pound capacity) CA. The National Institute for Occupational Safety
and Health (NIOSH) has found that these small CAs are ineffective in capturing PCE unless the carbon is
either changed or desorbed daily (NIOSH, 1997). The air vented from a machine's "door fan" into the
facility either directly or indirectly through a small, ineffective CA may contribute to increased PCE
concentrations in the facility. The various dry-to-dry machines described in this paragraph are
sometimes called "third generation" machines.
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Some closed-loop dry-to-dry machines have a large, "integral" CA (usually 50- to 60-pound
carbon capacity or greater [NIOSH, 1997]) that is activated at the end of the cool-down step to reduce the
PCE concentration in the cylinder. These machines are sometimes called "fourth generation" machines.
Air containing PCE from the cylinder passes through the CA where PCE is adsorbed to the carbon and
returns to the cylinder. CAs used in this configuration are sometimes called "secondary controls." Some
fourth generation machines may have a sensor to monitor PCE concentration in the air in the cylinder
and control the adsorption until a desired PCE concentration (e.g., 290 ppm) is achieved.
Some other machines have the features of the "fourth generation" machine just described and an
additional door lock. This lock will not open until the PCE monitor detects the desired PCE
concentration "set point" in the cylinder. Reaching this set point indicates that the PCE recovery cycle is
complete. Thus, the door lock assures that the PCE recovery cycle is completed before the door may be
opened. These machines are sometimes called "fifth generation" machines. The PCE adsorbed by the
CAs in these fourth and fifth generation machines is removed (desorbed) from the CA by non-contact
steam or electrical heating (desorption) of the CA. Most of the desorbed PCE is then recovered by the
RC.
Liquid PCE Reclamation Equipment
Filtration and distillation allow drycleaners to clean and reuse PCE. Careful equipment use and
on-site recovery of PCE reduces the amount of PCE lost per volume of articles and reduces the need to
purchase replacement PCE. To remove insoluble materials from PCE, four primary filter types are used:
cartridge, tubular, disk, and regenerative. The two most common filter types are disk (also called spin
disk) filters and cartridge filters (Murphy, 1994). Polishing filters and filter additives sometimes
supplement filters to improve PCE purity (CEPA, 1993).
The spin disk filter consists of fine-mesh disks in a tube. Some disk filters are made to use filter
powder to aid the filtration process. Powder is not needed for powderless disk filters. For those that use
powder, the powder is coated on the disks' surfaces, and that coating is maintained by a constant flow of
PCE through the filter. Powders such as diatomaceous earth (i.e., clay) and carbon are added to the PCE
that passes through the outer parts of the tube and is deposited on the outer sides of the disks. During
filtration, PCE contaminated with insolubles passes into the tube, depositing the insolubles on the outside
of the disk. When the pressure across the disk increases to a certain level, filtration ends and the filter is
spun. The insolubles (and powder, if used) spin off the disks and into the PCE, which is then sent to
distillation. Powderless disk filters may require a finishing or polishing filter to remove extremely small
insolubles such as dyes that pass through these filters (CEPA, 1993).
Tubular filters are cylindrical screens on the outside of which diatomaceous earth and carbon are
coated. During filtration, PCE contaminated with insolubles passes through the screen, depositing the
insolubles on the outside of the screen. At the end of the day, the filter is back washed with PCE to
remove the insolubles and powder sludge from the filter, and the sludge in the PCE is sent to distillation
(CEP A, 1993).
Regenerative, or "bump-style," filters are modified tubular filters that are "regenerated" after
each load of clothes (CEPA, 1993). At the end of each wash load, the regenerative filter coating is
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"bumped" from the filter by stopping the flow of PCE through the filter (IFI, 1994). The coating
redeposits on the filter when the PCE flow is restarted before the next load.
Cartridge filters are used and discarded, while all other filter types are reusable. PCE containing
insoluble impurities passes through the cartridge filter's perforated outer shell, through paper, carbon,
and a fine mesh that collectively remove the insolubles from the PCE, which then exits the filter. Several
indicators may be used to determine when cartridges need to be replaced and may include pressure drop
across the filter; numbers of loads or amounts of clothes cleaned using the filter. Spent filters are
drained, and some drycleaners use steam to strip additional PCE from the filters. Usually, the spent
filters are then removed from the facility as hazardous waste (CEPA, 1993).
The main advantage of cartridge filters is the ease and simplicity of operation and changing,
requiring less labor and skill relative to other filter types, which usually require special start-up, cleaning,
and handling of powder and carbon. The main disadvantage with cartridge filters is the increased
hazardous waste disposal cost (IFI, 1994) and the higher loss of PCE (CEPA, 1993) relative to other
filter types.
Most drycleaners use distillation to keep the solvent clean enough to avoid odors and darkening
articles. Without distillation, oils, soils, dyes, detergents, and other PCE-soluble impurities would build
up in the solvent. Distillation generates concentrated waste material sometimes called "still bottoms,"
which contain PCE-soluble impurities. The still bottoms are often composed of 20% to 80% PCE,
although steam injection or PCE/water azeotropic distillation can lower this PCE concentration to 5% in
the still bottoms. The newest stills can reduce the PCE to below 1% (USEPA, 1997). Still bottoms are
usually removed and treated by the same firms providing other hazardous waste disposal services to
drycleaners (CEPA, 1993).
To begin the distillation process, impure PCE is pumped from the charge tank to a still. This
impure PCE is boiled in a still using steam coils, and PCE vapors flow to a condenser where the PCE
condenses. Two types of PCE stills are batch and flash (continuous). Condensed PCE and water flow to
a water separator, that separates water from the PCE. PCE leaving the separator flows to a PCE storage
tank, and in some facilities flows through a "rag" filter before entering the storage tank. Some facilities
use steam or air sweeping or steam injection to remove additional PCE from the still bottoms near the
end of the distillation process. At the end of this process, the still bottoms are drained before becoming
cool enough to thicken (IFI, 1994).
A special type of still called a muck cooker is used with machines that use powder filters. Muck
cookers have several features that stills do not: a special intake opening and valve from the filter; an
agitator with a universal joint; a sight glass; and a large bottom clean out door. Muck cookers use a
distillation step, then a "cook down" step, and a final air or steam sweeping step, that results in a "dry"
powder muck. The "dry" muck, that contains used filter powder and other soluble and insoluble
impurities from the PCE, is then removed from the cooker (IFI, 1994).
The water separator may receive PCE/water mixtures from many sources, several having been
described previously: direct steam desorption of carbon adsorbers, distillation and muck cooker
condensates, condensate from machines' conventional and refrigerated condensers, and condensate from
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steam presses. These mixtures are received into the separator, which works using the immiscibility and
density differences of PCE and water. The mixtures enter the separator and separate into PCE and water
layers with the heavier PCE settling to the bottom. The water phase is usually drained from the top of
the separator into a container for later evaporation or disposal as a hazardous waste. The PCE is usually
drained from the bottom of the separator to either the PCE storage tank or the machine cylinder. The
water from the separator usually contains less than 150 ppm PCE, unless the capacity of the separator is
insufficient to allow proper settling time for the water and PCE phases to fully separate or the water
contains detergents or other impurities (CEPA, 1993).
Wastewater Evaporation Equipment
Evaporators are used in some facilities to evaporate PCE-contaminated waste water rather than
dispose of it through hazardous waste haulers or release it to the sewer. Prior to evaporation, most
facilities will separate PCE from wastewater in the separator, and some facilities will pass the water
through carbon for adsorption and removal of more PCE from the water. If this carbon is changed
according to the manufacturer's instructions, PCE in the evaporated water can be minimized (CEPA,
1993). Vapor is vented from the evaporator to either the inside or outside of the facility. If vented
inside, the PCE in this vapor will increase PCE concentrations in the facility.
Water-Repelling Equipment
Three primary methods are used to apply water-repelling or waterproofing solutions to articles.
One method uses an additional storage tank, sometimes called a third tank, in which a PCE/water
repellent mixture is stored. This mixture is pumped from this storage tank into the machine's cleaning
cylinder, where clothes are immersed in the mixture. The mixture is then returned to the storage tank for
later reuse. A second method employs hand-pumped spraying of a commercial repellent mixture
(usually non-PCE based) onto articles. The third method uses a dip tank containing a PCE/water
repellent mixture. Cleaned articles are placed into a wire basket that is immersed into the repellent
mixture. After immersion, the basket is raised and excess liquid drips from the articles before the
articles are manually transferred to a dryer.
Spill Containment
Spill containment is another control that reduces PCE losses and ground contamination due to
spills. Two options for spill containment are safety troughs and floor coatings. Safety troughs are shallow
rectangular tanks in which all drycleaning equipment and auxiliaries that contain solvent reside. These
tanks are designed to allow for containment of the entire volume of the largest storage tank. The tank
generally contains a drain that can be connected to a pump for removal of spilled solvent, or for smaller
spills, rags may be used to absorb the spill and later cleaned in the drycleaning equipment. Floor
coatings in conjunction with a diked area or containment lip can function similarly to a trough, although
the effectiveness of these coatings has yet to be determined (CEPA, 1993).
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Fugitive Emissions Control
A variety of fugitive emissions recovery, ventilation, and containment systems have been
employed to reduce emissions and/or exposure to PCE vapor in the facility. The "door fan" described
above under Equipment for Vapor Recovery in the Machine is one of these systems. Other local and
general exhaust systems may be used to remove and sometimes recover PCE vapor from air in the
facility. Floor vents can be effective at removing and recovering PCE, especially in the event of spills.
In some of these systems, air containing PCE can be directed to CAs to recover some of the PCE vapor
(CEPA, 1993).
PCE emissions and migration within and from drycleaning facilities can also be reduced through
the use of enclosures sometimes called vapor barriers. Vapor barriers can contain some or all drycleaning
equipment that uses PCE and can be used to achieve minimum ventilation rates or other requirements.
The walls and ceiling are made of materials that are impermeable to PCE. The enclosures have negative
air pressure relative to the surrounding facility to prevent PCE migration. The air collected from the
vapor barrier may be exhausted outside the facility or to a control device such as a CA to recover some
of the PCE vapor (CEPA, 1993). Similarly, particular coatings and wallpapers used as PCE'diffusion
barriers in Germany appear to have achieved some effectiveness, although significant numbers of
defective applications have been found (Hohenstein, 1994).
In facilities with transfer machines, the transfer of clothing from the washer/extractor to the
dryer may result in a significant fugitive emission that does not occur in facilities with only dry-to-dry
machines. Under the NESHAP, a dry-to-dry machine used in conjunction with a dryer/reclaimer is
considered to be a transfer machine. Articles are damp with PCE when they are physically transferred
from the washing machine to the dryer, and some evaporation occurs during this transfer. The NESHAP
identifies three control technology options for reducing transfer losses: hamper enclosures, room
enclosures (a particular variation of the vapor barriers described above), and replacement with dry-to-dry
machines.
The most effective alternative for reducing fugitive emissions from clothing transfer is to replace
the transfer machine with a dry-to-dry unit. By definition, this eliminates transfer losses, since the
transfer process is eliminated. The new dry-to-dry machine would likely include process controls
providing additional reductions in total PCE emissions relative to the older transfer machine. Another
alternative to reduce transfer emission is to enclose the space surrounding washing and drying machines
with a vapor barrier (described above) and to vent air from the enclosure to a control device, usually a
CA. This alternative is sometimes called a "room enclosure." The least effective of these alternatives is
a hamper enclosure, which consists of a hood or canopy that encloses the transfer basket and doors of the
washer and dryer during loading and unloading and covers the hamper during movement from the
washer to the dryer. The operator reaches into slits in the hamper enclosure to load and unload the PCE
damp articles. A fan can draw room air into the enclosure, and air and PCE vapor are routed to a control
device, usually a CA, attached to the hamper enclosure.
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2.3.2 Hydrocarbon Processes Equipment
HCs were once the dominant drycleaning solvents used in the U.S. before PCE, which now
predominates. The most commonly used hydrocarbons are two petroleum solvents: Stoddard solvent and
140°F solvent (IFI, 1994). However, synthetic HC and other alternatives to petroleum solvents are being
marketed. Regarding the process equipment, HC equipment has not undergone the evolution that PCE
machinery has, so fewer variations and options exist in HC equipment. Also, HC processes and
equipment seem to have received little attention as indicated by scant coverage in literature. Therefore,
information presented in this CTSA is based on older literature sources and some more recent personal
contacts.
Machine Types
Machines used to clean garments and other articles may be classified into two types: transfer and
dry-to-dry. Like home clothes washing equipment, transfer machines have a unit for washing/extracting
and another unit for drying. Following HC extraction, articles that have been immersed in HC are
transferred by a worker from the washer/extractor to the dryer, sometimes called a reclaimer. Dry-to-dry
machines wash, extract, and dry the articles in the same cylinder in a single machine, so the articles enter
and exit the machine dry. Exhibit 2-2 presents process flow diagrams for dry-to-dry and transfer
machines.
Equipment for Vapor Recovery in the Machine
As with the PCE process equipment, HC vapor can be recovered during the drying of the articles.
Some HC transfer machines have standard dryers, which do not recover any vapor during drying. Heated
air is forced into the cylinder containing the wet articles, and HC vaporizes into the heated air. The
heated air containing HC vapor leaves the cylinder and is then vented from the standard dryer to
atmosphere.
However, machines with recovery dryers and dry-to-dry machines have condensers, which can
recover HC during article drying. During the drying cycle of these machines, heated air is forced into the
cylinder containing the wet articles, and HC vaporizes into the heated air. The heated air containing HC
vapor leaves the cylinder, passes through a lint bag, and enters a condenser. The condenser cools the air
and condenses some of the HC vapor, which is recovered. The cooled air from the condenser is reheated
and cycled back to the cylinder until the condenser no longer condenses much HC from the heated air
stream. For water-cooled condensers, an exhaust/cool-down cycle follows the drying cycle. In this
exhaust/cool-down cycle, fresh air is forced through the tumbling clothes, removing residual HC, and is
then exhausted to the atmosphere. It is not clear whether HC machines with RCs, like PCE machines
with RCs, have a cool-down cycle following the drying cycle.
Two types of condensers are used to perform this HC vapor recovery: refrigerated and
conventional. Conventional condensers are usually cooled using water. This cooling water may be
circulated or once-through. Circulated water would pass through a cooling circuit such as a cooling
tower or a water chiller. Some conventional condensers may use air for cooling rather than water.
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Exhibit 2-2. Simplified Process Flow Diagram for Hydrocarbon Dry-to-Dry Solvent Machinery3
Sources: Adapted from OTEC, Swiss Clean Hydrocarbon Drycleaning Instruction Handbook
With consultation from Hill Jr., 1998.
Simplified Process Flow Diagram for Hydrocarbon Transfer Solvent Machinery
Source Adapted from USEPA, 1991b for the U S Environmental Protection Agency's Office of Pollution
Prevention and Toxics
With consultation from Hill Jr., 1998,
• The simplified process flow diagrams in this CTSA have been developed from various sources. These diagrams may therefore
have differences in appearance, components, and flows. The reader is cautioned not to interpret all these differences as having
significance due to the issues presented in this CTSA. These diagrams are intended to show some of the major equipment
components and flows. Some equipment components and flows may not be shown, and some facilities may have variations which
are not represented on these diagrams.
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Refrigerated condensers (RCs) usually operate at lower temperatures than conventional condensers, and
the lower the condenser's operating temperature, the more HC the condenser will recover from the air.
Liquid HC Reclamation Equipment
As with PCE, filtration and distillation allow drycleaners to clean and reuse HC. Careful
equipment use and on-site recovery of HC reduces the amount of HC lost per volume of articles and
reduces the need to purchase replacement HC. Filters remove insoluble materials from HC, and one
source states that the filter options available for PCE are also available for HC (peer review comment 1-
196) The four primary filter types are cartridge, tubular, disk, and regenerative. These options are
discussed in detail under the Liquid PCE Reclamation Equipment header in the previous PCE processes
equipment description section and will not be repeated here.
Most drycleaners use a distillation process to keep the solvent clean. Without distillation, oils,
soils, dyes, detergents, and other HC-soluble impurities would build up in the solvent. The distillation
process generates a concentrated waste material sometimes called "still bottoms" that contains HC-
soluble impurities. The still bottoms normally contains a significant fraction of HC. Still bottoms are
usually removed and treated by the same firms providing other hazardous waste disposal services to
drycleaners (CEPA, 1993).
Vacuum stills are used to distill impure HC. The vacuum reduces the steam pressure required
for HC distillation. To begin the distillation process, impure HC is pumped to a still. The steam coils in
the still transfer heat to the HC, which boils, and HC vapors flow to a condenser where the HC
condenses. Condensed HC and water flow to a water separator. At the end of this process, the still
bottoms are drained before becoming cool enough to thicken (IFI, 1994).
The water separator may receive HC/water mixtures from several sources, some haying been
described previously: distillation and muck cooker condensates; condensate from machines'
conventional and refrigerated condensers; and condensate from steam presses. These mixtures are
received into the separator, which works using the immiscibility and density differences of HC and
water. The mixtures enter the separator and separate into HC and water layers, with the heavier water
settling to the bottom. The water phase is usually drained from the bottom of the separator into a
container for evaporation or disposal to the sewer or as a hazardous waste. The HC decanted from the
separator flows to a HC storage tank, and in some facilities flows through a "rag" filter before entering
the storage tank. The water from the separator usually contains less than one part per million HC unless,
as with PCE/water separation in PCE processes, the phases do not fully separate or the water contains
detergents or other impurities (CEPA, 1993).
Flammability Controls
Two dry-to-dry equipment variations have been developed to reduce the likelihood of explosion
by reducing the oxygen concentration in the machine. These variations are nitrogen injection and
oxygen vacuum systems. No information was found in the literature for these systems. The following
descriptions are based upon limited personal contacts and assumptions. The nitrogen injection and
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oxygen vacuum is expected to be used only during the drying cycle when air containing HC vapor is
heated.
Drycleaning equipment with nitrogen injection injects nitrogen gas into the cleaning chamber in
combination with HC. The addition of nitrogen lowers the concentration of oxygen, reducing the chance
of explosion (Abt, 1994).
Drycleaning equipment with oxygen vacuum lowers the pressure in the cleaning chamber. The
partial vacuum resulting from the reduced pressure reduces the concentration of oxygen, which greatly
lowers the flashpoint of the solvent and reduces the chance of explosion (Abt, 1994).
2.3.3 Machine Wetcleaning Process Equipment
In the 1990s, several aqueous-based processes have been explored as substitutes for drycleaning
of some garments. One of these processes, sometimes called "multiprocess wetcleaning," relied heavily
on hand labor to "clean" garments. This process used a variety of different techniques depending on the
individual characteristics of the garment in need of cleaning. These techniques include steaming,
immersion and gentle hand washing in soapy water, hand scrubbing, tumble drying, air drying. This
process also used spotting and pressing as in any of the fabricare technologies. The spotter/cleaner
determined which technique was most appropriate for each garment, given the fabric, construction, and
degree of soiling. A number of different techniques may have been used on any one garment (Abt,
1994). Multiprocess wetcleaning has not gained acceptance as a marketable primary cleaning method.
However, some of its techniques have been used to supplement the second, more widely-accepted
aqueous process, which is sometimes called machine wetcleaning (Environment Canada, 1995).
The machine wetcleaning process differs from the multiprocess wetcleaning by using machinery
instead of hand labor in the washing process. The basic difference in the machinery from traditional
laundering units is that the agitation applied to the clothes is reduced (Abt, 1994). The following
example of machine wetcleaning process equipment is particular to a Miele/Kreussler system, one of the
earliest systems developed for this process. Although the equipment specifics mentioned in this section
are particular to this example system, the process equipment functions for this system are expected to be
generally applicable to other machine wetcleaning systems.
The example system consists of a washer/extractor and a separate dryer, which both control
mechanical action and temperature (Patton et al., 1996). The principle of the system is that "spinning"
clothes during both water-based washing and drying can thoroughly clean and dry the clothes without
incurring the damage to delicate fabrics caused by agitation and tumbling. The washer/extractor
developed for the example system has holes in its drum which have been devised to provide optimum
protection for the garment being washed, and to facilitate chemical flow and active cleaning. The
temperature and the water level are each monitored and controlled. The washing/extracting process is
fully automated, and a liquid detergent is dispensed by two pumps at a predetermined time. After the
garment washing step, the wash water containing soils, oils, and detergents is extracted and disposed to
the sewer. After the garment rinsing step, rinse water may be disposed to the sewer or may be recovered
and reused using storage and filtration systems (Patton et al, 1996). The dryer in the example system
monitors the moisture of items in the drum, and air passes horizontally through the drum. A fraction of
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Exhibit 2-3. Simplified Process Flow Diagram for Machine Wetcleaning"
Sources Adapted from USEPA, 1997 for the US. Environmental Protection A8ency's Office of Pollution Prevention and Toxics.
Trainintt Curriculum for Alternative Clothes Cleaning With consultation from Star. 1998.
• The simplified process flow diagrams in this CTSA have been developed from various sources. These diagrams may therefore
have diSnces Appearance components, and flows. The reader is cautioned not to interpret all these differences as having
sianfficancl due to the issues presented in this CTSA. These diagrams are intended to show some of the major equipment
comJSnTs and flow! lie equipment components and flows may not be shown, and some facilities may have variations wh.ch
are not represented on these diagrams.
drying air is recycled, and automatic drum reversal is intended to dry the load evenly and help prevent
creasing (Abt, 1994). Exhibit 2-3 shows a flow diagram of the machine wetcleaning process with a
separate washer/extractor/dryer.
2.4 CHEMICAL CHARACTERIZATION OF TECHNOLOGIES
The information on hazards, releases, exposures, and risks presented in the CTSA is primarily
focused upon the chemicals as they are used in the various cleaning processes evaluated. Therefore,
lifecycle considerations are not a part of the CTSA. For the PCE and HC technologies, the focus is upon
effects associated with those chemicals as they are used as solvents. The portrayal of risks associated
with wetcleaning focuses upon the chemicals contained in the detergent formulations used. While
detergents may be used in other processes, the significant reliance upon these products in wetcleaning
processes warrants their evaluation under that technology. Detergent use is not evaluated for the other
technologies (i.e., PCE or HC processes) because their use is less significant. Spotting chemicals are
another type of chemical common to all of the cleaning technologies; however, they are not evaluated in
this document.
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2.4.1 Drycleaning—Solvents
Drycleaning processes utilize solvents other than water to effect cleaning. The solvents covered
in the CTSA are PCE and the HCs, Stoddard solvent, 140°F solvent, and DF-2000.
2.4.2 Machine Wetcleaning—Detergents
In preparing the CTSA, USEPA collected information on wetcleaning processes' formulations
through the processes' developers and machine manufacturers. USEPA received little information
following the requests, and most of the information received was deemed proprietary. However, from
the non-proprietary information received, USEPA developed two example wetcleaning detergent
formulations. These example formulations are primarily comprised of the chemicals listed in Exhibit
2-4, and the formulations themselves are shown in Exhibit 2-5. It is important to note that it is not
known how representative the formulations considered in this report will be of the potential universe of
detergent formulations available. While the chemicals included are commonly found in detergent
formulations, actual formulations may vary considerably in terms of both constituents and
concentrations. Therefore, information presented on the individual chemical constituents of the sample
formulation is presented to illustrate possible considerations associated with these types of products.
Exhibit 2-4. Example Detergent Chemicals Included in the CTSA
Chemical Name
Acetic acid
Cellulose gum
Citric acid
Cocamidopropyl
betaine
Ethoxylated sorbitan
monodecanoate
Laurie acid
diethanolamide
Methyl 2-sulfolaurate,
sodium salt
Sodium carbonate
Sodium citrate
Sodium laureth sulfate
Sodium lauryl
isethionate
CAS No.
64-19-7
9004-32-4
77-92-9
61789-40-0
9005-64-5
120-40-1
4337-75-1
497-19-8
68-04-2
9004-82-4
7381-01-3
Chemical Synonyms
Acetic acid glacial; vinegar; ethanoic acid
Sodium carboxymethylcellulose; CMC;
carboxymethylcellulose, sodium salt; CM cellulose
1,2,3-Propane tricarboxylic acid; 2-hydroxy-
hydroxytricarballylic acid
1 -Propanaminium, 3-amino-N-(carboxymethyl)-N,
N-dimethyl-, N-coco acyl derivates, inner salts;
Cocamidopropyl dimethyl glycine
Polyoxyethylene (20) sorbitan monolaurate;
sorbitan, monodecanoate, poly(oxy-1 , 2-ethanediyl)
derivatives
Lauramide DEA; N,N-bis (2-hydroxyethyl)
lauramide
Sodium methyl 2-sulfolaurate; N-lauroyl-N-methyl-
taurine, sodium salt; ethanesulfonic acid, 2-[methyl
(1-oxododecyl) amino]-, sodium salt
Carbonic acid; sodium salt; soda ash; Solvay soda
Trisodium citrate; 1 ,2,3-propane tricarboxylic acid;
2-hydroxy-trisodium salt
Ethoxylated sodium laureth sulfate; ethoxylated
sodium lauryl ethyl sulfate; poly(oxy-1 , 2-
ethanediyl)-sulfo-(dodecyloxy)-, sodium salt
Sodium ethyl 2-sulfolaurate; sodium
dodecoylisethionate; dodecanoic acid, 2-
sulfoethylester, sodium salt
Function
Surfactant aid
Surfactant
Surfactant aid
Surfactant
Surfactant
Surfactant
Surfactant
Surfactant aid
Surfactant aid
Surfactant
Surfactant
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Exhibit 2-5. Example Wetcleaning Detergent Formulations
Example Detergent #1
Constituent
water
methyl 2-suIfolaurate, sodium salt
sodium lauryl isethionate
ethoxylated sorbitan monodecanoate
lauryl polyglucose
Aveda's fragrance
sodium citrate
cellulose gum
acetic acid
citric acid
diazolidinyl urea
Weight
Percent"
54
3.75
3.75
7.5
7.5
1
2.5
5
5
2.5
7.5
Example Detergent #2
Constituent
water
methyl 2-sulfolaurate, sodium salt
sodium lauryl isethionate
lauric acid diethanolamide
lauryl polyglucose
sodium laureth sulfate
sodium citrate
cocamidopropyl betaine
Aveda's fragrance (orange)
citric acid
diazolidinyl urea
cocoamphocarboxyproprionate
sodium carbonate
Weight
Percent"
54
2.14
2.14
4.28
4.28
4.28
2.5
4.28
1
2.5
4.28
4.28
10
1 Assumed based on assumed function of constituent.
Four of these chemicals, Aveda's fragrance, lauryl polyglucose, cocoamphocarboxy proprionate,and
diazolidinyl urea are not covered in the CTSA because information was lacking on their chemical
identity.
The detergent chemicals in these example formulations can be grouped into several categories,
such as surfactants and surfactant aids. Surfactants are used to reduce the surface tension of water so that
it may more throughly wet the surface (Soap and Detergent Association, 1998) and are the primary
chemicals found in the detergent formulation reviewed for this document. Surfactant aids may enhance
the functions of the surfactant and can include components such as soil suspenders, pH adjusters, and
solubilizers. The chemicals included as part of the machine wetcleaning detergent formulation in the
CTSA are identified as either surfactants or surfactant aids.
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2.5 COMMERCIAL FABRICARE INDUSTRY MARKET PROFILE
2.5.1 Introduction
The commercial fabricate industry, also called the professional clothes cleaning industry,
includes approximately 36,000 facilities' that generate a total revenue of $7.2 billion2 annually (Seitz,
1997; Faig, 1998; Wong, 1998). Clothes cleaning volume for these facilities is estimated to be 871
billion kg (1.9 billion pounds) of clothes per year3 (Faig, 1998; Wolf, 1998). The majority (over 90%) of
the 36,000 commercial fabricare facilities in the U.S. are small neighborhood stores that consist of a
small storefront operation with customer pickup and delivery in the front, and cleaning and finishing in
the back.
Although there are numerous fabricare processes under development, drycleaning and
wetcleaning are the primary clothes cleaning processes commercially available at this time. Drycleaning
uses organic solvents, such as perchloroethylene (PCE) and hydrocarbon (HC) solvents, to clean soils
from clothing. HC solvents are a by-product of the distillation of petroleum and are often sold as either
Stoddard solvent or 140°F solvent, in reference to its flashpoint. In 1994, Exxon introduced a synthetic
HC solvent, called DF-2000, with a flashpoint above 140°F. Since then several other firms have either
introduced or are testing synthetic petroleum solvents for the drycleaning market (DeSanto, 1998).
Approximately 30,600 (85%) fabricare facilities in the U.S. use PCE drycleaning solvents, while
approximately 5,400 (15%) use HC drycleaning solvents.
Wetcleaning is an alternative cleaning process that uses water as the primary solvent to clean
fabrics. Wetcleaning is used exclusively at relatively few facilities but is used in combination with other
methods at many more facilities. Exhibit 2-6 presents the solvent volume used by commercial cleaners
distributed by solvent type and number of facilities. The commercial sector's total consumption of
solvents is also shown.
2.5.2 Perchloroethylene Market Share and Volume
The dominance of PCE in the professional clothes cleaning market is a function of its cleaning
ability for a wide range of fabrics and the materials that soil them, and its inherent fire safety advantages
as compared to many hydrocarbon solvents (i.e., PCE is not a flammable liquid).
In the U.S., 37% of the PCE produced is used by drycleaners (Mannsville, 1997). Mannsville
estimates that 52.6 million kg of PCE is consumed by the drycleaning industry, while Risotto places this
'The number of facilities is estimated from data provided by the California Air Resources Board (Wong, 1998).
2Based on an average facility revenue of $200,000 (Seitz. 1997; Faig, 1998).
•"Based on $200,000 revenue per facility and $3/lb average revenue (Faig, 1998; Wolf, 1998).
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Exhibit 2-6. Solvent Usage in the Commercial Sector of the Drycleaning Industry
Fabricare Solvent Type
Number of Facilities
Drycleaning Volume (kg/year)
Solvent Consumption (MM
kg/year)
PCE
30,600a
741,818,181°
45"
HC Solvents
5,400"
130,909,091°
8.3 to 34e
Wetcleaning
38b
NA
NA
NA = not available . ,
• Estimate based on 85% PCE and 15% HC use; data provided by the California Air Resources Board
b There'are 38 facilities using wetcleaning methods exclusively (Star, 1998). By the end of 1997.
3.000 wetcleaning machines had been sold in the U.S.; however, it is not known how many facilities
combine wetcleaning with other methods (USEPA, 1998).
< Estimated from revenue (Seitz, 1997; Faig, 1998), and based on 85% PCE and 15% HC use.
d Estimate based on Textile Care Allied Trade Association survey, adjusted for brokered import
volume (Risotto, 1997). . .
< Estimated from the range of mileages presented with the petroleum solvent options in Chapter 8.
estimate of consumption at 45 million kg (Risotto, 1997; Mannsville, 1997). The following three
companies produce PCE in the U.S.: Dow Chemical in Plaquimine, Louisiana: PPG Industries in Lake
Charles Louisiana: and Vulcan Materials Company in Geismer. Louisiana (Chemical Marketing
Reporter. 1997). In 1996 these plants produced approximately 136.4 million kg of PCE (see Exhibit _-/)
(Mannsville. 1997).
Exhibit 2-7. Total Volume of PCE (in million kg)
Year
Capacity
Production
Imports
Exports
Consumption
(Drycleaning)
1996
184.93
136.4s
27.7a
21. 8a
52.6b(1996)
45° (1996)
a Mannsville, 1997.
b Based on 37% of PCE being used for drycleaning and in textile
manufacturing (Mannsville, 1997).
0 Risotto, 1997.
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Exhibit 2-8 provides a historical perspective of PCE use in the U.S. from 1981 to 1996 (Risotto.
1997). Although PCE holds the large$t market share in the clothes cleaning industry, the consumption of
this chemical by fabricare facilities has clearly declined since 1981. Exhibit 2-8 demonstrates that from
1981 to 1996 there has been a 72% decrease in PCE use. by the fabricare industry. One of the primary
reasons for this decline is the growth in the use of wash-and-wear fabrics by the garment industry
(Levine, 1997). In addition, concerns regarding the human health and environmental hazards associated
with PCE have placed pressure on fabricare professionals to reduce consumption and use more benign
process alternatives. Initially, the drycleaning industry has focused on designing new equipment with
more effective solvent recovery and recycling systems, as well as developing safer solvent alternatives.
2.5.3 Hydrocarbon Solvents Market Share and Volume
HC solvents dominated the drycleaning industry in the United States in the 1950s. However,
their use gradually declined in the next three decades, primarily due to concerns about their inherent fire
and explosion hazards and the increased use of PCE by the industry. HC solvents with lower flashpoints
are desirable because of their cleaning ability and quickness in drying, when compared to HCs with
higher flashpoints. Increasing regulatory pressures on PCE, the introduction of HC dry-to-dry machines,
and the availability of higher flashpoint solvents in the 1990s have resulted in an increase in the number
of facilities using HC solvents (Baker, 1996). The proportion of establishments that rely on HC solvents
for clothes cleaning is approximately 15% of all commercial drycleaners (IFI, 1989; USEPA, 1991). The
Neighborhood Cleaners Association International (NCAI) predicts that the proportion of HC-using
establishments has the potential to increase to almost 25% in the future if stricter regulation of PCE is
implemented (Seitz, 1998)
Exhibit 2-8. Perchloroethylene Use (Domestic and Import) in the U.S. Drycleaning Industry
180
160
« 14°
| 120
1
.= 100
QJ
I 80
I 60
I
eu 40
20
0
166
1981 1983 ':1985, 1987 1989 1991 1992 1993 1994 1995
1996
Source: Risotto (1997).
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The current producers of HC solvent include Exxon, Ashland Chemicals Inc., Texaco Chemical
Co Plaza Group (which sells only Stoddard solvent but not exclusively to the drycleanmg industry),
Citeo (formerly Unocal Chemicals Division), Sun Company, Inc., Calument Lubricants, and Shell
Chemicals (OPD, 1992; Hinrich, 1998; Schreiner, 1998). Besides use as drycleanmg agents, HC
solvents are commonly used as degreasers in manufacturing and as paint thinners (Gossehn et al., 1984).
No information was available to identify the relative volumes of HC in various uses.
HC solvents used in drycleaning are differentiated as Stoddard solvent, 140 ° F, and Naphtha.
Stoddard solvent is estimated to be used by 25% to 30% of HC drycleaners, while 140'F solvent is used
by 60% to 65% of HC drycleaners (Seitz, 1998). Greater use of the latter solvent is attributed to its
higher flashpoint, and therefore greater safety threshold. Naphtha solvent is estimated to be used by 10/o
of HC drycleaners (Seitz, 1998).
The American Society for Testing and Materials (ASTM) has developed standard specifications
for Stoddard solvent that cover 10 HC solvents. These specifications are currently being revised (ASTM,
1995 Hinrich 1998). According to ASTM, Stoddard solvents include the following four types with
flashpoints of 100°F or 142°F: Type I, Full Range Mineral Spirits; Type II, High Flashpoint; Type III,
Odorless; and Type IV, Low Dry Point. Each of these types contain one to three different classes with
varying ranges of percent aromatic content: Class A, 8% to 22%; Class B, 2% to 8%; and Class C, 0% to
2%.
Conventional Stoddard solvents with flashpoints of 100°F to 105°F (38°C to 41 °C) are highly
flammable and are banned in communities with strict fire codes. Many are regulated by local air
pollution control districts because of their volatile organic compound (VOC) content, which contributes
to the build-up of photochemical smog. The 140°F solvent was designed to reduce the flammabihty and
VOC problems. Due to its higher flashpoint, 140°F solvent does not require the same level of explosion-
proof equipment and building construction as conventional Stoddard solvent. It is likely that the
combination of new dry-to-dry hydrocarbon drycleaning equipment and the use of 140°F solvent will
meet many of the fire codes that previously forced cleaners to switch to PCE (Hill, Sr., 1997).
Several of the major producers of HC solvents have recently introduced, or are about to begin
marketing products with flashpoints of 140°F to 147°F (60°C to 64°C). New equipment available to
HC drycleaners and a reassessment of the drycleaning market prompted the development of these
products (Exxon, 1994; Shell, 1994). The DF-2000 solvent was introduced in 1994 and is a synthetic
hydrocarbon solvent with a flashpoint of 147°F. It is designed for use in petroleum drycleaning
machines, such as the new dry-to-dry systems, and may also be used in PCE machines that have been
properly converted (Exxon, 1998). One of the major advantages of DF-2000 is that chemical residuals
are not considered hazardous wastes under the Resource Conservation and Recovery Act, (RCRA),
which results in lower waste disposal costs. Manufacturers also report that pressing times associated
with using DF-2000 are reduced when compared to other HC solvents (Exxon, 1998). However, DF-
2000 is still a flammable liquid and is classified as a VOC. Therefore, the following restrictions may
apply to this HC solvent: local fire inspectors may have to pre-approve use; waste must by transferred
by a licensed hazardous waste hauling company; a permit from a local air quality management district
may be required; and facilities converting to DF-2000 may be required to follow the requirements of the
NFPA Code 32 (Guidelines for Class III A drycleaning plants).
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In response to the increased demand for HC drycleaning machines, equipment manufacturers
have added several safety features to their designs to reduce the risk of fire and explosion. For example,
a new dry-to-dry HC machine may include a mechanism that injects an inert gas, such as nitrogen, into
the drycleaning equipment to reduce the concentration of oxygen and thus the explosion potential. A
number of systems incorporate HC monitoring equipment, which measures the HC vapor concentration
and automatically shuts down the system when the solvent stream reaches the Lower Explosive Limit.
Another safety method is to reduce the oxygen supply during the dry cycle by applying a vacuum and an
oxygen monitor to the system to reduce the oxygen level below 8%. HC dry-to-dry machines with
nitrogen injection and oxygen vacuum have been used for about 1 year in the U.S. and 4 years in
Germany. There are approximately 25 HC dry-to-dry machines with nitrogen injection or oxygen
vacuum in use in the U.S. (Seitz, 1998).
The market for this equipment has supported an increase from a single supplier in 1993 to at
least five suppliers in 1998. Because of local fire code restrictions, each facility that purchases a
hydrocarbon dry-to-dry machine must apply for a zoning variance before using the new machine. There
are now approximately 250 petroleum dry-to-dry machines in use in the United States (DeSanto, 1998).
2.5.4 Machine Wetcleaning
Fabricare professionals have always cleaned a portion of their clothing throughput using
domestic washers and dryers. With the introduction of more advanced washers and dryers, that
incorporate microprocessor controls, the percentage of clothing that can be effectively wetcleaned is
expected to increase. Other improvements that have made wetcleaning a more viable and safer clothes
cleaning process include the development of specialized detergents, fabric softeners, dye setting agents
that reduce bleeding, mild bleaching agents, and fabric finishes (sizing chemicals) that restore fabric
hand (Seitz, undated). In the U.S., wetcleaning is being used in combination with either PCE or HC at
about 200 facilities and at 38 dedicated wetcleaning shops (Star, 1998). A survey by the Hohenstein
Institute of Germany reported that approximately 40% of the professional clothes cleaning stream in that
country is wetcleaned, while the remaining 60% is drycleaned using PCE (Seitz, undated). While the
clothing stream in Germany may differ from that in the United States, the value indicates that a greater
portion of the clothing steam can be wetcleaned.
Companies selling machine wetcleaning equipment in the U.S. include Aqua Clean Systems,
Inc., AquaTex, Bowe Permac, Continental Girbau (plans to market a wetcleaning machine in 1998),
Daewoo Electronics Company, Edrom, Marvel Manufacturing, Pellerin Milnor Corporation, and
UniMac, (Star, 1998). In addition, domestic washer models such as the Maytag Neptune have been used
in facilities for wetcleaning processes. Wetcleaning chemicals manufacturers selling products in the
U.S. include Adco Inc., Aqua Clean Systems, Inc., AquaTex, Biifa, Caled-Signal Corporation, Daewoo
Electronics Company, EnviroSafe Wetcleaning Technologies, Fabritec International, Gurtler Chemicals
Inc., Laidlaw Corporation, Priaser, R.R. Street & Co.,Royaltone, and Seit (Mains, 1996; Star, 1998). The
increased availability of these products (all wetcleaning chemicals were imported as recently as 3994)
indicates a growing market (CNT, 1996).
2-21
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Chapter 2
Overview of Professional Fabricare Technologies
2.5.5 Fabricare Industry Trends
Although PCE continues to dominate the professional fabricare industry in the U.S., the industry
is undergoing significant change. Five years ago there were no hydrocarbon dry-to-dry machines or
wetcleaning machines in use. Today, the major U.S. HC supplier is producing 60% HC drycleaning
machines and 38 facilities perform dedicated wetcleaning. The development of alternative solvents and
cleaning processes was motivated by concerns of stricter state and federal regulation of PCE, as well as
increasing evidence of the chemical's negative impact on human health and the environment. In fact,
many drycleaners are increasingly faced with financial liability associated with cleaning up PCE-
contaminated soil and groundwater around their facilities. These concerns have made many property
owners reluctant to renew leases or rent to PCE drycleaners (Lummis, 1996). In addition, several states
have imposed taxes on PCE that double its price. The adoption of wetcleaning and petroleum solvents in
Germany as a response to strict PCE regulation could presage the level of adoption that may occur in the
U.S. However, direct comparisons among countries must be understood in the context of differences in
fabric and garment type, lifestyle, geography, and climate. Different perceptions of cleaning quality
among countries will also affect customer acceptance of alternative cleaning technologies.
Increasingly, fabricare professionals are proving that they can effectively wetclean many
garments traditionally drycleaned. Most facilities have a washer and dryer that are being used for
"wetcleaning" a larger fraction of the clothing stream than was done in 1990 (Seitz, 1995). The major
challenge facing the industry is the decline in the total volume of clothing drycleaned. Several reasons
have been cited for the decrease, including the increase in casual wear among office workers (Levine,
1997). The industry is addressing this by trying to broaden the services it offers to customers. For
example, a cleaning facility may provide services that emphasize pressing and finishing over merely
cleaning. The industry is also cooperating with clothing designers and apparel manufacturers to make
professional fabricare an integrated part of the textile care process. By encouraging the use of fabrics
and clothing construction compatible with professional fabricare techniques, the industry hopes to
remain a viable aspect of the U. S. economy.
2-22
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Chapter 2
Overview of Professional Fabricare Technologies
REFERENCES
Abbot, T. 1998. Personal communication between Tom Abbot, Drylene, and Jessica Green, Abt
Associates Inc. February 18.
Abt. 1994. Dry cleaning industry. Use cluster analysis. Final report. Prepared for USEPA, Office of
Pollution Prevention and Toxics under Contract No. 68-D2-0175. Abt Associates. April 5.
ASTM 1995. American Society for Testing and Materials. Standard Specification for Mineral Spirits
(Petroleum Spirits) (Hydrocarbon Dry Cleaning Solvent). Designation: D 235-95.
Baker, S. 1996. Personal communication between Scott Baker, Hill Equipment Company, and Jonathan
Greene, Abt Associates Inc. December.
CEPA. 1993. California Environmental Protection Agency. Air Resources Board. Technical Support
Document to the Staff Report. Proposed airborne toxic control measure and proposed
environmental training program for perchloroethylene dry cleaning operation. August.
Chemical Marketing Reporter. 1997. Chemical Profile Perchloroethylene. December 15.
CNT. 1996. Center for Neighborhood Technology. Wetcleaning machines: a report by the Center for
Neighborhood Technology obtained from the World Wide Web site http://www.cnt.org.
DeSanto, Jim. 1998. Personal communication between Jim DeSanto, Marvel Manufacturing and Alice
Tome, Abt Associates Inc. April.
Environment Canada. 1995. Final Report for the Green Clean Project, Environment Canada and the
Green Clean Project Participants. October.
Exxon. 1994. Personal communication between Exxon representative and Michael Miiller, Abt
Associates Inc. March.
Exxon. 1998. Information on DF-2000 downloaded from Exxon Website: http://www.exxon.com
Faig, Ken. 1998. Personal communication between Ken Faig, International Fabricare Institute and Alice
Tome, Abt Associates Inc. January.
Gosselin, R.E., R.P. Smith, and H.C. Hodge. 1984. Clinical toxicology of commercial products.
Williams and Wilkins.
Hill, Sr., J. 1997. Personal communication between Jim Hill Sr., Hill Equipment Company, and Alice
Tome, Abt Associates Inc. January.
Hinrich, B. 1998. Personal communication between Bob Hinrich, Unocal, and Erica Shingara, Abt
Associates Inc. April.
2-23
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Chapter 2
Overview of Professional Fabricare Technologies
Hohenstein. 1994. Summary of Research Project: Investigation of Measures for Reducing the
Concentration of Solvents in the Neighborhoods of Textile Dry Cleaners.
Bekleidungsphysiologisches Institut Hohenstein e.V. November 1994.
IFI. 1989. International Fabricare Institute. Equipment and plant operations survey. Focus on Dry
Cleaning. Vol 13(1). March.
IFI. 1994. International Fabricare Institute. Drycleaning Fundamentals. A Self Study Course. October
1994.
Levine, J. 1997. Personal communication between Jerry Levine, Neighborhood Cleaners Association
International, and Alice Tome, Abt Associates Inc. January.
Lummis, D. 1996. Personal communication between Dennis Lummis, NIE Insurance, and Alice Tome,
Abt Associates Inc.
Mains, H. 1996. Personal communication between Harold Mains, Fabritec International, and Jonathan
Greene, Abt Associates Inc.
Mannsville. 1997. Mannsville Chemical Products Corporation. Mannsville Perchloroethylene
Chemical Products Synopsis. Asbury Park, NJ.
Murphy, T. 1994. Personal communication between Tom Murphy, Kleen Rite, and Sharon Dubrow,
SAIC. September.
NIOSH. 1997. National Institute for Occupational Safety and Health. Control of Health and Safety
Hazards in Commercial Dry Cleaners. March.
OPD. 1992. 1993 OPD Chemical Buyers Directory. 80th annual ed. Schnell Publishing Co., New
York, NY.
Patton, et al., 1996. Patton, J., W. Eyring, et al. Alternative Clothes Cleaning Demonstration Shop.
Final Report. Center for Neighborhood Technology. September.
Risotto, S. 1997. Personal communication between Steve Risotto, Center for Emissions Control, and
Steve Latham, Westat. December.
Schreiner, J. 1998. Personal communication between James Schreiner, Exxon Chemical Company, and
Erica Shingara, Abt Associates Inc. April.
Seitz, W. undated Statement by William Seitz, Neighborhood Cleaners Association. DfE conference
material.
Seitz, W. 1995. Statement by William Seitz, Neighborhood Cleaners Association, at the December 5
Phase II Stakeholders Meeting, Washington, DC.
2-24
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Chapter 2
Overview of Professional Fabricare Technologies
Seitz, W. 1997, Personal communication between William Seitz, Neighborhood Cleaners Association-
International and Alice Tome, Abt Associates Inc. December.
Seitz, W. 1998. Personal communication between William Seitz, Neighborhood Cleaners Association-
International and Erica Shingara, Abt Associates Inc. April.
Shell. 1994. Personal communication between a representative of Shell Chemicals and Michael Miiller,
Abt Associates Inc. March.
Soap and Detergent Association. 1998. http://www.sdahq.org.
Star, A. 1998. Personal communication between Anthony Star, Center for Neighborhood Technologies,
and Erica Shingara, Abt Associates Inc. May.
USEPA. 1991. U.S. Environmental Protection Agency. Economic impact analysis of regulatory
controls in the dry cleaning industry. Final. EPA-450/3-91-021. Office of Air Quality, Planning
and Standards. October.
USEPA. 1997. U.S. Environmental Protection Agency. Cleaner Technologies Substitutes Assessment
Peer Review Comments
USEPA. 1998. Personal communication between wetcleaning equipment manufacturers and EPA.
Wolf, K. 1998. Personal communication between Kathleen Wolf, Institute for Research and Technical
Assistance and Alice Tome, Abt Associates Inc. January.
Wong, Todd. 1998. Personal communication between Todd Wong of California Air Resources Board,
and Alice Tome, Abt Associates Inc. January.
2-25
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-------
CHAPTER 3
HAZARD SUMMARY
This chapter describes possible health,
environmental, and safety concerns related to
clothes cleaning processes and the chemicals
used therein. It highlights some of the issues
related to these chemicals, but it is not intended
to represent the full range of hazards that could
be associated with clothes cleaning
technologies.
3.1
3.2
3.3
CHAPTER CONTENTS
Introduction
Overall Summary
Hazard Summaries by Technology
The chapter provides data on each of the technologies and the individual chemicals used within
those technologies as defined by this Cleaner Technologies Substitutes Assessment (CTSA). For each
technology and/or chemical, the chapter presents summaries of human health and toxicological data,
including exposure routes; toxicity endpoints (e.g., carcinogenicity, developmental toxicity, and neurologic
effects); and hazard measures. More detailed discussions of the studies are presented in Appendix C.
Environmental effects data on acute and chronic aquatic toxicity levels for fish, invertebrates, and algae
and environmental hazard rankings for individual chemicals are included. The chapter also describes
safety hazards that may be associated with the various technologies or chemicals.
3.1 INTRODUCTION
In understanding how the choice of alternative technologies may affect humans and the
environment, it is important to consider the effects that could result from exposure to the clothes cleaning
processes and the chemicals used in the various technologies under a specified set of conditions. Effects
can relate to health and well-being, such as the ability of a chemical to cause cancer or respiratory illness.
They can also be environmental in nature, such as the ability of a chemical to cause harm to aquatic
organisms. These effects on human health and the environment are often described as the hazard
associated with the chemicals and technologies. In its description of the potential hazards associated with
the alternative fabricare technologies, the CTSA includes effects on physical property, such as those
related to flammability
The chemistry and environmental fate of a substance also play important roles in determining both
hazard and potential exposure. Appendix A provides the chemical/physical properties of each chemical
and environmental fate summaries for some of the chemicals considered in the CTSA.
The data presented on chemical hazards focus on individual chemicals. Some technologies
employ mixtures of chemicals or formulations. Examples include machine wetcleaning and hydrocarbon
(HC) solvents. Ingredients (or components) of the formulations may differ from manufacturer to
manufacturer or supplier to supplier. While information on the specific formulation would be preferable, it
is not generally available. This section provides hazard data for chemicals among those typically used as
components.
3-1
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Chapter 3
Hazard Summary
Certain hazards, common to all technologies, are not expected to be noticeably different across
technologies. For instance, there are hazards of physical injury associated with the ergonomic environment
of the fabricare operation. Fabricare requires that employees perform a variety of tasks, some to operate
the cleaning equipment, some to carry out associated activities (e.g., pressing, clothes bagging). The
highly repetitive nature of these tasks can generate musculoskeletal injury. In particular, shops where
garment transfer is required entail such tasks as (1) moving carts with soiled items, (2) loading the washer,
(3) unloading the washer/extractor and loading the reclaimer or dryer, (4) setting controls and turning on
each machine, (5) sorting dried items for presser designations, and (6) moving dried items to a pressing
area These tasks are largely comprised of lifting and bending stresses. (Terminology and machine
functions involved in transfer may differ from technology to technology; for instance, the machine
wetcleaning process or a perchloroethylene (PCE) dry-to-dry machine may not require task 3.) Adding a
hamper enclosure to a PCE operation to control fugitive emissions may increase lifting stress, through
increasing the horizontal distance from the spine to the lifting activity of the hands, the most critical
measurement in the multiplicative National Institute for Occupational Safety and Health (NIOSH) lifting
equation" for repetitive stress injuries (Waters et al., 1994). Because such injuries are more a function of
the specific fabricare operation than the technology used, they are not examined further in the CTSA.
3.2 OVERALL SUMMARY
3.2.1 Human Health Hazard
Approach
The CTSA is intended to compile existing information on potential health effects resulting from
exposures to clothes cleaning technologies. Literature searches were limited to such sources as USEPA's
Integrated Risk Information System (IRIS), the National Library of Medicine's Hazardous Substances Data
Bank (HSDB), TOXLINE, TOXLIT, GENETOX, and the Registry of Toxic Effects of Chemical
Substances (RTECS). These sources are considered to be secondary sources, and a minimal attempt was
made to verify the information contained therein. Additionally, toxicologic data developed under the
Chemical Testing Program of USEPA's Office of Pollution Prevention and Toxics (OPPT), where
available, are incorporated in the human health hazard summaries.
Results
Exhibit 3-1 summarizes human health effects information obtained to date on chemicals used in
the clothes cleaning industry. Later sections in the chapter provide a brief summary for each technology
and the chemicals used within that technology.
The "Toxicity Endpoint" column in Exhibit 3-1 lists adverse toxicological effects by expected
exposure routes reported in the literature for animal or human studies. This is simply a qualitative listing
of reported observed effects. The list does not imply anything about the severity of the effects, nor the
doses at which the effects occur. Furthermore, an entry in this column does not necessarily imply that
USEPA has critically reviewed the reported studies or that USEPA concurs with the authors' conclusions.
3-2
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Chapter 3
Hazard Summary
Exhibit 3-1. Human Health Hazard Summary3
Chemical Name
Perchloroethyleneb
Stoddard solvent
(petroleum)1"
CAS No.
Expected
Exposure Route
Toxicity Endpoint
Drycleaning Technology - Perchloroethylene
127-18-4
Inhalation, dermal,
oral
Liver and kidney toxicity, neurotoxicity,
developmental and reproductive toxicity,
and cancer.
Drycleaning Technology - Hydrocarbon Solvents
8052-41-3
Inhalation, dermal
Irritation of the eye, skin, and respiratory
tract, and neurotoxicity.
Machine Wetcleaning Technology - Detergent Component Examples"
Surfactants
Cellulose gum
Cocamidopropyl
betaine
Ethoxylated sorbitan
monodecanoate
Laurie acid
diethanolamide
Sodium laureth
sulfate
Sodium lauryl
isethionate
Surfactant Aids
Acetic acid
Citric acid and
sodium citrate
Sodium carbonate
9004-32-4
61789-40-0
9005-64-5
120-40-1
9004-82-4
7381-01-3
Dermal, inhalation
Dermal, inhalation
Dermal
Inhalation, dermal
Dermal
Dermal
No significant adverse effects noted in
animal and human studies.
Possible eye and skin irritant.
Little or no skin irritation. May enhance
tumor activity of carcinogenic compounds.
Mild eye irritant.
Eye and skin irritant.
Limited information suggests may not be
an irritant.
64-19-7
77-92-9
68-04-2
497-19-8
Inhalation, dermal
Inhalation, dermal
Inhalation, dermal
Eye injury.
Eye and skin irritant.
Eye and skin irritation; respiratory effects
1 Technical hazard summaries may be found in Appendix C. Hazards represent possible effects
identified and do not indicate the likelihood of the effect occuring.
* Refer to Appendix D for a discussion of the doses used in the risk assessment (Chapter 5).
c Stoddard solvent hazard data are assumed to be representative for other hydrocarbon solvents M40°F
solvent and DF-2000).
d Chemicals are based upon an example detergent formulation developed for presentation in the CTSA
Therefore, it is not clear how representative they may be of chemicals used in actual detergent
formulations.
3-3
-------
Chapter 3
Hazard Summary
In the sections that follow, the most salient human health hazards associated with individual
chemicals within each technology are summarized. The information includes route(s) of exposure,
absorption and metabolism, human and animal toxicity information, irritation and sensitizat.on potential
and carcinogenic potential. These sections represent brief summaries of applicable information. Appendix
C contains a more detailed review of the hazard summaries for many of these chemicals, including
citations and references. Appendix D contains the dose-response assessments for PCE and hydrcarbon
(HC) solvents, which are used in the risk assessment (Chapter 5).
3.2.2 Environmental Hazard
Approach
The environmental hazard assessment of chemicals identifies effects that a chemical may have on
organisms in the environment. An overview of this assessment process has been reported by Zeeman and
Gilford (1993) and is summarized in Appendix B. The effects are expressed in terms of the toxic.ty of a
chemical on the organisms and are generally given as the effective concentration (EC) thatdescnbes the
type and seriousness of the effect for a known concentration of a chemical. A Hazard Prof.le or Toxic.ty
Profile is created when the ECs for a range of species are tabulated for a chemical. A detailed discussion
of a prototypic comprehensive Hazard Profile has been presented by Nabholz (1991).
The most frequently used Hazard Profile for the aquatic environment consists of three chronic and
three acute effective concentrations as reported by Nabholz, et al. (1993). These are:
A fish acute value (usually a fish 96-hour LC50 value) where LC50 represents the
concentration that is lethal to 50 % of the tested organisms at the end of the exposure
period;
An aquatic invertebrate acute value (usually a daphnid 48-hour LC50 value);
A green algal toxicity value (usually an algal 96-hour ECSO value) where EC50 represents
the concentration at which a chemical inhibits algal growth (biomass) by 50% at the end
of the exposure period;
A fish chronic value (Chapter 5), calculated according to Nabholz et al. [1993]), which is
often obtained from a fish 28-day early life stage study;
An aquatic invertebrate chronic value (usually from a daphnid 21 -day study); and
An algal chronic value (usually from an algal 96-hour study for biomass).
USEPA obtained the ecological/environmental toxicity values used in the Hazard Profile from the
results of standard toxicity tests reported to USEPA or published in the literature (i.e., measured values) or
estimated them based upon Structure-Activity Relationships (SARs) (predictive equations). SARs are
based on the assumption that chemicals with similar structural features will show similar toxic effects, and
they use data from many chemicals to predict these effects.
3-4
-------
Chapter 3
Hazard Summarv
For the CTSA, USEPA assessed discrete organic chemicals using predictive SAR equations.
USEPA found no data that conflicted with these estimates; however, few of the specific chemicals, with
the exception of PCE and Stoddard solvent, have studies reported.
Some products, such as detergents, softeners, surfactants, and hydrocarbon solvents are mixtures
and do not lend themselves readily to the standard hazard assessment process using SARs. USEPA
therefore evaluated the machine wetcleaning detergent formulations on a per constituent basis for this
CTSA. Thus, the toxicity values are for the discrete chemical only; interactions between chemicals within
a formulation are not considered.
Upon completion of a hazard profile, USEPA determined a concern concentration (CC). A CC is
the concentration of a chemical jn the aquatic environment that if exceeded, may result in a significant risk.
Conversely, if the CC is not exceeded, it is assumed that the probability of a significant risk occurring is
low. The CC for each chemical is determined by applying assessment factors (USEPA, 1984) to the effect
concentrations in the Hazard Profile.
After assigning a CC, USEPA ranked chemicals according to hazard concern levels for the aquatic
environment. This ranking can be based upon the acute toxicity values expressed in milligrams per liter
(mg/L). The generally accepted scoring is as follows (Clements et al., 1993):
High Acute Concern (H) z ]
Moderate Concern (M) > 1 and < 100
Low Concern (L) > 100
This ranking can also be expressed in terms of chronic values as follows:
High,Chronic Concern (H) < 0.1
Moderate Concern (M) > 0.1 and < 10.0
Low Concern (L) > 10.0
The chronic toxicity ranking takes precedence over the acute ranking.
Results
The results of the estimated aquatic toxicity determinations are summarized in Exhibit 3-2. For
each chemical, the exhibit gives the estimated toxicity values in mg/L (ppm) for acute and chronic effects
offish, daphnid, and algae. The second-to-last column shows the CC set for the chemical in water. The
last column notes the hazard rank using the method described above.
3-5
-------
Chapter 3
Hazard Summarv
Exhibit 3-2. Estimated Aquatic Toxicity Values of Dry and Wetcleaning
Chemicals Based on Measured Data and Struture Activity Relationship (SAR) Analysis (mg/L)
Chemical
Name
CAS
Number
Acute Toxicity (mg/L)
Fish Daphnid Algal
Chronic Toxicity (mg/L)
Fish Daphnid Algal
Concern
Cone. (mg/L)b
Hazard
Rank
Drycleaning Technology - Perchloroethylene _ .
PCE (SAR)
PCE (measured data)
127-18-4
127-18-4
5.9 7.0 4.8
5 8.5
0.96 0.66 1.07
2.3 0.51
0.07
0.05
Pryrisaning Technology - Hydrocarbon Solvents' r r
Stoddard solvent
(SAR)
Stoddard solvent
(measured data)
8052-41-3
8052-41-3
0.14 0.19 0.14
2.1 0.42
0.005 0.006 0.015
_
O.001
0.004
moderate
moderate
high
high
Marhin* W»^'«aninq Technoloav - Deterqent Component Examples ] __I
Acetic acid (SAR)
Cellulose gume (SAR)
Citric acid (SAR)
Cocamidopropyl
betaine (SAR)
Ethoxylated sorbitan
monodecanoate
(SAR)
Laurie acid
diethanolamide (SAR)
Methyl 2-sulfolaurate,
sodium salt (SAR)
Sodium carbonate
(SAR)
Sodium laureth
sulfate (SAR)
Sodium lauryl
iseth onate (SAR)
64-19-7
9004-32-4
77-92-9
61789-40-0
9005-64-5
120-40-1
4337-75-1
497-19-8
9004-82-4
7381-01-3
>100 >100 >100
>100 >100 5
>10 >10 >10
20 20 20
666
20 15 15
8300 2400 240
40 30 30
10 10 >10
>10 >10 >10
_
>10 >10 1/30'
>10 >10 >10
333
0.6 0.6 1
3.0 2.3 3.7
>100 >100 >60
6.2 4.6 8.0
223
>1
-
0.1/3'
0.2
0.3
0.06
0.2
6
0.46
0.2
low"
-
moderate/
low'
moderate
moderate
high
moderate
moderate
moderate
moderate
• Aquatic toxicity values based on the use of SARs except where noted.
M • —i js derived by dividing the lowest chronic value by ten. If result is < 0.001 then 00 is set aiuuu i
™rn r.nncentrations. and hazard rankings for 140°F solvent and DF-2000 are assumed to be the
same;
i^ because after treatment the chemical wil, be reiased at PH 7. At this PH the
rfowcted in a saturated solution during the prescribed exposure period of a standard test.
' Algae Tare partSaiiySnlitive to citric acid. The first value represents predicted toxicity and concern for normal water hardness and
the second for moderately hard water.
3-6
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Chapter 3
Hazard Summary
3.3 HAZARD SUMMARIES BY TECHNOLOGY
3.3.1 Drycleaning Technologies
The review of drycleaning hazards focuses primarily on the use of non-aqueous solvents (PCE and
HC solvents), and does not cover spotting chemicals, fabric finishes, water softeners, and detergents that
may also be used in the process.
Perchloroethylene
PCE Health Hazard Summary
The majority of information summarized below comes from secondary sources (USEPA, 1985:
ATSDR, 1993). Refer to Appendix C for more detailed information.
Studies in laboratory animals have shown that PCE is quickly absorbed by the body after
ingestion. In addition, PCE vapor in the air can be rapidly absorbed into the body through the lungs. PCE
can be absorbed into the body through the skin; although the absorption via the skin is approximately equal
to inhalation at low exposures (410 mg/m3), it can be as low as 1% of the amount absorbed via inhalation
at .higher exposures (4,100 mg/m3). Most of the PCE that is absorbed into the body rapidly leaves
unchanged, in the exhaled air. However, PCE that remains in the body changes into other substances.
These other substances are thought to be responsible for many of the adverse health effects attributed to
r V^LJ.
•People who breathe air that contains PCE for a short time may experience short-term effects on the
nervous system that are suggestive of depressed brain activity. The effects range from altered electrical
activity in the brain at moderate levels to dizziness, drowsiness, lack of coordination, faintness, headache
and nausea at higher levels and collapse, seizures, coma, and death at still higher levels. The effects on the
nervous system gradually fade when the affected person is removed from the contaminated air.
Drycleaning personnel who were exposed to low (<350 mg/m3) concentrations of PCE in the air for three
or more years did not perform well on neurobehavioral tests. Studies in laboratory animals have shown
that large doses of PCE taken by mouth or inhaled can produce lack of coordination, tremors, narcosis, and
death. It is not known if PCE can produce effects on the nervous system by skin contact.
People who breathe air that contains PCE may also have liver and kidney dysfunction. These
effects are most strongly associated with short-term exposure to high PCE levels in humans, but mild
kidney and liver dysfunction has also been reported from long-term exposure to PCE. In support of
findings in humans, studies in laboratory animals have shown that PCE damages both the liver and
kidneys. These effects occur regardless of whether PCE is inhaled or taken by mouth and can occur either
from short-term exposure to high levels or long-term exposure to lower levels.
The International Agency for Research on Cancer (IARC) recently concluded that PCE is probably
carcinogenic to humans based on studies in laboratory animals and human epidemiological studies (IARC
1995). Male and female mice that breathed air containing PCE or ingested PCE for most of their lifetime '
developed liver tumors. In addition, rats that breathed air containing PCE for most of their lifetime
3-7
-------
Hazard Summary
Chapter 3 . — '
appeared to have increased rates of leukemia (males and females) and kidney tumors (males only). It is not
cle'ar^howeve'if the tumors that developed in these animals are relevant to humans. Workers; exposed to
PCE for many years showed increased rates of esophageal cancer. The significance of this finding is
limited however due to weaknesses in the study. PCE has not been shown to interact strongly with
genedc maS, but several of the substances produced from PCE in the body have been shown to do so.
It is not known if PCE produces birth defects or interferes with reproduction in humans. Some
studies of workers exposed to PCE in the drycleaning industry have reported findings suggesting that such
effeS otr, but thes'e studies have many limitations that hinder their interpretation. Stud.es m laboratory
animals indicate that PCE produces effects on the developing fetus that include altered growth, b.rth
defect and death. Exposure of rats to PCE for three consecutive generations resulted man increased
nmn£ ^stillborn young, decreased litter sizes and survival of the young, and decreased test.s we.ght ,n
males.
The hazard values to be used in the risk assessment (Chapter 5) are a cancer inhalation unit risk
value of 7 1 x 10-7 per ug/m3 (for use only with exposures below 1.4 x 10< ug/m3) and a provisional RfC of
0 7 mg/m3 (see append D for details). The oral values are a cancer slope factor of 0.051 per mg/kg/day
(for use only with exposures below 2x10-' mg/kg/day) and an RfD of 0.01 mg/kg/day.
PCE Environmental Hazard Summary
The results of the hazard profile are summarized in Exhibit 3-2. The acute toxicity values for fish
obtained from the AQUIRE database range from 13.4 to 21.4 mg/L with a 1^^° "}«"?'^basfto
(11 tests) (USEPA, 1994). USEPA did not critically review the studies from the AQUIRE database to
determine the validity of the test results reported.
A recent review of PCE toxicity to aquatic species was reported by the United Kingdom (SIAR,
1996) Valid acute toxicity data were reported for rainbow trout (96-hour LC50 of 5 mg/L) and daphmds
48-hour LC50 of 8.5 mg/L). Valid chronic toxicity data were also reported for fish (28-day no-observed-
effect concentration [NOEC] of 2.34 mg/L) and daphnids (28-day NOEC of 0.510 mg/L).
The lowest reported measured NOEC was 0.510 mg/L in a daphnid 28-day study (Richter et al
1983, as cited in SIAR, 1996). The estimated acute toxicity values for PCE are 5.9 7 0, and 4.8 mg/L for
fish, daphnid and algae, respectively. The estimated acute value for fish of 5.9 mg/L is wrthm a factor o
2 5 of the mean AQUIRE value of 16.1 and is similar to the value of 5 mg/L reported in SIAR (1996) The
estimated chronic values for fish, daphnid, and algae are 0.96, 0.66, and 1.07 mg/U respectively. PCE ,s
of moderate concern for chronic effects to aquatic organisms (equal or greater to 0.1 and less than or equal
to 10 mg/L). The overall ranking of PCE based on chronic concerns is included in Exhibit 3-2.
Hydrocarbon Solvents
The hazard summaries for hydrocarbon solvents focus on the solvents used in drycleaning, which
are mixtures of linear, branched, and cyclic carbon compounds that have different Chemical/physical
characteristics. Health data were predominately found for Stoddard solvent (ATSDR, 1995 ; however, ,t is
believed that the other hydrocarbon solvents, 140°F solvent and DF-2000, would have similar health
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Chapter 3
Hazard Summary
concerns. This is also true for the description of the environmental hazards of these solvents. Differences
are expected, however, in flammability hazards, and these differences are noted. -
Hydrocarbon Solvents Health Hazard Summary
It is not known to what extent Stoddard solvent taken by mouth will be absorbed, but comparisons
to other petroleum products suggest that at least some of the substances that make up Stoddard solvent can
be absorbed into the body through the gut. Stoddard solvent vapor or mist in the air is quickly absorbed
into the body through the lungs. Stoddard solvent can also be absorbed into the body through the skin.
Stoddard solvent that is absorbed by the body collects in body fat, but over time, it is gradually released
from the fat and leaves the body. While in the body, some of the substances that make up the solvent can
be changed to other substances by the body's metabolism. It is not known how much of the solvent is
changed in this way, nor is much known about the nature of these changes.
Stoddard solvent in the air may be irritating to the eyes, nose, throat, and other moist exposed skin.
At moderate levels, comparable to'those at which workers are typically exposed, irritation is slight and few
people are affected. At higher levels, the irritation becomes stronger and more people are affected.
Studies in laboratory animals have shown that liquid Stoddard solvent applied directly to the skin produces
moderate skin irritation. In one known case a worker whose skin was in contact with Stoddard solvent
developed an allergic skin reaction.
People who breathe air containing Stoddard solvent or whose skin comes into contact with
Stoddard solvent may also experience effects on the nervous system. In an experiment, volunteers who
breathed air containing high levels of Stoddard solvent for a short period did not perform as well on
nervous system tests, which measured reaction time and short-term memory, as people who had not been
exposed. Workers exposed to Stoddard solvent have reported headaches, lightheadedness, fatigue,
decreased color discrimination, and memory impairment. However, many of these workers were also
exposed to other substances at home 'and work that could have contributed to these effects. Laboratory
animals exposed to very high levels of Stoddard solvent in the air-showed effects ranging from slowed
reactions and incoordination to tremors, convulsions, and death. The levels that produced these effects
were more than 10 times the levels to which workers are typically exposed.
It is not known if Stoddard solvent can produce cancer; the available studies in humans and
animals were inconclusive. Stoddard solvent has not, however, been shown to interact with genetic
material in short-term mutagenicity tests. It is also not known if Stoddard solvent can produce birth defects
or interfere with reproduction in humans. Limited studies in. laboratory animals have not shown that
Stoddard solvent can produce these effects.
The hazard value to be used in the risk assessment (Chapter 5) is a NOAEL (no-observed-adverse-
effect level) of 480 mg/m3 (see Appendix D for details).
Hydrocarbon Solvents Environmental Hazard Summary
A search of the AQUIRE database-for aquatic toxicity of Stoddard solvent and 140°F solvents
yielded no information (USEPA, 1994). The World Health Organization (WHO) recently published an
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Hazard Summary
Environmental Health Criteria document on Stoddard solvent (WHO, 1996) Limited1 aquatic toxicity data
(acute only) show a range of both daphnid 48-hour LC50s (0.42 to 2.3 mg/L) and fish 96-hour LC50 values
(2-21 mg/L) under a variety of test conditions.
USEPA assessed the chemicals using SARs to estimate the inherent toxicity of these chemicals to
aquatic organisms. The chemicals belong to the chemical class "neutral organics," for which there are
predictive equations for estimating three acute and three chronic values. Hydrocarbon solvents are
mixtures- the chemical constituents and the percentage of each in the hydrocarbon solvent mixture vanes.
The standard hazard assessment process using SARs is not appropriate for mixtures such as these, and
therefore USEPA evaluated them in a slightly different manner. The constituents ,n these products mclude
linear hydrocarbons and cyclic hydrocarbons, with the total number of carbons varying between 9 and 1..
To measure the toxicity of the solvents, USEPA estimated the toxicity of each indiv.dual constituent and
then evaluated the potential hazard of the product.
The estimated chronic toxicity values for the individual components (i.e., C9 to C12 linear
hydrocarbons and cyclic hydrocarbons) are given in Exhibit 3-3. Acute toxicity data could only be
predicted for 9-carbon cyclic compounds (0.14, 0.19, and 0.14 mg /L for fish, daphn.d, and algae
respectively); 10- and 11-carbon cyclic compounds (algae only, 0.04 and 0.02 mg/L, respectively); and for
9- and 10-carbon linear/branched compounds (algae only, 0.06 and 0.02 mg/L, respectively). To estimate
the toxicity the geometric mean of the predicted values was calculated. The geometric mean of estimated
chronic values for fish, daphnids, and algae range from 0.005 to 0.028 mg/L, which constitutes a high
concern for chronic effects.
Measured acute toxicity data for Stoddard solvent suggest chronic values of 0.04 mg/L for
daphnids and 0.2 mg/L for fish. These are within a factor of 10 of the predicted acute toxicity values.
Using either the measured or predicted values, there is a high concern to aquatic organisms.
Hydrocarbon Solvents Flammability Hazard
The NFPA (19xx) Fire Protection Guide to Hazardous Materials (10th edition) of the National
Fire Protection Association (NFPA) ranks chemicals on a scale of 0 through 4 for flammability. Materials
ranked 0 will not burn, and those ranked 4 include flammable gases, pyrophoric liquids, and flammable
liquids All of the hydrocarbon solvents, covered in the CTSA are ranked 2, meaning that they must be
moderately heated before ignition will occur and that they readily give off ignitable vapors.
Stoddard solvent is also considered ignitable based upon the standard outlined in 40 CFR §261.20
(Protection of the Environment, RCRA; Identification and Listing of Hazardous Waste, Charactenst.c of
Ignitability). Under this standard, a chemical is considered ignitable if it "is a liquid, other than an ^
aqueous solution containing less than 24 percent alcohol by volume and has a flash point less than 60 C.
DF-2000 and 140°F solvent are considered to have a non-ignitable ranking.
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Exhibit 3-3. Estimated Chronic Toxicity Values (mg/L) for Linear, Branched, and Cyclic
Hydrocarbon Solvents3
Type of
Molecule
Linear or
Branched
No. of
Carbons
9
10
11
12
Est. Log
K b
i\ow
5.4
6.0
6.5
7.0
Geometric Mean
Cyclic
9
10
11
12
5.0
5.6
6.1
6.7
Geometric Mean
Fish Chronic
Value
0.013
0.004
0.002
None0
0.005
0.03
0.01
0.004
0.001
0.006
Daphnid
Chronic Value
0.019
0.008
0.004
0.002
0.006
0.04
0.02
0.007
0.003
0.011
Algal Chronic
Value
0.045
0.021
0.011
0.005
0.015
0.08
0.04
0.02
0.009
0.028
a Estimates derived from SAR equation for neutral organics using number of carbons and
LogKow.
b Estimated LogKow (octanol-water partition coefficient) taken from CLOGP Version 3.3
Program (Leo and Weininger, 1985).
c No effects expected in a saturated solution during the prescribed exposure period.
Data were not available to assess the potential for the hydrocarbon solvents to ignite and cause a
fire incident. A search of the NFPA Fire Incident Database Organization for articles published in the
NFPA Journal about incidents in drycleaning facilities in which Class II (flammability) combustible
liquids were first ignited resulted in no identified incidents (Ahrens, 1998). Fire potential is a commonly
recognized hazard of hydrocarbon solvents; however, the significance of that potential or of the differences
in potential among the three hydrocarbon solvents is not addressed in this CTSA.
3.3.2 Machine Wetcleaning Technology
Machine wetcleaning detergent formulations are complex mixtures typically containing water and
a variety of other different chemicals. Most formulations are trade secrets, and the concentrations of the
individual chemicals are unknown to all but the manufacturer. The CTSA bases exposure estimates on
two example detergent formulations developed for presentation in the CTSA (see Chapter 4 and Appendix
E). Detergent #1 contains 10 constituents (plus water), and Detergent #2 contains 12 constituents (plus
water). Seven constituents are common to both formulations, three are unique to Detergent #1, and five
are unique to Detergent #2. It is not known how representative these chemicals are of those found in
actual detergent formulations.
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Hazard Summary
Health hazard summaries are presented for 10 of the 15 constituents found in the example
detergents used in this CTSA. Hazard summaries are not provided for lauryl polyglucose, Aveda's
fragrance, cocamphocarboxyproprionate, diazolidinyl urea, and methyl-2-sulfolaurate. Environmental
hazard summaries are based upon SAR estimates. The summaries are designed to illustrate the potential
range of effects that are associated with surfactant and surfactant aids that are found in machine
wetcleaning detergents. The representativeness of these effects for actual formulations in not known.
Some environmentally desirable chemical characteristics pertain to a number of different detergent
components and may help guide those evaluating detergents.
Typically, the environmental profile of a chemical improves with its rate of biodegradation.
However, it is equally important to consider the byproducts formed by the degradation process. These
products can be more toxic than the parent compound.
Certain type of polymers have less potential to harm the environment than others. Nonionic
(negatively charged) polymers are generally the least aquatically toxic; cationic (positively charged)
polymers tend to have higher acute toxicity to aquatic organisms.
Generally, the potential for a molecule to be absorbed and harm an organism is lower the larger the
molecule. Also, molecules that have straight carbon chains present less environmental concerns than those
that are highly branched and tend to resist biodegradation.
The chemicals in the detergents considered in this hazard summary can be grouped into surfactants
and surfactant aids. Surfactants are used to reduce the surface tension of water so that it may more
thoroughly wet the surface to be cleaned (Soap and Detergent Association, 1998) and are the primary
chemicals found in the example detergent formulation reviewed for this document. Surfactant aids may
enhance the functions of the surfactants and can include components such as soil suspenders, pH adjusters,
and solubilizers.
The CTSA examines the human health and environmental hazards of surfactants because they are
the primary components of most detergents. In general, there are several characteristics of surfactants that
may affect the degree to which human health and environmental effects are likely. These chemicals can
differ in inherent toxicity, persistence, and bioaccumulation potential, any of which can be a concern.
Surfactants that minimize these characteristics are presumed to be more desirable. A desirable property of
surfactants is that they can be easily destroyed, either through conventional treatment processes or through
biodegradation. Those that are easily destroyed are less likely to be persistent in the environment. For
instance, linear alcohol ethoxylates (LAEs) biodegrade to linear alcohols and carboxylic acids, compounds
of low environmental concern; alkylphenol ethoxylates, in contrast, may biodegrade under anaerobic
conditions to alkylphenols, which persist in the environment and may be highly toxic to aquatic organisms.
Also, LAEs are soluble in colder water and so may aid in the development of low temperature, energy-
saving detergents.
The following are chemical specific hazard summaries for several surfactants included in the
CTSA's example formulations, provided for illustrative purposes.
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Surfactants
Cellulose Gum
Cellulose Gum Health Hazard Summary
The information in this summary is taken from CIR (1986a).
Cellulose gum does not appear to be absorbed into the body from the gut or through the lungs or
skin and has been shown to be excreted entirely in the feces. The likelihood that exposure to cellulose
gum would cause health effects is very low.
Cellulose gum has not been found irritating to the skin, lung, or eyes. Cellulose gum applied to
the skin of humans does not appear to be irritating or to produce an allergic reaction. In a few studies,
irritation was noted, but it was classified as mild at the worst. Repeated application of cellulose gum to the
skin of laboratory animals caused only slight irritation and only in a few animals. Minimal or no eye
irritation was noted in laboratory animals given various cosmetic products containing cellulose gum.
No adverse effects were found in people who swallowed cellulose gum regularly over a period of
six months to three years. Studies with a variety of laboratory animals have shown that ingestion of large
quantities of cellulose gum daily for several months did not cause any changes in behavior or other adverse
effects. Similarly, inhalation of cellulose dust has not been shown to cause any toxic effects in exposed
workers.
Laboratory animals given cellulose gum by mouth have shown no evidence of birth defects or
interference with reproduction. Cellulose gum has been found not to interact with genetic material. There
have been no carcinogenicity studies reported for cellulose gum.
Cellulose Gum Environmental Hazard Summary
The environmental hazard summary for cellulose gum is based on the SAR method described
above and in Appendix B. Results for cellulose gum (Exhibit 3-2) suggest that it does not warrant concern
as a hazard to the aquatic environment.
Cocamidopropyl Betaine (CAPB)
CAPB Health Hazard Summary
The information in this summary is taken from CIR (1991).
It is not known how readily CAPB is absorbed into the body through the gut, lungs, or skin, or
how easily the body can change it to other substances or excrete it. Available information suggests that for
humans, the most likely route of exposure to CAPB is through the skin.
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For humans, CAPS has been found to cause skin irritation. Exposure of human skin to a soap
formulation containing CAPB for several consecutive days produced minimal skin irritation, whereas
longer exposure produced more severe irritation. In laboratory animals, skin application of CAPB
solutions produced a range of irritation reactions, from no reaction to severe irritation, depending on the
percentage of CAPB in the solution tested. Allergic reactions were not found in humans whose skin was
exposed to several different formulations of CAPB. Several instances of apparent contact dermatitis in
humans exposed to consumer products that contain CAPB have been reported, but recent evidence
suggests that the major cause of this reaction is a different chemical present in the detergent formulation.
Laboratory animals whose skin was exposed to CAPB have shown no or slight allergic responses. CAPB
is potentially irritating to the eye. Laboratory animals exposed to varying concentrations of CAPB
exhibited swollen eyelids and mild to moderate corneal irritation.
It is not known how long-term exposure to CAPB through ingestion, inhalation, or skin contact
affects humans. When ingested by laboratory animals, CAPB does not appear to cause any serious health
effects Animals ingesting a single large dose or several doses of CAPB for one month exhibited only
stomach or intestinal irritation. Moreover, when CAPB was applied to the skin of laboratory animals
several times a week for 20 months, no serious health effects were observed.
There is no information on whether CAPB can affect the nervous system, interfere with
reproduction, or produce birth defects. CAPB has not been found to interact with genetic material in short-
term mutagenicity tests. There is no evidence that CAPB can cause cancer. CAPB was not carcinogenic
in a mouse skin-painting study.
CAPB Environmental Hazard Summary
The environmental hazard summary for CAPB is based on the SAR method described above and
in Appendix B. Results for CAPB (Exhibit 3-2) suggests that it warrants a moderate level of concern as a
hazard to the aquatic environment.
Ethoxylated Sorbitan Monodecanoate
Ethoxylated Sorbitan Monodecanoate Health Hazard Summary
The information in this summary is taken from CIR (1984).
It is not known to what extent ethoxylated sorbitan monodecanoate (P-20) is absorbed into the
body through the gut, lungs, or skin. If P-20 enters the body, it is broken down by the body. The fatty acid
portion of the broken down substance remains in the body, is readily absorbed, and is broken down further
to yield energy for important life processes. The remaining portion of the substance is poorly absorbed by
body tissues and leaves the body unchanged. The most likely routes of exposure are by mouth and by skin
contact. There is very little likelihood of inhalation exposure to P-20.
Skin contact with P-20 may cause little or no irritation in humans or animals. No evidence of
allergic skin reactions was found in people whose skin had previously been in contact with P-20.
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Chapter 3
Hazard Summary
However, skin exposure of laboratory animals to P-20 produced moderate to strong allergic reactions. In
laboratory animals, P-20 produced no or mild irritation when it came into contact with the eyes.
Low to moderate amounts of P-20, taken by mouth by humans or animals on one or more
occasions, produced no deaths or adverse effects. However, an extremely high dose given over a long
period of time produced damage to the kidneys, spleen, and gut in one species of laboratory animal. It is
not known if adverse effects occur in people who breathe air containing dusts of P-20.
There is no information on whether P-20 can affect the nervous system, produce birth defects, or
interfere with reproduction. Based upon findings for other similar polysorbates, P-20 is not expected to
interact with genetic material. Although P-20 is not a cancer-causing substance itself, it has been shown to
enhance the activity of known cancer-causing substances and to inhibit tumor growth activity under certain
conditions.
Ethoxylated Sorbitan Monodecanoate Environmental Hazard Summary
The environmental hazard summary for ethoxylated sorbitan monodecanoate is based on the SAR
method described above and in Appendix B. Results (Exhibit 3-2) suggest that ethoxylated sorbitan
monodecanoate warrants a moderate level of concern as a hazard to the aquatic environment.
Laurie Acid Diethanolamide (Lauramide DEAj
Lauramide DEA Health Hazard Summary
The information in this summary is taken from CIR (1986b).
It is not known how readily lauramide DEA is absorbed into the body through the gut, lungs, or
skin, or how easily the body can change it to other substances or excrete it.
Contact of human skin with lauramide DEA may cause skin irritation. Exposure of human or
animal skin to soaps containing lauramide DEA for several consecutive days produced minimal to
moderate skin irritation. The degree of irritation depended on the percentage of lauramide DEA in the
soap product. Laboratory animals exposed to skin products containing up to 25% lauramide DEA daily for
several months showed only minimal skin irritation. However, very high concentrations of lauramide DEA
caused severe skin irritation. Allergic reactions were not found in humans whose skin had been exposed to
products containing lauramide DEA.
Lauramide DEA is irritating and potentially damaging to the eyes. Exposure of the eyes of
laboratory animals to a low (1%) concentration of lauramide DEA produced only slight, temporary eye
irritation. A moderate (5%) concentration of lauramide DEA produced moderate eye irritation, whereas a
high (25%) concentration produced severe eye irritation and permanent damage in laboratory animals.
When lauramide DEA is taken by mouth, either in a single large dose or in many smaller doses
over a long period of time, it does not appear to cause any serious health effects in laboratory animals. It is
not known, however, if the same is true in humans. Laboratory animals fed moderate to high
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Chapter 3
Hazard Summarv
concentrations of lauramide DBA in their diets for three months showed changes in red blood cells, a
temporary increase in blood sugar, or a decrease in body weight gain, due to decreased food consumption.
A moderate (5%) dose of lauramide DBA in a skin cleanser was repeatedly applied to the skin of
laboratory animals for 13 weeks. This dose produced minimal irritation but no evidence of other adverse
health effects.
There is no information on whether lauramide DBA can affect the nervous system, produce birth
defects, interfere with reproduction, or cause cancer. No interaction of lauramide DEA with genetic
material was found in seven studies. One other study suggested that lauramide DEA may interact with
genetic material in short-term mutagenicity tests.
Lauramide DEA Environmental Hazard Summary
The environmental hazard summary for lauramide DEA is based on the SAR method described
above and in Appendix B. Results (Exhibit 3-2) suggest that lauramide DEA warrants a high level of
concern as a hazard to the aquatic environment.
Sodium Laureth Sulfate
Sodium Laureth Sulfate Health Hazard Summary
The information in this summary is taken from CIR (1983).
Sodium laureth sulfate is readily absorbed through the gut after intake by mouth, but is poorly
absorbed through the skin. Studies in laboratory animals have shown that most of the sodium laureth
sulfate taken by mouth is excreted in the urine, with small amounts appearing in the feces and in exhaled
air.
Sodium laureth sulfate has been shown to produce skin and eye irritation at concentrations above
5%. Sodium laureth sulfate applied to the skin of humans or animals produced mild skin irritation. Skin
application of consumer products that contained sodium laureth sulfate produced no irritation to severe
irritation in humans and animals, depending on the concentration of sodium laureth sulfate in the product.
Sodium laureth sulfate did not produce allergic skin reactions when applied to the skin of laboratory
animals as a solution in water or when applied to animal or human skin in consumer product formulations.
Application of sodium laureth sulfate to the eyes of laboratory animals produced severe eye damage in
some animals and no damage in others.
A study of laboratory animals fed diets containing moderate concentrations of sodium laureth
sulfate for two years showed no effects except an unexplained weight loss in males. A high concentration
of sodium laureth sulfate applied daily to skin with other unspecified substances for 65 days produced
severe irritation, hair loss, and death in laboratory animals. At lower concentrations, there were severe skin
changes but no deaths.
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Chapter 3
Hazard Summary
Studies in laboratory animals suggest that sodium laureth sulfate taken by mouth does not produce
birth defects, interfere with reproduction, or cause cancer, and that sodium laureth sulfate applied to the
skin does not cause cancer. It is not known if sodium laureth sulfate interacts with genetic material.
Sodium Laureth Sulfate Environmental Hazard Summary
The environmental hazard summary for sodium laureth sulfate is based on the SAR method
described above and in Appendix B. Results for sodium laureth sulfate (Exhibit 3-2) suggest that it
warrants a moderate level of concern as a hazard to the aquatic environment.
Sodium Lauryl Isethionate (SLI)
SLI Health Hazard Summary
The information in this summary is taken from CCRIS (1995).
Hazard information on SLI is very limited. It is not known how rapidly SLI is absorbed into the
body through the gut, lungs, or skin or if SLI is changed into other substances by the body. Available
information suggests that SLI may not be a skin irritant and does not interact with genetic material in short-
term mutagenicity tests. It is not known if SLI produces birth defects, interferes with reproduction,
produces cancer, affects body organs, produces effects on the nervous system, or can produce an allergic
response.
SLI Environmental Hazard Summary
The environmental hazard summary for SLI is based on the SAR method described above and in
Appendix B. Results for SLI (Exhibit 3-2) suggest that it warrants a moderate level of concern as a hazard
to the aquatic environment.
Surfactant Aids
Surfactant aids serve a variety of purposes in the detergent formulation, including builders. These
chemicals vary in their potential to cause health and environmental effects. For instance, inorganic
phosphates, once commonly used in detergents as builders, are algal nutrients that can cause algal
"blooms" (a large increase in algae) in fresh water. The blooms eventually die off, depleting dissolved
oxygen in the water; low oxygen levels diminish water's ability to support many forms of life. Substitution
of organic chemicals for inorganic phosphates as detergent builders can avoid this problem and offer a
better environmental choice.
Acetic Acid
Acetic Acid Health Hazard Summary
The information in this summary is taken from HSDB (1994).
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Chapter 3
Hazard Summary
Acetic acid can be absorbed into the body through the gut after intake by mouth and through the
lungs of people exposed to acetic acid vapors or mists in air. It is not known if acetic acid is absorbed into
the body from the skin. Once in the body, acetic acid is readily changed by the body into other substances.
The dilute form of acetic acid (under 6%) is commonly known as "vinegar." Depending on
concentrations, exposure to acetic acid results in various levels of irritation when taken by mouth, inhaled,
or applied to the skin. Laboratory animals given strong solutions of acetic acid by mouth showed stomach
inflammation and damage. Exposure of human skin to acetic acid may cause ulcers, burns, and
inflammation of the skin. Exposure of the skin of animals or humans to high concentrations of acetic acid
may produce severe irritation. However, when low concentrations of acetic acid came in contact with the
skin of animals, they exhibited no potential for causing irritation. Allergic skin reactions to acetic acid,
although rare, have been reported in people. Immediate pain and eye injury have resulted from splashing
of a dilute solution of acetic acid into the eye. Permanent eye damage occurred in people whose eyes were
exposed to undiluted acetic acid.
Workers exposed to high concentrations of acetic acid in the air have exhibited effects such as
inflammation of the lungs, throat, and eyes; erosion of the teeth; enlargement of lymph nodes; swelling of
the eyelids; digestive disorders; dry or blackened skin; and swelling of the skin. Animal studies (one to
four months in length) in which moderate to high levels of acetic acid were used resulted in weight loss
(dermal exposure) and stomach lesions (exposure via drinking water).
One study analyzed pregnant laboratory animals given dilute acetic acid by mouth and found no
evidence of birth defects. Available information suggests that acetic acid does not interact with genetic
material in short-term mutagenicity tests. However, it is not known conclusively if acetic acid interferes
with reproduction in humans or animals.
No direct information was found on the ability of acetic acid to cause cancer in humans or animals.
A long-term study in which laboratory animals were fed sodium acetate, a salt of acetic acid, found no
evidence of tumors.
Acetic Acid Environmental Hazard Summary
The environmental hazard summary for acetic acid is based on the SAR method described above
and in Appendix B. Results for acetic acid (Exhibit 3-2) suggest that it warrants a low level of concern as
a hazard to the aquatic environment because after treatment the chemical will be released at pH 7. At this
pH the chemical is neutral without acid reaction.
Citric Acid and Sodium Citrate
Citric Acid/Sodium Citrate Health Hazard Summary
The information in this summary is taken from HSDB (1994).
Citric acid is normally produced by the human body and occurs naturally in many foods, such as
fruits. It is not known to what extent citric acid or sodium citrate is absorbed through the gut or lungs.
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Chapter 3
Hazard Summary
Neither citric acid nor sodium citrate, a salt of citric acid, is expected to be absorbed through the skin.
Once in the body, sodium citrate is changed to a different substance and is excreted through the urine.
Citric acid is unlikely to cause harmful effects unless large quantities are consumed. Frequent or
excessive intake of citric acid by mouth has produced erosion of tooth enamel, local irritation of the mouth,
or ulcers in people. People have reported stomach irritation and stomach disturbances after drinking sodas
containing citric acid.
Citric acid can be irritating to the nose, throat, or lungs of people who inhale mists or dusts of
citric acid from the air. It can also irritate the eyes or skin if direct contact occurs. Strong solutions of
citric acid were a mild skin irritant and severe eye irritant to laboratory animals.
Studies in laboratory animals suggest that exposure to citric acid does not produce birth defects or
interfere with reproduction. It is not known from experiments if citric acid produces effects on the nervous
system, interacts with genetic material, or produces cancer in humans or animals.
Citric Acid/Sodium Citrate Environmental Hazard Summary
The environmental hazard summary for citric acid/sodium citrate is based on the SAR method
described above and in Appendix B. Citric acid and its soluble salts, such as sodium (Na) and potassium
(K), at pH 7 are expected to be moderately toxic to green algae in freshwater environments (acute toxicity
values are greater than 1 ppm but less than 100 ppm).
The average acute toxicity values for freshwater fish and freshwater aquatic invertebrates are
expected to be greater than 100 mg/L.
The most sensitive organism is freshwater green algae, especially in soft freshwater. The average
toxicity value (i.e., 96-hour EC50 for growth) is expected to be between 3 and 10 mg/L. The chronic value
(i.e., the concentration that begins to inhibit the growth of algae) is expected to be between 0.3 and 1 mg/L.
At concentrations less than the chronic value, citric acid actually is essential for algae growth. Citric acid
is indirectly toxic to algae through over-chelation of nutrient elements necessary for the growth of algae
(i.e., citric acid chelate calcium, magnesium, and iron ions) and prevents algae from absorbing enough of
these nutrients needed for adequate growth.
In hard water (i.e., hardness equal to or greater than 150 mg/L as calcium carbonate) citric acid is
not as toxic. When citric acid is chelated with calcium its toxicity has been mitigated; it is then exposed to
algae as the calcium salt and can no longer chelate calcium and other nutrient elements that algae need for
growth.
Toxicity of citric acid toward marine algae should be lower than it is for freshwater green algae
because of the much higher hardness of sea water as compared to freshwater.
Citric acid has a low potential to bioconcentrate because it is negatively charged and very water-
soluble. Therefore, food chain transport should be minimal.
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Chapter 3
Hazard Summary
Results for citric acid/sodium citrate (Exhibit 3-2) suggest that it warrants a moderate level of
concern as a hazard to the aquatic environment.
Sodium Carbonate
Sodium Carbonate Health Hazard Summary
The information in this summary is taken from CIR (1987).
If sodium carbonate is taken by mouth, it reacts with acids in the stomach to produce carbon
dioxide, which is released in expired air. Sodium carbonate can be absorbed into the body through the
lungs if it is present in air as a mist, but is not expected to be absorbed through the skin.
It is not known if sodium carbonate is irritating to the mouth or stomach if ingested. Sodium
carbonate has been found to be irritating if inhaled or applied to the skin. Laboratory animals that were
exposed to mists containing high concentrations of sodium carbonate for a short period of time
experienced difficulty in breathing, shortness of breath, wheezing, excessive salivation, swelling of the
abdomen, and sometimes death, due to changes or damage to the lungs and respiratory tract. Human skin
exposures to bar-soap products containing a low concentration of sodium carbonate resulted in weak
irritation but not allergic skin reactions. Application of a high concentration of sodium carbonate to intact
skin did not produce skin irritation in people or laboratory animals, but application of the same
concentration to abraded skin produced moderate skin irritation in people and one animal species, and
tissue destruction in some people. When sodium carbonate was placed into the eyes of laboratory animals.
it produced redness often accompanied by a discharge.
Workers who were repeatedly exposed to moderate concentrations of sodium carbonate dusts in air
experienced severe skin irritation, skin diseases, eye irritation, and upper respiratory irritation. Damage to
the lungs was found in laboratory animals that were repeatedly exposed to low concentrations of sodium
carbonate mists.
Studies in laboratory animals suggest that sodium carbonate does not produce birth defects. There
is no information on whether sodium carbonate interferes with reproduction, produces cancer, produces
effects on the nervous system, or interacts with genetic material in humans or animals.
Sodium Carbonate Environmental Hazard Summary
The environmental hazard summary for sodium carbonate is based on the SAR method described
above and in Appendix B. Results for sodium carbonate (Exhibit 3-2) suggest that it warrants a moderate
level of concern as a hazard to the aquatic environment.
3-20
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'Chapter 3
Hazard Summarv
REFERENCES
Ahrens, M. 1998. Letter from Marty Ahrens, National Fire Protection Association to Lynne Blake-
Hedges, USEPA. January 12.
ATSDR. 1993: Agency for Toxic Substances and Disease Registry. Toxicological profile for
tetrachloroethylene. USDHHS, Agency for Toxic Substances and Disease Registry, Public Health
Service. Atlanta, GA.
ATSDR. 1995. Agency for Toxic Substances and Disease Registry. Toxicological profile for Stoddard
solvent. USDHHS, Agency for Toxic Substances and Disease Registry, Public Health Service
Atlanta, GA.
CCRIS. 1995. Chemical Carcinogenesis Research Information System. Built and maintained by the
National Cancer Institute; reviewed by expert consultants and qualified contractors.
CIR. 1983. Cosmetic Ingredient Review Expert Panel. Final report on the safety assessment of Sodium
Laureth Sulfate and Ammonium Laureth Sulfate. J Am Coll Toxicol 2(5): 1-34
CIR. 1984. Cosmetic Ingredient Review Expert Panel. Final report on the safety assessment of
Polysorbates 20, 21, 40, 60, 61, 65, 80, 81, and 85. J Am Coll Toxicol 3(5): 1-82.
CIR. 1986a. Cosmetic Ingredient Review Expert Panel. Final report on the safety assessment of
hydroxyethylcellulose, hydroxyproplycellulose, methylcellulose, hydroxypropiymethylcellulose,
and cellulose gum. J Am Coll Toxicol 5(3): 1-59. 1994.
CIR. 1986b. Cosmetic Ingredient Review Expert Panel. Final report on the safety assessment of
lauramide DEA, linoleamide DEA, and oleamide DEA. J Am Coll Toxicol 5(5):415-454.
CIR. 1987. Cosmetic Ingredient Review Expert Panel. Final report on the safety assessment of Sodium
Sesquicarbonate, Sodium Bicarbonate, and Sodium Carbonate. J Am Coll Toxicol 6(1):121-138.
CIR. 1991. Cosmetic Ingredient Review Expert Panel. Final report on the safety assessment of
cocamidopropyl betaine. J Am Coll Toxicol 10(l):33-52.
Clements, R.G., J.V. Nabholz, D.W. Johnson, and M. Zeeman. 1993. The use of quantitative structure-
activity relationships (QSARs) as screening tools in environmental assessment. Environmental
Toxicology and Risk Assessment. 2nd Volume. ASTM STP 1216. J.W. Gorsuch, J.F. Dwyer,
C.G. Ingersoll, and T.W. La Point, Eds. American Society for Testing and Materials
Philadelphia, PA. pp. 555-570.
HSDB. 1994. Hazardous Substance Data Bank. Developed and maintained by the National Library of
Medicine, Washington, DC.
3-21
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Chapter 3
Hazard Summary
IARC 1995. International Agency for Research on Cancer. IARC Monographs on the Evaluation of
' Carcinogenic Risks to Humans, Vol. 63, Dry Cleaning, Some Chlorinated Solvents and Other
Industrial Chemicals. Tetrachloroethylene, pp. 159-221. Lyon, France.
Leo A and D. Weininger. 1985. CLOGPvers 3.3: Estimation of the n-octanol water partition
'coefficient for organics in the TSCA inventory. Pomona College. Claremont, CA.
Nabholz, J.V. 1991. Environmental hazard and risk assessment under the United States Toxic Substances
Control Act. The Science of the Total Environment. Vol. 109/110, pp. 649-665.
Nabholz JV P Miller, and M. Zeeman. 1993. Environmental risk assessment of new chemicals under
the Toxic Substances Control Act (TSCA) Section Five. Environmental Toxicology and Risk
Assessment. ASTM STP 1179. W.G. Landis, J.S. Hughes, and M.A. Lewis, Eds. American
Society for Testing and Materials. Philadelphia, PA. pp. 40-55.
SIAR. 1996. SIDS Initial Assessment Report. SIAR for the 5th SIAM. Tetrachloroethylene. Sponsor
country: United Kingdom. Available at EPA docket.
Soap and Detergent Association. 1998. http://www.sdahq.org.
USEPA 1984 US Environmental Protection Agency. Estimating concern levels for concentrations of
chemical substances in the environment. USEPA, Office of Pollution Prevention and Toxics,
Health and Environmental Review Division (7403), Environmental Effects Branch. Washington,
DC.
USEPA 1985 US Environmental Protection Agency. Health assessment document for
'tetrachloroethylene (perchloroethylene). EPA/600/8-82/005F. NTIS PB 85-249704/AS. USEPA
Office of Health and Environmental Assessment. Washington, DC.
USEPA. 1994. U.S. Environmental Protection Agency. AQUIRE (Aquatic toxicity information retrieval
database). USEPA, Office of Research and Development, Environmental Res. Labs., Scientific
Outreach Program. Duluth, MN.
Waters TR V. Putz-Anderson, and A. Garg. 1994. The applications manual for the revised NIOSH
' lifting equation. NIOSH Pub. 94-110. NTIS PB-94-176930.
WHO. 1996. World Health Organization. Environmental Health Criteria Document 187: White Spirit
(Stoddard Solvent). IPCS. WHO, Geneva, Switzerland.
Zeeman, M.G., and J. Gilford. 1993. Ecological hazard evaluation and risk assessment under EPA's
Toxic Substances Control Act (TSCA): An introduction. Environmental Toxicology and Risk
Assessment. ASTM STP 1179. W.G. Landis, J.S. Hughes, and M.A. Lewis, Eds. American
Society for Testing and Materials. Philadelphia, PA. pp. 7-21.
3-22
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CHAPTER 4
RELEASE AND EXPOSURE
4.1
4.2
4.3
4.4
CHAPTER CONTENTS
Introduction
Environmental Release Assessments
Exposure Overview
Exposure Assessments
This chapter addresses the releases to the
environment and human and environmental
exposures to chemicals that may result from dry
and machine wetcleaning operations. Section 4.1
contains an introduction to the chapter. Section
4.2 contains information on environmental
releases of chemicals used in various fabricare
processes. In this section, potential releases to
air, water, and for off-site recovery or disposal
are discussed for each applicable chemical. These estimates are used as inputs for general population
exposure estimation where monitoring data do not exist. Section 4.3 provides an overview of exposure
assessment principles, including definitions of the types of estimated exposures. Section 4.4 examines
potential exposures. Both worker exposure and general population (non-worker) exposure are assessed.
Both dermal (skin) and inhalation exposure are assessed for workers, when applicable. Inhalation,
ingestion, and dermal exposure are presented where applicable for the general population. Additionally,
surface water concentration estimates are made, when possible, to support assessment of risks to aquatic
organisms. The methodologies and models used for estimating releases and exposures are described along
with the associated assumptions and uncertainties. Additional information related to this chapter is
provided in Appendix E.
4.1 INTRODUCTION
For the assessments of economics of the processes and risks to the chemicals used in commercial
clothes cleaning, this chapter characterizes releases of and exposures to chemicals used in the clothes
cleaning processes covered by the CTSA. Section 2.4 discussed which chemicals this Cleaner
Technologies Substitutes Assessment (CTSA) examines for each of the processes. Releases occur when
chemicals are no longer contained within the process and are no longer under the control of the facility
using those chemicals. The assessment of releases is the estimation of magnitude, frequency, and media
(e.g., to air, to water, in solid waste for off-site disposal to landfill, incineration, or recovery processes) of
releases. Exposure is defined by USEPA.as the contact of a chemical with the outer boundary of a person.
The assessment of exposure is the estimation of the magnitude, frequency, duration, and route of exposure.
The exposure assessment describes who contacts the chemicals used in the various cleaning processes and
thus who may experience the effects related to the chemicals.
4.2 ENVIRONMENTAL RELEASE ASSESSMENTS
In this CTSA, chemical release estimates serve two primary purposes. Some release estimates are
used as inputs for estimating general population and environmental exposures, and process economics
when other data are not available. Release estimates may also be used for rough comparisons between
different fabricare processes. A summary of environmental release issues and comparisons is located in the
Executive Summary.
4-1
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Chapter 4
Release and Exposure
Chemical release is essentially equivalent to chemical consumption, and the cleaning facility must
pay a cost to replace a chemical which is released. Some releases also result ™*'°^m^^™™
to dispose a waste stream. Releases may also have regulatory implications for facilities. Chemica releases
to the environment can result in exposures to humans and other living organisms. The media of release
determines how the exposures may occur.
Release of a chemical to air can result in exposure to workers who may inhale workplace air
containing the chemical, to the general population who may inhale air containing the chemical, and to the
environment, where animals and plants may also be exposed to the chemical. Releases to water can result
in exposure to the general population who may drink, bathe, and/or shower in water containing the
chemical or eat aquatic organisms containing the chemical released, and to the aquatic environment, where
aquatic animals and plants may be exposed to the chemical. Releases to non-hazardous landfills can each
to groundwater, resulting in exposure to the general population who may drink bathe, and/or shower m
water containing the chemical or eat aquatic organisms containing the chemical released, and to the aquatic
environment, where aquatic animals and plants may be exposed to the chemical. Releases to licensed
hazardous waste landfills are assumed to result in no significant human or environmental exposure Some
factors that affect the transport of a released chemical to those exposed are discussed in more detail in the
exposure section of this chapter.
To allow for comparison of processes on an equal basis, all release estimates were based on a
CTSA "model facility" annual throughput of 53,333 pounds of clothes cleaned. Each model facility was
also assumed to clean 100% of the clothes using a single process. Model facilities are all assumed to
operate for 312 days per year. Each release estimate in this report is an "if-then" estimate which is an
estimate of release that is determined by postulating a release scenario with specific hypothetical or actual
combinations of factors. "If-then" estimates are used when actual release data and distributions cannot be
determined, and these estimates do not give information about how likely the release estimates are to be
representative of actual releases from "real world" facilities.
Various sources were used to gather data needed to generate release estimates. The most recent
sources found were used, although recent research and data could not be found for some important
parameters used to estimate releases. Published emission rates and emission factors, which are often
estimated as amount released per amount of articles cleaned, were used to estimate env,ronmental releases
of solvents from drycleaning facilities. Where such data were unavailable, estimates were calculated from
release-related data or assumptions. For example, releases of solvents to water were estimated using
estimated amounts of water released from facilities and estimated solubilities of solvents.
Two primary references used to estimate perchloroethylene processes' emissions were the
California EPA's Air Resources Board (CARB) Staff Report (CEPA, 1993) and USEPA's PCE
DrycleanSng NESHAP Background Document (USEPA, 1991). Most of the data for hydrocarbon
processes' release estimates were found in USEPA's document on Control of Volatile Organic Compound
Emissions from Large Petroleum Drycleaners (USEPA, 1982). Estimates of releases of cleaning and
processing aid formulations used in aqueous-based processes were based on estimated formulations use
rates and the simplifying assumption that all of the formulations are released with waste water. Specific
information and details regarding release estimates are provided in the Release Assessment sect.on for each
process.
4-2
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Chapter 4
Release and Exposure
4.2.1 Drycleaning Technologies
-•'-• • PCE Process Release Assessment
Release Sources and Media
Drycleaners can release perchloroethylene (PCE) to the air, as both vented and fugitive emissions,
and to water, mainly as separator wastewater. PCE is also disposed from drycleaners in solid wastes such'
as distillation still bottoms and used cartridge filters. Numerous factors affect the amounts of these
releases from individual facilities. These factors include, but are not limited to, equipment differences,
such as cleaning machine type, capacity, vapor recovery device(s), operating temperatures, separator size,
filter type, number of cleaning machines, and still type; differences in operating conditions, such as
number of articles cleaned per load, level of soil in articles cleaned, number of loads per day, drying time,
and residence time in water separator; and differences in maintenance and general housekeeping.
Vented air emissions include exhausts from the aeration step of the drying process, from still and
muck cooker condensers, and from inductive door fans that vent the cylinder when a machine's door is
open. Fugitive air emissions result from vapor escaping from the open door of a machine, leaking
equipment, off-gassing of residual in clothes after drying, evaporative losses during article transfer, button
trap cleaning, filter changes, and when containers with liquid PCE such as waterproofing "third" tanks and
storage drums are open to the workplace. Additional emissions may also come from carbon adsorber (CA)
exhausts, particularly if the adsorber is not properly maintained, and from the evaporation of wastewater
from the water separator.
PCE-containing wastewater from drycleaning collects in the water separator. The sources of this
wastewater are condensate from the direct contact steam desorption of CAs, still and muck cooker
condensate, condensate from the machine's conventional or refrigerated condenser, and condensate from
steam presses. Following separation from PCE, these wastewaters are generally discharged to sewers and
may leak to groundwater before reaching a Publicly Owned Treatment Works (POTW) for treatment
(Wolf, 1992). A California well contamination study indicates that historical practices of drycleaners have
caused groundwater contamination, but that the effect of current practices cannot be determined (Radian,
Additionally, PCE is released indirectly, from drycleaners in solid wastes removed from the
drycleaning facility. These PCE-containing solid wastes include spent filter cartridges, distillation bottoms
or muck, and, spent carbon. These solid wastes are defined as a hazardous waste under the Resource
Conservation and Recovery Act (RCRA), and facilities generating more than 220 pounds per month of
such waste are required to dispose of such waste through RCRA-approved waste handlers. Some facilities
also dispose of separator water as hazardous waste.
Release Estimates
Because other sources of exposure information are available, release estimates from PCE
drycleaning facilities are not needed for this CTSA's general population and environmental exposure
assessments. Because PCE technologies are the dominant method for commercial clothes cleaning,
releases of PCE from drycleaning facilities have been estimated for the purpose of illustrating potential
4-3
-------
Release and Exposure
differences in releases from PCE machines of a given capacity using different controls (i.e., refrigerated
condensers [RCs] and carbon adsorbers [CAs]) for reducing emissions. Another emission control ,s an
azeotropic unit (AU), which is discussed in Chapter 2; however, because AUs are not commonly used
releases from AUs are not assessed in this CTSA. It may be noted that these AUs may be less efficient
than CAs (i e. AUs do not lower emissions as effectively as CAs), but when used in conjunction with
CAs, the combination are more effective than a CA alone (i.e., CA/AU combination results ,n h.gher
emission reduction than CAs alone).
As mentioned previously in this chapter, release amounts of PCE and PCE-containing wastes were
estimated and spotting chemical releases and detergents used in PCE processes were not estimated. PCE
release estimates in this section are based on data from several sources, primarily USEPA sources (e.g.,
NESHAP documents) and the CARB Staff Report (CEPA, 1993). These data are combined with some
assumptions to generate the release estimates. The machines assessed here are erther transfer or dry-to-dry
machines with or without CAs or RCs. Estimates of releases are made for eight PCE machine
configurations utilizing emission control technologies in different combinations. These configurations are
described below.
PCE-A1: Transfer with No Carbon Adsorption or Refrigerated Condenser: Washing
and extraction in one machine, drying in a second machine (i.e., first generation
equipment). At the end of the drying cycle, aeration air leaving the drying tumbler vents
to atmosphere.
PCE-A2 • Transfer with Carbon Adsorber Vent Control: Washing and extraction in one
machine, drying in a second machine (i.e., first generation equipment). At the end of the
drying cycle, aeration air leaving the drying tumbler vents to a carbon bed, which may
remove much of the PCE before emitting the air stream.
PCE-A3 • Transfer with Refrigerated Condenser Control: Washing and extraction in one
machine, drying in a second machine (i.e., first generation equipment). By the end of the
drying cycle the refrigerated condenser will have removed more of the PCE from the
drying air stream, resulting in lower emissions than would occur from a machine with a
non-refrigerated condenser.
PCE-B1 • Dry-to-Dry with No Carbon Adsorption or Refrigerated Condenser: Washing,
extraction and drying operations all in one cylinder/one machine (i.e., second generation
equipment). At the end of the drying cycle, aeration air vents to atmosphere after leaving
the tumbler.
PCE-B2- Dry-to-Dry with Carbon Adsorber Vent Control: Washing, extraction, and
drying operations all in one cylinder/one machine (i.e., second generation equipment). At
the end of the drying cycle, aeration air leaving the tumbler vents to a carbon bed, which
may remove much of the PCE before emitting the air stream.
PCE-B3 • Dry-to-Dry Converted to Closed-Loop: Washing, extraction, and drying
operations all in one cylinder/one machine (i.e., second generation equipment converted to
third generation). Two common conversions are an internal conversion or an add-on.
4-4
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Chapter 4
Release and Exposure
Internal conversion includes converting the internal condenser from air- or water-cooled
condenser to a refrigerated condenser and ducting the exhaust back to the machine as
input air. The add-on includes ducting the vent to an add-on refrigerated condenser,
which supplements the original condenser, and ducting the exhaust from the condenser
back to the machine as input air.
• PCE-C: Dry-to-Dry Closed-Loop -with No Carbon Adsorber or -with Door Fan and Small
Carbon Adsorber: Washing, extraction, and drying operations all in one cylinder/one
machine. Built-in internal refrigerated condenser that exhausts drying air back to the
machine as input air in a "closed-loop" cycle (i.e., third generation equipment). On some
machines, when the machine door is opened after the drying cycle ends, a fan draws air
through the open door into the machine, and the air is exhausted elsewhere, sometimes to
a small carbon adsorber. These small adsorbers, sometimes known as "OSHA fans," are
not believed to have much effect on emissions.
• PCE-D: Dry-to-Dry Closed-Loop with Unvented Integral Secondary Carbon Adsorber
Control: Washing, extraction, and drying operations all in one cylinder/one machine.
Built-in internal refrigerated condenser that exhausts back to the machine as input air.
After the drying cycle ends while the door is closed, air from the drum circulates to a large
CA (50-pound or greater carbon capacity), which may remove most of the PCE before the
door is opened (i.e., fourth generation equipment). Some machines may have an integral
PCE sensor that will not allow the door to be opened until an allowable PCE level is
reached (i.e., fifth generation machine).
Exhibit 4-1 presents estimates of air, water, and hazardous waste releases that may result from
each of the eight PCE technologies evaluated. Assumptions and data used are noted in the footnotes to the
exhibit.
There are numerous uncertainties regarding the estimates in Exhibit 4-1, several of which are
identified here. There are uncertainties in the accuracy of the numerous assumptions and parameters used
to generate release estimates. The accuracy of some data gathered for the NESHAP is uncertain, and it is
not known whether data from the CARB survey of California facilities represents facilities nationally. The
assumptions used by the CARB to estimate emissions are unknown. The CARB Staff Report presents
average emissions estimates collected prior to the PCE drycleaning NESHAP, and the NESHAP has likely
decreased average emissions following its promulgation. There are also many variables that may affect
releases from a facility or that account for differences among facilities, and some of these variables are
listed at the beginning of this section. There is limited information on the extent to which these variables
contribute to differences among facilities. Exhibit 4-1 shows that machine type can affect releases
significantly. Operating practices can also increase or decrease emissions by up to a factor of four between
facilities with a particular machine configuration (CEPA, 1993). Also, because the releases estimated in
Exhibit 4-1 are intended to reflect relative averages and do not account for many site-specific factors,
releases from a specific facility in the real world may not compare well with the estimates.
Data on mileages of the various machine configurations relative to mileages that may be calculated
from the release estimates in Exhibit 4-1 indicate that many facilities with the same throughput as the
4-5
-------
Release and Exposure
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RC = refrigerated condenser; CA = carbon adsorber; see text 1
' Based on Table 4 of CEPA 1993 (see Exhibit E-1 in Appendi
machines. Total air emissions are the sum of vented emissior
fugitive emissions, and for dry-to-dry machines with no CA or I
95% for CA. The difference in emissions between transfer wit
converted to closed-loop. Average "model" and California faci
scaled proportionally from California throughput to "model" fac
b Based on 1 50 gal/year for RCs (USEPA, 1997 a) and 1 ,500 g
also, based on 150 ppm PCE average in wastewater and 3.78
c Based on the International Fabricare Institute estimate of 3.2
CA waste, as applicable, of less than 10 Ib PCE annually, bas
and a carbon change out frequency of 5 years for CAs used v,
PCE by weight (based on Safety Kleen, 1986, and PEI, 1985)
" CEPA 1993 estimates that secondary control reduces emiss
secondary control is 96.5% removal; emissions from drum is '
4-6
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Chapter 4
Release and Exposure
"model" facility may have lower releases than those shown in Exhibit 4-1, indicating inaccuracies in data
and assumptions used for Exhibit 4-1 estimates. However, no better data sources or bases for assumptions
could be found, nor did peer review of an earlier draft of this CTSA document identify additional
improvements to these release estimates. Despite these uncertainties, Exhibit 4-1 is expected to fairly
accurately reflect relative differences in releases between the configurations.
Hydrocarbon Processes Release Assessment
Release Sources and Media
Drycleaners can release hydrocarbons (HC) to the air, as both vented and fugitive emissions, and
to water, mainly in separator wastewater. HC is also disposed from drycleaners in solid wastes such as
distillation still bottoms and used cartridge filters. Numerous factors affect the amounts of these releases
from individual facilities. These factors include, but are not limited to, equipment differences, such as
cleaning machine type, capacity, vapor recovery device(s), operating temperatures, separator size, filter
type, number of cleaning machines, and still type; differences in operating conditions, such as number of
articles cleaned per load, level of soil in articles cleaned, number of loads per day, drying time, and
residence time in water separator; and differences in maintenance and general housekeeping.
Vented air emissions include exhausts from the drying process, from still condensers, and from
inductive door fans that vent the cylinder when a machine's door is open. Fugitive air emissions result
from vapor escaping from the open door of a machine, leaking equipment, off-gassing of residual in
clothes after drying, evaporative losses during article transfer, button trap cleaning, filter changes, and
when containers with liquid HC tanks and storage drums are open to the workplace.
HC-containing wastewater from drycleaning comes from three main sources. First, some water
may be added to articles in the cleaning process to remove water-soluble soils. Second, water is used in
the distillation and reclamation process. Finally, air pollution control processes can create wastewater,
including condensate from refrigerated condensers. These waters are generally discharged to sewers and
may leak to groundwater before reaching a POTW for treatment (Wolf, 1992). The California well
contamination study of PCE drycleaners indicates that historical practices of drycleaners have caused
groundwater contamination by solvents, but the effect of current practices cannot be determined (Radian
1993).
Additionally, HC is released indirectly from drycleaners in solid wastes removed from the
drycleaning facility. These HC-containing solid wastes include spent filter cartridges and distillation
bottoms or muck. Some of these solid wastes are defined as a hazardous waste under the Resource
Conservation and Recovery Act (RCRA). Section 8.4.5 discusses the criteria for determining whether HC-
containing solid wastes are hazardous. Facilities generating more than 220 pounds per month of hazardous
waste are required to dispose of such waste through RCRA-approved waste handlers. Some facilities also
dispose of separator water as hazardous waste.
Release Estimates
Because other sources of exposure information are not available, release estimates from HC
drycleaning facilities are used for this CTSA's general population and environmental exposure
4-7
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Chapter 4
Release and Exposure
assessments. Because HC technologies are the second dominant method, after PCE, for commercial
clothes cleaning, releases of HC from drycleaning facilities have been estimated for the sole purpose of
illustrating potential differences in releases from HC machines of a given capacity using different controls
(i.e., RCs and dry-to-dry type machines) for reducing emissions.
As mentioned previously in this CTSA, release amounts of HC and HC-containing wastes were
estimated, and sporting chemical releases and detergents used in HC processes were not estimated (see
Section 1.2). Very little information is available to determine solvent releases to the various media (e.g.,
air water^ landfill, incineration). HC release estimates in this section are based on data from several
sources, primarily one USEPA source, a 1982 Control Guideline document, which documented studies on
large petroleum drycleaning facilities. No newer emissions and release factor data could be located. These
data are combined with some assumptions, including analogy to PCE machines, to generate the release
estimates. The machines assessed here are either transfer and dry-to-dry machines with or without RCs.
For more details regarding these "model" machines, see Chapter 7. Estimates of releases are made for
three HC machine configurations utilizing emission control technologies in different combinations. These
configurations are described below.
HC-A1: Transfer with Standard Dryer (with No Condenser}: Washing and extraction in
one machine, drying in a second machine. Throughout the entire drying cycle, fresh air is
drawn into the tumbler, removes HC from the wet clothes, and exits the drying tumbler
directly to atmosphere. (All HC that is not extracted from the clothes is emitted to air.)
• HC-A2: Transfer with Recovery Dryer (with Condenser): Washing and extraction in one
machine, drying in a second machine. During the drying cycle, drying air leaving the
tumbler passes through a condenser. The condenser cools the air and recovers some of the
HC from the drying air stream, which is reheated and returned to the tumbler. At the end
of the drying cycle, aeration air vents to atmosphere after leaving the tumbler.
HC-B: Dry-to-Dry Closed-Loop with Condenser: Washing, extraction, and drying
operations all in one cylinder/one machine (i.e., second generation equipment). During
the drying cycle, drying air leaving the tumbler passes through a condenser. The
condenser cools the air and recovers some of the HC from the drying air stream, which is
reheated and returned to the tumbler. At the end of the drying cycle, aeration air vents to
atmosphere after leaving the tumbler.
Exhibit 4-2 presents estimates of air, water, and hazardous waste releases that may result from
each of the three HC technologies evaluated. Assumptions and data used are noted in the footnotes to the
exhibit.
There are numerous uncertainties regarding the estimates in Exhibit 4-2, several of which are
discussed below. The emissions factors from the primary reference (USEPA, 1982) used to estimate
releases were based on case studies of only a few large petroleum facilities. Those emission factors may
not be representative of smaller facilities, which are expected to generally use solvent less efficiently (i.e.,
lower solvent mileages) than larger facilities. Some data and information used to make assumptions
represent different time periods that may not be representative of current conditions and improved
4-8
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Chapter 4
Release and Exposure
Exhibit 4-2. Estimated Releases from HC Model Facilities with
Various Machine Types and Emission Controls
Machine Type and Control
Technology
Releases
HC Solvent
To Air3, To
(gal/yr) Water"
(gal/yr)
Transfer
w/ Standard dryer - Option HC-A1
w/ Recovery dryer - Option HC-A2
1,839 <10-5
678 1fJ5
In Solid
Waste0
(gal/yr)
Total Volume
Total
HC
Loss
(gal/yr)
320
320
2,159
998
Total
Waste
Water
Volume13
(gal/yr)
415
829
Total
Solid
Waste
Volume0
(gal/yr)
1,415
1,415
Dry-to-Dry
Closed-loop w/ condenser -
Option HC-B
194 ID'5
320
514
829
1,415
a Based on emission factors in USEPA, 1982. Total air emissions are the sum of vented emissions and
fugitive emissions. The CTSA's "model facility" throughput of 53,333 Ib/year clothes was used to
estimate these releases. Emission factors from USEPA 1982 and other assumptions are shown in
Appendix E. Air release from dry-to-dry closed-loop is based on air release from transfer with recovery
dryer multiplied by the ratio of PCE dry-to-dry closed-loop to PCE transfer with refrigerated condenser.
b Based on 3.4 Ib water recovered per 100 Ib clothes for a system with a recovery dryer, and same
recovery assumed for dry-to-dry; HC losses based on 0.036 ppm HC average in wastewater, 3.78
kg/gal water and 3.0 kg/gal HC, and 10% of total water volume recovered from a system with no
condenser relative to recovery from a system with a condenser.
0 Based on emission factors in USEPA, 1982. Total solid waste loss includes spent cartridge filters and
vacuum still bottoms. Hazardous waste is assumed to average 40% HC by weight (USEPA, 1982) and
to average 1.71 kg/gal (assuming that non-HC portion has a density of diatomaceous earth, 0.834
kg/gal).
technology. Operating practices can also increase or decrease emissions by up to a factor of four between
facilities with a particular machine configuration (CEPA, 1993). Also, because the releases estimated in
Exhibit 4-2 are intended to reflect averages and do not account for many site-specific factors, releases from
a specific facility in the real world may not compare well with the estimates. Both the method of
calculating HC fugitive emissions (see Appendix E) and the use of emission ratios from PCE machines to
estimate HC dry-to-dry air releases introduce additional uncertainties into the release estimates. There is
limited information on the extent to which these variables contribute to differences among facilities.
Data on mileages of the various machine configurations relative to mileages that may be calculated
from the release estimates in Exhibit 4-2 indicate that many facilities with the same throughput as the
"model" facility may have lower releases than those shown in Exhibit 4-2, indicating inaccuracies in data
4-9
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Chapter 4
Release and Exposure
and assumptions used for Exhibit 4-2 estimates. However, no better data sources or bases for assumptions
could be found, nor did peer review of an earlier draft of this CTSA document identify additional
improvements to these release estimates. Despite these uncertainties, Exhibit 4-2 is expected to fairly,
accurately reflect relative differences in releases between the configurations.
4.2.2 Machine Wetcleaning Release Assessment
Release Sources and Media
Clothes cleaners using the machine wetcleaning (MWC) process are expected to release various
MWC formulations such as detergents, finishes, water softeners, and other cleaning and processing aids,
primarily to water during wash and rinse cycles of the machines. Of these MWC formulations, only
detergents have been assessed in this CTSA as discussed in section 2.4. However, non-detergent
formulations may have more of an environmental impact from MWC than from drycleaning processes due
to the potential releases of these formulations to water.
Most chemical constituents in the various MWC formulations are likely to be non-volatile and
would remain in solution throughout the MWC process. Releases of chemical constituents such as
fragrances to air are expected to be relatively insignificant. Releases of chemicals from the formulations in
solid wastes, such as emptied formulation bottles and lint from dryers and from water recycling, are also
expected to be relatively small. Releases of MWC formulations are expected to vary between individual
facilities, and these variations may be affected by a number of factors including equipment differences,
such as machine capacity; differences in operating conditions, such as amount of articles cleaned, number
of loads per day, load types, percentages of load capacities, and dosages of MWC formulations; and
differences in cleaning procedures, formulations used and general housekeeping.
Release Estimates
Release estimates from machine wetcleaning (MWC) facilities are needed for this CTSA's
estimation of process costs and assessment of general population and environmental exposures. Compared
to drycleaning machines, MWC machines do not have a variety of machine configurations that affect
releases. Only a few studies of MWC were found in the literature, and from these studies only one primary
variable affecting release quantities could be found. This variable is the percent of clothes cleaned by
immersion in water. This variable was 100 percent in one study and not quantified but stated to be less
than 100 percent in another study. Therefore, detergent releases have been estimated for only two MWC
model facilities.
Because no environmental release data are available for MWC processes, releases have been
estimated based on expected average formulation use rates and simplifying assumptions. For this release
assessment, two studies were found which contained enough information to calculate formulation use rates
for MWC model facilities. "If-then" modeling was used to estimate releases of detergents from the two
model facilities using MWC processes. An estimated 29.5 gallons per year of detergent are estimated to be
released from the model facility which machine washes less than 100 percent of clothes "cleaned." An
estimated 95.4 gallons per year detergent are estimated to be released from the model facility that machine
washes 100 percent of clothes cleaned. It is not known whether these estimated releases are representative
of the potential universe of machine wetcleaning processes.
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Chapter 4
Release and Exposure
The following data and assumptions were used to calculate release estimates from the MWC
model facilities. The MWC model facility machine washing less than 100 percent of clothes used 0.0213
gallons per day detergent for 2.7 loads per day and 100 garments per 7 loads (Environment Canada 1995).
This use rate was scaled up to 53,333 pounds per year clothes assuming 1 pound per garment (Gottlieb et
al., 1997) to estimate the release rate. The MWC model facility machine washing 100 percent of clothes
used 48.8 ounces combined formulations per 100 garments. Spotting agents were 3 ounces of the 48.8
ounces, and the detergent and finish formulations were assumed to be equal volumes of the remaining 45.8
ounces. This use rate was applied to 53,333 pounds per year clothes assuming 1 pound per garment
(Gottlieb et al., 1997) to estimate the release rate.
These MWC model facilities' release estimates assume that all detergent formulations are in the
wastewater released from the wash and rinse cycles, and that insignificant amounts of the formulations
remain on the clothes after rinsing. MWC wastewater from the wash and rinse cycles would normally be
expected to be discharged to a municipal sewer, which route the wastewater to publicly owned treatment
works (POTW). These releases are assumed to occur over 312 days per year, the estimated number of
operating days annually for a CTSA model facility.
Reuse of water is an optional feature that, when used, is typically only done with the final rinse.
Reuse of water is not expected to significantly affect releases of formulations. The formulations used in
MWC processes are either of unknown or proprietary composition. Detergents account for 30-50% of the
total MWC formulations released based on the two studies used to estimate MWC model facilities'
releases. For the purpose of assessing potential risks from wetcleaning processes, the two example
detergent formulations discussed in Section 2.4.2 were assumed to be released in the amounts estimated for
the two MWC model facilities. The releases of individual chemical constituents in those example
detergents are provided in Appendix E, Exhibits E-3 and E-4. It is not known whether these example
detergent constituents or their estimated releases are representative of the potential universe of MWC
processes.
4.3 EXPOSURE OVERVIEW
4.3.1 Background and Definitions
Exposure is defined by USEPA as the contact of a chemical with the skin, nose, or mouth of a
person over a given period of time. This includes the magnitude, duration, and route of exposure. There
are a number of ways in which people and the environment can come into contact with the chemicals used
in clothes cleaning and become subjected to the effects of the chemicals. The populations generally
thought to be exposed include workers and the general population, including specific sub-populations of
co-located residents and children. This assessment is not comprehensive and examines only those
populations and pathways that appear most relevant to the specific technologies or for which appropriate
data and methods were available. Exhibit 4-3 illustrates the exposures covered.
This CTSA assesses two primary routes of worker exposure. Inhalation exposure, or workers
breathing workplace air containing significant concentrations of volatile solvents, is expected to be the
most significant route in drycleaning processes. Dermal exposure, or workers getting solvent and
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Chapter 4
Release and Exposure
detergents on the skin during various work activities, is expected to be the significant route of exposure for
non-volatile chemicals, such as most detergent components. Therefore, this route of exposure is examined
for machine wetcleaning. Dermal exposure is also a route of worker exposure for solvents, thus it is also
assessed for both PCE and HC technologies.
Exhibit 4-3. Pathways Covered in the CTSA
Inhalation:
PCE
Hydrocarbon
Environment:
-PCE
- Hydrocarbon
- Machine Wet Cleaning
Inhalation:
PCE
Hydrocarbon
Ingestiom
PCE
Dermal:
PCE
Hydrocarbon
Machine Wet Cleaning
Dermal:
PCE
Worker
General Population
The general population is exposed to the solvents used in drycleaning technologies and the
detergents used in the aqueous processes in several ways. Studies have measured exposures to individuals
residing in apartment buildings that are co-located with PCE drycleaning facilities. The CTSA provides
information on many exposure scenarios for this group, including inhalation exposures to residents,
exposure to wearers of drycleaned clothing, and exposures to nursing infants. Ingestion of PCE-
contaminated drinking water and dermal exposure during showering are also discussed.
PCE and HC exposures among members of the general population who do not live in co-located
residences are also assessed for the inhalation pathway. Dermal exposure to the detergents from machine
wetcleaning has been assessed for the general population; however, no other exposures related to the other
aqueous-based technologies have been examined.
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Chapter 4
Release and Exposure
In assessing exposures, the specific effects of a chemical, such as acute (short-term) effects or
chronic (long-term) effects, determine what period(s) of exposure were considered. For long-term effects,
such as carcinogenicity, it is often more helpful to have a central tendency of exposures, since the effect is
typically estimated from the cumulative exposure.
In this document, exposures are expressed as exposure concentrations, potential doses, or potential
dose rates. In order to simplify the presentations of exposures for each technology, both the expression of
exposure and the units of measure are those most commonly presented for the chemical in studies and
reports documenting exposure data in the literature. Some descriptions of the methods and assumptions
used to calculate these exposure expressions, as well as sample calculations, are contained in Appendix E.
Inhalation exposures are usually expressed as exposure concentrations in units of parts per million
(ppm) or milligrams per cubic meter (mg/m3). Potential dose is the amount of the chemical substance
available for inhalation, ingestion, or dermal absorption. These estimates are referred to as Lifetime
Average Daily Concentrations (LADCs). These exposures incorporate the measured concentration of the
chemical in air in mg/m3 and the estimated exposure duration. LADCs, which are averaged over a
lifetime, are used to assess the risks of cancer. For the dermal and ingestion exposure routes, potential
dose rates (PDRs) are presented. PDRs are the amounts of chemical either applied to the skin or ingested.
PDR units of measurement are mass per unit of time (and sometimes, per body weight as well) and are
often presented as mg/day or mg/kg/day. Occupational dermal PDRs are presented in mg/day, and general
population dermal and ingestion exposures are presented in mg/kg/day.
4.3.2 Exposure Descriptors
USEPA has published Guidelines for Exposure Assessment in the Federal Register (USEPA,
1992c). These guidelines provide the basic terminology and principles by which the Agency conducts
exposure assessments. The guidelines indicate that exposure descriptors describe or characterize
numerical expressions of exposure that can be made for a given population of concern. The guidelines
suggest that if the exposure assessment methodology allows an assessor in some way to quantify the
spectrum of exposure, the assessor should estimate central tendency exposures, as well as high-end or
bounding exposures.
Central tendency exposures are average or median estimates of exposure to a particular
substance. High-end exposures are exposures that are higher than those received by 90% of the people
who are exposed to the substance. Central tendency and high-end estimates are presented together when
possible to show the variability of the estimated exposures. Bounding exposures are exposure estimates
that, in the assessor's judgement, are higher than those incurred by the person in the population with the
highest exposure. Each of these exposure descriptors is used for at least one exposure scenario in the
CTSA, although estimates with some of each of these descriptors are often unavailable for many scenarios
in this CTSA.
In many cases, however, it is possible to calculate only an estimate of what the exposure would be
under a given set of circumstances, without a characterization of the probability of those circumstances.
These estimates are called "what-if' estimates, and they do not try to judge where on the exposure
distribution the estimate actually falls. Where insufficient information is available to provide central
tendency, high-end, or bounding estimates of exposure, what-if estimates are provided.
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Chapter 4
Release and Exposure
4.3.3 Exposure Comparisons
Comparing exposure data for different populations and for different studies entails more than
simple numeric comparisons. Different populations may have different exposure factors that have impacts
on their risks. These exposure factors may include, but are not limited to, volumes of air inhaled, durations
and frequencies of exposure, and body weights. It may be more appropriate to compare risks when they
can be calculated, rather than exposures, since some of these factors are included in risk. Also, different
studies of similar populations may have different collection methods, purposes, or sources of bias that may
cause their data sets to be incomparable. Finally, comparing measured exposure data to modeled exposure
estimates must be considered very carefully.
4.4 EXPOSURE ASSESSMENTS
4.4.1 Dry-cleaning Technologies: Perchloroethylene Processes
People are exposed to PCE primarily as a result of PCE releases to the air, water, and land
following commercial drycleaning. Workers are exposed to PCE solvent both from inhalation and dermal
exposure. The non-worker population is exposed to PCE from inhalation, ingestion, and dermal contact.
Inhalation is the most significant route of exposure for several reasons. PCE has a relatively high vapor
pressure and therefore volatilizes readily (see Appendix A). This sometimes leads to elevated
concentrations in both indoor and outdoor air, especially in locations close to drycleaners. Inhalation is
also a physiologically significant means of exposure because PCE is well absorbed from the lungs.
Oral exposure to PCE may occur from ingestion of contaminated drinking water, contaminated
foods (not evaluated here), or from ingestion by infants of breast milk from PCE-exposed mothers. PCE is
well absorbed from the gastrointestinal tract following ingestion. Metabolism of absorbed PCE is expected
to be low, roughly 20% (USEPA, 1985).
Absorption of PCE through the skin appears to vary depending upon the type of dermal exposure
(i.e., in water, as a vapor, or as a liquid). For the general population, one important means of dermal
exposure is from showering in water containing PCE. An exposure scenario is presented for dermal
contact during showering.
Occupational Exposures
This section examines issues regarding PCE exposures to the workers in the drycleaning industry.
Data sources include those that are readily available in published literature or through on-line access.
Some regulatory and recommended limits have been established for worker exposure to PCE. In
January 1989, the U.S. Occupational Safety and Health Administration (OSHA) adopted a 25 ppm (170
mg/m3) time weighted average (TWA) permissible exposure limit (PEL) to replace the pre-1989 PEL of
100 ppm (680 mg/m3) TWA. However, all new 1989 PELs were vacated via a court decision, and the pre-
1989 PEL for PCE is currently in effect. In addition to the PEL, OSHA requires a ceiling limit of 200 ppm
(five minute average in any three hours) and a maximum peak of 300 ppm (never to be exceeded during
the workday). Some states may maintain the 1989 PEL or other levels as state regulatory limits. Section
8.6 presents more details on OSHA requirements.
47J4
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Chapter 4
Release and Exposure
The American Conference of Government Industrial Hygienists (ACGIH) sets its Threshold Limit
Value (TLV) for PCE at 25 ppm (170 mg/m3)(ACGIH, 1994). The National Institute for Occupational
Safety and Health (NIOSH) Recommended Exposure Limit (REL) is the lowest feasible level. NIOSH
recognizes PCE as a potential carcinogen and lists the level of quantification as 0.4 ppm (3 mg/m3).
NIOSH also has established 150 ppm as a concentration immediately dangerous to life and health
(IDLH)(NIOSH, 1991 a).
: The National Occupational Exposure Survey (NOES) estimates that 61,724 workers may have
potential for exposure at 6,924 sites using PCE for all industries in the Standard Industrial Classification
(SIC) Code 72 (NIOSH, 1982). Commercial drycleaners are included as one of many industries in SIC 72.
Other information gathered for this CTSA indicate that NOES estimates of numbers of workers and sites
are underestimates.
For this CTSA, it has been estimated that there are 30,600 commercial facilities that dryclean
clothes in PCE (excluding drop-off/ pick-up sites) in the United States. NIOSH recently published a study
of commercial drycleaners which included data on numbers of workers and sites (American Business
Information, 1994). These BA data include drop-off/ pick-up sites that do no cleaning and include all
process types (PCE, hydrocarbon, etc.). In order to estimate numbers of workers in PCE dryclean ing
facilities nationwide, the BA data needed to be adjusted, and the BA data and assumptions used to adjust
them are shown in Exhibits E-5 and E-6 of Appendix E.
As a result, it is estimated that 119,000 to 278,000 workers are employed in facilities that dryclean
clothes using PCE in the U.S. The midpoint of this range suggests an average of 6.5 workers per facility.
It is not known how representative these estimates are of the industry due to the uncertainties in the data
and assumptions used to adjust them.
The population of drycleaning workers may be categorized into various job titles, such as operator
or presser, based on worker activities. However, typical activities and exposures may be difficult to
characterize because workers may have rotating responsibilities and overlapping activities, which often
vary from facility to facility. In a previous study, USEPA estimated the number of workers by job
description (PEI, 1985). Based on those estimates, the drycleaning workers may be categorized into the
following job titles with the corresponding percentage of the total drycleaning population: 3.8% managers/
administrators, 18.5% clerks, 9.9% tailors, 15.5% pressers, 48.7% operators, and 3.6% for all others
combined. It is assumed that the job descriptions of "(dry)cleaner" and "operator" are equivalent, and
include those workers who operate the drycleaning washing and drying equipment. For risk assessment in
Chapter 5, it is assumed that the workers may normally be exposed for 8 hours/day and 250 days/year.
Some worker subpopulations (e.g., some owner/operators and workers who work overtime) could be
exposed for up to 312 days/year or more and more than 8 hours/day, although no data were found to
support estimated average numbers of hours/day and days/year.
Occupational Inhalation Exposure
Many studies and data sets are available to characterize inhalation exposures to PCE for
drycleaning workers. The four data sets presented in this section illustrate variations in worker inhalation
exposures due to factors such as jobs, machine types and controls, numbers of machines, and time period
in which monitoring was performed. These data sets consist of OSHA monitoring data, a compilation of
4-15
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Release and Exposure
published data sets, data collected by the International Fabricare Institute, and survey data from a NIOSH
report These data sets include measured TWA exposure concentrations (ECs) of PCE; for risk screen.ng
later in this report, it is assumed that these data are representative of 8-hour (full-shift) TWAs.
The first data set consists of OSHA workplace personal exposure concentrations (ECs) for PCE in
drycleaning from 1991 to 1993 (OCIS, 1994) and 1997 (OCIS, 1998). ECs from these data are
summarized by job title in Exhibit 4-4. Distributions of data for four worker subpopulations (i.e.,
drycleaner, spotter, presser, and manager) were generated from the 1991 to 1993 data; worker
subpopulations were not available for the 1997 data. Other subpopulations could not be distinguished due
to multiple job descriptions for individual workers. Because OSHA often monitors for compliance or ,n
reaction to complaints, ECs generated from OSHA data may be higher than actual ECs for the total
population of workers. Exhibit 4-4 shows the following order of exposures from highest to lowest:
Exhibit 4-4. Summary of TWA ECs Based on OSHA Personal Monitoring for PCE Drycleaning3
Job Description
EC Units
Geometric
Mean EC± SD
Arith. Average
EC + SD
1 990 to 1 993
All Jobs [386]
Cleaner [157]
Spotter6 [37]
Manager [43]
Presser [41]
mg/m3
ppm
mg/m3
ppm
mq/m3
ppm
mg/m3
ppm
mq/m3
ppm
69+62
10+9.2
80+76
12+11
53+77
7.8+11
250±31
38+4.6
37±39
5.4+5.7
280±530
41 ±79
330+630
49±93
180±240
27±35
620±820
91±120
97±130
14±19
19Q7
All Jobs [40]
mg/m3
ppm
42+51
6.2+7.5
190±410
28+60
Maximum
EC
5,000
740
5,000
740
1,100
160
4,300
630
470
69
2,500
360
Source: OCIS (1994) and OCIS (1998).
a Number of measurements [n] are in brackets for each job title. All concentrations are
reported as means and, when applicable, ± standard deviation (SD). For 1990 to 1993,
39 of the 386 measurements (10%) exceed the current OSHA permissible exposure limit
of 100 ppm TWA; for 1997, two of the 40 measurements (5%) exceed the OSHA PEL.
b A majority with the job title "spotter" had the associated job title of "cleaner" (e.g.,
spotter/cleaner).
4-16
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Chapter 4
Release and Exposure
manager, cleaner, spotter, and presser. No information was available to determine why manager exposures
were higher than operator exposures in this data set, although it could be hypothesized that these managers
may perform many of the same activities that operators perform. Data on factors such as machine type and
controls, and numbers of machines were not available. The data show that exposure levels and OSHA
PEL excursions may be dropping over time, although the data were not examined for statistical
significance. This drop over time could be due to regulatory, economic, and other factors.
A second set of data is a compilation of data from several studies and sources on workplace PCE
concentrations in drycleaning facilities (Thompson and Evans, 1993). This compilation presented average
TWA concentrations for two worker subpopulations (operator and non-operator) working in facilities with
either of the two machine types (transfer and dry-to-dry). The ECs presented in Exhibit 4-5 are from three
studies/sources. Like Exhibit 4-4, Exhibit 4-5 shows that operator/cleaners generally have higher
exposures than most non-operators (e.g., pressers, spotters). This exhibit also shows that workers in
facilities with transfer machines may be expected to have higher exposures than workers in facilities with
dry-to-dry machines.
Exhibit 4-5. Central Tendencies of TWA Concentrations of PCE Reported in Some US
Occupational Studies for Drycleaning Workers by Job Type and Machine Type3
Machine Type
Dry-to-Dry
Transfer
TWA PCE Concentrations (n =number of samples) for
Operators
ppm
17
11±12
8±6
48
58±30
22±18
mg/m3
115(n=1301)
73±81 (n=3)
56±38(n=9.)
328- (n= 1027)
396±206 (n=9)
152±123(n=16)
Non-operators
ppm
12
6±3
2±1
26
16±14
5±5
mg/m3
79 (n=497)
39+22 (n=8)
11±10(n=26)
179(n=508)
107±96(n=19)
33±34 (n=20)
Data
Source
Codeb
1
2
3
1
2
3
1 Excerpts of Table 2 from Thompson and Evans, 1993. All concentrations are reported as
arithmetic averages and, when available, ± standard deviation; studies which reported only
geometric mean concentrations or which monitored from other than random sampling are
not included.
b Source Codes: 1=IFI, 1990; 2=Solet, 1990; 3=Toutonghi, 1992.
The third set of data was collected by the International Fabricare Institute (NIOSH, 1997). These
data, presented in Exhibit 4-6, are average worker TWA ECs and are differentiated by machine type and
time period. The data from Exhibit 4-6, which are not referenced in the NIOSH source, appear to be from
the same original IFI source document as the data associated with Data Source Code 1 in Exhibit 4-5. Like
Exhibit 4-5, Exhibit 4-6 shows that workers in facilities with transfer machines may be expected to have
higher exposures than workers in facilities with dry-to-dry machines. Relative to facilities with transfer
machines, facilities with dry-to-dry machines had a higher percentage of samples in Exhibit 4-6 that
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Chapter 4
Release and Exposure
complied with the OSHA PEL for PCE of 100 ppm TWA. Exhibit 4-6 also shows a general decrease in
exposure levels over time. Possible explanations for such decreases over time may include improvements
to machinery and workplace practices brought on by PCE regulations and economics.
Exhibit 4-6. Passive Air Monitoring Results for PCE Drycleaning Workers by Machine Type
Collected by the International Fabricare Institute3
Machine Type
Transfer
Dry-to-Dry
ppm
mg/m3
% > 25 ppmb
%> 100 ppmc
ppm
mg/m3
% > 25 ppmb
% > 1 00 ppm0
Before 1/1/87
55.3
375
76.2%
7.7%
20.5d
139d
24.3%
1.0%
1/1/87 - 9/30/89
46.4
315
59.9%
5.6%
16.1d
109d
18.5%
0.8%
After 10/1/89
42
285
56.8%
7.0%
17.2d
16.9s
16.7f
117d
115s
113'
18.6%e/17.2%f
1.3%e/0.8%f
1 Table is taken in its entirety from N1OSH, 1997. All concentrations are TWA.
b The ACGIH TLV is 25 ppm.
c The OSHA PEL is 100 ppm.
* Denotes standard dry-to-dry with water-cooled condenser and vent at end of dry cycle.
• Denotes dry-to-dry refrigerated with small vent to purge cylinder at end of dry cycle.
' Denotes dry-to-dry refrigerated with no vent.
The fourth set of data was from a recent NIOSH study (NIOSH, 1997). These data, presented in
Exhibit 4-7 are average worker TWA ECs and are differentiated by machine type and control, job tttle,
and number of machines. Like Exhibits 4-4 and 4-5, Exhibit 4-7 shows that operators tend to have higher
exposures than non-operators and that operators in facilities with transfer machines tend to have higher
exposures than workers in facilities with dry-to-dry machines. NIOSH concluded, and Exhib.t 4-7 shows,
that as the number of machines increases, exposure levels also increase. NIOSH determined that closed-
loop machines with integral CA (fifth generation) result in statistically significantly lower worker
exposures than all other machine configurations currently available. Compliance with the OSHA PbL tor
PCE of 100 ppm was 100% for 148 samples taken in the NIOSH surveys.
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Release and Exposure
Exhibit 4-7. TWA ECs for PCE Drycleaning Workers by Machine Type and Control and Job Title
Collected by the National Institute for Occupational Safety and Health8
Machine
Type/Control
Transfer: Dryer
with Refrigerated
Condenser
Dry-to-Dry Closed-
Loop/ Door Fan
exhausted to
Small Carbon
Adsorber
Dry-to-Dry Closed
Loop
Dry-to-Dry Closed
Loop/ Integral
Carbon Adsorber
Number
of
Machines
1
1
2
2
2
Worker Job Title
(n = number of
samples)
Operator (n= 13)
Presser 1
Presser 2
Operator (n=7)
Presser 1
Presser 2
Operator (n=1 5)
Spotter
Operator (n=8)
Presser
Operator (n=1 5)
Presser
TWA PCE
Concentration, in ppm
[in mg/m3]
Arith.
Mean
19.5 [132]
3.8 [26]
3.3 [22]
15.8 [107]
5.0 [34]
2.5 [17]
21. 6 [146]
8.3 [56]
7.8 [53]
0.6 [4]
1.6 [11]
ND [ND]
Geom. Mean
±GSD
16.1±1.7
[109±12]
-
-
14.8±1.7
[100±12]
-
-
19.3±13.1
[131+89]
-
7.0±2.0
[47±14]
-
0.4±1.6
[3±11]
-
SSD
A
-
-
A
-
-
A
-
A
-
B
-
a Taken entirely from NIOSH, 1997. All concentrations are average TWA taken from five
NIOSH surveys. GSD is the geometric standard deviation. The reference did not present
numbers of samples, geometric means, GSDs, and SSDs (see note below) for non-
operators.
ND = Below the detection limit.
Where available, n = number of samples. Total n = 148 for the five NIOSH surveys used
in the reference.
SSD: This Statistically Significant Difference (SSD) column presents letter indicators for
the operator data. The NIOSH reference states that different letters indicate a statistically
significant difference using the least significant difference test (a = 0.05).
4-19
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Ch
4
Release and Exposure
A number of factors make it difficult to associate the NIOSH data in Exhibit 4-8 with the CTSA s
PCE model facilities. The four machine types and controls studied by NIOSH and shown in Exhibit 4-8
correspond to the machine types and controls for four of the eight PCE model facilities stud.ed. However,
only two of the five facilities in the NIOSH study used only one dry cleaning machine, which was the basis
for a model facility. Also, the clothes cleaning throughputs for the facilities in the NIOSH studies were
unknown and the machine sizes of the facilities in the NIOSH study are significantly larger than those of
the CTSA's model facilities. As a result of these factors, the data in Exhibit 4-8 are not associated with
particular model facilities in this CTSA.
This NIOSH study explored a number of factors affecting worker exposures. NIOSH found that
loading and unloading of the machines accounted for over half of the operator's TWA exposures. Another
factor that affected worker exposures at several facilities was the presence of small, inadequately sized (1 -
to 2-pound carbon capacity) and inadequately maintained carbon canisters to which air from the cylinder is
purged at the end of the dry cycle when the machine door is opened. NIOSH estimated that these canisters
should be changed daily in order to be effective, and if steam desorbed, the carbon must be fully dried
before reuse Also at some facilities, the operation of waterproofing dip-tanks was found to result in very
high instantaneous exposures to PCE. NIOSH recommended that, ideally, this type of waterproofing be
eliminated- otherwise, when these dip tanks are operated, adequate local exhaust ventilation, respirators,
and gloves must be used. A detailed examination and discussion of these and other factors affecting
exposure, exposure reduction options, and other worker health and safety issues in commercial drycleanmg
may be found in the NIOSH report (NIOSH, 1997).
The NIOSH study also examined instantaneous and short-term worker exposures to PCE.
Exposures during unloading, transfer, and loading of a transfer machine reached instantaneous levels
between 1,000 ppm and 1,500 ppm, and the highest average exposures of 500 ppm to 600 ppm occurred
during the 1-minute garment transfer from the washer to the reclaimer. Real-time monitoring by NIOSH at
facilities using dry-to-dry machines yielded measurements of 1,500 to 2,000 ppm during machine loading
and unloading of the machines (NIOSH, 1997).
In summary, the following are five primary findings from the four exhibits summarizing worker
inhalation of PCE:
1. Operator/cleaners generally have higher exposures than most non-operators (e.g., pressers,
spotters).
2. There appears to have been a general decreasing trend in exposure levels and PEL
excursions over time.
3. Operators in facilities with transfer machines tend to have higher exposures than workers
in facilities with dry-to-dry machines.
4. As the number of machines increases, exposure levels also increase.
5. Closed-loop machines with integral CA (fifth generation) result in significantly lower
worker exposures than all other machine configurations currently available.
Interpretation and comparison of the data sets summarized in this CTSA raise some uncertainties
related to the data and the studies in which they were collected. It is not known whether the measured
concentrations in these data sets are representative of the distributions of concentrations to which the
populations of drycleaning workers are actually exposed nationwide. The smaller the observed numbers of
4-20
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Chapter 4
Release and Exposure
facilities, workers, and samples, the higher the degree of uncertainty regarding representativeness. Nor is it
known whether the measured TWA concentrations, if not adjusted to represent full-shift (i.e., normally
assumed as 8-hour shifts) values, are representative of full-shift TWA concentrations. Variations in
machinery and plant layout, exposure controls such as ventilation, work practices and procedures, amounts
of clothes cleaned daily, and many other factors affect an individual drycleaning worker's exposure. As a
result, an individual worker's exposure may or may not be well-represented by the data summarized in this
CTSA. The data in these exhibits may only compare qualitatively. Details about the facilities, the worker
activities, the monitoring studies, and other relevant details behind the monitoring data presented in the
exhibits were not available to allow for a detailed understanding and analysis of the ECs in the different
data sets and how they may be quantitatively compared. The sets of data in the exhibits do appear to
support one another generally. For instance, the arithmetic averages of larger data sets for a given
population or subpopulation appear to be within an order of magnitude and often compare closely.
Occupational Dermal Exposure
Drycleaning workers may also experience dermal exposure to PCE. No studies or data were
available that quantify dermal exposures to PCE for drycleaning workers; however, dermal exposures to
PCE can be modeled. Estimates presented here are based upon the Occupational Dermal Exposure Model
of the Office of Pollution Prevention and Toxics (OPPT ODEM; USEPA, 1991a). The model relies on a
two-hand contact or immersion in a liquid without any protective clothing and use of pure PCE. This
model is believed to present bounding estimates of amounts of solvent available for absorption on the skin
surface (see Section 4.3.2). Hence, these estimates are larger than the exposures that workers would be
expected to receive. This model assumes that the surface area for two hands is up to 1,300 cm2. No model
is available to estimate dermal exposures from vapors.
The OPPT ODEM is normally used to estimate potential dose rates (PDRs). However, in this
case, the volatility of PCE makes PDRs relatively.meaningless because most of the PCE that workers get
on their skin would be expected to volatilize before absorption. Also, the absorption rates available for
PCE in the literature are in units of mass per area per time. Therefore, the ODEM was used to estimate the
potential dose available for a given worker activity to demonstrate that a significant quantity of PCE is
available for absorption before the PCE evaporates. Evaporation time is roughly estimated using the
quantity available for absorption into skin and a model that estimates a rate of evaporation from a pool of
liquid with the same area as the estimated skin contact area. This method introduces additional
uncertainties to the assessment, but no better method could be found.
Operators are the primary workers expected to perform activities that result in dermal exposures to
liquid PCE, and these activities are shop and equipment dependent. Some of these activities occur at least
once per day (routine) and others occur on a less frequent basis (non-routine), such as changing cartridge
or rag filters and open-tank waterproofing. Routine activities include, but are not limited to, transferring
wet articles from the washer to the dryer and cleaning the button trap and still (or muck cooker). For the
wet article transfer activity, the OPPT ODEM immersion data were chosen to be applicable for exposure
modeling; for all other activities, the OPPT ODEM contact data were chosen to be applicable for exposure
modeling.
Based on the OPPT ODEM, the estimated dermal potential dose for workers performing wet
article transfer is 18,000 mg PCE available for dermal absorption per transfer. This activity is expected to
-------
Chapter 4
Release and Exposure
take approximately 1 to 2 minutes, and after this activity is completed, most of the PCE on the skin would
be expected to evaporate within 2 minutes as estimated roughly by the method described above. The total
maximum duration of dermal exposure to liquid PCE from transfer of wet clothing would be expected to
average 18 to 24 minutes per day, based on 3 to 4 minutes of total PCE dermal exposure per transfer and
six transfers per day. The estimated dermal potential dose for workers performing other activities is less
than 3,900 mg PCE per event available for dermal absorption, and most of the PCE on the skin from these
contacts would be expected to evaporate in less than one minute. In most shops, PCE liquid can be
contacted during routine and non-routine activities other than wet article transfer, and the duration of
dermal contact with liquid PCE for these activities is estimated to average up to 8 minutes per day (see
Appendix E for details).
Non-Worker Populations
Inhalation Exposure
Releases to air are caused by evaporation of chemicals during the clothes cleaning process.
Activities include removing clothes from the cleaning machine (dry or wet). These vapors are then carried
by and mixed with outside air. The resulting air concentration will depend on weather conditions.
Stagnant conditions will not move vapors away quickly, so local concentrations of the chemical will be
higher than the concentrations farther from the facility. Under windy conditions, the vapors will be carried
away faster, reducing the local concentrations. The number of people exposed at varying distances from
the facility may be larger or smaller depending on urbanization and the distance the vapor travels.
Within the non-worker population, those most highly exposed are persons living in the same
building as a drycleaner that cleans clothes on the premises. This population is referred to as "co-located
residents" and includes children, adults, and the elderly. The next most exposed are persons living in close
proximity to drycleaners, or those who work in buildings very close to drycleaners. Other exposed
populations include people bringing drycleaned clothes home and the families of workers in drycleaning
plants.
Throughout Chapter 4, different estimates of exposure duration are provided for the general
population exposure scenarios. In most cases, exposure to PCE is not expected to occur over an
individual's entire lifetime. For example, apartment residents in buildings that contain drycleaners can be
exposed to elevated levels of PCE. It is assumed that exposed individuals live in their apartments between
about 2.5 and 8 years. This assumption is made based on estimates of average and upper-end apartment
residence times provided in USEPA (1997b).
The exception is exposure to ambient levels of PCE. This exposure is assumed to occur over an
individual's entire lifetime. This assumption is made because PCE has been detected in ambient air at
many different locations (Wallace, 1989). .
4-22
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Chapter 4
Release and Exposure
Exposures Received by Co-located Residents
The results of a number of monitoring studies indicate that the highest concentrations of PCE in
indoor air are found in workplaces and in apartments or condominiums located in the same building as
drycleaners. PCE concentrations in apartments above drycleaners have been measured in New York, San
Francisco, Germany, and the Netherlands (Staub et al., 1992; USEPA, 1992a; BAAQMD, 1993; Fast,
1993; Schreiber et al., 1993; Consumers Union, 1995).
Investigations carried out by the New York State Department of Health in 1989 and 1990 revealed
high concentrations of PCE in apartments above drycleaners (Schreiber et al., 1993). Elevated
concentrations of PCE were found in an apartment in Mahopac, New York; the highest measured
concentration was 197 mg/m3. The drycleaning machine in this building was in very poor condition. This
facility was closed while improvements to the machine were made. Later sampling showed much lower
concentrations (although still elevated over ambient levels). Another investigation showed elevated PCE
concentrations in West Seneca, New York. These results prompted the first of the studies described below
(Schreiber et al., 1993). Expanded descriptions are in Appendix E.
Capital District Survey (Schreiber et al., 1993). The Capital District Survey was
conducted by the New York State Department of Health in the summer of 1990. PCE concentrations were
measured in the six apartments above drycleaners in the Capital District of Albany, New York. These
apartments were located in six different buildings; each building contained one drycleaning machine.
Three of the drycleaning facilities used transfer machines. Two used vented dry-to-dry machines, and one
used a non-vented dry-to-dry machine. Samples were taken in the room expected to have the highest PCE
levels. PCE concentrations ranged from 0.100 to 55.0 mg/m3. The highest concentrations were measured
above an old dry-to-dry unit "in poor operating condition" (Schreiber et al., 1993).
Samples at six control apartments were taken at the same time. Each control residence was located
at least 100 meters from one of the six drycleaning facilities. Controls were chosen based on their
similarity in building type, age, and neighborhood to the co-located apartments. In three of the control
apartments, average measured concentrations were less than 0.0067 mg/m3. Concentrations in the other
control residences ranged from 0.022 to 0.103 mg/m3. A resident of one control apartment worked in a
chemical laboratory; a resident of another apartment worked at a drycleaner (Schreiber et al., 1993).
Consumers Union (Wallace et al, 1995). In 1995, Consumers Union published a study of
PCE concentrations in 29 apartments above dry-to-dry non-vented machines. These apartments were
located in 12 residential apartment buildings, each with one drycleaner. Measurements were taken from
December 1994 to May 1995. Single-day measured concentrations ranged from 0.0007 mg/m3 to 38.0
mg/mj. Four-day average concentrations ranged from 0.007 mg/m3 to 25.1 mg/m3 (Wallace et al., 1995).
The highest PCE concentrations were measured above a drycleaner using a dry-to-dry vented
machine that had been modified to function like a non-vented machine. Consumers Union concluded that
the machine "had been described as an unvented dry-to-dry machine, but probably did not represent the
modern equipment that was our focus" (Wallace et al., 1995). The lowest measured concentrations were
found in apartments on the other side of the building from the drycleaning facility.
4-23
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Chapter 4
Release and Exposure
Concentrations in the control apartments were much lower, ranging from less than 0.0007 mg/m'
to 0.0305 mg/m3 for the single-day average values. The overall average PCE concentration, .based on
values from all control apartments, was 0.006 mg/m3 (Wallace et al., 1995).
New York State Health Department Data, Unpublished. Data on PCE concentrations have
been collected in New York State by the New York City and State Departments of Health in response.to
residential complaints. These data consist mainly of 4-hour samples taken during the daytime, although a
few sets of 24-hour samples are also available. Because these results have not been published by their
collectors, they were accompanied by minimal descriptive information. More than 50 samples above 23
machines were taken in New York in response to residential complaints from 1991 to 1993 (NYSDOH,
1993). Machine types included transfer and dry-to-dry. Machine conditions varied quite substantially.
PCE concentrations ranged from less than 0.02 mg/m3 to 2.5 mg/m3.
San Francisco Bay Area (BAAQMD, 1993). In 1993, the Bay Area Air Quality
Management District in San Francisco, California, published a study of measured PCE concentrations in
the hallways of apartments above four non-vented dry-to-dry machines. These measurements were made to
determine if new machines with advanced controls also produced elevated levels of PCE inside the
building. These samples were taken over two 40-minute periods; the arithmetic mean was reported
(BAAQMD, 1993). PCE concentrations ranged from 0.00224 mg/m3 to 0.673 mg/m3. The highest PCE
concentration was measured above a drycleaner that was the subject of a prior PCE odor complaint. This
facility did not have room enclosures or fans.
Concentrations Measured in Germany and Netherlands (Staub et al, 1992; USEPA,
1992a; Fast, 1993). Additional data are available on PCE concentrations in residences above drycleaners
in Germany'and the Netherlands. Unlike the U.S. data, which appear to show that PCE concentrations are
lower above non-vented dry-to-dry machines than above transfer and vented dry-to-dry machines, the
European data showed no difference in PCE concentrations above vented and non-vented dry-to-dry
machines. The European measurements ranged from less than 1 mg/m3 to 130 mg/m3, with most
measurements between 0.1 and 50 mg/m3 (Staub et al., 1992; USEPA, 1992a; Fast, 1993).
Uncertainties (BAAQMD, 1993, Schreiber et al, 1993; Wallace et. al, 1995). The
Capital District Survey was a census-based assessment, in which each co-located facility in the Albany area
was located and all were tested (Schreiber et al., 1993). Only six apartments were co-located, however, far
fewer than would be found in most major cities.
Samples taken by the New York City and State Departments of Health were based on complaints.
That means that sampling was not carried out based on machine characteristics, which varied
tremendously.
Residents of the apartments tested by Consumers Union volunteered for the study. It is possible
that residents who thought their apartments were polluted with PCE were more likely to volunteer for the
testing. However, Consumers Union concluded that there is nothing about the buildings or cleaners
chosen to suggest that there were more likely to be PCE problems in the tested buildings than any other
locations (Wallace et al., 1995).
4-24
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Chapter 4
Release and Exposure
The San Francisco Bay Area assessment measured concentrations above non-vented dry-to-dry
machines. The sample size was very small, and concentrations were measured in the hallways, not in the
actual apartments (BAAQMD, 1993).
In all cases, sampling occurred over short periods ranging from 4 hours to a few days. One would
expect the measurements prompted by complaints to be higher than PCE levels which are not related to
complaints. This effect is not seen. The small sample sizes, however, make it difficult to draw general
conclusions. Additionally, PCE concentrations were generally measured at one location. It is not known
whether PCE concentrations might vary throughout an apartment.
In the Capital District and Consumers Union studies, apartment residents were asked not to bring
newly drycleaned items into the home in the week prior to sampling. Most residents complied with this
request. However, there may have been some individuals who did not. Measured concentrations for such
individuals' residences could be higher than for others. Additionally, because sampling occurred during
the summer, residents were not asked to keep their windows closed. In two of the Capital District study
homes, windows were open during the sampling period (Schreiber et al., 1993). This could have lowered
measured concentrations by introducing a downward bias.
Concentrations have been measured above both older and newer machine types. A wide range of
machine conditions is also represented. However, the data presented here only go up to 1995. It is not .
known whether concentrations would be lower above the very best and most well-maintained machines.
Both Consumers Union and San Francisco have found elevated concentrations in buildings containing
non-vented dry-to-dry machinery (BAAQMD, 1993; Wallace et al., 1995).
Apartment location within the building can also affect concentration measurements. Both the
Capital District survey and Consumers Union measured higher PCE concentrations in the lower and upper
floors of multistory buildings than in the middle floors (Schreiber et al., 1993, Wallace et al., 1995).
Summary Statistics. Exhibit 4-8 provides summary statistics for the results obtained in the
Capital District, Consumers Union, and San Francisco studies, as well as the previously unpublished data
gathered by the New York City and State Departments of Health. Results are grouped for residences
above transfer machines as well as above vented and non-vented dry-to-dry facilities. Concentrations from
each study are presented separately. Analyzing the data separately in this way does introduce some
uncertainties, in that conclusions are being drawn based on smaller sample sizes. It prevents, however,
differences in study circumstances from masking similarities in results. The exposure assessment does
reflect a fairly good database on the whole, which includes several different monitoring studies. Note that
Exhibit 4-8 contains entries for number of apartments, number of buildings, and number of samples. PCE
concentrations were sometimes sampled in one co-located residence per building and sometimes in several
different apartments in the same building. There was generally one drycleaning machine in a co-located
building.
Different machine types tend to produce different levels of fugitive emissions. In general, the
more sophisticated the type of machine, including associated controls, the lower the fugitive emissions.
Machine condition is important as well. As the Consumers Union study shows, even relatively advanced
dry-to-dry machines can produce moderate to high PCE concentrations in co-located apartments (Wallace
etal., 1995).
4-25
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Chapter 4
Release and Exposure
The highest measurements shown in Exhibit 4-8 reflect machine type and machine condition. The
highest concentration, 62 mg/m3, was measured by the New York Health Department above a transfer
machine. The arithmetic means were also highest for these results. The high measurements above the
vented dry-to-dry machine in the Capital District survey reflect poor machine condition.
The influence of considering complaints in characterizing typical measured values is unclear. For
example, the arithmetic mean of the measurements taken in response to complaints concerning non-vented
dry-to-dry facilities is lower than the mean results found in the Consumers Union study. Both, however,
are close to the odor threshold of PCE in air, which has been reported at one ppm (ATSDR, 1993).
Exhibit 4-8. Summary Statistics for PCE Concentrations in Air in Co-located Residences
Study
No. of
Apartments
No. of
Buildings
No. of
Samples
PCE Concentrations in Air (mg/m3)
Range
Arithmetic
Mean
Standard
Deviation
Median
Residences Above Transfer Machines
Capital
District
New York
State
New York
State
3
5
7
3
1
6
3
10
7
1.35-17
0.4-62
0.02-2.47
7.72
15.5
0.85
7.72
22.4
0.92
6.12
5.95
0.48
Residences Above Vented Drv-to-Dry Machines
Capital
District
Capital
District3
New York
State
1
1
10
1
1
10
2
2
19
0.16-0.44
36.5-55
0.06-15.5
0.3
45.7
3.94
0.28
18.5
5.18
0.3
45.7
2.05
Rpsjripnnes Above Non-vented Dry-to-Drv Machines
Capital
District
New York
State
Consumers
Union"
San
Francisco
1
1
29
4 hallways
1
1
12
4
2a
4
116
4
0.1-0.3
0.2-1.9
0.0007-
38.0
0.0022-
0.67
0.2
0.75
1.85
0.25
0.2
0.68
4.79
0.31
0.2
0.56
0.441
0.17
The authors of the Capital District study describe this machine as old and in poor condition.
b These results include concentrations measured above a vented dry-to-dry machine that had been
modified to function as a non-vented machine. Consumers Union included these results in its statistical
analysis. Four observations were taken above this machine, with a mean of 25.1 mg/m3, a standard
deviation of 9.51, and a median value of 22.7.
4-26
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Chapter 4
Release and Exposure
Co-located Residents: Assumptions. The total number of co-located residents in the
United States is unknown. Information collected in New York State indicates that there are more than
70,000 co-located individuals in the state (NYSDOH, 1993). In New York City, about 30% of drycleaners
are estimated to be in buildings with co-located apartments; statewide, the authors estimate that 6% of
drycleaners are located in the same building as apartments. Similar information for other cities is not
available. Co-located living situations occur in many urban areas throughout the United States.
One estimate of the average time in residence at an apartment is 2.35 years (Israeli and Nelson,
1992, as cited in USEPA, 1997b). This duration was used in calculating the average LADCs. Israeli and
Nelson estimate that 5% of apartment dwellers are still living in the same apartment after 8 years (USEPA,
1997b). This upper-end duration of 8 years was used in estimating the high-end LADCs for adult co-
located residents. Adults have been estimated to spend about 16 hours a day indoors at home (USEPA,
1997b).' This factor was multiplied by the measured concentration in air and the estimated fraction of the
lifetime spent living in the apartment above a drycleaning facility. A lifetime of 70 years was assumed.
PCE concentration data were taken from monitoring studies (BAAQMD, 1993; NYSDOH, 1993;
Schreiber et al., 1993). Some of these monitoring studies reported A.M. and P.M. concentrations. The
A.M. concentrations generally were taken between 7:00 A.M. and 7:00 P.M., and the PM concentrations
between 7:00 P.M. and 7:00 A.M. These A.M. and P.M. concentrations were averaged to provide the
arithmetic mean concentration for the day. This was done because monitoring patterns and activity pattern
reports do not provide data that are readily combined across a day (USEPA, 1997b). If more than one set
of A.M. and P.M. measurements were taken, overall arithmetic mean concentrations were calculated based
on the daily average values.
LADCs were estimated from the arithmetic mean of the measured concentrations. Medians were
provided to help characterize the bulk of the observations. The median values potentially underestimate
exposure by lessening the importance of exposures at the high end of the distribution.
These assumptions were used to estimate long-term concentrations received by co-located
residents (LADCs). The results are presented in Exhibit 4-9.
Exposures Received by Special Co-located Populations
The exposures shown in Exhibit 4-9 are based on measured PCE concentrations in air as well as a
factor for exposure duration. The 90th percentile value for time spent indoors at one's residence is 23.3
hours per day (USEPA, 1997b). This represents 97% of the day spent indoors at home. This highly
exposed group of people clearly would not work outside the home and could include infants, children, and
the elderly. In general, adults are assumed to spend 68% of their time (16.4 hours per day) indoors at
home.
Estimated exposures received by persons at home 97% of the time would be less than double the
values presented in Exhibit 4-9. The estimates for this highly exposed subpopulation would range from
0.007 to 5 mg/m3. This is probably a bounding estimate, which overestimates actual exposures. The
The median value based on 9,343 24-hour diary responses is 16.4 hours in an activity study of 9,386 respondents by Tsang
and Klepeis (1996) as cited in USEPA (1997): the 25th percentile was 13.25 hours, the 75th percentile 20.6 hours.
4^27
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Chapter 4
Release and Exposure
activity pattern data were collected on a short-term basis, and it is difficult to appropriately use the 90th
percentile estimate of time indoors at home to predict the amount of time spent at home over a period of
years.
Activity pattern data gathered specifically for children indicate that children ages 3 to 11 spend 19
hours per day indoors during the week and 17 hours per day indoors during the weekend (USEPA, 1997b).
These values are not necessarily for time indoors at the child's residence, and could include time indoors at
other locations (such as school). For this reason, quantitative exposure estimates based on these activity
pattern data have not been calculated.
Exhibit 4-9. Estimated Exposures Received by Co-located Residents
Study (Number of
Residences)
Arithmetic Mean
PCE
Concentration
(mg/m3)
LADC (mg/m3)3
Average
Time in Residence
= 2.4 years
High End
Time in Residence =
8 years
Residences Above Transfer Machines
Capital District (N=3)
New York State (N=1)
New York State (N=7)
7.72
15.5
0.85
0.18
0.36
0.02
0.60
1.21
0.07
Residences Above Vented Drv-to-Drv Machines
Capital District (N=1)
Capital District (N=1)
New York State (N=9)
0.3
45.7
3.94
0.007
1.05
0.09
0.02
3.56
0.31
Residences Above Non-vented Dry-to-Dry Machines
Capital District (N=1)
New York State (N=1)
Consumers Union
(N=29)
San Francisco (N=4)
0.2
0.75
1.85
0.25
0.005
0.020
0.040
0.006
0.02
0.06
0.14
0.020
a LADC (mg/m3) = Arithmetic Mean PCE Concentration (mg/m3) x Exposure Duration (ED)/Lifetime
(LT)
ED = 16.4 hours/day x 365 days/year x 2.35 years (average)
ED = 16.4 hours/day x 365 days/year x 8 years (high end)
LT = 24 hours/day x 365 days/year x 70 years
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Chapter 4
Release and Exposure
Please note that other differences between children and adults, such as inhalation rates and body weights,
are not relevant to the calculations above because these inhalation exposures represent PCE
concentrations in air prior to inhalation.
Uncertainties:
The most significant uncertainty in this exposure assessment is the assumption that these
concentrations in air will remain constant over a period of years. Another important uncertainty involves
the assumed exposure duration. Although USEPA (1997b) information indicates that 8 years is an
appropriate upper-end value for time in residence at an apartment, it has been pointed out that residents in
New York City could live in the same apartment for a much longer period of time (Wallace et al., 1995).
Consumers Union found that residents of 15 apartments (out of the 29 apartments studied) had lived in
their present residence for 10 or more years. Several residents had lived in the same apartment for more
than 20 years (Wallace et al., 1995).
Exposures Received by People Working Near Drycleaners.
Data gathered by the New York State Department of Health shows elevated concentrations of PCE
in some locations next door to dry cleaners. A total often samples were taken in buildings located next
door to drycleaners in strip malls. Nine of the ten measurements showed elevated PCE concentrations,
which ranged from 0.2 to 50.4 mg/m3, with a median value of 11.8. The tenth sample showed a PCE
concentration of 0.008 mg/m3 (NYSDOH, 1993). This small data set shows that there is potential for
exposure to elevated levels of PCE for people working next door to drycleaners.
Exposures Received by the General Population
One study was carried out at four sites across the country to reflect exposures consequent to a
variety of exposure patterns. The Total Exposure Assessment Methodology (TEAM) study reported 24-
hour concentrations of PCE from close to 1,000 personal samples of persons living in New Jersey,
California, Maryland, North Dakota, and North Carolina (Wallace, 1989). The monitored persons were
chosen to represent members of the general population in these cities. No persons in co-located residences
were included in the study.
Each study participant carried a personal sampler for a 24-hour period, collecting both daytime and
evening samples. Identical samplers were set up near some participants' homes to measure concentrations
in outdoor air. The arithmetic mean 24-hour personal exposure across all locations was 0.017 mg/m3, as
opposed to 0.003 mg/m3 measured outdoors (Wallace, 1989).
Wallace concluded that if these concentrations represent the rest of the country, and if in the
absence of other sources outdoor concentrations will equal indoor concentrations, then "outdoor ambient
air is responsible for at most 20% of the risk due to tetrachloroethylene" (Wallace, 1989).
Wallace noted that there was one unusually high measured concentration of 1.6 mg/m3 in North
Dakota, which increased the overall average; without that single measurement, the mean personal exposure
received by residents of all cities was 0.012 mg/m3. Four sources of exposure were listed by the authors to
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explain why personal exposures (without the North Dakota measurement) were an average of 0.009 mg/m*
higher than the measured outdoor concentrations of 0.003 mg/m3 (Wallace, 1989):
1. Exposure in the drycleaning shop while picking up or dropping off clothes (commercial
drycleaners) or while using coin-operated drycleaning facilities. The author estimated that
these visits to drycleaners contributed less than 0.001 mg/m3 toward the higher indoor
concentrations.
2. Exposure in the car or at home while transporting or storing drycleaned clothes. These
exposures were estimated to contribute 0.005 mg/m3.
3. Exposure at work to one's own or fellow workers' drycleaned clothes. Exposures at work
were estimated to contribute 0.002 mg/m3.
4. Exposure to nonambient, non-drycleaning sources (e.g., paints, solvents, cleaning
materials). This was estimated to contribute the remaining 0.001 mg/m3 toward personal
exposures.
Based on these results, an average LADC can be estimated for persons in New Jersey, California,
Maryland, North Carolina, and North Dakota. For the CTSA, we shall assume that the concentration
measured from personal sampling will remain constant over the individuals' lifetimes. Therefore, the
estimated LADC received by the general population would be 0.017 mg/m3. A limited data set compiled
by the State of New York (NYSDOH, 1993) suggests the PCE is present at low concentrations above
pressing only/drop stores, which do not use PCE on the premises. Measured concentrations ranged from
0.008 to 0.016 mg/m3.
Uncertainties:
The TEAM data are relatively old and also include PCE concentrations from other sources
(although, as stated above, other sources are estimated to contribute only 0.001 mg/m3 toward the total).
As in the co-located scenario, short-term concentrations are used in this CTSA to predict long-term
exposures. Information on the fluctuations of PCE concentrations over time is not available. The
NYSDOH data above pressing only/drop stores are limited to two samples.
Other Studies Measuring Elevated Concentrations in the Home
Several studies have been published relating to consumer exposure to drycleaned clothes. They
relate to bringing clothing home as well as wearing newly drycleaned outfits. As described in the previous
section, arithmetic mean values from the TEAM study have been used in estimating general population
exposures. The following shows how additional information relates to those concentration measurements.
Exposures from Bringing Drycleaned Clothing Home. USEPA data show that the
presence of newly drycleaned clothes in the home will elevate PCE concentrations (Tichenor et al., 1990).
In this study, a polyester/wool suit, a wool skirt, and two polyester/wool blouses were drycleaned and then
brought into a building constructed as a test home. PCE concentrations were measured in the den,
bedroom, and closet. Measured concentrations were less than 1 mg/m3 in the den and bedroom, but
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approached 3 mg/m3 in the closet (Tichenor et al., 1990). Concentrations dropped off slowly over the
nine-day study duration; the authors believe that sink effects (i.e., adsorption and re-emission of PCE) were
responsible for this phenomenon (Tichenor et al., 1990).
Thomas et al. (1991) also examined the impact of drycleaned clothing on PCE concentrations in
indoor air. Newly drycleaned clothes were brought into nine New Jersey test homes. PCE concentrations
were measured in the living room and bedroom. Personal air and breath samples were also taken.
Elevated PCE concentrations were observed in seven of the nine homes, with a maximum indoor air
concentration of 0.3 mg/m3. Indoor air concentrations remained at elevated levels for at least 48 hours in
all seven homes. Personal air and breath samples also showed higher PCE concentrations, with breath
samples elevated two- to six-fold. Thomas et al. state that "Indoor air, personal air, and breath
tetrachloroethylene concentrations were significantly related (0.05 level) to the number of garments
introduced divided by the home volume" (Thomas et al., 1991).
Exposures Received by Families of Drydeaning Workers. Families of drycleaning
workers may also experience elevated PCE concentrations in the home (Aggazzotti et al., 1994; Thompson
and Evans, 1993). Aggazzotti et al. (1994) measured PCE concentrations in the homes of 50 Italian
drycleaning workers and found a median PCE concentration of 0.3 mg/m3, compared to 0.006 mg/m3 in
control homes.
Thompson and Evans "consider the hypothesis that workers introduce Perc into their homes via
their exhaled breath" (Thompson and Evans, 1993). They note that most inhaled PCE is exhaled as PCE,
and they cite results from Wallace (1989) showing elevated PCE concentrations in workers' exhaled breath
and in the homes of drycleaning workers (Thompson and Evans, 1993). Model results for the eighth
consecutive week of worker exposure showed that weekly time-weighted PCE averages in the home
ranged from 0.04 to 0.08 mg/m3 (Thompson and Evans, 1993). Modeled weekend concentrations in the
home ranged from 0.04 to 0.09 mg/m3 (on Saturday) and 0.03 to 0.06 mg/m3 (on Sunday). Thompson and
Evans state that "workers' families may represent one of the most highly exposed non-occupational
subgroups of the population" (Thompson and Evans, 1993).
Exposures Resulting from Wearing Drycleaned Clothes. Consumers Union asked 24
volunteers to measure breathing zone PCE concentrations emitted by newly drycleaned garments. The
garments included six charmeuse blouses, six men's cotton sweaters, six silk blouses, and six women's
blazers. These clothes were cleaned at non-vented dry-to-dry facilities (Wallace, 1995). Measured
concentrations ranged from 4.8 mg/m3 to below detection Jimits (Wallace, 1995). The median
concentrations were 0.032 mg/m3 for charmeuse blouses, 0.043 mg/m3 for men's cotton sweaters, 0.094
mg/m3 for silk blouses, and 0.22 for women's blazers. "Although average concentration follows this order:
charmeuse blouse < men's sweater < silk blouse < blazer, the scatter is so wide for each garment type that
the differences are not statistically significant except that between the charmeuse blouses and the blazers.
The same garment type cleaned at the same cleaner in the same run often yielded vastly different
concentrations" (Wallace, 1995).
Consumers Union also examined the influence of machine type on measured PCE residues.
Twenty volunteers measured breathing zone concentrations from newly drycleaned wool blazers.
Drycleaner facilities included five transfer machines as well as five vented and five non-vented dry-to-dry
machines. Five distributor (drop-off) facilities were also included in the study. Consumers Union stated
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that "the only trend we could detect is that blazers cleaned at distributors yielded generally lower
concentrations than those cleaned at either type of on-site cleaner" (Wallace, 1995) They also concluded
that "the same cleaner could yield vastly different results on different days or even between two d.fferent
blazers cleaned during the same round. These results suggest that consumers cannot guarantee low perc
exposure by choosing a cleaner with new equipment" (Wallace, 1995). A larger study is needed to
provide information on PCE residues on various types of garments and cleaning machines (Wallace,
1995).
Consumers Union used these results to estimate low, moderate, and high exposures received by
persons wearing drycleaned clothes (Wallace, 1995). The low-exposure scenario involves the assumption
that a consumer wears drycleaned clothes a few times a year, and the drycleaner "does a typical job ot
extracting perc from cleaned garments" (Wallace, 1995). The moderate exposure scenario "represents a
consumer who gets a few items of clothing drycleaned each month, and whose cleaner does a typical job ot
extracting perc" (Wallace et al., 1995). The high exposure scenario "represents a consumer who gets
clothes drycleaned at least once a week, and whose cleaner sometimes leaves residues of perc in garments
toward the high end of those we measured in our tests" (Wallace, 1995).
The author assumed that clothes are worn the day after they are cleaned, and that this exposure
occurs over the estimated 40-year career duration (Wallace, 1995). The results are shown in Exhibit 4-10.
These estimates are presented for the general adult population. It is assumed that the elderly,
infants and children will not wear drycleaned clothing on a regular basis. It is possible, however, that
some members of these subpopulations will occasionally wear drycleaned clothes. The low exposure
scenario could be the most appropriate scenario for these individuals.
Uncertainties:
Brand et al. (1997) have examined PCE residues on acetate cloth. In contrast to the Consumers
Union findings, Brand et al. found minimal variations in the amount of PCE residue on the cloth from
different drycleaners. As Wallace et al. (1995) state, a larger study is needed to provide additional
information on PCE residues. It is assumed for the CTSA that the PCE levels measured by Consumers
Union will represent actual residues left on clothing continously over many drycleanmg events.
The low exposure scenario could be an overestimate for people who very rarely wear drycleaned
clothes. Conversely, the high exposure scenario could underestimate exposures to PCE for people who
wear drycleaned clothing every day. A forty-year career duration has been assumed; this could be an
overestimate for some individuals.
Estimated Concentrations in Surface Water
Releases to water are estimated for different types of drycleaning machines in Exhibit 4-1.
Estimated releases range from 0.007 gallons/year (0.04 kg/year) to 0.1 gallons/year (0.61 kg/year). These
releases are assumed to occur over the estimated 312 days of drycleaner operation each year. The
estimated daily releases range from 0.00002 gallons/day (0.0001 kg/day) to 0.0003 gallons/day (0.002
kg/day). The maximum predicted PCE concentration in surface water resulting from these releases is
3ppb.
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Exhibit 4-10. Consumers Union Inhalation Exposure Estimates From Wearing Drycleaned Clothes
Exposure
Scenario
Low
exposure
Moderate
exposure
High
exposure
Garment Type (PCE concentration
description)
Blazer (median PCE concentration)
Blazer (low-end concentration), or silk
blouse (median concentration), or
sweater (high-end concentration)
Silk blouse or sweater (low-end
concentration)
Blazer (median concentration)
Blazer (low-end concentration), or silk
blouse (median concentration), or
sweater (high-end concentration)
Silk blouse or sweater (low-end
concentration)
Blazer (average value for blazers
cleaned with old equipment)
Blazer (low-end concentration), or silk
blouse (median concentration), or
sweater (high-end concentration)
Silk blouse or sweater (low-end
concentration)
Number of
Wearings per
Year
4a
6a
6a
12b
12b
12"
52C
26
26
Measured
PCE
Concentration
(mg/m3)
0.5
0.1
0.03
0.5
0.1
0.03
0.7
0.1
0.03
LADC
(mg/m3)
0.002
0.005
0.03
Source: Wallace, 1995
a Based on an IFI survey indicating, that 30% of drycleaning patrons clean clothes infrequently or
seasonally (Wallace, 1995).
b The IFI survey indicated that 35% of the drycleaning patrons had clothes cleaned on a monthly
basis.
c The IFI survey indicated that 21 % had clothes cleaned weekly.
Uncertainties:
These estimated concentrations are highly dependent on the estimated per-site release values
shown in Exhibit 4-1. Generic assumptions regarding streamflow data have been used to predict estimated
concentrations in surface water (see Appendix E for more information). These assumptions tend to be
conservative and could overestimate concentrations in surface water. PCE concentrations from spills and
splashes are not taken into account in this assessment. As the following section shows, extensive PCE
groundwater contamination has been found in locations close to drycleaners in California and New York.
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Ingestion Exposure
Ingestion of Food
PCE has been detected in fatty foods (such as butter and milk) at low concentrations. Although
ingestion of these foods will result in exposure to PCE, dietary intake is too variable to allow for a
quantitative estimate of exposure via this pathway (NYSDOH, 1998).
Ingestion of Contaminated Groundwater
Information on PCE concentrations in groundwater is available from California and New York.
Potential dose rates received by persons drinking contaminated groundwater are estimated based on
measurements taken by the California Regional Water Quality Control Board (Izzo, 1992). Groundwater
in more than 215 wells was contaminated by PCE. Most of these were large system municipal wells. The
source of the PCE contamination has been identified for 21 wells. In 20 of these wells, the source of PCE
is known to be drycleaners (Izzo, 1992). In many cases, concentrations in well water exceeded 0.8 parts
per billion (ppb). Forty-seven wells contained PCE in excess of California's maximum contaminant level
(MCL) of 5ppb (Izzo, 1992).
PCE is discharged in several forms. "The discharge from most drycleaning units contains
primarily water with dissolved PCE, but also contains some pure cleaning solvent and solids containing
PCE Being heavier than water, PCE settles to the bottom of the sewer line and exfiltrates through it. This
liquid can leak through joints and cracks in the line. PCE, being volatile, also turns into gas and penetrates
the sewer wall The PCE then travels through the vadose zone to the ground water (Izzo, 1992). 1 he
vadose zone, also known as the unsaturated zone, refers to the soft layers, which contain air and some
water, above the groundwater level. A 1988 survey of drycleaners indicates that more than 50% discharge
their separator water to a sewer (IFI, 1989).
The California Regional Water Quality Control Board believes that most PCE contamination in
groundwater is due to drycleaners. PCE is used in other industries, including the auto/boat industry
telephone companies, furniture, and paint dealers, but typically the products contain less than 30/o PCE
(Izzo 1992) Drycleaning uses 15 to 40 gallons per month of pure PCE solvent. In other industries,
"many of the solvents used that contain PCE are in aerosol cans. The solvent is sprayed on the part to
remove grease and as the part dries, the PCE volatilizes into the air. Most industries other than dry
cleaners which use solvents have no daily discharge of waste liquids containing PCE." (Izzo, 1992).
Sewer sampling conducted near seventeen drycleaners in the California cities of Merced,
Sacramento, Roseville, Turlock, and Lodi has revealed high concentrations of PCE. PCE concentrations in
sewer water range from 0.6 ppb to 3,800 ppb, with the median reported concentration at 190 ppb and the
average concentration at 748 ppb (Izzo, 1992). "Monitoring wells drilled adjacent to dry cleaners had
concentrations from 12 ppb to 32,000 ppb" (Izzo, 1992).
The New York State Department of Health has reported PCE concentrations in soil and
groundwater in areas in close proximity to drycleaners (Stasiuk, 1993). High concentrations have resulted
from "either direct discharges of PCE from drycleaner operations or from indirect contamination as a result
of improper disposal of wastes from drycleaner operations" (Stasiuk, 1993).
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Monitoring of areas near 30 drycleaners revealed that PCE has been found in groundwater at
concentrations ranging from 5 to 28,000 ppb. These samples were taken at various time periods between
the mid-1970s and the early 1990s. Eighty-five private wells were contaminated, with concentrations
ranging from 5 to 6,000 ppb. PCE has also been detected in six public wells at concentrations ranging
from 41 to 640 ppb (Stasiuk, 1993). After cleanup, PCE concentrations in public wells were at or below
the New York state standard of 5 ppb.
The PCE levels in groundwater can be used to develop an exposure assessment for household
residents, who ingest PCE in their drinking water. As described above, PCE has been reported in public
wells at concentrations ranging from 0.8 to 640 ppb (Izzo, 1992; Stasiuk, 1993). For the CTSA, it is
assumed that cleanup will occur and that PCE levels in excess of the New York and California standards of
5 ppb would not be present in drinking water on a long-term basis. It is also assumed that PCE levels in
drinking water over an extended period of time could range from 0.8 to 5 ppb. The .estimated what-if
exposures resulting from drinking water containing these levels of PCE range from 2 x 10'6 mg/kg/day (at
0.8 ppb) to 1 x lO'5 mg/kg/day (at 5 ppb).
These estimates are based on the assumption that exposed individuals drink 1.4 L of water per day,
which is an average value for tap water ingestion (USEPA, 1997b). A body weight of 72 kilograms is
assumed (USEPA, 1997b). The assumed exposure duration is 9 years, which is the average residence time
reported in USEPA, (1997b). For the purposes of this assessment, it is assumed that when residents move,
they would move to an area in which the water supply is no longer contaminated with PCE.
Infants and Children would also be exposed to PCE in household water supplies. Average values
for tap water intake range from 0.3 liters per day for infants to 0.97 liters per day for children ages 11 to 19
(USEPA, 1997b). Exposure scenarios are developed for infants and 11-year-old children. The assumed
body weight for infants is 10 kg, which is based on the 50th percentile values for male and female infants
at twelve months of age (USEPA, 1997b). A body weight of 41.1 kg is used for 11-year-old children
(USEPA, 1997b). Daily PCE intake ranges from 2 x 10'5 to Ix 10'4 mg/kg/day for infants. The estimated
range for 11-year-olds is 2 x 10'5 to Ix 10'4 mg/kg/day. Please note that these are daily values, unlike the
scenario for adults which provides chronic values.
Additional information on PCE concentrations in groundwater has been obtained by performing a
search of Dialog, STORET, and the Internet. These concentrations of PCE are accompanied by minimal
descriptive information, and it is not certain that the contamination source is dry cleaners. For this reason,
these data have not been included in the exposure assessment. A summary of the search results in shown '
in Appendix E.
Uncertainties:
These estimates were obtained from an analysis of a number of contaminated sites in California
and New York. It is assumed for the purposes of the CTSA that the concentrations in municipal wells as
reported above are representative of PCE concentrations in household water supplies. This could be a
conservative assumption if public water supplies are drawn from a number of different wells, which could
cause PCE concentrations to be diluted. Another uncertainty involves the assumption that removal in
drinking water treatment does not occur. In some cases, well water is treated before it is supplied to
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households. If PCE is removed during such treatment, these assumed concentrations could be
conservative.
An important assumption that could lead to underestimates of exposure is that PCE concentrations
in excess of the 5 ppb regulatory level will not be present in household drinking water over a period of
years The New York State investigations were prompted either by routine sampling or by taste and odor
complaints. The author states, however, that "we have not systematically sampled private drinking water
supplies near dry cleaners" (Stasiuk, 1993). It is possible that PCE could be present at higher levels in
some water supplies because sampling has not been done.
Ingestion of PCE in Breast Milk
Several authors have described the pathway of infant exposure to PCE via ingestion of their
mothers' milk (Fisher et al., 1997; Schreiber, 1997). The maternal exposures result from inhalation of
PCE. The breast milk concentrations may be measured; the amounts reaching infants are modeled.
Most inhaled PCE is exhaled as PCE (Schreiber, 1997). A small percentage of inhaled PCE,
however, is stored in adipose tissue and contaminates breast milk (Schreiber, 1997). Nursing infants then
ingest PCE from the mother's milk. A survey of 17 nursing mothers showed that 63% had PCE in their
breast milk at concentrations ranging from 0.15 to 43 ug/L. (Sheldon et al., 1985). Schre.ber used a
physiologically based pharmacokinetic model to estimate infant doses from ingestion of breast milk
(Schreiber 1997). Maternal inhalation exposure scenarios were developed for occupational^ exposed
women, persons living in apartments above drycleaners, and women inhaling a "residential background
concentration of 27 u.g/m3" (Schreiber, 1997).
The residential PCE exposure "results in a predicted breast milk PCE concentration of 1.5 ug/L,
similar to the mean PCE breast milk concentration of 6.2 ug/L found by Sheldon et al. (1985) in a study of
17 nursing mothers in the Elizabeth-Bayonne, New Jersey, area" (Schreiber et al., 1993). Predicted infant
exposures ranged from 0.0001 to 0.82 mg/kg/day (Schreiber, 1997). Schreiber assumed that the infant
weighs 7.2 kg (Schreiber, 1997).
Byczkowski and Fisher also developed a model for estimating infant exposure to volatile organic
chemicals (VOCs) from breast milk ingestion (Fisher et al., 1997). Results were in agreement with
Schreiber's predictions (Fisher et al., 1997). More recently, Fisher et al. (1997) revised this model to
improve the estimate of milk production and incorporate measured values for milk and blood partition
coefficients. The authors predicted that if a mother inhales PCE at the OSHA PEL of 25 ppm (170 mg/nr)
for 8 hours per day, the infant will ingest 1.36 mg of PCE per day (Fisher et al., 1997). In a similar
exposure scenario with 8 hours of maternal exposure at the PEL (25 ppm), followed by 16 hours of
exposure at 27 mg/m3, Schreiber predicted an infant exposure of 2.4 mg (0.34 mg/kg/day). These results
are comparable, recognizing that Schreiber (1997) included 16 hours of maternal inhalation exposure at
background levels while Fisher et al. (1997) assumed no maternal exposure outside the workplace.
Uncertainties:
These scenarios are based on measured PCE concentrations in air; however, the amount of PCE
reaching the infant is based on modeling. Maternal inhalation exposures could vary widely even within the
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co-located population. Schreiber (1997) has estimated exposures based on a wide range of exposures,
from maternal occupational exposure to inhalation of background levels.
PCE exposures to the fetus:
Very little information is available on fetal exposures to PCE. Fisher et al. (1989) developed data
to assess the feasibility of building a physiologically based pharmacokinetic model of exposure of pregnant
rats to trichloroethylene (TCE), a structurally similar chemical. Pregnant rats were exposed to TCE via
inhalation, gavage, and drinking water. Their data were compared to outcomes of the model which
diverged by no more than a factor of two, leading the authors to believe the approach was worth further
validation. We do not, however, have a comparable study for PCE. Fisher et al. did conduct a similar
exercise for estimates of lactational transfer for TCE. A later parallel simulation for PCE by Byczkowski
et al. (1994) indicated the compartmental models for lactational transfer for the two compounds are not
exactly parallel. Consequently, it may not be appropriate to use the findings on rat fetal exposure to TCE
to calculate human fetal exposure to PCE. This study does, however, suggest that further examination of
the potential for human fetal exposure to PCE should be included in any future assessment.
Dermal Exposure
Exposures would also result from bathing and showering in water contaminated with PCE.
Dermal uptake of PCE in bath water has been estimated to equal the dose received from drinking 2 liters of
water a day, for any given level of chemical contamination (Keifer, 1998). Therefore, if PCE is present in
bath water at concentrations ranging from 0.8 to 5 ppb, the estimated dermal uptake from bathing would be
slightly greater than the ingestion exposure for adults, which assumes a drinking water ingestion rate of 1.4
liters per day.
Uncertainties:
The assumption that dermal uptake is equivalent to ingesting an equivalent amount of PCE in two
liters of water per day is based on modeling results (see Appendix E for more information). In addition to
the uncertainties with the groundwater results, it is possible that dermal uptake could be higher or lower.
4.4.2 Drycleaning: Hydrocarbon Solvents
General
People are exposed to HC solvents (including Stoddard solvent and 140°F solvent) primarily as a
result of HC releases to the air, water, and land following commercial drycleaning. Workers are exposed
to HC solvents both from inhalation and dermal exposure. Hydrocarbon solvents are used much less often
than PCE in commercial drycleaning, and very little information is available on them. The exposure
analysis is therefore much less detailed than that performed for PCE.
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Occupational Exposure
This section examines issues regarding HC exposures to the workers in the drycleaning industry,
The HC solvents for which data were available were Stoddard solvent and HOT solvent. Data sources
include those that are readily available in published literature or through on-line access.
Some regulatory and recommended limits have been established for worker exposure to Stoddard
solvent In January 1989, the U.S. Occupational Safety and Health Administration (OSHA) adopted a 52.5
mg/m3 (100 ppm) TWA permissible exposure limit (PEL) to replace the pre-1989 PEL of 2,900 mg/m
(500 ppm) TWA However, all new 1989 PELs were vacated via a court decision, and the pre-1989 PEL
for Stoddard solvent is currently in effect. Some states may maintain the 1989 PEL or other levels as state
regulatory limits. Section 8.6 presents more details on OSHA requirements.
The American Conference of Government Industrial Hygienists (ACGIH) sets its Threshold Limit
Value (TLV) for Stoddard solvent at 525 mg/m3 (100 ppm) (ACGIH, 1994). The National Institute for
Occupational Safety and Health (NIOSH) Recommended Exposure Limit (REL) is 350 mg/m (100 ppm)
TWA and NIOSH recommends a ceiling of 1,800 mg/m3 (300 ppm) for a 15-minute TWA (NIOSH,
1997a). NIOSH also has established 20,000 mg/m3 (3,600 ppm) as a concentration immediately dangerous
to life and health (IDLH) (NIOSH, 1997a).
For this CTSA, it has been estimated that there are 5,400 commercial facilities that dryclean
clothes using hydrocarbon solvents (excluding drop-off/pick-up sites) in the United States. NIOSH
recently published a study of commercial drycleaners that included data on numbers of workers and sites
(American Business Information, 1994). These BA data include drop-off/pick-up sites that do no cleaning
and include all process types (PCE, hydrocarbon, etc.). In order to estimate numbers of workers in PCE
drycleaning facilities nationwide, the BA data needed to be adjusted, and the BA data and assumptions
used to adjust them are shown in Exhibits E-5 and E-6 of Appendix E.
As a result, it is estimated that 21,000 to 49,000 workers are employed in commercial facilities that
dryclean clothes using HC in the U.S. The midpoint of this range suggests an average of 6.5 workers per
facility. It is not known how well these estimates represent the industry due to the uncertainties in the data
and assumptions used to adjust them. National Occupational Exposure Survey (NOES) data for numbers
of workers in the HC drycleaning industry were not found and therefore could not be compared to the
numbers of workers estimated for this CTSA.
The population of drycleaning workers may be categorized into various job titles, such as operator
or presser, based on worker activities. However, typical activities and exposures may be difficult to
characterize because workers may have rotating responsibilities and overlapping activities, which often
vary from facility to facility. In a previous study, USEPA estimated the number of workers by job
description (PEI, 1985). Based on those estimates, the drycleaning workers may be categorized into the
following job titles with the corresponding percentage of the total drycleaning population: 3.8% managers/
administrators, 18.5% clerks, 9.9% tailors, 15.5% pressers, 48.7% operators, and 3.6% for all others
combined ("spotter" was not a job title in the classification list). It is assumed that the job descriptions of
"(dry) cleaner" and "operator" are equivalent, and include those workers who operate the drycleaning
washing and drying equipment. For risk assessment in Chapter 4, it is assumed that the workers may
normally be exposed for eight hours per day and 250 days per year (days/yr). Some worker subpopulations
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(e.g., some workers in "mom and pop shops") could be expected to be exposed for up to 312 days per year
or more and more than eight hours per day, although no data were found to support estimated average
numbers of hours per day and days per year.
Occupational Inhalation Exposure
Few studies and data sets are available to characterize inhalation exposures to HC for drycleaning
workers. Two data sets are presented in this section that illustrate variations in worker inhalation
exposures due to the one factor that could be differentiated from the data: job title. These data sets consist
of OSHA monitoring data and survey data from a NIOSH report. These data sets include measured TWA
exposure concentrations (ECs) of Stoddard solvent; for risk screening later in this report, it is assumed that
these data are representative of 8-hour (full-shift) TWAs.
The first data set is post-1990 monitoring data from OSHA's Computerized Information System
(OCIS, 1994 and 1998). ECs from these data are summarized by job title in Exhibit 4-11. Distributions of
data for two worker subpopulations (drycleaner and presser) could be generated from these data. Because
OSHA often monitors for compliance or in reaction to complaints, mean ECs generated from OSHA data
may be higher than actual ECs for the total population of workers. Exhibit 4-11 indicates that cleaners
have higher exposure than pressers. Factors such as machine type and controls and numbers of machines
were not available for these data.
Exhibit 4-11. Summary of TWA Exposure Concentrations (ECs) for Inhalation of Stoddard Solvent
by Job Title Based on OSHA Personal Monitoring Data
Job Description3
Geometric Mean
EC (mg/m3 TWA)
Arithmetic Mean EC
(mg/m3 TWA)
Maximum EC
(mg/m3 TWA)
1990 to 1993
All jobs [n = 28]
Cleaner [n = 16]
Pressed [n = 7]
17±7
25±6
3.5
92±190
99±200
3.5
720
720
3.5
1997
All jobs [n=11]
41±1
150±200
550
Source: OCIS (1994) and OCIS (1998).
3 Number of data points [n] is in brackets. Mean concentrations ± standard deviations are presented.
For both OCIS data sets, none of the measurements exceeds the current OSHA permissible exposure
limit of 2,900 mg/m3 TWA for Stoddard Solvent.
b All observations were below the detection limit.
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Release and Exposure
The second data set is a limited amount of personal monitoring data available from the study
conducted by NIOSH (1988) that included six industrial (several very large) and commercial drycleaners
using petroleum solvents. Monitoring data were collected from job categories with monitoring lasting at
least one hour These data form the basis for the mean concentrations for inhalation of petroleum solvents
presented in Exhibit 4-12. Again, as does Exhibit 4-11, Exhibit 4-12 shows that the cleaner has higher
mean exposures than all other worker categories. Compliance with the OSHA PEL for Stoddard solvent of
2,900 mg/m3 was 100% for all 56 samples taken in the NIOSH surveys.
Exhibit 4-12. Summary of TWA ECs for Inhalation of Petroleum Solvents
by Job Title Based on NIOSH Data
Job Category*
All jobs [n=56]
Cleaner [n=35]
Cleaner assistant [n=4]
Customer service [n=1]
Pants folder [n=1]
Inspector [n=4]
PCE cleaner" [n=6]
Supervisor [n=5]
Arithmetic Mean
EC (mg/m3 TWA)
260 + 350
380 + 400
24 + 31
3
63
83 + 43
27 ±15
120 ±54
Geometric Mean
EC (mg/m3 TWA)
93 ±5
170±5
14±3
3
63
74 ±2
21 ±2
100 ±2
Maximum EC
(mg/m3 TWA)
1,246
1,246
70
3
63 .
131
48
160
Source' NIOSH (1980). Based on six case studies conducted by NIOSH on industrial and
commercial facilities cleaning with petroleum solvents (Stoddard solvent and 140°F solvent).
• Number of data points [n] is in brackets. Mean concentrations ± standard deviations are
presented. None of the 56 measurements exceeded the current OSHA permissible exposure limit
of 2,900 mg/m3 TWA for Stoddard solvent.
b These cleaners operated the PCE machines in a facility that had both PCE and HC machines.
The value is their HC exposure.
In summary, the primary finding from the two exhibits summarizing worker inhalation of HC is
that operator/cleaners generally appear to have higher exposures relative to most non-operators (e.g.,
pressers, spotters). No other conclusions could be drawn due to the limited amount of data and
information available for this subpopulation of the industry. A comparison of the levels in the two exhibits
indicates a general decrease in exposure levels over time, although the mean values in the tables do not
conclusively verify this apparent decrease.
Interpretation and comparison of the data sets summarized in this CTSA raise some uncertainties
related to the data and the studies in which they were collected. It is not known whether the measured
concentrations in these data sets are representative of the distributions of concentrations to which the
populations of drycleaning workers are actually exposed nationwide. The smaller the numbers of facilities,
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Chapter 4
Release and Exposure
workers, and samples, the higher the degree of uncertainty regarding representativeness. It is also not
known whether the measured TWA concentrations, not adjusted to represent full-shift values (i.e., no
scaling from observed period to 8-hour shifts), are representative of full-shift TWA concentrations.
Variations in machinery and plant layout, exposure controls such as ventilation, work practices and
procedures, amounts of clothes cleaned daily, and many other factors affect an individual drycleaning
worker's exposure. As a result, an individual worker's exposure may or may not be well-represented by
the data summarized in this CTSA. The data in these exhibits may only compare qualitatively. Specifics
of the facilities, the worker activities, the monitoring studies, and other relevant details behind the
monitoring data presented in the exhibits were not available to allow for a detailed understanding and
analysis of the ECs in the different data sets and how they may be quantitatively compared. The sets of
data in the exhibits do appear to support one another generally. For example, the arithmetic averages of
larger data sets for a given population or subpopulation are within an order of magnitude and often
compare closely.
Occupational Dermal Exposure
Drycleaning workers may also experience dermal exposure to HC. No studies or data were
available which quantify dermal exposures to HC for drycleaning workers; however, dermal exposures to
HC can be modeled. Estimates presented here are based upon the OPPT Occupational Dermal Exposure
Model (USEPA, 199la). The model relies on a two-hand contact or immersion in a liquid without any
protective clothing and use of pure HC. This model is believed to present bounding estimates of amounts
of solvent available for absorption on the skin surface (see Section 4.3.2). Hence, these estimates are
larger than workers would be expected to receive. This model assumes the surface area for two hands is up
to 1,300 cm2. No model is available to estimate dermal exposures from vapors.
Operators are the primary workers expected to perform activities that result in dermal exposures to
liquid HC, and these activities are shop and equipment dependent. Some of these activities occur at least
once per day (routine) and others occur on a less frequent basis (non-routine), such as changing cartridge
or rag filters and open-tank waterproofing. Routine activities include, but are not limited to, transferring
wet articles from the washer to the dryer and cleaning the button trap and still. For the wet article transfer
activity, the OPPT ODEM immersion data were chosen to be applicable for exposure modeling; for all
other activities, the OPPT ODEM contact data were chosen to be applicable for exposure modeling.
The estimated dermal PDR for workers performing wet article transfer is 18,000 mg/day HC
available for dermal absorption. This PDR for transfer assumes essentially pure HC solvent, 1,300 cm2
two-hand surface area, and up to 14 mg/cm2 surface density of HC solvent on the skin. The estimated
dermal PDR for workers performing other activities is less than 3,900 mg/day HC available for dermal
absorption. This PDR for other activities assumes essentially pure HC solvent, 1,300 cm2 two-hand
surface area, and up to 3 mg/cm2 surface density of HC solvent on the skin. These estimates are not used
for risk calculation in this document.
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Release and Exposure
Non-worker Exposure
Members of the general population are exposed to HC solvents as a result of releases to the air,
water, and land following commercial drycleaning. HC solvents are used less frequently in commercial
drycleaning than PCE, and information on measured concentrations in air and water is not available. The
exposure analysis is therefore much less detailed than that performed for PCE.
Inhalation Exposure
An inhalation exposure scenario is presented for inhalation of HC solvents by the general
population. Studies providing monitoring data on concentrations were not available, so exposure from
inhalation of HC solvents was modeled by distance from a hypothetical facility. A 9-year exposure
duration, which is the average residence time reported in USEPA (1997b), is assumed for exposure to HC
solvents. It is assumed that residence time adequately accounts for exposure duration. It is expected that
exposures to HC solvents will decrease with increased distance from the facility. The estimates of HC
solvents releases used to calculate exposure concentrations (potential doses) are presented earlier in the
release section of this document. Using these releases, several estimates of Lifetime Average Daily
Concentrations (LADCs) are developed and presented in Exhibit 4-13. They are differentiated by distance
from the hypothetical facility and assumptions regarding the degree of emission controls on the HC
machines. Further details on the assumptions involved in these calculations can be found in Appendix E.
These estimates are based on conditional release ranges and therefore are "what-if' LADC
estimates.
Exhibit 4-13. Hydrocarbon LADCs by Distance from a Hypothetical Facility (mg/m3)
Distance
(meters)
100
200
400
Transfer Machines
Conventional Dryer
0.002
0.0009
0.0003
Recovery Dryer
0.0008
0.0003
0.0001
Dry-to-Dry Machine
0.0002
0.0001
0.00004
LADC (mg/m3) = Modeled Hydrocarbon Concentration (mg/m3) x Exposure Duration
(ED)/Lifetime (LT) < „„,,_*
ED = 16.4 hours/day x 365 days/year x 9 years (average residence time from USEPA, 1997b)
LT = 24 hours/day x 365 days/year x 70 years
The most sensitive value in the estimation of these values is probably the release concentration.
This concentration will vary with facility-specific machine type, controls, and ventilation systems.
Therefore, the distribution of expected HC solvent concentrations cannot be appropriately defined at
present.
These exposure estimates are generated for adults spending about 70% of the time at home (16.4
hours/day). As discussed in the case of PCE, children and members of other populations who spend more
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Chapter 4
Release and Exposure
time at home could receive higher exposures. However, the increased time spent at home for these
populations would contribute an additional factor of less than two to these estimated exposures.
Ingestion of Contaminated Drinking Water
The projected releases of HC solvents to surface water are very low, on the order of 5 x 10"8 to 1 x
10~7 kg/site/day. The HC solvent concentration in surface water resulting from these releases is estimated
at less than 1 ppb. The estimated drinking water exposure is much less than 1 mg/kg/day.
Uncertainties (these are applicable to both the inhalation and ingestion scenarios):
These exposure scenarios are highly dependent upon the estimated hydrocarbon releases to air and
to water. These release estimates may or may not be characteristic of actual facilities, and for this reason
the exposures are what-if. Exposures to water have been calculated with the use of generic streamflow
information because the information on the specific release sites is not available. These HC exposure
estimates are based on modeling and therefore could be considered more uncertain than estimates of
exposure to PCE, which are generally based on monitoring.
4.4.3 Machine Wetcleaning Process
Occupational Exposure
Workers in machine wetcleaning facilities (MWC) are exposed to formulations of the MWC
detergents and other cleaning agents. The primary route of exposure to workers for these formulations,
which are expected to be liquids, is the dermal route. Inhalation exposure is not expected for most of the
chemicals in these liquid formulations, most of which are relatively non-volatile. If powdered MWC
formulations are developed, small inhalation exposures to airborne powders could be expected. However,
because no such'formulations are known to exist for commercial applications, this CTSA assumes that
workers are not significantly exposed to chemical constituents in MWC formulations via the inhalation
route.
There are no regulatory limits for chemical constituents in MWC formulations that would be
expected to limit or affect worker exposures to these formulations.
There are approximately 38 dedicated MWC facilities in the U.S. Two studies of facilities that
used MWC processes noted numbers of workers at those facilities: four to five workers at one site
(Gottlieb, 1997), and five to seven workers at another site (Patton et al, 1996). Both of these sites cleaned
fewer clothes via MWC than the clothes cleaning throughput of 53,333 Ib/yr for this CTSA's "model
facility."
As mentioned above, potential occupational dermal exposure to liquid MWC formulations exists
among drycleaning workers. There are no studies or data that quantify occupational dermal exposures to
these formulations; however, dermal exposures to MWC formulations can be modeled. Estimates
presented here are based upon the OPPT Occupational Dermal Exposure Model (USEPA, 199la). The
model relies on a two-hand contact or immersion in a liquid without any protective clothing and use of
pure or diluted MWC formulations. This model is believed to present bounding estimates of amounts of
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Release and Exposure
formulation(s) available for absorption on the skin surface (see Section 4.3.2). This model assumes a
surface area for two hands of 1,300 cm2. Operators are the primary workers expected to perform activities
that result in dermal exposures to liquid MWC formulations, and these activities are shop- and equipment-
dependent. Some of these activities occur at least once per day (routine) and others occur on a less
frequent basis (non-routine). Routine activities include, but are not limited to, transferring wet articles
from the washer to the dryer; and non-routine activities include, but are not limited to, connecting the
formulation container to the dispensing pump line. For the wet article transfer activity, the OPPT ODEM
immersion data were chosen to be applicable for exposure modeling; for all other activities, the OPPT
ODEM contact data were chosen to be applicable for exposure modeling.
The estimated dermal potential dose rate (PDR) for workers performing wet article transfer is up
to 2.5 mg/day of combined MWC formulations available for dermal absorption, and the frequency of this
exposure would be daily for up to 250 days per year for most workers. This PDR assumes a maximum
concentration of 0.01% MWC formulations (e.g., detergents, finishes, water softeners) remaining in the
rinse water, 1,300 cm2 two-hand surface area, and up to 14 mg/cm2 surface density of detergent.
The estimated dermal PDR for workers connecting formulation containers to dispensing lines or
performing other activities that may result in contact with undiluted formulation(s) is less than 3,900
mg/day of one or more MWC formulations available for dermal absorption. This PDR assumes undiluted
MWC formulations (e.g., detergents, finishes, water softeners), 1,300 cm2 two-hand surface area, and up to
3 mg/cm2 surface density of detergent. The frequency of exposure for changing out formulation containers
(e.g., detergent or finish) would be approximately 29 days per year for the "model facility" assuming 20 L
(5 gallon) containers, 0.15 L/load detergent, 0.15 L/load finish, 6 loads/day, and 312 days per year
operation. It is not known whether these PDR estimates are representative of actual PDRs for machine
wetcleaning workers. PDRs of individual chemical constituents in two sample detergent formulations are
provided in Exhibits E-13 and E-14 in Appendix E.
Non-worker Exposure
Human Exposure
Machine wetcleaning processes are expected to result in exposures to the general population
primarily as a result of contamination of surface waters. Ingestion and dermal exposure can result from
showering in and drinking this contaminated water. A few of these machine wetcleaning chemicals are
expected to cause irritation; however, large dermal exposures among the general population are not
expected.
Concentrations in Surface Water
Estimated releases of machine wetcleaning chemicals to water are shown in Exhibit 4-3. Releases
to surface water are discharged through a drain at a dry or machine wetcleaning facility and end up going
to public sewers or POTWs. This discharge is treated before being released. The effectiveness of the
treatment is estimated so that the amount reaching the receiving water body can be calculated. Because the
receiving water will dilute the discharge from the POTW, stream flow information is used to calculate
surface water concentrations. Stream in this context means the receiving body of water and includes
creeks and rivers as well as streams.
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Release and Exposure
There is concern for the effect that a chemical may have on aquatic organisms, from algae to fish.
If the food chain is broken in a stream, the consequences are dire (i.e., no algae, no fish). A healthy stream
with many organisms will have a better ability to handle chemical releases than one whose quality is
already compromised. Since contaminant concentrations will vary with the stream flow, periods of lower
flow conditions may cause problems where regular flow conditions would not. Stream flow data are used
to predict how often this will happen.
Since these chemicals could be released from many drycleaning sites, site-specific data are not
available. Generic assumptions based on releases from single sites have been used to estimate surface
water concentrations (USEPA, 1995). Streamflow values for POTWs have been used in this assessment.
This provides a conservative estimate of surface water concentrations and is appropriate for use when the
specific locations of the sites are unknown (USEPA, 1995). See Appendix E for more information.
As an illustration, surface water concentrations were estimated for the constituents of the two
example machine wetcleaning formulations. Estimated surface water concentrations for "example
detergent #1" range from 40 to 130 ppb. For "example formulation #2," estimated surface water
concentrations range from 40 to 430 ppb.
Uncertainties:
As in the HC assessment, the accuracy of these surface water concentrations is dependent upon the
estimated releases. Two example formulations have been assessed; these may or may not be representative
of other machine wetcleaning formulations. Assumptions were made for a hypothetical facility, and for
this reason the exposure scenarios are what-if. As described above, generic streamflow assumptions have
been used because site-specific data are not available.
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Release and Exposure
REFERENCES
ACGIH 1994 American Conference of Government Industrial Hygienists. 1994-1995 Threshold Limit
Values for Chemical Substances and Physical Agents and Biological Exposure Indices, ACGIH.
Cincinnati, OH. ;
Aggazzotti et al., 1994 'Occupational and environmental exposure to perchloroethylene (PCE) in dry
cleaners and their family members' Archives in Environmental Health 49(6) 487-493.
American Business Information. 1994. Business America on Disk. (CD-Rom disk) Omaha, NE: ABI. [As
cited in NIOSH, 1997]
ATSDR. 1993. Agency for Toxic Substances and Disease Registry. Toxicological profile for
tetrachloroethylene. USDHHS, Agency for Toxic Substances and Disease Registry. Atlanta, GA.
BAAQMD. 1993. Bay Area Air Quality Management District. An Investigative Survey of
Perchloroethylene in Residential Areas above Dry Cleaners in San Francisco.
Brand et al., 1997. Residual perchloroethylene in'dry-cleaned acetate: the effect of pressing and extent of
inter dry-cleaner variability.
CEC. 1992. Center for Emissions Control. Dry cleaning-an assessment of emission control options.
September.
CEPA. 1991. California Environmental Protection Agency. Air Resources Board. Technical support
document, part C. Proposed identification of perchloroethylene as a toxic air contaminant.
August.
CEPA. 1993. California Environmental Protection Agency. Proposed airborne toxic control measure and
proposed environmental training program for perchloroethylene dry cleaning operations. Staff
report. CEPA, Air Resources Board. August.
Consumers Union. 1995. Perchloroethylene in the air in apartments above New York City dry cleaners: A
special report from Consumers Union.
Environment Canada. 1995. Final Report for the Green Clean™ project. Prepared by Environment
Canada and the Green Clean Project Participants. Government of Canada EN40-5-0/1995/E.
Fast, T. 1993. Municipal Health Service (MHS), Amsterdam, the Netherlands. "Exposure to
Perchloroethylene in Homes Nearby Drycleaners Using Closed Systems and the Effect of
Remedial Actions," Proceedings of Indoor Air '93, Vol. 2.
Fisher, J., D. Mahle, L. Bankston, R. Greene, and J. Gearhart. 1997. Lactational Transfer of Volatile
Chemicals in Breast Milk. American Industrial Hygiene Association Journal. 58:425-431.
4-46
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Release and Exposure
Gottlieb et al., 1997. Gottlieb, R., P. Sinsheimer, et al. Pollution Prevention in the Garment Care Industry:
Assessing the Viability of Professional Wet Cleaning. UCLA/ Occidental College/ Pollution
Prevention Education and Research Center. December.
IFI. 1989. International Fabricare Institute. Vol. 13, No. 1. IFFs Equipment and Plant Operation Survey.
Focus on Drycleaning. March. IFI: Silver Spring, MD.
IFI. 1990a. International Fabricare Institute. "Monitoring solvent vapors in drycleaning plants." Focus on
Drycleaning, Vol. 14, No. 3. July. IFI: Silver Spring, MD. [as cited in Thompson and Evans
1993]
IFI. 1990b. International Fabricare Institute. Summary of Passive Monitoring Data, [cited without
reference in NIOSH, 1997]
Israeli, M., and Nelson, C.B. 1992. Distribution and expected time of residence for U.S. households.
Risk Analysis. 12( 1 ):65-72.
Izzo, V. 1992. Dry Cleaners-A Major Source of PCE in Ground Water. Report to the California Regional
Water Quality Control Board, Central Valley Region. Sacramento, CA.
Keifer, L. 1998. Memorandum entitled "Information for Response to Peer Review Comments for
Perchloroethylene (PCE).
NIOSH. 1980. National Institute of Occupational Safety and Health. Arthur D. Little for NIOSH.
Engineering control technology assessment of the dry cleaning industry. U.S. Dept. of Health,
Education, and Welfare, NIOSH. Cincinnati, OH. October.
NIOSH. 1982. National Institute for Occupational Safety and Health. National occupational exposure
survey of 1982. U.S. Dept. of Health, Education, and Welfare, Public Health Service, Centers for
Disease Control, NIOSH. Washington, DC.
NIOSH. 1997. National Institute for Occupational Safety and Health. NIOSH Pocket Guide to Chemical
Hazards. DHHS (NIOSH) Publication Number 97-140. U.S. Dept. of Health, Education, and
Welfare, Public Health Service, Centers for Disease Control, NIOSH. Washington, DC. June.
NYSDOH. 1993. New York State Department of Health. Survey of dry cleaning facilities in Capital
District, New York, and New York City. Previously unpublished.
NYSDOH. 1998. New York State Department of Health. Tetrachloroethene Ambient Air Criteria
Document. January.
OCIS. 1994. OSHA Computerized Information System. Set of 3 data reports generated by OCIS staff for
USEPA. January.
OCIS. 1998. OSHA Computerized Information System. Set of 2 data reports downloaded from OCIS by
USEPA. January and March.
4-47
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Patton et al., 1996. Patton, J., and W. Eyfing. Alternative Clothes Cleaning Demonstration Shop. Final
Report. Center for Neighborhood Technology. September.
PEI 1985 PEI Assoc., Inc. Occupational exposure and environmental release assessment of
tetrachloroethylene. USEPA, Office of Pesticides and Toxic Substances. Washington, DC.
December.
Radian 1993 Radian Corporation. Memorandum from Amigo etal. of Radian Corp. to the Dry Cleaning
NESHAP Project File (USEPA Air Docket A-88-11). Summary of findings from a well
investigation project conducted by the California Water Quality Control Board. August.
Safety Kleen. 1986. Dry cleaning waste market analysis. Materials from Safety Kleen presentation to
USEPA. November 12.
Schreiber, J., S. House, E. Prohonic, G. Smead, C. Hudson, M. Styk, and J. Lauber. 1993. An
investigation of indoor air contamination in residences above dry cleaners. Risk Analysis,
13(3): 335-344.
Schreiber J 1997. Transport of organic chemicals to breast milk: Tetrachloroethylene case study.
Chapter 5 of Environmental Toxicology and Pharmacology of Human Development. Kacew, S.
and Lambert, G., eds. Taylor and Francis.
Sheldon L R. Handy, T. Hartwell, C. Leininger, and H. Zelon. 1985. Human exposure assessment to
environmental chemicals - nursing mothers study. Prepared for USEPA by Research Triangle
Institute. Research Triangle Park, NC.
Solet et al., 1990. "Perchloroethylene exposure assessment among dry cleaning workers." Am. Ind. Hyg.
Assoc. J. 51(10):566-574. [as cited in Thompson and Evans, 1993]
Stasiuk W 1993 Letter from William Stasiuk, Director, Center for Environmental Health, State of New
Vork Department of Health, to Bruce Jordan, USEPA. Attachment E: Summary of Groundwater
Contamination Related to Dry Cleaners.
Staub W and E. Schwarzbach. State Environmental Protection Agency, Hertzstrasse, Germany, 1992.
The Measurements of Tetrachloroethylene Concentrations in the Work Rooms of Dry Cleaning
Establishments and in Rooms Adjacent to Dry Cleaners in the German state of Baden-
Wurttemberg. Final Report. Translated by Abt associates for the USEPA.
Thomas K E. Pellizari, R. Perritt, and W. Nelson. 1991. Effect of dry-cleaned clothes on
tetrachloroethylene levels in indoor air, personal air, and breath for residents of several New Jersey
homes. Journal of Exposure Analysis and Environmental Epidemiology, Vol. 1, No. 4., 475-490.
Thompson, K. and J. Evans, 1993. Workers' breath as a source of perchloroethyelene (perc) in the home.
Journal of Exposure Analysis and Environmental Epidemiology, Vol. 3, No. 4, 417-430.
4-48
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Tichenor, B., L. Sparks, M. Jackson, Z. Quo, M. Mason, C. Plunkett and S. Rasor. 1990. Emissions of
Perchloroethylene from Dry Cleaned Fabrics. Atmospheric Environment, 24A(5): 1219-1229.
Toutonghi, 1992. "Characterization of perchloroethylene exposure in commercial dry cleaning workers
with biological monitoring." M.S. Thesis, University of Washington, Department of
Environmental Health, [as cited in Thompson and Evans, 1993]
Tsang, A.M., and Klepeis, N.E. 1996. Results tables from a detailed analysis of the National Human
Activity Pattern Survey (NHAPS) response. Draft report prepared for the U.S. Environmental
Protection Agency by Lockheed Martin, Contract No. 68-W6-001, Delivery Order No. 13.
USEPA. 1982. U.S. Environmental Protection Agency. Guideline series: Control of volatile organic
compound emissions from large petroleum dry cleaners. EPA-450/3-82-009. USEPA, Office of
Air Quality, Planning and Standards. Research Triangle Park, NC.
USEPA. 1985. U.S. Environmental Protection Agency. Health assessment document for
tetrachloroethylene (perchloroethylene). EPA/600/8-82/005F. PB-85-249704/AS. USEPA,
Office of Health and Environmental Assessment. Washington, DC.
USEPA. 199la. IT Corporation for the USEPA/OTS. Chemical engineering branch manual for the
preparation of engineering assessments. Prepared for USEPA, Office of Toxic Substances,
Chemical Engineering Branch. Washington, DC. February.
USEPA. 1992a. U.S. Environmental Protection Agency. USEPA proceedings: international round table
on pollution prevention and control in the dry cleaning industry. May 27-28.
USEPA. 1992b. U.S. Environmental Protection Agency. Preliminary economic assessment of transfer
enclosure requirements in the dry cleaning industry. USEPA, Office of Air Quality, Planning and
Standards. Research Triangle Park, NC. August.
USEPA. 1992c. U.S. Environmental Protection Agency. Guidelines for exposure assessment (57 FR
22888 - 22938).
USEPA. 1993. U.S. Environmental Protection Agency. Dry cleaning industry MACT standard. Briefing
for the Deputy Administrator. USEPA, Office of Air and Radiation. May 24.
USEPA. 1995. Draft guidelines for completing the initial review exposure report. Office of Pollution
Prevention and Toxics. USEPA.
USEPA. 1997a. U.S. Environmental Protection Agency. Cleaner Technologies Substitute Assessment
Peer Review Comments.
USEPA. 1997b. U.S. Environmental Protection Agency. Exposure Factors Handbook, Volumes I-III
EPA/600/P095/002Fa. Office of Research and Development
4-49
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Wallace D., E. Groth, E. Kirrane, B. Warren, and J. Halloran. 1995. Perchloroethylene in the air in
apartments above New York City dry cleaners: A special report from Consumers Union.
Wallace, D. 1995. Perchloroethylene Exposures from Dry Cleaned Clothes. Project T-1693.
Wallace L 1989 The Total Exposure Assessment Methodology (TEAM) Study: An Analysis of
Exposures, Sources, and Risks Associated with Four Volatile Organic Chemicals. Journal of the
American College of Toxicology. Volume 8, Number 5, 883-895.
Wolf, K. 1992. Case study: pollution prevention in the dry cleaning industry: a small business challenge
for the 1990s. Pollution Prevention Review, Summer.
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CHAPTER 5
RISK
This chapter integrates the hazard,
dose-response, and exposure assessments for
several major commercial clothes cleaning
processes into a risk assessment for each of the
cleaning processes and characterizes the risks as
to key issues, major assumptions, and
uncertainties. Section 5.1 provides definitions
of terms common to risk assessment and
descriptions of methodologies. Section 5.2
presents estimates of potential risks to workers,
co-located residents (i.e., residents in buildings
with drycleaning facilities), and the general population, as well as environmental risks from
perchloroethyiene (PCE). Section 5.3 estimates potential risks from drycleaning operations using
hydrocarbon (HC) technology. Section 5.4 evaluates the risks associated with machine wetcleanint
5.1
5.2
5.3
5.4
CHAPTER CONTENTS
Risk Characterization-Introduction
Drycleaning Using Perchloroethyiene
(PCE)
Drycleaning Using Hydrocarbon (HC)
Solvents
Machine Wetcleaning Process
5.1 RISK CHARACTERIZATION—INTRODUCTION
5.1.1 Scope of the CTSA Risk Assessments
This chapter integrates the.hazard, dose/response, and exposure assessments for several
commercial clothes cleaning technologies into a risk assessment for each of the cleaning processes and
characterizes the risks as to key issues, major assumptions, and uncertainties. A summary and
characterization of risk are given for each of the following cleaning processes: drycleaning with PCE;
drycleaning with HC; and machine wetcleaning. When information is available, risks for exposures to
different machinery within processes are also addressed.
The risk assessments were conducted at a "screening level" of review, using readily available
information and standard analyses for completion. The risk assessments and characterizations should give
an idea of the risks to human health and the environment associated with each of the processes and offer a
basis for comparison. However, since the extent and type of hazard and exposure data and uncertainties
associated with each process differ widely, the risk comparisons among processes will give only a general,
"ballpark" type of comparison. Information is developed with the intent of identifying the types of
potential health and environmental risks associated with various clothes cleaning technologies to allow
clothes cleaners to better understand the potential implications of technology choices. The information is
organized to provide general background on terminology and elements of risk assessment and to present
general risk characterizations for individual technologies.
5.1.2 Background Information on Human Risk Assessment Methodology
This section presents general information to increase understanding of the risk assessment process
used in this CTSA document. The principles of the risk assessment process are defined, and general
methodologies used in classifying potential human health risk are explained. (A description of ecological
risk methodology is given in Appendix B.)
5-1
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Chapte
Risk
Definitions—Risk Assessment
A risk assessment is an interactive process that generally includes the following components of
analysis:
(1) Hazard Assessment & Characterization, the process of determining whether or not exposure to
a chemical can cause adverse health effects in humans. It includes explanation of the evidence of
toxicity and describes major points of interpretation and assumptions. In addition, it explains
strengths and weaknesses of the data and analyses, as well as major uncertainties.
(2) Dose-response Assessment & Characterization, the process of defining the relationship
between the dose of a chemical received and the incidence and severity of adverse health effects in
the exposed population. From a quantitative dose-response relationship, toxicity values are
derived and used in the risk characterization step to estimate the likelihood of adverse effects
occurring in humans at different anticipated exposure levels. It includes explanation of key
scientific issues and assumptions, strengths and weaknesses of the data and analyses, and major
uncertainties.
(3) Exposure Assessment & Characterization, which identifies populations exposed to a chemical,
describes their composition and size, and presents the types, magnitudes, frequencies, and
durations of exposure to the chemical. It includes discussion of key issues, description of methods
used, and strengths and weaknesses of the data and analyses. Major uncertainties are also
discussed.
(4) Risk Characterization, which integrates hazard, exposure, and dose-response information into
qualitative and/or quantitative expressions of risk. A risk characterization includes a description of
the major assumptions and key issues, scientific judgments, strengths and weaknesses of data and
analyses, and the uncertainties embodied in the assessment.
Methods—Expressions of Human Health Risk
The manner in which estimates of hazard and risk are expressed depends on the human health
endpoint of concern and the types of data upon which the assessment is based. Overall, cancer risks are
most often expressed as the probability of an individual developing cancer over a lifetime of exposure to
the chemical in question. Risk estimates for adverse effects other than cancer are not expressed as
probabilities of occurrence; instead, a concentration or dose associated with the presence or absence of a
specific toxic endpoint of concern is compared to an estimated dose or exposure level for the population
considered. This comparison is expressed as a ratio, which is an indicator of the margin by which the
population's exposures differ from (exceed or not) levels where individuals are expected to be free of
adverse/deleterious effects. A key distinction between cancer and other toxicologic effects is that most
carcinogens are generally assumed to have no dose threshold; i.e., no dose or exposure level can be
presumed to be without some risk. Other toxicologic effects are generally assumed to have a dose
threshold; i.e., a dose or exposure level below which a significant adverse effect is not expected.
Sometimes understanding a process requires characterization of a mixture of chemicals, rather than
a single one. Under ideal circumstances, information would be available for the mixture or formulation.
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Chapter 5
Risk
More typically, information is available on at least some ingredients (components). Often, certain
components are exchangeable, with selection based on their function in the process, but with exposure and
toxicity properties unique to the selection. In Section 5.4, information on examples of these selections will
be provided for the machine wetcleaning process. Quantitative assessment of mixtures using their
components often relies on the assumption that the components produce their toxicities independently;
information on ways one or more components may modify others is incorporated qualitatively. Mixtures
with just a few ingredients may be characterized more readily than mixtures with many dissimilar
ingredients.
Quantitative Expressions of Risk - Not all substances evaluated for the CTSA have been reviewed
previously or have sufficient data available for quantitative expressions of risk. Only PCE has such
information for cancer. Only PCE and some hydrocarbon solvents have such information for quantitative
expression of other risks.
Cancer Risk Assessment
USEPA employs a "weight-of-evidence" approach to determine the likelihood that a chemical is a
human carcinogen. The USEPA's Cancer Risk Assessment Guidelines (USEPA, 1986) and in particular,
its proposed cancer guidelines (USEPA, 1996), emphasize the use of all pertinent information, not just
tumor findings in animals or humans, in making a decision about a chemical agent's carcinogenic
potential. This recognizes that information about mode of action of carcinogenic agents at the cellular and
sub-cellular levels, as well as toxicokinetic and metabolic process information, should play an important
role in evaluating carcinogenic toxicity. According to the 1986 guidelines, EPA describes a chemical's
carcinogenic potential by placing it in one of five weight-of-evidence categories [from Group A (human
carcinogen) to Group E (evidence of noncarcinogenicity for humans)] and providing a "basis" statement.
The 1996 proposed guidelines recommend major categories (and subcategories) that would be more
informative by requiring a brief narrative of information on all the evidence available to be included with
each category. In extracting information for this chapter, the CTSA, as a screening level assessment, has
aimed to incorporate the spirit of the narrative approach rather than categories per se.
Cancer Risk Indices -Where the available data are sufficient for dose-response assessment, EPA has
developed an estimate of the chemical's carcinogenic potency. An oral "slope factor" expresses
carcinogenic potency in terms of the estimated incremental upper bound excess lifetime risk per mg/kg
average daily dose ingested. "Unit risk" is a similar measure of potency for air or drinking water
concentrations and is expressed as risk per ug/m3 in air or as risk per ng/L in water for continuous lifetime
exposures. Underlying the unit risk concept is the assumption that the relationship between dose and level
of excess risk is linear; that is, for a given incremental change in dose, there is a proportional change in
estimated risk level. This is referred to as the "linear at low dose" approach throughout this assessment.
The unit risk or slope factor is regarded as an upper bound on the incremental lifetime excess cancer risk
because it is derived in a way intended to account for experimental variability and extrapolation
uncertainties. The lower bound on lifetime excess cancer risk is always recognized to be as low as zero.
As described in Appendix D, where possible the experimental data can be used to estimate a magnitude of
excess risk, but can only suggest how well the upper bound reflects true excess.
Cancer excess risk is calculated by multiplying the estimated dose or exposure level by the
appropriate measure of carcinogenic potency. For example, an individual with a lifetime average daily
5-3
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~. . e
Chapter 5
dose of 0 3 mg/kg of a carcinogen with a slope factor of 0.02 per mg/kg/day would experience a lifetime
excess cancer risk of 0.006 [6 X 10'3 or a risk of 6 in 1000] from exposure to that chemical. These risks
are identified as incremental over background; i.e., beyond those ordinarily sustained by the general
population with no particular exposure to the chemical. In general, risks from exposures to more than one
carcinogen are assumed to be additive, unless information points toward a different interpretation; that is,
when available, component quantitative estimates may be summed to obtain the mixture's estimate.
Risk Assessments for Human Health Toxicities Other Than Cancer
Because adverse effects other than cancer and gene mutations are generally assumed to have a
dose or exposure threshold, a different approach is widely used to evaluate potential risk for these non-
cancer effects, such as liver toxicity, neurotoxicity, and kidney toxicity. EPA uses the Reference Dose
(RfD) or Reference Concentration (RfC) approach to evaluate such chronic effects. The RfD or RfC is
defined as "an estimate (with uncertainty spanning perhaps an order of magnitude) of a daily exposure to
the human population (including sensitive subgroups) that is likely to be without appreciable risk of
deleterious effects during a lifetime" and is expressed as a mg/kg/day dose or mg/m3. The RfD or RfC is
usually based on the most sensitive known effect; i.e., the effect that occurs at the lowest dose. The basic ^
approach for deriving an RfD or RfC involves determining a "no-observed-adverse-effect level (NOAEL)'
or "lowest-observed-adverse-effect level (LOAEL)" from an appropriate animal study or human
epidemiologic study, and applying various uncertainty and modifying factors to arrive at the RfD/RfC.
Each factor represents a specific area of uncertainty. For example, an RfD based on a NOAEL from a
long-term animal study might incorporate a factor of 10 to account for the uncertainty in extrapolating
from the test species to humans, and another factor of 10 to account for the variation in sensitivity within
the human population. An RfD based on a LOAEL typically contains yet another factor of 1 0 to account
for the extrapolation from LOAEL to NOAEL. An additional modifying factor (between 1 and 10) is
sometimes applied to account for uncertainties in data quality.
To characterize potential risk of adverse health effects other than cancer, a "Hazard Quotient"
method is calculated. A "Hazard Quotient" is the ratio of the estimated chronic dose/exposure level to the
RfD/C. Hazard Quotient values below unity imply that adverse effects are very unlikely. The more the
Hazard Quotient exceeds unity, the greater the level of concern. It is important, however, to remember that
the Hazard Quotient is not a probabilistic statement of risk. A quotient of 0.001 does not mean that there js
a one-in-a-thousand chance of the effect occurring, it just means that the event is "very unlikely to occur."
Furthermore, it is important to remember that the level of concern does not necessarily increase in a linear
manner as the quotient approaches or exceeds unity, because the RfD/C does not provide any information
about the shape of the dose-response curve.
In general, the index of a mixture is derived by summing the Hazard Quotients for each of its
components. Risks from exposures to more than one chemical are considered individually for each type of
toxicity and organ affected.
An expression of risk that can be used with non-cancer toxicity evaluations when an RfD/C is not
available is a ratio of the expected exposure to a NOAEL or LOAEL from an animal or human study
(preferably a chronic study). This alternate approach is meant to determine the proximity of the exposures
from the various scenarios for humans to the animal or human experimental range. As with the Hazard
5-4
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Chapter 5
Risk
Quotient, it is important to remember that this ratio is not a probabilistic statement of risk. Further, if the
ratio is based on a LOAEL, even a ratio of unity may not indicate low concern.
Interpreting the Risk Results: Risk Estimates in the Tables and Text
The tables present Risk Indices for cancer risk and Hazard Quotients for non-cancer risks. The
Risk Indices are an estimate of individual cancer risk above background level (and are expressed, for
example, as 1 x 10"2 or a 1 in 100 risk). The Hazard Quotients are ratios of the expected human exposure
to RfC or RfD values.1 Hazard Quotients above 1 (which indicate exposure values greater than the RfC or
RfD) are considered less likely to be free of deleterious effects.
In general, the index of a mixture is derived by summing the component Hazard Quotients. Risks
from exposures to more than one chemical are considered individually for each type of toxicity and organ
affected. When the component RfD/Cs reflect different toxicities or target organs, an index analogous to
the Hazard Quotient can be formed, using a target organ toxicity dose based on NOAELs or modeled
levels (Mumtaz et al., 1997). A sum based solely on all the component RfD/Cs is believed to be high for
specific organ toxicities. Thus, there may be several quantitative indices for a particular formulation.
When each index is less than 1, and all relevant effects have been considered and are believed to be
independent, it may be more appropriate to consider the formulation free of significant toxicity overall than
when the indices are less than 1 but important information is missing (such information might indicate that
the ingredients interact). Such an analysis is usually not conducted when some components do not have
RfD/Cs.
Exhibit 5-1 summarizes the different exposure scenarios evaluated by the CTSA in Chapter 4,
which are considered for discussion of risk in this chapter.
Note: the provisional occupational RfC used in the Hazard Quotients dealing with occupational exposures of PCE differs
from the provisional RfC used for all other PCE exposure scenarios, and any RfC in non-PCE exposure scenarios. This is due to the
use of an uncertainty factor of 10 only, in the derivation of the provisional RfC for the PCE occupational scenario (see Appendix D).
_ _
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Chapter 5
Risk
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Chapter 5
Risk
5.2 DRYCLEANING USING PERCHLOROETHYLENE (PCE)
5.2.1 Human Health
Human data indicate that PCE is absorbed into the body via inhalation, from the gastrointestinal
tract following ingestion, and through the skin. There is human evidence indicating that PCE can cause
neurotoxicity and kidney effects, and animal data show that PCE can cause other effects, including cancer,
developmental toxicity, and liver effects. Toxicity comparison values for use in risk assessment are shown
in Exhibit 5-2.
Exhibit 5-2. Toxicity Comparison Values for PCE Risk Assessment
Effect
Cancer3
Cancer3
Cancer
Critical effects (i.e.,
most sensitive
effects)
Toxicity
Value
0.00071 per mg/m3
270 mg/m3
.051 per
mg/kg/day
0.01 mg/kg/day
0.17 mg/m3
Toxicity
Value
Type
Unit risk
ED10
Oral Slope
factor
RfD
"DfO "b
KTL/PCE
Basis for Toxicity Value:
Species/
, Duration/Route
Mouse and rat 2 year
inhalation bioassay+
inhalation metabolism
information0
Mouse and rat 2 year
inhalation bioassay +
inhalation metabolism
information0
Mouse 2 year gavage
bioassay + gavage
metabolism information"
Mouse 6 week gavage study
(liver)6
"RfC": Human cross-
sectional occupational study
(renal)'
a Derivation of the unit risk.and ED10 values are described in Appendix D. Unit risk is 7.1 x 10'7
per ug/m3, which is converted to mg/m3 by multiplying as follows:
7.1 x 10'7 per ug/m3 x 1,000 ug/mg = 7.1 x 10"4 per mg/m3, or 0.00071 per mg/m3.
b RfCPCE is a provisional RfC developed specifically for use in this document. Unlike the other
RfCs and RfDs in this document, it has not undergone formal USEPA review and approval.
Details on the derivation of the provisional RfC can be found in Appendix D.
°NTP(1986).
d NCI (1977).
e ATSDR (1993), Buben and O'Flaherty (1985), IRIS (1997).
' Franchini et al. (1983).
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Chapter 5
Risk
5.2.2 Human Health Risks
Risk—General
In this section, the hazards and dose-response relationships of PCE are integrated with individual
exposure scenarios to address potential risks of PCE to humans and the environment. These risks are
presented in tables and discussed with each exposure scenario.
For PCE, in addition to the linear at low dose approach described in Section 5.1.2, a second
approach is used. As discussed in Appendix D, questions remain as to the appropriate use of a linear
model to represent relative cancer risks at low exposures to PCE. Therefore, a measure of relative risk,
suggested by USEPA (1996), is also used in this assessment. This is called the Margin of Exposure
(MOE) nonprojection approach (see Appendix D). The intent of the nonprojection approach is to
determine the proximity of the exposures from the various scenarios for humans to the animal experimental
range, roughly represented by the ED10, the dose (in human equivalents) associated with an estimated
excess tumor response in 10% of an experimental group. [Note: the acronym ED10 has no relation to the
acronym ED (exposure duration) used extensively in Chapter 4.] The comparison is evaluated by the ratio
of the ED10 to expected exposure. The ratio is evaluated in this direction because it is hoped that exposures
will be far from the range where an excess 10% of the population would show cancer, and a large ratio will
be easier to evaluate. Again, the aim of using any approach is to highlight those PCE exposure scenarios
that may warrant the most attention for possible risk reduction.
Quantitative Expressions of Risk—Cancer Risk Indices
Relative indices of cancer risk to exposed population groups are presented for various exposure
scenarios. These indices are derived as follows:
• For each exposure scenario, an estimated inhalation exposure of PCE in milligrams per cubic
meter (mg/m3) is averaged over a lifetime to generate a Lifetime Average Daily Concentration
(LADC). [Footnote "a" in Exhibit 5-3 gives an example of such a calculation.]
• The calculated LADCs are multiplied by the unit risk of 0.00071 per mg/m3 (unit risk is defined in
section 5.1.2) to give linearly-based upper bound lifetime excess risks, called "linear risk indices"
hereafter; or divided into the EDIO of 270 mg/m3 to give MOE indices.
In comparing scenarios in these exhibits, one linear risk index value is of greater concern than
another if it is larger, e.g., 2 x 10'3 (0.002) is of more concern than 5 x 10'4 (0.0005).
When considering oral exposure scenarios, the Lifetime Average Daily Dose (LADD) is used (see
footnote "a," Exhibit 5-7, for sample calculation) instead of the LADC. The LADD is multiplied by 0.051
per mg/kg/day, the slope factor used for oral exposure to PCE (USEPA, 1985), to give a linear risk index
value.
The comparison toxicity values and cancer comparison values for use in risk assessment are shown
in Exhibit 5-2. These values are compared with predicted (modeled) human exposures to determine
5-8
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Chapter 5
Risk
whether any of the PCE exposure scenarios poses a concern for cancer or non-cancer effects to the people
exposed.
Routes of Exposure
Inhalation
Human exposure to PCE occurs in three ways; inhalation, oral, and dermal. By far, inhalation
exposure is the most significant route of exposure. PCE is well absorbed from the lung following
inhalation exposure. For purposes of this risk assessment, inhalation and oral doses are assumed to be
absorbed 100% into the body.
Oral
Oral exposure to PCE may occur from ingestion of contaminated drinking water or foods (not
evaluated here), or from ingestion of breast milk from PCE-exposed mothers. PCE is well absorbed from
the gastrointestinal tract following ingestion. Metabolism of absorbed PCE is expected to be low, roughly
20%(USEPA 1985).
Dermal
Dermal absorption is possible from activities that require contact with PCE, as might occur in
occupational settings. Dermal absorption can occur not only from direct contact with the liquid, but also
from contact with the vapor in the air. Dermal absorption from the liquid state can be modeled. Dermal
absorption from vapor may be estimated as approximately equal to the amount absorbed by the inhalation
route at low exposure levels (e.g., 58 ppm); or it may be as low as 1% of the amount absorbed by the
inhalation route at higher doses (e.g., 600 ppm) [McDougal et al., 1990; Riikimaki and Pfaffli, 1978; as
cited in Keifer 1998. Refer to Appendix C.]
5.2.3 Occupational Risks—Drycleaning Workers
Risk from PCE Inhalation
The number of workers exposed to PCE in.drycleaning facilities is estimated to be between
119,000 and 278,000 (Chapter 4). The most significant route of exposure for workers is expected to be
from inhalation of PCE, although they may also experience dermal exposure. Several data sets provided
maximum exposure concentrations (ECs) for PCE inhalation by drycleaning workers. Average ECs were
also provided in some of these data sets, and calculated from others. The data are discussed extensively in
Chapter 4 and illustrate variations in worker inhalation exposures due to factors such as machine type and
controls, number of machines, job category, and date of PCE exposure. In general, increased exposures to
PCE would result in an increase in health risk. Therefore, indications (as summarized in Chapter 4) that
there are higher PCE exposures for operators/cleaners compared with other job categories; and for workers
exposed to transfer machines compared with dry-to-dry machines; and for workers exposed to more than
one machine, are also indications for increased health risks to these workers. On the other hand,
indications (Chapter 4) that there has been a general decrease in drycleaning exposures to PCE over the
past decade, and that new,"fifth generation" machines result in lower worker exposures, indicate health
5-9
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Chapter 5
risks can be decreased for workers in those situations. The extent of such trends is variable and is not
estimated for this CTSA.
Two studies That include the largest numbers of measurements (OCIS, 1994, 1998; and IFI, 1990)
are used for the purpose of assessing workers' risk. The data from these two sources are presented in
Exhibits 5-3 and 5-4 and discussed below.
Exhibit 5-3. Occupational Health Risks Via Inhalation to Workers Based on Post-1990 OSHA
Monitoring Data for PCE Drycleaning
Job
Description
#1
1990to1993
All Jobs
[N=386]
Cleaner
[N=157]
Spotter
[N=37]
Manager
[N=43]
Presser [N=41]
Geometric
MeanEC'
(mg/m3)
(+) GSD
#2
Maximum EC
(mg/m3)
#3
69 + 62
80 ±76
53 + 77
250 + 31
37 ±39
5,000
5,000
1,100
4,300
470
LADC1
(mg/m3)
#4
Cancer Risk
Index9
(Unit risk"
x LADC)
#5
14
16
10
49
7
1 x 10'2
>1 x10'2d
7x 10'3
>1 x 10'2d
5x10'3
1997
All Jobs [N=40]
42 + 51
2,500
8
6X10'3
Non-Cancer
Hazard
Quotient'
LADC / Prov.
Occ. RfC
#6
8.2
9.5
5.8
1.7
4.1
4.5
' LADC = Exp. x 10 m3 x 250 days x 40 years
20 m3 365 days 70 years
where Exp. = Mean exposure concentration (occupational exposure) in mg/m3
10 m3 = Volume of air inhaled during an 8 hr workday
20 m3 = Volume of air inhaled in 24 hours
250 days = Days worked per year for the average worker (this is not the same as the number of days the
facility is in operation)
365 days = Days per year
40 years= Years worked in a lifetime
70 years = Average lifetime
" The Unit Risk is 0.00000071 per pg/m3 x 1,000 ug/mg = 0.00071 per mg/m3.
e ED,0 = 270 mg/m3
d The LADC exceeds the limit for use of the unit risk
(Note: when LADC exposure levels are >14 mg/m3, the unit risk should not be used ; therefore, the risk indices
are listed as >1 X 10-z , see Appendix D).
* The geometric means are used because these have been used historically with occupational data. A
geometric mean gives a feel for the median or 50th percentile of values. GSD= Geometric Standard Deviation.
1 Provisional occupational RfC = 1.7 mg/m3 TWA (see Appendix D) Sample HQ: "All Jobs": HQ = 14 mg/m3/1.7
mg/m3 = 8.2.
0 Cancer risk index = upper bound lifetime excess cancer risk.
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Chapter 5
Risk
Exhibit 5-3 presents data on PCE inhalation collected by OSHA during compliance inspections or
complaint investigations for 1990-93 and for 1997 (OCIS 1994, 1998). Column #1 lists job descriptions
and the number of persons sampled from each job category. In 1997, information for "all jobs" is
presented. The OSHA data do not give the types nor numbers of drycleaning machines used.
Column #2 presents average PCE exposure concentrations in mg/m3 presented as geometric
means, and Column #3 gives maximum exposure concentrations in mg/m3. As indicated by the large
geometric standard deviations, there is wide variation around the mean exposures. In addition, there are
some occasions when exposures can be quite high, as shown in Column #3. Column #4, LADC (Lifetime
Average Daily Concentration), assumes that a worker spends 40 years in the drycleaning industry at mean
exposure concentrations.
Column #5 gives an indication of upper bound lifetime excess cancer risk for each job type, given
average exposures. It can be inferred from the Risk Index that the estimated excess risk for cancer is likely
high for workers in all job categories (between 1 in 100 and 6 in 1000). Also, it can be seen from the table
that the PCE lifetime average daily concentrations (LADC) for workers in most job categories are only
about 20-fold lower than the EDIO dose of 270 mg/m3 [ i.e., the dose in human equivalents at which 10% of
the animal study population showed excess tumors; see Exhibit 5-2]. Using a margin of exposure (MOE)
nonprojection ratio approach as an alternate way of looking at cancer risk shows that there is not much
margin between the ED]0 and the workers' average concentration levels. (When MOEs are calculated for
the average exposure levels of the six worker job categories, they range from 6 to 39). MOEs for workers
at the maximum range from 0.02 to 0.6, indicating that there is virtually no margin of exposure from the
projected 10% effect level to the workers' exposure for each worker job category.
An assessment of non-cancer risk is given in Column #6. This column lists hazard quotients
(HQs) for the six worker job categories for lifetime average daily exposures. All the HQs were greater
than 1, indicating a concern for non-cancer toxicity risks to these workers. Also, since there is some
indication from animal studies that PCE can cause developmental toxicity at high exposures, there would
be concern for developmental toxicity at the maximum PCE levels above 2,000 mg/m3 (see Appendix C for
discussion of developmental toxicity).
Exhibit 5-4 (derived from Exhibit 4-5) uses data from a study conducted by the International
Fabricare Institute (IFI, 1990). It shows the mean inhalation exposures and subsequent health risks to
workers described as "operators" and as "non-operators." It also considers PCE exposures from "dry-to-
dry" and "transfer" machines separately. Exposures from transfer machines are greater for both job
categories.
Column #1 lists both job descriptions—"operators" and "non-operators"—as well as two types of
machines, "transfer" and "dry-to-dry," to which the workers were exposed. Column #2 gives the average
exposure concentrations in rhg/m3 as arithmetic means. These data show that "operators" have greater
average PCE exposures than "non-operators," regardless of machine type. It also shows that workers in
facilities with transfer machines had greater average exposures than workers in facilities with dry-to-dry
machines. Column #3, "Risk Index," gives an indication of upper bound lifetime excess cancer risk for
operators and non-operators, each group exposed to PCE from transfer machines, or from dry-to-dry
machines. It can be inferred that the estimated excess risk for cancer is projected to be high (1 in 100 or
greater) for both job categories.
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Chapter:
Risk
Exhibit 5-4. Occupational Health Risks to Drycleaning Workers From PCE Inhalation
by Job Title and Machine Type
Job Description/
Machine Type
#1
Arithmetic
Mean Exp.a
(mg/m3)
#2
LADCb
(mg/m3)
#3
Cancer Risk Index0
(Unit risk
x LADC)
#4
Operators
Dry-to-dry (N=1, 301)
Transfer (N=1 ,027)
115
328
23
64
>1 x 10'2
>1 x10'2
Non-operators
Dry-to-dry (N=497)
Transfer (N=508)
79
179
15
35
1 x10'2
>1 x10'2
Non- Cancer
Hazard Quotient"
LADC/Prov. Occ.
RfC
#5
13.5
37.6
8.8
20.6
a Arithmetic means used because only arithmetic means were reported in published study.
b LADC calculated as for Exhibit 5-3. (Note: when LADC exposure levels are >14 mg/m3, the unit risk
should not be used; therefore, the risk indices are listed as >1 X 10'2. See Appendix D).
c Cancer risk index = upper bound excess lifetime cancer risk.
d Provisional occupational RfC = 1.7 mg/m3 TWA (see Appendix D). Sample HQ: "Operators Dry-to-dry :
HQ = 23 mg/m3/1. 7 mg/m3 = 13.5.
In addition, if we use a margin of exposure (MOE) nonprojection ratio approach to compare the
lifetime average daily concentrations (LADC) of PCE for workers in both job categories with the EDIO of
270 mg/m3, we find that the workers' exposures are about 10-fold lower than the EDI0. When MOEs are
calculated for the four scenarios listed in Exhibit 5-4 they range from 4 to 18.
An assessment of non-cancer risk, using the hazard quotient (HQ) approach, is given in Column
#5. All of the HQs are greater than one indicating a potential for non-cancer toxicity to these workers.
Risk From Dermal Exposures
Drycleaning workers are not only exposed to PCE through inhaling the vapor, but also through
dermal contact. The two studies cited in Exhibits 5-3 and 5-4 give an indication of exposures and risks
due to inhalation. There are no comparable data, however, to assess worker dermal exposures to PCE, and
therefore, only a qualitative statement of risk can be made. Dermal exposures can occur through exposures
to liquid PCE, such as when handling wet clothes, or when the skin is exposed to PCE vapor present in the
workplace. Chapter 4 used a model to estimate possible dermal exposures to liquid PCE. It assumed
1,300 cm2 as the surface area of two hands, and 24 minutes total duration of contact with the liquid. Using
this information, and limited information on absorption rates (Riihimaki et al., 1978; McDougal et al.,
1990; Bogen etal., 1992; in Keifer, 1998), a rough estimate can be made of PCE absorbed dermally by
workers.2
20.243 mg/cmVhour x 1,300 cm2 x 24 minutes/60 minutes/day = 126 mg/day divided by 70 kg = 1.8 mg/kg/day PCE
absorbed dermally from liquid contact.
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Chapter 5
Risk
Absorption of PCE vapor through the skin is another source of PCE exposure to workers in
drycleaning facilities. There are some very limited data indicating that PCE vapor can be absorbed through
the skin (Riihimaki et al., 1978; McDougal et al., 1990; Bogen et al., 1992; in Keifer, 1998). These data
indicate that absorption of PCE vapor through the skin may be equal to the amount of PCE absorbed via
inhalation'in situations where the PCE vapor levels are in the range of 58 ppm (400 mg/m3). In situations
where PCE vapor levels are 10-fold higher, (i.e., in the range of 600 ppm [4,000 mg/m3]), the amount
absorbed via the skin would be about 1% of that absorbed via inhalation.
It is assumed that dermal and inhalation exposures of PCE to workers would be additive and
dermal exposure could be an important route of entry of PCE into the body.
Combined Risks from Inhalation and Dermal Routes
The health risks to drycleaning workers from PCE depend on PCE entering the body through two
major routes—inhalation and through the skin. (Oral, hand-to-mouth exposure is not considered a major
route, but would also be added to the total risk). Dermal exposures can be from direct contact with liquid
PCE or PCE vapor. The risks from dermal exposures would be added to the risks indicated for inhalation
in Exhibits 5-3 and 5-4.
Risk Conclusions—Occupational Exposures
There is a reasonable basis to conclude that there can be a health risk for cancer and non-cancer
effects to workers from the relatively high PCE exposures observed on average in the drycleaning industry.
This conclusion is based on monitored worker inhalation exposure data from several sources, from
information about the circumstances of derma! exposures in the workplace and the absorption potential of
PCE through the skin, combined with evidence from animal studies indicating that PCE can cause cancer
and non-cancer toxicity in laboratory rodents. The cancer risk analysis used both the unit risk approach
and the MOE nonprojection ratio approach. The unit risk approach is tied to an upper bound lifetime
excess cancer risk estimate and there is the possibility that the lower bound is as low as zero.
The International Agency for Research on Cancer (IARQ recently reviewed the human and
animal cancer data on PCE (IARC, 1995). IARC concluded that PCE is a probable human carcinogen.
Although a provisional RfC was developed for potential non-cancer effects of PCE, to which
lifetime exposures would be compared, occupational exposures are properly compared to shorter-term
exposures. Because the provisional RfC, based on an occupational level, encompassed evaluation of all
types of possible effects, it may be expected that exposures in the workplace at monitored levels offer little
or no margin from deleterious effects of some kind. Also, there is an indication that there may be
developmental toxicity effects, since one of the studies in the database indicated developmental effects at
300 ppm (2,000 mg/m3) (Schwetz et al., 1975, as cited in Appendix C). This is an exposure level that
some workers exceeded.
It is concluded that workers in the drycleaning industry are potentially at some risk for cancer, and
for non-cancer effects. Also, pregnant workers exposed to short-term high PCE levels could be at risk for
developmental toxicity.
5-13
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Chapter 5
Risk
Uncertainties
The risk conclusions are based on readily available toxicity and exposure data and on models,
assumptions, and professional judgements about toxicity and exposure information. These give rise to a
variety of uncertainties and assumptions and influence, to a great extent, how close the assessment ot risk
comes to representing a realistic situation. The factors and uncertainties concerning worker risk
conclusions are listed below. Many of these are discussed in more detail in Chapter 4, and Appendices C,
D, andE:
The critical study for the provisional RfC does not permit a quantified dose-response relationship,
and does not characterize variability of the exposure concentrations; hence, some lower exposures
may still demonstrate the effects.
It is not clear whether the relationship between PCE dose and human cancer response is best
represented by the linear-at-low dose response model used.
The relevance of animal cancer studies to human carcinogenicity, and whether the mechanism of
action of PCE in animals is comparable in humans is under discussion.
It is not known how representative the occupational exposure studies are of actual exposures to
drycleaning workers nationwide. Since the OSHA data are gathered from compliance inspections
and compliant investigations, the measurements may not be representative of "average" exposures.
There are gaps in the human data for developmental and reproductive toxicity, and uncertainties in
the animal data, since the study cited included only one dose level.
The measured Time-Weighted Average samples of PCE may not be representative of the full 8-
hour shifts of most workers.
Variations in the workplace such as machinery maintenance, facility layout, machine controls,
work practices, amounts of clothes cleaned daily, and ventilation, may affect an employee's
exposure (and hence risk) from PCE. The extremely wide standard deviations in both worker
studies may be explained by some of these workplace factors.
5.2.4 Risks to Residents Co-Located with Drycleaning Establishments
Risks from PCE Inhalation
Co-located residents are persons living in the same building as a drycleaning facility that cleans
clothes on the premises. The term encompasses children and the elderly as well as adults. Currently it is
not known how many persons living in the U.S. are co-located residents. Monitoring studies indicate that
persons living in co-located residences are potentially exposed to elevated levels of PCE . Those
exposures, however, are not as high as those shown in Chapter 4 for workers. Studies have measured PCE
concentrations in apartments above drycleaners in New York, San Francisco, Germany, and the
Netherlands (BAAQMD, 1993; NYSDOH, 1993; Schreiber et al., 1993; Wallace et al., 1995).
Preliminary information reported in a recently published abstract (Schreiber et al., 1998) suggests that
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Chapter 5
Risk
5.2.4 Risks to Residents Co-Located with Drycleaning Establishments
Risks from PCE Inhalation
"' '"> Go-located residents are persons living in the same building as a drycleaning facility that cleans
clothes on the premises. The term encompasses children and the elderly as well as adults. Currently it is
not known how many persons living in the U.S. are co-located residents. Monitoring studies indicate that
persons living in co-located residences are potentially exposed to elevated levels of PCE . Those
exposures, however, are not as high as those shown in Chapter 4 for workers. Studies have measured
PCE concentrations in apartments above drycleaners in New York, San Francisco, Germany and the
Netherlands (BAAQMD, 1993; NYSDOH, 1993; Schreiber et al., 1993; Wallace et al., 1995).
Preliminary information reported in a recently published abstract (Schreiber et al., 1998) suggests that
some body fluid measures of PCE in co-located residents are higher than in control subjects who are not
co-located. •
Measured concentrations reported in these studies are highly variable, due to a number of factors.
These include machine type and condition, machine maintenance, building type, presence of a vapor
barrier, small numbers of measurements, and emissions from newly drycleaned clothes stored in the
facility (NYSDOH, 1993, 1994). Exposures, and therefore risks from PCE, are expected to vary widely
for co-located residents. The wide range of PCE concentrations is shown in Exhibits 4-9 and 4-10. Data
are presented by machine type to show their possible significance on measured PCE concentrations.
Monitoring data from four non-overlapping studies of PCE concentrations in U.S. residences co-
located with drycleaning establishments were used in assessing exposures and potential for risks to the
residents (references listed above). Measurements were taken at different locations, during different
seasons, and at different times of the day. (For a detailed discussion of the studies see Chapter 4). Since
the studies were conducted under different conditions, they cannot be combined for analysis. However,
they can be discussed together qualitatively. Together they give measured PCE concentrations in 62
separate residences co-located with drycleaning establishments.
Exhibit 5-5 illustrates the exposures and relative cancer risk indices for inhabitants of co-located
residences. The table lists the average airborne PCE concentrations measured in the four U.S. studies in
Column #1. It also indicates which measurements were taken from residences above different machine
types. Lifetime Average Daily Concentrations (LADCs) of PCE for adults living in co-located
residences are in Column #2, Average LADCs are based on residents' occupying a co-located residence
for 2.4 years; high-end exposures are based on an 8-year co-located residency.
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Chapter 5
Risk
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5-16
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Chapter 5
Risk
Upper bound lifetime excess cancer risks, as indicated by the risk indices in Column #3 for both
average and high-end exposure situations, range from 1 x 10'6(risk of 1 in a million) to >1 x 10'2 (>1 in
100). These data show that in general, lower exposures were seen in residences above dry-to-dry
machines, followed by vented dry-to-dry machines. These are associated with lower risks. The highest
exposures (associated with highest risk) were found in residences above transfer machines.. However, the
one highest exposure level (and highest estimated risk index) indicated in Exhibit 5-5 was measured in the
Capital District study in a residence above a vented dry-to-dry machine described as an old unit, "in poor
operating condition" (Schreiber et al., 1993). This illustrates that, while both the occupational data and
these data for co-located residences indicate higher exposures from transfer machines, machines of any
type in poor condition can release high concentrations of PCE.
The data in the table show that all the co-located residences have risk indices greater than
1 x IQ-6. These upper bound risks are projected for adults expected to be at home about 16 hours per day.
Sub-populations of persons who would spend approximately 23 hours per day at home (which can include
infants, children, and the elderly) are estimated to have exposures about 1.4 times those listed in Exhibit
5-5. Currently, we cannot assess whether these sub-populations are more or less sensitive than the
population as a whole to PCE exposure.
As a second method of assessing cancer risk for co-located residents, we can use the margin of
exposure (MOE) nonprojection ratio approach by comparing their average and high-end Lifetime Average
Daily Concentrations (LADCs) with the EDIO dose of 270 mg/m3 [ the level in human equivalents at which
10% of the animal study population showed excess tumors]. All of the average LADCs (except for the one
machine known to be in poor condition, cited in Schreiber et al., 1993) are close to, or greater than 1,000-
fold lower than the ED10dose. (When MOEs are calculated for these "average" co-located residents''
exposures, the MOEs range from 750 to 54,000, indicating a fairly large to very large margin from
exposure to effect level.3 This is also true for the high-end LADC co-located residents (those who spend at
least 8 years in the same residence), although the MOEs are lower, especially for residents above transfer
machines (MOEs range from 223 to 13,500).
Column #4 in Exhibit 5-5 gives hazard quotients (HQs) for non-cancer effects for average (2.4
years' residence) and high-end (8 years' residence) exposures for the co-located residents. HQ values
above 1 indicate a concern for non-cancer effects. The data presented in the table indicate concerns for
non-cancer risks to co-located residents living above transfer machines and vented dry-to-dry machines,
but not above nonvented dry-to-dry machines, regardless of duration of residence. This concern for risk
would also be true for infants, children, and the elderly living in the same residences, whose exposures are
estimated at about 1.4 times that of the adults in general. Data are not currently available to evaluate
whether these sub-populations are more pr less sensitive than the population as a whole to non-cancer
effects caused by PCE.
Sample MOE calculation: EDH/LADC = 270 mg/m3/0.18 = 1,500.
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Chapter 5
Risk
Risks from Dermal Exposures
As mentioned in the section on occupational risks, dermal absorption can occur from PCE vapor in
the air. There are limited data to suggest that the amount absorbed dermally can be equal to the amount
absorbed via inhalation at relatively low levels.
Combined Risks
The health risks to co-located residents from PCE are usually considered the sum of all risks due to
exposures through all major routes of the body. Data were available to give an indication of PCE
exposures through inhalation. No equivalent data were available for dermal exposures. It is possible that
an equivalent amount of PCE vapor could also be absorbed into the body through the skin. [This would
increase the mean exposure numbers listed in Exhibit 5-5, but the risk indices would still be of the same
order of magnitude].
The PCE exposures to the general population through such means as drinking groundwater,
showering and bathing, wearing drycleaned clothes, or taking them into the home, would also apply to co-
located residents. Risks from these exposure scenarios are discussed in the next section which deals with
general population risks. These general population risks would be added to the risk associated with co-
residency.
Risk Conclusions—Co-located Populations
There is concern that there can be a cancer risk to residents living in co-location with PCE
drycleaning establishments, particularly if they live in such dwellings for several years (indicated by high-
end risk indices). The cancer risk indices generally show rates higher than one in a million. The data
show that exposures and associated upper bound lifetime excess cancer risks appear to be higher for
residents living above transfer machines, although use of poorly maintained dry-to-dry machines also
causes high exposures. There is also concern for risk for non-cancer effects. Adults in residences above
nonvented dry-to-dry machines appear to have lower exposures. Co-located residents are also at risk
through a variety of PCE exposures that the general public experience, in addition to their exposures
related to co-location with drycleaning facilities. Risks potentially experienced by the general population,
such as drinking PCE-contaminated water, or wearing drycleaned clothes, would be added to the risks due
to co-location. Children, infants, and the elderly, who spend most of their day in the residence, may be at
slightly greater risk than adults in general for both cancer and non-cancer effects due to increased exposure
duration.
As stated previously, the cancer risk analysis approach (unit risk) is tied to an upper bound lifetime
excess cancer risk estimate and there is the possibility that the lower bound is as low as zero.
Uncertainties
The risk conclusions are based on readily available toxicity and exposure data and on models,
assumptions and professional judgements about toxicity and exposure information. These give rise to
many uncertainties and assumptions and influence, to a great extent, how close the assessment of risk
comes to realistic representation. In addition to uncertainties regarding the evaluation of PCE's toxicity,
which are enumerated in the section on occupational risks, selected prominent factors and uncertainties
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Chapter 5
Risk
concerning conclusions regarding co-located residents' risk are listed below. Many of these are discussed
in more detail in Chapter 4, and appendices C, D, and E:
• It is not known whether the exposure data presented can successfully represent co-located
residents nationwide, or whether there are major regional or local differences.
• Although conclusions about exposures are based on four U.S. studies, these studies were carried
out under different circumstances and may only be regarded individually. Each study in itself is
relatively small, and the complaint investigations may not adequately characterize exposure
comparisons between machine types;
• Although we discuss risks for residents exposed to estimated arithmetic mean PCE concentrations,
there is uncertainty as to what the mean concentration value is, since the individual exposure
studies show large variations (standard deviations).
• It is not clear whether the short-term sampling done in some of the studies may have missed major
fluctuations in exposures.
• It is not clear whether significant numbers of residents stay in their apartments for more than 8
years, or fewer than 2.4 years.
• In certain studies, the presence of drycleaned clothes in the residences may have added to
measured air concentrations.
5.2.5 General Population Risks
Risks from PCE Inhalation
In the mid-1980s, USEPA characterized general population exposures to a selected slate of
chemicals in four urban areas. The Total Exposure Assessment Methodology (TEAM) study reported 24-
hour concentrations of PCE from cloie to 1,000 personal samples of persons living in New Jersey,
California, Maryland, North Dakota, and North Carolina (Wallace, 1989). The monitored persons were
chosen to represent members of the general population in these areas. No persons in co-located residences
were included in the study.
This study was chosen for use in assessing risk for the CTSA because of its size, coverage of
several states, and personal sampling of people's indoor and outdoor exposures over several days. The
TEAM study hypothesized that the PCE exposure levels of the persons measured were due not only to
ambient air, but also due to PCE exposures from visiting drycleaning shops, wearing and being exposed to
others wearing drycleaned clothes, transporting and storing drycleaned clothes, and PCE from non-
drycleaning sources.
Exhibit 5-6 illustrates the exposures and risk indices associated with the residents' 24-hour
inhalation of combined indoor and outdoor air in a typical home not in proximity to a drycleaning shop.
The first entry in Column #1 in the table gives the Lifetime Average Daily Concentration of PCE for the
general population based on the 24-hour personal sample average exposures of the persons in the TEAM
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Chapter
study (0.017mg/m3). The CTSA exposure assessment (Chapter 4) assumed this exposure to be constant
over a lifetime (to be the Lifetime Average Daily Concentration). Therefore, it is listed as the LADC.
Average outdoor ambient air was measured in the TEAM study as 0.003 mg/m3, and was also assumed to
be constant over a lifetime. It is listed in the second entry in Column #1 of the table as the LADC, serving
as a background level.
Exhibit 5-6. General Population Cancer and Non-Cancer Risks from Inhalation of PCE
Exposed Population3
(24 hour exposure)
General Population-
Adults (daily activities
indoors & outdoors)
Ambient Air
LADC
(mg/m3)
#1
0.017
0.003
Cancer Risk lndexb
LADC x Unit Risk0
#2
1.2x10-5
2X10-6
Hazard Quotient
LADC/Provisional RfCd
#3
0.1
0.02
a TEAM Study, 1989
b Cancer risk index = upper bound lifetime excess cancer risk.
0 Inhalation Unit Risk = 0.00071 per mg/m3
d "Provisional RfC" = 0.17mg/m3
Exposures and corresponding cancer risk indices to the general population are lower than those in
most co-located residences (Exhibit 5-5), but are higher than PCE levels measured in ambient outdoor air
alone from the TEAM study . The calculated risk index of 1.2 x 10'5 for the general population seen in
Column #2 is above that from exposure to ambient air alone (2 x 10"6).
The LADCs for both the general population and ambient air are more than 1,000 times lower than
the ED10 of 270 mg/m3 [the level in human equivalents at which 10% of the animal study population
showed excess tumors]. These MOE nonprojection ratios indicate a large margin between expected
exposures and the effect level.4
Column #3 in Exhibit 5-6 shows the hazard quotients for non-cancer effects. The HQs are below
1, indicating lowered concern that deleterious effects will occur.-
Risk from PCE Ingestion
Exhibit 5-7 illustrates potential risks from exposures to PCE-contaminated water. The exposure
scenario for drinking water ingestion is based on measurements of PCE in contaminated groundwater from
two independent studies, Izzo (1992) and Stasiuk (1993). The California Regional Water Quality Control
Board took measurements from more than 215 wells, most of which were large system municipal wells.
Many wells contained PCE in excess of 5 ppb (parts contaminant per billion parts of water), California's
maximum contaminant level (MCL). The New York State Department of Health has also reported PCE
4LADC compared with ED,0: MOE= 270 mg/m3/0.017 mg/m3 = 15,882
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Chapter 5
Risk
concentrations in groundwater in public and private wells. They measured PCE in eight public wells at
concentrations from 61 to 640 ppb. (See Chapter 4 for further discussion.)
Exhibit 5-7 lists Lifetime Average Daily Doses ( LADDs) calculated for individuals assumed to
drink 1.4 liters of PCE-contaminated water each day. (See Exhibit 5-7 footnote LADD sample
calculation.) It was assumed for this CTSA that PCE contamination of municipal wells would be kept at or
below the 5 ppb maximum contaminant level (MCL). The range of the LADDs presented in Exhibit 5-7
would be the lifetime average daily dose expected from drinking water contaminated with PCE at a low of
0.8 ppb to the 5 ppb MCL. The cancer risk indices are also presented as a range from 1 x 10~7 to 5 x 10"7.
Therefore, if PCE contaminant levels are kept below the MCL of 5 ppb, cancer risks would be low. The
last column in the table presents hazard quotients (HQs) for non-cancer effects for the high and low end of
the exposure range from 0.8 to 5 ppb PCE contamination. The very small HQs suggest low risk for non-
cancer toxicity to the public from drinking well water contaminated at these levels.
Exhibit 5-7. Cancer and Non-Cancer Risks from Exposure to PCE-Contaminated Drinking Water
Exposure Scenario
Potential Risks from PCE-Contaminated
Drinking Water - PCE in ground water
LADDa
(mg/kg/day)
Range
0.000002 to
0.00001
Cancer Risk
index"
(LADD x Unit
Riskc) Range
1 x10-7to
5x10'7
Non-Cancer
Oral Hazard
Quotients"
(LADD/RfD)
0.0002 to
0.001
a LADD = Lifetime Average Daily Dose
LADD = [PCE] x 1.4 liters x 9 years/70 years x 1/72kg
where [PCE] = PCE concentration in drinking water in mg/L
[PCE] = 0.0008 mg/L
1.4 liters = Average adult consumption of drinking water
70 years = Average lifetime
72 kg = Average adult weight
b Cancer risk index = upper bound lifetime excess cancer risk
c Oral Unit Risk = 0.051 per mg/kg/day. Sample Calculation, Risk Index = 0.0001 mg/kg/day X 0.051
per mg/kg/day = 1 x 10"7
d RfD = 0.01 mg/kg/day.
Risks from Dermal Exposures
Exposures (and consequently risks) could also result from bathing or showering in water
contaminated with PCE. Dermal uptake of PCE in bath water has been estimated to equal the dose
received from drinking two liters of water a day ( Riihimaki et al., 1978; McDougal et al., 1990; Bogen et
al., 1992; in Keifer, 1998). Therefore, the estimated risk indices from dermal exposures by daily bathing
in PCE-contaminated water would be somewhat similar to those presented in Exhibit 5-7 for drinking 1.4
liters of PCE-contaminated water a day.
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Chapters
The HQs for drinking PCE-contaminated water are well below one; thus, expected risks from
dermal exposures from bathing/showering are low for toxicities other than cancer.
Combined Risks from Other Routes
The health risks to the general population from PCE are regarded as the sum of the individual risks
due to exposures through all major routes of the body. Therefore, if persons in the general population are
also exposed to PCE from contaminated drinking water, shower or bath water, risks from those exposures
would be added to the risks from inhalation of PCE.
Risk Conclusions — General Population
If the general population were exposed to PCE via inhalation for its lifetime at the average daily
level measured in the TEAM study, there can be a concern for risk of cancer, albeit much lower than either
the occupational or co-located resident scenarios described earlier. There would not be a concern for non-
cancer health risks. However, it is not possible to generalize from the data that the individuals in the
general population of the United States would be exposed at these levels for a lifetime.
If PCE contaminated drinking water is at or below the MCL of 5 ppb, there would not be a
concern for health risks to the general public. Although higher PCE levels have been measured in private
and municipal wells, it is assumed for this CTSA that PCE levels in excess of the MCL would be
remediated so that contamination would not be present in drinking water on a long-term basis.
Uncertainties
The risk conclusions are based on readily available toxicity and exposure data and on models,
assumptions and professional judgements about toxicity and exposure information. These give rise to
many uncertainties and assumptions and influence to a great extent how closely the assessment of risk
represents reality. Prominent specific factors and uncertainties concerning general population risk
conclusions are listed below. These and other factors are discussed in more detail in Chapter 4, and
Appendices C, D, and E:
The risk conclusions for the inhalation exposure scenario are based on a single study's exposure
estimates. The TEAM study is 10 years old, took measurements over a short time, and focused on
persons living in several states across the country. It is uncertain how well this study represents
the actual PCE exposures to the general population throughout the United States.
• The TEAM study results included a single, unusually high measured concentration from North
Dakota. Since the TEAM study results included this measurement in the calculation of the
arithmetic mean concentration, it has been included in the CTSA as well. Wallace (1989) stated
that if this measurement were not used, the arithmetic mean concentration would have been 0.012
mg/m3. The general population's overall LADC then would have been 0.012 mg/m3, and the
associated risk index 2 x 1 0'6.
• The two groundwater studies show considerably differing measurements of PCE contamination. It
is not known how representative the studies are of groundwater contamination throughout the
United States.
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Chapter 5
Risk
A major uncertainty is whether, in fact, PCE contamination of municipal and private drinking
water wells is kept at or below the MCL of 5 ppb.
• The estimates of lifetime average daily dose of PCE from contaminated drinking water used in the
CTSA could be conservative since they do not take into account that household water supplies
may be drawn from a number of different wells; and they assume there is no PCE removal during
treatment.
• The estimates of ingestion exposure assume that there is daily exposure to the PCE contaminated
water over a lifetime. It is not known whether this is the case for the general population.
• The inferences regarding potential for dermal exposures are based on very limited data.
5.2.6 Special Sub-populations
General
The data available for this CTSA do not adequately permit addressing the question of whether
health risks due to PCE exposures differ significantly between such special sub-populations, as infants,
children, the elderly, and adults in general. Therefore, risks to sub-populations from PCE exposures are
considered the same as for adults in general unless there is specific information to the contrary. There is a
lack of data concerning:
(1) The toxicity of PCE to different sub-populations compared with adults as a whole (i.e.,
whether different sub-populations or groups are more susceptible, or less susceptible to the
carcinogenic and non-carcinogenic effects of PCE). We currently have no information as to
whether PCE is more or less carcinogenic or otherwise toxic to infants, children, or the elderly.
The RfD/RfC concept incorporates the idea that a 24-hour exposure over a lifetime at the
designated level generally is not expected to be toxic to the general public, including sensitive sub-
populations. Therefore, in this CTSA the measures of toxicity (cancer unit risk, RfD/RfCs) used
for adults are also used for all sub-populations.
(2) The PCE exposures of different sub-populations compared with adults as a whole, (i.e.,
whether different sub-populations or groups are exposed to PCE at higher or lower levels than
adults in the general population.) There are some indications that certain sub-populations differ
from adults in their exposures to PCE. This may be indicative of their different exposure patterns
throughout the day. These patterns are mentioned in the discussion of co-located residences.
Infants, children, and the elderly on the whole are thought to spend more time in the co-located
residence than adults in general, resulting in an estimate of about 1.4 times the exposures of PCE
for them than for those adults. Therefore, their risks are derived using the higher exposure level.
Infants
Several models have been developed to estimate the amount of PCE to which an infant is exposed
through ingesting breast milk that contains PCE. One model predicted infant exposures would range from
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,,, . , Risk
Chapter 5 _ —
0.0001 to 0.92 mg/kg/day (Schreiber, 1997). Another model (Fisher et al.,1997) estimated infant exposure
at 0.34 mg/kg/day. These models and their background information are discussed in more detail in
Chapter 4.
One estimate of infant exposure was made for a hypothetical situation in which a woman is
exposed at work to PCE at the OSHA Permissible Exposure Level of 25 ppm and then breast feeds her
infant. The infant was estimated to ingest 1.36 mg/day of PCE. That author concluded that this would
result in a health risk since the infant's exposure would exceed an EPA Health Advisory Intake of 1.0
mg/day. [The Health Advisory is set by the USEPA Office of Water for chronic ingestion of contaminated
water by 10 kg children, assuming ingestion of 1 liter of water per day (Fisher et al, 1997)]. Schreiber
(1997) concluded that the benefits of breast feeding outweigh the risks; and also estimated that the majority
of an infant's PCE exposure results from inhalation rather than ingestion.
It is beyond the scope of this CTSA to properly evaluate these pharmacokinetic models given their
complexity in design and assumptions. Further, even with an estimate of PCE delivered by lactation, there
is no cancer model or non-cancer comparison value adapted for use with infant exposures. Therefore, no
attempt is made to utilize estimated exposures for quantifying potential health risks to infants.
Qualitatively, there appears to be a potential for health risks to infants in situations where they are exposed
to levels of PCE which are also a concern for the adult population. This could be via inhalation, dermally,
or through ingestion. Exposure scenarios which appear to be of most concern for risk for infants are those
providing inhalation of PCE-contaminated air in co-located residences, and ingestion of contaminated
breast milk.
Children/Families
There have been some studies suggesting that families of drycleaning workers may experience
elevated PCE concentrations in their homes, and it has been hypothesized that workers introduce PCE into
their homes through their exhaled breath. (Thompson and Evans, 1993; Aggazzotti et al.,1994). The
information is of interest (see Chapter 4) and suggests a specific exposure scenario through which children
might be at additional health risk from PCE.
Summary
Adult risk does not translate directly to infants, children, and the elderly. In scenarios where high
risk indices have been inferred at high exposure levels for adults in general, however, there should be
concern for sub-populations exposed by similar routes at similar exposure levels.
5-24
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Chapter 5
Risk
5.2.7 Environmental Risk
Risk to Aquatic Organisms
A PCE concern concentration (CC) for aquatic organisms was determined by dividing the lowest
chronic toxicity value for PCE, 0.66 mg/1 for daphnids (Chapter 3, Exhibit 3- 2), by an assessment factor5
often. The CC of 0.07 mg/1 is the concentration of PCE in surface water above which toxic effects may
occur to aquatic organisms. The greater the exceedence and the longer the CC is exceeded, the greater the
' probability of toxicity to aquatic organisms.
If effluent (wastewater) flows from drycleaning facilities are sent to Publicly Owned Treatment
Works (POTWs), the estimated PCE concentration in water, 3 ppb (see Section 4.4.1) is expected to be
well below the concern concentration of 0.07 mg/L (70 ppb). If effluent flows are not sent to a POTW. it
is possible that PCE could be present in surface water in excess of the CC. Anecdotal data suggest,
however, that most drycleaners discharge their effluent to a POTW.
Surface water contamination by PCE has been found in many locations throughout the U.S., with
PCE concentrations ranging from a fraction of a part per billion to hundreds of thousands of parts per
billion. Of course, these levels are due to all sources of PCE and not just from drycleaning establishments.
In this assessment, only surface water concentrations in which the contaminating source was identified as a
drycleaning facility were used (General Population Exposure Assessment).
Risk Conclusions
The concern concentration (CC) for aquatic organisms for PCE is not exceeded, and therefore,
there is low risk to aquatic species for the majority of drycleaners who send their wastewater effluents to a
POTW. Drycleaning establishments that do not send their wastewater effluents to a POTW may cause
surface waters to exceed the PCE CC, and therefore put aquatic organisms at risk.
Uncertainties
There are uncertainties connected with using the Structure-Activity-Relationship (SAR)
methodology (see Appendix B) for calculating the concern concentration. However, the combination of
cross-checking the PCE literature and the extent of the PCE database, as well as the history of usage of this
technique, increases the belief that this concentration predicts toxicity to aquatic organisms well.
There are uncertainties as to actual surface water levels, since estimated levels are based on
estimated wastewater releases from drycleaning establishments, and the assumption that most
establishments send effluent wastewaters to a POTW with subsequent further PCE removal.
Assessment factors incorporate the uncertainty associated with (1) toxicity data-laboratory tests versus field tests and
measured versus estimated data; and (2) species sensitivity. Assessment factors range from 1.000 to I depending on the amount and
quality of available aquatic toxicity data. Because the hazard profile for PCE contained three chronic SAR values (in addition to one
measured and two SAR acute values), an assessment factor of 10 was used (for a full explanation, see Appendix B).
5^25 "
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Chapter 5
Risk
Other Environmental Effects
PCE is not a stratospheric (higher atmosphere) ozone depleter, because it is destroyed in the
troposphere (lower atmosphere, or a region of the atmosphere extending to between eight and sixteen
kilometers above the earth's surface). In the troposphere, PCE undergoes photochemical degradation to
the extent that its estimated lifetime is appreciably less than one year (Appendix A).
5.2.8 Human and Environmental Risks—Overall Summary and Conclusions
Exhibit 5-8 summarizes in a graphical format the human health hazards of PCE and the inhalation
exposures associated with its use as a drycleaning solvent. Two exposure scenarios stand out as the
highest levels of concern: occupational exposure to drycleaning workers and exposure to residents
(including children) of dwellings located above drycleaning shops. There is a potential concern for cancer
and non-cancer toxicity risks to workers exposed to average PCE levels measured in drycleaning facilities.
There are also qualitative data supporting a concern for developmental toxicity risk to workers exposed to
the high end PCE concentrations measured in the workplace. Exposures and, consequently, risks tend to
be higher if transfer machines are used instead of dry-to-dry machines, but there are still health risks
associated with PCE exposure levels from dry-to-dry machines. Worker PCE exposures appear highly
variable, which may be due to such diverse factors as differences in facility layouts, machine maintenance,
machine' controls, amount of clothes cleaned, and ventilation. Workers can also be exposed to PCE via
dermal exposures, either directly through contact with the liquid, or skin contact with PCE vapor. Risks to
workers by this exposure route would be added to risks due to inhalation exposures.
Residences above shops with transfer machines typically have airborne PCE concentrations 10- to
100-fold lower than the occupational scenarios. There is concern for cancer and non-cancer risks to these
residents who live co-located with drycleaning facilities. Such residents include infants, children, and the
elderly, as well as adults. Residences above non-vented dry-to-dry machines tended to have lower PCE
exposures than those above transfer machines and were at the lower end of the exposure range. Some
measured levels in such residences are not much higher than ambient indoor air in homes not co-located
near drycleaning shops. However, limited data indicate that high exposures can occur even with dry-to-dry
machines if they are poorly maintained.
Sufficient data are not available to make quantitative risk conclusions concerning exposures to
special sub-populations such as infants, children, and the elderly. As a rule of thumb, however, exposure
scenarios where health risks are of concern for adults should be considered to be of concern for health risks
to these sub-populations. Models have been developed to predict levels of PCE ingested by infants from
contaminated breast milk. This is a possible scenario for a health risk to infants.
Measured ambient air levels of PCE are low, but the general population can be exposed to PCE
from a variety of sources in addition to ambient air, such as from visiting drycleaning establishments;^
bringing home and storing dry-cleaned clothes; wearing dry-cleaned clothes; being exposed to others' dry-
cleaned clothes; and drinking and bathing in contaminated well water. Limited data indicate that these
exposures can increase average exposures several times over ambient levels. Exposures from inhalation,
ingestion, and through the skin would be additive.
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Chapter 5
Exhibit 5-8. PCE Hazards and Inhalation Exposures
Health-Based
Indicators
Air Level
(mg/m3)
Human
Exposures-
1000
APPTTT TT V '70
100
1
o
•
1
•ovHnna'l RfT °'17
Occupational Exposure -
— . Transfer Machines
-
Occupational Exposure -
Dry-to-Dry Machines
Indoor Air in Co-located
— Residences - Transfer
Machines
Indoor Air in Co-located
— Residences - Non-vented
Dry-to-Dry Machines
1
]00000
Cancer Risk Index
Cancer Risk Index"
Cancer Risk Index"
0014
0001
0.100
_ _
0.01
13 — General Population Exposure
; Outdoor air - Ambient
Concentrations
Q.OOl
a Concentrations are arithmetic means. Therefore, the brackets do not reflect the entire range
of concentrations found in any particular study.
b Based upon linear-at-low dose approach with a unit risk value of 0.00071 per mg/m3.
Risk
5-27
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ou * c
Chapter 5
Health risks to aquatic organisms are expected to be low if drycleaning wastewater effluents are
sent to (POTWs). This is expected to be the case for most drycleaning establishments. If, wastewater
effluent is not sent to a POTW, there could be health risks to aquatic organisms from PCE concentrations
in surface waters exceeding the concern concentration. Health risks to terrestrial organisms were not
evaluated.
Some yet-unanswered key issues surrounding the assessment of risks due to PCE used during the
drycleaning processes are:
whether PCE causes cancer in humans at low doses, and what its mechanism of action is;
do the various models used to estimate PCE exposures in nursing infants present realistic estimates
of exposures;
does PCE cause developmental toxicity in humans, and if so, at what concentrations; and
what is the true range of exposures to PCE experienced by co-located residents throughout the
country?
5.3 DRYCLEANING USING HYDROCARBON (HC) SOLVENTS
5.3.1 Human Health
Hydrocarbon (HC) solvents (Stoddard solvent, 140°F solvent, and DF-2000) may be used to
dryclean clothes. In this CTSA, hazard information (Chapter 3) on Stoddard solvent is assumed to
represent all three solvents. Exposure information (Chapter 4) is available for Stoddard solvent and 140°F
solvent. Both Stoddard and 140°F solvents are mixtures that consist of linear and cyclic paraffins with
total carbons varying from C9 to C12. The constituents and their percentages vary.
A major hazard identified with the HC solvents considered in the CTSA is their potential
flammability (Chapter 3). The National Fire Protection Association (NFPA) gives HC solvents a ranking
of "2" for flammability, indicating that they must be moderately heated or exposed to relatively high
ambient temperatures before ignition can occur. For comparison, perchloroethylene receives a ranking of
"0" for flammability, which indicates that it will not burn (Ahrens, 1998).
5.3.2 Human Health Risks
Risk — General
In this section, the hazards and individual exposure scenarios are integrated to address the
potential risks of hydrocarbon (HC) solvents. Stoddard solvent will be used, for risk assessment purposes,
to represent HC solvents in the drycleaning industry. There is evidence indicating that Stoddard solvent is
absorbed into the body via inhalation, the gastrointestinal tract, and through the skin. There are some
human data indicating that it can cause neurotoxic effects, and is an irritant to the eyes, mucous
membranes, and skin. Kidney toxicity (see Appendix C) has also been reported in animal studies.
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Chapter 5
Risk
There were no data suitable for drawing conclusions concerning the carcinogenic potential of
Stoddard solvent, so no expression of risk is made for cancer. No cancer unit risk or slope factor has been
established. Also, no oral RfD or inhalation RfC has been established to date for Stoddard solvent or any
other HC solvent.
For the purposes of the CTSA, a non-cancer comparison value was derived from an animal study
(see Chapter 3 and Appendix C) for a discussion of the spectrum of effects associated with Stoddard
solvent. The comparison value was taken directly from a 13-week study in male rats (Carpenter et al.,
1975a, 1975b, see Appendix D). A No-Observed-Adverse-Effect Level (NOAEL) was identified as 480
mg/m3 with recognition that it is not from the usual chronic study. [Note: The American Conference of
Government Industrial Hygienists, ACGIH has established a Threshold Limit Value (TLV) guideline for
Stoddard solvent exposure in the workplace of 525 mg/m3 (lOOppm) (ACGIH, 1996)].
Routes of Exposure
Inhalation
Inhalation is the likely route of exposure to HC solvents based on their physicochemical
characteristics (Appendix A). Stoddard solvent, the HC solvent reviewed in Chapter 3, is readily absorbed
from the lung following inhalation exposure.
Oral
There are no data on the oral absorption rate of Stoddard solvent. Based on studies of other
petroleum distillates, it is judged that the rate and extent of gastrointestinal absorption of Stoddard solvent
is likely to depend on the lipophilicity and size of its various components and the amount of food in the
stomach.
Dermal
Dermal absorption is expected to occur, but there is no information on the rate of absorption.
Stoddard solvent was found to be dermally absorbed by rats, and by analogy, there should be some
absorption through human skin.
5.3.3 Occupational Risks—Drycleaning Workers
Risks from HC Solvent Inhalation
HC solvents are used much less often than PCE in commercial drycleaning, and less information is
available for them. The number of workers exposed to hydrocarbon (HC) solvents in facilities that
dryclean clothes is estimated to be between 21,000 and 49,000 (Chapter 4). The most significant route of
exposure for workers is expected to be from inhalation, although they may also be exposed through the
skin. Only a few studies and data sets are available to characterize inhalation exposures to HC solvents.
These are presented and discussed in Chapter 4. Inhalation exposures and consequently, potential risks
from HC solvents to workers, are expected to be higher than for any other exposure group.
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Risk
Chapter 5 . —
The two data sets available for exposure estimates are from OSHA air monitoring data for the
years 1990-1993 and 1997 (OCIS, 1994,1998), and from a pre-1980 NIOSH survey (NIOSH, 980). They
are presented in Chapter 4. The OSHA data include a set of 28 inhalation exposure samples listed by_
worker job category. An additional 11 samples were obtained for 1997, for the category all jobs. The
NIOSH survey was of 6 drycleaning facilities, ranging from very small to a large industrial facility, and
exposures were listed by worker job categories.
As in the case of PCE, there are differences in exposures and risks to workers in different job
categories. Limited exposure data give an indication that persons in the job classification "cleaner
(equivalent to "operator") may be the most exposed to HC solvents via inhalation.
To get a general estimate of non-cancer risks to workers, we can use the exposure levels measured
(arithmetic mean as average and maximum as high-end) from the OSHA and NIOSH studies (see Exhibits
4-11 and 4-12) to represent worker exposures in the commercial drycleaning industry, and compare these
exposure levels with the toxicity comparison value of 480 mg/m3 as a NOAEL for non-cancer toxicity. In
most cases, (except for job categories "presser" and "customer service") there was not a large difference
between the NOAEL from the animal study and worker lifetime average daily exposures Worker average
exposures ranged from about 5- to 120-fold lower than the animal NOAEL of 480 mg/m3. Worker high-
end lifetime average daily exposures were about 2- to 50- fold lower than the comparison value. These
exposures to HC solvents, especially the high-end ones, are indicative of a potential concern for non-cancer
risk for workers. (A sample calculation of the LADC and comparison! with the NOAEL is presented using
OSHA 1997 data from Exhibit 4-11 for "all jobs".6)
Risks from Dermal Exposure
Although there is potential for dermal exposure to HC solvents as with PCE, there are no data to
assess the potential magnitude of dermal exposures. Dermal exposures can be modeled, however, and
those procedures are discussed in Chapter 4. Dermal exposures can be from direct contact with liquid HC,
and also possibly with the HC vapor. The risks from dermal exposures would be added to the risks
indicated for inhalation.
Combined Inhalation and Dermal Risks
The health risks to drycleaning workers from HC solvents depend on the solvent entering the body
through two major routes of entry—inhalation and through the skin. (Oral, hand-to-mouth exposure .s not
6LADC •
Exposure x 10 m3/20m3 x 250 days/365 days x 40 years/70 years
10 m3 = Volume of air inhaled during an 8 hr workday
20 m3 = Volume of air inhaled in 24 hours
250 days = Days worked per year
365 days = Days per year
40 years = Years worked in a lifetime
70 years = Average lifetime
The "All Jobs" arithmetic mean = 150 mg/m3'. therefore using the formula above, the
LADC = 29 mg/m3
This LADC is about 17-fold less than the NOAEL of 480 mg/m-1
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Chapter 5
Risk
considered a major route, but if it occurs would also be added to the total risk). Dermal exposures would
be added to the overall risks estimated from inhalation exposures, although inhalation is expected to be the
dominant route of exposure.
Risk Conclusions
There is a reasonable basis to conclude that there can be a health risk for non-cancer toxicity to
workers from the relatively high HC solvent exposures observed in the drycleaning industry. This
conclusion is based on monitored worker inhalation exposure data from several sources, from information
about circumstances for dermal exposures in the workplace, and the potential for Stoddard solvent to
absorb through the skin, combined with evidence from animal studies indicating that Stoddard solvent can
be toxic in laboratory rodents. Monitored worker inhalation exposure concentrations, especially at
maximum exposure concentrations were close to the toxicity comparison NOAEL.
It was not possible to quantify the risk of fire in this CTSA. However, the risk for fire is an
important concern for the HC solvents and would be a greater risk for the HC solvents than for PCE based
on their higher flammability rating.
Uncertainties
The risk conclusions are based on readily available toxicity and exposure data and on models,
assumptions, and professional judgements about toxicity and exposure information. These give rise to-
many uncertainties and assumptions and influence, to a great extent, how close the assessment of risk
comes to realistic representation. Some central factors and uncertainties concerning worker risk
conclusions are listed below. Many of these are discussed in more detail in Chapter 4, and Appendices C,
D, and E:
There is not a sufficient database to indicate whether Stoddard solvent or other HC solvents are
carcinogenic in humans or animals. Epidemiologic studies reporting associations of certain
cancers with mineral spirits' exposure could not separate this exposure from others sustained by
the cases. It is not clear what might be seen if HC solvents were used more widely.
It was not possible to develop and review a provisional RfC for this CTSA. Therefore, a
comparison was made with a NOAEL directly from an animal study. This toxicity comparison
value has not had the level of review that the provisional RfC for PCE has had, and therefore there
is a greater level of uncertainty as to its validity. The toxicity comparison value may be higher or
lower than the one that a USEPA Agency-wide analysis of a more extensive database might select.
It is not known how representative the occupational exposure studies are of actual exposures to
drycleaning workers nationwide. Since the OSHA data are obtained from compliance inspections
and complaint investigations, the measurements may not represent "average" exposures. The
NIOSH data were collected almost 20 years ago (pre-1980) and may not represent current
exposures. Also, they included exposures from industrial drycleaning settings which may not be
representative of the commercial drycleaning industry.
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Chapter 5
Risk
The measured time-weighted average samples of Stoddard solvent may not represent well the full
8-hour shifts of most workers.
Variations in the workplace, such as machinery maintenance, facility layout, machine controls,
work practices, amounts of clothes cleaned daily, and ventilation may affect an employee s
exposure (and hence risk) from HC solvents. The extremely wide standard deviations from the
mean exposure levels in both worker studies seen in Exhibits 4-11 and 4-12 may be indicative of
some of the workplace factors listed here.
5.3.4 General Population Risks—Residents Co-Located with Drycleaning Establishments
It is possible that co-located residents have potential ambient air exposures to HC solvents, and
therefore would have health risks. Although no data were available for this exposure scenario, and
therefore no further discussion of risk is considered in the CTSA, the reader may comparethe relative
magnitudes of worker scenarios between PCE and the HC solvents, and take into account the possibilities
for co-located residents exposures to HC solvents.
5.3.5 General Population Risks
Risks from HC Solvent Inhalation
There were no data available for actual ambient air exposure levels for the general population
exposed to HC solvents. In this case, therefore, several hypothetical exposure scenarios for potential
inhalation exposures were modeled for the general population. Exhibit 4-13 presents a 'what-.f-exposure
scenario " which assumes that HC solvent would be released to air continuously, and expose people at
nearby homes to HC vapors throughout the day over a period of 9 years (considered to be the average time
spent in any one residence). It gives estimated Lifetime Average Daily Concentrations of HC solvent to
such persons. (These would include infants, children, the elderly, and other adults). The exposure
scenarios include exposures from facilities 100 meters to 400 meters away, with transfer or dry-to-dry
machines.
If the modeled worst case (i.e., a transfer machine releasing HC solvent at a distance of 100 meters
from the general population) general population exposure level listed in Exhibit 4-13 is compared to the
toxicity comparison value of 480 mg/m3 for a NOAEL for non-cancer toxicity, it can be seen that the
estimated general population lifetime exposure is 240,000 times lower than the NOAEL. This would
therefore, suggest low concern for non-cancer health risk.
Risks from HC Solvent Ingestion
There is a lack of information concerning the HC solvents in groundwater; however, it is thought
that the migration potential of HC solvents to groundwater is negligible. The estimated drinking water
exposure to the general population is very low—much less than one mg per kg per day (Chapter 4), and
therefore, risks are estimated to be very low.
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Chapter 5
Risk
Risk Conclusions
Chronic health risks to the general population from estimated inhalation exposures to HC solvents
are considered low. Risks from ingesting drinking water contaminated with HC solvents are also
considered low, given the very low projected releases of HC solvents to surface waters. These conclusions
are based on modeled exposure scenarios combined with evidence from animal studies indicating that
Stoddard solvent can cause toxicity in laboratory animals and were hampered by lack of actual exposure
data.
Uncertainties
The risk conclusions are based on readily available toxicity and exposure data and on models,
assumptions, and professional judgements about toxicity and exposure information. These give rise to
many uncertainties and assumptions and influence to a great extent how close the assessment of risk comes
to realistic representation. Some central factors and uncertainties concerning general population risk
conclusions are listed below. Many of these are discussed in more detail in Chapter 4, and Appendices C,
D, and E. The same uncertainties hold as to the limitations of the toxicity database as are indicated in the
Uncertainties section on risks from occupational exposures.
Using models to estimate potential general population airborne exposures and concentrations in
drinking water necessitates many assumptions, and therefore introduces uncertainties regarding the
closeness of these estimated exposures to reality.
• There are uncertainties as to the actual surface water levels, since estimated levels are based on
estimated wastewater releases from drycleaning establishments, and on the assumption that most
establishments send effluent wastewater to a POTW with subsequent HC solvent removal.
• Hazard and most of the exposure information are based only on Stoddard solvent. Other HC
solvents may differ somewhat.
5.3.6 Special Sub-populations
General
As was the case with PCE, the data available for this CTSA do not provide an answer to the
question of whether health risks due to HC solvent exposures differ significantly between special sub-
populations, such as infants, children, the elderly, and other adults. Therefore, risks to special sub-
populations from HC solvent exposures should be treated the same as for the broad class of other adults
unless there is specific information to the contrary. Information regarding items (1) and (2) below may
permit future estimations of risk.
(1) The toxicity of HC solvents to infants, children, and the elderly compared with other
adults (i.e., whether these different sub-populations or groups are more susceptible, or
less susceptible to the toxicity of HC solvents.) We currently have no information on this.
(2) The HC solvent exposures of these different sub-populations compared with adults in
general (i.e., whether different sub-populations or groups are exposed to HC solvents at
5-33 ~ : ~
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Ch
higher or lower levels than adults in the general population.) Infants, children, and the
elderly on the whole may spend as much as 1 .4 times longer in their residences than most
adults, resulting in higher estimates of HC solvent exposures.
Infants
Since the physicochemical properties of the HC solvents indicate that they would be taken up by
fatty tissue the scenario of prenatal exposure, and hence risk to infants nursing from mothers exposed to
HC solvents via inhalation, is reasonable. However, no data on HC solvents nor modeling (as was the case
for PCE) are available for this scenario.
Summary
Although adult risk does not translate directly to infants, children, and the elderly, in scenarios
where unacceptable risk levels have been determined for adults, there should be concern for similarly
exposed (or dosed) sub-populations.
5.3.7 Environmental Risk — Summary and Conclusions
Risk Characterization — Hazard to Aquatic Organisms
The hazard of the HC solvents was assessed using limited toxicity data and structure activity
relationships (SAR). Measured acute toxicity values ranged as low as 500 ppb for Stoddard solvent. SAR
was used to estimate toxicity values for the individual components of the HC solvents (i.e., C9 to C12
linear paraffins and cyclic paraffins). Since the solvents are very similar chemically and contain
approximately equal amounts of linear and cyclic paraffins, they were given the same hazard estimates.
The estimated chronic toxicity values for both daphnid and algae are in the range of 80 ppb to 2 ppb which
constitutes a high concern for chronic effects. The measured toxicity data for Stoddard solvent are
consistent with the SAR predictions (WHO, 1996).
Risk Conclusions
The projected releases of HC solvents to surface water are negligible, on the order of 1 x 10'7 to
1 x 1 0'8 kg/site/year (Chapter 4). Resulting surface water concentrations are not expected to exceed the
aquatic organisms toxicity concern concentrations (CC) of 0.001 mg/L for HC solvents (see Chapter 3 and
Appendix B). Thus, there is a low risk of toxicity to aquatic species. Health risks to terrestrial animals
were not evaluated.
Uncertainties
The risk conclusions are based on readily available toxicity and exposure data and on models,
assumptions and professional judgements about toxicity and exposure information. These give rise to
many uncertainties and assumptions and influence to a great extent how close the assessment of risk comes
to realistic representation. Some central factors and uncertainties concerning environmental risk
conclusions are listed below. Many of these are discussed in more detail in Chapter 4, and Appendices B
and E.
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Chapter 5
Risk
There was no assessment of risks to terrestrial species in this CTSA.
• The hazard assessment for aquatic species is not as certain as that for PCE since the HC solvents
are chemical mixtures w,ith uncertainty as to their exact composition, and to the extent that their
chemical composition is uncertain, there is uncertainty in the SAR analysis.
• There are uncertainties as to the actual surface water levels, since estimated levels are based on
estimated wastewater releases from drycleaning establishments, and an assumption that most
establishments send effluent wastewaters to a POTW with subsequent further HC solvent removal.
Other Environmental Effects
None of the CTSA HC solvents have stratospheric ozone-depletion potential, but are volatile
organic chemicals (VOCs) and are expected to contribute to lower-level photochemical smog levels. They
also have global warming potential.
5.4 MACHINE WETCLEANING PROCESS
Two cleaning formulations were assessed for the machine wetcleaning processes. Water
constitutes the majority of each formulation, and weight percentages of the chemical components range
from 1% to 10%. Wetcleaning detergent formulations are complex mixtures typically containing water
and a variety of different chemicals. Most formulations are trade secrets, and the concentrations of the
individual chemicals are unknown to all but the manufacturer. In this CTSA, exposure estimates were
based on two example detergent formulations (see Exhibit 2-7). Detergent #1 contains 10 constituents
(plus water) and Detergent #2 contains 12 constituents (plus water). Seven constituents are common to
both formulations.
5.4.1 Human Health
Very few toxichy data were available in the open literature on the chemical constituents of the two
formulations. Some toxicity information, however, was found in reports of the Cosmetic, Toiletry and
Fragrance Association (CTFA) (see Chapter 3 and Appendix C). These data do not indicate a potential
toxicity for major systemic health effects from the chemicals as low percentage components in an aqueous
solution. When hazard data were available, they were generally lacking on key health effects (such as
cancer, developmental toxicity, etc.).
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Ch
Risk
5.4.2 Human Health Risks
Risk—General
No oral RfD inhalation RfC, cancer unit risk, or slope factor has been established to date for any
of the sample wetcleaning chemicals reviewed for this CTSA. Unlike for PCE or the HC solvents, toxic.ty
comparison values were not generated for these chemicals.
The example detergents are mixtures. Under ideal circumstances, toxicity information would be
available for the mixture or formulation as a whole. More typically, information is available on some or all
of the ingredients (components). Often, certain components are exchangeable, with selection based on
their function in the process.
Routes of Exposure
Most detergent ingredients, and especially surfactants, are not likely to exist as vapors, mists, or
dusts and inhalation exposure is thus unlikely. Oral exposure to the.general population is possible based
on potential releases of detergent components to groundwater/surface water resulting in contaminated
drinking water.
Since the formulations are expected to be aqueous liquids, the dermal route is the expected route
of exposure Little information is available concerning absorption of the components of the wetcleaning
detergent formulations. No data are presented here for dermal absorption rates for the various detergent
components.
5.4.3 Occupational Risks—Wetcleaning Workers
Risks from Inhalation and Dermal Exposure
Workers are expected to be the most highly exposed population to machine wetcleaning (MWC)
detergent formulations. Dermal exposures are expected, but currently there are no data on actual worker
dermal exposures. Inhalation exposure of workers is not expected because of the low volatilities of the
component chemicals and because they are in aqueous solution. Dermal exposures to MWC formulations
can foe modeled, and these models are discussed in Chapter 4, and maximum modeled exposures listed in
Exhibit 5-9, along with limited toxicity information. Workers can be exposed to diluted formulation or to
full-strength. Maximum modeled exposures assume exposure to full strength formulation.
Operators are the primary workers expected to perform activities which result in dermal exposures
to liquid MWC formulations, and these activities are shop- and equipment- dependent. Some of these
activities occur at least once per day (routine) and others occur on a less frequent basis (non-routine).
Routine activities include but are not limited to transferring wet articles from the washer to the dryer; and
non-routine activities include but are not limited to connecting the formulation container to the dispensing
pump line. Non-routine activities would more likely expose workers to full-strength formulations.
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Chapter 5
Risk
Risk Conclusions—Occupational Exposures
No quantitative estimate of health risks to workers is possible due to lack of sufficient hazard data.
A complete qualitative assessment of risk also requires more extensive hazard data. An illustration of how
the available information can be used, however, to indicate whether there can be irritation to workers from
dermal exposure to wet process formulations is shown in Exhibit 5-9 using chemicals in the example
detergent formulations. Although water is the major constituent of these formulations and the chemical
constituents are expected to be found as 1-10% of the mixtures, some studies have suggested some irritant
effects at such low concentrations. Sensitization and allergy, however, do not tend to be indicated
(Appendix C).
Exhibit 5-9. Summary of Occupational Risk to Example Detergent Constituents
via Dermal Exposure
Example Detergent
Constituent
(amount in formulation)
Example Detergent
(taken from Ex. 2-7)
Max. Expected
Dermal Exposure'
(mg/day)
Observed Hazards
Following Dermal
Exposure in
Humansb
Qualitative
Comparison0
Example Surfactants
Cellulose gum (5%)
Cocamidopropyl betaine
(4.28%)
Ethoxylated sorbitan
monodecanoate (7.5%)
Lauramide DEA (4.28%)
Sodium laureth sulfate
(4.28%)
Sodium lauryl isethionate
(3.75%,,2.14%)
Acetic acid (5%)
Citric acid (2.5%)
Sodium carbonate (10%)
1
2
1
2
2
1,2
195
170
290
170
170
150, 83
100% soln = no
irritation
3% soln = maximum
acceptable cosmetic
use
No irritation
observed
iO.8% soln = mild
irritation
> 0.5% soln =
irritation
Not enough
information
L
P
L
L
P
—
Example Surfactant Aids
1
1
2
195
98
390
5% = vinegar
Not enough
information
50% soln = irritation
to abraded skin
L
—
L
a Level reported in either Exhibit E-13 or E-14 for dermal contact with full-strength detergent formulation.
b Taken from Appendix C.
0 L = low concern; P = potential concern.
5-37
-------
Chapte
Risk
Uncertainties
There is a high level of uncertainty as to the health risks to workers from using MWC formulations
due to lack of toxicity data for most of the potential chemical constituents of the formulations.
5.4.4 General Population Risks
Dermal exposure of the general population to the component chemicals from wearing newly
machine wetcleaned clothing is expected to be negligible. Potential oral exposures to MWC formulations
that may be present in drinking water are also expected to be negligible, given the expected levels of less
than 1 ppm in surface water for these chemicals (Chapter 4).
5.4.5 Environmental Risk—Summary and Conclusions
Risk Characterization—Hazard to Aquatic Organisms
Acute and chronic toxicity of the chemical constituents to aquatic organisms were estimated using
SAR methodology. Almost all of the chemicals in the CTSA example formulation were given a "medium
hazard ranking, and none were considered "high" hazard (see Chapter 3).
All wastes from machine wetcleaning are released to water. The affected population thus is in the
aquatic environment. Since these chemicals could be released from many drycleaning sites, site-specific
data are not available. Generic assumptions were used to estimate surface water concentrations (USEPA,
1995) and streamflow values for streamflow values for (POTWs). This provides a conservative estimate
of surface water concentrations and is appropriate for use when the specific sites are unknown (USEPA,
1995). (See Appendix E for more information.)
Environmental Risk Conclusions
Surface water concentrations were estimated for constituents of the two example wetcleaning
formulations. Estimated surface water concentrations for Sample Detergent #1 formulation ranged from
0 04 tO 0.13 ppm. The concern concentrations for aquatic species were not exceeded by any of the
chemical'constituents. Estimated surface water concentrations for Detergent Sample #2 formulation
ranged from 0.04 to 0.43 ppm. The concern concentrations (see Exhibit 3-2) of 0.06 ppm for launc acid
diethanolamide and 0.2 ppm for sodium lauryl isethionate were the only ones exceeded, indicating a
hazard for aquatic species from these example constituents.
Uncertainties
There are uncertainties connected with using the structure-activity relationship (SAR)
methodology for calculating the concern concentration. However, the combination of confirmation
through cross-checking the literature which rests on the available database as well as the general history of
usage of this technique lessens the uncertainty.
There are uncertainties as to actual surface water levels, since estimated levels are based on
estimated releases of wetcleaning formulations from wetcleaning facilities, and an assumption that most
establishments send effluent wastewaters to a POTW with subsequent further removal.
• " 5^38
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Chapter 5
Risk
REFERENCES
ACGIH. 1996. American Conference of Governmental Industrial Hygienists TLVs and BEIs Cincinnati
OH.
Aggazzotti et al. 1994. Occupational and environmental exposure to perchloroethylene (PCE) in dry
cleaners and their family members: Archives in Environmental Health 49 (6): 487-493.
Ahrens, M. 1998. Letter from Marty Ahrens, National Fire Protection Association, to Lynne Blake-
Hedges, USEPA. January 12.
ATSDR. 1993. Agency for Toxic Substances and Disease Registry. Toxicological profile for
tetrachloroethylene. USDHHS, Agency for Toxic Substances and Disease Registry. Atlanta, GA.
BAAQMD. 1993. Bay Area Air Quality Management District. An investigative survey of
perchloroethylene in residential areas above dry cleaners in San Francisco.
Barnes, D. And M. Dourson. 1988. Regulatory Toxicology and Pharmacology 8:471-486.
Bogen, K.T., D.W. Colston Jr., and L.K. Machicao. 1992. Dermal absorption of dilute aqueous
chloroform, trichloroethylene, and tetrach loroethylene in hairless guinea pigs. Fund Appl Toxicol
18:30-39.
Buben, J.R., and E.J. O'Flaherty. 1985. Delineation of the role of metabolism in the hepatotoxicity of
trichloroethylene and perchloroethylene: A dose-effect study. Toxicol Appl Pharmacol 78:105-
122. [As cited in IRIS (1993).]
Carpenter, C.P., E.R. Kinkead, D.L. Geary Jr., et al. 1975a. Petroleum hydrocarbon toxicity studies: I.
Methodology. Toxicol Appl Pharmacol 32:246-262.
Carpenter, C.P., E.R. Kinkead, D.L. Geary Jr., et al. 1975b. Petroleum hydrocarbon toxicity studies: III.
Animal and human response to vapors of Stoddard solvent. Toxicol Appl Pharmacol 32:282-297.
Fisher, etal. 1997. Lactational transfer of volatile chemicals in breast milk. Amer Ind Hygiene Assoc J
58:425-431.
Franchini, I., A. Cavatorta, M. Falzoi, S. Lucertini, and A. Mutti. 1983. Early indicators of renal damage
in workers exposed to organic solvents. Int Arch Occup Environ Health. 52:1-9.
IARC. 1995. International Agency for Research on Cancer. Tetrachloroethylene. IARC Monographs on
the Evaluation of Carcinogenic Risks to Humans, Vol. 63, Dry Cleaning, Some Chlorinated
Solvents and Other Industrial Chemicals, pp. 159-221.
5-39
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Chapt
IFI 1 990 International Fabricare Institute. "Monitoring solvent vapors in drycleaning plants." Focus on
Drycleaning, Vol. 14, No. 3. July. IFI: Silver Spring, MD. [as cited in Thompson and Evans,
1993]
IRIS. 1997. Integrated Risk Information Database. Chemical files. Washington, DC. Available through
TOXNET on line.
Izzo,V. 1992. Dry cleaners— A major source of PCE in ground water. Approved by the California
Regional Water Quality Control Board, Central Valley Region. Sacramento, CA.
Keifer, L. 1998. Memorandum entitled: "Information for Response to Peer Review Comments for
Perchloroethylene (PCE)
McDougal J.N., Jepson G.S., Clewell H.J. III, Gargas M.L., and Anderson M.E. 1990. Dermal absorption
of organic chemical vapors in rats and humans. Fund. Appl. Toxicol. 14:299-308
Mumtaz MM. K.A. Poirier, and J.T. Coleman. 1997. Risk assessment for chemical mixtures: Fine-
tuning the hazard index approach. J Clean Technol Environ Toxicol & Occup Med. 6(2): 189-
204
NCI. 1997. [As cited in USEPA, 1985]
NIOSH. 1980. Arthur D. Little for NIOSH. Engineering control technology assessment of the dry
cleaning industry.
NTP 1986 National Toxicology Program. NTP technical report on the toxicology and carcinogenesis
studies of tetrachloroethylene (perchloroethylene). Publ. No. 86-2567. U.S. Department of Health
and Human Services, NIH.
NYSDOH. 1993. New York State Department of Health. Survey of dry cleaning facilities in Capital
District, New York, and New York City. Previously unpublished.
NYSDOH. 1994. New York State Department of Health. Investigation of tetrachloroethylene in the
vicinity of two dry cleaners: An assessment of remedial measures. Draft report.
OCIS. 1994. OSHA Computerized Information System. Set of three data reports generated by OSHA
staff for USEPA. January.
OCIS. 1998. OSHA Computerized Information System. Set of two data reports downloaded from OCIS
by USEPA. January and March.
Riihimaki V. and P. Pfaffli. 1978. Percutaneous absorption of solvent vapors in man. Scand J Work
Environ Health 4:73-85.
Schreiber, J. (NYSDOH). 1992. An assessment of tetrachloroethane in human breast milk. Journal of
Exposure Analysis and Environmental Epidemiology. Vol. 2., Suppl. 2.
5-40
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Chapter 5
Risk
Schreiber, J. 1997. Transport of organic chemicals to breast milk: tetrachloroethylene case study. Chapter
5 of Environmental Toxicology and Pharmacology of Human Development. Edited by S. Kacew
and G. Lambert. Published by Taylor and Francis.
Schreiber, J., S. House, E. Prohonic, G. Smead, C. Hudson, M. Styk, and J. Lauber. 1993. An
investigation of indoor air contamination in residences above dry cleaners. Risk Analysis 13(3V
335-344.
Schreiber, J., K. Hudnell, and J. Parker. 1998. Assessing residential exposure to tetrochloroethene using
biomarkers and visual system testing in populations living above dry cleaning facilities.
Toxicologist(l-5:132).
Schwetz, B.A., B.K. Leong, and P.J. Gehring. 1975. The effect of maternally inhaled trichloroethylene,
perchloroethylene, methylchloroform, and methylene chloride on embryonal and fetal development
in mice and rats. Toxicol Appl Pharmacol 32:84-96.
Stasiuk, W. 1993. Letter from William Stasiuk, Director, Center for Environmental Health, New York
State Department of Health, to Bruce Jordan, USEPA. Attachment E: Summary of Groundwater
Contamination Related to Dry Cleaners.
Thompson, K. and J. Evans, 1993. Workers' Breath as a Source of Perchloroethyelene (PERC) In the
Home. Journal of Exposure Analysis and Environmental Epidemiology, 3(4): 417-430.
USEPA. 1985. U.S. Environmental Protection Agency. Health assessment document for
tetrachloroethylene (perchloroethylene). EPA-600-8-82-005F. PB-85-249704/AS. USEPA, Office
of Health and Environmental Assessment. Washington, DC.
USEPA. 1986a. U.S. Environmental Protection Agency. Risk Assessment Guidelines. EPA EPA-600-8-
87-045. Washington, DC.
USEPA. 1986. U.S. Environmental Protection Agency. The Total Exposure Assessment Methodology
(TEAM) Study: Summary and analysis. USEPA, Office of Acid Deposition, Environmental
Monitoring and Quality Assurance.
USEPA. 1996. U.S. Environmental Protection Agency. Proposed guidelines for carcinogen risk
assessment. EPA/600/p-92/003Ca. April.
Wallace, D. et al. 1995. Perchloroethylene in the air in apartments above New York City dry cleaners: A
special report from Consumers Union.
Wallace, L. 1989. The Total Exposure Assessment Methodology (TEAM) Study: An Analysis of
Exposures, Sources, and Risks Associated with Four Volatile Organic Chemicals. Journal of the
American College of Toxicology 8(5).
WHO. 1996. World Health Organization. Environmental Health Criteria 187: White Spirit (Stoddard
Solvent). International Programme on Chemical Safety (IPCS). Published under joint sponsorship
ofUNEP, ILO,andWHO. Geneva, Switzerland.
5-41
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-------
CHAPTER 6
PERFORMANCE DATA ANALYSIS
6.1
6.2
CHAPTER CONTENTS
Performance Evaluation of
Professional Fabricare
Review of Performance Studies
for Fabricare Options
This chapter presents performance data
associated with the various fabricare cleaning
alternatives. The information and data focus
primarily on the factors that affect the ability of
a process to clean garments effectively.
Section 6.1 summarizes relevant
performance assessment criteria for comparing
alternative clothes cleaning processes. Section 6.2 includes a study-by-study presentation of garment and
fabricare performance data associated with drycleaning and wetcleaning cleaning technologies. The
performance data summarized include the results from clothes cleaning demonstrations and laboratory
studies performed in the United States and Canada.
The studies range in scope and complexity, but are generally limited to comparisons of the
drycleaning (perchloroethylene [PCE] and hydrocarbon [HC] solvent based) and machine wetcleaning
cleaning options. Although improved HC solvents with lower flash points are included in one study in
progress, the results were not available at the time of publication. Because the information collected in
these studies varies widely, performance results are presented in the format chosen by the study author(s).
No further analysis of study data was performed independently to verify results or conclusions. In
addition, individual studies may contain specific limitations that are not necessarily identified in this
chapter. Due to the wide variability in potential operating conditions, the performance studies summarized
in this chapter represent case studies rather than generalizable scenarios.
6.1 PERFORMANCE EVALUATION OF PROFESSIONAL FABRICARE
The Cleaner Technologies Substitutes Assessment (CTSA) has identified various qualitative and
quantitative criteria to assist stakeholders in evaluating a fabricare process. This information has been
compiled through a review of literature pertaining to performance-based studies of fabricare process
options. When evaluating cleaning performance, it is important to note that variations in technology
and the knowledge base of operators will cause a range of results (Bladder et al., 1995).' Although
many of the criteria mentioned below are used in the performance-based studies discussed in Section 6.2.
they are not universally applied or accepted by the public and private sectors. In addition, other
performance considerations may become apparent as clothes cleaning studies expand to include additional
alternative technologies.
In any industry there is a performance learning curve, which is inherent with the use of "cutting-edge" technology. The
fabricare industry is no different in this case; the effective cleaning performance and financial viability associated with using innovative
fabricare methods, other than drycleaning, will inevitably increase with time. Enhancements in equipment technology, detergents
clothing manufacturing, and care labeling practices are all likely to influence the use. acceptance, and therefore success of innovative
cleaning methods by the industry and its customers. Such changes are likely to positively affect traditional drvcleanine methods as well
(Adamson. 1998: Riggs, 1998). '
6-1
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Chapter 6
Performance Data Analysis
6.1.1 Performance Assessment Protocol
Consensus protocols for comparing the performance of fabricare options have been under review
for several years by a number of public and private organizations. Drycleaning quality control standards
have been established by the International Fabricare Institute (IFI). The American Association of Textile
Chemists and Colorists (AATCC) also has developed historical criteria for "troubleshooting • drycleaning
problems and test methods for standard soil and fabric combinations (Patton, 1994). In addition the
following organizations provide evaluation services for standard soil/fabric combinations: IFI (United
States) Krefeld Research Institute for Cleaning Technology (WFK - Germany), Cleaning Techniques
Research Institute (TOO - Netherlands), Hohenstein Institute (Germany), and the International Wool
Secretariat (England) (Riggs, 1996).
The American Society for Testing and Materials (ASTM) and AATCC have developed
performance specifications and test methods, respectively, for acceptable dimensional change (shrinkage
and stretching) after laundering and drycleaning (CNT, 1996). These standards assist clothing
manufacturers in establishing some consistency in their care labeling instructions. In general the
maximum allowable shrinkage is 2% after three drycleanings and 3% after five laundenngs (CNT, 1996).
Textile scientists affiliated with AATCC and ASTM have developed performance criteria
regarding colorfastness, soil removal, odor, fiber damage, shrinkage, and hand (fabric texture) These
standards, listed in volume 7.01 of tte Annual Book of ASTM Standards (ASTM, 1998 are hnked to care
labeling guidelines currently under revision by these organizations. Such standards will inevitably affect
specifications for soap and detergents, as well as clothes cleaning equipment.
The European Wetcleaning Committee (EWCC), a consortium of research institutes, machine and
system manufacturers, detergent suppliers, and organizations with technical expertise, has performed a
study to develop a test method for wetcleaning. The EWCC hopes that the combined results of the study
and a second series of tests will provide data adequate to establish consensus guidelines for wetcleaning
care labels (den Otter, 1996).
6.1.2 Subjective Measures of Cleaning Performance
Numerous studies included in this chapter take advantage of customer mail and telephone surveys
to measure customer satisfaction, as a surrogate measure of cleaning process performance. In some
instances, researchers have performed parallel surveys to compare customer perceptions of the cleaning
performance of two separate process options (e.g., dry versus wetcleaning). Customer surveys are a ^
subjective measure of cleaning performance because they record customers' perceptions of how ' clean
their garments are as a result of using a particular technology. Researchers note that customer perceptions
of a clean garment may vary due to regional, socioeconomic, and cultural differences. Variations in
acceptable cleaning performance and pricing levels are noted among European, Canadian, and American
consumers (Adamson, 1996). Other researchers note that the cultural differences may affect how many
times a garment is worn prior to re-cleaning, rather than how "clean" a garment must be for it to be
acceptable to a consumer (Riggs, 1998).
6-2
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Chapter 6
Performance Data Analysis
6.1.3 Physical and Chemical Characteristics of Clothes Cleaning
All professional clothes cleaning technology should strive to achieve the following goals (Wentz,
1994; Hohenstein, undated):
• Optimize soil removal by overcoming the physical and chemical forces that bind soils to textiles:
• Transport soils away from the textile through the cleaning medium; and
Preserve and/or restore the original attributes of textiles, including dimensions, dye character,
hand, and overall fabric finish.
The cleaning ability of a process depends on the following factors: (1) soil chemistry,'(2) textile
fiber type, (3) transport medium (aqueous vs. non-aqueous), (4) chemistry of additives (detergents,
surfactants), (5) use of spotting agents, and (6) process controls (time, temperature, and mechanical
actions). These factors work interactively to provide a range of cleaning abilities for all clothes cleaning
processes.
In general, non-aqueous (solvent-based) cleaning processes are effective in dissolving non-polar
soils (e.g., oils, fatty stains). Aqueous (water-based) cleaning processes tend to dissolve polar soils (e.g.,
sugar, salt; perspiration) with greater success. Neither process type removes particulate soils significantly
better than the other (Wentz, 1996). However, the cleaning ability of a particular process option may be
enhanced with the use of spotting agents, alternative detergents, surfactant additives, and other process
modifications such as cleaning time, temperature, or mechanical action.
Non-aqueous cleaning processes are most effectively used with textiles that contain hydrophilic
fibers, low-twist yarns, low-count fabrics, and polar colorants. Aqueous cleaning processes are effective
with textiles containing hydrophobic fibers, high-twist yarns, high-count fabrics, and non-polar colorants
(Wentz, 1996).
Water-based cleaning methods tend to cause expansion of natural and cellulose fibers, leading to a
loss of strength, wrinkling, color loss, and dimensional change (shrinkage, stretching). However, such
alterations are not necessarily apparent when synthetic fibers are subjected to similar water-based cleaning
methods. Textile manufacturers have developed a number of fiber treatments and modifications that may
minimize such alterations. For synthetic fibers, non-aqueous cleaning methods may not be appropriate due
to potential fiber deterioration (Wentz, 1996).
Other process characteristics that affect cleaning performance include detergent type, mechanical
action of equipment, cleaning time, and temperature of cleaning medium. Such characteristics affect not
only soil and stain removal, but also potential damage to garments. These individual factors vary in
importance according to the cleaning method (Hohenstein, undated).
Pre-treatment and post-treatment spotting is often necessary, regardless of the cleaning method
chosen. Spotting agents can be brushed, sprayed, or dripped onto clothing prior to final rinsing and are
chosen based on the chemical nature of the target soils. The choice of spotting agent and the application
procedure are important considerations because they can cause color changes and dye transfers
(Hohenstein, undated).
6-3
-------
Performance Data Analysis
Another factor in the success of a particular fabricare process is the skill and experience of the
clothes cleaning operators. Their ability to properly sort garments and to choose the appropriate process
conditions as well as their knowledge of textiles and cleaning processes, will have a decisive influence on
the success of a particular cleaning method. Clothes cleaning operators can also prevent potential damage
to garments by being aware of adverse interactions between textiles and cleaning methods (Wentz, 1996).
As indicated previously, the ability of cleaning processes to successfully remove soils from a variety of
textiles occurs within a range. Because human skill affects that range, textile properties alone cannot be
used as a strict guideline for evaluating the ability of a cleaning process (Wentz, 1996; Blackler et al.,
1995).
6.1.4 Clothes Cleaning and Textile Damage Potential
Textile damage during cleaning processes includes dimensional change (shrinkage and stretching).
appearance change (color loss, dye transfer, damage to decorative trim), tears (mechanical action), and
tactile change (garment texture) (Wentz, 1996; Hohenstein, undated). Mechanisms of garment shrinkage
include felting (the increase in differential friction between wool fibers caused by swelling in water) and
relaxation (the release of microscopic and macroscopic fiber stress via mechanical action, swelling in
liquid media, or excessive heat). Relaxation shrinkage, also called progressive shrinkage, is unavoidable in
most textiles after multiple cleanings, regardless of the cleaning methodology (Wentz, 1996).
The ability of a fabricare process to maintain the visual (color, finish) and tactile (texture)
appearance of a garment is equally important when considering cleaning performance. Restoration of the
physical properties of a garment is a function of the cleaning method, textile properties, and the expertise
of the operator In the case of both aqueous and non-aqueous cleaning methods, fabric finishes may be
necessary to restore and improve the feel of a garment's texture (hand). Careful sorting, the use of process
additives that protect garment fibers, and careful attention to process conditions and their effect on specific
clothing types can mitigate garment damage (Hohenstein, undated).
6.2 REVIEW OF PERFORMANCE STUDIES FOR FABRICARE OPTIONS
6.2.1 Summary of Findings
This chapter has identified laboratory-based and "real world" demonstration studies, both of which
are a necessary component of performance evaluation for alternative clothes cleaning processes. Although
there are many fabricare technologies under development by manufacturers, the performance assessments
identified in this chapter focus entirely on machine wetcleaning as an alternative to non-aqueous based
methods. Results of the machine wetcleaning performance studies included here should be considered
preliminary due to a lack of uniform performance assessment protocols.
Given the limited number of performance studies available for comparing alternative clothes
cleaning options, it is difficult to draw conclusions. The variations associated with clothing fibers and soils
result in performance differences for all process options considered. A number of studies mention that the
skill of the cleaners follows a distinct learning curve, resulting in greater performance as they adapt to new
technology. For example, the Cleaner by Nature (UCLA/Occidental/PPERC) study mentioned that their
redo rate increased when there was turnover in their cleaner and presser positions (Gottlieb et al., 1997).
- —
-------
Chapter 6
Performance Data Analysis
Greater use of these cutting-edge technologies in the fabricare industry will inevitably result in
advancements in equipment design and operator skills, therefore resulting in increased cleaning
performance (Gottlieb et al., 1997; Riggs, 1998; Adamson, 1998).
Most researchers agree that many garments labeled "dryclean only" can be effectively wetcleaned.
The results from The Greener Cleaner, Cleaner by Nature, and other ongoing demonstration studies
indicate that the cleaning performance associated with modern wetcleaning equipment makes this
technology an acceptable substitute for a significant fraction of consumer garments. There continues to be
debate as to the actual percentage of clothing types traditionally labeled "dryclean only" by manufacturers
that can be safely and effectively wetcleaned. Researchers note that the debate should focus not
necessarily on percentages of clothing, but on the types of clothing and fabrics that can be successfully
wetcleaned (Adamson, 1998; Riggs, 1998).
Based solely on customer claims, one could argue that 99% of all garments can be wetcleaned.
However, when an evaluation factor (i.e., a customer satisfaction survey) is introduced, the percentage
drops to 93% (CNT - Overall was your clothing clean?), 95% (Environment Canada - Will you use the
cleaner again?), and 93% (UCLA/Occidental/PPERC - overall customer rating of excellent or good). If
one considers the results of expert panel evaluations of garments wetcleaned multiple times, the percentage
is lowered to 83% (UCLA/Occidental/PPERC)2 and 63% (CNT). In reporting such findings from these
studies, it is important to consider that there may be differences between garments that have been
wetcleaned, and those that are wetcleaned effectively, to the satisfaction of the customer. Other study
variables noted to affect the feasibility of wetcleaning in professional fabricare operations include cleaning
costs, garment sample size, garment type, and operator skill.3
Additional financial analysis, in conjunction with performance assessment, is necessary to
determine the feasibility of using the alternative technologies in the professional clothes cleaning market.
Although the clothes cleaning customer is an important arbiter for deciding the effectiveness of a garment
care option, fabricare operators must also consider the cost effectiveness of each process option. The
competitive nature of the fabricare industry demands that both traditional and innovative technologies be
cost-competitive, regardless of their ability to clean garments to the satisfaction of customers. Future work
related to performance of cleaning operations should focus on technology cost assessment studies, in
addition to the development of consensus testing and evaluation protocols. An ongoing U.S.
Environmental Protection Agency (USEPA) laboratory study is expected to aid in the development of the
latter information (Riggs, 1998).
Cleaning performance data from several comparative clothes cleaning studies are presented in the
following section. Performance assessment techniques include customer satisfaction surveys, evaluation of
cleaned garments and fabric swatches by industry experts, and analysis of repeatedly cleaned and damaged
The percentage of drycleaned garments whose appearance was deemed acceptable is 87.5%.
Modern wetcleaning is new to the professional fabricare industry, compared to drycleaning with PCE or HC solvents
Several factors may influence the performance of this and other innovative technologies in comparison studies- (1) operator
inexperience, (2) relative immaturity of the equipment, (3) fabric and dye incompatibility, and (4) garment labeling biases (Gottlieb et
al 1997). In particular, operator sk.ll is consistently cited as an important factor in improving the success of wetcleaning in the studies
included m this chapter (Adamson. 1998). The fabricare industry is currently working with government regulators, garment and fabric
manufacturers, and equipment manufacturers to resolve these issues in a manner that is beneficial for all stakeholders (Riggs. 1998).
6-5
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Chapter 6
Performance Data Analysis
garments. Each study summary includes general project information, results indicated or expected, and
additional results provided by researchers.
6.2.2 Alternative Clothes Cleaning Demonstration Shop (The Greener Cleaner) - Draft
Final Report (September 1996)
Sponsor: USEPA
Investigating Organization: Center for Neighborhood Technology (CNT)
Duration of Study: 12 months (May 1995 to May 1996)
Location: Chicago, Illinois
Source of Information: Center for Neighborhood Technology, 1996
Summary of Performance Evaluations
Two customer satisfaction telephone surveys of customers of The Greener Cleaner
Evaluation of a random sample of wetcleaned customer garments by The Greener Cleaner
Evaluation of identical garments before and after wetcleaning and drycleanmg
Comparison of "old" clothing after multiple wet and drycleanings
Wetcleaning Demonstration Site
Between 1995 and 1996, CNT designed, monitored, and evaluated a machine wetcleaning shop,
The Greener Cleaner. This shop was developed and operated to mimic a "typical" commercial drycleamng
shop in terms of size, price, fabric types, and garments cleaned. Exhibit 6-1 is a demonstration profile for
The Greener Cleaner operation. Using only wetcleaning equipment for this aspect of the study, CN 1
evaluated the costs and customer satisfaction associated with a range of typically drycleaned garments.
Performance results for this part of the CNT study pertain to the 1 year the shop was operated as a
demonstration site.
6-6
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Chapter 6
Performance Data Analysis
Exhibit 6-1. The Greener Cleaner Demonstration Shop Profile
Description
Location
Shop Size
Personnel
Cleaning/Drying
Equipment
Retail garment cleaning operation, plant on premises, 100%
wetcleaning
5312 North Broadway, Chicago; mini-mall shopping plaza
1250 sq.ft.
Noam Frankel (owner)
Ann Hargrove (plant manager)
1 to 2 pressers (full-time equivalent)
2 to 3 counter personnel (full-time equivalent)
Wascomat/Aqua Clean ACS50G (50 Ib. washer and 30 Ib. gas-
heated dryer)
Whirlpool domestic washing machine
Drying cabinet
Pressing/Finishing Unipress utility press
Equipment Unipress hot head press
Cissell triple puff
Cissell form finisher
Veil pants topper
Veil form finisher
Veit ironing table
Cleaning Supplies Bufa Aquasafe Detergent
for Wetcleaning Bufa Aquasafe Pre-Finish
Equipment
Sample Price List Tie
Pants
2-piece wool suit
Silk dress
Full-length down coat
$3.00
3.50
6.50
7.50
13.00
Number of
Garments
Wetcleaned
31,734 (60% labeled "dryclean only")
Exhibits 6-2 and 6-3 describe the distribution of the fiber and garment types, respectively, cleaned
during The Greener Cleaner demonstration. Blended fibers are recorded in terms of the dominant fiber or
the fiber most difficult to clean. Clothes were cleaned between May 11, 1995, and May 11, 1996. The
report recognizes that regional and seasonal variations make it difficult to develop a "typical" sample of
garments that includes an industry-wide representation of fiber types, fabrics, and garment types. The shop
accepted virtually all garments for cleaning regardless of the instructions on the care label. During the
duration of this study, 43 garments (0.14%) were rejected for machine wetcleaning if the shop employees
felt they would not be able to clean them successfully. The shop fully guaranteed its work and reimbursed
customers for the few damaged garments. Claims were paid on 28 (0.08%) of the total garments cleaned,
which included 9 lost garments, 10 garments with shrinkage, 3 garments with color loss or fading,
1 garment with a burn from pressing, 1 garment with unresolved spotting problems, and 4 garments with
miscellaneous or unreported problems.
6-7
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Chapter 6
Performance Data Analysis
Exhibit 6-2. Fiber Types Machine Wetcleaned at The Greener Cleaner
Fiber Type
Woo!
Rayon
Cotton
Silk
Linen
Polyester
Down
Unknown
Total
Number Cleaned
7,341
6,468
5,117
3,532
1,984
199
221
6,872
31,734
% of Total
23%
20%
16%
11%
6%
1%
1%
22%
100%
Exhibit 6-3. Garment Types Machine Wetcleaned at The Greener Cleaner
Garment Type
Suit
Pants
Blazer/jacket
Vest
Shirt
Blouse
Skirt
Dress
Scarf
Outerwear
Sweater
Home items
Tie
Misc.
Total
Number Cleaned
2,715
6,766
2,783
517
2.673
4,363
1,924
2,372
280
1,416
3,403
589
355
1,578
31,734
% of Total
9%
21%
9%
2%
8%
14%
6%
7%
1%
4%
11%
2%
1%
5%
100%
6-8
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Chapter 6
Performance Data Analysis
Results of Customer Satisfaction Survey
Two independent surveys were performed by Audits and Surveys Worldwide, Inc. During
November 1995, 203 of the 1,800 customers of The Greener Cleaner were randomly chosen for telephone
interviews. Eighty-five percent of these individuals rated the shop's performance as either "good" or
"excellent." In June 1996, 100 of the 2,868 shop customers were randomly chosen for the same survey.
Eighty-seven percent of these individuals rated the shop's overall service as "good" or "excellent," and
84% said they would recommend the service to a friend. The second survey indicated that 64% of the
customers used The Greener Cleaner as a result of their concern for the environment. The questions and
the results of both surveys are listed below in Exhibit 6-4.
Exhibit 6-4. Telephone Survey Questions and Results
Survey Question
1 . How would you rate their
service overall ?
2. How would you rate their
counter service overall?
3. After being serviced by
The Greener Cleaner, were
your clothes pressed and
finished nicely?
4. Was there any size
difference?
4a. Would that be ?
5. Did the seams pucker or
bulge?
6. Was there any odor
present in your clothing?
6a. If odor was present, was
this odor acceptable or
unacceptable?
7. Was there any color
change to your clothing?
Response
Excellent
Good
Acceptable
Poor
Don't know/refused
Excellent
Good
Acceptable
Poor
Don't know/refused
Yes
No
Don't know/refused
Yes
No
Don't know/refused
Shrinking
Stretching
Other
Yes
No
Not applicable
Don't know/refused
Yes
No
Don't know/refused
Acceptable
Unacceptable
Yes
No
Don't know/refused
November 1995
41.0%
45.0%
6.5%
6.5%
1.0%
49.0%
42.0%
7.0%
1 .5%
0.5%
90%
9.0%
1 .0%
14.0%
82.0%
4.0%
13.0%
1 .0%
0.0%
7.0%
87.0%
1 .0%
4.0%
3.0%
96.5%
0.5%
1 .5%
1.5%
6.0%
92.0%
2.0%
June 1996
' 48.5%
38.5%
8.0%
4.0%
1 .0%
48.5%
40.5%
9.0%
2.0%
0.0%
88.0%
9.0%
3.0%
18.0%
82.0%
0.0%
15.0%
5.0%
1 .0%
5.0%
93.0%
1.0%
1.0%
1 .0%
99.0%
0.0%
1.0%
0.0%
1 .0%
99.0%
0.0%
6-9
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Chapter 6
Performance Data Analysis
Exhibit 6-4. Telephone Survey Questions and Results (Cont'd)
7a. With regard to the
color change was
there....?
8. Were stains or spots
removed?
9. Were there any rips or
tears?
10. If your clothing had
any buttons or
decorations were any...
11. Overall, was your
clothing clean?
12. Would you
recommend The Greener
Cleaner lo a friend?
13. Why did you first take
your clothes to The
Greener Cleaner?
14. Were you aware that
the process used at The
Greener Cleaner is water
based, not the usual
solvent-based process
that is used to dryclean
clothes?
14a. How did you first
react to hearing of the
use of this water-based
process?
Overall change with improvement
Overall change, no improvement
Some unevenness in color
Don't know/refused
Yes
No
Not applicable/no spots or stains
Don't know/refused
Yes
No
Don't know/refused
Damaged
Missing
No problems/decorations
Not applicable/no buttons or
decorations
Don't know/refused
Yes
No
Don't know/refused
Yes
No
Don't know/refused
Convenient location/parking
Concern about the environment
Reputation for quality and service
Curious
Other
Don't know/refused
Yes
No
Don't know/refused
Very positive
Somewhat positive
Neither positive or negative
Somewhat negative
Very negative
Don't know/refused
0.0%
3.5%
2.0%
0.5%
60.0%
14.0%
23.0%
3.0%
2.0%
96.5%
1 .5%
3.5%
1.5%
59.0%
34.0% .
2.0%
94.5%
5.5%
0.0%
85.0%
12.0%
3.0%
Question not used
in survey
Question not used
in survey
Question not used
in survey
0.0%
0.0%
1 .0%
0.0%
63.0%
15.0%
18.0%
4.0%
8.0%
91.0%
1 .0%
0.0%
3.0%
95.0%
3.0%
0.0%
93.0%
4.0%
3.0%
84.0%
12.0%
4.0%
18.0%
64.0%
1 1 .0%
16.0%
14.0%
0.0%
87.0%
12.0%
4.0%
61 .0%
12.0%
12.0%
1 .0%
0.0%
1 .0%
Random Evaluation of Machine Wetcleaned Garments
A panel of 19 volunteers (one or two per evaluation) and a CNT engineer randomly selected 460
garments (108 knit, 352 woven) and evaluated them prior to and after washing by The Greener Cleaner.
The volunteers included 12 drycleaners, two fashion design educators, two fabric specialists working with
large retailers, and three consumers. The selected garments were not made apparent to shop personnel in
order to minimize cleaning bias. Care labels were found on 355 of the 460 garments (77%). Of those
6-10
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Chapter 6
Performance Data Analysis
garments, 68% were labeled "dryclean," "dryclean only," or "professionally dryclean." The remainder
were labeled "hand or machine wash." Exhibit 6-5 contains the results of these evaluations.
Exhibit 6-5. Results of Panel Evaluation of Wetcleaned Clothes at The Greener Cleaner
Evaluation Criteria
Overall Appearance
Excellent
Good
Fair
Poor
Presence of Odor
None detectable
Slight odor
Fresh odor
Objectionable odor
Stain Removal
No stain detectable prior to cleaning
Stain/soil completely removed
Minor stain/soil remain
Stain/soil remain
Dimensional Change - Woven Garments
0 to 2% dimensional change
2 to 4% dimensional change
Greater than 4% dimensional change
Dimensional Change - Knit Garments
0 to 2% dimensional change
2 to 4% dimensional change
Greater than 4% dimensional change
Percent of Total
28%
39%
23%
10%
87%
7%
3%
3%
53%
21%
7%
19%
62%
27%
11%
20%
22%
58%
Evaluators commented on the general appearance of the garment before and after cleaning.
Evaluators did not note any of the following problems for clothes evaluated: color unevenness,
splotchiness, tears, missing buttons, or other problems related to cleaning and finishing.
Dimensional change measurements were noted in test garments in terms of the maximum amount
per garment. In one example, a jacket shrinks 1% in length, 0% in the waist, and 2% in the sleeves. Its
maximum dimensional change is therefore reported as -2%. The variables reported for this aspect of the
evaluation included fiber type, fabric (knit or woven), garment type, color, and care label. The study
indicated that dimensional change is best correlated with fabric type (i.e., knit garments). Operators
modified their cleaning procedure by placing knit garments in mesh bags prior to washing, thus reducing
the effect of mechanical action on dimensional change. After drying to 15% residual moisture, sweaters
were placed on flat surfaces to complete the drying process.
Side-by-Side Evaluation of Identical Garments
In this test, 52 sets of identical garments (three per set) were compared throughout six wash-and-
wear cycles. One garment per set was wetcleaned at The Greener Cleaner, one was drycleaned at one of
six different shops, and the third was used as a control for comparison. Volunteers wore garments and
6-11
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Chapter 6
Performance Data Analysis
noted any unusual wearing conditions such as spills, tears, or rips. An effort was made to make these tests
blind; for example, wearers did not know which cleaning method would be used. Evaluation of the
garments took place immediately after purchase and again after multiple wash and wear cycles. Exhibit
6-6 summarizes the results of these evaluations, which include general appearance and color change.
Although both cleaning methods were evaluated with similar success in terms of color change (87% and
85%, respectively), the general appearance of wetcleaned garments had significantly lower acceptance
(63%) than the drycleaned ones (88%).
Exhibit 6-6. Side-by-Side Evaluations of Identical Wet and Drycleaned Garments
General Appearance
Drycleaned
Machine wetcleaned
Color Change
Drycleaned
Machine wetcleaned
Acceptable
88%
63%
85%
87%
Not Acceptable
12%
37%
15%
13%
Exhibits 6-7a and 6-7b summarize the evaluations of maximum dimensional change for woven
garments and fabrics. Exhibits 6-8a and 6-8b summarize the evaluations of maximum dimensional change
for knit garments and fabrics. The wool, rayon, and silk fabrics seemed to exhibit the most dimensional
change (greater than 6%) for both knit and woven garments. These results indicate that greater
percentages of wetcleaned woven and knit garments (21% and 77%, respectively) exhibit significant
dimensional change (greater than 4%) than similar drycleaned garments (5% and 38%, respectively).
Comparison of "Old" Clothing After Multiple Wet and Drycleanings
A small sample (25 garments) of volunteer-owned clothing was selected and assigned by coin toss
to either the wet or drycleaning process. Clothing samples were evaluated, cleaned six times, and re-
evaluated for evaluator and volunteer approval, as well as maximum dimensional change. Protocols
similar to those used in the previous evaluations were followed to maintain accuracy and test validity. A
greater number of the wetcleaned garments experienced more dimensional change than the drycleaned
ones. Evaluators noted that 7 of 11 wetcleaned garments and 6 of 11 drycleaned garments were judged
"good." Researchers note that the small sample size and absence of control garments limits the value of
this comparison.
Additional Comments
The CNT project was designed to mirror an average commercial drycleaning operation in terms of
volume, rates, and fabric and garment types cleaned (Patton, 1996). Prior to the release of the UCLA
wetcleaning study, the CNT study represented one of the most complete wetcleaning studies to date.
Researchers concluded that wetcleaning, although not a complete replacement for drycleaning, is a viable
substitute for a significant percentage of clothing labeled "dryclean only." They also concluded that the
many variables associated with performance assessment make it difficult to establish a generic guide
appropriate for commercial cleaning shops (CNT, 1996).
6-12
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Chapter 6
Performance Data Analysis
Exhibit 6-7a. Maximum Dimensional Change for Woven Garments3
Garment
Type
Pants
Jacket
Vest
Shirt
Blouse
Skirt
Scarf
Coat
Tie
Total
% of Total
0-2% Dim. Change
Wet
5
3
2
4
1
15
38%
Dry
6
5
2
1
4
1
1
20
51%
2-4% Dim. Change
Wet
6
•2
1
4
3
16
41%
Dry
5
1
1
3
1
4
2
17
44%
4-6% Dim. Change
Wet
2
1
3
8%
Dry
1
1
2
5%
6+% Dim. Change
Wet
1
1
2
1
5
13%
Dry
0
0%
Total
Number
11
7
2
1
1
8
1
5
3
39
' Thirty-nine sets of woven garments were analyzed in this comparison.
Exhibit 6-7b. Maximum Dimensional Change for Woven Fabrics3
Fabric
Type
Cotton
Wool
Rayon
Silk
Linen
Acrylic
Polyester
Total
% of Total
0-2% Dim. Change
Wet
1
5
3
1
1
1
3
15
38%
Dry
1
8
4
1
2
1
3
20
51%
2-4% Dim. Change
Wet
2
7
1
3
2
1
16
41%
Dry
2
7
3
3
1
1
17
44%
4-6% Dim. Change
Wet
1
2
3
8%
Dry
1
1
2
5%
6+% Dim. Change
Wet
2
3
5
13%
Dry
0
0%
Total
Number
4
16
7
4
3
1
4
39
' Thirty-nine sets of woven garment fabrics were analyzed in this comparison.
6-13
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Chapter 6
Performance Data Analysis
Exhibit 6-8a. Maximum Dimensional Change for Knit Garments3
Garment
Type
Pants
Shirt
Sweater
Total
% of Total
0-2% Dim. Change
Wet
0
0%
Dry
2
2
15%
2-4% Dim. Change
Wet
3
3
23%
Dry
1
5
6
46%
4-6% Dim. Change
Wet
2
2
15%
Dry
3
3
23%
6+% Dim
Wet
1
1
6
8
62%
Change
Dry
1
1
2
15%
Total
Number
1
1
11
13
1 Thirteen sets of knit garments were analyzed in this comparison.
Exhibit 6-8b. Maximum Dimensional Change for Knit Fabrics3
Fabric
Type
Cotton
Wool
Rayon
Silk
Linen
Acrylic
Total
% of Total
0-2% Dim. Change
Wet
0
0%
Dry
1
1
2
15%
2-4% Dim. Change
Wet
1
1
1
3
23%
Dry
3
3
6
46%
4-6% Dim. Change
Wet
1
1
2
15%
Dry
1
1
1
3
23%
6+% Dim
Wet
3
1
4
8
62%
Change
Dry
2
2
15%
Total
Number
1
4
1
5
1
1
13
" Thirteen sets of knit garment fabrics were analyzed in this comparison.
6-14
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Chapter 6
Performance Data Analysis
6.2.3 Final Report for the Green Clean Project (October 1995)
Sponsors:
Investigating Organization:
Duration of Study:
Location:
Source of Information:
Environment Canada, Korean Dry Cleaners Association, Ontario
Fabricare Association, Ontario Ministry of Environment and
Energy
Environment Canada
Phase I - June to November 1994: Phase II- December 1994 to
February 1995; Phase III - September 1995 to March 1996
Phase I - Toronto and Markham, ONT; Phase II - Toronto,
Markham, and Windsor, ONT; Phase III - Hamilton, ONT
Environment Canada, 1995
Summary of Performance Evaluations
Customer response surveys (Survey I - wet and steam options; Survey II - wet. steam, and dry
options; Survey III - dry option) to rate garment appearance, fit, damage, cleaning, and repeat visit
' potential
• Analysis of customer claims based on first 6 months of Phase I
• Fabric swatch studies (related to shrinkage, color change, soil removal, and effect on fusible
interfacing) performed for Environment Canada at the University of Guelph, Textile Science
Group
• Comparison of 13 dry and wetcleaned consumer garments in terms of shrinkage, pressing quality
and visual appearance, and pressing and finishing time
Project Description
Exhibit 6-9 provides a demonstration shop profile for the wetcleaning operation undertaken for
this study. Exhibit 6-10 is a profile of the garment and fabric types wetcleaned during the same period.
Phase I of this study consisted of establishing a "drop-off site (Green Clean Depot) for
researching and evaluating customer acceptance of solvent-free cleaning (wetcleaning and steam cleaning
with no drycleaning option). Multi-process wetcleaning technology was installed at two existing
drycleaning plants.
6-15
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Chapter 6
Performance Data Analysis
Exhibit 6-9. Wetcleaning Shop Profile for the Green Clean Project8
Description
Location
Shop Size
Wet
Cleaning
Equipment1
Drying
Equipment
Finishing
Equipment
Cleaning
Supplies
Sample
Price List
Multiple garment cleaning plants; wet and drycleaning equipment on premises
Toronto, Ontario, Canada
Varies
IPSO/Aqua Tex: HFH 145 (18 Ib), 324 (50 Ib), 304 (70 Ib)
Milnor 30022F8W (33 pounds)
Aqua Clean: SOS (18 pounds), 50S (30 pounds), 805 ( 80 pounds)
Unimac: UA 75, 160 (12 pounds), 230 (20 pounds), 400 (52 pounds)
MieleWS5190TR
Aqua Tex - American W/C (30 pounds)
American: ADS 50 (30 pounds) and 75 (45 pounds)
Aqua Clean S & G 30 (18 pounds), 50 (30 pounds), 80 (48 pounds)
Unimac DTB - 50/75 CSHPMM (18 pounds, 30 pounds, 45 pounds)
Miele T6550 TR
Not specified
Not specified
Not specified
• All machine capacities (pounds) represent 60% of laundry capacity specified by manufacturer.
In Phase II a private operator took over the Green Clean Depot. Three additional wetcleaning
locations were established. Customers were given the option of multi-process wet or drycleaning.
In Phase III an existing drycleaning plant was converted to a wetcleaning-only facility. During this
phase project participants evaluated the financial viability of a wetclean-only plant, as compared to a
drycleaning alternative.
The results presented in the October 1995 report study were collected between June 1994 and
February 1995- They apply to all of Phase I and the first 3 months of Phase II.
Customer Satisfaction Survey
Up to three survey cards per customer were distributed with each garment cleaned. Postage was
pre-paid on cards for return mail, and cards were also accepted at the drop-off points. A breakdown of the
survey response is as follows: 412 responses for Survey I on wet and steam options (June 6 to November
30, 1994); 60 responses for Survey II on wet, steam, and dry options (December 1994 to February 1996);
and 201 responses for Survey III on drycleaning only (November 1994 to April 1995). Note that the
survey schedule does not necessarily correlate with the project schedule. Also, the Survey II results are not
differentiated in terms of cleaning method.
6-16
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Chapter 6
Performance Data Analysis
Exhibit 6-10. Garment Profile Summary for the Green Clean Depot
Garment Type
Bedding
Coat
Drapes
Dress
Pants
Shirt (hand pressed)
Skirt
Shorts
Suit jacket
Suit vest
Sweater
Ties
T-shirt
Machine pressed shirts
Other
Fabric Type
Cotton, polyester, nylon
Wool
Wool polyester mix
Angora/cashmere
Linen
Rayon
Silk
Rayon linen/acetate viscose mix
Rayon, cotton, linen mix
Rayon, linen, ramie mix
Down
Leather and suede
Unknown
Total
Number Cleaned
June-November
1994
72
231
18
217
916
547
443
53
757
71
258
20
26
1,391
162
905
815
308
37
195
439
315
321
152
112
29
29
134
5,182
Number Cleaned
December 1994-
February 1995
29
102
2
68
446
248
140
3
258
27
172
11
5
385
52
333
450
8
48
89
176
141
90
11
15
14
0
188
1,948
Exhibit 6-11 is a summary of the results obtained from customer satisfaction surveys. Exhibit 6-12
summarizes the negative responses received for each survey. The results of the second survey do not
distinguish which of the three cleaning methods was chosen by customers. In addition, the response rates
for Surveys II (9.7%) and III (3.5%) were much lower than the response rate for Survey I (27.4%). The
Green Clean report makes the following overall observations regarding these customer response surveys:
• There was little difference in the amount of garment shrinkage reported on the surveys.
• Garment damage was not significant, with the exception of button deterioration associated with
drycleaning.
In evaluating general appearance, 97% of customers who chose wetcleaning (Survey I), 97% of
customers who chose wet/steam/drycleaning (Survey II), and 98% of customers who chose
drycleaning (Survey III) stated that their clothing was clean overall.
6-17
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Chapter 6
Performance Data Analysis
Exhibit 6-11. Summary of Customer Satisfaction Surveys3
Survey Question
Garment Appearance
- Are clothes pressed/finished
nicely?
- Is the shaping/body OK?
- Do any seams pucker or bulge?
- How is the color?
Garment Fit
-How/sfhes/ze?
Garment Damage
- Are there any new tears?
- Are buttons and decorations OK?
Garment Cleaning
- Is the clothing clean overall?
- Were stains or spots removed?
- Is any unpleasant odor present?
Customer Return
- Will use Cleaner again
Response
Yes
No
Yes
No
Yes
No
No change
Some improvement
Not an improvement
No change
Some shrinkage
Some stretching
Yes
No
Yes
Not applicable
Broken or missing
Yes
No
Not applicable
Yes
No
Yes
No
Yes
No
Number of Surveys Returned
Survey Response Rate
SI - Wet/Steam
Clean
Options'
93%
7%
96%
4%
4%
96%
89%
9%
3%
95%
5%
<1%
0%
100%
89%
11%
<1%
97%
3%
44%
50%
6%
1%
99%
95%
5%
412
27.4%
Sll - Wet, Steam,
and Dry Options'"
90%
10%
95%
5%
1%
99%
83%
11%
6%
, 98%
0%
2%
0%
100%
87%
12%
1%
97%
3%
42%
51%
7%
2%
98%
97%
3%
60
9.7%
Sill - Dry
Option
Onlyc
97%
3%
98%
2%
2%
98%
91%
6%
3%
95%
5%
0%
0%
100%
77%
17%
6%
98%
2%
39%
55%
5%
5%
95%
98%
201
3.5%
• Wet and steam cleaning performed at two facilities for Survey I.
"Wet, steam, and drycleaning performed at one facility for Survey II.
' Drycleaning performed at six facilities for Survey III.
6-18
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Chapter 6
Performance Data Analysis
Exhibit 6-12. Summary of Customer Satisfaction Surveys with Negative Responses
Survey Question
Garment Appearance
- Not pressed and finished nicely
- Shaping or body not OK
- Seams pucker or bulge
- Change in color of garment, no
improvement
Garment Fit
- Some shrinkage/stretching
Garment Damage
- Tears
- Buttons and decorations not OK
Garment Cleaning
- Garment is not clean overall
- Odor
- Stains and spots not removed
Customer Return
- Will not use Cleaner again
Number of Surveys Returned
Survey Response Rate
Survey I*
Number of
Responses
29
17
16
13
24
0
3
13
5
25
20
Wetclean
19
12
11
10
14
0
3
10
5
18
16
Steam Clean
10
5
5
3
10
0
0
3
0
7
4
412
27.4%
Survey llb
Number of
Responses
5
3
0
4
1
0
1
2
1
5
2
60
9.7%
Survey lllc
Number of
Responses
7
4
4
5
10 •
0
12
5
10
11
3
201
3.5%
* Wet and steam cleaning performed at two facilities for Survey I.
b Wet, steam, and drycleaning performed at one facility for Survey I
c Drycleaning performed at six facilities for Survey III.
Responses regarding stain and spot removal did not vary significantly among the three surveys.
Customers were most dissatisfied with the color change associated with the wetcleaning-only
option.
Wetclean and dryclean-only customers responded similarly to questions about garment size.
Analysis of Customer Claims
Customer claims about damaged clothing were analyzed using the IFI's Fair Claims Guide
Claims were paid on 14 out of 3,791 garments cleaned during the first 6 months of operation (Survey I) of
the Green Clean Depot (7 - color/dye run; 5 - shrinkage; 2 - stains and cracking). Out of 1,563 garments
washed, 2 claims resulting from wetcleaning silk and specialty wool were paid between December 1994
and February 1995 (Survey II).. No claims are mentioned in this study for the Survey III period.
6-19
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Chapter 6
Performance Data Analysis
Fabric Swatch Studies
Some data regarding fabric swatch studies performed at the University of Guelph (Section 6.2.7)
are presented in this study. Swatches were tested using drycleaning (Lindus Dry-to-Dry Refrigerated
System) wetcleaning (Wascomat Aqua Clean Washer and Dryer System; IPSO Washer and American
Dryer System), home laundering (Maytag Top-loader Laundry Machine), steam cleaning (steam gun and
detergent spray treatment), and pressing only.
The following types of fabric swatches were tested in this experiment: undyed test fabrics (for
shrinkage) dyed consumer fabrics (for shrinkage and color change), standard soiled fabrics (for soil
removal), and bonded fabrics (for determining effects on fusible interfacing). All fabrics, except bonded
fabrics were prepared and measured by students and faculty in the Textile Science Group at the University
of Guelph Bonded fabrics were prepared and evaluated by Canada Hair Cloth, a Canadian manufacturer.
A total of 414 swatches were processed 950 times at two drycleaning facilities in Toronto with regular
garment loads. Pressing was completed according to ASTM D-2724-87 (Bonded Apparel Fabrics
Method) by Environment Canada staff.
Exhibit 6-13 contains the results for the shrinkage studies on processed undyed fabric swatches.
The study identifies both rayon and wool as fabrics with "problem shrinkage." Past experience with
drycleaning, however, indicates that shrinkage may have been exaggerated for the undyed test fabrics in
this study (Environment Canada, 1995).
Exhibit 6-13. Percent Warp Shrinkage of Undyed Fabrics After One Cleaning3
Fabric Swatch
Press
Only
Dryclean
Steam
Clean
Low Shrinkage (Less than 3%)
Polyester plain
Cotton/polyester
Silk
0.00
0.00
0.27
0.80
0.00
0.00
0.67
0.47
-0.13
Moderate Shrinkage (Less than 5%)
Acetate
Mercerized cotton
Cotton
Worsted wool
Linen
1.33
0.00
0.80
2.13
0.53
1.87
0.40 -•
3.47
3.07
0.80
3.13
3.73
6.73
5.07
2.93
Problem Shrinkage (more than 5%)
Wool
Rayon
2.00
0.93
2.53
0.27
4.40
4.40
Home
Laundry
1.73
0.40
4.67
3.07
5.20
10.00
10.40
8.13
12.27
7.87
Wetclean
(GC)
1.47
0.53
-0.53
2.80
4.27
7.60
6.40
5.13
7.53
6.07
Wetclean
(WC)
0.80
0.40
0.40
3.60
4.40
8.40
6.13
4.80
7.33
7.33
• Percent shrinkage is calculated on the basis of original measurements on fabrics.
6-20
-------
Chapter 6
Performance Data Analysis
Exhibit 6-14 contains the results of a shrinkage study performed on dyed consumer fabrics that
were donated by garment manufacturers. Problem shrinkage was exhibited in the following fabrics:
polyester after one drycleaning, light wools and polyester after five wetcleanings, and laundered light
wools and polyesters after one or more cleanings. Steam cleaning produced no problems except for slight
bubbling of polyester after the fifth cleaning. There was a wide range of results for bonded fabric
interfacing, indicating the difficulty in predicting results for some cleaning methods, especially
wetcleaning.
Exhibit 6-15 contains the results of standard soil removal tests for cotton fabric swatches. In
addition, a white swatch area was evaluated for soil redeposition. Results for drycleaning indicate that it
was deficient in cleaning blood and red wine and had the highest amount of redeposition. Wetcleaning
was most effective with blood and red wine and had the lowest amount of redeposition. Home laundry
removed the highest amount of carbon black/mineral oil. Steam cleaning seemed to have little or no soil
removal capacity.
Exhibit 6-14. Percent Shrinkage Results for Consumer Fabric Swatches3
Fabric Swatch
Press
Only
Dry clean
Steam
Clean
Low Shrinkage (Less than 3%)
100% Polyester plain
55% Cotton/45% polyester plain
100% Polyester twill
100% Mercerized cotton ripstop
100% Silk
50% Linen/50% polyester
0.0%
0.0%
1.2%
0.1%
0.7%
0.4%
0.4%
0.0%
2.1%
0.3%
0.0%
0.5%
1.1%
0.0%
1 .5%
1.6%
0.0%
1.3%
Wetclean
(Wascomat)
1.2%
0.0%
2.0%
2.0%
- 0.3%
1 .2%
Moderate Shrinkage (Less than 5%)
70% Wool/20% nylon/10% cashmere
1 .6%
1.6%
4.3%
4.7%
Problem Shrinkage (more than 5%)
96% Cotton/4% lycra twill
64% Acetate/36% rayon crepe
95% Rayon/5% silk
100% Wool (loose weave)
0.8%
1.7%'
0.1%
0.0%
4.1%
1 .6%
2.0%
1.1%
3.2%
4.8%
5.1%
2.4%
5.7%
8.7%
9.3%
5.5%
Wetclean
(IPSO)
0.5 %
0.0%
0.9%
1.7%
- 0.9%
1 .3%
4.3%
5.2%
7 3%
5.9%
5.3%
Home
Laundry
31%
0.1%
4.9%
2 7%
1 5%
21%
8.4%
10.1%
9 5%
14.4%
8 3%
Results are presented for maximum shrinkage in either warp or weft direction after one cleaning Results in most cases are for
40 cm (15 mch) square fabnc swatches with triplicate measurements. Results were within the 99% confidenceTnterlal for 98 5%
of measurements. Results were within the 95% confidence interval for 100% of measurements ")nr'aence lmerval Tor 9H-5 /0
6-21
-------
Chapter 6
Performance Data Analysis
Exhibit 6-15. Percent Soil Removal from Standard Soil Test Fabrics
Soil Type
Unsoiled (redeposition)
Carbon black/mineral oil
Cocoa
Blood
Red wine
Dryclean
6
30
18
8
4
Steam
Clean
2
10
0
0
2
Home
Laundry
3
68
16
39
14
Wetclean (IPSO
& Lever)
—
7
58
10
Wetclean
(Aqua Clean)
20
20
Garment Comparison Study
Thirteen sets (three identical garments per set, including one control) of consumer garments were
compared after multiple wet and drycleanings. Garment samples were selected to ^^J^S
tvnicallv drvcleaned They were wet and drycleaned five times with other laundry loads, alternating
K2 fthTtwTfacilities dressing facilities included a medium/large facility (Cleaner A) and a relatively
small facility (Cleaner B) in order to assess differences in pressing times.
Results for shrinkage, pressing quality, visual appearance, and pressing and f'nishin§ j
in Exhibits 6-16, 6-17, and 6-18. In general, results for shrinkage and finishing quality
^ntextite type. Finishing problems are noted for the rayon blouse (wet) cotton knit shorts (wet
;) v°scose/linen jacket (wet and dry), wool/viscose dress (wet), and wool/polyester/pmstnpe dress
(wet and dry).
Pressing and finishing time was reported to be a function of shrinkage; that is, garments with
significant shige require more time to return to their pre-cleaning state. Wetcleaned garments required
between 5% and 50% more pressing time, compared to drycleaned garments. Exhibit 6-18 presents a
range as a result of differences identified in facility scale, and percent capacity used of dry and
wetcleaning options. It was concluded that some garments should not be wetcleaned based on the amount
of pressing time required to adequately restore them .
6-22
-------
Chapter 6
Performance Data Analysis
Exhibit 6-16. Percent Garment Shrinkage Results Before and After Pressing3
Color
Red
Patterned
Multi-color
Beige
Brown
Grey
Patterned
Black/White
Patterned
Black/White
Light Green
Patterned
Multi-color
White
Light Blue
Dark Blue
Brown
Pinstripe
Material
Garment
Point of
Measure
Cleaner Ab
Dryclean
Wetclean
Garments with Shrinkage Less than 3%
100% Silk
100% Silk
100% Linen
1 00% Cotton
100% Wool
100% Wool
100% Wool
100% Polyester
100% rayon
100% cotton knit
80% Viscose
20% Linen
60% Wool
40% Viscose
99% Wool
1 % Polyester
Shirt (Protocol)
Tie
(Leo Chevalier)
Shirt
(Dalia)
Pants
(Functionals)
Pants
(Protocol)
Pants
(Cool Wool)
Suit Jacket
(Cool Wool)
Suit Jacket
(Tan Jay)
After drying
After pressing
After drying
After pressing
After drying
After pressing
After drying
After pressing
After drying
After pressing
After drying
After pressing
After drying
After pressing
After drying
After pressing
0.7%
0.0%
0.5%
- 0.6%
0.3%
0.0%
1 .3%
0.5%
0.5%
0.0%
1.3%
0.0%
0.4%
0.1%
0.3%
0.3%
Garments with Shrinkage Greater than 3%
Blouse w/pads
(Jessie)
Shorts
(Divine One)
Suit Jacket
(Sterling)
Dress
(Holt Renfrew)
Dress
(Holt Renfrew)
After drying
After pressing
After drying
After pressing
After drying
After pressing
After drying
After pressing
After drying
After pressing
0.9
0.4
1.2
0.8
1.4
0.8
1.2
0.9
0.5
0.2
1 .3%
1.1%
0.5%
- 0.3%
1.6%
1 .2%
1 .4%
0.8%
1 .6%
0.8%
1.8%
0.7%
0.5%
0.8%
0.9%
0.9%
5.4
4.4
15.2
15.6
5.7
3.7
4.5
1.7
9.9
8.0
Cleaner Bc
Dryclean
1 .7%
0.5%
2.2%
0.8%
1.2%
0.8%
1 .8%
0.9%
1.2%
0.1%
0.3%
0.0%
1.3%
0.5%
0.7%
0.4%
2.1
0.5
4.6
4.2
2.2
1.0
2.0
0.6
1.7
0.5
Wetclean
1.2%
1 .0%
1.6%
0.1%
1 .7%
1.1%
1 .4%
0.8%
1.8%
1 .2%
2.2%
0.6%
1.3%
0.4%
1.3%
1.1%
6.5
3.0
16.0
14.5
7.6
2.7
4.8
1.5
10.0
4.6
a Shrinkage results are calculated from original reference measurements and are cumulative effects. Results are for the same
garments after four and five cleanings, respectively, for Cleaner A and Cleaner B.
b Cleaner A cleaned and pressed garments for the second and fourth treatments.
c Cleaner B cleaned and pressed garments for the first, third, and fifth treatments.
6-23
-------
Chapter 6
Performance Data Analysis
Exhibit 6-17. Garment Pressing Quality
Color
Material
Garment
Cleaner A"'b
Dryclean
Wetclean
Cleaner B"'c
Dryclean
Wetclean
Garments with Low Shrinkage (Less than 3%)
Red
Patterned multi-color
Beige
Brown
Grey
Patterned black/white
Patterned black/white
Light green
100% Silk
100% Silk
1 00% Linen
100% Cotton
100% Wool
100% Wool
100% Wool
1 00% Polyester
Shirt (Protocol)
Tie (Leo Chevalier)
Shirt (Dalia)
Pants (Functionals)
Pants (Protocol)
Pants (Cool Wool)
Suit jacket
(Cool Wool)
Suit jacket
(Tan Jay)
B
A
B
A
A
A
A
A
B
A
B
A
A
A
A
A
A
A
A
A
A
A
A
A
A
A
A
A
A
A
A
A
Garments with Problem Shrinkage (More than 3%)
Patterned
multi-color
White
Light blue
Dark blue
Brown pinstripe
100% Rayon
100% Cotton knit
80% Viscose
20% Linen
60% Wool
40% Viscose
99% Wool
1 % Polyester
Blouse w/pads
(Jessie)
Shorts
(Divine One)
Suit jacket
(Sterling)
Dress
(Holt Renfrew)
Dress
(Holt Renfrew)
A
B
B
B
B
A
A
D
B
D
A
B
B
B
B
A
A
C
B
C
• A - Finished Nicely; B -
b Cleaner A cleaned and
€ Cleaner B cleaned and
Some Minor Defects; C - Many Minor Defects; D - Major Defects/Possible Claim/Unwearable.
pressed garments for the second and fourth treatments.
pressed garments for the first, third, and fifth treatments.
6-24
-------
Chapter 6
Performance Data Analysis
Exhibit 6-18. Garment Pressing Time
Color
Red
Patterned
multi-color
Beige
Brown
Grey
Patterned
black/white
Patterned
black/white
Light green
Material
Garment
Cleaner A*
Dryclean
(min.)
Wetclean
(min.)
% More
W/C
timec
Cleaner B"
Dryclean
(min.)
Wetclean
(min.)
Garments with Low Shrinkage (less than 3%)
100% Silk
100% Silk
100% Linen
100% Cotton
100% Wool
100% Wool
100% Wool
100%
Polyester
Shirt
(Protocol)
Tie
(Leo
Chevalier)
Shirt (Dalia)
Pants
(Functionals)
Pants
(Protocol)
Pants
(Cool Wool)
Suit Jacket
(Cool Wool)
Suit Jacket
(Tan Jay)
2.4
0.5
2.9
1.9
2.4
1.8
2.5
1.8
2.5
0.5
2.8
1.9
2.6
2.0
2.6
1.5
3%
0%
-3%
0%
7%
9%
3%
-18%
2.9
0.3
4.0
1.8
1.9
2.3
3.3
2.5
3.3
0.3
4.3
1.8
2.3
2.7
3.8
2.3
% More
W/C
timec
11%
0%
8%
0%
17%
15%
15%
-10%
Garments with Problem Shrinkage (more than 3%)
Patterned
multi-color
White
Light blue
Dark blue
Brown
pinstripe
100% Rayon
1 00% Cotton
knit
80% Viscose
20% Linen
60% Wool
40% Viscose
99% Wool
1% Polyester
Blouse
w/pads
(Jessie)
Shorts
(Divine One)
Suit Jacket
(Sterling)
Dress
(Holt
Renfrew)
Dress
(Holt
Renfrew)
0.9
1.0
3.1
1.2
3.5
0.9
0.9
3.9
2.3
6.3
0%
-8%
27%
99%
81%
1.5
1.2
3.5
2.7
3.3
1.7
1.0
6.7
3.8
7.8
11%
- 15%
91%
43%
135%
• Cleaner A cleaned and pressed garments for the second and fourth treatments.
b Cleaner B cleaned and pressed garments for the first, third, and fifth treatments.
c W/C denotes wetcleaning.
6-25
-------
Chapter 6
Performance Data Analysis
6.2.4 Pollution Prevention in the Garment Care Industry: Assessing the Viability of
Professional Wetcleaning, Final Report (Cleaner by Nature) (December 11,1997)
Sponsors:
Investigating Organization:
Principal Investigator:
Duration of Study:
Location:
Source of Information:
South Coast Air Quality Management District, California Air
Resources Board, USEPA Office of Research and Development,
UCLA Center for Environmental Risk Reduction, University of
California Toxic Substances Research and Training Program,
Occupational and Environmental Division of the Los Angeles
County District Attorney's Office
UCLA /Occidental College, Pollution Prevention Education and
Research Center
Robert Gottlieb
1 year (February 1996 to January 1997)
Los Angeles, California
Gottlieb et al., 1997
Summary of Performance Evaluations
Profile of customer garments cleaned at Cleaner by Nature, including information about the care
labels of garments, the garment type, and the fiber type
Analysis of rejected garments, redos, and customer claims to provide a quantitative measurement
of the extent and type of garments that pose a problem for professional wetcleaning
Repeat clean test to compare professional wetcleaning and drycleaning performance after the
repeated wearing and cleaning of "dryclean only" labeled garments
Survey of volunteers wearing the garments used in the repeat clean test, used to compare the
results from the quantitative measurement of test garments in the repeat clean test with the
experience of customers wearing these same garments
Telephone survey of Cleaner by Nature and drycleaning customers, used to measure their
experience and level of satisfaction with the professional wetcleaning process compared to the
drycleaning process
Cleaner by Nature Wetcleaning Demonstration Site
The Cleaner by Nature demonstration site opened on February 6, 1996, as a wetcleaning-only
facility, located in Los Angeles, California. A drop-off store was located in Santa Monica. The combined
operation was set up as a small drycleaning shop, with the exception of the cleaning equipment. Exhibit 6-
19 contains a demonstration profile for this wetcleaning operation.
A total of 34,950 garments were processed by Cleaner by Nature during the first year of operation
(February 1, 1996, and January 31, 1997). However, a computer register failure during the months of
October, November, and December 1996 corrupted some of the data set for this study. Additional data
were lost for the month of August 1996; however, data are included from March 11 to April 11, 1997.
Therefore, in some instances data analyzed in the final report are from variable time periods, as specified in
the following summaries.
6-26
-------
Chapter 6
Performance Data Analysis
Exhibit 6-19. Demonstration Shop Profile for Cleaner by Nature
Description 100% wetcleaning operation with a Santa Monica agency and a Los Angeles plant
Location 2407 Wilshire Blvd., Santa Monica, CA 904023 (agency)
3317 La Cienega Place, Los Angeles, CA 90016 (plant)
Size -850 sq. ft. (agency)
~ 2,000 sq. ft. (plant)
Personnel 1 full-time clerk, 1 to 2 part-time clerks, 1 part-time delivery person (agency)
1 full-time cleaner, 1 part-time presser, 1 part-time assembly person (plant)
Cleaning/Drying Aquatex 30/50 Ib. microprocessor washer
Equipment Aquatex 50 Ib. microprocessor dryer
Maytag domestic washer
Maytag domestic dryer
Pressing/Finishing Forenta hot head press
Equipment Forenta utility press
Cissell steam iron (2)
Forenta upright pant topper (reconditioned)
Cissell form finisher (reconditioned)
Forenta 3-way puff (reconditioned)
High-steam JAM 500 tensioning form fitter (reconditioned)'
High-steam RAM 200 tensioning pant topper (reconditioned)*
Spotting Board
Lattner 9.5 HP gas boiler
Rol-Aire 5 HP vertical compressor
Vertical dryset vacuum
800 slot conveyor (Iowa Tech)
Rayne water conditioning unit
Aquatex detergent
Aquatex finish
Aquatex leather detergent
Aquatex leather finish
Wash cycle 18 to 20 minutes
Dry cycle 15 to 30 minutes
Other Equipment
Cleaning Supplies
Cycle Length
Sample Price List
Pants/skirt
2-Piece suit
Dress
Shirt/blouse
$4.15
8.75
7.75
4.35
' Purchased in September 1996; tensioning equipment has replaced the function of the Forenta pant topper and Cissell form
finisher originally purchased by Cleaner by Nature.
Profile of Customer Garments
Exhibit 6-20 shows a profile of the garment types cleaned by Cleaner by Nature from February to
September 1996 and for January 1997. During this time period a total of 23,094 identifiable garments and
559 unidentifiable garments were wetcleaned at the facility. The study notes that jackets may be under-
represented because of the missing data for the colder months of October, November, and December
However, garment profile data collected by a drycleaner during January 1997 are comparable to the data
collected by Cleaner by Nature for the duration of the study.
6-27
-------
Performance Data Analysis
Exhibit 6-20. Garment Types Cleaned at Cleaner by Nature
(February 1 to September 30,1996, January 1997)
Garment Type
Pants
Shirts/blouses
Suit jackets/outer jackets
Sweaters
Dresses
Skirts
2-piece suit, 2-piece tuxedo3
Bedding"
Household items0
Vests
Shorts
Ties
Miscellaneous11
Unknown
Total
Total
5,675
5,456
2,267
2,142
1,726
1,311
794
442
686
334
427
198
1,077
559
23,653
Percentage
24.0
23.1
9.6
9.1
7.3
5.5
3.4
1.9
2.9
1.4
1.8
0.8
4.6
2.4
100.0 %
a Two- and three-piece suits are counted as one item.
b Includes sheet, pillow case, sham, and comforter.
0 Includes tablecloth, curtain, napkin, drape, and sofa cover.
d Includes coat, raincoat, hat, gloves, robe, three-piece suit, jumpsuit,
nightwear, shawl, culottes, shoes, and sleeping bag.
Exhibit 6-21 provides a profile of fiber types for the garments cleaned during the demonstration
period. This data set includes 60% (20,808/34,950) of those garments cleaned for which fibers could be
properly identified. The percentage of wool garments cleaned during the demonstration period may be
under-represented because of the corrupted data for October, November, and December. Wool, linen,
mohair, silk, cashmere, rayon, and acetate fibers, which are all typically drycleaned, account for 70% of all
garments cleaned by Cleaner by Nature. Cotton was the fiber cleaned most frequently by Cleaner by
Nature (24%).
6-28
-------
Chapter 6
Performance Data Analysis
Exhibit 6-21. Fiber Types Cleaned at Cleaner by Nature (February 1,1996 to January 1997)a
Fiber
% of Total
Wool
18.8%
Downb
0.6%
Misc.c
1.1%
Linen
10.9%
Silk
15.5%
Cashmere
0.9%
Rayon
21.9%
Acetate
2.3%
Polyester6
4.3%
Cotton"
23.8%
a This profile of fiber types represents 60% of the garments cleaned by Cleaner by Nature, for which fiber information was available
(20,808/34,950).
b Cotton, polyester, and down are not fibers normally labeled "dryclean only."
c Miscellaneous (Misc.) includes acrylic, leather, and ramie.
Pro/lie of Problem Garments
During the demonstration period, Cleaner by Nature kept records on four types of problem
garments:
Rejects - garments turned away by the cleaner because they could not be safely cleaned;
• Customer claims - damaged or lost garments that needed to be replaced;
• Store credits - store credit awarded for damaged or lost garments; and
Redos - garments brought back by customers who felt their clothing required additional attention.
The number of rejects was tracked at Cleaner by Nature from February 1996 to August 1996 and
from September 1996 through January 1997. A total of 33 items (0.09% of total) were rejected by Cleaner
by Nature, the majority because of potential problems with colorfastness (90%). There was no
comparative information on rejects available for drycleaning.
The number of claims (cash payments for lost or damaged garments) paid to Cleaner by Nature
customers was tracked from February 1996 to August 1996, September 1996 to January 1997, and March
11, 1997, to April 11, 1997. There were a total of 14 customer claims on the 44,860 garments cleaned
during these periods. Over half of the claims (eight) were related to shrinkage problems. The study notes
that there was a decline in the claim rate as a result of the increased experience of the cleaner at the facility.
In addition to cash payments made for claims on lost or damaged garments, Cleaner by Nature
issued store credit when problems occurred with garments. Data for store credit issued were collected
from November 1996 through April 11, 1997. During this 5-month period, the store manager reported
issuing store credit for 8 garments out of 21,937 cleaned (0.037%). Researchers combined the claims rate
for the post-start-up period (0.010%) and the store credit rate for this 5-month period (0.037%) for a total
rate of 0.047% (11 out of 21,937 garments).
The study also compared the claims and store credit rate for Cleaner by Nature with those of a
local drycleaning facility. Researchers note that the drycleaner had a policy of awarding store credit as
rarely as possible, which is the reason for combining the store credit and claims data in this comparison.
Even though lost garments are not necessarily a direct measure of cleaning performance, they are included
in the analysis because the owner of the drycleaner suspected that spotters who ruin garments may be
tempted to "lose" garments in order to avoid responsibility for the damage. Cleaner by Nature's combined
claims/store credit rate (0.047%, or 11 of 21,937 garments cleaned) was about three times greater than the
figure for the drycleaner (0.015%, or 16 of 107,692 items cleaned).
6-29
-------
Chapter 6
Performance Data Analysis
The total redo rate for Cleaner by Nature was 0.52% (163 redos out of 31,524 garments cleaned)
for data collected between February 1996 and January 1997, but excluding August 1996. This redo rate is
comparable to that of a local drycleaner, whose overall redo rate was 0.45% (59 redos out of 13,256
garments cleaned). Spotting (i.e., stain removal) was reported as the most common reason for a redo
(40%), followed by pressing (25%), shrinkage (25%), colorfastness problems (4%), odor (3%), and other
miscellaneous damage (3%). The study reports that the redo rate was related to the level of expertise of the
facility's cleaners, noting that the redo rate increased in months when a new cleaner was hired. The
following related observations were reported, including:
There was a general decline in the percentage of garments returned for problems related to spotting
and shrinkage during the study period.
Pressing problems did not appear to decline over the study period, which is potentially related to
the high turnover rate for pressers.
Customers returned silk garments for additional work at a higher than expected rate (25% of all
redos were silk).
• Thirty-nine percent of all spotting problems were related to silk garments.
Thirty-six percent of all pressing problems were related to wool garments, and 18% were related to
linen garments.
• Fifty-four percent of garments redone for shrinkage were rayon.
Repeat Clean Test
A blind repeat clean test was used to compare the performance of wet and drycleaning on garments
labeled "dryclean only" after repeated cleaning and wear. Three identical sets of 40 "dryclean only"
garments were obtained for the test. One of the sets was wetcleaned six times, another drycleaned six
times, and a third stored for comparison. Volunteers were recruited to wear two garments from the wet
and drycleaned sets between cleanings. Trained evaluators were used to determine changes in garment
dimensions, general appearance, color, color migration, and odor.4 Evaluators and wearers were not
informed as to which garments were being dry or wetcleaned. Garment types included shirts/blouses,
pants, skirts, dresses, jackets, sweaters, vests, and ties. Fiber types included acetate, acrylic, cashmere,
linen, polyester, rayon, silk, and wool. In addition, a representative sample of woven versus knit; tailored
versus unstructured; and light, medium, and dark colors was chosen.
Exhibit 6-22 shows the results of the dimensional change experiments for measurements of length
and width, as compared to drycleaned garments. For each garment, dimensional change was calculated as
the difference between the initial measurement and the final measurement, divided by the initial
measurement. AATCC test method 158-1990 was used for guidance on dimensional change calculations.
The average dimensional change in length was 2.65% for wetcleaning and 2.35% for drycleaning. The
average dimensional changes in width for wetcleaning (2.96%) and drycleaning (2.97%) were virtually
identical. Therefore, the study notes that there were no statistically significant differences in measurements
between dry and wetcleaning. The study also states that while dimensional change varied substantially
depending on a garment's construction, fiber, and fabric, the cleaning method did not alter the results
significantly.
4Although not reported in this study, the evaluators also tested for garment resiliency, stain and soil removal, and hand.
Researchers noted that both cleaning methods performed similarly for these tests.
-------
Chapter 6
Performance Data Analysis
Exhibit 6-22. Dimensional Change for Identical "Dry Clean Only" Garments
Repeatedly Wet Cleaned and Dry Cleaned3
Grouping
All Garments
Fabrication
Woven
Knit
Construction
Tailored
Unstructured
Fiber
100% & blends
Rayon
Silk
Wool
Linen
Origin
Natural0
Manf.d
Length - Dimensional Change
.(n)b
36
29
7
22
14
12
10
7
5
21
11
Wetclean
2.65%
2.20%
4.48%
2.37%
3.07%
3.26%
2.31%
2.60%
2.64%
2.51%
2.60%
Dryclean
2.35%
2.05%
3.58%
1.75%
3.30%
3.28%
1.92%
2.38%
1.30%
1.95%
3.29%
Width - Dimensional Change
(n)b
35
28
7
21
14
12
8
7
6
19
11
Wetclean
2.96%
2.18%
6.08%
2.24%
4.03%
3.09%
2.18%
3.59%
2.51%
2.98%
3.90%
Dryclean
2.97%
2.14%
6.31%
1.87%
4.71%
3.52%
1.84%
4.14%
2.57%
3.03%
3.96%
a Percentage measurements noted are averages.
b (n) refers to the number of pairs of garments, with one wetcleaned and one drycleaned.
c Natural fibers include wool, silk, linen, or blends of natural fibers (including cotton).
d Manufactured fibers include rayon, polyester, acetate, or blends of manufactured fibers
(including acrylic).
Exhibit 6-23 contains the results of the expert panel's general appearance evaluations, including
cleaning performance quality, and the acceptability of appearance and pressing. The exhibit identifies
cases where a problem was identified with one garment in the pair but not with the other (discordant pairs)
and cases where the evaluator was either satisfied or dissatisfied with both garments (concordant pairs).
The study notes that most garment pairs were judged acceptable in terms of pressing (35 of 39) and general
appearance (32 of 40).
6-31
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Chapter 6
Performance Data Analysis
Exhibit 6-23. Performance Quality and Acceptability of General Appearance Evaluations
Performance Quality and
Acceptability Ratings3
Color consistency problems
Tears, rips, split seams"
Button problems
Trim problems
Shoulder pad problems
Stains or soil evaluation
Pressing acceptable
General appearance
acceptable
Discordant Pairs
Yes - WCb
No - DC c
5
6
1
1
1
3
0
1
No -WC
Yes - DC
2
8
4
0
1
5
2
3
Concordant Pairs
Yes - WC
Yes - DC
2
15
3
0
1
10
35
32
No-WC
No -DC
30
10
31
38
36
21
2
4
* These questions are not covered by an AATCC protocol.
b WC - wetcleaned garment in pair.
e DC - drycleaned garment in pair.
d Category includes loose seams, fabric damage, and hanging or pulling threads.
Exhibit 6-24 contains data pertaining to the color change evaluation performed by the panel of
evaluators Color change was visible in both the wet and drycleaned garments (21 of 39). There was color
change in 69% of all wetcleaned garments (27 of 39) and 62% of all drycleaned garments (24 of 39),
indicating color change problems with both cleaning processes. Although color migration was not a large
problem overall, the study notes that there seems to be a disproportionate amount associated with
wetcleaning (four discordant pairs) when compared to drycleaning (one discordant pair).
Exhibit 6-24. Color Change Evaluation
Performance Quality
Visible color change
Visible color migration
Discordant Pairs
Yes - WCa
No - DCb
6
4
No-WC
Yes - DC
3
1
Concordant Pairs
Yes - WC
Yes - DC
21
2
No-WC
No -DC
9
32
3 WC - wetcleaned garment in pair.
"DC - drycleaned garment in pair.
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Chapter 6
Performance Data Analysis
If color change or color migration was observed in garment pairs, the intensity of change and/or
migration was quantified using the AATCC Gray Scale for Color Change rating and the AATCC
Chromatic Transference Scale. Data for these tests are shown in Exhibit 6-25. Color change and
migration were rated from 1 (maximum change) to 5 (no change). Color consistency and migration
problems for wet and drycleaning were noted as comparable, although slightly higher (i.e., better) for
wetcleaning. The average degree of color change for wetcleaned garments was 4.42 versus 4.55 for
drycleaned garments; the average degree of color migration for wetcleaned garments was 3.63 versus 4.17
for drycleaned garments.
Exhibit 6-25. Gray Scale for Color Change and Chromatic Transference Scale for Color Migration
Cleaning Method
Number of
Garments
Minimum
Maximum
Mean
Gray Scale for Color Change3
Wetcleaning
Drycleaning
Wetcleaning
Drycleaning
38
38
2.75
1.75
5.0
5.0
4.42
4.55
Chromatic Transference Scale3
6
3
3.0
4.0
4.5
4.5
3.63
4.17
3 Color change and chromatic transference scales range from 5 (no change) to 1 (maximum change).
Exhibit 6-26 contains the data from the odor evaluation. Evaluators made a slit in the plastic bag
near the center of the front of the garment and inhaled through the hole. Odors were reported and described
in detail. Overall, all odors were considered acceptable, although evaluators were able to detect some odor
in practically all of the garments—81% of wetcleaned garments (32 of 39) and 95% of drycleaned garments
(37 of 39). The study notes that more of the drycleaned garments had a chemical or "drycleaning" smell,
and more of the wetcleaned garments smelled clean than those drycleaned.
Wearer Survey
A survey of 28 volunteer wearers who participated in the repeat clean test was used to assess
whether the experience of wearing a wetcleaned garment differed from wearing an identical, drycleaned
garment. Questions included reference to both positive qualities (e.g., cleanliness, satisfaction with
pressing) and negative performance (e.g., shrinkage, discoloration). The results of this survey are found in
Exhibit 6-27. Responses are divided into cases where the wearer was satisfied with one garment in the pair
but not with the other (discordant pairs) and cases where the wearer was either satisfied or dissatisfied with
both garments in the pair (concordant pairs).
The study notes that while not statistically significant, the results in Exhibit 6-27 indicate slightly
more dissatisfaction with the pressing and shrinkage of wetcleaned garments. In addition, problems with
discoloration, rips or tears, buttons, and garment feel were virtually the same for both wet and drycleaned
garments.
6-33
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Chapter 6
Performance Data Analysis
Exhibit 6-26. Odor Evaluation
Performance Quality
Has odor
Smells clean
Smells like chemical
Smells like drycleaning
Odor unacceptable
Discordant Pairs
Yes - WC"
No - DC"
1
9
1
4
0
No-WC
Yes - DC
6
1
12
18
0
Concordant Pairs
Yes-WC
Yes - DC
31
1
2
3
39
No-WC
No -DC
1
28
24
14
0
a WC = wetcleaned garment in pair.
"DC - drycleaned garment in pair.
Exhibit 6-27. Positive and Negative Performance Qualities: Distribution of Wearer Responses
Performance Quality
Satisfied with pressing
Satisfied with stain
removal
Satisfied with
appearance
Shrinkage
Stretching
Discoloration
Feels worse
Rips or tears
Damaged buttons
Discordant Pairs
Yes - WCa
No - DC b
1
0
4
3
0
0
1
2
2
No-WC
Yes - DC
3
0
5
1
2
0
0
2
1
Concordant Pairs
Yes - WC
Yes - DC
33
3
25
1
0
4
0
1
0
No-WC
No -DC
2
2
6
35
38
35
38
35
37
• WC - wetcleaned garment in pair.
"DC - drycleaned garment in pair.
Exhibit 6-28 includes the survey results for overall satisfaction with the wet and drycleaned
garments worn by volunteers. The study notes that for most of the garments (60.6%), wearers responded
6-34
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Chapter 6
Performance Data Analysis
that they had no preference. Exhibit 6-29 contains survey results for preference of wearing wet and
drycleaned garments. For those who did have a preference, twice as many seemed to prefer wetcleaned
garments (69.2%) over drycleaned garments (30.8%).
Exhibit 6-28. Percent with Preference for Wearing One Garment Pair
Response
Yes
No
Don't know
Frequency
13
23
3
Percent
33.3%
60.6%
7.7%
Exhibit 6-29. Preference for Wearing Wetcleaned or Drycleaned Garments3
Preference
Wetcleaned garment
Drycleaned garment
Frequency
9
4
Percent
69.2%
30.8%
a Wearers did not know which garment was being wetcleaned and which
drycleaned. The survey asked the wearer to write down the number
associated with the specific garment for which they had a preference.
In summary, the study notes that wearers did not notice any significant difference between wet and
drycleaned garments in shrinkage, stretching, pressing, color change, spot removal, odor, damage, or
appearance. More wearers identified shrinkage and pressing problems associated with wetcleaned
garments, while stretching problems were associated with drycleaned garments. In addition, twice as many
wearers preferred wearing the garment that was wetcleaned over the garment that was drycleaned.
Customer Satisfaction Survey
Two telephone surveys were conducted to measure customer satisfaction, a key indicator of
performance viability. The first telephone survey, directed toward customers who used Cleaner by Nature
at least once, was used to measure satisfaction with and attitudes toward this professional cleaner. The
second telephone survey was directed toward drycleaning customers who live in or near Cleaner by
Nature 's market area. The purpose of this second survey was to assist in evaluating the results of the
Cleaner by Nature survey by comparing it with customers' satisfaction with drycleaning.
Cleaner by Nature Customers
Exhibit 6-30 summarizes the questions related to positive performance attributes that professional
cleaners seek to maximize. The customer response rate to the Cleaner by Nature survey was 78% (180
surveys out of a total of 231 contacts). Exhibit 6-31 summarizes the responses to questions related to
6-35
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3ter6
Performance Data Analysis
negative performance attributes that professional cleaners seek to minimize. The study notes that more than
three quarters of the customers reported that their garments were always clean and that they were always
satisfied with how the garments were pressed. Fewer than half the customers who brought garments to
Cleaner by Nature with spots or stains said they were always removed to their satisfaction. However,
78 6% of all customers were always or frequently satisfied with stain removal. Over 80% of Cleaner by
Nature customers interviewed reported never experiencing any shrinkage, stretching, change in color,
change in feel, bad odors, rips or tears, or damage to buttons or decorations. Shrinkage was the most
common problem reported, with more than 15% of customers interviewed having shrinkage in the garment
cleaned by Cleaner by Nature.
Exhibit 6-30. Positive Performance Qualities Experienced by Cleaner by Nature Customers
Performance Quality
Clean
Satisfied with pressing
Satisfied with stain removal
Always
88.4%
75.8%
47.5%
Frequently
8.1%
15.2%
31.1%
Sometimes
2.3%
6.1%
13.9%
Never
1.2%
3.0%
7.4%
Exhibit 6-31. Negative Performance Qualities Experienced by Cleaner by Nature Customers
Performance Quality
Shrinkage
Stretching
Change in color
Change in feel
Odor
Rips or tears
Damage to buttons or
decorations
Never
84.1%
92.9%
92.3%
88.7%
94.1%
95.9%
95.7%
Sometimes
12.9%
6.0%
4.7%
9.4%
3.6%
4.1%
3.6%
Frequently
1.8%
0.6%
2.4%
1.3%
0.0%
0.0%
0.7%
Always
1.2%
0.6%
0.6%
0.7%
2.4%
0.0%
0.0%
The study notes that if each of the 10 performance measures in Exhibits 6-30 and 6-31 is treated
individually there appears to be a high level of satisfaction with how customers' garments were treated.
Stain removal was noted as the largest problem: over half of surveyed customers with spotted or stained
garments noted that the spots or stains were not always removed to their satisfaction. Other problems noted
included shrinkage (15% of customers) and pressing (25% of customers). Collectively, half of all
customers (91 of 180) reported having at least one of the performance problems noted in Exhibit 6-31, yet
only half of these customers reported that they had experienced a "problem" with the garment as a result of
sending it to Cleaner by Nature.
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Chapter 6
Performance Data Analysis
Exhibit 6-32 contains the results of customer rating of Cleaner by Nature. More than 60% of the
180 customers surveyed reported Cleaner by Nature as an excellent professional cleaner, 32.4% rated it as
good, 4.6% rated it as fair, and 2.3% rated it as poor. These data are highly correlated with whether or not
customers would recommend Cleaner by Nature to friend: all but 4 of the 161: customers interviewed who
rated Cleaner by Nature as excellent or good also would recommend it to a friend, while 3 of the 12
customers rating it as fair to poor would recommend it to a friend. In addition, 77.8% of the customers
surveyed said they were still customers of Cleaner by Nature.
Exhibit 6-32. Customer Rating of Cleaner by Nature as a Professional Cleaner
Rating
Excellent
Good
Fair
Poor
Frequency
105
56
8
4
Percent
60.7%
32.4%
4.6%
2.3%
Of the 39 customers who stopped using Cleaner by Nature, 41 % noted that location was the reason
why they stopped. Other reasons for not using Cleaner by Nature included dissatisfaction with cleaning
quality (23.1%), price (20.5%), and service or convenience (15.4%). The study notes that nearly 65% of
Cleaner by Nature customers use it exclusively, while the remaining 35% still use a drycleaner also. Three
quarters of these customers take fewer than 25% of their garments to the drycleaner. The reasons for
continuing to use a drycleaner, in addition to Cleaner by Nature, include location/convenience (43.9%),
cleaning quality (29.3%), price (14.6%), and turnaround time (12.2%).
A customer comparison of Cleaner by Nature customers who still used a local drycleaner was also
performed for this survey. All customers interviewed mentioned that they had used drycleaning in the past.
When asked to state which operation was better for the environment, all customers stated that Cleaner by
Nature was better. In terms of cost, 37% of customers said drycleaning was lower, 22% said Cleaner by
Nature was lower, 28% said prices were equivalent, and 13% said it depended on the individual cleaner.
Cleaner by Nature customers rated the quality of cleaning for that operation to be higher than drycleaning
73% of the time (compared to 5.8% for drycleaning) and rated the quality as the same 20.6% of the time. In
addition, nearly 86% of customers were more satisfied, overall, with Cleaner by Nature, compared to 10.3%
of customers being more satisfied with drycleaning. The remaining 4% of customers were equally satisfied
with dry and wetcleaning results.
Drycleaning Customers
A survey of customers of drycleaners, conducted in May 1997, was performed to provide a baseline
for analysis of the Cleaner by Nature customer satisfaction survey. The customer response rate to the
dryclean survey was 36% (100 surveys out of a total of 250 contacts). Exhibit 6-33 summarizes how
experienced Cleaner by Nature customers and drycleaning customers responded to questions relating to
three positive performance qualities that professional cleaners seek to maximize. The study notes that while
6-37
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Chapter 6
Performance Data Analysis
over 96% of Cleaner by Nature customers reported their garments as clean, only 79% of drycleanmg
customers reported the same. While satisfaction with garment pressing was similar (89.6% for Cleaner by
Nature; 83.8% for drycleaning), fewer than 50% of the drycleaning customers expressed satisfaction with
stain removal, versus nearly 80% for Cleaner by Nature customers.
Exhibit 6-33. Positive Performance Qualities Experienced by Cleaner by Nature Customers
and DryCleaner Customers8
Performance Quality
Clean
Pressing
Stain removal
Professional Cleaner
Cleaner by Nature
Drycleaning
Cleaner by Nature
Drycleaning
Cleaner by Nature
Drycleaning
Frequently or Always
96.2%
79.0%
89.6%
83.8%
79.7%
49.0%
Never, Rarely ,b or
Sometimes
3.80%
19.0%
10.4%
16.2%
20.3%
51.0%
* Cleaner by Nature customers with six or more transactions.
b Only drycleaning customers were asked whether these performance attributes occurred rarely.
Exhibit 6-34 summarizes how repeat Cleaner by Nature customers and drycleaning customers
responded on seven negative performance qualities that professional cleaners seek to minimize. Based on
the data from this table, shrinkage, stretching, and rips and tears in garments are reported similarly for both
cleaning methods. The study notes that drycleaning customers reported significantly more problems with
changes in the color or feel of garments, damage to buttons or decorations, and odor, compared with
vvetcleaning customers.
In terms of overall customer satisfaction with the cleaning process, 91.1% of Cleaner by Nature
customers provided an excellent or good rating, versus 86.6% for drycleaning. In addition, 93.2% of
Cleaner by Nature customers said they would recommend the cleaner to a friend, versus 87.7% of
drycleaning customers. The study also reports that 54.0% of drycleaning customers have stopped using a
professional cleaner in the last year, while only 22.7% of all Cleaner by Nature customers reported that they
were no longer using Cleaner by Nature.
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Chapter 6
Performance Data Analysis
Exhibit 6-34. Negative Performance Qualities Experienced by Cleaner by Nature Customers
and DryCleaning Customers3
Performance Quality
Shrinkage
Stretching
Rips or tears
Color change
Change in feel
Damage to buttons0
Unpleasant odor
Professional Cleaner
Cleaner by Nature
On/cleaning
Cleaner by Nature
Drycleaning
Cleaner by Nature
Drycleaning
Cleaner by Nature
Drycleaning
Cleaner by Nature
Drycleaning
Cleaner by Nature
Drycleaning
Cleaner by Nature
Drycleaning
Rarely or Never11
74.0%
81.0%
86.8%
86.0%
91.0%
89.0%
90.4%
79.0%
83.1%
66.3%
96.1%
63.0%
100.0%
72.7%
Sometimes,
Frequently, or
Always
26.0%
19.0%
13.2%
14.0%
9.0%
11.0%
9.6%
21.0%
12.9%
33.7%
3.9%
37.0%
0.0%
28.3%
1 Cleaner by Nature customers with six or more transactions.
5 Only drycleaning customers were asked whether performance attributes occurred
: This category also includes damage to decorations.
rarely.
Exhibit 6-35 shows the distribution of reasons why customers stopped using a professional cleaner.
The proportion of Cleaner by Nature customers citing quality of cleaning or price as the primary reason
they stopped using this wetcleaner is similar to the proportion of drycleaning customers who also listed
these as their primary reason. The study also notes that twice as many Cleaner by Nature customers
mentioned location as the primary reason for discontinuing use of the wetcleaner, while almost twice as
many drycleaning customers mentioned service and convenience.
Exhibit 6-35. Primary Reason Customers Stopped Using Professional Cleaner: A Comparison of
Cleaner by Nature and Drycleaning Customers3
Professional
Cleaner
Cleaner by Nature3
Drycleaning
Location
42.9%
23.5%
Quality of
Cleaning
28.6%
35.3%
Price
14.3%
15.7%
Service/Convenience
14.3%
25.5%
Includes all Cleaner by Nature customers.
6-39
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Chapter 6
Performance Data Analysis
Performance Assessment Conclusions
The Cleaner by Nature study concludes that it is possible for all garments brought in,by customers,
including those labeled "dryclean only," to be wetcleaned. The researchers note that overall, Cleaner by
Nature was comparable to a drycleaner in terms of the magnitude of problems identified through the
cleaning performance evaluation. Problems areas that were identified for wetcleaning included color
change, shrinkage, and pressing, while problem areas associated with drycleaning operations included stain
removal, garment damage, and stretching. The study also mentions a high level of satisfact.on w.th Cleaner
by Nature overall, continual growth of its customer base, and a high retention rate of customers.
6.2.5 Alternative Textile Care Technologies: Part I
Sponsor:
Investigating Organization:
Principal Investigator:
Duration:
Location:
Source of Information:
USEPA, Office of Research and Development
Texas Woman's University, Department of Fashion and Textiles
Dr. Charles Riggs
3 years (currently funded for 1 year)
Houston, Texas
Riggs, 1996
Summary of Performance Evaluations
This study is assessing the performance of alternative technologies. Researchers hope to gather
data using machine wetcleaning, PCE drycleaning, HC solvent drycleaning (Exxon's DF-2000), and
potentially liquid CO2 technology. The scope of this study is limited to soil and fabric combinations that are
problem areas for the cleaning industry.
Performance Evaluations
Identification of "problem" soil and fabric combinations for alternative clothes cleaning
technologies . .
Development of a methodology to evaluate the cleaning performance of alternative technologies
Work with North Carolina State University to develop consensus procedures for evaluating clothes
cleaning technology
Experimental Technology
Unimac wetcleaning machine (Model UA230) with Seitz chemicals
• Aquatex drying cabinet
Boewe-Passat, Permac PCE drycleaning machine (P546 - 46 Ib)
Boewe-Passat, Permac DF-2000 HC drycleaning machine
- Liquid CO2 cleaning technology (may not be available for test)
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Chapter 6
Performance Data Analysis
6.2.6 Alternative Textile Care Technologies: Part II
Sponsor:
Investigating Organization:
Principal Investigator:
Duration of Study:
Location:
Source of Information:
USEPA, Office of Research and Development
North Carolina State University, College of Textiles
Dr. Perry Grady
3 years (currently funded for 1 year)
Raleigh, North Carolina
Grady, 1996
Summary of Performance Evaluations
This study focuses on testing and developing alternative cleaning technologies to reduce indoor air
emissions from PCE drycleaning and drycleaned fabrics. Currently, the project is studying the effectiveness
of "piggy backing" ultrasonic cleaning technology with current wet and drycleaning methods. Additional
work is planned with a bench scale apparatus for liquid CO2 cleaning technology. Fabric and soil samples
will be used in cooperation with the investigation in Part I (Section 6.2.5). The goal of this exploratory
study is to develop a cleaning system that removes complex soils and eliminates the use of non-aqueous
solvents.
Performance Evaluations
Ultrasound and, possibly, liquid CO2 technologies will be used in tandem with machine
wetcleaning, traditional PCE drycleaning, and HC solvent drycleaning systems.
Preliminary Test Results
Ultrasound assists solvent soil removal with compatible soils (i.e., oil-based). In terms of water-
based cleaning, ultrasound technology reduces the need for mechanical agitation, decreasing the amount of
shrinkage in garments. It may also reduce the temperature and mechanical agitation necessary for non-
aqueous-based clothes cleaning methods.
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Chapter 6
Performance Data Analysis
6.2.7 University of Guelph Fabric Swatch Study
Sponsor: Environment Canada
Investigating Organization: University of Guelph, Textile Sciences Group
Principal Investigator: Anne Wilcock
Location: Guelph, ONT, Canada
Duration: Unknown
Source of Information: Wilcock, 1996
Summary of Performance Evaluations
The data obtained from this study have not been analyzed in total due to a lack of research funding.
Environment Canada has used selective parts of the data to support the previously mentioned Green Clean
study (Section 6.2.3). Most of the data generated by the principal investigator remain unpublished and
unanalyzed at this time.
Performance Evaluations
Six cleaning processes (pressing only, steam cleaning, drycleaning in PCE, "green cleaning,"
machine wetcleaning, and home laundering) were used for comparison in this study. Textile swatches
included undyed/unfmished fabrics, dyed/finished fabrics, fused fabrics, and whole garments. Within each
category 4 to 13 different fabrics were cleaned, representing an array of weights, fiber mixtures, and
constructions likely to be encountered in day-to-day business. The data obtained from these cleaning trials
have not yet been completely analyzed.
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Chapter 6
Performance Data Analysis
REFERENCES
Adamson, K. 1996. Personal communication between Ken Adamson, Langley-Parisan Cleaners, and
Jonathan Greene, Abt Associates Inc. November 25.
Adamson, K. 1998. Personal communication between Ken Adamson, Langley-Parisan Cleaners, and
Jonathan Greene, Abt Associates Inc. February 20.
ASTM. American Society of Testing and Materials. 1998. Annual Book of 'ASTM Standards. Volume
7.01. West Consohocken, PA.
Bladder, C., R. Denbow, W. Levine, and K. Nemsick. 1995. A comparative analysis of PCE drycleaning
and an alternative wet cleaning process. National Pollution Prevention Center for Higher
Education. Ann Arbor, MI.
CNT. 1996. Center for Neighborhood Technology. Alternative clothes cleaning demonstration shop.
Final report. Chicago, IL.
den Otter, W. 1996. Report on the European Wet Cleaning Committee. Presented at the Conference on
Apparel Care and the Environment: Alternative Technologies and Labeling, Washington, DC.
September, pp. 107-114.
Environment Canada. 1995. Final report for the Green Clean™ project. Prepared by Environment Canada
and the Green Clean Project Participants. Government of Canada EN40-5-0/1995/E.
Gottlieb, R., J. Goodheart, P. Sinsheimer, C. Tranby, and L. Bechtel. 1997. Pollution prevention in the
garment care industry: assessing the viability of professional wet cleaning. UCLA/Occidental
College Pollution Prevention Education and Research Center. Los Angeles, CA. December.
Grady, P. 1996. USEPA's ORD research program on alternative technologies, part II. Presented at the
Conference on Apparel Care and the Environment: Alternative Technologies and Labeling,
Washington, DC. September, pp. 49-54.
Hohenstein. Undated. Forschungsinstitut Hohenstein. The importance of wet cleaning for the textile care
industry: options for organizational expansion and/or rationalization. Methods for Management,
Inc.
Patton, J. 1994. Personal communication with Jo Patton, Center for Neighborhood Technology. October
21. [As cited in Blackler et ai. (1995).]
Patton, J. 1996. Results and conclusions from wet cleaning demonstration projects. Presented at
Conference on Apparel Care and the Environment: Alternative Technologies and Labeling,
Washington. September, p. 129-136.
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Performance Data Analysis
Riggs, C. 1996. EPA'sORD research program on alternative textile care technologies, parti. Presented at
the Conference on Apparel Care and the Environment: Alternative Technologies and Labeling,
Washington, DC, September, pp. 37-49.
Riggs, C. 1998. Personal communication between Charles Riggs, Texas Women's University Department
of Fashion and Textiles, and Jonathan Greene, Abt Associates Inc. March 2.
Wentz, M. 1994. Clearing the air on clean air. Video teleconference presented by the Fabricare
' Legislative and Regulatory Educational Organization, the University of Tennessee Center for
Industrial Services, and the Tennessee Department of Environment and Conservation. May 12. [As
cited in Bladder et al. (1995).]
Wentz, M. 1996. The status of wet cleaning in Canada: the concept of textile care process spectra.
' Presented at the Conference on Global Experience and New Developments in Wet Cleaning
Technology. Schloss Hohenstein, Boennigheim. June. pp. 20-25.
Wilcock, A. 1996. Personal communication between Anne Wilcock, University of Guelph - Textile
Science Group, and Jonathan Greene, Abt Associates Inc. November 12,
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CHAPTER?
PROCESS COST ESTIMATES
7.1
7.2
7.3
7.4
7.5
CHAPTER CONTENTS
Summary of Technologies and Cost Elements
Modeled
Assumptions and Cost Estimation Methodology
Cost Estimates for PCE Machine Configurations
Cost Estimates for Hydrocarbon Solvent
Machine Configurations
Cost Estimates for Machine Wetcleaning
The costs of running a
professional clothes cleaning business
include rent, basic operating expenses,
equipment, and labor. The equipment
capacity, equipment type, and the
location of the facility will affect the
costs and economic viability of a
professional cleaning operation. While
some fabricate technologies have been in
use for many years, others are still
prototypes and have not yet been
commercially marketed. As manufacturers gain expertise with new machines, and their production
quantities increase, it is expected that there will be a decrease in the cost of production of new machines
relative to established technologies and therefore a decrease in the cost of these options to fabricare
operators (Pindyck and Rubinfeld, 1989).
This chapter focuses on the evaluation of a subset of costs associated with using fabricare
technologies. Section 7.1 provides an introduction to the technologies and cost elements that have been
included in the cost estimations that follow. Section 7.2 describes the methodology and assumptions used
to estimate the cost components in this chapter. In Sections 7.3, 7.4, and 7.5. operational cost estimates are
provided for the various fabricare process options. The analyses presented in this chapter should be
regarded as a general guide for cost comparisons.
7.1 SUMMARY OF TECHNOLOGIES AND COST ELEMENTS MODELED
The technologies analyzed in this chapter include eight configurations of perchloroethylene (PCE)
equipment, three configurations of hydrocarbon solvent (HC) equipment, and one configuration of
machine wetcleaning technology.
The cost categories considered in this analysis are capital equipment cost, annualized cost of that
equipment, annual solvent cost, energy cost, hazardous waste disposal cost, regulatory compliance costs,
cost of filters and other supplies, and maintenance cost. These cost elements were chosen for evaluation
because of their importance to facility operation, their potential for highlighting differences among
technologies, and the availability of data. Exhibit 7-1 presents additional operating factors that are
associated with fabricare operations, many of which are outside the scope of this analysis.
7-1
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Chapter 7
Process Cost Estimates
Exhibit 7-1. Potential Operating Factors Associated with Fabricate Facilities
Revenues
>• Sale of product
>• Marketing of by-product
»• Change in process throughput
>• Change in sales from improved
corporate image and market
share
Utilities
>• Electricity
»• Cooling and process water
»• Refrigeration
•• Fuel (gas or oil)
>• Plant air and inert gas
> Sewerage
Direct Labor
•• Operating labor and supervision
>• Clerical labor
•• Inspection (QA & QC)
>• Worker productivity changes
Materials
>• Direct product materials
»• Solvents
> Wasted raw materials
>• Transport and storage
Waste Management
(Materials and Labor)
> Pre-treatment and on-site
handling
>• Storage, hauling, and
disposal
>• Insurance
Future Liability
>• Fines and penalties
>• Personal injury
Regulatory Compliance
>• Equipment monitoring and lab
fees
» Personal protective gear
>• Reporting, notification,
inspections, and manifesting
•• Training (right-to-know,
safety) and training materials
» Workplace signage and
container labeling
» Penalties, fines, and solvent-
use fees
» Insurance, closure and post-
closure site maintenance
Indirect Labor
> Maintenance (materials and
labor)
•• Miscellaneous
(housekeeping)
»• Medical surveillance
Source: USEPA (1997).
Exhibit 7-2 provides a summary comparison of the various costs associated with a number of the
fabricare technology options. This table is presented for illustrative purposes and provides comparisons
among the technology types. Detailed explanations of how cost estimates were derived, as well as varying
configurations of individual technologies, are provided in Sections 7.3, 7.4, and 7.5.
Wherever possible, the cost information reported is based on current prices of equipment and
supplies offered by domestic manufacturers or distributors. If current prices are not available (e.g.,
equipment is no longer sold), then historic prices provided by a vendor are used if they are available.
Costs or cost ranges may also be derived from secondary sources (materials published by the U.S.
Environmental Protection Agency [USEPA], state and local governments, and industry). If prices are
obtained from both current sources and published materials, the current prices are used, and the
information from published sources is noted in the text. Where applicable, sample calculations are
included for each cost element.
7-2
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Chapter 7
Process Cost Estimates
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7-3
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Chapter 7
Process Cost Estimates
7.2 ASSUMPTIONS AND COST ESTIMATION METHODOLOGY
Only those process-dependent cost components (i.e., equipment and chemicals) that are directly
related to the various cleaning processes are included in these cost analyses. Operating costs that do not
vary with the process used, such as storefront operations and rent, are excluded from these analyses. Note
that rounding and unit conversions associated with cost components may result in slight differences
between numbers reported in the text and the actual data.
Some of the costs are based on the average of prices offered by several vendors, while others are
based on reported prices from a single vendor. Solvent and detergent cost estimates are adjusted to 1997
dollars using the Producer Price Index for Chemicals and Allied Products (PPI-Chem). All other cost
estimates are adjusted to 1997 dollars using the Producer Price Index for Capital Equipment (PPI-CE)
(BLS 1997). Exhibit 7-3 shows the values from the PPI-CE and PPI-Chem indices. Cost figures are
presented in constant 1997 dollars in order to allow direct comparison among the process options. A
sample calculation of conversion to constant dollars based on PPI-CE is given below Exhibit 7-3.
Exhibit 7-3. Producer Price Index for Machines and Equipment (PPI-CE)
and Chemicals and Allied Products (PPI-Chem)
Year
PPI-CE
PPI-Chem
1982
100
100
1986
109.7
102.6
1987
111.7
106.4
1988
114.3
116.3
1989
118.8
123.0
1990
122.9
123.6
1991
126.7
125.6
1992
129.1
125.9
1993
131.4
128.2
1994
134.1
132.1
1995
136.7
142.5
1996
138.3
142.1
1997"
138.3
143.6
• PPI-CE and PPI-Chem estimates based on 10-month average for 1997 (January to October).
Sample Calculation of Conversion to Constant Dollars - Data from
Section 7.3.3:
Capital Cost for Retrofit of Equipment in 1994 dollars = $8,556
PPI-CE 1994 (base year) =134.1
PPI-CE 1997 (current year) =138.3
138.3
$8,556 (1994 dollars) x
134.1
= $8,824 (1997 dollars)
7.2.1 Clothes Cleaning Plant Capacity
In this chapter, the model clothes cleaning plant for each technology is assumed to process an
annual average clothing volume of 53,333 pounds.1 This annual clothing volume for the average facility is
derived by dividing the total volume of clothes cleaned using PCE and HC solvents in the commercial
sector (1.92 billion pounds) by the number of firms using PCE and HC solvents in the commercial sector
(36,000) (Wolf, 1998; Wong, 1998). Facilities are assumed to operate 312 days annually (6 days a week
and 52 weeks a year [Shaffer, 1995]) and to have an average daily throughput of approximately 171
pounds of clothing.
'The total throughput of the model plant is 66,666 pounds, of which 80% is drycleaning or an alternative and 20% is washing
(Faig, 1998). It is assumed that the revenue per pound is constant at $3, generating a revenue per facility of $200,000.
7-4
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Chapter 7
Process Cost Estimates
7.2.2 Equipment Capacity
The cost estimates for PCE assume a 35-pound (15.9 kg) nominal capacity machine with a
distillation unit and filtration system, unless otherwise noted. This is the machine size most commonly
used in the commercial sector (USEPA, 1991b). The price of retrofitting machines with emission control
equipment is estimated for the same cleaning capacity. It is assumed that the PCE machines operate at
90% capacity (USEPA, 1993), and that 6 loads per day are needed to process the throughput.
The cost estimates for the HC machines assume a 40-pound (18.1 kg) nominal capacity machine
that includes a washer/extractor (with filter and explosion kit) and a basic dryer. The HC solvent machines
are assumed to operate at 80% capacity (Jenkins, 1994), resulting in a daily throughput of six loads per
day.
The cost estimates for wetcleaning machines assume a 30-pound (13.6 kg) nominal capacity.
Manufacturer estimates indicate that wetcleaning equipment is designed to be operated at 100% capacity,
resulting in a daily throughput of six loads per day.
7.2.3 Capital Equipment Costs
Capital costs for equipment and the costs of retrofitting machines with control technologies are
converted to annual cost equivalents using a 7% real cost of capital and a 15-year lifespan2 (equivalent to
using a capital recovery factor of 0.1098), to be consistent with previous clothes cleaning analyses
(USEPA, 1993).3 The example below demonstrates the annualization of capital costs and the calculation
of capital equipment costs using constant dollars.
Sample Annualization Cost Calculation4 - Data from Section 7.3.3:
Where:
Ac — Annualized cost
Tc = Total cost
/ = Interest rate (7%)
n = Number of years (15)
[ ] = Note that bracketed term is the
capital recovery factor of 0.1098
4 -Tv
•**• — J. J\-
[o+o"-i
Ac = Tc x 0.1098
Ac = $27,801 x 0.1098
A = $3,053
According to Ken Faig of the International Fabricare Institute (1996) the average life of wetcleaning washers and dryers is
15 to 18 years, comparable to that of drycleaning equipment. Fifteen years was assumed, to be consistent with prior analyses.
The cost of capital used to analyze public investments and private investments is different. The real cost of capital of 7% is
a typical value used in evaluating public investments. For the private firm deciding to purchase equipment, the appropriate value is the
interest rate charged on the loan modified by the inflation over the course of the payments. The authors investigated the typical loans
for clothes cleaning equipment and discovered that they varied considerably. In addition, the tax savings from depreciation must be
included for an individual making a financial decision. The public financing rate has been used in this analysis.
The annualization of capital equipment expenses allows recovery of the original investment over the course of the lifetime of
the equipment (15 years in this case), accounting for the time value of currency. The discounted annualized costs (where the discount
rate equals the interest rate) summed over the lifetime of the equipment is equal to the total immediate cost of purchasing the equipment
(Perry and Chilton, 1973).
7-5
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Chapte
Process Cost Estimates
7.2.4 Equipment Maintenance Costs
The Neighborhood Cleaners Association International (NCAI) estimates the annual maintenance
costs for PCE-based fabricare operations to be between 1.25% and 3% of total annual revenues, based on a
range of standard garment pricing5 (NCAI, 1998). The International Fabricare Institute (IFI) estimates
annual equipment maintenance costs for PCE-based operations to be 2.27% to 3.26% of total annual
revenue based on an annual sales volume of $100,000 to $300,000 (IFI, 1992). The Pollution Prevention
Environmental Research Center (University of California at Los Angeles/Occidental College) study
averages the low-end IFI and NCAI estimates (2.27% and 1.25%, respectively) and applies a 50%
preventive maintenance factor to yield 1.765% of total sales revenue. For the purpose of the CTSA, PCE
and HC annual equipment maintenance costs are calculated as 3% of total annual revenues. The
equipment maintenance costs for other technologies are noted directly in the corresponding text of this
chapter.
7.2.5 Energy Costs
Energy costs are based on the national average commercial electricity price of $0.0764 per
kilowatt-hour (EIA, 1997). Energy use estimates for each technology include only actual cleaning and
drying equipment and do not include non-cleaning processes such as pressing. In cases where data are
available, energy costs are provided for machines and emissions control technologies, based on estimates
by equipment manufacturers and suppliers. Estimates for energy use of PCE emissions control
technologies are derived from information in the PCE National Emission Standard for Hazardous Air
Pollutants (NESHAP) (USEPA, 199la). More recent energy use data for PCE transfer machines are not
available because these machines are not currently in production.
Sample Calculation for Energy Consumption Costs - Data from Section 7.3.4:
Assumption: Energy use estimate of 725 kilowatt-hours/year is based on capacity of 105,240
pounds of clothes cleaned per year (USEPA, 1993).
53,333 pounds per year/105,240 pounds per year = 0.507 (adjustment for facility capacity)
Cost of Energy = $0.0764/kilowatt-hour x 725 kilowatt-hour/year x 0.507
Cost of Energy = $28/year
7.2.6 Installation Costs
Installation costs are included in the cost of retrofitting machines with emissions control
technologies, as these costs are a necessary and unavoidable part of the retrofitting process. For the
purpose of this analysis, installation costs are not included for new equipment because the installation costs
of a new machine vary significantly. Replacing an existing machine requires relatively little installation
cost, while an entirely new installation requires significantly higher costs to provide water, steam, and
electricity supplies.
5The NCAI estimate of annual maintenance costs is based on a survey of 854 fabricare stores with between $ 130.000 and
S334.000 in annual sales revenue (NCAI, 1998).
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Chapter 7
Process Cost Estimates
7.2.7 Solvent and Other Material Costs
Solvent costs may vary based on per-gallon and bulk prices.6 PCE solvent costs range from
$5.50/gallon to $8.0I/gallon, based on estimates provided by manufacturers and distributors. A median
PCE solvent price of $6.83/gallon is used for the purposes of this analysis.
HC solvent costs range as follows: (1) Stoddard solvent costs $1.50/gallon to $4.00/gallon, with a
median price of $2.24/gallon; (2) DF-2000 costs $3.49/gallon to $5.01/gallon, for a median price of
$3.79/gallon; and (3) Drylene solvent costs $7.50/gallon. For the purpose of this analysis, the median
price of Stoddard solvent ($2.24/gallon) will be used to calculate total HC solvent costs, although it should
be recognized that costs will vary depending upon which HC solvent is used.
Water for wetcleaning costs $2.73/100 cubic feet in 1993 dollars or $3.06/100 cubic feet in 1997
dollars (USEPA, 1993; BLS, 1997). This price includes the average cost of water and sewerage fees.
Sample Calculation for Solvent/Material Consumption Costs - Data from Section 7.3.3:
Assumed usage =417 gallons PCE/year
Total Solvent Cost =417 gallons PCE/year x $6.83/gallon PCE (1997 dollars)
= $2,848/year
7.2.8 Filters/Cleaning Supplies
PCE filters are estimated to cost $606 annually, and detergents and spotting chemicals for PCE
machine configurations are calculated to cost $1,307 annually, for a total of $1,913 (BLS, 1997; USEPA,
1993). For the HC configurations, the filters cost $244 annually, while the detergents and spotting agent'
costs are estimated at $1,307 annually, for a total of $1,551 (BLS, 1997; Hill, Jr., 1994a). Annual costs for
machine wetcleaning detergent, fabric softener, and spotting chemicals are calculated to be $2,877, $40
and $245, respectively, for a total of $3,162 (BLS, 1997).
7.2.9 Hazardous Waste Disposal Costs
Because PCE is a hazardous waste, the CTSA compares the costs of hazardous waste disposed.
For the purposes of this analysis, all hazardous waste cost estimates provided in this chapter include only
the cost of disposal and do not include the cost of associated paperwork and other regulatory compliance
activities noted in Exhibit 7-2. The cost of disposing of potentially hazardous spotting chemicals is not
included in this analysis. Hazardous waste disposal costs for PCE and HC-based equipment are calculated
using a cost of $6.94 per gallon7 and engineering estimates of volume. Hazardous waste cost estimates
included in the HC estimates assume that all the waste products require hazardous waste disposal
procedures. Wastes derived from HC drycleaning processes are not necessarily classified as hazardous
wastes under environmental regulations. Wastes composed solely of HC products, such as well-drained
filter cartridges and drained filter muck, are not likely to meet the criteria for classification as ignitable
solids (USEPA, 1990). However, other cleaning process by-products (such as dissolved fats, dyes, and
Several states have instituted annual usage fees ($ 100 to $2,500) and/or per-gallon taxes on PCE solvent, which can increase
the purchase price of thIS product from $3.75 to $10.00 per gallon. Additional information regarding solvent use taxes is presented in
Chapters of this document.
Hazardous waste costs are estimated at $111/16 gallons ($6.94/gallon) (Beedle, 1998).
-------
Chapte
Process Cost Estimates
cleaning products), in combination with the HC solvent, may create wastes that fail the Toxicity
Characteristic Leaching Procedure (TCLP) and qualify as hazardous waste under the Resource
Conservation and Recovery Act (RCRA) definition. Water is not a hazardous waste under environmental
regulations. However, as with HC cleaning, wastes derived from using these solvents in clothes cleaning
applications could generate some hazardous waste.
Sample Calculation for Annual Hazardous Waste Disposal Costs-Data from Section 7.3.2:
Assumed production of hazardous waste = 658 gallons/year
Hazardous Waste Disposal Cost =658 gallons of hazardous waste/year x $6.94/gallon
= $4,567/year
7.2.10 Regulatory Compliance
Compliance with government regulations imposes industry-specific costs upon the private sector.
Exhibit 7-1 lists many of the regulatory compliance cost categories pertinent to the fabricare industry,
including expenditures for waste management. The range of equipment ages and types currently in use
will result in variations in regulatory compliance costs within and across process categories. In addition,
regulatory compliance costs will vary regionally due to differing local and state fees, taxes, and permitting
procedures.8 For the purpose of this analysis, the use of spotting agents is not factored into the regulatory
cost estimates provided in this chapter.9
NCAI estimates that regulatory compliance costs associated with PCE technology are between
2 25% and 4 5% of total revenues10 (NCAI, 1998). These costs include registration and permit fees for
pollution abatement; hazardous waste disposal charges; USEPA and Occupational Safety and Health
Administration (OSHA) compliance; local water pollution discharge fees; and other local, state, and
federal fees. The Pollution Prevention Environmental Research Center (University of California at Los
Angeles/Occidental College) study calculates regulatory compliance costs for drycleaning based on the
NCAI estimate of 2.25% of annual revenue ($5,483) but subtracts out hazardous waste disposal costs
($1 010) and the cost of regulatory fees" ($851), for a final annual estimate of $3,622. Because hazardous
waste costs have already been considered separately, regulatory compliance costs associated with PCE-
based drycleaning are estimated to be 1.84% of total annual revenues, the percentage resulting from the
Pollution Prevention Environmental Research Center (University of California at Los Angeles/Occidental
College) study when the hazardous waste costs are subtracted from the regulatory compliance costs
(Gottlieb etal., 1997).
8Regu!atory fees tend to vary, based on local and state requirements (Gottlieb et al., 1997).
'Spotting agents that contain regulated chemical ingredients are used by fabricare operators, regardless of the cleaning
technology they employ. It is important for a user to consider the additional regulatory impact, and therefore additional cost, these
chemicals might have upon a fabricare business.
'°TheNCAI estimates for regulatory compliance costs are based on a survey of 854 stores with annual sales revenue ranging
from $ 130,000 to $364,000. The base price of cleaning a two piece suit ranges from $6.50 (4.5% estimate) to $8.50 (2.25% estimate)
(NCAI, 1998).
"The PPERC/UCLA study includes the following annual regulatory fees in their cost of compliance for PCE drycleaning:
hazardous waste control license ($412) and hazardous materials control license ($110) from the Los Angeles County Fire Department,
South Cost Air Quality Management District annual operating fee ($168) and emissions fee (exempt; $0.21/pound of PCE emitted for
businesses that emit more than 4,000 pounds annually), Los Angeles County Public Health licence fee ($111), and California Air
Resources Board employee training course taken every three years by employees ($150) (Gottlieb et al., 1997).
--7-8'~~
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Chapter 7
Process Cost Estimates
No data are currently available for estimating the regulatory compliance costs associated with HC
drycleaning. USEPA is currently in the process of writing a NESHAP regulation for HC solvents used in
the fabncare industry. The proposed NESHAP is expected to be released by November 15, 1999, and then
formally promulgated by November 15, 2000. Currently, HC drycleaners are regulated under the Clean
Air Act by New Source Performance Standards, which include required record keeping, leak detection,
and maintenance procedures. The NESHAP is expected to require HC solvent drycleaners to use
maximum available control technology to reduce emissions from their fabricare operations (KSBEAP,
1997; Szykman, 1998). Therefore, this NESHAP could result in an increase in regulatory costs associated
with Clean Air Act compliance over current levels. At this time, there are insufficient data to determine
regulatory compliance costs for HC-based drycleaning operations. For the purpose of this analysis,
regulatory compliance costs are excluded from the total cost calculation of this technology.
No data are currently available for estimating the regulatory compliance costs associated with
wetcleamng. However, fabricare operators may be subject to permitting fees and record keeping costs
associated with their local sewerage authority. At this time, there are insufficient data to determine total
regulatory compliance costs for wetcleaning operations. For the purpose of this analysis, regulatory
compliance costs are excluded from the total cost calculation of this technology.
7.2.11 Labor Costs
Labor costs associated with professional clothes cleaning operations vary based on the mix of
employee job functions, qualifications and experience of workers, productivity of workers, equipment type
and configuration, facility size, and geographic location of the facility. For example, rough pressers tend to
earn a lower wage than specialized pressers, who are trained to work on intricate garments such as
wedding dresses and expensive fabrics such as silks (Seitz, 1996). It is also noted that one employee may
perform several job functions within a fabricare shop, each of which requires different skill levels. For
example, an employee may work at the drop-off counter during part of his shift, in addition to sorting and
washing clothing in the back of the facility. Because of this variability and the lack of available
quantitative data, the labor costs associated with fabricare operations are not included in this cost model.
7.3 COST ESTIMATES FOR PCE MACHINE CONFIGURATIONS
The cost components of the eight PCE drycleaning machine configurations are summarized in
Exhibit 7-4. The discussion that follows explains the cost estimates of each technological configuration of
PCE equipment.
7.3.1
PCE Transfer with No Carbon Adsorption or Refrigerated Condenser (PCE-A1)
Capital Cost: New transfer machines are no longer available, so historic data must be used. The estimate
of the price of an uncontrolled transfer drycleaning machine is based on responses to the Clean Air Act
Section 114 Questionnaires, which was a survey conducted for the Chemical and Petroleum Products
Division, Office of Pesticides and Toxic Substances (USEPA, 1988). The price of a 35-pound transfer
machine was estimated at $15,895 (1987 dollars), or $19,680 in 1997 dollars (BLS, 1997).
Solvent Cost: Assuming a solvent use of 627 gallons/year (USEPA estimates) and a solvent price of $6 83
per gallon, the solvent cost is $4,282. The mileage is 85 pounds per gallon.
Energy Cost: Data are not available for this technology.
7-9
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Chapter 7
Process Cost Estimates
Regulatory Compliance Cost: Regulatory compliance costs are estimated at 1.84% of annual revenue
($200,000), for a total of $3,680.
Hazardous Waste Disposal Costs: The estimate of hazardous waste disposal cost is based on engineering
estimates of 658 gallons of waste generated per year and a disposal cost of $6.94 per gallon (Beedle,
1998), for a total of $4,567.
Cost of Filters/Cleaning Supplies: Each 35-pound capacity machine needs 20 24 replacement standard
carbon core filters at $17.57 per filter and 7.59 double all carbon filters at $29.03 per filter (USERA,
1993) for an annual cost of $576, or $606 in 1997 dollars (BLS, 1997). All costs presented for filters and
cleaning supplies are average costs. (Individuals will not buy 7.59 filters but are likely to buy packages of
8 or 10 This is also true of cleaning supplies.) The annual cost of detergents and spotting chemicals is
estimated at $l,307/year (BLS, 1997; USEPA, 1993), for a total supplies cost of $1,913 per year. The
annual cost of supplies without spotting chemicals is $1,527 (BLS, 1997; USEPA, 1993).
Maintenance Cost: Maintenance costs are based on 3.0% of annual revenue ($200,000), for a total of
$6,000.
7.3.2 PCE Transfer with Carbon Adsorber (PCE-A2)
Capital Cost: Current price quotes are not available for this configuration. The Pri^ for a retroflit carbon
adsorber (CA) unit is based on information from the 1991 NESHAP document (USEPA 1991 a) The
estimated cost of retrofitting an uncontrolled transfer machine with a CA is $6,976 (1989 dollars) or
$8 PI in 1997 dollars (BLS, 1997). An alternative source of price information (not used but included tor
comparison) is a report from the Division of Air, Office of Policy and Program Analys.s, New York State
Department of Environmental Conservation, Regulating PCE Emissions from Dry Cleaning Machines:
An Economic and Public Health Impact Analysis (NYSDEC, 1993). It estimates that the addition of a
total vapor containment system, including a CA, to an existing transfer machine would cost from $10 000
to $12,000 including installation (1991 dollars, or between $10,916 and $13,099 in 1997 dollars) (BLS
1997). The implied cost of an uncontrolled transfer equipment combination ($19,680 from Option FCb-
A1) is added to the retrofit cost of $8,121 to give a total effective capital cost of $27,801.
Solvent Cost: Assuming a solvent use of 469 gallons/year (USEPA estimates) and a solvent price of
$6.83 per gallon, the solvent cost is $3,203 (USEPA, 1993). The mileage is 114 pounds per gallon.
Energy Cost: Data are not available at this time.
Regulatory Compliance Cost:" Regulatory compliance costs are estimated at 1.84% of annual revenue
($200,000) for a total of $3,680.
7-10
-------
Chapter 7
Process Cost Estimates
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7-11
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Chapter 7
Process Cost Estimates
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7-12
-------
Chapter 7
Process Cost Estimates
Hazardous Waste Disposal Costs: Hazardous waste costs are based on engineering estimates of 667
gallons per year. Assuming a hazardous waste disposal cost of $6.94 per gallon (Beedle, 1998), the total
cost is $4,629.
Cost of Filters/Cleaning Supplies: Each 35 -pound capacity machine needs 20.24 replacement standard
carbon core filters at $17.57 per filter and 7.59 double all carbon filters at $29.03 per filter (USEPA,
1993), for an annual cost of $576, or $606 in 1997 dollars (BLS, 1997). All costs presented for filters and
cleaning supplies are average costs. (Individuals will not buy 7.59 filters but are likely to buy packages of
8 or 10. This is also true of cleaning supplies.) The annual cost of detergents and spotting chemicals is
estimated at $l,307/year (USEPA, 1993;BLS, 1997), for a total supplies cost of $1,913 per year. The
annual cost of supplies without sporting chemicals is $1,527 (USEPA, 1993; BLS, 1997).
Maintenance Cost: Maintenance costs are based on 3.0% of annual revenue ($200,000), for a total of
$6,000.
7.3.3 PCE Transfer with Refrigerated Condenser (PCE-A3)
Capital Cost: The cost shown is based on quotes from two vendors. Kleen Rite will retrofit a transfer
machine with a refrigerated condenser (RC) for a list price of $8,611, which includes a $300 installation
fee (Becknell, 1994). ArtiChill will retrofit a transfer machine with an RC for a list price of $8,500, which
includes a $500 installation fee (Stork, 1994). Indexing the average price of $8,556 to 1997 dollars brings
the total to $8,823 (BLS, 1997). An alternative source of price information (not used in the table, but
included for comparison) is the Source Reduction Research Partnership (SRRP, 1992). The SRRP
estimates that retrofitting an uncontrolled transfer machine with an RC costs $9,366 in 1997 dollars (BLS,
1997). To calculate the annualized cost of equipment on a comparable basis with new equipment, the
implied cost of an uncontrolled transfer equipment combination ($19,680 from Option PCE-A1) is added
to the retrofit cost of $8,823 to give a total effective capital cost of $28,503 (BLS, 1997).
Solvent Cost: Assuming a solvent use of 417 gallons/year (USEPA estimates) and a solvent price of
$6.83 per gallon (USEPA, 1993;BLS, 1997), the solvent cost is $2,848. The mileage is 128 pounds per
gallon.
Energy Cost: Data are not available at this time.
Regulatory Compliance Cost: Regulatory compliance costs are estimated at 1.84% of annual revenue
($200,000) for a total of $3,680.
Hazardous Waste Disposal Costs: Hazardous waste costs are based on engineering estimates of 658
gallons per year. Assuming a hazardous waste disposal cost of $6.94 per gallon (Beedle, 1998), the total
cost is $4,567.
Cost of Filters/Cleaning Supplies: Each 35-pound capacity machine needs 20.24 replacement standard
carbon core filters at $17.57 per filter and 7.59 double all carbon filters at $29.03 per filter (USEPA,
1993), for an annual cost of $576, or $606 in 1997 dollars (BLS, 1997). All costs presented for filters and
cleaning supplies are average costs. (Individuals will not buy 7.59 filters but are likely to buy packages of
8 or 10. This is also true of cleaning supplies.) The annual cost of detergents and spotting chemicals is
estimated at $l,307/year (USEPA, 1993;BLS, 1997), for a total supplies cost of $1,913 per year. The
annual cost of supplies without spotting chemicals is $1,527 (USEPA, 1993;BLS, 1997).
7-13
-------
Chapter 7
Process Cost Estimates
Maintenance Cost: Maintenance costs are based on 3.0% of total revenue ($200,000) for a total of
$6,000.
7.3.4 PCE Dry-to-Dry with No Carbon Adsorber or Refrigerated Condenser (PCE-B1)
Capital Cost: Uncontrolled dry-to-dry machines are no longer available, so historical information must be
used The price for an uncontrolled dry-to-dry machine is based on a 1989 price sheet from Marvel
Manufacturing Company (Villareal, 1994). The 1989 list price with a filter and still was $27,300.
Adjusting to 1997 dollars brings the price to $31,781 (BLS, 1997). An alternative source of price
information (not used but included for comparison) is the Clean Air Act Section 114 Questionna.res,
which was a survey conducted for the Chemical and Petroleum Products Division, Office of Air Quality,
Planning, and Standards. The median reported price of a 35-pound dry-to-dry machine was $24,000 in
1987 dollars (USEPA, 1988). Adjusting to 1997 dollars brings the total to $29,715 (BLS, 1997).
Solvent Cost: Assuming a solvent use of 561 gallons/year (USEPA estimates) and a solvent price of
$6.83 per gallon, the solvent cost is $3,832. The mileage is 95 pounds per gallon.
Energy Cost: A Model M-30 Bowe Permac dry-to-dry machine with no CA or RC draws approximately
1 1 kilowatt-hours (kWh) of electricity (Morgal, 1998). Six loads per day (30 minutes per load) are needed
to process the annual throughput of 53,333 pounds. Therefore, at a cost of $0.0764/kWh, annual energy
costs are calculated to be $78.
Regulatory Compliance Cost: Regulatory compliance costs are estimated at 1.84% of annual revenue
($200,000), for a total of $3,680.
Hazardous Waste Disposal Costs: Hazardous waste costs are based on engineering estimates of 658
gallons per year. Assuming a hazardous waste disposal cost of $6.94 per gallon (Beedle, 1998), the total
cost is $4,567.
Cost of Filters/Cleaning Supplies: Each 35-pound capacity machine needs 20.24 replacement standard
carbon core filters at $17.57 per filter and 7.59 double all carbon filters at $29.03 per filter (USEPA,
1993), for an annual cost of $606 (BLS, 1997). All costs presented for filters and cleaning supplies are
average costs. (Individuals will not buy 7.59 filters but are likely to buy packages of 8 or 10. This is also
true of cleaning supplies.) The annual cost of detergents and spotting chemicals is estimated at
$1 307/year (BLS, 1997; USEPA, 1993), for a total supplies cost of $1,913 per year. The annual cost of
supplies without spotting chemicals is $1,527 (BLS, 1997; USEPA, 1993).
Maintenance Cost: Maintenance costs are based on 3.0% of total revenue ($200,000), for a total of
$6,000.
7.3.5 PCE Dry-to-Dry with Carbon Adsorber (PCE-B2)
Capital Cost: The cost is based on quotes from two vendors. District Cleaners Equipment retrofits a 35-
pound capacity vented dry-to-dry machine to a closed-loop machine with a CA unit for $7,000 to $8,000
(the median price of $7,500 is used to calculate the average price) (Immanuel, 1994). lisa Multi-Solver
produces a free-standing CA unit for dry-to-dry vented machines for $7,000 (including $500 installation)
(Lage, 1994). The average price of these two units is $7,250. Indexing for inflation brings the total price
to $7,477 (BLS, 1997). An alternative source of price information (not used but included for comparison)
is the New York State Department of Environmental Conservation report previously cited (NYSDEC,
7-14
-------
Chapter 7
Process Cost Estimates
1993), which estimates that the addition of a CA to an existing dry-to-dry machine would cost $6,000
including installation (1991 dollars, equivalent to $6,549 in 1997 dollars) (BLS, 1997). The implied cost
of an uncontrolled dry-to-dry machine ($31,781 from Option PCE-B1) is added to the retrofit cost of
$7,477 to give a total effective capital cost of $39,258 in 1997 dollars (BLS, 1997).
Solvent Cost: Assuming a solvent use of 355 gallons/year (USEPA estimate) and a solvent price of $6.83
per gallon, the solvent cost is $2,425. The mileage is 150 pounds per gallon.
Energy Cost: A Model M-30 Bowe Permac dry-to-dry machine draws approximately 1.1 kWh of
electricity (Morgal, 1998). Six loads per day (30 minutes per load) are needed to process the annual
throughput of 53,333 pounds. The total energy use of a CA unit on a dry-to-dry machine is 344 kWh/year
reported in USEPA (199la) for an annual throughput of 87,524 pounds per year. In this analysis, the
throughput is 60.9% (53,333 pounds/87,524 pounds) of that used in USEPA (199 la). The adjusted annual
energy use for the CA unit is therefore 210 kWh/year. Therefore, at a cost of $0.0764/kWh, annual energy
costs are calculated to be $94.
Regulatory Compliance Cost: Regulatory compliance costs are estimated at 1.84% of annual revenue
($200,000) for a total of $3,680.
Hazardous Waste Disposal Costs: Hazardous waste costs are based on engineering estimates of 667
gallons per year. Assuming a hazardous waste disposal cost of $6.94 per gallon (Beedle, 1998), the total
cost is $4,629.
Cost of Filters/Cleaning Supplies: Each 35-pound capacity machine needs 20.24 replacement standard
carbon core filters at $17.57 per filter and 7.59 double all carbon filters at $29.03 per filter (USEPA,
1993), for an annual cost of $606 (BLS, 1997). All costs presented for filters and cleaning supplies are
average costs. (Individuals will not buy 7.59 filters but are likely to buy packages of 8 or 10. This is also
true of cleaning supplies.) The annual cost of detergents and spotting chemicals is estimated at
$l,307/year(BLS, 1997; USEPA, 1993), for a total supplies cost of $1,913 per year. The annual cost of
supplies without spotting chemicals is $1,527 (BLS, 1997; USEPA, 1993).
Maintenance Cost: Maintenance costs are based on 3.0% of total revenue ($200,000) for a total of
$6,000.
7.3.6 PCE Dry-to-Dry Converted to Closed-Loop (PCE-B3)
Capital Cost: The price to retrofit a vented dry-to-dry machine with an RC unit is based on a survey of
equipment offered by four drycleaning manufacturers and distributors. Pros Equipment (Hope, 1994)
retrofits a 35-pound vented dry-to-dry machine to a closed-loop machine with an RC unit using a water-
cooled condensing unit for $6,000, and an RC unit using an air-cooled condensing unit for $5,400.
Although the air cooled unit is less expensive, 80% of Pros' current customers select the water cooled
system because it tends to be both easier for them to understand and easier to install. Therefore, the $6,000
price is used to calculate the average. District Cleaners Equipment retrofits a 35-pound vented dry-to-dry
machine to a closed-loop machine with an RC unit for $6,000 to $8,000 (the $7,000 midpoint is used to
calculate the average) (Immanuel, 1994). ArtiChill sells the Arctic Dry 75, a closed-loop conversion
system that retrofits a 35-pound capacity vented dry-to-dry machine to a closed-loop machine with an RC
unit for $9,995 (Stork, 1994). The Vapor Condensing System by Kleen-Rite, a closed-loop conversion
system that retrofits a 35-pound capacity vented dry-to-dry machine to a closed-loop machine with an RC
unit, costs $6,507 (including $300 installation) (Becknell, 1994). The average price of these four units is
7-15
-------
Chapter 7
Process Cost Estimates
$7 376 (1994 dollars). Indexing to 1997 dollars brings the average price to $7,607 (BLS, 1997). In order
to calculate the annualized cost of equipment on a comparable basis with new equipment, the implied cost
of an uncontrolled dry-to-dry machine ($31,781 from Option PCE-2A) is added to the retrofit cost of
$7,607 to give a total effective capital cost of $39,388 (BLS, 1997).
Solvent Cost: Assuming a solvent use of 303 gallons/year (USEPA estimates) and a solvent price of
$6.83 per gallon, the solvent cost is $2,069. The mileage is 176 pounds per gallon.
Energy Cost: A Model M-30 Bowe Permac dry-to-dry machine draws approximately 1.1 kWh of
electricity (Morgal, 1998). Six loads per day (30 minutes per load) are needed to process the annual
throughput of 53,333 pounds. The total energy use of an RC unit on a dry-to-dry machine is 604
kWh/year, for an annual throughput of 87,524 pounds per year (USEPA, 199la). In this analysis the
throughput is 60.9% (53,333 pounds/87,524 pounds) of that used in USEPA (1991a). The adjusted energy
use for the RC unit is therefore 368 kWh/year. Using the price of $0.0764/kWh, the total annual energy
cost is calculated to be $106.
Regulatory Compliance Cost: Regulatory compliance costs are estimated at 1.84% of annual revenue
($200,000) for a total of $3,680.
Hazardous Waste Disposal Costs: Hazardous waste costs are based on engineering estimates of 658
gallons per year. Assuming a hazardous waste disposal cost of $6.94 per gallon (Beedle, 1998), the total
cost is $4,567.
Cost of Filters/Cleaning Supplies: Each 35-pound capacity machine needs 20.24 replacement standard
carbon core filters at $17.57 per filter and 7.59 double all carbon filters at $29.03 per filter (USEPA,
1993), for an annual cost of $606 (BLS, 1997). All costs presented for filters and cleaning supplies are
average costs. (Individuals will not buy 7.59 filters but are likely to buy packages of 8 or 10. This is also
true of cleaning supplies.) The annual cost of detergents and spotting chemicals is estimated at
$1 307/year (BLS, 1997; USEPA, 1993), for a total supplies cost of $1,913 per year. The annual cost of
supplies without spotting chemicals is $1,527 (BLS, 1997; USEPA, 1993).
Maintenance Cost: Maintenance costs are based on 3.0% of total revenue ($200,000), for a total of
$6,000.
7.3.7 PCE Dry-to-Dry Closed-Loop with no Carbon Adsorber or with Door Fan and
Small Carbon Adsorber (PCE-C)
Capital Cost: The price of a closed-loop dry-to-dry machine with an RC unit is based on a survey of
equipment offered by six major drycleaning manufacturers. The six machines are Fibrimatic's Ecodry,
with a purchase price of $24,500 (Du Bach, 1994); Fluormatic's Blue Tiger Model 37, with a list price of
$39,500 (Moser, 1994); Marvel's Ranger 35, with a list price of $36,875 (Villareal, 1994); VIC's Model
1235FS, with a list price of $41,400 (Giesen, 1994); Boewe Passat's Model P535 (36-pound capacity),
with a list price of $47,105 (Cannon, 1994); and Multimatic Shop Star 300, with an estimated list price of
$34,667 (list price estimated based on purchase price of $26,000) (Immanuel, 1994). The average price of
these six machines is $37,341. Indexing to 1997 dollars brings the total average price to $38,511 (BLS,
1997).
Solvent Cost: Assuming a solvent use of 210 gallons/year (USEPA estimates) and a solvent price of
$6.83 per gallon, the solvent cost is $1,434. The mileage is 254 pounds per gallon.
7-16
-------
Chapter 7
Process Cost Estimates
Energy Cost: Model P-536 Bowe Permac dry-to-dry machine draws approximately 1.9 kWh of electricity
(Morgal, 1998). Six loads per day (30 minutes per load) are needed to process the annual throughput of
53,333 pounds. Therefore, at a cost of $0.0764/kWh, annual energy costs are calculated to be $136.
Regulatory Compliance Cost: Regulatory compliance costs are estimated at 1.84% of annual revenue
($200,000) for a total of $3,680.
Hazardous Waste Disposal Costs: Hazardous waste estimates are based on engineering estimates of 662
gallons per year. Assuming a hazardous waste disposal cost of $6.94 per gallon (Beedle, 1998), the total
cost is $4,594.
Cost of Filters/Cleaning Supplies: Each 35-pound capacity machine needs 20.24 replacement standard
carbon core filters at $17.57 per filter and 7.59 double all carbon filters at $29.03 per filter (USEPA,
1993), for an annual cost of $606 (BLS, 1997). All costs presented for filters and cleaning supplies are
average costs. (Individuals will not buy 7.59 filters but are likely to buy packages of 8 or 10. This is also
true of cleaning supplies.) The annual cost of detergents and spotting chemicals is estimated at
$l,307/year (BLS, 1997; USEPA, 1993), for a total supplies cost of $1,913 per year. The annual cost of
supplies without spotting chemicals is $1,527 (BLS, 1997; USEPA, 1993).
Maintenance Cost: Maintenance costs are based on 3.0% of total revenue ($200,000), for a total of
$6,000.
7.3.8
PCE Dry-to-Dry Closed-Loop with Unvented Integral Secondary Carbon Adsorber
(PCE-D)
Capital Cost: The price for new "fourth generation" drycleaning equipment includes filters and a
distillation unit and is based on a survey of three distributors and manufacturers: Fibrimatic's Ecostar 4th
Plus, with a list price of $29,995 (Du Bach, 1994); Fluormatic's Blue Tiger 37 Next Generation, with a
list price of $45,000 (Moser, 1994); and Boewe Passat's Model P535 (36-pound capacity), with a list price
of $63,105 (Cannon, 1994). The average price for these three machines is $46,033. Indexing to 1997
dollars brings the average total price to $47,475 (BLS, 1997).
Solvent Cost: Assuming a solvent use of 178 gallons/year (USEPA estimates) and a solvent price of
$6.83 per gallon, the solvent cost is $1,216. The mileage is 300 pounds per gallon.
Energy Cost: P-536 Bowe Permac dry-to-dry machine with CA unit (consorber) draws approximately 2.6
kWh of electricity (Morgal, 1998). Six loads per day (30 minutes per load) are needed to process the
annual throughput of 53,333 pounds. Therefore, at a cost of $0.0764/kWh, annual energy costs are
calculated to be $186.
Regulatory Compliance Cost: Regulatory compliance costs are estimated at 1.84% of annual revenue
($200,000) for a total of $3,680.
Hazardous Waste Disposal Costs: Hazardous waste estimates are based on engineering estimates of 662
gallons per year. Assuming a hazardous waste disposal cost of $6.94 per gallon (Beedle 1998) the total
cost is $4,594.
Cost of Filters/Cleaning Supplies: Each 35-pound capacity machine needs 20.24 replacement standard
carbon core filters at $17.57 per filter and 7.59 double all carbon filters at $29.03 per filter (USEPA,
7-17
-------
Chapfc
Process Cost Estimates
1993) for an annual cost of $606 (BLS, 1997). All costs presented for filters and cleaning supplies are
average costs. (Individuals will not buy 7.59 filters but are likely to buy packages of 8 or 10 This is also
true of cleaning supplies.) The annual cost of detergents and spotting chemicals is estimated at
$1 307/year (BLS 1997; USEPA, 1993) for a total supplies cost of $1,913 per year. The annual cost ot
supplies without spotting chemicals is $1,527 (BLS, 1997; USEPA, 1993).
Maintenance Cost: Maintenance costs are based on 3.0% of total revenue ($200,000), for a total of
$6,000.
7.4 COST ESTIMATES FOR HYDROCARBON SOLVENT MACHINE
CONFIGURATIONS
Exhibit 7-5 summarizes the three HC solvent machine configurations analyzed. The discussion
that follows details the cost estimates of each technology configuration for HC solvents.
7.4.1 HC Transfer Machine with Standard Dryer and No Condenser (HC-A1)
Capital Cost: A transfer machine has two components, a washer/extractor machine and a dryer (or
reclaimer) The solvent removed during the extractor process (i.e., spin drying) in the washer/extractor
equipment is captured, filtered, and reused. The two components are available for sale separately. The
price of an uncontrolled HC solvent transfer machine is based on a J&T Model 40 (40-pound capac.ty)
washer/extractor (with filter and explosion kit), which sells for $23,900 (Jenkins, 1994) plus the average
cost of a basic Cissell Dryer, $3,085 (Stanley, 1994). The combined price for the two components is
$26,985 (1994 dollars). Indexing to 1997 dollars brings the total to $27,830 (BLS, 1997).
Solvent Cost: Assuming a solvent use of 2,159 gallons/year (USEPA estimates) and a Stoddard solvent
price of $2.24 per gallon, the solvent cost is $4,836. The solvent mileage is 25 pounds per gallon.
Energy Cost: Data are not available at this time.
Regulatory Compliance Cost: Regulatory compliance costs are excluded from this analysis due to a lack
of information.
Hazardous Waste Disposal Costs: Hazardous waste estimates are based on engineering estimates of
1,415 gallons per year. Assuming a hazardous waste disposal cost of $6.94 per gallon (Beedle, 1998), the
total cost is $9 820 Note that HC solvent waste may not be considered hazardous waste under RCRA if
their flashpoint is greater than 140°F. This is the case for DF-2000. Therefore, this value represents an
upper bound estimate. If wastes are considered non-hazardous, operating expenses may be significantly
reduced.
Cost of Filters/Cleaning Supplies: Each machine needs 4.92 replacement standard carbon core filters at
$34 per filter and 1.64 double all carbon filters at $42 per filter (Hill, 1994a), for an annual cost of $244 in
1997 dollars (BLS, 1997). Adding the cost of detergents and spotting chemicals, $1,307 (BLS, 1997;
USEPA, 1993), yields atotal of $1,551 (BLS, 1997). The annual cost of supplies without spotting
chemicals is $1,169 (BLS, 1997).
Maintenance Cost: Maintenance costs are based on 3.0% of total revenue ($200,000), for a total of
$6,000.
-------
Chapter 7
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-------
Chapter'
Process Cost Estimates
7.4.2 HC Transfer Machine with Recovery Dryer (HC-A2)
Capital Cost: The price of a transfer machine system, including a reclaimer dryer, is the sum of the
washer/extractor in the transfer system in Option HC-A1 ($23,900), plus the price of the Hoyt Petro-Miser
solvent reclaimer ($12,395) (King, 1994), or $36,295. Indexing the cost from 1994 dollars to 1997 dollars
brings the combined total to $37,432 (BLS, 1997).
Solvent Cost: Assuming a solvent use of 998 gallons per year (USEPA estimates) and a Stoddard solvent
price of $2.24 per gallon, the solvent cost is $2,236. The mileage is 53 pounds per gallon. The
manufacturer claims the Petro-Miser reclaims from 3.5 to 5 gallons of solvent for every 100 pounds of
clothes washed.
Energy Cost: Data are not available at this time.
Regulatory Compliance Cost: Regulatory compliance costs are excluded from this analysis, due to a
lack of information.
Hazardous Waste Disposal Costs: Hazardous waste estimates are based on engineering estimates of
1,415 gallons per year. Assuming a hazardous waste disposal cost of $6.94 per gallon (Beedle, 1998), the
total cost is $9,820. Note that HC solvent waste may not be considered hazardous waste under RCRA if its
flashpoint is greater than 140°F. Therefore, this value represents an upper bound estimate. If wastes are
considered non-hazardous, operating expenses may be significantly reduced.
Cost of Filters/Cleaning Supplies: Each machine needs 4.92 replacement standard carbon core filters at
$34 per filter and 1.64 double all carbon filters at $42 per filter (Hill, 1994a), for an annual cost of $244 in
1997 dollars (BLS, 1997). Adding the cost of detergents and spotting chemicals, $1,307 (BLS, 1997;
USEPA, 1993), yields a total of $1,551 (BLS, 1997). The annual cost of supplies without spotting
chemicals is $1,169 (BLS, 1997).
Maintenance Cost: Maintenance costs are based on 3.0% of total revenue ($200,000), for a total of
$6,000.
7.4.3 HC Dry-to-Dry Closed-Loop with Refrigerated Condenser (HC-B)
Capital Cost: The price of an HC dry-to-dry closed-loop machine with filter and RC that uses an
azeotropic process during the final aeration is based on the $50,500 price for a Midwest 35 pound capacity
machine ($41,000 for machine, $5,000 for filter, and $4,500 for RC) (Hill, 1994b). Indexing the cost to
1997 dollars brings the total price to $52,082 (BLS, 1997). A distillation unit can be added for $10,000
but would not be necessary for good performance, according to the machine's supplier (Hill, 1994b).
Solvent Cost: Assuming a solvent use of 514 gallons per year (USEPA estimates) and a Stoddard solvent
price of $2.24 per gallon, the solvent cost is $1,151. The solvent mileage is 104 pounds of clothes cleaned
per gallon of solvent.
Energy Cost: Energy costs, based on Hill's assumption that HC process energy costs are 10% higher than
those for a comparable PCE drycleaning machine (PCE-C), are estimated to be $149.
Regulatory Compliance Cost: Regulatory compliance costs are excluded from this analysis due to a lack
of information.
7-20
-------
Chapter 7
Process Cost Estimates
Hazardous Waste Disposal Costs: Hazardous waste estimates are based on engineering estimates of
1,415 gallons per year. Assuming a hazardous waste disposal cost of $6.94 per gallon (Beedle, 1998), the
total cost is $9,820. Note that HC solvent waste may not be considered hazardous waste under RCRA if
its flashpoint is greater than 140°F. Therefore, this value represents an upper bound estimate. If wastes are
considered non-hazardous, operating expenses may be significantly reduced.
Cost of Filters/Cleaning Supplies: Each machine needs 4.92 replacement standard carbon core filters at
•$34 per filter and 1.64 double all carbon filters at $42 per filter (Hill, 1994a) for an annual cost of $244 in
1997 dollars (BLS, 1997). Adding the cost of detergents and spotting chemicals, $1,307 (BLS, 1997;
USEPA, 1993), yields a total of $1,551 (BLS, 1997). The annual cost of supplies without spotting
chemicals is $1,169 (BLS, 1997).
Maintenance Cost: Maintenance costs are based on 3.0% of total revenue ($200,000), for a total of
$6,000.
7.5 COST ESTIMATES FOR MACHINE WETCLEANING
Exhibit 7-6 details the cost components for machine wetcleaning. The discussion below provides
information on the cost estimates of for this technology configuration. Capital costs include both washing
and drying.
Capital Cost: Wetcleaning equipment ranges in price considerably based on the size and sophistication of
the equipment. Six suppliers and their list prices are the Aqua Clean SOS ($36,380) and 80G ($33,475);
the Bowe Permac Wash 200 with a 35-pound capacity including single reuse tank, circulation pump, and
door pump with spray ($37,605); the Unimac UW30 with a 30-pound capacity ($8,373) and the DTB50
dryer with a 75-pound capacity ($2,729); the Marvel ADS 60# with a 60-pound capacity including
thermometer, alarm, steam injection, extra supply, and two thermal fills ($25,585); the Milnor 30022 F8W
with a 55-pound capacity ($17,245 without dryer; $25,061 with dryer); and the Daewoo DWF-1088PA
with a 24-pound capacity ($1,099)12 (Fleck, 1998; Schmelik, 1998; Star and Vasquez, 1997). The
configuration of the Unimac UW30 washer and DTB50 dryer will be used in this analysis. The total
capital cost for this equipment is $11,102. Based on Unimac specifications, this equipment is expected to
run at 100% capacity, resulting in 6 loads per day for an annual throughput of 53,333 pounds of clothes
(Fleck, 1998; Schmelik, 1998).
Solvent Cost: The solvent used in machine wetcleaning is water. Based on Unimac's specifications, an
average of 3.5 gallons of water is used per pound of clothes cleaned. The price of water is $3.06/100 ft3
(USEPA, 1993; BLS, 1997). Based on an annual throughput of 53,333 pounds, the total cost is $763 in
1997 dollars (BLS, 1997; Fleck, 1998; Schmelik, 1998).
The large price difference between Daewoo brand wetcleaning machines and the other commercial brands is associated
with the following factors: (1) Daewoo machines have pre-programmed cycles, while a fully programmable microprocessor control is
available for many of the other brands; and (2) the capacity of the Daewoo machines is considerably less than many of the other
manufacturer's models (Star, 1998).
— —- .
-------
Chapter'
Process Cost Estimates
Exhibit 7-6. Estimated Process-dependent Cost Components for Machine Wetcleaning3
Technology
Machine Wetcleaning
Total Capital
Cost
of Equipment
$11,102
Annualized
Cost of
Equipment11
$1,219
Annual
Cost
Solvent0
$763
Annual
Energy
Cost"
$788
Annual Cost
Hazardous
Waste'
NA
Annual Cost
Filters and
Supplies'
$3,162
Exhibit 7-6. Estimated Process-dependent Cost Components for Machine Wetcleaning8 (Cont'd)
Technology
Machine Wetcleaning
Annual Cost
Regulatory
Compliance9
NA
Annual
Cost
Maintenance11
$376
Total
Annual
Operating
Cost'
$5,089
Total
Annual
Cosf
$6,308
Total
Annual
Cost/Pound
$0.12
Thvatoesn^ services direct|y related to machine Wetcleaning but exclude costs for pressing,
storefront operations, and rent. All values are in 1997 dollars, and all calculations assume a 53,333 pound annual volume of
clothes cleaned per facility. .
"Annual cost of equipment, annualized using 7% interest; assuming equipment life of 15 years.
c Solvent costs based on $3.06/100 cubic feet for water (BLS, 1997; USEPA, 1993).
11 Assumes $0.0764/kWh national average electricity cost (BLS, 1997).
• No hazardous waste disposal costs are estimated for machine wetcleaning. However, some spotting agents and wetcleanmg
detergents may contain chemical constituents that are considered RCRA hazardous wastes.
'Assumes detergent costs ($2,878), fabric softener costs ($40), and spotting chemical costs ($245).
8 Requlatory costs could not be estimated at this time.
* Machine wetcleaning maintenance costs are based on 3.39% of total capital costs (Murphy, 1 994)
1 Includes solvent, energy, hazardous waste, filters, detergent, and maintenance costs. The cost of labor, another component of
annual operating costs, is omitted due to lack of data.
1 Includes all operating costs and annual capital costs.
Energy Cost: The total energy draw of the washer is 2.2 kWh with an average cycle time of 25 minutes.
The dryer uses 9.1 8 kWh of energy with an average cycle time of 30 minutes. Using the price of $0.0764
per kWh, the total energy cost is calculated to be $788 (Fleck, 1998; Schmelik, 1998).
Hazardous Waste Disposal Cost: This analysis assumes that no hazardous waste disposal costs are
associated with the wetcleaning process. However, some spotting agents (e.g., PCE and trichloroethylene)
and wetcleaning detergents may contain chemical constituents that are considered RCRA hazardous wastes
when they are present in a waste water stream.
Regulatory Compliance Cost: Machine wetcleaning technology is too new to the fabricare industry for
regulatory' compliance costs to be estimated at this time.
Cost of Filters/Cleaning Supplies: Unimac estimated detergent costs of $1 .19 (1993 dollars) to clean 30-
pounds of lightly soiled clothes and $1.72 (1993 dollars) to clean 30-pounds of heavily soiled clothes. An
average price of $1 .46 (1993 dollars) per 30-pounds of clothes cleaned is used, assuming that 50% of loads
are lightly soiled and 50% are heavily soiled (BLS, 1997). Chemicals used include Seitz Chemicals
Company's Frankolan S and Frankopal W. The ingredients of these detergents are proprietary information
and therefore confidential. For an annual throughput of 53,333 pounds of clothes cleaned, detergent costs
are $2,877 in 1997 dollars (BLS, 1997). The total cost of $3,162 includes fabric softener ($40) and
spotting chemicals ($245) in 1997 dollars (BLS, 1997).
7-22
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Chapter 7
Process Cost Estimates
Maintenance Cost: For the purpose of this analysis, the wetcleaning equipment maintenance cost is
estimated as 2% per year of the purchase price with a major overhaul, costing 8% of the purchase price.
every 5 years for the life of the machine (Murphy, 1994). These investments are annualized using 7% over
the 15-year life span of the equipment, for an annual maintenance cost of 3.39% of the capital cost. The
total annual maintenance cost is $376. This estimate is consistent with the UCLA/PPERC study
wetcleaning maintenance estimate of $379 annually for 15 years, which includes replacing the door lock,
water drain valve, water extractor bearings, circulation pumps, and computer control unit (Gottlieb et al
1997).
7-23
-------
Ch
Process Cost Estimates
REFERENCES
Becknell, C. 1994. Personal communications between Gary Becknell, Safety-Kleen, and Cassandra De
Young, Abt Associates Inc. August 22 and September 1.
Beedle, L. 1998. Personal communication between Lee Beedle, Safety-Kleen of Grand Junction, CO, and
' Jonathan Greene, Abt Associates Inc. March 19.
BLS 1997 Bureau of Labor Statistics. Downloaded from the BLS Information Bulletin Composite File
of the Producer Price Index for Capital Equipment and Chemicals and Allied Products. U.S.
Department of Labor, Bureau of Labor Statistics, Office of Prices and Consumer Living
Conditions.
Cannon, B. 1994. Personal communications between Barry Cannon, Bowe Passat/Permac, and Cassandra
De Young, Abt Associates Inc. August 11 and 16.
Du Bach, C. 1994. Personal communication between Chris Du Bach, Fibrimatic, and Cassandra De
Young, Abt Associates Inc. August 17.
EIA. 1997. U.S. Department of Energy, Energy Information Administration. Monthly Energy Report
Database, http://tonto.eia.doe.gov/mer/mer-toc-dt.cfm
Faig, K. 1996. Personal communication between Ken Faig, International Fabricare Institute, and Alice
Tome, Abt Associates Inc.
Faig, K. 1998. Personal communication between Ken Faig, International Fabricare Institute, and Alice
Tome, Abt Associates Inc. January.
Fleck, T. 1998. Personal communication between Tom Fleck, Raytheon Commercial Appliances, and
Jonathan Greene, Abt Associates Inc. April 17.
Giesen, L. 1994. Personal communication between Leo Giesen, VIC Manufacturing, and Cassandra De
Young, Abt Associates Inc. August 11.
Gottlieb, R., J- Goodheart, P. Sinsheimer, C. Tranby, and L. Bechtel. 1997. Pollution Prevention in the
Garment Care Industry: Assessing the Viability of Professional Wet Cleaning. UCLA/Occidental
College Pollution Prevention Education and Research Center. Los Angeles, CA. December.
Hill, J., Jr. 1994a. Personal communication between Jim Hill, Jr., Hill Equipment Company, and Leland
Deck, Abt Associates Inc. March.
Hill, J., Jr. 1994b. Personal communications between Jim Hill, Jr., Hill Equipment Company, and
' Cassandra De Young, Abt Associates Inc. June and August.
Hope, B. 1994. Personal communications between Bruce Hope, Pros Equipment, and Cassandra De
Young. Abt Associates Inc. July.
IFI. 1992. International Fabricare Institute. Results of IFI Survey of 1991 Operating Costs. September.
7-24
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Chapter 7
Process Cost Estimates
Immanuel, F., Jr. 1994. Personal communication between Frank Immanuel Jr., District Cleaners
Equipment, and Cassandra De Young, Abt Associates Inc. August 11.
Jenkins, L. 1994. Personal communication between Lauri Jenkins, Four State Machinery, and Cassandra
De Young, Abt Associates Inc. August 18.
King, P. 1994. Personal communication between Pat King, Hoyt Corporation, and Cassandra De Young,
Abt Associates Inc. August 22.
KSBEAP. 1997. Kansas Small Business Environmental Assistance Program. Kansas Dry Cleaners:
Complying with Kansas Environmental Regulations. The University of Kansas, Division of
Continuing Education. Lawrence, KS. August.
Lage, A. 1994. Personal communications between Al Lage, Columbia-lisa, and Cassandra De Young,
Abt Associates Inc. August 17 and 18.
Morgal, B. 1998. Personal communication between Bill Morgal, Bowe Permac, and Jonathan Greene,
Abt Associates Inc. March 25.
Moser, J. 1994. Personal communication between Joe Moser, Fluormatic, and Cassandra De Young, Abt
Associates Inc. August 22.
Murphy, M. 3994. Personal communication between Mike Murphy, Unimac, and Cassandra De Young,
Abt Associates Inc. August 26.
NCAI. 1998. Neighborhood Cleaners Association International. NCAI Bulletin: Cost Comparison Chart
for 1998. March.
NYSDEC. 1993. New York State Department of Environmental Conservation. Regulating PCE
emissions from dry cleaning machines: an economic and public health impact analysis. Office of
Policy and Program Analysis and Division of Air. Albany, NY. March.
Perry, R., and C. Chilton. 1973. Chemical Engineers Handbook, 5th edition. McGraw-Hill Inc.
Pindyck, R., and D. Rubeinfeld. 1989. Microeconomics. Macmillan Publishing Company New York
NY.
Schmelik, T. 1998. Personal communication between Tom Schmelik, Raytheon Commercial Appliances,
and Jonathan Greene, Abt Associates Inc. April 17.
Seitz, W. 1996. Personal communication between William Seitz, National Cleaners Association, and
Jonathan Greene, Abt Associates Inc. December 19.
Shaffer, W. 1995. Letter to Joseph Breen, USEPA, from William B. Shaffer Jr. on behalf of the
Martinizing Environmental Group. September 22.
SRRP. 1992. Source Reduction Research Partnership. Source reduction and recycling of halogenated
solvents in the dry cleaning industry. Technical support document. Metropolitan Water District of
Southern California and the Environmental Defense Fund. Pasadena, CA.
7-25
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Chapter 7
Process Cost Estimates
Stanley, M. 1994. Personal communication between Mary Stanley, Cissell Manufacturing, and Cassandra
De Young, Abt Associates Inc. August 23.
Star, A. 1998. Personal communication between Anthony Star, Center for Neighborhood Technology,
and Jonathan Greene, Abt Associates Inc. April 22.
Star,A.,andC.Vasquez, 1997. Wet Cleaning Equipment Report: A Report on Washers, Dryers,
Finishing Equipment, and Detergents for Machine-based Professional Wet Cleaning. The Center
for Neighborhood Technology (CNT). May.
Stork, B. 1994. Personal communication between Bill Stork, ArtiChill, and Cassandra De Young, Abt
Associates Inc. August 15.
Szykman, J. 1998. Personal communication between Jim Szykman, USEPA Office of Air Quality
Planning and Standards, and Jonathan Greene, Abt Associates Inc. January 28.
USEPA 1988 U S. Environmental Protection Agency. Options for regulating PCE emissions in the dry
cleaning industry: a cost-benefit analysis. Draft report. Office of Pesticides and Toxic
Substances. Washington, DC.
USEPA 1990 U.S. Environmental Protection Agency. Drycleaning and laundry plants, RCRA/
Superfund fact sheet. EPA/530-SW-90-027b. Draft environmental impact statement. EPA-
450/3-9 l-020a. Office of Air Quality, Planning and Standards. Washington, DC.
USEPA 199la. U.S. Environmental Protection Agency. Dry cleaning facilities - background information
for proposed facilities. Draft environmental impact statement. EPA-450/3-91-020a. Office of Air
Quality, Planning and Standards. Washington, DC. November.
USEPA 1991b US Environmental Protection Agency. Economic Impact Analysis of regulatory
controls in the dry cleaning industry. Final. EPA-450/3-91-021. Office of Air Quality, Planning
and Standards. Washington, DC. October.
USEPA 1993 U.S. Environmental Protection Agency. Multiprocess wet cleaning cost and performance
comparison of conventional dry cleaning and an alternative process. EPA 744-R-93-004. Office
of Pollution Prevention and Toxics. Washington, DC.
USEPA 1997. U.S. Environmental Protection Agency. Comment document of the cleaner technologies
substitutes assessment for the fabricare industry project. Attachment to comment #6-6. Material
adapted from information provided to commenter by Tellus Institute.
Villareal, J. 1994. Personal communications between Joe Villareal, Marvel, and Cassandra De Young,
Abt Associates Inc. August 11 and 22.
Wolf, K. 1998. Personal communication between Kathleen Wolf, Institute for Research and Technical
Assistance, and Alice Tome, Abt Associates, Inc. January.
Wong, T. 1998. Personal communication between Todd Wong, California Air Resources Board, and
Alice Tome, Abt Associates Inc. January.
7-26
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CHAPTER 8
SELECTED FEDERAL REGULATIONS
8.1
8.2
8.3
8.4
8.5
8.6
8.7
8.8
CHAPTER CONTENTS
Clean Air Act
Glean Water Act
Safe Drinking Water Act - Underground
Injection Control Regulations
Resource Conservation and Recovery Act
Comprehensive Environmental Response,
Compensation and Liability Act
Occupational Safety and Health Act
Care Labeling Rule
Other Applicable Regulations
This chapter describes some federal
regulations that may affect the various fabricare
alternatives analyzed in this document.
Regulatory requirements are an important aspect
of comparing alternative fabricare processes
because of their effect on daily and long-term
costs, equipment requirements, cleaning
processes, overhead, owner/operator liability,
and business compliance time (Blackler et al.,
1995).
Professional clothes cleaners may be
affected by the requirements of the following
federal air, water, waste management, and
occupational health and safety regulations: (1) Clean Air Act (CAA); (2) Clean Water Act (CWA); (3)
Safe Drinking Water Act - Underground Injection Control Regulations (SDWA-UIC); (4) Resource
Conservation and Recovery Act (RCRA); (5) Comprehensive Environmental Response, Compensation and
Liability Act (CERCLA); (6) Occupational Safety and Health (OSH) Act; and (7) the Federal Trade
Commission's Care Labeling Rule.
Following a summary of each of these federal regulations, individual sections discuss how each
statute applies to the individual fabricare processes. The final section of the chapter provides examples of
state and local regulations, as well as consensus standards of the National Fire Protection Association
(NFPA) that apply to the fabricare industry. Exhibit 8-1 summarizes the federal regulations that apply to
the various fabricare technologies covered in this Cleaner Technologies Substitutes Assessment (CTSA).
In some cases implementation of federal mandates may be.delegated to a state agency. Such
programs must be at least as stringent as the applicable federal regulation. However, state and local
authorities may impose requirements that are more stringent than those addressed by federal law. There
may also be additional state or local requirements that have no federal counterpart.
Owners and operators of drycleaning facilities are encouraged to consult USEPA's Plain English
Guide for Perc Drycleaners: A Step by Step Approach to Understanding Federal Environmental
Regulations [EPA 305-B-96-002 (USEPA, 1996a)] and Multimedia Inspection Guidance for Drycleaning
Facilities [EPA 305-B-96-001(USEPA, 1996c)] for more detailed discussions of perchloroethylene (PCE)
drycleaning regulations.
The discussion in this document is intended for informational purposes only. Stakeholders
are encouraged to examine all potentially applicable federal, state, and local regulatory
requirements that apply to professional fabricare operations in their jurisdiction. Although
spotting agents, fabric finishes, and water softeners are not covered in this regulatory assessment,
they should not necessarily be overlooked for their impact on a fabricare operation's regulatory
compliance activities.
8-1
-------
Chapter 8
Selected Federal Regulations
Exhibit 8-1. Summary of Regulations Related to Fabricare Technologies8
Fabricare
Option
PCE
cleaning
HC cleaning
Machine
Wetcleaning
CAA
'
/
NA
CWA
'
/
'
RCRA
'
/
NA
CERCLA
'
/
NA
OSH
'
/
NA
Care Labeling
Rule
'
'
'
Other
NFPA-32
NFPA-32
NA
S Indicates that a technology is regulated specifically in statute.
NA Indicates that although the statutes apply to the technology there are no specific regulatory requirements.
• The list of regulations covered in this chapter should not be considered exhaustive and may not cover all regulated aspects of
the fabricare industry.
8.1 CLEAN AIR ACT
The Clean Air Act (CAA) and subsequent amendments are a regulatory framework established to
protect and improve ambient air quality in the United States. The CAA was passed in 1970 and amended
with significant provisions in 1977 and 1990.
Section 111 established new source performance standards and best achievable technology
standards for sources of specific volatile organic chemical compounds (e.g., fabricare establishments).
These standards require establishments that emit volatile chemicals to establish and maintain records, make
reports, install/use/maintain monitoring equipment, sample locations, and provide this information to
applicable regulatory agencies.
Section 112 of the CAA establishes requirements that directly restrict the emission of 189
hazardous air pollutants. USEPA has listed 174 categories of emitters of hazardous air pollutants and
developed a schedule for establishing national emissions standards for hazardous air pollutants
(NESHAP). These standards require emitters to establish and maintain records, make reports,
install/use/maintain emissions controls and monitoring equipment, sample locations, and provide this
information to applicable regulatory agencies.
Under Title V, "major sources" of air pollutants may be required to apply for operating permits.
Section 112 of the CAA defines major sources as having the potential to emit more than 10 tons per year
of any one hazardous air pollutant (e.g., PCE), or more than 25 tons per year of any combination of
hazardous air pollutants. Generally, these permits are issued by state programs approved by USEPA.
Fabricare operators should contact their appropriate state agency to help them in determining the
applicability of "major source" requirements under Title V.
Title VI of the CAA, included in amendments passed in 1990, calls for a phase-out in the
production and importation of chlorofluorocarbons (CFCs)in the year 2000 and trichloroethane in 2002
due to their ozone-depleting potential. USEPA originally set up a program to control production and
importation of these chemicals through allowances or permits that would be expended in the production
and importation of these chemicals. In response to new scientific evidence, USEPA accelerated the phase-
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out dates to December 31, 1995. This ban has affected drycleaners using CFCs as their primary solvent
and also the type of spotting agents used in all fabricare processes.
8.1.1 Perchloroethylene Cleaning
On September 23, 1993, USEPA promulgated a NESHAP to control PCE emissions from
drycleaning facilities (National Perchloroethylene Air Emissions Standards for Dry Cleaning Facilities - 40
CFR Part 63, Subpart M). Compliance with this NESHAP was required by September 1996 for cleaners
operating prior to December 9, 1991. Cleaners that began operating on or after December 9, 1991 were
required to immediately comply with this regulation. The NESHAP regulations for drycleaners are
technology-based, rather than emissions-based. USEPA felt that it would have been prohibitively
burdensome to require owners to continuously monitor emissions concentrations and solvent mileage.
Therefore, USEPA, as authorized under Section 112(h) of the CAA, passed standards that require
installation of certain levels of emissions control equipment combined with mandatory performance testing
to ensure that the equipment is functioning properly. NESHAP standards for drycleaners are intended to
control emissions of major sources to a level that is represented by maximum achievable control
technology. Some area sources (non-major sources) are required in the framework of these regulations to
control their emissions to a level that is represented by generally available control technology.
The applicability of NESHAP requirements is dependent on the facility's size category. Exhibit
8-2 presents the air control requirements for drycleaners with new and existing machines based on the
volume of PCE purchased and the type of drycleaning machine (USEPA, 1996a). Facilities with coin-
operated drycleaning equipment, although mentioned in the NESHAP, are specifically exempted from all
NESHAP regulations (40 CFR§63.320(j)). With regard to the three remaining size categories,
requirements involving installation of equipment are generally more stringent for larger facilities. The
intent is to avoid unduly burdening small businesses with requirements they cannot afford to meet. On the
other hand, requirements involving little or no capital investment (e.g., monitoring and recordkeeping)
have been standardized for all drycleaners regardless of size.
Requirements for the PCE NESHAP, summarized in Exhibit 8-3, are divided into the following
four categories:
Emissions control equipment requirements (intended to reduce PCE emissions);
• Emissions equipment monitoring (tests to ensure that the control devices are operating properly);
• Fugitive emissions control (prevention of miscellaneous PCE emissions resulting from leaks,
improper operation of drycleaning machines, or improper handling of PCE and PCE wastes); and
• Recordkeeping and reporting (demonstration of compliance).
Aside from these requirements, the provisions of this NESHAP prohibit the sale of new transfer
machines and require all new machines to be sold with vapor control technology. New transfer machines
installed between December 9, 1991, and September 22, 1993, are considered "existing" transfer
machines. Existing machines installed before December 9, 1991, are excluded from the equipment
requirements in the NESHAP. However, such machines require specific equipment and facility retrofitting
if they fall under "large area" and "major source" classifications (40 CFR§63.320). For more specific
information, individuals are encouraged to consult the PCE NESHAP directly, or USEPA's Multimedia
Inspection Guidance for Drycleaning Facilities (USEPA, 1996c).
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Exhibit 8-2. Air Control Requirements for Drycleaners with New and Existing Machines
Based on PCE Purchase Volume'
Small Area Source Dry Cleaner
Large Area Source Dry Cleaner
Major Source Drycleaner
Dry-to-dry machines only; PCE use less
than 140 gallons/year
-or-
Transfer machines only; PCE use less
than 200 gallons/year
-or-
Transfer and dry-to-dry machines; PCE
use less than 140 gallons/year
Dry-to-dry machines only; PCE use 140
to 2,100 gallons/year
-or-
Transfer machines only; PCE use 200 to
1,800 gallons/year
-or-
Transfer and dry-to-dry machines; PCE
use 140 to 1,800 gallons/year
Dry-to-dry machines only; PCE use more
than 2,100 gallons/year
-or-
Transfer machines only; PCE use more
than 1,800 gallons/year
-or-
Transfer and dry-to-dry machines; PCE
use more than 1,800 gallons/year
Install main PCE vapor recovery system
(refrigerated condenser or carbon
adsorber) for new machines upon start-
up
No control equipment required for
existing machines
Meet good housekeeping, monitoring,
recordkeeping, reporting, and leak
detection/repair requirements
Install main PCE vapor recovery system
(refrigerated condenser or carbon
adsorber) for new machines upon start-
up
Install main PCE vapor recovery system
(refrigerated condenser or carbon
adsorber)b for existing machines by
September 23, 1996
Meet good housekeeping, monitoring,
recordkeeping, reporting, and leak
detection/repair requirements
Same requirements as large area
source, plus install additional carbon
adsorber for new machines upon start-
up and for existing machines by
September 23, 1996
Surround all existing transfer machines
with room enclosure vented by carbon
adsorber by September 23, 1996
Meet good housekeeping, monitoring,
recordkeeping, reporting, and leak
detection/repair requirements
?e tefased ujon'the total amount of PCE purchased at facility location for all PCE machines for the previousj 2 months.
* PCE vapor recovery system should be refrigerated condensers or existing carbon adsorbers installed before September 22,
1993.
PCE drycleaners characterized as a major source are required to obtain a Title V operating permit,
in addition to meeting the requirements of the PCE NESHAP. USEPA or a designated state agency may
be the entity that issues a Title V operating permit in a particular state. Note that any drycleaner defined as
a major source is required to obtain a Title V permit. Owner/operators of major source drycleanmg
facilities are encouraged to contact the applicable state agency to obtain additional information regarding
the permit process under Title V.1 If a drycleaner is not considered a major source (i.e., it is a small or
large area source), USEPA recommends that the owner check with the appropriate state air authority to
determine if Title V or other air permits are required in the drycleaner's jurisdiction.
Many of the newer PCE drycleaning systems use R-22 (HCFC-22) as a refrigerant in their
refrigerated condensers. Although R-22 is a replacement for CFCs, this refrigerant still has ozone-
depleting potential. USEPA has established a ban on all production and consumption of R-22 for the year
2020. In the year 2010, production and consumption of R-22 will be banned for all uses except as a
chemical feedstock and as a refrigerant in appliances manufactured prior to January 1, 2010. Older
machines may still contain the now banned CFC-11 or CFC-12 refrigerants, which have an even higher
'Under Section 507 of the CAA, USEPA set up a Small Business Assistance Program (SBAP) to assist industries in
complying with regulations in every state. Drycleaning operators can contact the SBAP program office in their state to ass.st them in
making a determination of their potential status as a major source under the PCE NESHAP. The SBAP Web site contains a l.st of
state-level contacts for this program (http://www.epa.gov/ttn/sbap).
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Exhibit 8-3. PCE NESHAP Compliance Requirements for Drycleaners
Requirement
Size Category of Drycleaning Facility
Small Area Source
Large Area Source
Equipment Requirements
Elimination of all transfer
machines classified as new
Existing transfer machines
surrounded with room
enclosure vented by carbon
adsorber
Installation of main PCE
vapor recovery system
(refrigerated condenser or
carbon adsorber)'
Installation of additional
carbon adsorber for residual
PCE recovery system
Major Area Source
Required
Not required
Required
Not required
Not required
Required
Not required
Emissions Equipment Monitoring
Monitoring of refrigerated
condensers
Monitoring of carbon
adsorbers
Required
Required
Required
Weekly monitoring required
Weekly monitoring required
Fugitive Emissions Control
Leak detection program
Simple leak repair
Leak repairs requiring
ordering parts
Disposal of cartridge filters
General operation of
drycleaning machines
Machine doors kept closed
when transferring clothes
PCE and PCE waste stored
in tightly sealed containers
Biweekly inspections
Weekly inspections
Repair within 24 hours
Weekly inspections
Order parts within 2 working days and install parts within 5 days of receipt
Drain for at least 24 hours
As per manufacturer specifications and recommendations
Required
Required
Reporting
Initial compliance report
Additional compliance report
Required upon start-up
Required 30 days after start-up and after any change in facility status1"
Recordkeeping
Facility log book
Maintain on-site for 5 years
Source: USEPA, 1996c
a PCE vapor recovery systems should be refrigerated condensers or existing carbon adsorbers installed before September 23,
1996.
b
Change in facility status includes changes in ownership or address of the facility, purchase of new equipment, or a change in
size category.
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ozone-depleting potential and contribute to global warming. As mentioned previously, these chemicals
were banned from production and importation on December 31, 1995. If equipment using such chemicals
is in need of a recharge, the refrigerant technology must be retrofitted or replaced to accommodate an
allowable alternative (Gottlieb et al., 1997).
8.1.2 Hydrocarbon Solvent Cleaning
New source performance standards (NSPSs) for hydrocarbon-based (HC) drycleaners2 (40 CFR
Part 60 - Subpart JJJ) were promulgated on September 24, 1984. They are applicable in CAA non-
attainment areas3 for ozone and related photochemical oxidants and may also have been adopted by
individual states. The NSPSs set limits on solvent loss from drying, outline standards on the use of filters,
and require leaks to be repaired in a timely manner. Drycleaners must add control devices to reduce
solvent loss from the washer, dryer, and filters. In addition, they must monitor their machines more closely
for leaks (USEPA, 1995).
The following equipment is regulated if it is installed at a facility having a total manufacturer's
rated dryer capacity equal to or greater than 84 pounds (38 kg) and constructed after December 14, 1982:
(1) HC solvent drycleaners, (2) washers and filters, and (3) stills and settling tanks. The total
manufacturer's rated dryer capacity is the sum of the rated capacity for each HC solvent dryer that is in
operation or is proposed for operation after a facility modification is finished. A dryer is exempt from
these regulations if it was constructed between December 14, 1982, and September 21, 1984, and uses less
than 4,700 gallons (17,800 L) of solvent per year.
The following are requirements under the current USEPA NSPS for HC solvent drycleaning
operators (KSBEAP, 1997):
• Installation of solvent recovery dryer only.
Conversion to cartridge-type solvent filters.
Draining of cartridge-type solvent filters for 8 hours in their sealed housing before removal Irom
equipment. . . . .
Posting of leak inspection and repair notices on all dryers with a clearly visible label. Leak
inspection and repair notices also must be recorded in a manual (see 40 CFR§60.622 for
recommended label warnings).
Performance of an initial test to verify that the flow rate of recovered solvent from the solvent
recovery dryer at the end of the recovery cycle is no greater than 0.05 L per minute (50
mL/minute).
• Recording of all performance testing as specified in the regulation.
^ese new source performance standards specifically regulate drycleaners that use petroleum-based solvents and do not
mention the term "hydrocarbon." For the purpose of this analysis, the phrase "hydrocarbon solvent" encompasses three different types
of petroleum solvents, two of which were not available to the drycleaning industry when the standards were promulgated in 1984.
USEPA encourages stakeholders to refer to the specific regulations (40 CFR Part 60 Subpart JJJ) for a more detailed defin.tion.
3Non-attainment areas are geographic areas that do not meet the national ambient air quality standards for one or more of the
six criteria air pollutants outlined in the CAA (i.e., sulfur dioxide, nitrogen oxides, paniculate matter, lead, carbon monoxide, ozone).
Non-attainment areas are designated as such if monitored ambient concentrations of criteria pollutants have exceeded the standard more
than the acceptable number of times over a specified period. The time period and number of acceptable exceedences varies among
criteria pollutants. Typically, a non-attainment area includes the county(ies) that make up a metropolitan statistical area plus one rmg of
surrounding counties or communities (USEPA, 1995).
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Fabricare operators should note that USEPA is considering the proposal of a NESHAP for HC
solvents. Should a proposal proceed, the NESHAP would be expected to require HC solvent drycleaners
to use maximum available control technology to reduce emissions from their fabricare operations
(KSBEAP, 1997; Szykman, 1998).
8.1.3 Machine Wetcleaning
The chemical detergents and additives analyzed by USEPA for the purposes of this document do
not contain ingredients that are regulated under the CAA. However, other wetcleaning products may
contain such chemicals. Fabricare operators should always check the ingredient list and material safety.
data sheet of wetcleaning detergents, additives, and spotting agents to determine the potential applicability
of the CAA and other regulations.
8.2 CLEAN WATER ACT
The Clean Water Act (CWA) is the federal law designed to protect the chemical, physical, and
biological quality of surface waters in the United States. The original statute of the CWA and subsequent
amendments evolved from the Federal Water Pollution Control Act of 1972 (PL 92-500). The CWA
regulates both wastewater discharges directly into surface waters via the National Pollutant Discharge
Elimination System (NPDES) and discharges into municipal sewer systems. The CWA designates and
regulates pollutants in waste water effluent according to the following three categories:
• Priority Pollutants - 126 toxic chemicals;
• Conventional Pollutants - include biological oxygen demand, total suspended solids, fecal
coliform, fats/oils/greases, and pH; and
• Non-conventional Pollutants - any pollutant not identified as conventional or priority.
8.2.1 National Pollutant Discharge Elimination System Program
Direct, or point source, discharges of discrete sources of wastewater into a navigable waterbody
are regulated under USEPA's NPDES program (CWA§402). This program applies to commercial and
industrial facilities, as well as municipal wastewater treatment plants (also known as publicly-owned
treatment works, or POTWs). This program requires regulated facilities to apply for an NPDES permit
that is issued either by USEPA or an authorized state agency. There are currently 42 USEPA-approved
state NPDES programs.
The permits issued under the NPDES program contain industry-specific, technology-based, and
water quality-based standards for wastewater effluent. Generally, the standards vary according to the
classification of receiving waters. For example, state- and locally-mandated water quality criteria may be
designated to protect surface waters for aquatic life and recreation. Such standards may not necessarily
account for technological feasibility and/or cost of effluent treatment, more typical of other federal
technology-based emissions standards. In addition, NPDES permits specify the pollutant monitoring and
reporting requirements for each regulated source of waste water effluent.
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There is a small business exemption [40 CFR§ 122.21 (g)(8)] for all NPDES permit applicants
with gross total annual sales averaging less than $ 100,000 per year in 1980 dollars (approximately
$146 000 in 1997 dollars).4 This exempts small businesses from submitting quantitative data on certain
organic toxic pollutants (see 40 CFR 122.21 Table II). However, small businesses must still provide
quantitative data for other toxic pollutants (metals and cyanides) and total phenols, as listed in 40 CFR
122.21 Table III. Other small business exemptions may apply to clothes cleaning operations, depending on
state and/or regional variances in water quality standards. Regulations concerning other hazardous and
non-conventional pollutants are similar for both small and larger facilities.
8.2.2 Wastewater Discharges to Publicly-owned Treatment Works
A facility that diverts its wastewater to a publicly-owned treatment works (POTWs) is not required
to obtain an NPDES permit. A national pretreatment program [CWA§307(b)] was established to regulate
the indirect discharge of pollutants to POTWs by users. Commercial and industrial customers may be
required to comply with regional and local discharge requirements and pretreatment standards.
Pretreatment standards include both "categorical" industry standards, implemented on a nationwide basis,
and "local limits." These requirements, which include both narrative and numeric pretreatment standards,
are established by the local and regional sewerage authorities to prevent significant interference with the
POTW5 and to allow POTWs to meet the effluent standards set by their NPDES permits.
Narrative pretreatment standards consist of general and specific prohibitions (40 CFR§403.5),
which apply to all discharges made to a POTW. General prohibitions specify that pollutants introduced
into POTWs by a non-domestic source (e.g., fabricare operations) shall not pass through the POTW or
interfere with the operation or performance of treatment works, create problems with sludge disposal, or
cause health and safety problems for plant workers from exposure to chemicals.
The specific prohibitions prevent the discharge of pollutants that cause the following conditions
(USEPA, 1996c):
Fire or explosion hazard (including discharges with a closed-cup flashpoint below 140°F);
• Corrosive structural damage (no pH<5.0);
• Solid or viscous pollutants in amounts that will cause obstruction of flow in the POTW, resulting
in interference;
• Any pollutant released in a discharge at a flow rate and/or pollutant concentration causing
interference;
Heat causing inhibition of biological activity and temperature at the treatment plant exceeding
40°C(104°F);
Petroleum oil, non-biodegradable cutting oil, or products of mineral oil origin in quantities that
will cause pass through and interference;
4This estimate is based on conversion using the Apparel and Upkeep Consumer Price Index for urban consumers.
5Many POTWs are required, through their NPDES permits, to implement a pretreatment program that provides for control of
toxics and compliance with narrative numeric pretreatment standards by its users. A POTWs authority to implement this program is
contained in its local Sewer Use Ordinance (USEPA, 1996c).
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Pollutants that result in the presence of toxic gases, vapors, or fumes in the POTW that may cause
acute worker health and safety problems; and
• Trucked or hauled wastes, except at locations designated by the POTW.
Numeric standards consist of categorical standards and local limits. Categorical standards apply to
many types of specific industries (e.g., metal finishers), but do not apply specifically to fabricare operators.
POTWs required to develop pretreatment programs must develop local limits to implement the general
prohibitions listed above. Local limits are site-specific numeric standards, enforceable by the POTW that
ensure protection of the treatment works and the receiving water body. Local limits apply to all discharges
to the POTW, including those from drycleaners.
One of the reporting requirements that may be applied to a drycleaning facility through a permit is
the submission of a report at least once every 6 months regarding the nature, concentration, and flow of
pollutants in the wastewater, based on a sampling study and analysis (40 CFR§403.12). Additional
reporting requirements that apply to all users of a POTW include (40 CFR§125) (USEPA, 1996c):
Notification of the POTW, USEPA, and appropriate state agency of any discharge to the POTW
that would be considered hazardous if discharged in a different manner. A discharge of more than
15 kg per month of a hazardous waste (e.g., 2.4 gallons of pure PCE) into the sewer would require
this type of notification;
• Notification of the POTW in advance of any substantial change in volume or character of
pollutants in their discharge, including hazardous wastes; and
• Requirement to submit a notice of discharges, including slug loadings, immediately upon
identification of such discharges that could cause problems for the POTW.
Users subject to monitoring requirements must also comply with specific recordkeeping
requirements and maintain the records for a minimum of 3 years. Such records include
date/place/method/time of sampling and person(s) taking samples, date(s) sample analysis was performed,
person performing analysis, analytical technique/method used in analysis, and the results of the analysis
(USEPA, 1996c).
As a part of the national pretreatment program, POTWs are required to identify significant
industrial users (SIUs), as defined in 40 CFR 403.3. Fabricare operators may be considered significant
based on their reasonable potential to adversely affect the POTW or to violate any pretreatment
requirements (e.g., through spills or sludge discharges). The regulations further require that POTWs use a
control mechanism (i.e., permit) to ensure that all applicable standards and requirements are met by the
SIUs (40 CFR§403.8(f)(2)(iii)). Typically, fabricare facilities are not issued permits. However, operators
should be aware of the requirements and contact the local POTW to determine the status of their facility.
Permits issued by POTWs include effluent limitations, monitoring and reporting requirements, and
standard and special conditions.
All professional cleaners, regardless of process option, use several different spot removal products
for clothing. Although many biodegradable spotting agents have been developed, a number of the more
popular ones (i.e., trichloroethylene, acetone, 2-[2-butoxyethoxy] ethanol) should be disposed of as
hazardous wastes, rather than washed down the drain. Wastewater testing performed for the Center for
Neighborhood Technology's wetcleaning demonstration project indicates that use of the spotting agent
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Picrin™ (100% trichloroethylene) could result in concentrations that exceed USEPA drinking water
standards (5 parts per billion, or ppb) (CNT, 1996). Therefore, potentially hazardous spotting agents
should be identified and treated appropriately, or eliminated from use.
8.2.3 Perchloroethylene Cleaning
Fabricare facilities using PCE drycleaning technology produce wastewater contaminated with
PCE. Possible sources of the wastewater are the use and maintenance of emission control and filtration
devices (carbon adsorbers, cartridge stripping cabinets, stills, muck cookers, and refrigerated condensers).
PCE-contaminated wastewater is typically called separator water and includes (WEF, 1995):
Water added to PCE and detergent at the start of the drycleaning cycle;
• Steam used in the desorption step when a carbon adsorber is the primary air pollution control
• Water vapor from air that is condensed when a refrigerated condenser is the primary air pollution
control device;
• Water used in steam-stripping the cartridge filters;
• Water used in the distillation process; and
• Water used in the vacuum press.
Wastewater is typically gravity-separated prior to discharge. Concentrations of PCE in wastewater
vary depending on removal technology (25 to 150 ppm in separator water depending on temperature).
Refrigerated condensers produce about 50 gallons of PCE-contaminated wastewater per year, while carbon
adsorbers produce up to 1,500 gallons per year depending on the size and type of equipment (Blackler et
al., 1995).
If more than 15 kg per month (2.4 gallons) of PCE is discharged into the sewer, operators must
notify their local municipal authority, the USEPA Regional Waste Management Division Director, and the
state hazardous waste authority in writing. In this case, the notification must include the name of the
hazardous waste (PCE), the USEPA hazardous waste number (F002 - still bottom, U210 - unused PCE
from machine or storage tanks), and the type of discharge (i.e., batch event or continuous/ongoing spill). If
more than 100 kg per month (approximately 16 gallons) is discharged into the sewer, the following must
be included in the written notification: hazardous constituents (i.e., additional solvents), an estimate of
how much was discharged (in terms of mass and concentration), and an estimate of how much will be
discharged during the next 12 months.
To meet the 15 kg threshold, a drycleaner would have to discharge approximately 28,000 gallons
of wastewater based on a PCE concentration of 150 ppm. However, if a spill of pure PCE occurred, a
release of only 2.4 gallons into the sewer would be needed to meet this threshold level (USEPA, 1996a).
Under section 307(b) of the CWA, a national pretreatment program controls the indirect discharge
of pollutants to POTWs by "industrial users." Therefore, large-scale clothes cleaning facilities may need
to meet pretreatment standards for wastewater containing PCE residuals. Technically, PCE-contaminated
wastewater at levels greater than 0.7 ppm is considered a hazardous waste under RCRA. However,
USEPA has excluded such wastewater from regulation under RCRA if it is discharged directly to a
POTW. Unless local POTWs require discharge permits, it is not illegal to dispose of wastewater in this
manner. PCE-contaminated wastewater may not be discharged into a septic system according to
regulations specified under the SDWA.
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8.2.4 Hydrocarbon Solvent Cleaning
Discharge of HC solvents to a POTW may be prohibited under the CWA if their closed-cup
flashpoint is less than 140°F and therefore may cause a significant fire or explosion hazard. HC solvents
may be classified as "oils" under the CWA (40 CFR§311.1) and the Oil Pollution Act of 1990. Discharge
or spills of oils that produce a visible sheen on either surface water, or in waterways and sewers that lead to
surface waters, must be reported to the National Response Center at 1-800-424-8802 if they meet
reportable quantity criteria. Fabricare operators are encouraged to check the material safety data sheet of a
particular HC solvent to determine the applicability of the CWA and other regulations.
8.2.5 Machine Wetcleaning
Machine wetcleaning can result in the discharge of significant amounts of wastewater. The
amount of wastewater discharged depends on the fabricare technology used. The content of the
wastewater is determined by the soils and the chemical additives used during the cleaning process (i.e.,
detergents, finishing additives, spotting agents). The contaminants that must be monitored in the
evaluation of wastewater will depend on state regulations and local POTW restrictions. The following is a
sample of contaminants of concern identified by the Illinois Environmental Protection Agency Bureau of
Water and the Illinois Department of Public Health (Tchobanoglous and Burton, 1991; CNT, 1996):
• Biological Oxygen Demand - The rate at which organisms use oxygen in the water while
stabilizing decomposable organic matter under aerobic conditions. Biological oxygen demand is a
measure of the organic strength of wastes in water and the environmental impact of chemical
pollution.
• Suspended Solids - The nonfilterable residue present upon evaporation of wastewater at 103° to
105°C.
• Fats, oils, and greases.
• Ammonia Nitrogen, Nitrogen, and Phosphorus - Depending on the receiving stream these
components may or may not be desirable.
• Metals - The type and level of metals allowed for discharge to municipal treatment systems
depends on the treatment systems available to remove them. Standards may be process-specific or
applied across an industry.
• Total Toxic Organics - There are 126 priority pollutants found in Appendix D of Section 307 of
the Clean Water Act (40 CFR 423, Appendix A) for which water quality levels have been
developed under the NPDES program.
Analysis of facility wastewater performed in conjunction with two recent wetcleaning studies
(Center for Neighborhood Technology; Pollution Prevention Environmental Research Center - University
of California at Los Angeles/Occidental College) indicate that such facilities are within POTW wastewater
discharge standards (CNT, 1996; Gottlieb etal., 1997). The chemical detergents and additives analyzed by
USEPA for the purposes of this document do not contain ingredients that are regulated under the CWA.
However, other wetcleaning products may contain constituent chemicals that are regulated under the
provisions of the CWA. Fabricare operators should always check the ingredient list and material safety
data sheet of wetcleaning detergents, additives, and spotting agents to determine the potential applicability
of this and other regulations.
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8.3 SAFE DRINKING WATER ACT - UNDERGROUND INJECTION
CONTROL REGULATIONS
The Safe Drinking Water Act (SDWA) prohibits the injection of contaminants through wells that
will cause a public water supply system to violate a national drinking water standard or otherwise endanger
public health or the environment. This statute requires USEPA to set maximum levels for contaminants in
water delivered to users of public water systems. Such standards are health-based for drinking water and
require water supply system operators to come as close as possible to meeting these standards by using the
best available technology that is economically and technologically "feasible." Primary enforcement -
responsibility may be delegated to states that request it, if they adopt drinking water regulations no less
stringent than the national standards and implement adequate monitoring and enforcement procedures
(USEPA, 1996c).
Of special concern are toxic contaminants in water from underground sources. Fabricare
operations that use cesspools or septic systems capable of handling the sole sanitary waste of more than 20
people per day, or that use on-site disposal systems for the disposal of industrial waste (different types of
Class V injection wells), are subject to federal or state underground injection control regulations (UIC)
established under SDWA (USEPA, 1996c).
A Class V injection well is a sub-surface apparatus that meets the definition of an injection well
and is used to emplace fluids above or into underground sources of drinking water. USEPA regulates all
large household, commercial, and industrial cesspools and septic systems capable of serving more than 20
people no matter what they inject; excluded from USEPA regulation are individual household cesspools
and septic systems serving less than 20 people that inject solely sanitary waste. USEPA regulations
applicable to Class V injection wells are found in 40 CFR 144 and 146 (Underground Injection Control
Program). USEPA Class V guidance documents are currently under development (USEPA, 1996c).
An on-site disposal system typically includes a septic tank and fluid distribution system, or
leachfield, which relies on biological organisms and gravity flow to treat and disseminate solely sanitary
wastewater. Disposal of even small quantities of industrial wastewater into a septic system is dangerous to
the environment in two important ways: (1) industrial waste contains harmful chemicals that undergo
minimal change in a septic tank before entering the sub-surface environment and ground water resources;
and (2) the industrial waste may also destroy biological organisms in the septic system necessary for
sanitary wastewater treatment.
The SDWA prohibits any activity that would "endanger" underground sources of drinking water
by contamination. Septic systems discharge wastewater directly underground without any treatment.
Industrial waste fluids washed down floor drains into dry wells or cesspools undergo even less change
before entering the ground. Chemicals that are denser than water (e.g., PCE) will "sink" below the water
table and migrate down through sandy aquifers and fractures in bedrock when released to the ground
(USEPA, 1996c).
Violation of the "endangerment" criteria for underground sources of drinking water can result in
fines, remediation costs for clean-up, and possible closure of operations and can require permitting
procedures. Fabricare operators found in non-compliance may be responsible for penalties up to $25,000
for each day of non-compliance (USEPA, 1996a).
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Chapter 8
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USEPA directly regulates Class V wells in 15 states,6 American Samoa, the Virgin Islands, and the
District of Columbia, and for all Indian Tribes. In the other 35 states, Guam, Puerto Rico, and the
Commonwealth of the Northern Marianas, drycleaners are subject to applicable state UIC regulation's
(USEPA, 1996c).
8.3.1 Perchloroethylene Cleaning
In USEPA jurisdictions, all drycleaners who dispose of industrial waste in on-site disposal systems
must,,at a minimum, submit inventory information to be in compliance with UIC regulations. In addition,
drycleaners are required to submit inventory information for cesspools and septic systems that are capable
of handling the sole sanitary waste of more than 20 people per day, even if PCE waste or other hazardous
chemicals are not disposed of in the system. In all state jurisdictions, drycleaners should contact their
applicable state agency to determine minimum compliance requirements (USEPA, 1996c).
A drycleaning facility that disposes of PCE waste and other hazardous chemicals into a Class V
injection well is in violation of the SDWA and should close its on-site disposal system immediately. On-
site disposal systems that receive PCE waste and hazardous chemicals are associated with many
documented cases of groundwater contamination. USEPA considers them high-risk and advises closing all
of them. The highest priorities for closure include (USEPA, 1996c):
• Dry wells;
• Cesspools and septic systems that discharge PCE waste and hazardous chemicals into aquifers in
Wellhead and Source Water Protection Areas;
• Aquifers that are hydrologically connected to drinking water aquifers;
• Aquifers designated as Sole Source Aquifers; and
• Aquifers that support sensitive ecosystems in estuaries, coastal zones, and watersheds.
USEPA Class V regulations and guidance applicable to drycleaners focus on (USEPA, 1996c):
Employing pollution prevention methods such as recycling, proper hook-ups to sewers, good
housekeeping methods and best management practices, holding tanks and removal off-site, and
waste minimization;
• Reporting the location of all on-site disposal systems that receive industrial waste to the applicable
state UIC program director;
• Inspecting on-site disposal systems to determine if they are being properly operated and
maintained, and if they are being used to dispose of PCE waste or other hazardous chemicals;
Evaluating the public health and environmental risk of the injection fluid or on-site system based
on the site hydrogeological setting of the system;
Requiring analysis of injected fluids, ambient monitoring, and additional soil or groundwater
sampling, as warranted;
• Closing on-site disposal systems that receive PCE waste and other hazardous chemicals or
otherwise endanger public health, underground sources of drinking water, or the environment;
• Requiring groundwater remediation, as warranted; and
6These states are Alaska, Arizona, California, Colorado, Hawaii, Indiana, Iowa, Kentucky, Michigan, Minnesota, Montana,
New York, Pennsylvania, South Dakota, Tennessee, and Virginia (USEPA, 1996c).
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Chapter 8
Selected Federal Regulations
• Closing all cesspools.
Cesspools receive and discharge untreated solely sanitary water. All states except Hawaii have
recognized the high risk posed by cesspools by, at a minimum, banning the construction of new cesspools
(USEPA, 1996c).
8.3.2 Hydrocarbon Solvent Cleaning
The UIC regulations mentioned above for PCE cleaning apply similarly to HC solvents.
8.3.3 Machine Wetcleaning
If an on-site disposal system of a machine wetcleaning operation receives hazardous chemicals
(e g detergents, spotting agents, and additives), it may be regulated under the provisions of the SDWA-
UIC regulations. Local municipalities and states regulate the discharge of wetcleaning waste from a
professional cleaner into a septic system. In many states, waste from professional clothes cleaners is
considered industrial, and its disposal into a septic system is therefore prohibited (TURI, 1996). The
wetcleaning detergent and additive formulations analyzed by USEPA for the purpose of this document are
not regulated by the SDWA-UIC regulations. However, other chemical detergents and additives used in
wetcleaning equipment may contain ingredients that are regulated by this and other provisions of the
SDWA. Fabricare operators are encouraged to check the ingredient list and material safety data sheet of
wetcleaning products to determine the applicability of this and other regulations.
8.4 RESOURCE CONSERVATION AND RECOVERY ACT
Passed in 1976, the Resource Conservation and Recovery Act (RCRA) is the primary waste
management statute in the United States. RCRA regulates the management and disposal of hazardous
(Subtitle C) and solid (Subtitle D) wastes. It establishes a "cradle to grave" system for tracking the
production, management, and disposal of hazardous waste. Detailed definitions are provided for both
hazardous and solid wastes, as well as specific requirements related to waste generation, management,
storage, and disposal. The Hazardous and Solid Waste Amendments of 1984 strengthened RCRA's waste
management provisions and added Subtitle I, governing the management of underground storage tanks.
USEPA has issued regulations implementing the federal RCRA statute (40 CFR Parts 260-299).
As of March 1994, 46 states were authorized to implement their own RCRA programs. Non-RCRA-
authorized states (Alaska, Hawaii, Iowa, and Wyoming) may have additional or more stringent state laws
pertaining to hazardous waste management. Facility operators should always check with their state
regulator when determining which requirements apply to their waste management activities.
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Chapter 8 Selected Federal Regulations
RCRA sets forth the following requirements for companies that generate sources of hazardous
waste:
• Procedures for generators to identify solid and hazardous wastes or wastes exempted from
regulation (40 CFR Part 261);
• Standards for obtaining a generator identification number, performing manifesting and other
recordkeeping and reporting requirements, ensuring proper labeling and packaging, and waste
accumulation units (40 CFR Part 262);
• Land disposal restrictions and treatment standards (40 CFR 268);
• Used oil storage and disposal requirements (40 CFR Part 279);
• Emission standards for volatile organic compounds stored in tanks and containers (40 CFR§264-
265, Subpart C); and
• Requirements regarding design and release detection for underground storage tanks, as well as
financial responsibility and corrective action standards.
8.4.1 Classification of Hazardous Wastes
USEPA classifies wastes as "hazardous" through regulations (40 CFR Part 261) and lists many
wastes according to industrial processes. A waste can be classified as hazardous if it is either listed as a
waste or is a characteristic waste. Listed wastes are specifically named in the regulations (e.g., discarded
commercial toluene, spent non-halogenated solvents). The different lists of hazardous wastes found in
Appendix VII of 40 CFR§261 are as follows:
F List - wastes from non-specific sources, including wastes generated by industrial processes that
may occur in several different industries;
• K List - wastes from specific industry-sources;
P List - acutely hazardous commercial chemical products that have been or are intended to be
discarded;
U List - hazardous commercial chemical products that have been or are intended to be discarded;
and
D List - materials exhibiting a hazardous waste characteristic (ignitability, corrosivity, reactivity, or
toxicity).
Characteristic wastes, a subset of listed wastes, are defined as hazardous if they meet the defined
criteria for one of four hazardous characteristics (as defined in 40 CFR 261.21-24), which are:
Ignitability - ability to start burning easily; liquids with a flashpoint below 140°F; solids that
spontaneously ignite; or oxidizing;
Corrosivity - ability to dissolve metal or burn skin; pH less than or equal to 2.0 or greater than or
equal to 12.5;
Toxicity - materials that are poisonous to humans and other living organisms, as determined by the
toxicity characteristic leachate procedure7; and
The toxicity characteristic leachate procedure is an analytical test that simulates the acidic conditions found in a landfill and
determines the amount of a certain regulated substance that would leach from the waste if placed in a landfill Regulatory levels in
parts per million (ppm) are set for 39 hazardous constituents. Any waste exceeding these levels is considered a toxic hazardous waste
8-15
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Chapter 8
Selected Federal Regulations
Reactivity - ability to undergo rapid or violent chemical reactions, which necessitates special
handling requirements.
The waste generator has the responsibility for determining whether a waste is hazardous and what
classification, if any, may apply to a waste stream. In addition to laboratory testing, waste generators_may
use their own knowledge and familiarity with a waste stream to characterize its status under RCRA. 1 hey
are subject to enforcement penalties for improperly determining that a waste is not hazardous.
8.4.2 Classification of Hazardous Waste Generators
Generator requirements under RCRA are found in 40 CFR Parts 261.5 and 262. A hazardous
waste generator is defined as any person, by site, who creates a hazardous waste or a waste subject to
RCRA Subtitle C (USEPA, 1995). Generators are divided into the following three categories (USEPA,
1996b):
Large Quantity Generators (LQGs) generate more than 1,000 kg (approximately 2,200 pounds) of
hazardous waste per month, or more than 1 kg (2.2 pounds) of acutely hazardous waste per month;
Small Quantity Generators (SQGs) generate between 100 and 1,000 kg (approximately 220 to
2,200 pounds) of hazardous waste per month, or less than 1 kg (2.2 Ibs) per month of acutely
hazardous waste; and
Conditionally Exempt Small Quantity Generators (CESQGs) generate no more than 100 kg
(approximately 220 pounds) of hazardous waste per month or less than 1 kg (2.2 pounds) ot
acutely hazardous waste per month.
Exhibit 8-4 contains the RCRA requirements for LQGs, SQGs, and CESQGs. CESQGs are
required to evaluate the hazardous waste produced by their facility, considering all objects that come in
contact with potential waste. In addition, CESQGs must ensure delivery of the hazardous waste to an off-
site permitted hazardous waste facility and limit the quantities accumulated on-site to less than 1,000 kg
(2,200 pounds). Hazardous waste generators who do not meet the conditions for CESQGs mustComply
with the recordkeeping and reporting requirements and meet the following requirements (USEPA, 1996b):
• Obtain a generator identification number;
Store and ship hazardous waste in suitable containers or tanks (for storage only);
Conduct weekly inspections of hazardous waste storage area(s);
• Properly manifest waste and label containers;
Maintain copies of the manifest, a shipment log covering all hazardous waste shipments, and
testing records;
• Comply with employee training requirements;
• Use only licensed treatment, storage, and disposal facilities;
Comply with applicable land disposal restriction requirements; and
Report releases, or threats of releases, of hazardous wastes that may exceed the reportable quantity.
The provisions of 40 CFR§262 provide that SQGs may accumulate up to 6,000 kg of hazardous
waste on-site at any one time for up to 180 days without being regulated as a treatment, storage, or disposal
facility (TSDF). The provisions of 40 CFR§262.34 (f) allow SQGs to store waste on-site for 270 days
without having to apply for TSDF status, provided the waste must be transported over 200 miles.
" 8-16 "
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Chapter 8
Selected Federal Regulations
Exhibit 8-4. RCRA Requirements for Hazardous Waste Generators
Requirement
Determination of whether
waste Is hazardous
USEPA I.D. Number
Personnel training
Contingency planning and
emergency procedures
On-site storage quantity limit
On-site storage time limit3
Satellite accumulation of
waste
Storage maintenance
requirements
Packaging, labeling, marking,
and placarding requirements
Uniform hazardous waste
manifest
Exception reports
Type of facility required for
off-site management of waste
Land disposal notification
requirement
Category of Hazardous Waste Generator
Conditionally Exempt Small
Quantity Generator
(CESQG)
Small Quantity
Generator
(SQG)
Large Quantity
Generator
(LQG)
General Requirements
Required
Not federally, required
Not federally required
Not federally required
Required
Required
Employees must be familiar
with proper waste handling
and emergency procedures
Basic plan required
Required
Hazardous waste handling
training required for all
employees
Full plan required
[40 CFR§262.34(a)(4)]
Waste Storage Requirements
£2,200 Ibs (1,000 kg)
No limit
Not applicable
Not federally required
s1 3,200 Ibs (6,000 kg)
180 days or s200 days if
TSDF is over 200 miles
away"
£55 gallons
Basic requirements with
technical standards under
Part 265 for storage tanks
and containers
Transporting Requirements
Not federally required
Not federally required
Not federally required
State-approved solid waste
facility or RCRA
permitted/interim status
hazardous waste facility;
check state-specific
requirements
Not federally required
In accordance with applicable
DOT regulations
Required
Report missing manifest
return copy within 60 days of
transporter accepting
RCRA permitted/interim
status hazardous waste
facility
Required
No limit
s90 daysb
<55 gallons
Full compliance with
management tanks,
containers, and drip pads
In accordance with applicable
DOT regulations
Required
Contact transporter and
TSDF within 35 days of
transporter accepting waste
to determine status; submit
report within 45 days
RCRA permitted/interim
status hazardous waste
facility
Required
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Chapter 8
Selected Federal Regulations
Requirement
Category of Hazardous Waste Generator
Conditionally Exempt Small
Quantity Generator
(CESQG)
Small Quantity
Generator
(SQG)
Large Quantity
Generator
(LOG)
Recordkeeping Requirements
Copy of manifests
,^^—n«^^——• "™
Copies of biennial report
Records of waste analyses
Not federally required
Not federally required
Not federally required
Maintain copies for 3 years
Not federally required
Maintain for 3 years after last
shipment of waste
Maintain
Maintair
(40 CFF
Maintair
shipmer
Thepca generator from being regulated as a hazardous wastetreatment-^.-nd gwl facili*
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Chapter 8
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8.4.4 Perchloroethylene Cleaning
Drycleaners using PCE commonly produce up to seven types of listed hazardous wastes (F002)
including (USEPA, 1996a, 1996b, 1996c):
• Spent solvent;
• Still residues from solvent distillation (still bottoms);
• Spent filters and filter media from recovery of used PCE from washers (e.g., cartridge, disk,
powder, regenerative, non-regenerative);
Cooked powder residue or filter muck (associated with powder filters only);8
• Button and lint trap wastes, rags and solvent storage containers; and
Process water (e.g., from a separator).
Occasionally, drycleaners may dispose of unused PCE (including spill residue or materials used to
clean spills), which is listed as a hazardous waste (U210). Amounts of these wastes produced depend on
the cleaning capacity of the facility and the type of equipment used. Therefore, RCRA management,
reporting, and employee training requirements for drycleaning owners/operators will vary, potentially
resulting in episodic generator status. Owners/operators of PCE drycleaning facilities are encouraged to
consult USEPA's Plain English Guide for Perc Drycleaners: A Step by Step Approach to Understanding
Federal Environmental Regulations (USEPA, 1996a), USEPA's Multimedia Inspection Guidance for
Drycleaning Facilities (USEPA, 1996c), or the state regulatory office for additional RCRA-specific
requirements and classifications.
The slightly-contaminated wastewater generated from PCE cleaning is considered hazardous waste
under RCRA because it was "derived from" an F002 waste. The previously mentioned variance under the
CWA precludes regulation of PCE-contaminated wastewater under RCRA as a listed hazardous waste
(spent halogenated solvent). Drycleaners are reminded that such discharges to a POTW must comply with
the CWA and any local regulations. In addition, typical separator water contains 150 ppm of PCE, which
is much higher than the toxicity threshold for PCE-contaminated waste. Separator water may therefore be
considered a "toxic" hazardous waste as a result of failing the toxicity characteristic leachate procedure test
for this waste stream.9
There are two additional disposal options for hazardous separator water produced by a drycleaning
operation. USEPA and the drycleaning industry encourage individual businesses to have a licensed waste
management company haul and dispose of their PCE-contaminated wastewater for treatment at a properly
permitted facility (USEPA, 1995; Ohio EPA, 1996b). It is also acceptable in some states to use an
evaporator unit to treat separator water on-site. Although the PCE vapors that result from this treatment
Cooked powder residues are a by-product of PCE cleaning processes that use diatomaceous earth (clay) powder filters to
remove oil and grease from the solvent. This potentially hazardous waste product is not associated with PCE cleaning processes that
use carbon cartridge and fabric disk filters.
Q
In some instances, a material is considered hazardous based on two or more criteria in RCRA. For example, PCE separator
•water is considered a hazardous waste by default under RCRA's "Derived From" rule, because it is derived from an F002 waste In
addition, separator water typically contains about 150 ppm of PCE. Since this level exceeds the TCLP level of 0.7 ppm for PCE
contaminated waste, the separator water meets the RCRA toxicity criteria for a characteristic hazardous waste (Blackler et ah. 1995;
UOE/.TA, 177 j).
8-19
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Selected Federal Regulations
method are not considered a hazardous waste, individual states may have specific emissions control
standards for evaporator equipment used in this manner (IDEM, 1995; Ohio EPA, 1996a). Drycleaners are
encouraged to contact their applicable state regulatory agency to determine the most appropriate disposal
method for their jurisdiction.
Land disposal restrictions have been established for chemicals regulated under RCRA, prohibiting
the disposal of waste containing more than 1% (10,000 ppm) of halogenated solvents (40 CFR Part 268).
Since wastewater typically contains 150 ppm of PCE, the federal land disposal restrictions provision is not
likely to apply to this waste source (USEPA, 1995). However, there may be state regulations affecting
drycleaning operators that supersede this federal exemption.
Drycleaning facilities that store PCE in USTs are subject to USEPA and state UST regulations.
These require that a tank be protected from corrosion, equipped with devices that prevent spills and
overfills, and monitored for leaks every 30 days (40 CFR§265.190-196) (USEPA, 1995, 1996a).
8.4.5 Hydrocarbon Solvent Cleaning
Waste materials contaminated with HC solvents may be considered characteristic hazardous waste
under RCRA if the flashpoint is less than 140°F (ignitable). Fabricare operators who use these types of HC
solvents will have to comply with hazardous waste generator requirements under RCRA. Many of the
newer HC solvents and associated cleaning technologies have been developed with a flashpoint equal to or
greater than 140°F specifically to avoid classification as ignitable.
Sources of waste contaminated with HC solvents are similar to those found in PCE drycleaning
operations and may include (USEPA, 1996a, 1996b, 1996c):
• Spent HC solvent;
• Still residues from solvent distillation (still bottoms);
• Process water (e.g., from a separator);
Spent filters and filter media from recovery of used HC from washers (e.g., carbon cartridge, fabric
disk, diatomaceous earth powder-coated, regenerative, non-regenerative);
• Cooked powder residue (associated with powder filters only);
• Button and lint trap wastes; and
• Rags and solvent storage containers.
Drycleaning facilities that store HC solvent in underground storage tanks are subject to USEPA
and state UST regulations. These require that a tank be protected from corrosion, equipped with devices
that prevent spills and overfills, and monitored for leaks every 30 days (40 CFR§265.190-196) (USEPA,
1995, 1996a).
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Chapter 8
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8.4.6 Machine Wetcleaning
The chemical detergents and additives analyzed by USEPA for the purposes of this document do
not contain chemicals regulated under RCRA. However, other wetcleaning product formulations may
contain ingredients that are regulated under RCRA. Fabricare operators are encouraged to check the
ingredient list and/or material safety data sheet of wetcleaning detergents and additives to be sure that this
and other regulations do not apply.
8.5 COMPREHENSIVE ENVIRONMENTAL RESPONSE, COMPENSATION
AND LIABILITY ACT
The Comprehensive Environmental Response, Compensation and Liability Act (CERCLA),
known more commonly as Superfund, is the federal statute that establishes a variety of mechanisms to
clean up sites contaminated with improperly disposed chemical wastes. This 1980 statute authorizes
USEPA to respond to releases, or threatened releases, of hazardous substances that may endanger public
health, welfare, or the environment. CERCLA also enables USEPA to force responsible parties to clean
up environmental contamination or reimburse USEPA's Superfund for emergency response costs. The
Superfund Amendments and Reauthorization Act (SARA) of 1986 revised various sections of CERCLA,
extending the taxing authority for the Superfund and creating an additional free-standing federal law
(SARA Title III - Emergency Planning and Community Right to Know Act).
Under CERCLA, potentially responsible parties (PRPs) that contribute to chemical contamination
on a particular site, regardless of the extent or intent of their involvement, are held strictly liable. Such
liability is retroactive; that is, PRPs can be identified for a contaminated site many years after the actual
event has occurred, regardless of the legality of the management and disposal practices at the time of
disposal. Current and past land owners, as well as fabricare shop owners, may be held liable if any type of
contamination is found on a site. Even if concentrations of chemicals in wastewater are within limits set
by a POTW, there is a possibility that individual shops can be held liable in the future if a sewer line leaks
contaminated wastewater.
CERCLA regulations apply to any release of a hazardous substance on a site, as defined in the
following manner:
Substances designated pursuant to Section 31 l(b)(2)(A) of the Federal Water Pollution Control
Act;
• Elements, compounds, mixtures, solutions, or substances designated pursuant to Section 102 of
CERCLA;
• Hazardous wastes having the characteristics identified under or listed pursuant to Section 3001 of
the Solid Waste Disposal Act (excludes any waste whose regulation under the SWDA has been
suspended by Act of Congress);
• Toxic pollutants listed under Section 307(a) of the Federal Water Pollution Control Act;
• Hazardous air pollutants listed under Section 112 of the CAA; and
• Imminently hazardous chemical substance or mixture with respect to which the USEPA
Administrator has taken action pursuant to Section 7 of the Toxic Substances Control Act.
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Chapter 8
Selected Federal Regulations
Petroleum, including crude oil or any fraction thereof, which is not otherwise specifically listed or
designated as a hazardous substance, is exempted from regulation under CERCLA. This exemption
includes natural gas, natural gas liquids, liquefied natural gas, synthetic gas usable for fuel, and mixtures of
natural and synthetic gases.
Hazardous substance release reporting regulations under CERCLA (40 CFR Part 302) direct the
person in charge of a facility to report to the National Response Center any environmental release of a
hazardous substance that exceeds a "reportable quantity." Reportable quantities are defined and listed in
40 CFR 302.4. Generally, a release report triggers a response by USEPA or by one or more federal or state
emergency response authorities (USEPA, 1995).
USEPA implements hazardous substance responses according to procedures outlined in the
National Oil and Hazardous Substance Pollution Contingency Plan (NCP) (40 CFR Part 300). The NCP
includes provisions for permanent clean-ups, known as "remedial actions," and other clean-ups, referred to
as "removals." USEPA generally takes remedial actions only at sites on the National Priorities List, which
currently includes 1,300 sites. Both USEPA and states can act at other sites; however, USEPA provides
responsible parties the opportunity to conduct removal and remedial actions and encourages community
involvement throughout the Superfund response process (USEPA, 1996a).
8.5.1 Perchloroethylene Cleaning
The presence of PCE in the separator water of drycleaning operations is a potential liability
concern for professional clothes cleaning operations. The traditional discharge of this water directly into
municipal sewer systems, a practice that the drycleaning industry now discourages, may be responsible for
contamination of groundwater in some areas. Accidental spills and leaks of PCE on cement floors are
reported to have caused some soil and groundwater contamination at these sites (Blackler et al., 1995).
Leakage of underground storage tanks containing PCE is another potential source of contamination at these
sites (USEPA, 1995).
Many sites with past and present PCE drycleaning operations are already contaminated to levels
that will limit future uses of the property. Indeed, many property owners will not lease space to clothes
cleaners who use PCE and other solvents in their operations. CERCLA allows USEPA to hold land
owners and drycleaning operators jointly and severally liable for PCE contamination. The industry is
working with Congress to incorporate provisions in the reauthorization legislation for CERCLA that
address the clean-up of PCE-contaminated drycleaning operations (Blackler et al., 1995).
The effluent water of drycleaning operations can contain as much as 150 ppm of PCE and can
contribute 0.3 to 6 pounds per year of PCE loss depending on the equipment (WEF, 1995). Although this
dilute waste stream is discharged directly to a municipal sewer system, pipe leakage of wastewater from
this potentially persistent source can result in contamination of soils and ground water (Blackler et al.,
1995). Installation of a refrigerated condenser, in addition to a carbon adsorber, can reduce the amount of
wastewater by 30 times. Even so, the industry now recommends that all wastewater be disposed of
through properly licensed RCRA waste hauling and disposal companies (USEPA, 1995, 1996a).
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Chapter 8
Selected Federal Regulations
Since passage of CERCLA, court rulings have repeatedly established the liability of property
owners in Superfund actions. Therefore, financial lending institutions and realtors have developed specific
procedures to reduce their liability if they are associated with drycleaning facilities. These procedures
include requirements for site inspections, soil and groundwater monitoring, and survey and sampling work,
all often at the cost of the drycleaner. Leasing restrictions and loan withdrawal mechanisms have become a
part of real estate and lending transactions to drycleaners (Gottlieb et al., 1997).
The potential financial liability that CERCLA places on drycleaners and their property owners has
promoted protective legislation in eight states. This legislation may include funding mechanisms to assist
drycleaners in reducing their liability exposure, drycleaner registration fees, per-gallon surcharges on PCE
purchases, mandatory liability insurance, and/or a gross receipts tax.10 Additional information regarding
this topic is presented in Section 8.8 (Other Applicable Regulations) (Gottlieb et al., 1997).
8.5.2 Hydrocarbon Solvent Cleaning
Fabricare operations that result in the contamination of a site with HC solvents may result in
CERCLA liability, in a manner similar to sites contaminated with PCE solvent. Many HC solvents can be
characterized as a hazardous substance under CERCLA, because they are considered ignitable (listed)
hazardous wastes under RCRA (flashpoint less than 140°F). However, the petroleum exemption and the
nature of HC solvent mixtures necessitates making the following determination:
• Mixtures of petroleum distillate fractions that are modified beyond the refining process (i.e.,
chemicals considered hazardous substances are added to the mixture) are considered hazardous
substances.
• Mixtures of petroleum distillate fractions that contain hazardous substances, but are not modified
beyond the refining process, are not considered hazardous substances under CERCLA's petroleum
product exemption.
Therefore, the chemical composition and the manner in which HC solvent products are produced
will determine if CERCLA liability applies to specific substances. Also, some of the newer solvents, such
as 140°F solvent and DF-2000, may not be considered ignitable (hazardous) due to their higher
flashpoints. Fabricare operators are encouraged to carefully read the ingredient list and material safety data
sheet of petroleum solvent products to assist them in making a determination in this regard (USEPA,'
1987). Even if CERCLA does not apply to a particular HC solvent product, fabricare operators should
check with an appropriate state agency to determine if future liability can result under a state statute.
8.5.3 Machine Wetcleaning
Contamination of a wetcleaning site may occur as a result of leaky wastewater pipes and accidental
spills. Analyses performed in conjunction with two recent studies (Center for Neighborhood Technology;
Pollution Prevention Environmental Research Center - University of California at Los Angeles/Occidental
College) indicate that a site contaminated with wetcleaning wastewater has the potential to result in
CERCLA liability. Constituents of concern identified in the wastewater effluent of wetcleaning operations
Legislation has been enacted in Connecticut, Florida, Kansas, Minnesota, Oregon, South Carolina, and Tennessee, with
legislation pending in Illinois, New Jersey, North Carolina, and Pennsylvania (Gottlieb et al., 1997).
8^23
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Chapter!
Selected Federal Regulations
include heavy metals, phthalate, acids, acetone, diethylene monobutyl ether, and various organic spotting
chemicals (PCE and trichloroethylene) (CNT, 1996; Gottlieb et al., 1997).
The wetcleaning detergent and additive formulations analyzed by USEPA for the purposes of this
document did not contain chemicals that are regulated under CERCLA. However, fabricare operators are
encouraged to check the ingredient list and material safety data sheet of all wetcleaning products to
determine the potential applicability of this and other regulations.
8.6 OCCUPATIONAL SAFETY AND HEALTH ACT
The Occupational Safety and Health Administration (OSHA) was established in 1970 under the
U.S. Department of Labor to reduce occupational fatalities, injuries, and illnesses and to develop health
and safety standards and training programs for the protection of workers in the United States.
Section 6 (a) of the Occupational Safety and Health (OSH) Act enabled OSHA to promulgate
existing federal and national consensus standards as OSHA standards. Under authority of this provision,
the Health Standards program of OSHA established the following exposure limits for general industry air
contaminants (29 CFR 1910.1000 SubpartZ):
Permissible Exposure Limit-Time-Weighted Average (PEL-TWA) - an 8-hour average exposure
that workers should not exceed. A PEL-TWA assumes a 40-hour work week, 50-week work year,
and 45 years of work.
Short Term Exposure Limit (STEL) - a 15-minute, TWA exposure that shall not be exceeded at any
time during a workday unless another time limit is specified for the contaminant.
Ceiling Limits - exposure levels that shall not be exceeded during any part of the workday. If
instantaneous monitoring is not feasible, the ceiling limit shall be assessed as a 15-minute average
exposure that shall not be exceeded during any part of the workday.
Most PELs were adopted from the Walsh-Healey Public Contracts Act, which adopted standards
from the 1968 Threshold Limit Values of the American Conference of Governmental Industrial Hygienists.
On June 7, 1988, OSHA proposed to revise the PELs by adding 164 substances to the list and lowering the
PEL for 212 of the 600 substances listed. OSHA also wanted to establish skin designations, STELs, and
ceiling limits for some of these substances. In 1994 the 11th Circuit Court of Appeals vacated the
standard. OSHA currently only enforces the earlier PELs for the substances in the original Z tables.
OSHA can rely on the "general duty clause," Section 5(a)(l) of the OSH Act, if it considers exposure to
any air-borne substance to be too high. Under Section 5(a)(l) citations, the burden is on OSHA to show
what is technologically and economically feasible for the cited employer. The 1994 court ruling prompted
OSHA to begin developing individual PELs, STELs, and ceiling limits for the substances included in the
Health Standards program (USEPA, 1996b).
In addition to chemical exposure standards, OSHA has established exposure standards for a
number of relevant physical hazards found in occupational environments (e.g., non-ionizing radiation - 29
CFR 1910.97, occupational noise exposure - 29 CFR 1910.95). OSHA standards also cover the following
workplace health and safety issues:
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Chapter 8
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• Employee hazard communication (employee-right-to-know) and required signage;
• Recordkeeping associated with workplace injuries and illness;
• Employee personal protective equipment;
• First aid, blood-borne infectious diseases, workplace sanitation, and emergency response
guidelines;
• Machine guarding, fire safety, electrical safety, and lockout/tagout standards; and
• Employee training.
These and other occupational health and safety issues are discussed in detail in the State of
Michigan's Regulatory Guide for the Michigan Fabricare Industry (MDEQ, 1996). Fabricare operators
are also encouraged to contact OSHA and their state occupational health and safety department to
determine which regulations pertain to their operation and jurisdiction.
8.6.1 Perchloroethylene Cleaning
The PEL for PCE is 100 ppm; however, when OSHA promulgated its PELs in 1989, the state-plan
states also adopted them. Since these standards were not vacated by court decision, some states may still
enforce the 25 ppm 8-hour TWA. Many drycleaners voluntarily have taken measures to meet the 25 ppm
PEL in their facilities by installing control devices, such as carbon adsorbers or refrigerated condensers,
and implementing work practice controls (Blackler et al., 1995). Today, OSHA recommends that
drycleaners limit occupational exposures of PCE to 25 ppm, but can only enforce 100 ppm. In addition to
the PEL-TWAs, there is a ceiling limit of 200 ppm (5-minute average in any 3 hours) and a 300 ppm
maximum peak never to be exceeded during the workday. OSHA is currently undertaking a review of the
PEL for PCE in the drycleaning industry (Gottlieb et al., 1997).
8.6.2 Hydrocarbon Solvent Cleaning
Some regulatory and recommended limits have been determined for Stoddard solvent, a specific
type of HC solvent. In January 1989, OSHA adopted a 100 ppm PEL-TWA to replace the pre-1989 PEL.
However, the pre-1989 PEL for Stoddard solvent of 580 ppm TWA is in effect because all new 1989 PELs
were vacated via court decision. Some states may still maintain the 1989 PEL, however
8.6.3 Machine Wetcleaning
Acetic acid, which is an additive to the water used in wetcleaning, has a 10 ppm PEL-TWA
established by OSHA. A dilute mixture of acetic acid and water forms the equivalent of household vinegar.
8.7 CARE LABELING RULE
The Care Labeling Rule (16 CFR 423) was promulgated by the Federal Trade Commission (FTC)
in order to establish uniform care instructions for textile garments and accessories. This rule requires
clothing manufacturers to label garments with an acceptable cleaning method, supported by a "reasonable
basis." The reasonable basis for labeling a garment with a particular cleaning method can be based either
upon the historical success with a particular cleaning technology or actual test results that consider fiber,
fabric, and garment construction variables (Riggs, 1998).
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Selected Federal Regulations
Chapter 8
There is some controversy over the effectiveness and usefulness of this rule in promoting
drycleaning versus alternative cleaning methods. A garment often can be cleaned effectively by either dry,
wet or other cleaning methods. In order to avoid confusion and ambiguity, as well as potential liability
associated with damaged clothing, clothing manufacturers may label a garment with a dryclean only
label (Bladder et al., 1995). Researchers call this practice "low labeling," in which manufacturers tend to
indicate very cautious care instructions, in an effort to avoid liability for damaged merchandise (Riggs,
1998).
Professional clothes cleaners are not legally bound to clean garments in the manner specified by
the manufacturer. However, they are legally responsible for any damage to a customer's garment if it is
not cleaned in the manner specified by the manufacturer. Otherwise, it is the manufacturer s legal
responsibility to reimburse a customer if damage occurs when the garment is cleaned according to its
instructions. Low labeling therefore discourages customers and professional cleaners from using
alternative process options (Bladder et al., 1995).
In 1994 and 1995 the FTC requested public comment on the Care Labeling Rule in an effort to
begin revisions that would remove barriers to the use of alternative clothes cleaning process options. The
FTC is now in the process of collecting additional information for revision of this rule (Vecelho, 1996).
USEPA is also working with fabricare stakeholders, including clothing and textile manufacturers, to
develop a more accurate care labeling system that does not discriminate among cleaning methods.
8.8 OTHER APPLICABLE REGULATIONS
There are numerous regional, state, and local health, safety, and environmental regulations that
may affect the fabricare industry in the U.S. As mentioned previously, many federal regulations are
enforced more strictly by designated state agencies.
As an example, the State of Oregon established a waste minimization and hazardous waste
management program designed to eliminate future drycleaning solvent releases to the environment. This
program was established in response to the following concerns:
The drycleaning industry feared that individual drycleaners would go out of business as a result of
the liability associated with Oregon's cleanup law. This law would have required business and
property owners to pay for the cleanup of contamination on or around their premises.
Property owners faced considerable difficulty in obtaining loans from lending institutions if a
fabricare operation was co-located or adjacent to their property.
. Drycleaners were finding it increasingly difficult to obtain and renew leases.
The law established an exemption for drycleaners from paying environmental clean-up costs and
damages as a result of solvent contamination, set up a program in which all drycleaners paid annual fees to
be used to clean up contaminated sites, and required individual operations to establish equipment and
waste management practices to prevent future contamination of the environment. Faced with uncertainties
and potentially damaging liabilities, drycleaning organizations have successfully promoted the passage of
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Chapter 8
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similar legislation in seven other states, with legislation pending in four states" (Gottlieb et al., 1997;
ODEQ, 1997). Exhibits 8-5 and 8-6 contain information regarding state fees and other provisions for
reduced liability exposures, respectively.
In addition, cities and municipalities have enacted numerous zoning restrictions that may affect all
types of fabricare operations. For example, the City of Beverly Hills, California, has passed restrictions on
drycleaning operations that specify noise and odor requirements, allowable cleaning capacities, numbers of
machines per operation, location of equipment in buildings, and required approval of building inspectors
and the fire department prior to equipment installation and/or modification. In addition, many localities
have adopted some or all of the National Fire Protection Association's standards for drycleaning
equipment and operations (NFPA-32), as noted below (CBH, 1997).
The National Fire Protection Association (NFPA) is a national consensus-building organization
that has established fire protection safety standards. Although all NFPA standards are considered
voluntary, many localities and state agencies have adopted them into law. Owners of drycleaning
operations should consult with their local fire marshal about the applicability of NFPA-32 standards. In
1996 the NFPA passed safety standards (NFPA-32) for drycleaning plants classified in the following
solvent categories:
Type I - systems employing solvents with a flashpoint of less than 100°F (37.8°C);
Type II - systems employing solvents with a flashpoint between 100°F and 140°F (38°C and
60°C), such as Stoddard solvent;
Type IIIA - systems employing solvents with a flashpoint of 140°F (60°C) and above, such as
140°F solvent and DF-2000;
• Type IIIB - systems employing liquids with a flashpoint at or above 200°F (93.4°C) and
complying with building requirements (ventilation, fireproofing, and electrical equipment) of
Chapter 3 of the regulation;
Type IV - systems employing nonflammable liquids (PCE) and complying with building
requirements (ventilation and electrical equipment) of Chapter 4 of the regulation;
Type V - systems employing nonflammable solvents (PCE) and complying with building
requirements (ventilation and electrical equipment) of Chapter 5 of the regulation.
States with current liability-limiting legislation pertaining to drycleaners include Connecticut, Florida, Kansas, Minnesota,
Oregon. South Carolina, and Tennessee. Legislation is pending in Illinois, New Jersey, North Carolina,and Pennsylvania Arizona
does have cleanup and reduced liability legislation, but there is no specific reference to the drycleaning industry. Similar legislation
was introduced to the California legislature in 1995 (Assembly Bill 1096), but was subsequently withdrawn with no current plans of
reintroduction (Gottlieb et al., 1997).
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Exhibit 8-5. State Fees for Reduced Liability Exposures
State
Connecticut
Florida
Kansas
Minnesota
North Carolina
Oregon
South Carolina
Tennessee
Annual Fee1
NA
$100
NA
$1,000
$2,500C
$1,500"
$1,500
$1,000
PCE Tax
NA
$5.00/gallon
$3.75/gallonb
$3.50/gallon
$4.25/gallon
103% of sale
$10.00/gallon
$10.00/gallon
Gross Receipt
Tax
1%
2%
2%
NA
NA
NA
NA
NA
Equivalent Cost Per
Garment
$0.054
$0.124
$0.116
$0.028
$0.061
NA
$0.052
$0.041
Source: Gottlieb et al., 1997
NA Category not applicable to individual state. ..,.»,«
• For facilities with approximately nine employees (or no cost difference for size was indicated).
" This tax will be raised by $0.25 each year until the fee reaches $5.50/gallon.
«Cost can be ,owe ed to $500 if financial responsibility is demonstrated by obtaining pollution and remediatior, legarhability
Insurance with coverage of not less than $1 million or deposit with-the Commission securities or a third-party bond for
securing for pollution and liability for $1 million.
" Fee is lowered to S1,000 if annual sales are less than $50,000.
TheNFPA is currently in the process of revising this standard in order to reflect updated
equipment, alternative HC solvents, and the newer fabricare technologies that are currently being
developed.' The NFPA expects the revised standards to be performance-based, rather than focusing on
specific technology. This revision is slated for completion by mid-1999 (Spencer, 1998).
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Exhibit 8-6. State Legislative Provisions for Reduced Liability
State
Connecticut
Florida
Kansas
Minnesota
North
Carolina
Oregon
South
Carolina
Tennessee
Deductible*
$10,000 if reported prior to
1990; $20,000 if after 1990
Up to 6/30/97 -$1,000' '
7/1/97 to 6/30/01 -$5,000
7/1/01 to 12/31/05 -$10,000
After 2005 - fund pays $0
$2,500
$10,000
$10,000
$10,000
Prior to 10/1/97 -$1,000
10/1/98 -$5,000
10/1/99 -$10,000
10/1/00 -$15,000
10/1/01 -$20,000
After 2001 -$25,000 '
10% with a max. of $10,000
Maximum Paid/Year
$50,000
Up to 7/1/95 -$100,000;
After 7/1/95 -10% of
fund's income for previous
fiscal year
20% of account balance at
beginning of fiscal year
$200,000: or $400,000 if
substantial threat to human
health or the environment
$200.000
Site
Investigation
X
X
X
X
X
X
X
Remediation
and/or Treatment
X
X
X
X
X
X
Monitoring
X
X
X
X
Source: Gottlieb et al., 1997
* For facilities with approximately nine employees.
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Ch
Selected Federal Regulations
REFERENCES
Bladder C R. Denbow, W. Levine, and K. Nemsick. 1995. A Comparative Analysis of PCE Dry
Cleaning and an Alternative Wet Cleaning Process. National Pollution Prevention Center for
Higher Education. Ann Arbor, MI.
CBH 1997 City of Beverly Hills, California. Dry Cleaning Plant Restrictions (Section 10-3.1607 of the
Municipal Code). http://www.ci.beverly-hills.ca.us/municode/titlelO/chapter3/articlel6/10-
3.1607.html. Beverly Hills, CA.
CNT. 1996. Center for Neighborhood Technology. Alternative clothes cleaning demonstration shop. Final
report. Chicago, IL.
Gottlieb R L Bechtel, J. Goodheart, P. Sinsheimer, and C. Tranby. 1997. Pollution Prevention in the
Gament Care Industry: Assessing the Viability of Professional Wet Cleaning. Pollution Prevents
Education Research Center (PPERC), University of California at Los Angeles and Occidental
College. Los Angeles, CA. December 11.
IDEM. 1995. Indiana Department of Environmental Management. Regulatory Compliance Manual for
Indiana Dry Cleaners. Indiana Department of Environmental Management. July 22.
KSBEAP 1997. Kansas Small Business Environmental Assistance Program. Kansas Dry Cleaners:
Complying with Kansas Environmental Regulations. The University of Kansas, Division of
Continuing Education. Lawrence, KS. August.
MDEQ. 1996. Michigan Department of Environmental Quality. Regulatory Guide for the Michigan
'pabricare Industry. MDEQ, Environmental Assistance Division. Lansing, MI. October 31.
ODEQ 1997 Oregon Department of Environmental Quality. Oregon's Dry Cleaner Program: Cleaning Up
Contamination and Preventing Future Pollution. Article originally published in Oregon Insider,
February 15, 1997- http://www.deq.state.or.us/wmc/cleanup/dryclnup.htm.
Ohio EPA. 1996a. State of Ohio Environmental Protection Agency. Environmental Guide for Ohio Dry
Cleaners. Columbus, OH. http://www.epa.ohio.gov/dhwm/drymain.htm.
Ohio EPA. 1996b. Ohio Environmental Protection Agency. Fact Sheet on Managing Hazardous Waste
From Dry Cleaning, http://www.epa.ohio.gov/dhwm/dryclnfc.htm. April.
Riggs, C. 1998. Personal communication between Charles Riggs, Texas Women's University, and Jonathan
Greene, Abt Associates Inc. March 2.
Spencer, A. 1998. Personal communication between Amy Spencer, National Fire Protection Association,
and Jonathan Greene, Abt Associates Inc. February 24.
Szykman, J. 1998. Personal communication between Jim Szykman, USEPA Office of Air Quality Planning
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and Standards, and Jonathan Greene, Abt Associates Inc. January 28.
Tchobanoglous, G., and F. Burton. 1991. Wastewater Engineering: Treatment, Disposal, and Reuse 3rd ed
McGraw-Hill, Inc. New York, NY. pp. 71-82.
TURI. 1996. Toxic Use Reduction Institute. Training curriculum for alternative clothes cleaning. Draft
final report. Lowell, MA.
USEPA. 1987. U.S. Environmental Protection Agency. Scope of the CERCLA Petroleum Exclusion Under
Sections 101(14) and 104(a)(2). Memorandum from Francis S. Blake, USEPA General Counsel, to J.
Winston Porter, Assistant Administrator for Solid Waste and Emergency Response (OSWER
Directive #9838.1). http://es.epa.gov/oeca/osre/870731.html. July 31.
USEPA. 1995. U.S. Environmental Protection Agency. Profile of the drycleaning industry.
EPA310-R-95-001. USEPA, Office of Enforcement and Compliance Assurance. Washington, DC.
USEPA. 1996a. U.S. Environmental Protection Agency. Plain English Guide for Perc Drycleaners: A Step
by Step Approach to Understanding Federal Environmental Regulations. EPA 305-B-96-002.
USEPA, Office of Enforcement and Compliance Assurance. Washington, DC.
USEPA. 1996b. U.S. Environmental Protection Agency. Cleaner Technologies Substitute Assessment-
Lithographic Blanket Washes. EPA 744-R-95-008. USEPA, Office of Pollution Prevention and
Toxics. Washington, DC.
USEPA. 1996c. U.S. Environmental Protection Agency. Multimedia Inspection Guidance for Drycleaning
Facilities. EPA 305-B-96-001. USEPA, Office of Enforcement and Compliance Assurance
Washington, D.C.
VeceIlio,C. 1996. FTC care labeling revisions. EPA 744-R-96-002. Presented at Conference on Apparel
Care and the Environment: Alternative Technologies and Labeling, Washington September
pp. 147-153.
WEF. 1995. Water Environment Federation. Controlling Dry Cleaner Discharges in Wastewater: How to
Develop and Administer a Source Control Program. Water Environment Federation. Alexandria,
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CHAPTER 9
ADDITIONAL ENVIRONMENTAL
IMPROVEMENT APPROACHES
9.1
9.2
9.3
CHAPTER CONTENTS
PCE and Hydrocarbon Drycleaning
Facilities
Machine Wetcleaning Facilities
Contacts for Further Information
This chapter focuses on techniques that
may be employed by fabricare operations to
prevent pollution, reduce chemical consumption,
and minimize waste, with significant emphasis
on perchloroethylene (PCE) and hydrocarbon
(HC) solvent technologies. Section 9.1 examines
the pollution prevention options with the
potential to achieve environmental improvements
for facilities using PCE and HC solvent
technologies. The most common operating and maintenance procedures, control devices, and their effects
are presented, including options for recycling. Methods for extracting solvents are addressed, as are
methods for treating spent solvents so that they may be reused. In addition, this section discusses the
impact of facility conditions and remedial actions on PCE concentrations in co-located residences (i.e.,
residences located in the same building as a fabricare operation). Section 9.2 suggests practices and
improvements that may help cleaners using machine wetcleaning reduce chemical releases and exposure.
Section 9.3 provides a summary of the several major clothes cleaning trade and research associations, their
contact numbers, and some of their initiatives and publications involving environmental improvement
practices.
9.1 PCE AND HC DRYCLEANING FACILITIES
9.1.1 Recommended Operating and Maintenance Procedures
On September 22, 1993, USEPA finalized the National Emission Standard for Hazardous Air
Pollutants (NESHAP) for PCE drycleaners (58 FR 49354). This regulation set standards for the reduction
of PCE emissions from drycleaning operations. Included in the NESHAP were requirements that owners
or operators of drycleaning machines and control devices follow their manufacturers' instructions for the
proper operation and maintenance of machines and control devices. Owners or operators are required to
keep a copy of any manufacturers' specifications or operating and maintenance recommendations at the
drycleaning facility.
USEPA realizes that some drycleaners may no longer have equipment manuals for older
drycleaning machines and control devices. However, owners or operators of older machines and control
devices should make every reasonable effort to obtain these manuals. These efforts include contacting
manufacturers, if the manufacturers are still in business, and contacting local, state, and national trade
associations.
In case efforts to obtain manufacturers' manuals are unsuccessful, USEPA's Office of Air Quality
Planning and Standards (OAQPS) has developed many of the following recommendations for operating
and maintenance practices for owners or operators of PCE drycleaning machines and emission control
devices. The Office of Pollution Prevention and Toxics (OPPT) has supplemented the 1994 OAQPS
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Chapter 9
Additional Environmental Improvement Approaches
recommendations, primarily based on some more recent information. These recommendations serve only
as a last resort when manufacturers' information is not available. They should never supersede ava.lable
manufacturers' information.
This section includes various practices and improvements that may help drycleaners reduce
releases, exposures, and usage of PCE or HC solvents. This section primarily provides recommendations
on the operation and maintenance of PCE drycleaning equipment but also contains suggestions for HC
drycleaning equipment. In 1992, the International Fabricare Institute (IFI) published an Industry Focus
(IFI 1992) documenting general information on the operation and maintenance of petroleum drycleaning
equipment. For drycleaners using HC equipment, this IFI publication is likely more informative and
relevant than the information provided in this chapter of the Cleaner Technologies Substitutes Assessment
(CTSA) It should also be noted that some of the changes identified in this section may not be appropriate
when site-specific factors are taken into account. Emphasis is placed on the importance of operating and
maintaining the drycleaning equipment according to manufacturers' specifications. Training workers on
proper maintenance and operating procedures may serve to further reduce releases, exposures (including
their own exposures), and usage of solvents.
Maintenance and Operation of Drycleaning Machine Components
Exhibit 9-1 provides a summary of recommended maintenance practices for drycleaning machine
components when manufacturers' information is not available. These recommendations should never
supersede available manufacturers' information. The remainder of this section discusses those practices in
more detail. Exhibit 8-3, "Summary of PCE NESHAP Compliance Requirements for Drycleaners
identifies the items required by the NESHAP and references other USEPA documents that contain details
for complying with NESHAP requirements.
Dry-to-Dry Machine Cylinder
Although dry-to-dry machines wash and dry garments in one cylinder, PCE emissions can come
from many sources, which include the cylinder, a leaking door gasket or other gaskets, and the unloading
of garments that have not been adequately dried (reclaimed). Drycleaning operators should detect and
repair liquid and vapor PCE leaks during a weekly inspection program. If a liquid leak is detected, the
operator should replace the seal immediately because significant PCE loss can occur. Vapor leaks can
sometimes be detected by running a finger along the entire perimeter of the door seal while the machine is
operating or by placing a liquid bubble solution around the door seating and looking for bubbles. An
electronic halogen leak detector is capable of locating vapor leaks that other methods might miss.
Vented dry-to-dry machines and dryers with add-on refrigerated condensers or carbon adsorbers
have exhaust dampers to control the flow of hot air. Because the exhaust damper can be a major source of
PCE losses operators should check it monthly to ensure that it is functioning properly. Even though the
exhaust damper is usually difficult to access, every effort must be made to check and repair it. Operators
may check for leaks by placing and sealing a collapsed, inflatable plastic bag over the ductwork used to
vent the dry-to-dry machine. Operators should ensure that the bag is placed at a point downstream from
the direction of flow past the exhaust damper. If the exhaust vent outlet cannot be used, operators may
need to make some minor modifications to the ductwork, such as drilling a small test hole, which can be
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Chapter 9
Additional Environmental Improvement Approaches
Exhibit 9-1. Maintenance Schedule for Drycleaning Equipment
Component
Frequency
Maintenance Procedure
Machine Component
Dry-to-dry machine cylinder
Transfer washer/extractor
cylinder
Transfer dryer (reclaimer)
Heating and condensing coils
Button trap
Fans
Lint trap
Weekly
Monthly
Weekly
Weekly
Monthly
Monthly
Annually
Daily
Weekly
Annually
Daily
Weekly
Check door seatings and gaskets for leaks.
Check exhaust damper (vented machines) for leaks.
Check door seatings and gaskets for leaks.
Check door seatings and gaskets for leaks.
Check exhaust damper for leaks.
Check for lint build-up.
Clean coils.
Clean strainer.
Check lid for leaks.
Inspect and lubricate.
Clean lint bag, check lint build-up on temperature probe,
ductwork for lint build-up.
Dryclean or launder lint bag.
and check
Auxiliary Equipment
Filters
Distillation unit
Muck cooker
Water separator
Pumps
Tanks
Bi-weekly
Monthly
Semi-annually
Monthly
Semi-annually
Annually
Weekly
Monthly
Clean and change filters (filters drained and muck stored
containers).
in sealed
Check seals and gaskets for leaks.
Check steam and condensation coils.
Clean steam and condensation coils.
Check steam and condensation coils.
Clean steam and condensation coils.
Lubricate motor and gear box.
Clean separator tank.
Check vent.
Check for vapor and liquid leaks.
Check for vapor and liquid leaks.
Control Device
External refrigerated
condenser
Carbon adsorber
Daily
Weekly
Weekly
Monthly
Annually
Daily or before
saturation
Weekly
Clean any lint filters in air stream.
Measure temperature on exhaust for dry-to-dry machines/transfer
dryer reclaimer. Measure temperature on inlet and exhaust for
transfer washer.
Check seals, gaskets, and diverter valve for leaks.
Check refrigerant coils for lint build-up.
Clean refrigerant coils.
Desorb.
Measure concentration of PCE in exhaust air stream or in machine
drum, clean all lint filters, and check gaskets and ductwork
• Maintain according to manufacturer or media supplier's specifications or recommendations.
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Chapter 9
Additional Environmental Improvement Approaches
reseated with a leak proof plug or tape. New ductwork or a manual damper can also be added for the
testing. Operators should place and seal the plastic bag over the test hole during the beginning portion of
the drying cycle. At that point, the vent to the control device should not be in use, but should be shut off
with the exhaust damper. Operators should check to see if the plastic bag (placed over the exhaust outlet
vent or test hole) inflates. If it inflates, then there is a leak and the exhaust damper will need to be
repaired. It is also common for these dampers to stick in a position that does not allow them to close all the
way, and thus they leak. As a result, it is very important to check the operation of the damper and its
closed position very closely to ensure that the damper swings freely and closes completely when not in use.
Dampers are also known to wear and will need parts repaired so that they will seal properly again.
Transfer Washer/Extractor Cylinder
Potential emissions from the washer cylinder result from leaking door gaskets. Operators should
detect and repair liquid PCE leaks from door seatings and gaskets during a weekly inspection program.
Operators should check for these leaks in the same manner as discussed above for leaks from the dry-to-dry
machine cylinder.
Transfer Dryer (Reclaimer)
As with the washer cylinder, one source of potential PCE emissions from a dryer, or reclaimer, is
through the door. Operators should check for leaking door gaskets in the same manner as discussed above
for leaks from the dry-to-dry machine cylinder. Operators should not open the door before the end of the
drying cycle. When the machine door is open, operators should vent the dryer air to a carbon bed. If the
carbon bed is small (approximately 1- to 2-pound carbon capacity), the carbon should be changed or
desorbed daily to ensure its effectiveness (NIOSH, 1997). Another main source of potential PCE
emissions from dryers is through intake and exhaust dampers on exhaust systems. The machine damper
gaskets should be checked monthly to ensure proper operation. It is quite common for these dampers to
stick in a partially open position. As a result, it is very important to check the operation of the damper and
its closed position very closely to ensure that the damper swings freely and closes completely when not in
use.
Heating and Condensing Coils
Operators should check heating and condensing coils of dryers for lint build-up every month and
thoroughly clean them on an annual basis. Operators should place special emphasis on the fins
surrounding the heating and condensing coils. Only heating and condensing coils on older tilt back dryers
for transfer systems need daily cleaning.
As mentioned above, operators should clean the coils annually at a minimum. However, if the
coils are covered with lint that is difficult to remove when cleaned annually, operators should clean the
coils on a semi-annual basis. Heating coils can be cleaned by blowing compressed air or steam over the
coils. Condensing coils can be cleaned by brushing the coils with a stiff brush to loosen lint, then picking
up the residue with an industrial vacuum.
9-4
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Chapter 9
Additional Environmental Improvement Approaches
Button Trap
The button trap lid and strainer need regular servicing. Operators should open button traps only
long enough for cleaning. Operators should clean the strainer daily and check the lid for a vapor leak proof
seal during the weekly leak inspection program. Operators should replace the door gasket on the button
trap when needed. Operators should ensure that the lid is seated properly to prevent vapor loss and allow
for proper operation of the pump (IFI, 1994).
Fans • . • ,
Operators need to inspect and lubricate fans annually to ensure that they are functioning properly.
According to the International Fabricare Institute (IFI, 1994), to properly control emissions the local fans
for PCE drycleaning machines should be capable of maintaining a 300 to 500 cubic feet per minute air
velocity. •
Lint Trap
The lint trap located in the air flow system usually contains a removable lint bag or filter.
Operators should clean this bag or filter daily and wash or dryclean it weekly. Operators should open lint
baskets only long enough for cleaning. Operators should never run a dry-to-dry machine or dryer without a
lint bag or filter and should use a second lint bag or filter while the first is being cleaned. Once a day,
operators should check the ductwork in front of and behind the lint bag or filter for lint build-up. Also,
operators should also make a daily check for lint build-up on machines with heat sensor probes located
under or behind the lint bag or filter.
Maintenance and Operation of Auxiliary Drycleaning Equipment
In addition to the components of drycleaning machine systems, all drycleaning facilities use
auxiliary equipment in the drycleaning process. This equipment is also covered by the NESHAP and
includes filters, distillation units, muck cookers, and water separators. Spotting and pressing activities are
not covered under the NESHAP or the CTSA; therefore, the equipment used for these activities is not
discussed. Exhibit 9-1 provides a summary of recommended maintenance practices for drycleaning
machine auxiliary equipment when manufacturers' information is not available. These recommendations
should never supersede available manufacturers' information. The remainder of this section discusses
those practices in more detail. Exhibit 8-3, "Summary of PCE NESHAP Compliance Requirements for
Drycleaners," identifies the items required by the NESHAP. Section 8.1.1 summarizes the NESHAP and
references other USEPA documents that contain details for complying with NESHAP requirements.
Filters
Filters are used to remove suspended particles and dyes from PCE. Several types of filters are
currently used at drycleaning facilities, including spin disk (powder and powderless), constant pressure
powder, regenerative powder, and cartridge filter systems. Most drycleaning facilities currently use some
type of cartridge or disk filter system. Proper maintenance includes solvent recovery from filter media and
muck.
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Spin Disk Filters
Using spin disk filters instead of cartridge filters may lower PCE releases and increase solvent
mileage (CEPA 1993). Spin disk filters allow the operator to backwash filtered material directly into the
still which results in lower worker exposure to PCE vapors than changing cartridge filters. Spin disk
filters are manufactured either to use filter powder or to be powderless. A motor drives a shaft, which
spins the disks. The spin disk filters often contain 36 double-walled disks with 15-inch diameters. The
disks are made of a polyester fine-mesh material and are mounted on a center support. Solvent enters the
filter housing through the center mounting and flows through both walls of the disks and out through
perforations on the shaft.
Soils and filter powder (if used) collect on the disks, which are stationary during filtration. Spin
disk filters have a pressure gauge to measure the pressure drop across the filter. Once the pressure reaches
22 pounds per square inch (psi), the filter needs to be regenerated (NIOSH, 1997). Regeneration of the
filter involves spinning the disks to wash off the soil and powder (CEPA, 1993). A drain valve opens, and
the solvent soil and sludge flow into the still. The operator then precoats the filter with powder (if used)
after each regeneration of the filter. To ensure proper performance of the PCE solvent, a powderless spin
filter system may require finishing or polishing to catch and trap residual dyes.
Constant Pressure Filters
Constant pressure filters are only used in powder filtration systems. The pump must run
continually to keep the powder adhered to the filter. The type of constant pressure filters presently in use
uses a rigid tube. Rigid tube filters need at least 4.5 pounds of powder per 1,000 gallons per hour rated
flow, or 30 square feet of filtering area, for a good precoat.
The diatomite filter powder is lightweight, organic, and composed of fossil shells. The powder
forms clusters, which remain porous and allow PCE to flow through while trapping soil particles.
Operators should clean off the powder built up on the tube and reapply fresh powder to the tube when the
PCE flow rate decreases to 1 gallon per minute for each pound of rated load capacity that enters the wheel.
The rate of build-up will vary depending on the amount of clothing cleaned, the size of the filter, and the
size of the pump.
Excessive filter pressure is a common problem. The causes of excessive pressure include the
accumulation of muck in the filter to a point above the manifold, which reduces the filtering area; PCE in
poor condition; and nonvolatile residue, which causes slime to deposit on the filter plate if the filter is
drained and not refilled. Damp filter powder and improper or insufficient precoating can also cause
excessive pressure.
Operators should store all powder in a dry place to keep it from absorbing moisture. Operators
should determine the correct amount of filtering powder for the filter according to the filtering area. For
example, operators should use 1.5 pounds of powder per 10 square feet of filtering area for precoat and
should use at least 0.5 pound per 100 pounds of clothes to maintain the filter coating. Some common
causes for loss of precoat are back pressure, air in the filters, and obstructions or air leaks in the inlet line to
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the pump that result in uneven settling of the filter powder. Slipping pump belts or badly worn tubes could
also cause a loss of precoat.
Regenerative Filters
Regenerative filters are one of the most widely used powder filters. They consist of flexible tubes
that are constructed of braided metal wire, metal helical springs, or braided knit fibers. Unlike constant
pressure filters, regenerative filters do not require body feed, since the precoat is bumped off after each
load and is reapplied to the tube before the next load. Since no body feed is needed, operators should use
2.5 pounds of powder per 10 square feet of area to precoat regenerative filters.
The chief advantage of regenerative filters is that they do not require as much filter area as
constant pressure filters. A 100-pound washer using a regenerative filter requires only 60 square feet,
compared to 150 square feet for a constant pressure filter.
The braided wire tubes in regenerative filters can become crimped during the bumping operation,
leaving holes in the tubes that result in leakage. Damaged tubes also allow powder and carbon to pass
through the filter and muddy the PCE. Operators should correct this by repairing or replacing damaged
tubes. If carbon or powder appears in the load, or the filter is not working well, operators should inspect
the filter for holes and replace it if necessary.
Tubes can also become clogged. There must not be any interruption of PCE flow after precoating
and while PCE is flowing into the washer. Operators should ensure that the tubes are seated properly.
Backwashing may eliminate the clogging. If this is not successful, operators should remove the tubes and
clean them with trisodium phosphate.
Cartridge Filters
Cartridge filters require less maintenance than regenerative or constant pressure filters because
neither precoating nor body feed is necessary. The filters come in a range of sizes and use various filtering
media. Because cartridges are changed routinely, manufacturers' information for cartridges is always
readily available and should always be used. Operators should determine and maintain the ideal amount of
clothing cleaned for each filter cartridge before stripping. To dispose of the carbon filters, operators should
drain used filters for 24 hours and should steam strip drained filters at a proper steam pressure in a still, if
available. There are two types of commonly used cartridges:
Standard Cartridges. Standard cartridges are TA inches in diameter and 14% inches high
and use various filtering media. Carbon-core cartridges remove both insoluble soil and
color from PCE. They have a normal life span of approximately 1,000 pounds per
cartridge, depending on the type of work being processed and the amount of soil,
moisture, and lint it contains. All-carbon cartridges primarily remove color.
Adsorptive Cartridges. Adsorptive cartridges are 13'/2 inches in diameter and 18 inches
high and contain more activated clay and carbon than standard cartridges. Half-sized
cartridges, or "splits," which are 9 inches high, are also available and are easier to handle.
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Adsorptive cartridges are designed to remove insoluble soil and non-volatile residue along
with the color. Most full-sized adsorptive cartridges are built to process 2,000 pounds
before being replaced. Half-sized cartridges are made to process 1,000 pounds before
being replaced. Operators should not exceed the poundage recommendations on the
cartridges.
Operators should determine when to change cartridges either by the number of pounds cleaned or
by a measurement pressure increase according to the manufacturers' instructions. Operators should change
cartridges at a specific pressure, or at a pressure increase over the original, according to instructions and
should never let the pressure exceed 40 psi. The ability to remove nonvolatile residue may be exhausted
before a pressure rise indicates that the cartridge's capacity for insoluble soil has been reached. Exceeding
this pressure may force soil through the filter and rupture it. If PCE starts to become too dark or streaks
and swales appear, operators should change cartridges or increase the distillation rate.
Operators should ensure that gaskets or felt washers used between the cartridges are seated
properly. Gaskets that are damaged or used too long can allow soil to leak out. Some all-carbon cartridges
take a different size gasket than other cartridges made by the same manufacturer. Operators should read
the manufacturers' instructions carefully and replace gaskets frequently.
Excess moisture or poorly dispersed moisture in the filter will cause a rapid increase in pressure.
The same result may occur when some water repellents or fabric finishes are removed from fabric by the
PCE and carried over into the filter.
Operators should inspect new cartridges for physical damage before installing them. Also, a new
set of cartridges will often leak insoluble soil and carbon until several loads have been cleaned. Operators
should run only dark loads until this leakage stops.
Distillation Unit
The purpose of a distillation unit is to purify and recover used PCE to recycle it back into the
drycleaning system. Distillation units typically consist of steam and condensation coils. Water and PCE
retrieved from the distillation process are channeled to a water separator. Potential PCE loss from these
units can be due to leaks in seals and gaskets, build-up of still bottoms on the heating coil, and improper
water or steam temperatures.
Seals and gaskets in the distillation unit should be checked for leaks and repaired at least every 2
weeks. The steam and condensation coils for the distillation unit should be checked monthly and cleaned
semi-annually to avoid lint build-up. They may be cleaned in the same way as the coils used in the
drycleaning machine. Some stills do not require coil removal for cleaning.
The following practices are recommended to achieve optimum still performance and minimize
PCE in the still residue:
• Operators should never exceed 75% of the still kettle capacity, or the level recommended
by the manufacturer.
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• Operators should set up condenser water flow countercurrent to PCE flow.
• Operators should keep the PCE return temperature at a maximum of 32°C (90°F) to
minimize evaporative loss through the PCE storage tanks.
• Operators may redistill still bottoms used solvent at a rate of 6 to 8 gallons per 100 pounds
of clothes cleaned (IFI, 1994).
• Operators may redistill still bottoms with more water following boil down to recover more
solvent. However, this may create more hazardous wastewater and maintenance problems
(USEPA, 1997).
Muck Cooker
Older drycleaning systems with tubular powder filtration systems (constant pressure and
regenerative) use muck cookers to distill the residue from these systems. Maintenance procedures for
muck cookers are the same as for distillation units, except that annual or more frequent lubrication of the
motor and gear box is needed.
Water Separator and Water Evaporator
Water separators separate water and PCE from the PCE-water mixture that comes from various
condensates, including carbon desorption, distillation, machine condenser, and pressing. To function
properly, water separators must be vented to the atmosphere. The vent can become clogged and should be
checked each month. The maintenance schedule for water separators should also include vapor and liquid
leak detection procedures. In addition, operators should clean the separator tank weekly. It should be
noted that separator water usually contains minor amounts of PCE. Operators should treat separator water
as a hazardous waste and should not pour it down a drain or flush it down a toilet.
A proper way to control PCE from separator water is through double-activated carbon treatment of
separator water and evaporation (provided the separator water does not contain a layer of separated PCE).
Operators should send the spent carbon cartridges and other hazardous wastes to a USEPA-licensed
hazardous waste hauler. Vapor from the evaporator contains PCE and should be vented outside the
facility. Venting this vapor inside the facility may increase PCE concentrations in the facility and may
increase workers' exposure to PCE.
Maintenance and Operation of Emission Control Devices
USEPA's NESHAP for PCE drycleaning was intended to reduce emissions primarily by
introducing requirements for emission control devices. Under the NESHAP, drycleaning machines
installed before December 9, 1991, are considered "existing" machines, while machines installed on or
after December 9, 1991, are considered "new" machines (USEPA, 1994a). All "new" drycleaning
machines must be equipped with at least a refrigerated condenser used as a PCE vapor recovery system.
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"Large"1 drycleaners with "existing" drycleaning machines must be equipped with a refrigerated condenser
(or a carbon adsorber if it was in place before September 22, 1993). "Small"2 drycleaners do not need to
install PCE vapor recovery systems on "existing" machines. In addition, existing major source drycleaning
facilities must keep their transfer machine systems inside a room enclosure, and new major source
drycleaning facilities must install both a refrigerated condenser and a secondary carbon adsorber.
Exhibit 9-1 provides a summary of recommended maintenance practices for refrigerated
condensers and carbon adsorbers. These recommendations should never supersede available
manufacturers' information. The remainder of this section discusses those practices in more detail.
Refrigerated Condensers
Drycleaning operators should route the refrigerated condenser's one-pass outlet ducts to exhaust
outside the plant. The ducting is recommended in the rare configurations where the refrigerated condenser
exhausts to the atmosphere. The NESHAP requires temperature monitoring and checking of all gaskets
and seals during a weekly leak detection and repair program. Operators should clean all lint filters in the
ductwork associated with refrigerated condensers on a daily basis.
Carbon Adsorbers
Operators should route carbon adsorber (CA) one-pass outlet ducts to exhaust outside the plant.
The exhaust stack should be monitored during the exhaust process with a detector tube, an ionization
detector, or an equivalent sensor (NIOSH, 1997). Integral CAs in fourth and fifth generation machines
(see Chapter 2 for equipment details) are not included since these CAs do not exhaust to the atmosphere.
It is also recommended that operators determine the maximum quantity of PCE that the CA can hold. The
CA must be desorbed (i.e., steam stripped) daily, unless the daily return of PCE from the CA is less than
50% of that capacity. One way to determine the maximum capacity a CA can hold is to check the CA
exhaust with a colorimetric detector tube. Once the exhaust reads over 100 ppm (parts per million) of
PCE, the CA is considered saturated. Operators should then completely desorb the saturated CA by steam
desorption for 1 hour. The amount of PCE returned from this desorption will be the maximum quantity of
PCE that the CA can hold.
'"Large" drycleaners are defined as facilities (1) with transfer machines only and that purchase 200 or more gallons of PCE
per year; (2) with dry-to-dry machines only and that purchase 140 or more gallons of PCE per year; or (3) with a combination of dry-to-
dry and transfer machines and that purchase 140 or more gallons of PCE per year.
^'Smair drycleaners are defined as facilities (1) with transfer machines only and that purchase less than 200 gallons of PCE
per year: (2) with dry-to-dry machines only and that purchase less than 140 gallons of PCE per year; or (3) with a combination of dry-
to-dry and transfer machines and that purchase less than 140 gallons of PCE per year.
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Operator maintenance is crucial with carbon adsorption. The NESHAP recommends the following
operating and maintenance practices:
• Operators should clean the lint screen regularly.
• Operators should check for leaks in the damper that restricts steam from entering the
adsorber.
• Operators should determine and maintain the maximum or ideal ratio of clothes cleaned
per activated carbon used (USEPA, 1997).
• Operators should determine and maintain ideal stream pressure passed through the bed to
strip solvents from the carbon beds (USEPA, 1997).
• Operators should restrict desorption to a maximum of 60 minutes, whether or not PCE is
still returning. It is extremely important to dry out the adsorber for at least 15 minutes
after desorbing.
If, after an undetermined period, the carbon bed becomes contaminated, then operators
should try an extended, all day steam stripping at the highest possible steam pressure. If
that does not burn off the contamination, the carbon bed may have to be replaced.
• Operators should determine how often to desorb and maintain that schedule. An
adsorber's capacity is determined by the pounds of carbon it contains. Typical adsorber
capacities are 2 gallons, 4 gallons, or 6 gallons.
• To establish a desorption schedule, operators should begin by desorbing every day. If the
capacity is 4 gallons and every day produces less than 2 gallons but at least 0.5 gallon,
operators should strip every second day. If the stripout produces more than 2 gallons,
operators should strip every day. If the stripout produces 4 gallons every day, operators
must strip twice daily, or preferably, determine why so much PCE is getting to the
adsorber and remedy the problem. If the stripout produces no more than 1 gallon daily,
operators should strip the carbon adsorber every third day.
In addition to the monitoring requirements of the NESHAP, operators should clean all lint filters
and screens associated with carbon adsorbers on a weekly basis. Operators should include all gaskets and
ductwork associated with the carbon adsorber in a weekly detection and repair program.
Operators should always maintain the proper air filter type specified by the manufacturer. Some
older "lint filters" (e.g., furnace filters) may be improper. Improper filters can allow fine particles to
slowly clog the pores of the activated carbon. This clogging reduces the ability of the carbon to adsorb
PCE.
A CA's maximum holding capacity can diminish substantially over time depending on how
heavily the carbon is used. Operators can use a cumulative flow meter to monitor the solvent recovery
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process. It is recommended that operators consider replacing or reactivating the activated carbon every 5
years, or more or less frequently depending on how heavily the adsorber is used.
Facility Design and General Operating Procedures
Additional practices to improve environmental performance involve the design of exhaust and
ventilation systems and proper operating procedures. This section discusses those issues m more detail.
Recommendations in this section should never supersede available manufacturers' information tor the
systems discussed.
Exhaust Systems
Proper design and maintenance of exhaust systems is essential for controlling emissions. Local
exhaust systems consist of an exhaust fan, ductwork, and a hood. Local exhaust systems are designed to
collect contaminants at the source to prevent their escape into the work environment, thus reducing PCE
exposure (NIOSH, 1997). Operators should use elevated hoods between the washer and dryer for transfer
operations rather than less effective floor ducts to collect vapors into local exhaust systems. Operators
should avoid abrupt changes in duct size in local exhaust systems. Operators can also install permanent
pressure gauges on local exhaust systems to allow identification of system performance changes.
Operators should practice regular maintenance procedures and promptly repair holes in air and exhaust
ducts upon detection. Operators should use exhaust ventilation through doors of washers and dryers.
The National Fire Protection Association (NFPA) guidelines recommend that drycleaning
machines have an integral exhaust system and a door face velocity of at least 100 feet per minute (NIOSH,
1997) This face velocity provides a draft of clean air over the items removed from the machine, thus
reducing solvent vapors escaping into the shop. Also, the Michigan Department of Public Health Rules
state that the blower must be ducted to a point 5 feet above the roof. This prevents vapors from re-entering
the work environment. Another option is to place a ventilation hood outside the machine door and
maintain an airflow capacity in cubic feet per minute, not less than 100 times the door opening area in
square feet (NIOSH, 1997).
Ventilation Systems
Proper design and maintenance of ventilation systems is also essential for controlling emissions.
Local ventilation involves removing the contaminant at or near the source to prevent emissions from
reaching the breathing zone or diffusing through the plants (NIOSH, 1997). Subsequently, general
ventilation involves diluting the concentration of the contaminant before it reaches the worker's breathing
zone Drycleaning systems should pull air from other areas into the drycleaning area to avoid solvent
dispersion into peripheral plant areas (i.e., operators should keep the drycleaning and pressing rooms under
negative pressure). Operators should design ventilation systems in temperate climate areas for winter
conditions when natural ventilation is at a minimum. Also, operators should adequately ventilate areas
where garments are hung after removal from the dryer. According to NFPA codes and Michigan
Department of Public Health Rules, there should be an air change in the workroom every 5 minutes to
decrease background PCE concentrations (NIOSH, 1997).
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Liquid Leakage and Vapor Control
To find liquid leakage, operators should look for the brown residue of PCE-soluble nonvolatile
compounds on the underside of fittings. This can be a sign of leakage in pipe fittings, welds, elastomers,
and plastic hose connections. Loose pipe connections are generally caused by wear, normal expansion and
contraction created by temperature, and vibration of equipment. Operators should check connections
unions, and couplings as soon as they start to leak. When required, operators should replace the packing
on the valves.
PCE loss from pipe fittings can be considerable. For example, PCE dripping at the rate of one drop
per second means that a gallon of PCE is lost in an 8-hour work day. Routine checkups with a portable
halogenated hydrocarbon leak detector around the pumps, seals, flanges, door openings, and other
components of the machine can detect vapor losses before they become leaks (CEPA, 1993).
The proper storage and use of chemicals can also prevent liquid leaks. Operators should properly
label all chemicals and should not store chemicals in extreme heat or cold, which may diminish the
chemicals' shelf-life or make them unusable (USEPA, 1997). New solvent, saturated lint from lint
baskets, dirty filters or filter powder, and recovered solvent from condensers, adsorbers, and water
separators should all be collected and stored in closed containers (NIOSH, 1997). Operators should
provide secondary containment around storage areas and should keep dip tanks for water repellent covered
even during the drainage of clothing (USEPA, 1997). Operators should drain filter cartridges in a closed
container or consider drying filters in housings vented to carbon adsorbers. Operators should not allow
hazardous materials to mix with non-hazardous materials, as this will result in all of the waste requiring
hazardous waste treatment. Finally, it is important to inspect all chemical and waste storage containers for
leaks.
Transfer Operations
To prevent PCE releases and exposure during transfer operations, the washer and dryer should be
near each other in PCE systems (NIOSH, 1997). HC transfer machines, however, should be separated to
reduce the fire hazard. Operators should transfer clothing from washer to dryer quickly after drainage and
close machine doors immediately after loading and unloading. Enclosed, automated transfer from washer
to dryer may be an additional prevention measure.
Exhibit 8-3, "Summary of PCENESHAP Compliance Requirements for Drycleaners " includes
requirements for certain transfer operations. In some cases, operators may implement these requirements
using room enclosures. Room enclosures without adequate ventilation may contain high PCE
concentrations. Therefore, operators must ensure that PCE concentrations in room enclosures do not
exceed regulatory limits such as the OSHA PELs. Operators should design room enclosures to avoid
increasing their workers' exposures to PCE.
Cooling Water or Drying Temperature
If the temperature of the cooling water or refrigerant is not kept low enough, the condenser coils
cannot cool the air stream enough, and less PCE condenses out of the stream. When the air is recycled to
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the dryer it cannot pick up as much PCE, and drying takes longer. One indication of this problem is if
cloths have a PCE odor after the end of the typical drying cycle. In summer months m warmer climates,
this can be a problem at drycleaning facilities using water-cooled condenser ™^™to™mg
towers The water-cooled condenser temperature should be no higher than 90 F (NIOSH 1997). borne
poSal solutions are to increase drying time, use a water chiller or use a city water supply. The exhaust
air stream from a refrigerated condenser must not be above 45 F (USEPA, 1994a).
Drying temperature is important for the same reasons as proper cooling temperature. If the
temperature isnot hot enough, clothes will not be dry when the cycle is completed. The operator sho,,d
maintain adequate steam pressure to keep the drying temperature between 135 F and 145 F for a regular
cycle and about 120°F for a fragile load (IFI, 1994; NIOSH, 1997).
Drying Time
The drying cycle should be long enough to ensure that garments are completely dry when they are
finished The operator should not open the machine door until the drying cycle is complete. In addition
he proper cycle length may vary according to the amount of air flow through the machine. To ensure the
maximum amount of air flow in the machine, operators should keep the steam and condenser coils and hnt
bags clean.
Loading of Machine
To ensure that clothes are completely dry and that machines recover the maximum amount of PCE,
it is recommended that machines be under-loaded by at least 5 pounds, but not by more than 25 /o of the
machine's capacity. Otherwise, the normal PCE losses that occur when running the machine will outweigh
the PCE savings gained by slight under-loading.
When feasible operators should clean clothes of similar types together. If mixtures of fabric types
are cleaned, some clothes removed from the machine may not be dry or may be damaged by excess drying
(USEPA, 1997).
Handling of Other Wastes
Waste reduction applies to all wastes generated, not just hazardous waste. Operators should try to
replace disposable items with reusable ones (USEPA, 1997). For example, operators should ask suppliers
to provide solvents in returnable containers. Operators should recycle materials such as plastics, glass
cardboard, and paper and should encourage customers to use reusable garment bags or to return unused
hangers (Department of Natural Resources and Environmental Control, 1998). Operators should maintain
a consistent waste reduction policy and should try to identify other possibilities. A successful waste
reduction program continually searches for additional ways to eliminate wastes.
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9.1.2 Impact of Facility Conditions and Remedial Actions on PCE Concentrations in Co-located
Residences
There is empirical evidence to demonstrate that remedial actions and proper maintenance can
lower PCE emissions in co-located residences. However, results of such studies vary because successful
remediation must encompass all PCE transmission pathways.
Overall facility conditions affect PCE concentrations in co-located residences in many ways
(BAAQMD, 1993; MHS, 1993; NYSDOH, 1993a, 1994), It is important for drycleaning owners and
operators to understand the prospective benefits of proper maintenance procedures, remedial actions, and
state-of-the-art equipment. USEPA has reviewed the available information and has drawn the following
conclusions: °
Buying a state-of-the-art machine will not eliminate PCE concentrations in co-located
residences, but it can reduce them, perhaps substantially (depending upon the condition of
the old machine).
• Vapor barriers and room enclosures are marginally effective in reducing PCE
concentrations in co-located residences, and their effectiveness increases when they
enclose both the drycleaning and pressing areas.
Proper machine maintenance is very important. For example, saturated carbon adsorbers
can elevate PCE concentrations,
Building condition is also important. Cracks and holes in the ceiling facilitate PCE
transmission.
Venting above the roof at a high velocity may substantially alleviate PCE concentrations.
Alleviation of the problem is not guaranteed even after substantial remedial efforts,
particularly if pathways of PCE transmission remain intact.
Remedial efforts must address the whole problem if they are to succeed. For example,
substantive machine modifications and the construction of vapor barriers will not
compensate for holes in the ceiling.
These conclusions are based on a review of several studies conducted in the U.S. and abroad. The
most informative of these studies was an in-depth look at remediation for two drycleaners in New York
City (NYSDOH, 1994). For one of these drycleaners (Facility 21), three sets of remedial actions were
inadequate to alleviate concentrations of PCE in a co-located residence. These remedial actions included
building a room enclosure and installing a vapor barrier. Indoor air sampling in a second floor apartment
showed a PCE concentration of 12.7 mg/m3 (NYSDOH, 1994).
The above-mentioned remediations to Facility 21 did not include repairing large holes in the
ceiling above the pressing area. These holes provided an ideal route of PCE transmission from the facility
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Chapter 9
on the ground floor to the apartments on the second floor (NYSDOH, 1994). This highlights the
taportance of addressing all PCE transmission pathways before undertaking remedial efforts^ Tobe
successful remediations in co-located facilities must include operator training, improved machine
SSS^Jmirs to the building, and blockage of other obvious routes of PCE transmission such as
Anting to a courtyard. Again, successful remediation requires more than upgrading machines and
building vapor barriers.
For the other drycleaner (Facility 41), a facility with apartments next door, remediation resulted in
improvements but did not eliminate PCE concentrations. As part of the remediation efforts, the owner of
™ePd Jcleaner facility built a room enclosure around the machines, installed a vapor barrier, ™Proved
venation, tried to reduce the available pathways of PCE transmission through the ta.ld.ng, and .mproved
"he PCE reclamation process. However, PCE concentrations ranged from ambient levels (0.026 mg/m ) to
nearly 5 mg/m3 after these remedial efforts (NYSDOH, 1994).
New York State officials have performed and supervised remedial efforts on a number of other
drvcleaners mainly to reduce PCE concentrations in the facility itself. The results show that reductions in
Pcfconcenins Sside the facility do not necessarily lead to the elimination of PCE concentrates m
the co-located residence (NYSDOH, 1993b).
In San Francisco, PCE concentrations were measured above facilities with state-of-the-art
equipment and controls. PCE concentrations measured by the Bay Area Air Quality Management District
(BAAQMD) above four non-vented dry-to-dry machines with refrigerated condensers ranged from 0 002
to 0 67 mg/ni3 These concentrations are lower than most of the reported samples taken in New York
mAAOMD 1993) The BAAQMD's recommendation is that a "combination of state-of-the-art
equipment good diffusion proofing (barriers/taping), and high ventilation rate (10,000 cubic feet per
minute) may be the optimal solution for preventing exposure of PCE to people residmg above drycleamng
facilities" (BAAQMD, 1993).
The effects of remediation have also been examined in Amsterdam, the Netherlands, as part of a
study of PCE concentrations in co-located residences. Here again, the results indicate that remed.al act.ons
do not necessarily remove the concern. PCE concentrations were relatively high after remedial actions
took place (MHS, 1993).
Machine type also affects PCE concentrations in co-located residences. A study of PCE
concentrations above three transfer machines, two well-functioning dry-to-dry machines, and one dry-to-
dry machine in poor condition was performed in Capital District, New York. The results showed that PCE
concentrations above the transfer machines were higher than concentrations above the two well-
functioning dry-to-dry machines. The maximum PCE concentration at the pressing stat.on was found to
correlate well with the measured concentrations in co-located residences. However, no correlation was
found with the residential concentrations and the type of ceiling and location of exhaust vents (NYSDOH,
1993a).
Other New York State data collected in response to residential complaints show that PCE
concentrations above non-vented dry-to-dry machines are significantly lower than concentrations above
vented dry-to-dry and transfer machines.
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9.2 MACHINE WETCLEANING FACILITIES
Information on best management practices and environmental and exposure control options for
this technology is very limited. Several of the following may be considered but should not supersede
available manufacturers' information:
Automated addition of water and chemicals to washing machines, particularly decreasing
the amount of human error due to spillage or addition of excessive detergent amounts.
Good housekeeping practices, such as keeping detergent storage containers tightly closed
to reduce chance of spillage.
Recycling/recovery of rinse water/steam condensate.
9.3 TRADE ASSOCIATION CONTACTS FOR FURTHER INFORMATION
This section provides a summary of the major clothes cleaning trade and research associations,
their contact numbers, and their initiatives and publications involving environmental improvement
practices. This listing does not constitute endorsement of these institutions, their initiatives, and
publications, nor is the listing intended to be a complete listing of sources that may have beneficial
information. Rather, this list is intended as a source of some information that may prove useful to
drycleaners and others interested in drycleaning issues.
Neighborhood Cleaners Association International (NCAI)
252 West 29th Street
New York, NY 10001 -5201
Tel: (212) 967-3002
NCAI initiatives and publications include a training manual and a publication entitled "Keep It
Clean: Guidelines To Reduce or Eliminate PCE Releases to Air, Soil, and Water." These offer useful
maintenance and operation guidelines. NCAI also offers a self-test on the Internet that covers such topics
as hazardous waste laws; laws on discharges to ground (soil), air, and water; Occupational Safety and
Health laws; general requirements; tanks; and the federal NESHAP.
9-17
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Chapter 9
Additional Environmental Improvement Approaches
Federation of Korean Drycleaners Association (FKDA)
25606 Alicia Parkway
Lagona Hills, CA 92653
Tel: (714)770-8613
FKDA provides educational opportunities through newsletters as well as educational seminars on
subjects such as pollution prevention and other critical issues. State FKDA chapters may provide
additional resources to their members.
International Fabricare Institute (IFI)
12251 Tech Road
Silver Spring, MD 20904
Tel: (301)622-1900
IFI initiatives and publications include a training manual that describes compliance issues,
pollution prevention practices, proper waste handling procedures, waste reduction methods and
occupational safety methods. IFI also implements the Certified Environmental Drycleaner (CED)
program which promotes the environmentally improved operation of drycleanmg establishments. To
become a CED, a drycleaner must pass a standard examination that tests drycleaners on various
environmental topics, including environmental regulations, proper waste handling occupational safety and
health, safe operation of drycleaning equipment, *nd other federal regulatory requirements. IFI also offers
a self-study drycleaning course that focuses on drycleaning and the environment. This course includes
USEPA regulations, OSHA regulations, recent federal regulations, state regulations, and operating
practices and procedures. IFI also published an article that focuses on maintenance guidelines and offers a
checklist for minimizing pollution:
International Fabricare Institute. 1993. Pollution prevention in the drycleaning industry.
Industry Focus. No. 5. November.
Hohenstein Institutes (Forschungsinstitut Hohenstein)
Boenningheim, Germany
Tel: 011-49-7143-2710
Fax: 011-49-7143-2717
The Hohenstein Institutes are an independent, internationally recognized research and service
center The Hohenstein Institutes have published research reports that focus on fugitive emission control
technologies, analytical measurements, and the effectiveness of diffusional barriers in 114 German
drycleaning plants. Relevant reports include:
1 Hohenstein Institutes. 1991. The feasibility of lowering solvent vapor load in the vicinity of
drycleaning machines. Research sponsored by the German Environmental Protection Agency.
September.
9-18
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Chapter 9
Additional Environmental Improvement Approaches
2.
Hohenstein Institutes. 1994. Reduction of solvent vapor concentration in the vicinity of
drycleaning plants. Research sponsored by the six German State Agencies. November.
Additional information can be retrieved from the Hohenstein Institutes' Web site at
.
9-19
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Chapter 9
Additional Environmental Improvement Approaches
REFERENCES
BAAQMD 1993. Bay Area Air Quality Management District. An Investigative Survey of
Perchloroethylene in Residential Areas Above Dry Cleaners in San Francisco. June.
CEPA 1993 California Environmental Protection Agency, Air Resources Board. Technical Support
' Document for Proposed Airborne Toxic Control Measure and Proposed Environmental Training
Program for Perchloroethylene Dry Cleaning Operations. August.
Department of National Resources and Environmental Control. 1998. A Pollution Prevention Guide for
Dry Cleaners. Downloaded from the Environmental Protection Agency's EnviroSense Web site.
March.
IFI. 1992. International Fabricare Institute. Industry Focus. Vol. 16, No. 3. July.
IFI. 1994. International Fabricare Institute. Drycleaning Fundamentals: A Self Study Course. October.
MHS. 1993. Municipal Health Service. Exposure to perchloroethylene in homes nearby drycleaners
using closed systems and the effect of remedial actions. Proceedings of Indoor Air '93, Vol. 2.
Amsterdam, the Netherlands.
NIOSH 1997. National Institute for Occupational Safety and Health. Control of Health and Safety
'Hazards in Commercial Dry Cleaners—Chemical Exposures, Fire Hazards, and Ergonomic Risk
Factors. U.S. Dept. of Health, Education, and Welfare, Public Health Service, Centers for Disease
Control, NIOSH. Washington, DC. December 1997.
NYSDOH. 1993a. New York State Department of Health. An investigation of indoor air contamination
in residences above dry cleaners. Risk Analysis, Vol. 13, No. 3.
NYSDOH. 1993b. New York State Department of Health. Survey of dry cleaning facilities in Capital
District, New York and New York City. Previously unpublished.
NYSDOH. 1994. New York State Department of Health. Investigation of tetrachloroethylene in the
vicinity of two dry cleaners: An assessment of remedial measures. Draft report. (The names of
the facilities have been removed from this version of the report.)
USEPA. 1994a. U.S. Environmental Protection Agency. New Regulation Controlling Emissions from
Dry Cleaners. EPA 453/F-94-025. Office of Air Quality Planning and Standards.
USEPA. 1994b. U.S. Environmental Protection Agency. Perchloroethylene Dry Cleaning
Facilities—General Recommended Operating and Maintenance Practices for Dry Cleaning
Equipment. EPA4531R-94-073. Office of Air Quality Planning and Standards. October.
USEPA. 1997. U.S. Environmental Protection Agency. Cleaner Technologies Substitute Assessment
Peer Review Comments.
9-20
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CHAPTER CONTENTS
Summary of Trade-off Factors
Approaches for Considering Trade-offs
CHAPTER 10
TRADE-OFF ISSUES
The Cleaner Technologies Substitutes
Assessment's goal is to offer as comprehensive
a picture as possible of the relevant factors
associated with each of the available clothes
cleaning alternatives—the possible
environmental and health risks, the costs of
mitigating these risks, operating costs, and the
level of cleaning performance associated with each alternative. With this information, fabricare
professionals can make more informed decisions regarding pollution prevention and the possible
advantages and disadvantages associated with alternative approaches for reducing exposures to chemicals
used in fabricare processes.
This chapter summarizes much of the information presented throughout the CTSA. Section 10 1
presents a summary of the factors influencing choices in cleaning technology or the type of equipment used
within a cleaning technology category. The factors associated with each cleaning process include the
following: (1) potential risks, (2) costs, (3) performance characteristics, and (4) other characteristics.
Section 10.2 introduces a benefit/cost analysis as a method of assessing alternative options This section
reformulates the summary discussion in Section 10.1 by demonstrating how the factors discussed there can
be assessed using a benefit/cost approach. Section 10.2 also presents an assessment of the costs and
benefits of alternative cleaning options using a cost-effectiveness approach.
10.1 SUMMARY OF TRADE-OFF FACTORS
In order to implement pollution prevention and possibly reduce exposures and/or risks from the
chemicals used in clothes cleaning, clothes cleaners may consider either controlling releases of chemicals
from their current technology or switching to an alternative technology. Such decisions involve numerous
trade-offs among costs, performance, health and environmental risks related to a particular process, and
other factors. These trade-offs are summarized in the following sections.
10.1.1 Potential Health and Environmental Risks
This section summarizes the available information about the potential health-, environmental and
other risks associated with the cleaning alternatives discussed in this document. It is important to
acknowledge that several components are relevant to an understanding of the risks associated with the
chemicals and/or processes used in clothes cleaning. These components are the hazards or effects that may
be caused by chemicals and/or processes, and the exposure to those chemicals and/or processes.
Previous chapters of the CTSA on hazard, exposure, and risk describes the risk considerations
associated with the covered technologies. It is clear that there is a disparity in the amount of risk-related
information available on the various chemicals and processes. In addition, circumstances affecting hazards
(e.g., actual detergent formulations) and exposure (e.g., machine type and operating procedures) will vary
for specific operations, thus affecting actual risks. Therefore, the consideration of risk factors is best
presented by highlighting the most relevant hazard and exposure components. Those populations that are
" HM '
-------
Trade-Off Issues
Chapter 10
most likely to be highly exposed, and therefore more likely to experience effects of the chemicals and
p^oce ses are identified associations of concern. It is these populations for which exposure red ctlon ,s
expected o be most relevant. The information on risk considerations should be reviewed with the
appropriate regard to the surrounding uncertainties. It is important to understand that a lack of information
does not necessarily mean that a chemical with limited information is better or worse than another.
Exhibit 10-1 summarizes the risk considerations for the clothes cleaning technologies covered in
the CTSA These considerations were primarily identified as those resulting in potential health and
environmental risks, given the scenarios and assumptions of the hazard, exposure, and risk
cnl acteTizations in earlier chapters. Therefore, it is likely that not every identified effect assorted with a
chemical or process is included. Additionally, the reader should understand that these considerat.ons may
be less important or may be heightened by the specific characteristics of individual operations.
The risk assessments for the CTSA were conducted at a "screening level" of review, using readily
available information and standard analyses for completion. The risk assessments and characterizations
should give a rough idea of the array of potential risks to human health and the environment associated
with each of the cleaning processes, and should offer a basis for comparison. However, careful
interpretation is necessary, given that the extent of uncertainties associated with the type of hazard and
exposure data, and the uncertainties associated with each process, differ widely. It is important to
recognize that tabular displays, while convenient for organizing information, cannot extract all the details
that may be important for each individual's decision.
Drycleaning - PCE
There is a reasonable basis to conclude that there can be a health risk of cancer and some non-
cancer effects to workers from the relatively high perchloroethylene (PCE) exposures observed on average
in the drycleaning industry. Cancer concerns also extend to residents living in co-location with
drycleaning establishments, particularly if they live in such dwellings for several years The risk indices
calculated for this CTSA generally show upper bound excess cancer risks to be high As expected, cancer
risks appear to be higher for residents living above transfer machines due to higher levels of exposure
(higher levels of solvent release), although poorly maintained dry-to-dry machines have been documented
to potentially cause high exposures.
There can also be a risk of non-cancer effects from PCE to co-located residents. Adults in
residences above non-vented dry-to-dry machines appear to have lower exposures. Children, infants and
the elderly who spend most of their days within the residence, may be at slightly greater risk for both
cancer and non-cancer effects due to increased exposure duration. Co-located residents are additionally at
risk through a variety of PCE exposures experienced by the general public. Risks experienced by the
general population, such as drinking or showering with PCE-contaminated water, would be added to the
risks due to co-location.
Given the release estimates developed in the CTSA, it does not appear that there is concern for risk
to aquatic species from the majority of drycleaners who send their wastewater effluents to a publicly owned
treatment works (POTW).
10-2
-------
Chapter 10
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Chapter 10
Trade-Off Issues
Drycleaning - HC
A major hazard identified for the HC solvents considered in the CTSA is their potential
flammability. The National Fire Protection Association (NFPA) gives them a grading of "2" for
flammability, indicating that the HC solvents must be moderately heated or exposed to relatively high
ambient temperatures before ignition can occur. For comparison, perchloroethylene receives a grade of
"0" for flammability, which indicates that it will not burn. Data are not available to evaluate the risks of
fire in drycleaning facilities due to use of these HC solvents. However, the risk of fire from their use can
be considered greater than the risk of fire due to PCE-based solvents, based on the NFPA's low
flammability ranking for PCE. In addition, the varying flashpoints of the three HC solvents examined
suggest that the fire potential is lessened as one employs a higher flashpoint HC solvent. Of the HC
chemicals examined in the CTSA, DF-2000 generally has the highest flashpoint, followed by 140°F
solvent, and Stoddard solvent.
The health risk conclusions for the HC solvents in the CTSA are based on findings for Stoddard
solvent; however, there are no data suitable for drawing conclusions concerning carcinogenic potential.
Worker exposures to HC solvents, especially the high-end exposures, are indicative of a concern for non-
cancer risk for workers. No data were available on exposures of co-located residents, and therefore, no
risk estimates were made. Based on expected releases, there is a low risk of toxicity to aquatic species
from the HC solvents.
Machine Wetcleaning
There may be a risk to aquatic organisms from some of the constituents of the machine
wetcleaning formulations, dependent on the local stream flow and water treatment conditions. There is
no expected health risk to the general public based on low expected exposures to detergents; however,
there could be a possible risk to workers of eye and skin irritation from wet process formulations, based
upon findings associated with the example detergents.
10.1.2 Federal Regulatory Environment
Professional clothes cleaners are subject to the requirements of many federal air, water, waste
management, and occupational health and safety regulations, including the Clean Air Act (CAA); the
Clean Water Act (CWA); the Safe Drinking Water Act - Underground Injection Control Regulations
(SDWA-UIC); the Resource Conservation and Recovery Act (RCRA); the Comprehensive
Environmental Response, Compensation and Liability Act (CERCLA); the Occupational Safety and
Health Act (OSH); and the Federal Trade Commission's Care Labeling Rule. In addition, cities and
municipalities have enacted numerous zoning restrictions that may affect all types of fabricare
operations. Many localities have adopted some, or all, of the National Fire Protection Association's
standards for drycleaning equipment and operations (NFPA-32). These regulations and requirements can
affect the choice of cleaning technology by restricting the use of or adding requirements to the use of
certain processes. These restrictions and requirements have the potential to affect costs and liabilities.
Exhibit 10-2 summarizes some federal regulations that relate to fabricare technologies covered in
the CTSA. State and other requirements are not included; however, they may have a significant effect on
technology choice. Requirements that pertain to the use of spotting chemicals are not covered, but they
should not be overlooked because they may affect regulatory compliance activities for fabricare
operations.
10-5
-------
Ch
10
Trade-Off Issues
PCE and HC cleaning are most affected by provisions of federal regulations. Machine
wetcleaning currently has fewer requirements that are directly applicable. It is unclear how requirements
may change as industry use of these technologies changes. The Care Labeling Rule relates to all
cleaning methods, although it does not contain specific requirements for cleaning garments. The rule
requires manufacturers to label garments identifying acceptable cleaning methods. Garments that are
cleaned in a manner other than that specified by the manufacturer and are subsequently damaged are the
responsibility of the cleaner. Manufacturers may cautiously label garments as "dryclean only (Wentz,
1996; Riggs, 1998). In effect, this may constrain the cleaner interested in avoiding liability from
utilizing wetcleaning processes.
Exhibit 10-2. Summary of Federal Regulations Applicable to Fabricate Technologies8
Fabricare
Option
PCE
cleaning
HC cleaning
Machine
wetcleaning
CAA
/
/
NA
CWA
/
/
/
RCRA
/
/
NA
CERCLA
/
/
NA
OSH
/
/
NA
Care Labeling
Rule
/
/
/
Other
NFPA 32
NFPA 32
NA
-'^nScSes tLuFthouaM , . ^ . ,«,
, ind.cates mat annougn me si ^ ^ vgy^ ^^ ^ ^ considered exhaustive and may not cover all regulated aspects of the
fabricare industry.
10.1.3 Costs
The costs of running a professional clothes cleaning business include rent, basic operating
expenses, and equipment. The equipment capacity, equipment type, and location of the facility will also
affect the costs and economic viability of a professional cleaning operation. This document has focused
on a subset of the costs associated with operating clothes cleaning facilities and a subset of the possible
technologies, for which information is available.
The cost components of each of the cleaning options summarized in the CTSA include capital
(equipment) cost and the annualized cost of that equipment. In addition, estimates of total annual
operating cost, total annual cost (the sum of total annual operating cost and annualized capital cost), and
total annual cost per pound of clothes cleaned are provided. Exhibit 10-3 summarizes the process-
dependent cost components estimated for selected cleaning technologies covered in the CTSA. Cost
figures are presented in constant 1997 dollars in order to allow direct comparisons among the process
options. More detailed cost estimates and explanations of how estimates were derived are given in
Chapter 7.
In order to reduce exposure to chemicals used or to prevent pollution, cleaners may consider
either controlling emissions from the technology they currently use or switching to a different
technology. For this reason, the CTSA assesses the costs of PCE and HC process modifications that can
reduce exposure. This is intended to provide examples for reducing solvent exposure without changing
technologies for cleaners who are unable to change their entire process.
10-6
-------
Chapter \0
Trade-off Issues
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Chapter 10
Trade-Off Issues
The CTSA considers the estimated process-dependent costs of eight PCE machine configurations
and three hydrocarbon machine configurations. These alternatives are developed to provide information
useful in making comparisons of the relative costs of the alternatives within a single technology (e.g..
PCE) Some alternatives are no longer available (e.g., new PCE transfer machines); however, they are still
provided so that individual cleaners using these configurations can compare the costs of changing to
another configuration. Exhibit 10-4 presents a summary of estimated process-dependent costs for the PCb
machine configurations; Exhibit 10-5 presents a summary of estimated process-dependent costs for the HL
machine configurations.
10.1.4 Performance Characteristics
The basic performance goals of all professional clothes cleaning technologies are the same. Any
cleaning technology applied to a textile should strive to (1) optimize soil removal by overcoming the
physical and chemical forces that bind soils to the textile; (2) transport soils away from the textile through
the cleaning medium; (3) preserve and/or restore the original attributes of the textile, including its
dimensions, dye character, and overall fabric finish: and (4) be cost-effective to the cleaner. Chapter 6
summarizes the performance tests that have been conducted on alternative cleaning technologies. For
several reasons (discussed below), however, it is difficult to rank alternative technologies on cleaning
performance, and there is no single industry measure that could be used for such a ranking.
Several factors may affect the performance of a cleaning process, including soil chemistry, textile
fiber type, transport medium (aqueous vs. non-aqueous), chemistry of additives (detergents, surfactants),
use of spotting agents, and process controls (time, temperature, and mechanical actions). These factors
work interactively to provide a range of cleaning abilities for all clothes cleaning processes. In addition,
customer perceptions of a "clean" garment will vary due to regional, socioeconomic, and cultural
differences. Finally, variations in technology and the knowledge base of operators may also affect the
performance of the clothes cleaning process.
Although there is insufficient information to characterize the cleaning performance of each of the
cleaning technologies considered in this document some general comparisons are possible between
drycleaning (solvent-based) cleaning processes and wetcleaning (water-based) processes. Drycleanmg
processes are more effective at dissolving oils and fatty stains (non-polar soils), while wetcleaning
processes tend to dissolve sugar, salt, and perspiration (polar stains) with greater success. It is unclear
whether paniculate soils are better handled by one process type or the other. The cleaning ability of both
wet and drycleaning processes may be enhanced with the use of spotting agents, alternative detergents,
surfactant additives, and other process modifications (e.g., time, temperature, mechanical action).
These two types of cleaning processes also excel at cleaning different kinds of materials.
Drycleaning processes are most effectively used with textiles that contain water-loving (hydrophilic) fibers
(such as wool), low-twist yarns, low-count fabrics, and polar colorants. Wetcleaning processes are
effective with textiles containing water-hating (hydrophobic) fibers (such as polyester and nylon), high-
twist yarns, high-count fabrics, and non-polar colorants.
10-8
-------
Chapter 10
Trade-off Issues
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Chapter 10
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-------
Chapter 10
Trade-Off Issues
The preservation of the original attributes of the textile (the third performance goal) may itself
depend on the combination of cleaning process and type of textile being cleaned. Wetcleaning methods
tend to cause expansion of natural and cellulose fibers, leading to a loss of strength, wrinkling, color-Ioss,
and dimensional change (i.e., shrinkage or stretching). However, textile manufacturers have developed a
number of fiber treatments and modifications (resin preparation, shrink prevention preparation, wool teIt
prevention) that may minimize such cleaning impacts on clothing. Such alterations are not necessarily
apparent when synthetic fibers are subjected to similar water-based cleaning methods. Drycleanmg
methods, however, may not be appropriate for synthetic fibers due to potential for fiber deterioration.
Because different cleaning processes are more effective with certain types of materials and/or
certain types of soils, and because the effectiveness of all cleaning processes may be enhanced by certain
process modifications, it is difficult to draw any general conclusions concerning the relative performance
of the cleaning technologies considered in this document.
10.1.5 Other Factors
There are several other factors that may affect a clothes cleaner's decision in selecting alternative
technologies These may include consumer issues beyond performance, such as odor in clothing, liability
concerns, and the current state and availability of alternatives. These factors can affect the costs faced by
the cleaner, customer satisfaction, or ability to select alternatives.
Clothing cleaned with PCE and some HC solvents can have characteristic odors, although the
odors are generally expected to be less for HC. The manufacturer of DF-2000 claims that the solvent is
odorless (Exxon 1998). Odor is not a consideration for machine wetcleaning. This factor may affect
consumer satisfaction with cleaning technologies and may affect a clothes cleaner's selection of cleaning
solvents.
CERCLA addresses the cleanup of sites contaminated with improperly disposed chemical wastes.
Under CERCLA potentially responsible parties that contribute to chemical contamination of a particular
site regardless of the intent or involvement of that party, are held strictly liable. Many sites with past and
present PCE drycleaning operations are already contaminated to levels that will limit future uses of the
property. Groundwater contamination is also possible. These liability considerations may affect decisions
regarding technology choices.
Other liability concerns could result from worker claims for health effects resulting from chemicals
used in clothes cleaning processes or from garment damage resulting from the various cleaning processes.
Of particular note is potential liability for garments damaged in wetcleaning processes that are labeled
"dryclean only."
PCE and HC technologies are well established; PCE currently dominates the market. Wetcleaning
has been available in the U.S. since 1994 and is not as well known as the drycleaning technologies.
10.1.6 Summary of Trade-Off Considerations
Each of the factors summarized above may affect the technology choices made by clothes cleaners.
Cleaners must consider the costs of running an operation, the service they can provide to consumers, and at
10-12
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Chapter 10
Trade-Off Issues
what cost. Choices may also be limited by regulatory requirements and levels of necessary capital
investment. The potential effects of technology choice on the health and well-being of the environment
and individuals exposed to the chemicals used in the cleaning process are also important factors. The
choice of cleaning technology involves a complex array of decision factors. Those identified and
summarized in the CTSA are organized and presented in Exhibit 10-6.
10.2 APPROACHES FOR CONSIDERING TRADE-OFFS
Given the number of trade-off considerations identified in the CTSA and summarized in Exhibit
10-6, choosing a technology that best suits the needs of a clothes cleaner, while balancing cost and
performance considerations, along with trying to meet the goals of solvent reduction, pollution prevention,
and profit, can be daunting. This section of the CTSA presents approaches that can be used to structure
these considerations and assist the business decision maker.
10.2.1 Benefit/Cost Analysis
Social benefit/cost analysis is used by decision makers to systematically evaluate the impacts to
society resulting from individual decisions. A social benefit/cost analysis seeks to compare all the benefits
and all the costs of a given action, considering both private and external costs and benefits. Private costs
include those affecting the cleaner, and are typically reflected in the firm's balance sheet. In contrast,
external costs' are those resulting from the business decision and that are imposed on people (or the
environment) who are not a party to the decision. Exhibit 10-7 defines a set of terms typically used in
benefit/cost analysis.
Benefit/cost criteria could be used by individual cleaners to evaluate their choice of clothes
cleaning technologies. A cleaner might ask what effect the choice of a cleaning technology or machine
configuration will have on operating costs, compliance costs, liability costs, and insurance premiums
(private costs), as well as on cleaning performance and attractiveness to customers (private benefits). It is
less likely, however, that the cleaner would be as familiar with the social costs and benefits of decision
making. Costs such as the health and environmental risks discussed in the CTSA may not add to the cost
of producing clothes cleaning services (other than, perhaps, an increased liability or insurance costs);
however, they represent real costs to society.
Therefore, to develop a social benefit/cost analysis of a choice among fabricare processes, the
cleaner would consider not only private costs, such as operating costs and regulatory costs, of the different
technologies, but also the external costs, such as environmental and health effects associated with cleaning
services. The considerations summarized in the earlier parts of this chapter (and assessed throughout the
CTSA) are the key components of a social benefit/cost analysis. They are presented together in Exhibit
10-8 and are organized as private costs and benefits and known external costs.
A common example of external costs is provided by the electric utility whose emissions are reducing crop yields for the
farmer operating downwind. The external costs incurred by the farmer in the form of reduced crop yields are not considered by the
utility when deciding how much electricity to produce. The farmer's losses do not appear on the utility's balance sheet.
10-13
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Chapter 10
Trade-Off Issues
Exhibit 10-6. An Overview of Alternative Cleaning Technologies' Trade-Off Factors3
Characteristic
Health and
Environmental
Risks
PCE
Health: Risk of cancer to
workers, co-located residents.
Risks of non-cancer effects,
including potential for
developmental and reproductive
effects for workers. May be
cancer and non-cancer risks to
co-located children.
Environmental: Potential risk to
aquatic organisms for effluent
not treated by a POTW
HC
Health: Risk of neurotoxic
effects and skin and eye irritation
for workers.
Fire: Highest for Stoddard
solvent, less for 140°F and DF-
2000, based on flashpoint.
Environmental: Potential to
contribute to smog and global
warming.
Machine Wetcleaning
Health: Risk not evaluated
quantitatively. Potential risks of
skin and eye irritation for
workers. Environmental:
Potential risk to aquatic
organisms from specific
detergent component releases.
Costs'1
Potential liability
costs
Capital costs'
Hazardous waste
disposal"
Groundwater contamination and
worker illness.
$38,511
$4,594
Fire damage.
$37,432
$9,820
Damaged clothing labeled
"Dryclean Only."
$11.102
NA
Annual operating
costs'
$14,077
$19,607
Total annual
$18,305
$23,717
$5,089
$6,308
Market Considerations
State of
technology
Dominant in market.
Well-established in market; use
of some HCs may be limited by
local fire codes.
Commercial use since 1994 in
U.S.; numerous detergent
suppliers. _____
Odor
Yes
Yes, maybe less for particular
HCs .
No
Cleaning
Performance
Wide range of clothes.
Wide range of clothes.
Wide range of clothes.
NA means cost category not applicable for technology or that data are not available at this time.
heese^ services directly related to the various fabricare deaning processes b ut Delude
costs for pressing, storefront operations, and rent. All values are in 1997 dollars and all calculations assume a 53,333 pound
ffi yS«S^g^^ control equipment, distillation unit, and filters; list price of 35- to 40-
pound HC drycleaning system includes control equipment, filters, and an explosion kit.
"Hazardous waste disposal costs for PCE and HC based on $6.94-per-gallon disposal cost (Beedle, 1998) and volume
calculattons from EPA engineering estimates; HC solvent waste may not be considered hazardous waste unde r he Rwouroe
Conservation and Recovery Act. Therefore, this is a high-end estimate. Hazardous waste costs associated with spotting
and maintenance costs. The cost of labor, another component of
annual operating costs, is omitted due to lack of data.
1 Includes all operating costs and annual capital costs.
10-14
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Chapter 10
Trade-Off Issues
Exhibit 10-7. Glossary of Benefit/Cost Analysis Terms
Term
Definition
Exposed Population
The number of people in the general public or a specific population
group exposed to a substance through dispersion of that substance in
the environment. A specific population group could be exposed
because of its physical proximity to a manufacturing facility that uses
or produces the substance (e.g., residents who live near a facility
using a chemical), because it uses the substance or a product
containing the substance, or through other means.
Exposed Worker Population
The number of employees in an industry exposed to the chemical,
process, and/or technology under consideration. This number may be
estimated by market share data, as well as by estimates of the number
of facilities and the number of employees in each facility associated
with the chemical, process, and/or technology under consideration.
Externality
"The effects of production and consumption activities not directly
reflected in the market" (Pindyck and Rubinfeld, 1989)~i.e., not
affecting market prices. For example, a cost or benefit experienced by
a third party not a part of a market transaction; or an adverse health
effect experienced by a consumer unaware of the adverse effects
associated with the product he is using or consuming. The term
"externality" is a general term which can refer to either external
benefits or external costs.
External Benefits
Benefits of production and consumption of private goods not directly
reflected in the market; i.e., not affecting market prices. For example,
the market price of landscaping materials does not reflect the benefits
enjoyed by the neighbors of homeowners who improve the aesthetic
view by landscaping.
External Costs
Costs of production and consumption of private goods not directly
reflected in the market—i.e., not affecting market prices. For example,
if a steel mill emits waste into a river and the waste poisons the fish in
a nearby fishery, the fishery experiences an external cost as a
consequence of the steel production. Another example is an adverse
health effect experienced by a consumer who is unaware of the
adverse effects associated with the product he is using or consuming.
Human Health Benefits
Reduced health risks to workers in an industry or business and/or to
the general public; such benefits may, for example, result from an
industry switching to less toxic or less hazardous chemicals,
processes, and/or technologies. An example would be switching to a
less volatile organic compound, thereby lessening worker inhalation
exposures.
10-15
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Chapter 10
Trade-Off Issues
Exhibit 10-7. Glossary of Benefit/Cost Analysis Terms (Cont'd)
Term
Definition
Human Health Costs
ncreased health risks to workers in an industry or business and/or to
the general public; such costs may, for example, result from the
jroduction, consumption, and disposal of a firm's product. An
example is respiratory effects from stack emissions. These costs can
be quantified by analyzing the resulting costs of health care and the
reduction in life expectancy, as well as the lost wages as a result of
oeing unable to work.
Cost of Illness
The total cost of an illness to society, including (1) total medical costs
and (2) the cost of lost productivity resulting from the illness.
Private (Internalized) Costs
The direct costs incurred by industry or consumers in the marketplace.
Examples include a firm's cost of raw materials and labor, and a firm's
costs of complying with environmental regulations. The private costs
associated with a good or service are reflected in market prices.
Social Cost
The total cost to society of an activity. Social costs are the sum of
private costs and external costs. In the example of a steel mill that
emits waste into a river and the waste poisons fish in a nearby fishery,
the social cost of steel production is the sum of all private costs (e.g.,
raw material and labor costs) and all external costs (e.g., the costs
associated with the poisoned fish).
Social Benefit
The total benefit to society of an activity; i.e., the sum of the private
benefits and the external benefits associated with that activity. For
example, if a new product yields pollution prevention opportunities
(e g., reduced waste in production or consumption of the product),
then'the total benefit to society of the new product is the sum of the
private benefit (value of the product that is reflected in the
marketplace) and the external benefit (benefit society receives from
reduced waste). __
Willingness-to-pay
Willingness-to-pay (WTP) is the measure used for the value an
individual places on something, whether it can be purchased in a
market or not. If available, estimates of WTP are used in benefits
valuation because they encompass the full value of avoiding an
adverse health (or environmental) effect, including, for example, the
value of avoiding the pain and suffering associated with the health
effect. The total cost of an individual's illness, then, is the cost of
illness as defined above, plus the individual's WTP to avoid the pain
and suffering associated with the illness.
10-16
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Chapter 10
Trade-off Issues
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10-17
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Chapter 10
Trade-Off Issues
Because of limited information, the private costs and benefits and external costs associated with
the various alternative cleaning options are, for the most part, presented qualitatively. They are intended to
give only a broad overview of what may be the important benefits and costs of each of these different
options. In actual practice, a business decision maker would evaluate the specifics of the operation under
consideration (e.g., particular concerns associated with a machine wetcleaning detergent) and attempt to
assign monetary value to the trade-off factors to determine the best choice of cleaning processes.
Where quantitative measures are presented, such as in the area of cost, they are most reflective of
the comparison of alternatives relative to each other, rather than a measure of actual value. This is because
of the assumptions and uncertainties found when developing general characterizations of the technologies,
as done in the CTSA. The effect of such a presentation is to show how the social benefit/cost framework
can support the decision-making process, and highlight significant factors and considerations for each
technology choice. By understanding which factors are significant, and how they are interpreted as costs
and benefits, the individual cleaner could use such information as a starting point for developing
technology comparisons for a specific operation.
Comparisons of the costs and benefits associated with different process options within the PCE-
based drycleaning category and within the petroleum solvent-based drycleaning category are presented
later in this section using an alternative decision-making process.
10.2.2 Cost-Effectiveness Analysis
Given the investment required to switch among technologies, it is also useful to examine the trade-
offs faced when attempting to reduce exposure to solvents. Therefore, more detailed comparisons of the
costs and benefits associated with different release reduction options are presented. It is recognized that
solvent release is not necessarily the best measure of exposures and/or risk, particularly for populations
such as co-located residents and the general population. However, the uncertainties involved in assessing
exposures and risks associated with specific machine configurations preclude the quantitative estimation of
risk trade-offs among those configurations.
As an alternative, the cost-effectiveness of the different options (alternative machine
configurations) may be used as a means of comparison. Cost-effectiveness is a measure of the efficiency
of an option in achieving a desired goal. In this analysis, the desired goal is the reduction of PCE or HC
solvent emissions as a surrogate for reducing exposures to solvents and, therefore, the risks associated with
those exposures.
10.2.3 Comparison of Alternative PCE-Based Machine Configurations
PCE is the dominant drycleaning solvent used by industry today. It is used in approximately 82%
of all commercial drycleaning facilities. Although there are identified health and environmental concerns
with PCE, cleaners currently using PCE may not be inclined to change cleaning technologies for a variety
of reasons. They might, however, be willing to make changes to their current PCE technologies that may
serve to prevent pollution by reducing releases, thereby potentially reducing exposures. Various
modifications of the basic technology are expected to achieve different degrees of reduction in the release
of PCE. The CTSA recognizes that release reduction may not be the best surrogate for exposure reduction.
However, release reduction is used as a proxy for exposure reduction for illustrative purposes. The costs
10-18
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Chapter 10
Trade-Off Issues
associated with these variants on the basic PCE-based drycleaning technology are also expected to differ
across technologies. This subsection presents a comparison of some of the costs and benefits of eight
different variants on the basic PCE-based drycleaning technology.
Exhibit 10-9 summarizes the solvent releases, performance characteristics, and cost characteristics,
including capital and operating costs, of several PGE drycleaning machine configurations, and presents
qualitative information on potential health and ecological risks using the solvent release volume as an
indicator for exposure and risk. The estimated solvent use per year and a relative ranking of solvent
mileage is provided for each of the eight PCE drycleaning machine configurations. Estimated solvent
releases are also detailed along with information regarding maintenance, capital, operating, and total
annual costs. Other issues, such as garment cleanliness and damage, may be considered performance
issues in the drycleaning industry, but are not evaluated and are not expected to vary significantly across
machine configurations.
Based on the model facility2 (see Chapters 4 and 7), the PCE closed-loop dry-to-dry machine with
unvented integral secondary controls (Option PCE-D) uses the least solvent and has the lowest emissions
of the PCE options considered. Solvent usage can be measured in terms of mileage, the number of pounds
of clothes cleaned per volume of unrecovered solvent. Exhibit 10-9 ranks mileage, with one being the best
and eight the worst. Option PCE-D has the best solvent mileage and Option PCE-A1, a transfer machine
with no vent control, has the worst. Therefore, replacing a PCE transfer machine with Option PCE-D, a
PCE dry-to-dry closed-loop machine with integrated unvented secondary controls, decreases both PCE use
and releases to air by 449 gallons per year while increasing the total wastewater and total hazardous waste
volumes (the latter only slightly).
Along with all other dry-to-dry options, Option PCE-D is expected to result in less exposure to
PCE to the extent that releases are indicative of exposure. This implies that risks to human health are
probably lessened with dry-to-dry technologies when compared with the uncontrolled transfer machine
option (PCE-A1). Option PCE-D is also expected to result in lower risks to aquatic life relative to those
posed by Option PCE-A1. Overall costs do increase somewhat in going from Option PCE-A1 ($18,923)
to PCE-D ($19,122). A more important comparison of costs is the difference between PCE-B1 ($19,879)
and PCE-D ($19,122). The slight cost difference indicates a financially positive incentive for fabricare
The model facility processes 53,333 pounds of clothes per year and operates six days a week for 52 weeks a year.
10-19
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Chapter 10
Trade-off Issues
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10-20
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Trade-off Issues
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Chapter 10
Trade-Off Issues
professionals to use the maximum available control technology when converting transfer equipment. More
detailed information on the risks of the options and the types of costs associated with each is described in
Chapters 5 and 7.
Since benefit/cost analysis is not entirely possible in the CTSA because of the lack of quantified
benefits, cost effectiveness can be used as an approach for comparing the eight PCE options. The cost-
effectiveness of an option is a measure of its efficiency in achieving a desired goal. In this analysis, the
options are the 8 PCE machine configurations, and the desired goal is the reduction of PCE emissions as a
surrogate for reducing exposures to solvents and, quite likely, the risks associated with those exposures.
Exhibit 10-10 compares the cost effectiveness of the three PCE transfer machine options in
controlling PCE releases. Compared to the baseline technology option, a transfer machine with no vent
control (PCE-A1), the transfer control options (PCE-A2 and PCE-A3) both have lower total annual costs,
as well as lower solvent releases per year. Each of these alternatives therefore results in a cost-savings per
gallon of solvent emissions controlled. Therefore, instead of the cost per gallon of emissions reduced, the
number of gallons of emissions reduced per dollar saved is used as the measure of cost effectiveness.
Each bar in Exhibit 10-10 represents the gallons of solvent emissions reduced per dollar saved when a
technology option is compared with the baseline option (PCE-A1). For example, there is a 0.45 gallon
reduction in PCE emissions for every dollar saved by switching from a transfer machine with no vent
control (PCE-A1) to one with carbon adsorber vent control (Option PCE-A3). This figure is derived by
taking the difference in the total annual number of gallons of solvent released, 210, and dividing by the
savings in total annual cost resulting from moving from Option PCE-A1 to Option PCE-A3, $466.
Compared to a baseline transfer machine with no vent control (Option PCE-A1), all additional transfer
control options have less initial capital cost. These options reduce solvent usage on an annual basis, as
well as having a lower initial capital cost for retrofitting existing transfer equipment. It is also clear from
Exhibit 10-10 that retrofitting a transfer machine with a carbon adsorber (PCE-A2) is the most cost-
effective option, using the above definition of cost-effectiveness, within this PCE technology category.
Similarly, Exhibit 10-11 compares the cost-effectiveness of the five PCE dry-to-dry machine
options in controlling PCE releases. As with the comparison of transfer options, the alternative dry-to-dry
options (PCE-B2, PCE-B3, PCE-C, and PCE-D) all have both lower total annual cost and lower solvent
releases (in gallons/year) than the baseline technology option (dry-to-dry with no control, option PCE-B1)
with which they are being compared. Each bar in Exhibit 10-11 represents the gallons of solvent
emissions reduced per dollar saved when a technology option is compared with the baseline emissions
from a dry-to-dry machine with no carbon adsorber or refrigerated condenser control (Option PCE-B1).
The dry-to-dry closed-loop machine with unvented integral secondary carbon adsorber (PCE-D) appears to
be the most cost-effective option, using the above definition, followed by PCE-B2 (carbon adsorber vent
control). PCE-B3 (dry-to-dry machine converted to closed-loop controls) and PCE-C (closed-loop with no
carbon adsorber or with door fan and small carbon adsorber) seem to have the smallest reductions in
emissions per dollar saved.
This presentation illustrates the most cost-effective way to reduce emissions, given the
assumptions made in the analysis. It does not, however, present the complete benefits derived from that
reduction. These may include reduced health risk to workers, customers, and nearby residents, as well as
reduced potential liability from waste disposal.
10-22
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Chapter 10
Trade-Off Issues
Exhibit 10-10. Estimated Cost Effectiveness of PCE Transfer Drycleaning Alternatives Compared
to PCE Transfer with No Vent Control (PCE-A1)
Gallons of PCE controlled per dollar
saved annually (gal/S saved)
1.40
1.20
1.00
0.80
0.60
0.40
0.20
0.00
0.00
1.25
PCE-A1
PCE-A2
PCE-A3
Exhibit 10-11. Estimated Cost Effectiveness of PCE Dry-to-Dry Cleaning Alternatives Compared to
PCE Dry-to-Dry with No Vent Control (PCE-B1)
Gallons of PCE controlled per dollar
saved annually (gal/$ saved)
0.60
PCE-B1
PCE-B2
PCE-B3
PCE-C
PCE-D
10-23
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Chapter 10 Trade-Off Issues
10.2.4 A Comparison of Alternative Hydrocarbon Solvent-Based Technologies
Risks, Release Reduction Performance, and Cost Characteristics
HC solvents dominated the drycleaning market in the United States in the 1950s, but their use has
gradually declined, partly due to concerns of fire and explosion hazards. The NFPA classifies drycleaners
by the petroleum solvent (HC) they use, and solvents by their flashpoint. Class II solvents (flashpoints
between 100°F and 140°F, often termed Stoddard solvent) and Class IIIA solvents (flashpoints 140°F and
above, often termed 140°F solvent) are the primary solvents used in this industry. NFPA codes limit Class
II solvents to use in free-standing buildings (i.e, not in multi-dwelling buildings) only.
Exhibit 10-12 summarizes the solvent releases, performance characteristics, and cost
characteristics, including capital and operating costs, of HC drycleaning machine configurations, as well as
both health and environmental risks using solvent releases as a surrogate for potential risk. The estimated
solvent use per year and a relative ranking of solvent mileage is provided for each of three HC drycleaning
machine types. Solvent releases also are detailed as well as cost information regarding maintenance and
energy use. Other issues, such as garment cleanliness and damage, which may be considered performance
issues in the drycleaning industry, are not evaluated, and are not expected to vary significantly across
machine configurations.
Based on the model facility3 (see Chapters 4 and 7), the use of a closed-loop dry-to-dry machine
with a refrigerated condenser (HC-B) shows a reduction in solvent consumption compared to a transfer
machine with conventional dryer (Option HC-A1). This higher mileage decreases solvent air emissions
and lowers the corresponding exposures and health risks. Replacing an uncontrolled HC transfer machine
with a dry-to-dry closed-loop machine with a refrigerated condenser decreases both the HC solvent use and
the release to workplace air by 1,645 gallons per year, although wastewater releases increase by 414
gallons.
Cost-Effectiveness
Reduction in solvent losses may offset the cost of control technology in some HC solvent options.
Exhibit 10-13 compares the cost effectiveness of alternative hydrocarbon cleaning technologies in
controlling HC) solvent releases. As was the case in the two PCE-based cost-effectiveness comparisons
(Exhibits 10-10 and 10-11), the alternatives have both lower total annual cost and lower solvent releases
(in gallons/year) than the baseline technology option (HC-A1). Each bar therefore represents the gallons
of solvent emissions reduced per dollar saved when a technology option is compared with the baseline
option, a transfer machine with standard dryer (Option HC-A1). For example, there is a 1.88 gallon
reduction in PCE emissions for every dollar saved by switching to Option HC-B. This measure of cost
effectiveness is calculated by dividing the difference in the number of gallons of HC released (1,645) by
the savings in total annual cost in moving from Option HC-A1 to Option HC-B ($874). As shown in
Exhibit 10-13, Option HC-B is the most cost-effective hydrocarbon option considered, using the above
measure of cost-effectiveness.
3The model facility processes 53,333 pounds of clothes per year operating six days a week for 52 weeks a year.
10-24
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Chapter 10
Trade-Off Issues
Exhibit 10-12. Estimated Release Reduction, Performance, and Cost Characteristics of HC
Drycleaning Machine Configurations"
Release Reduction
Performance and Cost
Characteristics
Total Solvent Use (gal/year)
Solvent Mileage Rank
(Best = 1 ; Worst = 3)
Solvent Releases (gal/year)
HC to air
HC in wastewater
(total wastewater)
HC in solid waste
(total solid waste)
Relative Health Risks
Relative Environmental Risks
Degree of Required
Maintenance
Impact of Poor Maintenance
Capital Costs'1
Annual Operating Costs"
Total Annual Costs'*
HC-A1
Transfer with
Conventional Dryer
2,159
3
2,159
1,839
5x10-6
(415)
320
(1,415)
High
High
NA
NA
$27,830
: $22,207
$25,263
HC-A2
Transfer with
Recovery Dryer
998
2
998
678
1 x10'5
(829)
320
(1,415)
Medium-High
Medium-High
Low
Increased HC Use
$37,432
$19,607
$23,717
HC-B
Dry-to-Dry with
Condenser
514
1
514
194
1x10'5
(829)
320
(1,415)
Low
Low
Low
Machine Failure
$52,082
$18,671
$24,389
NA means data are not available at this time.
* The value includes the price of eguipment and services directly related to the various drycleaning
processes, but excludes costs for expenses such as pressing, storefront operations, and rent. All values are
reported in 1997 dollars and all calculations assume a 53,333-pound (24,191 kg) annual volume of clothes
cleaned per facility.
"The.list. P.rice °f a 35'to 40-pound drycleaning machine (or system) with control equipment as shown The
price includes filters and an explosion kit where applicable.
C Ttf ?f t™ate inc'udes solvent, energy, hazardous waste, filters, detergent, and maintenance costs The
cost of labor, another component of annual operating costs, is omitted due to lack of data
The estimate includes ail operating costs and annual capital costs.
10-25
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Chapter 10
Trade-Off Issues
Exhibit 10-13. Estimated Cost Effectiveness of HC Cleaning Alternatives Compared to
HC Transfer with Standard Dryer
Gallons of HC controlled per dollar
saved annually (gal/$ saved)
1.88
HC-A1
HC-A2
HC-B
This presentation identifies the most cost-effective way to reduce emissions, given the assumptions
made in this analysis. It does not, however, present the complete benefits that are derived from that
reduction. These may include reduced health risk to workers, customers, and nearby residents, as well as
reduced potential liability from waste disposal.
10-26
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Chapter 10
Trade-Off Issues
REFERENCES
Beedle, L. 1998. Personal communication between Lee Beedle, Safety-Kleen of Grand Junction,
Colorado, and Jonathan Greene, Abt Associates Inc. March 19.
BLS. 1997. Bureau of Labor Statistics. Downloaded from the BLS Information Bulletin Composite File
of the Producer Price Index for Capital Equipment and Chemicals and Allied Products. U.S.
Department of Labor, Bureau of Labor Statistics, Office of Prices and Consumer Living
Conditions.
Exxon. 1998. http://www.exxon/exxoncorp/current_news/fo_Chemical4.html.
Gottlieb, R., J. Goodheart, P. Sinsheimer, C. Tranby, and L. Bechtel. 1997. Pollution Prevention in the
Garment Care Industry: Assessing the Viability of Professional Wet Cleaning. UCLA/Occidental
College Pollution Prevention Education and Research Center. Los Angeles, CA. December.
Hill Jr., J. 1994a. Personal communication between Jim Hill Jr., Hill Equipment Company, and Leland
Deck, Abt Associates Inc. March.
Hill Jr., J. 1994b. Personal communications between Jim Hill, Jr., Hill Equipment Company, and
Cassandra De Young, Abt Associates Inc. June and August.
Murphy, M. 1994. Personal communication between Mike Murphy, Unimac, and Cassandra De Young,
Abt Associates Inc. August 26.
NCAI. 1998. Neighborhood Cleaners Association International. NCAI Bulletin: Cost Comparison Chart
for 1998. March.
Pindyck, R.S., and D.L. Rubinfeld. 1989. Microeconomics. Macmillan Publishing Company New
York, NY.
Riggs, C. 1998. Personal communication between Charles Riggs, Texas Women's University
Department of Fashion and Textiles, and Jonathan Greene, Abt Associates Inc. March 2.
USEPA. 1991. U.S. Environmental Protection Agency. Dry cleaning facilities - background information
for proposed facilities. Draft environmental impact statement. EPA-450/3-91-020a. Office of Air
Quality, Planning and Standards. Washington, DC. November.
USEPA. 1993. U.S. Environmental Protection Agency. Multiprocess wet cleaning cost and performance
comparison of conventional dry cleaning and an alternative process. EPA 744-R-93-004. Office
of Pollution Prevention and Toxics. Washington, DC.
Wentz, M. 1996. The status of wet cleaning in Canada: the concept of textile care process spectra.
Presented at Conf. On Global Experience and New Developments in Wet Cleaning Technology.
Schloss Hohenstein, Boennigheim. June. p. 20-25.
10-27
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-------
CHAPTER 11
EMERGING TECHNOLOGIES
There are several new technologies
under development. Some involve substituting
solvents coupled with modifications to existing
machinery, while others involve the use of
newer machinery. The Cleaner Technologies
Substitute Assessment (CTSA) briefly
describes liquid carbon dioxide (CO2) and
aqueous ultrasonic fabricare technologies and
the solvents Rynex and Biotex. There may be
others, but these are the only ones USEPA currently has information on. These technologies are in various
stages of commercial development, therefore, information is limited and may be speculative.
11.1
11.2
11.3
11.4
CHAPTER CONTENTS
Liquid Carbon Dioxide Process
Ultrasonic Cleaning Process
Rynex Solvent
Biotex Solvent
11.1 LIQUID CARBON DIOXIDE PROCESS
A carbon dioxide (CO2) process that uses CO, in a liquid state is being developed for fabric
cleaning. Liquid CO2 seems to have adequate characteristics for drycleaning garments. Ongoing studies
should present a clear determination of the capabilities of drycleaning with liquid CO2 (Williams et al.,
Undated). The level of detail on each technology is reflective of its state of development.
Because liquid CO2 processes are in the pre-commercial stage of development, little information
on these processes is available. The information that is available is highly vulnerable to change. Those
persons interested in this technology are advised to determine whether more recent information on this
technology are available. The following process description summarizes the information available as of
December 1997.
Hughes Environmental Systems and Los Alamos National Laboratories (supported by USEPA and
the US Department of Energy), have conducted research on this technology, which Global Technologies,
Inc. is attempting to commercialize. MiCELL Technologies, Inc. is also developing a liquid CO, process
(MiCELL, 1997). Although both closed-loop and open-loop liquid CO2 clothes cleaning were initially
investigated (Chao, 1994), pre-commercial machines have been closed-loop. The closed-loop configuration
significantly reduces CO, emissions by recovering and recycling the solvent in which garments are
washed. Because these developing technologies are proprietary, complete process operating parameters
are not available.
A problem that is being addressed is how solid materials that are not soluble in liquid CO, can be
removed from fabric. Liquid CO2 removes inorganic compounds such as salts even more poorly than PCE.
The liquid CO2 process developers are researching and developing cleaning additives (e.g., detergents)
(Caled, 1995; DeSimone and Smith, 1996; and MiCELL, 1997). These cleaning additives may have to be
specially formulated for use with liquid CO, (Chao, 1994).
The Hughes process was the only process for which process details adequate to describe the unit
operations and their configuration were readily available. This pre-commercial Hughes-specific process is
described below; if and when a liquid CO2 process is commercialized, it may differ from that described.
11-1
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Chapter 11
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Equipment sizes have not yet been fully determined for the Hughes process, but will probably be similar to
those of PCE systems (USEPA, 1996). The following unit operations comprise the Hughes pre-
commercial liquid CO2 process: stationary cylinder, or drum, for washing, extracting, and drying;
cooler(s); solvent tanks; a still; filters; a pump; and a compressor. The cleaning cylinder, or drum, is
initially charged with about one-half gallon of liquid CO2 per pound of clothes to be cleaned (Hughes,
1994) In conventional drycleaning, the rotating cylinder provides mechanical agitation of the clothes, in
the pre-commercial Hughes-specific liquid CO2 process, high velocity fluid jets provide mechan.cal
agitation of the clothes during cleaning (Caled, 1995).
The soiled solvent, loaded with both soluble and insoluble (paniculate) soils, will circulate in a
closed loop, through the cleaning vessel, a filter train, and lint trap, to remove the particulates and lint At
the end of the cleaning cycle, the filtered cleaning fluid is returned to a storage tank. The cylinder will be
depressurized, and CO2 will vaporize from the cleaned clothes. A compressor and condenser will recover
much of the C02 vapor from the cylinder during depressurization. Some CO2 vapor loss will occur at the
decompression. This loss will require periodic make-up in liquid CO2 storage. The stored liquid CO2 will
be distilled to remove the soluble soils and detergents. The developer expects the distilling frequency to be
similar to that of PCE drycleaning, per unit weight of cleaned garments. To reduce solvent loss, the still
"bottoms" (i.e., concentrated mixture of soils and detergents) will be drained without still decompression
and stored for recovery and disposal (Caled, 1995).
Global Technologies' DryWash™ cleaning process developmental prototype "Alpha Unit" was
displayed during the "Clean '97 Show" in Las Vegas, Nevada. Global Technologies has the right to
license seven manufacturers (including Raytheon Commercial Laundry and MVE, Inc.), five chemical
additive manufacturers (including Caled Chemical), and one fluid manufacturer (DryWash fluid
manufacturing corporation headquarters is AGA AB in Stockholm, Sweden) (Global Technologies, 1998).
Global Technologies aspires to open test sites and have all its manufacturers in the market in 1998. Ihey
estimate that the capital production price of machines with DryWash™ will be $80,000 (Kinsman, 1998).
Cycle times for these machines will be 30 minutes.
MiCell Technologies expects the MiCARE process to be available in 1998 (USEPA, undated).
The estimated commercial price for their MiCare™ machine is approximately $150,000 (Lienhart, 1998).
The NIOSH Criteria Document for CO, provides the following hazard information (SRI, 1976). A
large body of human experimental information suggests the potential for CO2 exposure to cause
respiratory, cardiovascular, central nervous system, behavioral, electrolyte balance, and muscle effects over
a variety of concentrations and durations. Inhalation of carbon dioxide at concentrations greater than 17 /o
is lethal to humans.
No irritation or sensitization studies were reported in the literature discussed by NIOSH.
Continuous exposure to 1.5-3% CO2 (15,000 to 30,000 ppm in air) does not result in serious toxicity to
humans. Physiological effects at these exposure levels include increased CO2 and bicarbonate ion levels in
blood, changes in other electrolyte levels, and increased ventilation rates.
Two weeks of exposure to 4% CO2 in an environmental chamber showed no psychomotor
impairment and no decrement in complex-task performance by six healthy male human subjects. Exposure
of an unspecified number of men to 3% CO2 for 8 days, however, showed a progression through mental
11-2
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Chapter 11
Emerging Technologies
stimulation and euphoria at day 1 to exhaustion and confusion on days 2 through 8. NIOSH does not
summarize any human studies focusing on reproductive and/or developmental toxicity, although some
studies in laboratory animals have shown these effects at very high doses.
No mutagenicity studies are summarized by NIOSH. There were no reports of carcinogenicity in
animals or in humans from inhalation of gaseous CO2.
Williams et al. (undated) conducted a study using liquid CO2 in both small-scale and pilot-scale
test systems to address fabric compatibility with this alternative cleaning method, compared with
drycleaning using PCE. The study concluded that the liquid CO2 technology is not necessarily a "drop-in"
replacement for PCE drycleaning, although liquid CO, is an effective solvent for removal of common types
of organic soils. Researchers noted that liquid CO2 processing had no deleterious effects on test fabrics,
had acceptable shrinkage, and removed more soil than standard PCE drycleaning. The next step, '
according to the study, would be to evaluate full scale prototype cleaning units, which are currently under
development.
11.2 ULTRASONIC CLEANING PROCESS
Aqueous-based ultrasonic washing processes have been used in industrial cleaning applications for
many years. It is now being researched for garment cleaning. Ultrasonic cleaning uses high intensity
sound waves in a fluid medium to create mechanical forces that dissolve and displace contaminants on
clothing. No ultrasonic process equipment description is available. This section discusses several of the
concepts and issues involved in the development of this process.
Surfactants, detergents and/or ozone may theoretically be used in an ultrasonically agitated
aqueous solution to clean stationary garments. Free-floating items tend to severely dampen ultrasonic
energy in solutions, and this dampening would not allow for needed mechanical agitation. Transducers
create cavitation, which may dislodge insoluble particles from the garments in the cleaning solution. A
combination of blended detergents and ultrasonics may allow polar and non-polar contaminants to be
removed at temperatures between 90°F to 122°F (32°C to 50°C) without fabric damage (Abt, 1994). If
developed, a machine that could accomplish such cleaning would achieve similar results to the washer in
the machine wetcleaning system. Extraction and drying would need to be incorporated into this ultrasonic
system.
Cavitation creates the mechanical agitation in ultrasonic cleaning. Cavitation is energy-created by
the conversion of electrical pulses to acoustic energy via transducers which are bottom- or side-mounted in
the cleaning system. This energy exists in the cleaning solution as alternative rarefactions and
compressions of the liquid. During the rarefaction, small vacuum cavities are formed that collapse or
implode during compression. This continuing process, called cavitation, is responsible for the scrubbing
effect that dislodges contaminating particles (Abt, 1994). According to one source who has conducted
small-scale research in ultrasonic cleaning, three areas of change must be researched for this process:
Optimizing the time and temperature of washing, the ultrasonic agitation, and the
detergents needed'to provide adequate cleaning;
• Designing systems for rinsing, dewatering, and drying; and
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Chapter 11
Emerging Technologies
Designing a material handling system (Porter et al., 1995).
Proponents of ultrasonic cleaning claim that it is faster, uses less water and energy and performs
more thoroughCleaning than conventional fabricare cleaning methods (Hoffman, 1998). The Department
of Energy provided funding for a test of ultrasonic cleaning in 1993. Since that time, further work has
been conducted at North Carolina State University using continuous processing. Currently, the Fraunhpfer
Technology Center, a joint venture of the City of Hialeah, Florida and Fraunhofer USA, is raising funds to
develop a prototype ultrasonic clothes cleaning machine.
11.3 RYNEX SOLVENT
Rynex Corporation currently is developing a drycleaning solvent named Rynex for substitution in
existing PCE machines. This solvent is a mixture containing one or more propylene glycol ethers. The
folTowfng process information summary contains the information available as of December 1997, with the
exception of a personal contact from April 1998.
Rynex Corporation intends this solvent to be a drop-in substitute for PCE in modified PCE
machinery. The company claims that PCE drycleaners could use this mixture by modifying cycle times
and temperatures, installing a new water separator, and cleaning the PCE from the machinery, and filling
the machine with the mixture (Colletti, 1998). A water separator change would apparently be necessary
because the Rynex mixture has a lower density than water (Rynex, 1997). The Rynex mixture would then
be removed from the top of the separator, and water would be removed from the bottom The Rynex
mixture and water phase separation would be opposite to that of PCE and water because PCE has a higher
density than water. In the PCE separator, PCE is removed from the bottom of the separator, and water is
removed from the top.
Rynex is currently being studied in five test sites. Although official performance reports have not
yet been released, the company claims that the chemical has the following advantageous characteristics:
biodegradablity, contains no hazardous materials or carcinogens, recyclable via distillation, and a
flashpoint higher than HC solvents (Colletti, 1998).
Rynex is considered a volatile organic compound (VOC), its use by cleaners may be regulated
by state and Federal air pollution legislation. However, Rynex is not regulated as a hazardous air pollutant
(HAP) under the Clean Air Act (Hayday, 1998).
Hazard data are available for a variety of propylene glycol ethers. Proprietary information
precludes identification of the particular solvent used in Rynex, but it is known to be a propylene glycol
ether. USEPA has published a review of the hazard information on several propylene glycol ethers
(USEPA, 1986), however, and also recently derived a reference concentration (RfC) on a specific
propylene glycol ether, propylene glycol monomethyl ether (PGME) (IRIS, 1998).
Propylene glycol ethers appear to be extensively absorbed following either oral or inhalation
exposure There is no information on absorption following contact with the skin. A study with a small
number of human volunteers exposed to moderate levels of PGME in air resulted in eye, nose, and throat
irritation and headaches, but there were no controls in the study.
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CHapter 11
Emerging Technologies
In animal studies, exposure (via drinking water, oral intubation, or inhalation) to high
concentrations of PGME resulted in general toxicity (lowered body weights) and specific effects on the
liver and the central nervous system (narcosis/sedation effects).
Limited studies in animals suggest no developmental or reproductive effects following exposure to
several different propylene glycol ethers. No studies reviewed in either USEPA document were designed
to examine whether these chemicals interact with genetic material or cause cancer.
11.4 BIOTEX SOLVENT
Another new cleaning process still in development is based on a new solvent, tentatively named
"Biotex," by the developer Bio-Clean Ventures. In a May 27, 1998 communication to USEPA, Dieter
Berndt, PhD, Director of R&D for Bio-Clean indicates their plans to market "Biotex" as an alternative to
PCE and HC solvents. The company claims "Biotex" is non-carcinogenic, not a VOC, its use will not
result in the production of secondary hazardous waste, and that its distillation residue will be dischargeabie
into ordinary sewage (Berndt, 1998) although these claims are unsubstantiated by USEPA.
Bio-Clean Ventures states that "Biotex" will be "...a little higher [priced] than Perc" and makes the
following claims, based on their "extensive" testing program:
Drycleaners will be able to use "Biotex" in existing PCE machines, with certain
modifications to their equipment;
• "Biotex" can also be used in existing HC machinery without modification.;
The solvent will not attack or pull dyes of any type, even at temperatures over 150°F, nor
will it shrink garments;
• It has a degreasing ability of around 58-63, as compared to PCE at 90 and HC at 31;
• It has a surface tension of 16 dynes/square cm, as compared to PCE at 36; and
• It is slightly lighter than water.
No studies have been found to verify these claims, and the commercial status of this solvent is
currently unknown.
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REFERENCES
Abt 1994 Dry cleaning industry. Use cluster analysis. Final report. Prepared for USEPA, Office of
Pollution Prevention and Toxics under Contract No. 68-D2-0175. Abt Associates. April 5.
Berndt. 1998. Personal communication between Dieter Berndt, BioClean and Cindy Stroup, USEPA.
May.
Caled. 1995. Comments submitted by Caled on CTSA Phase II drafts sent for stakeholder comments.
Colletti, James. 1998. Personal communication between James Colletti, Rynex Corporation, and Erica
Shingara. Abt Associates, Inc. April.
Chao, S. 1994. Personal communication between Sid Chao, Hughes Corporation, and Alice Tome, Abt
Associates Inc. December.
DeSimone J , and M.A. Smith. 1996. Design and application of surfactants for carbon dioxide.
Nomination for the Presidential Green Chemistry Challenge Awards Program. November 29.
Global Technologies. 1998. Information downloaded from Global technologies Website:
http ://www.globaltech.com.
Mayday, W. 1998. Correspondence between William Hayday, Rynex Corporation, and Earl Fischer,
America Drycleaner. February.
Hoffman, T. 1998. Personal communication between Thomas Hoffman, Fraunhofer Technology Center
Hialeah, and Erica Shingara, Abt Associates. April.
Hughes. 1994. Personal communication between Mariana Purrer, Hughes Environmental Systems, Inc.,
and Sue Hollenbeck, SAIC. July.
IRIS. 1998. Integrated Risk Information System, http://www.epa.gov/ngispgm3/iris/subst/0404.htm.
Kinsman, R. 1998. Personal communication between Richard Kinsman, Global Technologies, and Erica
Shingara, Abt Associates Inc. April.
Lienhart. 1998. Personal communication between R. Bradley Lienhart, MiCELL Technologies, and
Jonathan Greene, Abt Associates, Inc. April 22.
MiCELL. 1997. MiCELL Technologies. Providing cleaner solutions. April 10.
Porter, D., et al. 1995. An environmentally conscious approach to clothes maintenance. Final report.
' Prepared for the U.S. Department of Energy under contract DE-ACO4-76-DP00613. December.
Rynex Corporation. 1997. Information on Rynex downloaded from Web site http://www.rynex.com.
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SRI. 1976. Stanford Research Institute. Criteria for a recommended standard. Occupational exposure to
carbon dioxide. Prepared for NIOSH. Menlo Park, CA. PB-266 597. August.
USEPA. Undated. Alternatives to Cleaning with Perchloroethylene.
USEPA. 1986. Health Effects Assessment for Glycol Ethers. USEPA Office of Research and
Development EPA-540-1 -86-052.
USEPA. 1996. Site Visit Summary Report: Liquid Carbon Dioxide Technology Development. By Scott
Prothero, USEPA/OPPT. May.
Williams, S., K. Laintz, W. Spall, L. Bustos, C. Taylor. Undated. Fabric Compatibility and Cleaning
Effectiveness of Drycleaning with Carbon Dioxide. Report Number LA-UR-96-822. Chemical
Science and Technology Division (CST-12), Los Alamos National Laboratory.
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APPENDIX A
CHEMISTRY AND FATE
This appendix discusses the physical nature of specific chemicals used in dry and machine
wetcleaning operations. Perchloroethylene (PCE) and hydrocarbon (HC) solvents are used at high
concentrations in drycleaning. In machine wetcleaning, the detergents and soaps are chemical mixtures,
typically containing numerous chemicals and water. Most of the formulations are trade secrets; therefore,
the individual chemical concentrations are unknown. Nor is it known how representative the formulations
considered in this report will be of the potential universe of formulations in existence. The following
provides information on PCE, HC, and various chemicals that machine wetcleaning (MWC) formulations
may contain. It is important to remember that the actual constituents of MWC formulations may vary
significantly. First, this appendix describes the types of information that are provided for each chemical,
including a glossary of chemical properties, or terms, presented in Exhibit A-1. These descriptions
highlight chemical and physical properties, safety hazard factors, and environmental consequences.
Following these descriptions, Exhibit A-2 lists the name, Chemical Abstracts Service (CAS) Registry
Number, and common synonyms for each chemical. A Chemical Properties and Information Summary for
each chemical lists its physical properties and safety hazard factors. Sections A.2, A.3, and A.4 summarize
the environmental fate of PCE, HC, and machine wetcleaning chemicals, respectively.
A.1 CHEMICAL PROPERTIES AND INFORMATION
For each chemical identified, there is a corresponding summary of its chemical properties and
relevant information. All information in these summaries was obtained by searching standard references,
listed at the end of this chapter. These summaries contain information on the chemical and physical
properties listed in Exhibit A-l.
The summaries of the chemicals' property values acquired from the standard references are
designated as measured (M) (i.e., the data in these references were experimentally determined) or
estimated (E). Terms and concepts such as synonyms and the role of the chemical in the cleaning process
have no such designation since these are not values that can be measured.
Because information was proprietary, and therefore confidential, there were negligible or no data
in the standard references for certain chemicals. Therefore, many of the values for the physical and
chemical properties of these chemicals needed to be estimated. These estimations were obtained using
several programs accessed through the Estimation Programs Interface (EPI), available from Syracuse
Research Corporation (SRC, 1993a and 1993b). The EPI uses the structure of the chemical for input to
eight chemical property estimation programs. The programs used to complete the individual Chemical
Properties and Information summaries are as follows:
Octanol-Water Partition Coefficient Program (LOGKOW) (Meylan and Howard, 1995).
Henry's Law Constant Program (HENRY) (Meylan and Howard, 1991).
Soil Sorption Coefficient Program (PCKOC) (Meylan et al., 1992).
Melting Point, Boiling Point, Vapor Pressure Estimation Program (MPBPVP).
-------
Appendix A
Chemistry and Fate
Exhibit A-1. Glossary of Chemical and Physical Properties
Term
Definition
Chemical Abstracts Service
Registry Number (CAS#)
Synonyms
Molecular Weight
Melting Point
Vapor Pressure
Octanol-Water Partition
Coefficient
Bioconcentration Factor
(BCF)
Henry's Law Constant
Applicable Function
Molecular Formula and
Physical Structure of the
Chemical
Boiling Point
Density
Flash Point
Safety Hazard Factors
A unique identification code, up to ten digits long, assigned to each
chemical registered by the Chemical Abstracts Service. The CAS# is
useful when searching for information on a chemical with more than
one name.
Alternative names commonly used for the chemical.
A summation of the individual atomic weights based on the numbers
and kinds of atoms present in a molecule of a chemical substance.
For polymers, this may included molecular weight distributions,
ranges, and averages. Typical unit is grams per mole (g/mol).
The temperature at which a substance changes from the solid to the
liquid state. Typical unit is °C.
The pressure exerted by a chemical in the vapor phase in equilibrium
with its solid or liquid forms. It provides an indication of the relative
tendency of a substance to volatilize. Typical unit is mm Hg.
Provides a measure of the extent to which a chemical partitions
between water and octanol (as a surrogate for lipids) at equilibrium. It
is an important parameter because it provides an indication of a
chemical's water solubility and its propensity to partition in aquatic
organisms or sorb to soil and sediment. The higher the Log Kow, the
more likely a chemical is to move from water to lipids.
Provides a measure of the extent of chemical partitioning at
equilibrium between a biological medium such as fish tissue or plant
tissue and an external medium such as water. The higher the BCF,
the greater the accumulation in living tissue is likely to be.
Provides a measure of the extent of chemical partitioning between air
and water at equilibrium; estimated by dividing the vapor pressure of a
sparingly water soluble chemical substance by its water solubility. The
higher the Henry's Law constant, the more likely a chemical is to
volatilize than to remain in water.
The primary function(s) of the chemical in the cleaning operation.
A description of the number and type of each atom in the chemical,
how the atoms are arranged, and the types of bonds between atoms.
The temperature at which a liquid under standard atmospheric
pressure (or other specified pressure) changes from a liquid to a
gaseous state. It is an indication of the volatility of a substance. The
distillation range in a separation process, the temperature at which the
more volatile liquid of a mixture forms a vapor, is used for mixtures in
the absence of a boiling point. Typical unit is °C.
The mass of a liquid, solid, or gas per unit volume of that substance,
i.e., the mass in grams contained in 1 cubic centimeter of a substance
at 20°C and 1 atmosphere. Typical unit is g/cm3.
The minimum temperature at which a liquid gives off sufficient vapor to
form an ignitible mixture with air near the surface of the liquid or within
the test vessel used.
Discussed in detail below.
A-2
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Appendix A
Chemistry and Fate
Water Solubility Estimation Program (WSKOW) (Meylan et al., 1996).
• Sewage Treatment Plant Model (STP), a fugacity model for estimating the efficiency of pollutant
removal (Clark et al., 1995).
The accuracy of these programs is not established in all cases, but the listed programs are
considered the best methods currently available. The reference section at the end of this appendix lists
journal articles discussing the development and use of these programs (except the MPBPVP program). A
user's guide also is available for the EPI and each program. Any property values determined using these
programs are designated as estimated (E). It should be noted that the water solubility estimation program
has an anticipated margin of error of plus or minus one order of magnitude. The Log KQW is expected to
be accurate to 0.1 log units for most compounds, although the PCKoC is likely to be somewhat less
accurate due to the complex nature of the soil/sediment sorption phenomena.
For several chemicals, data were not available in any of the primary sources, and EPI estimation
methods were not performed because the complex nature of the chemical (e.g., chemicals with ranges of
carbon atoms) skewed the estimation results. For these chemicals, chemical and physical data had to be
estimated based on structure-activity relationships (i.e., comparison with analogous chemicals with known
properties). In addition, some properties were estimated from best chemical judgment based on the class
of compounds to which the specific chemical belongs. Any property values determined by this comparison
method are designated by an E. Any chemical and physical property values that still could not be
estimated have been designated as not available.
Exhibit A-2 contains the dry and machine wetcleaning chemicals under consideration with their
common synonyms and specified CAS Registry Number (CAS, 1993). Immediately following the exhibit
are individual Chemical Properties and Information summaries for each chemical.
. A-3
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Appendix A
Chemistry and Fate
Exhibit A-2. Chemicals Utilized in Dry and Machine Wetcleaning Operations
Chemical Name
Acetic acid (WC)
Cellulose gum (WC)
Citric acid (WC)
Cocamidopropyl betaine (WC)
Ethoxylated sorbitan
monodecanoate (WC)
Laurie acid diethanolamide
(WC)
Methyl 2-sulfolaurate, sodium
salt (WC)
Perchloroethylene (DC)
Sodium carbonate (WC)
Sodium citrate (WC)
Sodium laureth sulfate (WC)
Sodium lauryl isethionate (WC)
Stoddard solvent (Petroleum)
(DC)
140°F solvent (Petroleum) (DC)
DF-2000 solvent (DC)
CAS No.
64-19-7
9004-32-4
77-92-9
61789-40-0
9005-64-5
120-40-1
4337-75-1
127-18-4
497-19-8
68-04-2
9004-82-4
7381-01-3
8052-41-3
64742-88-7
Chemical Synonyms
Acetic acid glacial; vinegar; ethanoic acid
Sodium carboxymethylcellulose; CMC;
carboxymethylcellulose, sodium salt; CM cellulose
1,2,3-Propane tricarboxylic acid; 2-hydroxy-
hydroxytricarballylic acid
1-Propanaminium, 3-amino-N-(carboxymethyl)-N, N-
dimethyl-, N-coco acyl derivates, inner salts;
cocamidopropyl dimethyl glycine
Polyoxyethylene (20) sorbitan monolaurate; sorbitan,
monodecanoate, poly(oxy-1 , 2-ethanediyl) derivatives
Lauramide DEA; N,N-bis (2-hydroxyethyl) lauramide
Sodium methyl 2-sulfolaurate; N-lauroyl-N-methyl-
taurine, sodium salt; ethanesulfonic acid, 2-[methyl
(1-oxododecyl) amino]-, sodium salt
Tetrachloroethylene; perchlor; perc; carbon bichloride;
carbon dichloride; ethylene tetrachloride;
tetrachloroethene
Carbonic acid; sodium salt; soda ash; Solvay soda
Trisodium citrate; 1,2,3-propane tricarboxylic acid; 2-
hydroxy-trisodium salt
Ethoxylated sodium laureth sulfate; ethoxylated
sodium lauryl ethyl sulfate; poly(oxy-1, 2-ethanediyl)-
sulfo-(dodecyloxy)-, sodium salt
Sodium ethyl 2-sulfolaurate; sodium
dodecoylisethionate; dodecanoic acid, 2-
sulfoethylester, sodium salt
Solvent naphtha; white spirits; mineral spirits
Solvent naphtha (petroleum), medium aliphatic
Hydrotreated heavy naphtha (petroleum); naphtha
(petroleum), hydrotreated and heavy, nonaromatic
A-4
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Appendix A
Chemistry and Fate
Acetic Acid
CAS# 64-19-7
Chemical Properties and Information
Synonyms: Acetic acid glacial,
vinegar, ethanoic acid
Molecular Weight 60.05
Melting Point 16.7°C (M)
Boiling Point 118°C(M)
FlashPoint 103°F (closed cup) (M)
Vapor Pressure: 10mgHg(at
' 0
CH3COH
Molecular Formula: C2H4O2
Physical State: Liquid
Water Solubility: Miscible in water in Density. 1.049 g/L (at 25°C) (M)
all proportions (M)
Other Solubilities: Miscible with
alcohol, glycerol, ether, carbon
tetrachloride
Applicable Function: pH adjuster
Log10KOW: -0.09
Log10BCF: <1
Cellulose Gum
CAS'# 9004-32-4
Chemical Properties and Information
Synonyms: sodium
carboxymethylcellulose; CMC;
carboxymethylcellulose, sodium salt;
CM cellulose
Molecular Weight High (>10,000)
Melting Point: not available
Boiling Point: not available
Flash Point: Not available
Vapor Pressure: <10'6 mm Hg (E)
Water Solubility: Soluble (M)
Applicable Function: soil suspender
R-O-CH2 COONa
R=(C6H1005)
Molecular Formula: varies
Physical State: Solid
Density: 0.75 g/cm3
Log10KOW: n/a
Log10BCF: n/a
Other Solubilities: Insoluble in
organic liquids
A-5
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Appendix A
Chemistry and Fate
Citric Acid
CAS# 77-92-9
Chemical Properties and Information
Synonyms: 1, 2, 3-Propane
tricarboxylic acid, 2-hydroxy-
hydroxytricarballylic acid
Molecular Weight 191.12
Melting Point: 153°C (loses water)
(M)
Boiling Point Decomposes (M)
Flash Point Not available
Vapor Pressure: <10'6 mm Hg
Applicable Function: pH control
HOC (CH2COOH)2COOH
Molecular Formula'. C6H8O7
Physical State: solid
Density. 1.542g/cm3
Log10Kow -1.67
Log10BCF: <1
Water Solubility: 592 g/L @20°C
(M)
Other Solubilities: Soluble in
alcohol and ether.
Cocamidopropyl betaine
CAS# 61789-40-0
Chemical Properties and Information
Synonyms: 1-Propanaminium, 3-
amino-N-(carboxymethyl)-N,N-
dimethyl-, N-coco acyl derivatives, inner t
salts; cocamidopropyl dimethyl glycme CH3-N+.
CH3
Molecular Weight 342.53
Vapor Pressure: Negligible (E)
Molecular Formula: C19H38N2O3 (forC-
11)
Physical State: Solid (E)
Water Solubility: > 200 g/Lat25°C(E) Log10Kow -4.9
(dispersible)
Other Solubilities: Slightly soluble in Log10BCF: <1
some organic solvents
Applicable Function: amphoteric surfactants
A-6
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Appendix A
Chemistry and Fate
Ethoxylated Sorbitan Monodecanoate
CAS# 9004-64-5
Chemical Properties and Information
Synonyms: Polyoxyethylene (20)
sorbitan monolaurate; sorbitan,
monodecanoate, poly(oxy-1, 2-
ethanediyl) derivatives
Melting Point Not available
Boiling Point Not available
Flash Point: 148°C (closed cup) (M)
Water Solubility, completely soluble
(M); 1000g/L(E)
Other Solubilities: Soluble in alcohol,
in mineral oil and mineral spirits.
Molecular Formula: C5H114O2S
Molecular Weight 1180
Physical State: Liquid
Density. 1.1g/cm3
Log10BCF: n/a
Vapor Pressure: <10'6 mm HG
Applicable Function: non-ionic
surfactant
ethyl acetate, and dioxane. Insoluble
Laurie Acid Diethanolamide
CAS# 120-40-1
Chemical Properties and Information
Synonyms: Lauramide DEA; N, N-bis
(2-hydroxyethyl) lauramide; N, N-bis (2-
hydroxyethyl) Dodecanamide
Molecular Weight 287.17
Melting Point: 50°C (E)
Boiling Point: 359°C (M)
FlashPoint: Not Available
Vapor Pressure: <10'6mm Hg (E)
Other Solubilities: Soluble in polar
organic solvents
Molecular Formula: C16H33NC>3
Structural Formula:
CH3(CH2)10CON(CH2CH2OH)2
Physical State: Solid
Density: 0.979 g/cm3
Log10KOW: n/a
Log10BCF: n/a
Water Solubility: 0.69 g/L (M)
Applicable Function: surfactant
A-7
-------
Chemistry and Fate
Methyl 2-Sulfolaurate, Sodium Salt
CAS# 4337-75-1
Chemical Properties and Information
Synonyms: sodium methyl 2-
sulfolaurate; N-lauroyl-N-methyl-
taurine, sodium salt; ethanesulfonic
acid, 2-[methyl (1-
oxododecyl) amino]-, sodium salt
Molecular Weight. 343.2
Melting Point 207 - 208 °C
Boiling Point. Decomposes (E)
Flash Point, n/a
Vapor Pressure: <10"6mm Hg (E)
Other Solubilities: Soluble in polar
organic solvents
Applicable Function: dispersant
CH- 0
I * II - +
0=C —N—CH—SO No
I I II
C,,H23 CH}0
Molecular Formula:
C15H30N04S?Na
Physical State: solid
Density. >1g/cm3
Log10Kow n/a
Log10BCF: n/a
Water Solubility. Dispersible (E)
A-8
-------
Appendix A
Chemistry and Fate
Perchloroethylene
CAS# 127-18-4
Chemical Properties and Information
Synonyms: tetrachloroethylene,
perchlor, perc, carbon bichloride, carbon
dichloride, ethylene tetrachloride,
tetrachloroethene
Molecular Weight 165.82
Boiling Point: 121.07°C
Vapor Pressure: 18.5 mm Hg@25°C
Other Solubilities: Soluble in most
organic solvents; dissolves a wide range
of organic compounds including organic
acids, fats, oils, rubber, tars, and resins;
solubilizes a number of inorganic
materials including sulfur, iodine,
mercuric chloride, and aluminum
chloride
Freezing Point: -22.35°C
Flashpoint: Not flammable
Specific Gravity: 1.6@25°C
Refractive Index: 1.503
Viscosity: 0.798 cP@30°C
Evaporation Rate: 2.10 (butyl acetate=1)
Odor Threshold: 50 ppm
Applicable Function: solvent
Molecular Formula: C2CL
Cl
cr
.ci
x>c;
Physical State: Liquid
Log10Kow: 3.40
BCF: 49/40 (M)
Henry's Law Constant. 0.0184
atm/m3-mole
Water Solubility. 150 mg/Kg
Hildebrand Solubility is 9.3 cal1/2/cm3'2
Surface Tension: 31.3 dynes/cm2
Dielectric Constant. 2.280
Vapor Density: 5.8 (air=1)
Heat of Vaporization: 9.47 cal/g@25c
Specific Heat 35.01 cal/°K-mole
Kauri Butanol Number. 90
A-9
-------
Chemistry and Fate
Sodium Carbonate
CAS# 497-19-8
Chemical Properties and information
Synonyms: carbonic acid, sodium
salt, soda ash, Solvay soda
Molecular Weight 83
Melting Point. 851 °C (M)
Boiling Point. Decomposes (M)
Flash Point Not Available
Vapor Pressure: <10-6 mm Hg (E)
Other Solubilities: Soluble in
glycerol; insoluble in alcohol and
acetone
Molecular Formula: NaCO3
Physical State: Solid
Density. 2.53 g/cm3 (M)
LogwKOM 0.0
Log10BCF: <1
Water Solubility. 71 g/L (M)
Applicable Function: solubilizer,
detergent aid
Sodium Citrate
CAS# 68-04-2
Chemical Properties and Information
Synonyms: Trisodium citrate; 1,2,3-
propane tricarboxylic acid, 2-hydroxy-
trisodium salt
Molecular Weight. 258.07
Melting Point Becomes anhydrous at
150°C(M)
Boiling Point Not Applicable
Flash Point Not Available
Vapor Pressure: Not Available
Water Solubility. 760 g/L (M)
Applicable Function: emulsifier aid
O OH • O
II I M
NaOCCH2CCH2 CONa
O = CONa
Molecular Formula: C6H5NaO7
Physical State: solid
Density. Not Available
Losr,0/
-------
Appendix A
Chemistry and Fate
Sodium Laureth Sulfate
CAS# 9004-82-4
Chemical Properties and Information
Synonyms: Ethoxylated sodium
laureth sulfate; ethoxylated sodium
lauryl ethyl sulfate; poly(oxy-1, 2-
ethanediyl)-sulfo-(dodecyloxy)-,
sodium salt
Melting Point not available
Boiling Point not available
Flash Point not available
Water Solubility, dispersible (E)
Other Solubilities: Soluble in polar
organic solvents and alcohols
Molecular Formula:
(C2H4O)nC12H25O4S,Na Molecular
Weight varies with degree of
ethoxylation (>330)
Physical State: solid
Density: >1 g/cm3
Log10Kow n/a
Log10BCF: n/a
Vapor Pressure: <10~6mmHg(E)
Applicable Function: surfactant
Sodium Lauryl Isethionate
CAS#7381-01-3
Chemical Properties and Information
Synonyms: sodium ethyl 2-
sulfolaurate; sodiumdodecyl-
isethionate; dodecanoic acid, 2-
sulfoethylester, sodium salt
Molecular Weight 330.3
Melting Point: 216 - 218 °C
Boiling Point decomposes (E)
Flash Point not available
O=SCH2CHj
0
Molecular Formula: C14H27O5S,Na
Physical State: solid
Density: >1 g/cm3
LogwKow: n/a
Vapor Pressure: <10'6 mm Hg (E) LogwBCF: n/a
Water Solubility. Dispersible (E)
Applicable Function: surfactant
Other Solubilities: soluble in polar
organics
A-ll
-------
idixA
Chemistry and Fate
Stoddard Solvent
CAS# 8052-41-3
Chemical Properties and Information
Synonyms: Solvent naphtha; white spirits;
mineral spirits
Molecular Weight: 126.24 (LOWWT, C9H18)
Boiling Point: 150-210 °C; 149-208 °C (Merck)
Freezing Point: -70 °C
Vapor Pressure: 2 mm Hg at 20 °C
Vapor Density: 4.9 (air = 1)
Surface Tension: 0.027 - 0.05 N/m
Flash Point 41 °C; 38 °C (MerckJ
Heat of Vaporization: 284.3 J/g
Upper Explosive Limit: 6.0% (Chemcentral)
Lower Explosive Limit: 1.0%
Kauri Butanol Number: 27 - 45
Dielectric Constant: 2.00 - 3.00
Definition: A colorless, refined petroleum distillate that
is free from rancid or objectionable odors and that
boils in the range of approx. 149 - 205 °C.
Molecular Formula: Cn2n+2 (paraffins) and
CnH2n (cycloparaffins) (typical)
Log10Kow: 4.76*
Water Solubility: 0.0024 g/L*
Specific Gravity: 0.75 - 0.85
Refractive Index: 1.4278
Evaporation Rate: 0.12 (butyl acetate = 1)
Reactivity: 0
Flammability: 2
Ignitability: Y; Autoignition temp: 232 °C
Applicable Function: Cleaning solvent
*Water solubility and log K^, were estimated using the EPI program (SRC) for nonane (C9H20)
representing the most soluble component of Stoddard solvent. The water solubility average estimate for
23 C9 paraffins and cycloparaffins is 2.5 - 4.7x10'5 g/kg.
A-12
-------
Appendix A
Chemistry and Fate
140°F Solvent
CAS# 64742-88-7
Chemical Properties and Information
Synonyms: Solvent naphtha (petroleum),
medium aliphatic
Molecular Weight 126.24 (LOWWT, C9H18)
Boiling Point 183 -199 °C Ashland 140)
191 - 203 °C (Chemcentral 140)
187-206 °C (Shell Sol 140)
Vapor Pressure: 0.5 mm Hg at 20 °C
(Chemcentral 140)
Vapor Density. 5.4 (a1r= 1) (Ashland 140)
Flash Point 60 - 62.2 °C (typical)
Hildebrand Solubility Parameter.
7.6 cal1/2/cm3/2 (Chemcentral 140)
Kauri Butanol Number: 30 - 31
Dielectric Constant: 2.04 (Shell Sol 140)
Definition: Saturated hydrocarbons obtained
from the distillation of crude oil or natural
gasoline having carbon numbers predominantly
in the range of C9-C12 and boiling in the range
of 140 -220°C.
Molecular Formula: Cn2n+2 (paraffins) and
CnH2n (cycloparaffins) (typical)
Log10Kow: 4.76*
Water Solubility. 0.0024 g/L*
Specific Gravity: 0.78 at 25 °C (typical)
Refractive Index: 1.43 (Chemcentral 140)
Evaporation Rate: 0.08
-------
Chemistry and Fate
DF-2000 Solvent
Chemical Properties and Information
Synonyms: Hydrotreated heavy
naphtha (petroleum); Naphtha (petroleum),
hydrotreated and heavy, nonarom.
Molecular Weight. 84.16 (LOWWT, C6H12)
Bo///ng Point 191 - 205 °C (Exxon Chemical)
Freezing/Melting Point <-60 °C
Vapor Pressure: 1 at 20 °C (E)
Vapor Density: 5.90 (Air= 1) (calculated)
Flash Point: 64 °C (TCC) (typical)
Viscosity: 2.1 cSt at 15 °C (E)
Definition: A complex combination of
hydrocarbons obtained by treating a petroleum
fraction with hydrogen and catalyst. It consists
of hydrocarbons having carbon numbers
predominantly in the range of C6-C13 and
boiling in the range of approx. 65-230 °C.
Molecular Formula: Cn2n+2 (paraffins) and
CnH2n (cycloparaffms) (typical)
Log10Kow: 3.9*
Water Solubility: <0.01 at 15 °C
Specific Gravity: 0.77 at 15 °C
Refractive Index: n/a
Evaporation Rate: <0.1 ( n-butyl acetate = 1)
Reactivity: 0
Flammability: 2 (LEL: 1.3; UEL 8.8 @ 25 °C)(E)
Ignitability: Y; Autoignition temp: 338 °C (E)
Applicable Function: Cleaning solvent
*Log K^ was estimated using the EPI program
component of DF-2000 Solvent.
(SRC) for hexane (C6H12) representing the most soluble
A-14
-------
Appendix A
Chemistry and Fate
A.2 PERCHLOROETHYLENE ENVIRONMENTAL FATE SUMMARY
PCE is expected to biodegrade slowly in water and in soils. Aerobic and anaerobic
biodegradation, in water and soil, respectively, are estimated as taking months and hydrolysis as taking
years. Actual biodegradation rates will depend upon local soil conditions. In one study, trichloroethylene,
cis-l,2-dichloroethene, trans- 1,2-dichloroethene, chloroethene, and dichlormethane were produced as PCE
biodegraded over a 21-day period.
Groundwater contaminated by PCE has been found in a number of places; the contamination may
take place because PCE is more dense and less viscous than water. PCE's migration potential from a
landfill to groundwater is estimated as negligible to moderate and depends on local conditions. PCE is a
classic groundwater contaminant.
PCE's rate of volatilization depends upon the depth and turbulence of surface water. Using a
model that assumes a standard 1-meter depth stream, the volatilization potential is estimated as moderate.
Sorption to soil and sediment is low. The estimated half-life of PCE in stream or river water is 1.4 hours.
The estimated wastewater treatment removal efficiency, which depends mainly on volatilization, is 88
percent. Hydrolysis of PCE is expected to be slow compared with volatilization from surface water
(Versar, 1987). In the presence of sunlight, PCE is also expected to photooxidize in water (Versar, 1987).
A.3 HYDROCARBON SOLVENT ENVIRONMENTAL FATE SUMMARY
Stoddard solvent is expected to biodegrade slowly, with aerobic and anaerobic biodegradation
taking weeks to months. Migration to groundwater is negligible, and sorption to soil and sediment is very
strong. The estimated half-life for volatilization from water in rivers is 1.58 hours; the half-life for
volatilization from water in lakes is 6.11 days. The estimated removal efficiency in wastewater treatment
is 95 percent. The estimated half-life resulting from atmospheric oxidation is five hours.
Stoddard solvent's stratospheric ozone depletion potential is zero (USEPA, 1992). However,
Stoddard solvent is a potential VOC (lower level ozone) contributor and has global warming potential
(USEPA, 1992).
The 140°F solvent is expected to biodegrade rapidly, with aerobic and anaerobic biodegradation
taking days to weeks. Migration to groundwater is negligible, and sorption to soil and sediment is strong.
The estimated half-life for volatilization from water in rivers is 1.3 hours; the half-life for volatilization
from water in lakes is 5.2 days. The estimated removal efficiency in wastewater treatment is 99.9 percent
due to high volatilization and biodegradation. The estimated half-life resulting from atmospheric oxidation
is 9.4 hours.
The stratospheric ozone depletion potential of 140°F solvent is zero (USEPA, 1992). It is also a
potential VOC (lower level ozone) contributor and has global warming potential (USEPA, 1992).
A-15
-------
Appendix A
Chemistry and Fate
A.4 MACHINE WETCLEANING ENVIRONMENTAL FATE SUMMARY
Partial removal of chemicals from water often occurs during treatment in publicly owned treatment
works (POTWs). Two frequently encountered removal mechanisms are adsorption to sludge and
hydrolysis. Others include biodegradation and volatilization. An environmental fate summary (see Exhibit
A-3) presents information on adsorption to soils and sediments, ultimate biodegradation, and percent
removal in wastewater treatment and removal process.
Adsorption to soil and sediment is the tendency of a chemical to bind to the material at the bottom
layer of a water body (e.g., a river bed). This is significant because chemicals trapped at the bottom of a
river bed generally do not contaminate the drinking water supply.
Ultimate biodegradation, which occurs in water and soils, is the conversion of the carbon in an
organic chemical to carbon dioxide. This occurs when microorganisms break down a chemical to its
elemental state (e.g., carbon dioxide and ammonia). Once the chemical is in its elemental state, it is no
longer of concern.
Exhibit A-3. Environmental Fate Information for Machine Wetcleaning Chemicals3
Chemical
Name
Acetic acid
Cellulose gum
Citric acid
Ethoxylated sorbitan
monodecanoate
Laurie acid
diethanolamide
Methyl 2-sulfolaurate,
sodium salt
Sodium carbonate
Sodium citrate
Sodium laureth
sulfate
Sodium lauryl
isethionate
CAS
Number
64-19-7
9004-32-4
77-92-9
9005-64-5
120-40-1
4337-75-1
497-19-8
68-04-2
9004-82-4
7381-01-3
Adsorption
to Soil and
Sediment
low
strong
low
moderate
low
moderate
unspecified
low
unspecified
moderate
Time for
Biodegradation
days
weeks to months
days ,
days to weeks
days to weeks
days to weeks
unspecified
days
days to weeks
days to weeks
% Removal in
Wastewater
Treatment
90
50
90
90
90
90
zero
90
90
90
' No information is available for cocoamidopropyl betaine.
A-16
-------
Appendix A
Chemistry and Fate
REFERENCES
CAS. 1993. Chemical Abstracts Service. On-line search of Registry File. August.
Clark, B., J.G. Henry, and D. Mackay. 1995. Fugacity analysis and model of organic chemical fate in a
sewage treatment plant. Environ Sci Technol 29:1488-1494.
Meylan, W.M., and P.H, Howard. 1991. Bond contribution method for estimating Henry's Law
constants. Environ Toxicol Chem 10:1283-1293.
Meylan, W.M., and P.H. Howard. 1995. Atom/fragment contribution method for estimating octanol-water
partition coefficients, J Pharm Sci 84:83-92.
Meylan, W.M., P.H. Howard, and R.S. Boethling. 1992. Molecular topology/fragment contribution
method for predicting soil sorption coefficients. Environ Sci Technol 26:1560-1567.
Meylan, W.M., P.H. Howard, and R.S. Boethling. 1996. Improved method for estimating water solubility
from octanol/water coefficient. Environ Toxicol Chem 15(2): 100-3 06.
SRC. 1993a. Syracuse Research Corporation. National center for manufacturing sciences solvents
database. Syracuse, NY. Version 1.5. July 1.
SRC. 1993b. Syracuse Research Corporation. LOGKOW Program. Version 1.1 Oa. Syracuse NY
July 18.
USEPA. 1992. U.S. Environmental Protection Agency. Protection of Stratospheric Ozone: Final Rule
(57 FR 33754).
Versar, 1987. Versar, Inc. Physical/chemical properties, environmental fate and mobility, and monitoring
data for six halogenated solvents. Prepared by VERSAR, Inc. under Contract No. 68-02-4254,
Task 43. USEPA, Office of Pollution Prevention and Toxics. July 31.
A-17
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-------
APPENDIX B
ECOLOGICAL HAZARD METHODOLOGY
This appendix provides further background on the development of hazard profiles and
determination of the concern concentration.
B.I DEVELOPMENT OF HAZARD PROFILE
Chapter 3 presented a hazard profile consisting of three chronic and three acute effective
concentrations representing acute and chronic values for fish, aquatic invertebrates (daphnid), and algae for
each chemical. For most of the chemicals in the Cleaner Technologies Substitutes Assessment, measured
values from studies were generally not available, and structure-activity relationships (SARs) were used
instead as predictive measures.
SAR methods include Quantitative Structure Activity Relationships (QSARs), qualitative SARs,
or use of the best analog. The use of SARs by USEPA's Office of Pollution Prevention and Toxics
(OPPT) has been described (Clements, 1988). The use and application of QSARs for the hazard
assessment of new chemicals has been presented (Clements et al., 1993a). The development, validation
and application of SARs in OPPT have been presented by OPPT staff (Boethling, 1993; Clements et al
1993b; Lipnick, 1993; Nabholz et al., 1993; Newsome et al., 1993; Zeeman et al., 1993).
The predictive equations (QSARs) are used in lieu of test data to estimate a toxicity value for
aquatic organisms within a specific chemical class. The equations are derived from correlation and linear
regression analysis based on measured data; however, the confidence interval associated with the equation
is not used to provide a range of toxicity values.
B.2 DETERMINATION OF CONCERN CONCENTRATION
Concern concentration (CC) is the concentration of a chemical in the aquatic environment that, if
exceeded, may result in a significant risk. Concern concentrations are determined by applying assessment
factors (USEPA, 1984) to the effect concentrations in the hazard profile. These assessment factors
incorporate the uncertainty associated with toxicity data, laboratory tests versus field tests, measured versus
estimated data, and species sensitivity. For example, if only a single LC50 value for a single species is
available, there are several uncertainties to consider. First, how good is the value itself? If the same
laboratory or a different laboratory were to redo the test, would the value differ? Second, there are
differences in sensitivity (toxicity) among and between species that have to be considered. Is the species
tested the most or the least sensitive? In general, if only a single toxicity value is available, there is a large
uncertainty about the applicability of this value to other organisms in the environment, and a large
assessment factor (e.g., 1,000) is applied to cover the range of sensitivity known to exist among and
between organisms in the environment. Conversely, more information results in more certainty concerning
the toxicity values and allows the use of a smaller assessment factor. For example, if toxicity values are
derived from field tests, then an assessment factor of one is used.
B-l
-------
,. _, Ecological Hazard Methodology
Appendix B . . . —=
USEPA uses four assessment factors to set a CC for chronic risk: one, 10, 100, and 1,000. The
assessment factor used depends on the amount and type of toxicity data contained in the hazard profile and
reflects the amount of uncertainty about the potential effects associated with a toxicity value. In general,
the more complete the hazard profile and the greater the quality of the toxicity data, the more likely that a
smaller assessment factor is used. The following describes the use and application of the assessment
factors:
1. If the hazard profile only contains one or two acute toxicity values, the CC is set at
1/1,000 of the acute value.
2. If the hazard profile contains three acute values (base set), the CC is set at 1/100 of the
lowest acute value.
3 If the hazard profile contains one chronic value, the CC is set at 1/10 of the chronic value
if the value is for the most sensitive species. Otherwise, it is 1/100 of the acute value for
the most sensitive species.
4. If the hazard profile contains three chronic values, the CC is set at 1/10 of the lowest
chronic value.
5. If the hazard profile contains a measured chronic value from a field study, then an
assessment factor of 1 is used.
B-2
-------
Appendix B
Ecological Hazard Methodology
REFERENCES
Boethling, R.S. 1993. Structure activity relationships for evaluation of biodegradability in the EPA's
Office of Pollution Prevention and Toxics. Environmental Toxicology and Risk Assessment 2nd
Volume. ASTM STP 1216. J.W. Gorsuch, F.J. Dwyer, C.G. Ingersoll, and T.W. La Point. Eds.
American Society for Testing and Materials. Philadelphia, PA. pp. 540-554.
Clements, R.G. (Ed.). 1988. Estimating toxicity of industrial chemicals to aquatic organisms using
structure activity relationships. EPA-560/6-88-001. Environmental Effects Branch Health and
Environmental Review Division (7403), Office of Pollution Prevention and Toxics, U.S.
Environmental Protection Agency. Washington, DC. PB89-117592. National Technical
Information Services (NTIS), U.S. Department of Commerce. Springfield, VA.
Clements, R.G., J.V. Nabholz, D.W. Johnson, and M. Zeeman. 1993a. The use and application of QSARs
in the Office of Toxic Substances for ecological hazard assessment of new chemicals.
Environmental Toxicology and Risk Assessment. ASTM STP 1179. W.G. Landis, J.S. Hughes,
and M.A. Lewis, Eds. American Society for Testing and Materials. Philadelphia, PA. pp. 56-64.
Clements, R.G., J.V. Nabholz, D.W. Johnson, and M. Zeeman. 1993b. The use of quantitative structure-
activity relationships (QSARs) as screening tools in environmental assessment. Environmental
Toxicology and Risk Assessment. 2nd Volume. ASTM STP 1216. J.W. Gorsuch, J.F. Dwyer,
C.G. Ingersoll, and T.W. La Point, Eds. American Society for Testing and Materials
Philadelphia, PA. pp. 555-570.
Lipnick, R.L. 1993. Baseline toxicity QSAR models: A means to assess mechanism of toxicity for aquatic
organisms and mammals. Environmental Toxicology and Risk Assessment. 2nd Volume. ASTM
STP 1216. J.W. Gorsuch, F.J. Dwyer, C.G. Ingersoll, and T.W. La Point, Eds. American Society
for Testing and Materials. Philadelphia, PA. pp. 610-619.
Nabholz, J.V., R.G. Clements, M.G. Zeeman, K.C. Osborn, and R. Wedge. 1993. Validation of structure
activity relationships used by USEPA's Office of Pollution Prevention and Toxics for the
environmental hazard assessment of industrial chemicals. Environmental Toxicology and Risk
Assessment. 2nd Volume. ASTM STP 1216. J.W. Gorsuch, F.J. Dwyer, C.G. Ingersoll, and
T.W. La Point, Eds. American Society for Testing and Materials. Philadelphia, PA. pp.'571-590.
Newsome, L.D., D.E. Johnson, and J.V. Nabholz. 1993. Quantitative structure-activity predictions for
amme toxicity algae and daphnids. Environmental Toxicology and Risk Assessment 2nd
Volume. ASTM STP 1216. J.W. Gorsuch, F.J. Dwyer, C.G. Ingersoll, and T.W. La Point, Eds
American Society for Testing and Materials. Philadelphia, PA. pp. 591-609.
USEPA. 1984. U.S. Environmental Protection Agency. Estimating concern levels for concentrations of
chemical substances in the environment. USEPA, Office of Pollution Prevention and Toxics
Health and Environmental Review Division (7403), Environmental Effects Branch. Washington,
B-3
-------
Ecological Hazard Methodology
Zeeman MG J V. Nabholz, and R.G. Clements. 1993. The development of SAR/QSAR for use under
Z EPA'sToxic Substances Control Act (TSCA): An introduction. EnvironmentalToxicolog>-and
Risk Assessment. 2nd Volume. ASTMSTP1216. J-w-^^".^,CG.Inge«oll,
and T.W. La Point, Eds. American Society for Testing and Materials. Philadelphia, PA. pp.523-
539.
B-4
-------
APPENDIX C
HEALTH HAZARD SUMMARIES
This appendix reviews the available human health hazard data for each chemical/process
associated with commercial clothes cleaning. "Hazard" data include information from animal and/or
human studies on the inherent toxicity of a chemical/process. The data are presented under one of two
general categories: drycleaning (non-aqueous based) and wetcleaning (aqueous-based).
C.I DRYCLEANING
• Hazard data are presented on perchloroethylene and hydrocarbon solvents (data are presented for
Stoddard solvent, which is assumed to be a representative hydrocarbon used in drycleaning).
C.I.I Perchloroethylene
Summary
Inhalation of perchloroethylene (PCE) has caused neurotoxic effects; may cause cancer in liver,
kidney, and other organs; and may have developmental and reproductive effects. This section details these
hazards in the following subsections: absorption/metabolism; acute toxicity; irritation/sensitization;
subchronic/chronic toxicity; neurotoxicity; developmental/reproductive toxicity; mutagenicity; and
carcinogenicity. Appendix D contains the dose-response assessment for PCE, for both non-carcinogenic
and carcinogenic effects.
PCE does not have marked acute toxicity by inhalation. Lethal concentrations for laboratory
animals are in the range of several thousand parts per million (ppm). Deaths have been reported in humans
following unmeasured, but likely high, levels of exposure.
Neurotoxic effects are well established in both humans and animals following inhalation of air
containing PCE at a few hundred ppm for several hours. Humans exposed to short-term, non-lethal
inhalation exposures of PCE have exhibited neurotoxic effects (dizziness, drowsiness, and other signs of
central nervous system depression). Developmental effects have been seen in laboratory animals exposed
to several hundred ppm PCE by inhalation for 7 hours/day during the critical period of gestation and
suggest a potential for developmental effects in the fetuses of exposed pregnant women. But human data
regarding the potential of PCE to cause developmental and reproductive effects are inconclusive.
Chronic (long-term) exposure to PCE adds concern for carcinogenicity and kidney and liver
effects to those already mentioned. Kidney and liver effects have been seen in rats and mice exposed to
PCE at concentrations ranging from 10 to 20 ppm and above. Increased incidences of tumors have been
found in laboratory rats and mice following inhalation or ingestion exposure to PCE; however, controversy
surrounds each of the tumor end points concerning their relevance to humans. Existing epidemiologic
studies suggest there is "limited evidence" (IARC, 1995) for establishing a causal relationship between
PCE exposure and cancer in humans.
Available animal data indicate that PCE itself is not mutagenic, but the following PCE metabolites
have been shown to be mutagenic: perchloroethylene epoxide, trichloroacetaldehyde,
C-l ~ '
-------
,. _ Health Hazard Summaries
Appendix C —
dichloroacetaldehyde, monochloroacetaldehyde, trichloroacetic acid, and S-(l,2,2-trichlorovinyl) gluta-
thione Some of the metabolic pathways that generate mutagenic metabolites of PCE in animals may not
be operative in humans. The relevance of the mutagenic metabolites, therefore, to PCE's potential as a
human carcinogen is not firmly established. Recently, the the International Agency for Research on
Cancer (IARC) has classified PCE as a Group 2A carcinogen (probably carcinogenic to humans). Overall,
USEPA has judged the existing evidence as sufficient for classifying PCE as a probable human carcinogen
(group B2) USEPA's Science Advisory Board (the preface in USEPA, 1991) stated that the evidence of
PCE's toxicity places PCE on the continuum from group C (possible human carcinogen) to group B2
(probable human carcinogen). Their view was framed to encompass a concern for high PCE exposures,
which is consistent with the uncertainties regarding the modes of action associated with the several tumor
types.
Absorption/Metabolism
Absorption
Human data indicate that PCE is absorbed well following inhalation exposure (ATSDR, 1993)
although good, measured data on absorbed dose are not readily available. Dermal absorption, relative to
inhalation, can be approximately equal to the amount absorbed via inhalation at low exposure levels (e.g.,
60 ppm) or can be as low as 1% of the amount absorbed via inhalation at higher doses (e.g., 600 ppm)
(Riihimaki and Pfaffli, 1978; McDougal et al., 1990). While inhalation is expected to be the principal
route by which PCE enters the body, and is expected to be the principal route of exposure in the
drycleaning industry, dermal absorption cannot be ruled out as a potentially important route of entry ot
PCE into the body.
Data from studies in rats and mice indicate that PCE is also absorbed well by the oral route
(USEPA, 1985).
Metabolism—General Considerations
Once PCE is absorbed into the body, its metabolism is important, as much of the toxicity of PCE is
generally considered to result from its reactive metabolites. For example, studies show that several
parameters of liver toxicity (liver weight increase, liver triglyceride accumulation, serum SGPT activity)
vary linearly with the amount of PCE metabolized.
There are major differences among mice, rats, and humans in their ability to metabolize PCE.
Humans appear to metabolize PCE to a lesser degree than rats, and rats metabolize PCE to a lesser degree
than mice. One study shows that the amount of PCE undergoing metabolism is five to 10 times greater in
the mouse than in the rat (Schumann et al., 1980).
Human data indicate that the metabolism of PCE overall is relatively limited, as evidenced by the
fact that a high percentage of the chemical is excreted unchanged in the breath. In one study, volunteers
exposed to 72 or 144 ppm of PCE for 4 hours excreted 80-100% of the total uptake of PCE unchanged
(ATSDR, 1993).
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Appendix C
Health Hazard Summaries
The metabolism of PCE appears to be saturable in both humans and rodents. In humans and in
rats, saturation begins to occur at levels greater than or equal to 100 ppm (ACGIH, 1986). In mice,
saturation occurs at much higher levels, but the inhalation exposure level at which this process begins
could not be found. In one study (Odum et al., 1988, as reported in ECETOC, 1990), saturation had not
occurred in mice exposed to 400 ppm PCE for six hours.
Metabolism—Pathways (from USEPA, 1991, unless noted otherwise)
PCE is metabolized through at least two distinct pathways. Oxidative metabolism via the
cytochrome P-450 system, which probably occurs mainly in the liver, is believed to be the primary
pathway. This pathway is operative in both humans and rodents. The major metabolite of this pathway is
trichloroacetic acid, which is excreted in the urine. Trichloroacetic acid and other metabolites that have
been demonstrated or postulated to occur by this pathway—dichloroacetic acid (DCA), PCE epoxide, and
mono-, di-, and trichloroacetaldehyde (or, chloral hydrate)—are cytotoxic/genotoxic or carcinogenic
(trichloracetic acid, DCA, and chloral hydrate produce liver tumors in mice).
' A secondary but potentially important pathway of PCE metabolism is glutathione conjugation, by
which the liver conjugates PCE with glutathione to form 1,2,2-trichlorovinylglutathione (TCVG). This
metabolite, in turn, is transformed in the kidney to 1,2,2-trichlorovinylcysteine (TCVC). TCVC is further
metabolized in the kidney by p-lyase to yield an unstable thiol that may give rise to cytotoxic and
mutagenic intermediates.
In vitro studies (Green et al., 1990) on human liver samples failed to detect glutathione
conjugation with PCE, although glutathione conjugation has been demonstrated in rats and mice (in vivo
and in vitro}. Because of the very low levels of enzyme activity being measured and the limited number of
human liver samples tested, however, it is premature to conclude that humans are unlikely to carry out this
metabolic step. In a more recent study, TCVC has been identified in the urine of workers exposed to PCE,
indicating that glutathione-dependent bioactivation of PCE is operative in humans (Birner et al.. 1996).
The p-lyase pathway has also been demonstrated to exist in human kidney (proximal tubule) cells
in two in vitro studies. In one of these studies, the rate of metabolism of chemically synthesized TCVC by
P-lyase was up to 10 times higher in the rat kidney than either the mouse or human kidney (Green et al.,
1990, as reported in ECETOC, 1990). Although only 11 human kidney samples were used in this study,
the variation in P-lyase activity was remarkably small—rates ranged from 0.1 to 0.56 nmol/minute/mg
protein.
Acute Toxicity
The LD50/LC50 values for PCE in mice and rats show that the chemical does not have marked acute
toxicity. A 4-hour inhalation LC50 of 5,200 ppm (35.3 mg/L) for female albino mice was established in an
earlier study (ATSDR, 1993). In an NTP (1986, as cited in ATSDR, 1993) study, the highest
concentration for a 4-hour exposure that did not produce death in B6C3F1 mice or F344 rats was 2,445
ppm; the lowest concentrations producing mortality were 2,613 ppm in mice and 3,786 ppm in rats. Single
oral LD50 values of 3,835 and 3,005 mg/kg were determined for male and fema|e rats treated by gavage.
Death occurred within 24 hours after dosing and was preceded by tremors, ataxia, and central nervous
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Health Hazard Summaries
system depression (ATSDR, 1993). In other studies (Regulatory Toxicology and Pharmacology, 1994),
oral LDj0 values ranged from 8,800 to 10,800 mg/kg for mice.
Death has been reported in humans following unmeasured, but likely high, levels of exposure
(Lukaszewski, 1979; Levine et al., 1981, both as reported in ATSDR, 1993).
Irritation/Sensitization
No data have been located regarding the irritation/sensitization potential of PCE exposure in
humans or animals.
Subchronic/Chronic Toxicity
Kidney
In rodents, renal toxicity has been demonstrated after short-term and chronic inhalation exposures.
Male rats exposed to 1,000 ppm for 10 days developed hyaline droplets in proximal tubules, but no lesions
were present after exposure to 400 ppm for 28 days. Renal tubular karyomegaly occurred in both sexes ot
mice exposed to 200, 400, 800, and 1,600 ppm for 13 weeks, but did not occur in mice exposed to 100
ppm Kidney lesions did not occur in rats similarly exposed to 1,600 ppm (NTP, 1986, as cited in
ATSDR 1993) In the chronic inhalation study, both sexes of F344 rats and B6C3F1 mice developed
renal tubular cell karyomegaly at all exposure concentrations. This alteration was accompanied by low
incidence of renal tubular cell hyperplasia in male rats. Thus, a no-observed-adverse-effect level
(NOAEL) for renal toxicity was not established in a lifetime bioassay.
Compound related kidney damage has been reported in animals after oral exposure. Daily
administration of 1,000 mg/kg by gavage to male F344 rats for 10 days produced an increase in protein
droplets correlated with an increased amount of a-2u-globulin and peroxisomal proliferation; these effects
were not seen in female rats. Male rats exposed to 1,500 mg/kg by gavage for 42 days developed male-
specific nephropathy. Male B6C3F1 mice exposed to 1,000 mg/kg by gavage for 10 days had peroxisomal
proliferation in the kidneys. Osborne-Mendel rats and B6C3F1 mice of each sex were exposed by gavage
for 78 weeks, followed by observation periods of 32 weeks (rats) and 12 weeks (mice) in a carcmogemcity
bioassay (NCI, 1977, as cited in USEPA, 1985). Average doses for the study were 536 and 1,072
mg/kg/day for male mice, 386 and 772 mg/kg/day for female mice, 471 and 941 mg/kg/day for male rats,
and 474 and 949 mg/kg/day for female rats. Toxic nephropathy occurred at all dose levels in both sexes.
The nephropathy was characterized by degenerative changes in the proximal convoluted tubules with
cloudy swelling, fatty degeneration, and necrosis of the tubular epithelium and hyalin intralummal casts.
Thus, the lowest dose levels in this study (386 to 536 mg/kg/day for mice and 471 to 474 mg/kg/day for
rats) produced nephrotoxicity.
Symptoms of renal dysfunction, including proteinuria and hematuria, have been associated with
accidental exposure of humans to anesthetic concentrations of PCE vapor. Weak or no renal effects,
depending on the parameters evaluated, were reported in people with chronic occupational exposure
(average exposures of 10 to 21 ppm). No studies were found regarding renal effects in humans after oral
exposure (ATSDR, 1993).
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Health Hazard Summaries
Mutti et al. (1992) recently evaluated a variety of parameters in blood (4) and urine (19)
potentially indicative of kidney damage in PCE-exposed drycleaning workers (n=50) versus matched
controls. PCE exposure was evaluated by measuring PCE in the workplace air (ranging from trace to 85
ppm, median = 15 ppm) and concomitant analysis of PCE in blood. Results showed significant differences
between exposed and control groups for 2/4 blood parameters and 9/19 urinary parameters; however, the
authors noted a lack of association between kidney dysfunction and duration of PCE exposure.
Liver
The hepatotoxic effects of PCE have been characterized in a number of laboratory studies. In
general, fatty degeneration, enlargement, cellular vacuolization, and necrosis have been observed in
rodents following inhalation or oral exposure for about 90 days or longer. Mice appear to be more
susceptible to hepatotoxic effects than rats. In a 14-day inhalation study, male B6C3F1 mice exposed to
875 or 1,750 ppm had hepatocellular vacuolization; females exposed to the highest dose also showed this
lesion. Liver lesions differed markedly between mice and rats after longer duration exposure. In a 13-
week study (6 hours/day, 5 days/week), male mice exposed to 200 ppm and higher concentrations had
mitotic alterations in the liver, while both sexes had leukocytic infiltrations, centrilobular necrosis, and bile
stasis at 400, 800, and 1,600 ppm. Rats, however, had liver congestion at 200 ppm but no other lesions at
any exposure concentration. Hepatocellular degeneration and necrosis occurred in male mice exposed to
100 and 200 ppm for 103 weeks and in females exposed to 200 ppm. Liver lesions were not reported in
rats chronically exposed to these concentrations (NTP, 1986, as cited in ATSDR, 1993). The hepatic
lesions in male mice were dose-dependent, and no NOAEL was established for the hepatotoxic effects.
Another shorter-term (30-day) inhalation study with NMRI mice showed liver effects at the lowest
concentration, 9 ppm. Mice continuously (24 hours/day) exposed to 37, 75, or 150 ppm developed
hepatocellular vacuolization and enlargement. Absolute liver weights were significantly elevated at
exposure concentrations of 9 ppm and higher. Liver weights were still increased (10%) 120 days after
exposure to the highest concentration. In another study with mice and rats, light microscopic and ultra-
structural liver lesions were correlated with levels of cyanide-insensitive palmitoyl CoA oxidase, a marker
for peroxisomal p-oxidation (ATSDR, 1993). Animals were exposed to 200 ppm for 28 days or 400 ppm
for 14, 21, or 28 days. In all exposed mice, centrilobular hepatocellular vacuolization corresponded to
lipid accumulation, and cytoplasmic eosinophilia corresponded to peroxisomal proliferation with a
significant increase in the marker enzyme. Exposed male rats in both dosage groups and female rats at 400
ppm had hepatocellular hypertrophy but no increase in peroxisomes (ATSDR, 1993).
The lowest effective doses in the chronic exposure study and the shorter-term (30 day) inhalation
study differ by approximately an order of magnitude. Nine ppm may be close to a NOAEL since no
microscopic lesions were observed at this dose. The quantitative differences in the lowest effective dose
between the two studies may be related to the length of exposure each day (6 versus 24 hours) and/or the
strain of mice.
The liver is also a target organ in rodents after oral administration of PCE (ATSDR, 1993).
Gavage doses of 1,000 mg/kg/day for 10 days to male B6C3F1 mice increased relative liver weights and
elevated cyanide-insensitive palmitoyl CoA oxidase levels. The same dose given to F344 rats did not
increase enzyme levels above controls, although relative liver weights increased. Toxic effects induced in
male Swiss Cox mice by oral gavage at doses of 20, 100, 200, 500, 1,000, 1,500, or 2,000 mg/kg/day, 5
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dixC
Health Hazard Summaries
days/week for 6 weeks, were increased relative liver weights and triglycendes beginning at 100
mg/ke/day decreased glucose-6-phosphate and increased serum alanine aminotransferase at 500
mi/kg/day and hepatic lesions. Lesions consisted of hepatocellular hypertrophy, karyorrhexis, necrosis,
polyploidy, and vacuolization. The NOAEL for this study was 20 mg/kg/day.
The liver is a target organ in humans, particularly in those exposed in occupational settings. There
have been two recent occupational exposure studies that reported subtle liver effects in PCE-exposed _
dry-cleaning workers (Gennari et al., 1992, and Brodkin et al., 1995). Gennari et al. found a statistically
significant increase in total serum gamma glutamyltransferase (GOT) in PCE-exposed workers (n=141)
versus controls (n=130) drawn from unexposed university staff/students with a similar age/sex
composition. A similar difference was not observed in other enzyme levels measured (alkaline
phosphatase [ALP], lactic acid dehydrogenase [LDH], aspartate aminotransferase [AST] alanine
aminotransferase [ALT], and 5'-nucleotidase [5'-NU]). Also, none of the workers showed any clinical
signs of liver disease. The reported levels of PCE in the workplace air on the day the blood samples were
drawn was 11.3 ppm ± 4.0 ppm.
Brodkin et al (1995) report a new technique (ultrasonography) to assess subclinical liver toxicity
in PCE-exposed workers. The authors compared the ultrasonographic results with the results of traditional
liver function tests (serum measurements of ALT, GGT, AST, and ALP). Results suggest that
ultrasonography, in which parenchymal changes were noted, was more sensitive than the serum liver
enzyme levels in showing a difference between exposed drycleaning operators (n=29, mean PCE exposure
= 16 ppm) and non-exposed laundry workers (n=29).
Saland (1967) reported on nine firemen who were exposed to high concentrations of PCE fumes
for approximately 3 minutes in the cellar of a drycleaning facility. Transient increases in SGOT (8/9),
decreases in white blood count (3/9), and hepatomegaly (1/9) were observed.
There is only one report of adverse effects on the liver from oral ingestion in humans; obstructive
jaundice and hepatomegaly were reported in an infant exposed via breast milk (ATSDR, 1993). The
concentrations that produced hepatotoxic effects in the infant are not known.
Other Effects
Osborne-Mendel rats received PCE in corn oil by gavage at doses of 316, 562, 1,000, 1,780, or
3 160 mg/kg for 6 weeks. Deaths (number unspecified) occurred in both males and females at the two
highest doses but not at 1,000 mg/kg or lower (NCI, 1977, as cited in ATSDR, 1993). In a 14-day
inhalation exposure study, mortality occurred in rats exposed to 1,750 ppm but not in mice. Compound
related mortality did not occur in either species at exposure concentrations of 875 ppm or lower. In a 13-
week inhalation study, mortality occurred in rats and mice exposed to 1,600 ppm but not to concentrations
of 800 ppm or lower (NTP, 1986, as cited in ATSDR, 1993).
There have been case reports of cardiovascular, immunologic, or respiratory toxic effects in
humans. For the first two systems, alternative explanations preclude evaluating the significance of the
findings in the case reports. Respiratory irritation appears to occur in humans exposed to concentrations of
PCE as low as 216 ppm for 45 minutes to 2 hours (ATSDR, 1993).
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Health Hazard Summaries
Neurotoxicity
The brain is a major target organ in humans exposed to PCE by inhalation. It is generally agreed
that acute exposure to high concentrations can result in narcosis (Regulatory Toxicology and
Pharmacology, 1994) and other reversible mood and behavioral changes, (Coler and Rossmiller, 1953:
Lob, 1957; Eberhardtand Freundt, 1966; Gold, 1969; Stewart, 1969; Bagnell and Ellenberger, 1977, all as
reported in USEPA, 1985). No behavioral effects were reported in humans after exposure to 106 ppm for
1 hour, and symptoms of dizziness and drowsiness were reported after exposure to 216 ppm for 45 minutes
to 2 hours. Coordination was impaired after exposure to 280 ppm for 2 hours or 600 ppm for 10 minutes
(see USEPA, 1985).
More recent human studies have supported earlier findings with animals indicating that chronic
exposure to low doses of PCE may have adverse effects on the nervous system. Stewart et al. (1981) and
Hake and Stewart (1977, as cited in ATSDR, 1993) found that electroencephalogram (EEC) responses
reflect a very sensitive measure of central nervous system depression. These controlled studies in healthy
human adults indicate significant EEG effects following PCE exposures of 100 ppm for 7.5 hours/day
over 5 days; and no effects following PCE exposures of 20 ppm for 7.5 hours/day over 5 days. In a
clinical study of 65 drycleaning personnel, Echeverria et al. (1995) reported neurobehavioral deficits after
3 or more years of exposure to concentrations below 50 ppm. Deficits were seen on behavioral tasks
designed to measure frontal and limbic lobe functions of the brain.
Concentrations between 216 and 1,000 ppm PCE over varying exposure durations result in reports
of dizziness, faintness, headache and nausea (see ATSDR, 1993). Collapse, coma, and seizures have
occurred following exposure to higher concentrations of PCE fumes, such as 2,000 ppm after as little as 5
to 7 minutes (Carpenter, 1937; Hake and Stewart, 1977; Morgan, 1969; all as cited in ATSDR, 1993).
Animal studies have reported similar neurological effects of inhaled PCE. At high concentrations
(greater than 1,750 ppm), effects of hyperactivity, ataxia, hypoactivity, and loss of consciousness have
been reported in rodents (Friberg et al., 1953; NTP, 1986; Rowe et al., 1952, all as reported in ATSDR
1993).
Developmental/Reproductive Toxicity
Most of the information presented in this section was obtained from review documents prepared by
USEPA (USEPA, 1985, 1988) and other organizations (ATSDR, 1993). This report focuses on the effects
of PCE via inhalation, as this route is of primary concern for human exposure.
Available human data have been inconclusive with regard to the potential of PCE exposure to
cause developmental and reproductive toxicity. In animals, however, PCE was shown to be
developmentally toxic by causing decreased fetal body weights in mice (altered growth) and increased
resorptions in rats (death of the developing organism) exposed by inhalation at the only dose tested, 300
ppm.
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Health Hazard Summaries
Human Data
Some of the available human data suggest that occupational exposure to PCE in the drycleaning
industry may be associated with adverse developmental/reproductive effects (e.g., an increase in
spontaneous abortions and menstrual disorders). Other studies have been unable to find any such
association Due to the discrepancy in findings and the numerous limitations associated with these studies
(i.e., small sample populations, failure to account for confounding factors, poor or no exposure data,
inadequate study methodology, etc.) no definitive conclusions can be drawn.
Eskenazi et al. (199 la) compared the reproductive outcomes of wives of men exposed to PCE in
the drycleaning industry with wives of laundry workers. The numbers of pregnancies, the standardized
fertility ratios and the rates of spontaneous abortions were similar for both groups, after consideration of a
variety of possible contributing factors. Wives of drycleaners did have a slightly longer time to conception
compared with the wives of laundry workers, but inadequate sample size and broad exposure indices
prevent definite conclusions from being drawn. Sallmen et al. (1995) reported a similar effect, defined as
the number of menstrual cycles that occurred prior to a desired pregnancy, in women exposed to
drycleaning solvents, including PCE.
Subtle changes in semen quality were noted in specimens from drycleaning workers compared
with those from laundry workers (Eskenazi et al., 1991b). On average, standard clinical measurements
showed that the drycleaners' semen was within normal limits. However, sperm of drycleaners were
significantly more likely to be round and less likely to be narrow. These effects were related to expired air
levels of PCE and to an exposure index based on job tasks. Also, sperm of drycleaners tended to swim
with greater amplitude of lateral head displacement (a finding that correlated with expired air levels of
PCE). The authors concluded that additional studies are required to determine whether these changes are
associated with changes in fertility.
A small scale exploratory study described menstrual disorders in drycleaning workers (Zielhuis et
al., 1989, as cited in ATSDR, 1993). Limitations of the study include lack of exposure measurement data,
methodological problems (self-administered questionnaire with no follow-up, and failure to account for
various confounding factors such as smoking, alcohol consumption, and medicinal drugs), and a relatively
small study population.
Several recent case control studies of female drycleaning workers in Nordic countries suggest that
these women had an increased risk of spontaneous abortion (Ahlborg, 1990; Kyyroenen et al., 1989; both
as cited in ATSDR, 1993). Limiting factors include a low number of pregnancies among exposed women
(Ahlborg, 1990), as well as a small group of exposed affected workers and biological monitoring not
concurrent with the first trimester of pregnancy (Kyyroenen et al., 1989).
Olsen et al. (1990) conducted a combined analysis of data from Norway, Sweden, Denmark, and
Finland, which includes data from the Ahlborg and Kyyroenen et al. studies mentioned above. They used
meta-an'alysis (a statistical procedure which combines quantitative results across studies) and other
statistical procedures to evaluate the data. Practical problems, however, caused several differences in the
study design and precluded use of a common Nordic study protocol. Risks for reproductive failures in
relation to births (congenital malformations, still births, and low birth weights) showed no elevated risk
related to exposure in the studies from Sweden, Norway, or Finland when analyzed together. The relative
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Appendix C
Health Hazard Summaries
risk (odds ratio) was significantly elevated for all types of reproductive failures combined (reproductive
failures in relation to births plus spontaneous abortions) for the high exposure group (drycleaning plus spot
removal at least 1 hour/day) for Sweden, Denmark, and Finland combined, and for spontaneous abortions
in the high exposure group for Finland only. Because of the low plant participation rate for Sweden,
Norway and Finland combined (54%), inability to control for various lifestyle factors known to influence
pregnancy outcome, and the questionable utility of combining data sets in the meta-analysis (i.e.,
heterogeneity of the studies with respect to their design, methodology, cohort selection, exposure criteria,
endpoints, sample sizes, etc.), interpretations of these findings should be viewed with caution.
Spontaneous abortions and birth defects occurred at a higher incidence in Italian drycleaning
workers than in housewives, but this difference was not statistically significant (Bosco et al., 1987, as cited
in ATSDR, 1993). No increase in spontaneous abortion rates for laundry and drycleaning workers in
Canada was detected in a cross-sectional study (McDonald et al., 1986, as cited in ATSDR, 1993).
Animal Data
Several studies on the developmental and reproductive toxicity of perchloroethylene (PCE) have
been found. In one of these studies, PCE caused a statistically significant decrease in fetal body weights in
mice, and increased resorptions in pregnant rats exposed to 300 ppm PCE for 7 hours/day on gestation
days 6-15 (Schwetz et al, 1975). Although this is a single-dose study, the slight maternal toxicity (slightly
reduced body weight gain) seen indicates that the dose was not excessively high.
Another developmental toxicity study in rats showed, in the absence of maternal toxicity, a
statistically significant reduction of body weight plus excess skeletal and soft tissue variations in fetuses of
dams exposed to 1,000 ppm (Tepe et al., 1982, as cited in USEPA, 1985).
Hardin et al. (1981, as cited in ATSDR, 1993) evaluated the.developmental toxicity for a selected
group of chemicals using a single concentration of 500 ppm PCE in Sprague Dawley rats and New
Zealand white rabbits, exposed 6-7 hours/day on gestation days 1-19 and 1-24, respectively. There was no
evidence of feto/maternal toxicity; however, the study had limitations. It used only one dose level, and
portions of the study were done in different laboratories.
Narotsky and Kavlock (1995) tested nine pesticides, solvents, and industrial chemicals, in timed-
pregnant Fischer 344 rats given PCE once daily by gavage at doses of 0, 900, or 1,200 mg/kg/day on
gestation day 6-19. Litters delivered by dams were examined on postnatal day 1, 3, and 6. All compounds
exhibited dose-related maternal toxicity as manifested by alterations in weight gain. Observed
developmental effects for PCE consisted of micro-/anophthalmia (eye defects), dose-related full-litter
resorption, delayed parturition, increased post-natal losses, and reductions in fetal weights. The authors
state this is the first report of developmental malformations for PCE, although previously reported studies
used doses not shown to be maternally toxic. In this study, PCE produced developmental toxicity at doses
that were also maternally toxic. However, full-litter resorption was not observed with other chemicals
tested in the presence of maternal toxicity, and therefore the authors suggest there may not be a causal
relationship, for PCE, between maternal and developmental effects.
Moreover, the data are consistent with effects observed in Long Evans rats when trichloroacetic
acid, a metabolite of PCE, was administered by gavage at doses of 0, 330, 800, 1,200, and 1,800
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Appendix'
Health Hazard Summaries
mg/kg/day (Smith et al., 1989, as cited in Davidson and Beliles, 1991). In that study, the authors
concluded the lowest-observed-adverse-effect level (LOAEL) for developmental toxicity to be 300
mg/kg/day, based on effects such as full-litter resorption, cardiac malformations, and micro-/anophthalmia.
Given this, Narotsky and Kavlock (1995) suggested that trichloroacetic acid may be the primary
developmental toxicant associated with PCE exposure.
Two studies on the reproductive toxicity of PCE have been found. Carpenter (1937), as cited in
ATSDR (1993), exposed rats to 70, 230, and 470 ppm PCE by inhalation for 28 weeks. Although this
study has numerous limitations, including nonstandard protocols and inadequate controls, no adverse
effects on reproductive performance, as measured by the number of pregnancies, numbers of litters
conceived, and number of offspring per litter, were observed.
The second study is a reproductive toxicity study of PCE by the inhalation route (Tinston, 1995).
Initially, groups of 24 male and female F0 parental Sprague Dawley rats were exposed for 6 hours/day to 0,
100, 300, or 1,000 ppm PCE vapor. Prior to being housed for mating, the rats were exposed to these
dosages 5 days/week for 11 weeks and were then exposed daily for up to 21 days. Following mating,
males and females were exposed daily until termination and gestation day 20, respectively. An F,A litter
was produced from the first generation by daily exposure of dams and their litters to the dosages on post-
partum day 6-29, at which time a second generation of parents, F,, was selected and then subsequently
exposed to the same dosages of PCE 5 days/week for 11 more weeks prior to mating.
Three additional litters were produced from the F, parental matings, F2A, F2B, and F2C. Each of
these three litters were exposed to different dosing regimes. Dams and litters from the F2A litter were
exposed during lactation on post-partum day 6-29 to 0 and 100 ppm or on post partum day 7-20 to 300
ppm. No exposure was conducted at the 1,000 ppm dose level. The F2B dams and their litters, which
were obtained from mating the control, 300, and 1,000 ppm dose groups of the F,, were not exposed to
PCE during lactation. The F2C litter was produced by mating males in both the control and 1,000 ppm
dose groups with unexposed females.
A LOAEL of 300 ppm for adult toxicity was established based on central nervous system
depression, decreased respiration rate during or immediately following exposure, decreased parental body
weight gain, increased kidney weight with associated histopathological effects, and increased absolute liver
weight. In addition, the effect on kidney and liver weights was more pronounced in adult males.
A LOAEL of 300 ppm was indicated for reproductive toxicity based on statistically significant
reductions in number of live births, litter sizes, post-natal survival indices, and pup and testis weight.
Mutagenicity
Available data on PCE have not clearly demonstrated it to be mutagenic (USEPA, 1985, 1991).
Most of those data indicate that it is not mutagenic, or at most weakly mutagenic. It is believed that certain
commercial or technical preparations of PCE may contain mutagenic impurities and/or stabilizers that
contribute to the mutagenicity of PCE under test conditions.
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Appendix C
Health Hazard Summaries
However, available data on metabolites (perchloroethylene epoxide, trichloroacetaldehyde,
dichloroacetaldehyde, monochloroacetaldehyde, trichloroacetic acid, S-(l,2,2-trichlorovinyl) glutathione)
of PCE indicate that these metabolites are mutagenic.
Carcinogenicity
'•'- Human Data
A variety of epidemiologic studies have been carried out in occupational and residential
populations. Most of these studies have been conducted in populations exposed to a mixture of solvents,
making it difficult to ascribe the results to PCE alone. In addition, limitations in the study designs, expo-
sure characterization, impact of potential confounding factors (e.g., smoking, alcohol consumption,
ethnicity, and socioeconomic status) and statistical considerations (e.g., having multiple endpoints) make
these studies inadequate overall for establishing a causal relationship between PCE exposure and cancer in
humans.
Occupational Studies
USEPA (1985) reviewed a number of occupational studies (Blair et al., 1979; Duh and Asal,
1984; Kaplan, 1980; Katz and Jowett, 1981; and Lin and Kessler, 1981; all as cited in USEPA, 1985);
however, only the Kaplan (1980) study could verify exposure to PCE. The 1985 USEPA review
acknowledged an association between cancer and employment in the drycleaning industry, but the lack of
PCE-specific exposure information precluded identifying PCE as a causative agent. A more recent review
of the epidemiologic studies of PCE also concluded that they provide inadequate evidence for an increased
cancer risk associated with PCE (ATSDR, 1993).
Since the ATSDR review was completed, at least one epidemiologic study has been updated. In
the original report, its overall cohort (i.e., 1,690 drycleaning workers exposed to PCE as well as other
solvents) had a significant excess of mortality from bladder, kidney, and cervical cancer, the latter being
attributed to the low socioeconomic status of the cohort (Brown and Kaplan, 1987, as reported in ATSDR,
1993). A subcohort of 615 workers employed only in shops where PCE was the primary solvent (referred
to as the PCE-only cohort), were not found to be at any increased risk for cancer mortality at any site
analyzed. In an 8-year follow-up (Ruder et al., 1994), statistically significant excesses of bladder,
esophageal, and intestinal cancer deaths were observed in the overall cohort. In the PCE-only subcohort,
no increases in mortality were identified for any cancer site. When duration (greater than or equal to five
years' employment) and latency (greater than or equal to 20 years from first exposure to diagnosis of
disease) were considered in the analysis, however, a significant excess of esophageal cancer was noted in
the subcohort (Ruder et al., 1994). Although smoking and alcohol are both potential risk factors for
esophageal cancer, the investigators failed to determine the smoking and alcohol habits of the cohort. The
authors indirectly explored the possible influence of these confounding factors and concluded that they
were not important, based largely on the low lung cancer mortality rates and the low liver cirrhosis rates;
both of which would have been expected to be higher if either heavy smoking or heavy alcohol use were
involved. Coupled with other study weaknesses, such as the lack of quantitative exposure information,
these confounding factors limit the interpretation of the findings.
C-ll
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Appendix C
Health Hazard Summaries
Finally, IARC (1995) recently reviewed the cancer epidemiology on PCE alone, and the
drycleaning industry as an occupation. IARC concluded there was limited evidence in humans for the
carcinogenicity of PCE, based on studies showing elevated risks for esophageal cancer, non-Hodgkin's
lymphoma, and cervical cancer (IARC, 1995).
Residential Studies
A study conducted among Upper Cape Cod, Massachusetts, residents exposed to PCE-
contaminated well water (Aschengrau et al., 1993) explored the relationship between exposure and the
incidence of bladder and kidney cancers and leukemia. The authors noted an elevated relative risk for both
leukemia (with and without consideration of latency) and bladder cancer (without consideration of latency)
among "ever-exposed" subjects as compared to a control group. However, these results are difficult to
interpret due to poor exposure measurements/modeling and the lack of substantial differences in exposure
between the cases and controls.
Animal Data
The evidence of carcinogenicity of PCE is based primarily on the results of two long-term
bioassays in rodents. An earlier study conducted by NCI (1977, as cited in USEPA, 1985) reported
increased hepatocellular carcinomas in male and female mice following PCE exposure by gavage. In a
more recent bioassay by inhalation (NTP, 1986, as cited in ATSDR, 1993), there were also significantly
increased incidences of liver tumors in male and female mice exposed to PCE. In addition, marginally
increased incidences of mononuclear cell leukemia were found in male and female rats; low incidences of
kidney tumors occurred in treated male rats.
In the gavage study (NCI, 1977), groups of 50 Osborne-Mendel rats and 50 B6C3F1 mice of each
sex were exposed to PCE in corn oil 5 days/week for 78 weeks, followed by observation periods of 32
weeks (rats) and 12 weeks (mice). Time weighted average (TWA) doses were 471 or 941 mg/kg/day for
male rats, 474 or 949 mg/kg/day for female rats, 536 or 1,072 mg/kg/day for male mice, and 386 or 772
mg/kg/day for female mice. Groups of 20 untreated and vehicle-treated rats and mice of each sex served as
controls. PCE induced a statistically significant increase In the incidence of hepatocellular carcinomas in
both high- and low-dose male and female mice. Incidences in the untreated control, vehicle control, low-
dose, and high-dose groups were 2/17, 2/20, 32/49, and 27/48, respectively, in male mice, and 2/20, 0/20,
19/48, and 19/48, respectively, in female mice. No increases in tumor incidences were observed in treated
rats. However, the rat study was deemed inconclusive because of high mortality of the animals.
In the inhalation study (NTP, 1986), groups of 50 F344/N rats of each sex were exposed to 0, 200,
or 400 ppm PCE, and groups of 50 B6C3F1 mice of each sex were exposed to 0, 100, or 200 ppm PCE.
Exposures were 6 hours/day, 5 days/week, for 103 weeks. Increased incidences of mononuclear cell
leukemia were found in the treated male rats (28/50 in controls, 37/50 at low dose, 37/50 at high dose) and
female rats (18/50 in controls, 30/50 at low dose, and 29/50 at high dose). The increased incidences in the
males were borderline significant; the increases in females were clearly significant. Low incidences of
renal tubular cell adenomas or adenocarcinomas (1/49, 3/49, 4/50) occurred in male rats. The kidney
tumor incidence was not statistically significant; however, such tumors are rare in control F344/N rats. In
mice, there were significantly increased incidences of hepatocellular carcinomas in males (7/49, 25/49,
26/50, respectively) and in females (1/48, 13/50, 36/50, respectively).
C-12
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Appendix C
Health Hazard Summaries
Overall Evidence
Based on these bioassay data, which show increased incidences of tumors at three different sites
and in two animal species, together with its evaluation of several epidemiological studies including Ruder
et al. (1994), IARC (1995) classified PCE as a group 2A carcinogen; i.e., probably carcinogenic to
humans.
Although PCE increased the incidence of tumors at three different sites and in two rodent species,
controversy surrounds each of the tumor endpoints regarding their relevance to humans. Mononuclear cell
leukemia is a common tumor that occurs spontaneously in F344/N rats. Furthermore, mononuclear cell
leukemia is a rodent-specific tumor with no human correlate. Therefore, the biological significance of the
marginally increased incidences of mononuclear cell leukemia observed in rats is considered by some to be
questionable. Subsequent studies on the mechanisms of PCE carcinogenesis have suggested that the
mouse liver tumors and male rat kidney tumors observed in the bioassays may be species specific;
uncertainties exist regarding their relevance to humans.
In both carcinogenicity bioassays of PCE, a significant increase in hepatocellular carcinoma was
observed in male and female mice but not rats. Based on species differences in metabolism of PCE to
trichloroacetic acid and in hepatic peroxisome proliferation between rats and mice, it has been suggested
that PCE-induced hepatic carcinogenesis may be related to peroxisome proliferation and toxicity of
trichloroacetic acid (Odum et al., 1988, as cited in ECETOC, 1990). As human liver cells are even less
efficient metabolizers of PCE (to trichloroacetic acid) than rats and are generally unresponsive to
peroxisome proliferating agents, it would be unlikely that PCE exposure could lead to liver cancer in
humans if this is the mechanism of action in mice.
Several studies have sought an explanation for the kidney tumors seen in male rats exposed to
PCE. Male rats given high doses of PCE by gavage have been found to accumulate the protein
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dixC
Health Hazard Summaries
The Health Assessment Document for PCE (USEPA, 1985) and its Addendum (USEPA, 1986)
were reviewed by USEPA's Science Advisory Board (SAB), which subsequently also considered
USEPA's response to the mechanistic data and issues of PCE (USEPA, 1991). The SAB expressed the
view that the PCE evidence falls on the continuum from group C (possible human carcinogen) to group B2
(probable human carcinogen). These positions were expressed prior to the publication of epidemiological
studies (particularly, Anttila et al., 1995; Ruder et al., 1994; both as cited in IARC, 1995) that IARC
(1995) recently reviewed. Anttila et al. (1995) does not appear to add statistically significant elevations to
the evidence; while Ruder et al. (1994), as discussed earlier in this section, saw significant duration and
latency-related incidence of esophageal cancer, limitations remained in their conclusions. IARC however
considered the pattern of endpoints to be important, despite the individual lack of statistical significance of
some of them. Meanwhile, the view of USEPA's SAB was framed to encompass a concern for high PCE
exposures, which is consistent with the uncertainties regarding the modes of action associated with the
several tumor types.
C.1.2 Hydrocarbon Solvents
A variety of hydrocarbon solvents (e.g., Stoddard solvent, 140°F solvent, naphtha, and DF-2000,
to name a few) may be used as drycleaning agents. Each solvent is a unique mixture of carbon and
hydrogen molecules that co-exist as linear and branched chains, as well as in cyclic forms. In this CTSA,
hazard data are presented on Stoddard solvent, which is assumed to qualitatively represent the hazard of
the other, similar solvents used in drycleaning.
Summary
The information presented on Stoddard solvent is based primarily on ATSDR (1995). In humans,
Stoddard solvent has been shown to be an irritant to eyes, skin, and mucous membranes (the membranes
lining all bodily channels that communicate with the air, such as the nose and throat). Neurological effects
(1 e headaches, the feeling of euphoria, color blindness, cerebral atrophy, memory deficits, and fatigue)
have been observed in humans occupational^ exposed to Stoddard solvent either by breathing or skin
contact; however, these studies contain poor exposure information and multiple solvent exposures, making
it difficult to draw any definitive conclusions.
Limited information prevents any conclusions regarding developmental/reproductive toxicity. A
study of individuals with prostate cancer, lung cancer, and Hodgkin's lymphoma suggested associations of
those cancers with chronic inhalation exposure to mineral spirit, an often used synonym for Stoddard
solvent. Interpretation of these findings is limited, however, and no other studies of human experience
have been located.
The primary toxic effects following acute exposures to high concentrations of Stoddard solvent in
animals (observed variously in rats, dogs, and cats) consist of eye irritation, irritation to the upper
membranes of the respiratory tract, salivation, loss of coordination, muscle spasms, tremors, convulsions,
and death. Skin contact has been associated with skin irritation in rabbits and guinea pigs.
One study in which Stoddard solvent together with two other components was applied to the skin
of mice repeatedly over their lifetime showed some skin cancers. This result can not be attributed solely to
the Stoddard solvent. Stoddard solvent does not appear to be mutagenic in bacteria or in mammalian
_ . —
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Appendix C
Health Hazard Summaries
systems. Kidney effects were observed in exposed male rats but were not considered to be clinically
relevant to humans.
Absorption/Metabolism
Very limited data are available concerning the pharmacokinetics of Stoddard solvent. Stoddard
solvent is readily absorbed by inhalation based on the results of two studies dealing with the kinetics of
Stoddard solvent in human volunteers (Pedersen et al., 1984, 1987, both as cited in ATSDR, 1995). The
calculated pulmonary uptake from humans (eight males) exposed to 600 mg/m3 (about 100 ppm) for 3
hours was approximately 400 mg (133 mg/hour) (Pedersen et al., 1984). Stoddard solvent was detected in
the blood and subcutaneous fat. The estimated mean half-life in fat, associated with this single short-term
exposure, was 2 days. Using a multi-compartmental analysis (simulated model) of the data obtained from
blood and fat samples of seven male volunteers exposed to 600 mg/m3 Stoddard solvent 6 hours/day for 5
consecutive days, the authors estimated minimum and maximum steady-state concentrations of Stoddard
solvent in the brain to be 0.6 and 5-11 mg/kg, respectively (Pedersen et al., 1984, 1987). The half-life was
estimated to be 18-19 hours in the brain and 7 days in fat (Pedersen et al., 1984).
Although there are no data on the oral absorption rate of Stoddard solvent, it is known that other
petroleum distillates with longer carbon chains, such as kerosene (C10-C16), are very poorly absorbed from
the gastrointestinal tract (Dice et al., 1982; Mann et al., 1977; Wolfsdorf and Kundig, 1972, all as cited in
USEPA, 1993), whereas gasoline, a smaller chain petroleum distillate (C4-CI2), appears to be relatively
completely absorbed (NESCAUM, 1989). The smaller (C9-Cn), alkane or aromatic hydrocarbons (10-20%
in Stoddard solvent) may be absorbed readily (Litovitz and Greene, 1988). The rate and extent of
gastrointestinal absorption of Stoddard solvent would, therefore, likely be dependent on the lipophilicity
and size of various components and the amount of food in the stomach (USEPA, 1993).
No information on the absorption following dermal exposure was located. However, Stoddard
solvent (absorbed dose of 210 mg) applied to the tails of rats daily for 6 weeks was associated with axonal
prenodal swelling, an indication that dermal absorption had occurred (Verkkala et al., 1984).
Elevated levels of dimethylbenzoic acid (a marker of exposure) were found in the urine of men
occupationally exposed to Stoddard solvent mist (Pfaffli et al., 1985), and in rats dermally exposed by
daily applications to their tails for 6 weeks (Verkkala et al., 1984), showing that this solvent is indeed
metabolized.
Acute Toxicity
An acute inhalation LC50 greater than 5,500 mg/m3 and an acute oral LD50 greater than 5 g/kg have
been estimated for rats (Vernot et al., 1990, as cited in ATSDR, 1995). An acute dermal LD50 in rabbits
was reported to be greater than 3 g/kg (Vernot et al., 1990, as cited in ATSDR, 1995). The primary
symptoms observed in animals consist of eye irritation, irritation to the upper membranes of the respiratory
tract, salivation, loss of coordination, clonic spasms, tremors, convulsions, and death. No additional data
have been located pertaining to the potential oral or dermal toxicity of Stoddard solvent in animals.
Groups of 15 rats inhaled various concentrations (420 to 1,400 ppm) of Stoddard solvent for single
8 hour periods followed by either immediate necropsy (n=5) or necropsy after 14 days of observation
C-15
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dixC
Health Hazard Summaries
(n=10) (Carpenter et al., 1975a, 1975b). Effects observed in rats exposed to 1,400 ppm (8 000 mg/m )
ncluded loss of coordination, eye irritation, and bloody exudate around the nostrils. Similar signs, without
loss of coordination, were observed at 800 ppm (4,600 mg/m3). No effects were observed during or after
exposure at 420 ppm (2,400 mg/m3). A female dog exposed to 1,400 ppm (8,000 mg/m3) Stoddard so vent
for 8 hours displayed eye irritation at 1 hour, increased salivation at 3 hours, tremors at 4 hours and clomc
spasms at 5 hours, whereas a second female dog exposed to the same level under the same condit.ons was
asymptomatic during and after exposure (Carpenter et al., 1975a, 1975b).
Histopathological changes in the nasal cavity, trachea, and larynx were observed in three rats
exposed to atmospheric levels of 214 mg/m3 Stoddard solvent (a level selected to represent one half the
TLV of 525 mg/m3 for Stoddard solvent) 4 hours/day for 4 days compared to no changes in the control
(Riley et al., 1984, as cited in ATSDR, 1995).
Irritation/Sensitization
In humans, Stoddard solvent is an irritant to the eyes, mucous membranes, and skin. One of six
human volunteers exposed to 850 mg/m3 (150 ppm) Stoddard solvent vapors for 15 minutes/day for 3 days
experienced slight eye irritation (Carpenter et al., 1975a, 1975b); all subjects experienced eye irritation
following exposure to 2,700 mg/m3 (470 ppm). Additionally, one subject exposed to 2700 mg/m showed
throat irritation; two volunteers experienced slight dizziness at this concentration. No eye or throat
irritation was seen in the subjects after exposure to 140 mg/m3 (24 ppm). Minor irritation was reported in
50 male volunteers exposed to 600 mg/m3 Stoddard solvent; however, there was no observable difference
between cases and controls with respect to eye-blink rate, swallowing rate, or respiration rate (Hastings-et
al., 1984).
One man working with Stoddard solvent in a drycleaning factory, who had his forearms and hands
wetted with or immersed in the solvent, developed follicular dermatitis of the exposed skin after 2 weeks
(Braunstein 1940), and a positive skin sensitization response to Stoddard solvent was observed. Five men
wearing coveralls damp from drycleaning with Stoddard solvent developed sores on their genitals and
buttocks (Nethercott et al., 1980, as cited in ATSDR, 1995). The limited information makes it impossible
to determine whether Stoddard solvent is a cause of contact dermatitis in humans.
Stoddard solvent has been classified as a moderate irritant to the skin in rabbits (Vernot et al.,
1990 as cited in ATSDR, 1995). Dermal exposure to Stoddard solvent, three times daily for 3 days,
resulted in skin irritation in guinea pigs as evidenced by an increase in mean epidermal thickness, visible
redness, palpable induration, and evident swelling (Anderson et al., 1986, as cited in ATSDR, 1995). A
dermal sensitization study in guinea pigs did not show positive results (Vernot et al., 1990, as cited in
ATSDR, 1995); the details of this study are not clear.
Subchronic/Chronic Toxicity
There have been a few case reports associating occupational exposure to Stoddard solvent (boiling
point 150-200°C) and other higher-boiling-point petroleum distillates with the development of aplastic
anemia (Prager and Peters, 1970, and Scott et al., 1959, both as cited in ATSDR, 1995), but no
epidemiological studies appear to have been done.
C-16
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Appendix C
Health Hazard Summaries
A young man (29 years old), exposed to direct dermal contact and inhalation of Stoddard solvent 6
hours a day for 1 year, developed glomerulonephritis (Daniell et al., 1988, as cited in ATSDR, 1995)
Exposure concentrations were not reported. This isolated case report is inadequate for assessing the risk of
kidney effects.
No hepatic effects were observed in a laboratory study of 12 men exposed to 610 mg/m3 of
vaporized Stoddard solvents for 6 hours (Pedersen et al., 1984, as cited in ATSDR, 1995), or among a
group of house painters compared to controls (Hane et al., 1977, as cited in ATSDR, 1995).
No statistically significant differences were observed in dogs exposed to 480, 1,100 or 1,900
mg/m (84, 190, and 330 ppm, respectively) of Stoddard solvent for 6 hours/day, 5 days/week for 13 weeks
compared to controls (Carpenter et al., 1975a, 1975b). Nephropathic effects (i.e., kidney damage) have
been observed in groups of 25 male rats exposed to up to 1,900 mg/m3 (330 ppm) of Stoddard solvent for
13 weeks (Carpenter et al., 1975a, 1975b). This type of "hydrocarbon nephropathy" appears to be unique
to the male rat (Alden, 1986, and Rothman and Emmett, 1988, both as cited in ATSDR, 1995).
Neurotoxicity
A number of studies have reported neurological findings in humans who have been chronically
exposed to Stoddard solvent via the inhalation or dermal routes at the workplace; however, details of
exposure concentrations and/or exposure duration were not reported. In addition, workers'were often
exposed to other solvents, making it difficult to identify which solvent (or combination of solvents) may be
responsible for the neurological effects. Neurological effects that have been reported include bifrontal
headaches and the feeling of euphoria (Daniell et al., 1988, as cited in ATSDR, 1995), color blindness
(Mergler et al., 1988, as cited in ATSDR, 1995), cerebral atrophy (Mikkelsen et al., 1988, as cited in
ATSDR, 1995), memory deficits, and fatigue (Arlien-Soberg, et al. 1979; Flodin et al., 1984; Gregersen et
al., 1984; and Hane et al., 1977, all as cited in ATSDR, 1995; Olson, 1982). Gregersen (1988) has also
reported significantly more symptoms of chronic encephalopathy, in particular memory and concentration
impairment in a group of solvent-exposed workers (n=59) compared to controls (n=30).
Exposure of eight male volunteers to 4,000 mg/m3 (about 698 ppm) Stoddard solvent vapor for 50
minutes resulted in a prolonged reaction time and a possible impairment of short-term memory in
performance tests (Gamberale et al., 1975). These men (plus six others) remained unaffected by exposure
to 625, 1,250, 1,850 and 2,500 mg/m3. Human subjects exposed to 2,400 mg/m3 (419 ppm) Stoddard
solvent for 30 minutes displayed no problems with visual-motor tasks (Hastings et al., 1984). No adverse
systemic, immunological, or neurological effects were observed in human subjects exposed to 570 mg/m3
(about 100 ppm) Stoddard solvent for 6 hours/day for 5 days (Pedersen et al., 1987, as cited in ATSDR,
Incoordination at 8,200 mg/m3, and tremors and convulsions at 8,000 mg/m3 were observed in rats
and dogs, respectively, exposed for 8 hours (Carpenter et al., 1975a, 1975b; for more details see acute
section above). Exposure of cats to 10,000 mg/m3 (1,700 ppm) Stoddard solvent for 2.5 to 7 5 hours
resulted in slowed reaction to light at 20 minutes, tremors at 26 to 74 minutes, clonic convulsions at 1 75 to
7.5 hours, and deaths at 2.5 to 7.5 hours (Carpenter et al., 1975a, 1975b); only one concentration was
examined.
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Appendix C
Health Hazard Summaries
Developmental/Reproductive Toxicity
Sperm counts, motility, and morphology measured over a period of 2 months were normal in 11
men occupational^ exposed to a mixture of organic solvents, including 50 ppm Stoddard solvent, m a
printing factory (Tuohimaa and Wichmann, 1981, as cited in ATSDR, 1995).
No signs of toxicity were exhibited in fetuses of three groups of 20 to 27 female rats exposed from
day 6 to 15 of gestation, 6 hours/day, to Stoddard solvent at concentrates from zero to 2,356 mg/m (400
ppm) (API, 1977, as cited in ATSDR, 1995). No embryonic or teratogenic effects were seen m mated
female rats expo ed to 100 or 300 ppm Stoddard solvents 6 hours/day by inhalationfrom day 6 to-day^15
of gestation (Phillips and Egan, 1981). Pregnancy rates, implantation efficiency and rates, and fetal deaths
for female rats mated to fertile male rats exposed to 100 or 300 ppm Stoddard solvent 6 hours day 5
days/week for 8 consecutive weeks prior to mating, were comparable to those of controls (Phillips and
Egan, 1981). No further information is available regarding exposures to Stoddard solvent and
reproductive/developmental effects in animals or humans.
Mutagenicity
Based on data derived from several types of assays, Stoddard solvent does not appear to be
mutagenic in bacteria or in mammalian systems. Stoddard solvent has been tested for genotoxic Potential
^several in vitro assays (two Ames tests, two mouse lymphoma tests, and a chromosomal aberration assay
using human peripheral lymphocytes), and in vivo assays (mouse micronucleus test, mouse and rat
dominant lethal tests, and chromosomal aberration test using rat bone marrow) (Conaway et al., 1984,
Gochet et al., 1984; API, 1982; API, 1987). No significant increase in sister chromatid exchange in
human peripheral lymphocytes was observed. No chromosomal aberrations were found m bone marrow
cells Negative results were obtained in the dominant lethal assays. The Ames and lymphoma tests
support the negative results observed in the mammalian m vivo and human in vitro studies.
Carcinogenicity
There is limited information available regarding the potential carcinogenic effects of Stoddard
solvent in humans and animals. Although lung cancer, prostate cancer, and Hodgkin's lymphoma were
observed in humans exposed to mineral spirits and skin cancer in mice exposed to Stoddard solvent,
limitations of these studies preclude their usefulness in assessing risk. Therefore, no conclusions regarding
the carcinogenic potential of Stoddard solvent can be drawn at this time.
In a case-referent study of 3,762 cancer patients, associations of prostate cancer, lung cancer, or
Hodfikin's lymphoma with chronic inhalation exposure to mineral spirit (a common synonym for Stoddard
solvent) were seen (Siemiatycki et al., 1987). The absence of exposure information, multiple comparisons,
lack of control for confounding factors, use of other cancer patients as referents, and other limitations ot
this study make it unsuitable for risk determinations.
In a lifetime (864 days) skin-painting study, squamous cell carcinomas were observed in 6 of 50
mice exposed to a mixture of 90% Stoddard solvent, 7% calcium petroleum sulfonate, and 3% ethylene
glycol monobutyl ether compared to none of the 50 controls (USEPA, 1984); this is a statistica ly
significant increased incidence. It is not possible, however, to assess the carcinogenic potential ot
~ ~ C-18 "
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Appendix C
Health Hazard Sumrm
Stoddard solvent in this study because the test substance contained additional components that could have
contributed to the result, and only one dose level was used. No inhalation or oral animal studies appear to
be available.
C'2 MACHINE WETCLEANING EXAMPLE DETERGENT CHEMICALS
Wetcleaning detergent formulations are complex mixtures typically containing water plus several
chemicals. Most formulations are trade secrets, and the concentrations of the individual chemicals are
unknown to all but the manufacturer. Hazard summaries are presented for 10 constituents of the two
sample detergents used in the exposure assessment (see Chapter 4 and Appendix E) portion of this CTSA1
They are meant to provide illustrative information on the types of hazards that could be related to
chemicals potentially found in machine wetcleaning detergent formulations. It is not known how
representative these effects are of the chemicals that may be found in actual detergent formulation.
The detergents considered in this hazard assessment are grouped into surfactants and surfactant
aids. It should be noted that especially for surfactants (e.g., CAPB and lauramide DBA), the substances
discussed herein are rarely used by themselves, and the variety of formulations makes it difficult to
establish general toxicity conclusions.
C.2.1 Surfactants
Cellulose Gum (CG)
A number of studies in both animals and humans have been conducted by the manufacturers of
products containing cellulose gum in concentrations of less than or equal to 0.1% to up to 10%
(concentrations most frequently used range between 0.1 and 1.0%). Results of these studies have been
voluntarily submitted to the Cosmetic, Toiletry and Fragrance Association (CTFA) and reviewed by the
Cosmetic Ingredient Review (CIR, 1986a) panel. The following information (studies and conclusions)
used to compile this health hazard review was adapted from the published materials of the CIR panel
unless otherwise cited.
Summary
Cellulose gum (CG) is used as a thickener, suspending agent, film former, stabilizer, emulsifier
emollient, and binder or water retention agent in a wide variety of cosmetic and toiletry products and is
one of a number of water-soluble cellulose ethers (carboxymethyl cellulose [CMC], methylcellulose [MCI
mD^^TlT^10611111086 [HPMC]' Mroxyethylcellulose [HEC], and hydroxypropylcellulose
[HPC]). All of these ethers have been reported to be nonirritating and nonsensitizing, exhibiting very low
oral toxicity, and no neurologic, reproductive, or mutagenic effects have been reported Cellulose gums
are largely negative for developmental effects. Rat oral LD50 values ranging from greater than 3 0 to 27
g/kg have been reported. NOAELS of 20 and 10 g/kg were reported in rats and guinea pigs, respectively
urea, and
' Aveda'
cocamphocarboxyproprionate, diazolidinyl
C-19
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Appendix C
Health Hazard Summaries
Absorption/Metabolism
Cellulose gum does not appear to be absorbed by humans, rats, or dogs and so is excreted
unchanged The lack of absorption is also inferred from wide use in concentrations from less than 0.1 /o to
1% asbulk JxSive protectivTcolloid, surgical and dental adhesive, and binder in dietary supplements
slecta^SleTn water and organic solvents, and some are not; thus, solubility does not help mfer
humans' susceptibility (Clayton and Clayton 1982; CIR, 1986a).
Acute Toxicity
Oral LD50 values in rats range from 3 to 27 g/kg. Acute toxicity studies have not been identified
for dermal exposure routes.
Irritation/Sensitization
Cellulose gum, as well as the other cellulose polymers tested, was found to be non-irritating or
slightly irritating to the skin and eyes of humans and animals (rabbits).
Humans
CG and MC were evaluated for irritation and sensitization in groups of 200 volunteers by patch
test and/or challenge tests. All results were negative. Twenty-four-hour patches contaming 100% or 5.0/o
HEC o 10% HPC applied every other day to the skin of 50 subjects, for a total of 10 exposures
producedJcTiSon'or sensitization. Of the 48 studies presented in the ™™™™™«***
Litancy and sensitization potential of the various cellulose denvat.ves, only five stud.es showed any
indication of an effect, which was classified as mild at worst.
No irritation occurred to the eyes of 10 volunteers given four artificial tear drops (5 minutes apart)
containing a 2.0% concentration of HPMC or HEC or to an unspecified number of md.v.duals
administered an eye lotion containing 0.5% CG.
Animals
Following applications of 23- and 24-hour occlusive patches no or slight skin irritation,was
observed in rabbits exposed to various cosmetic products containing CG, CMQ HEC, HpC» and HFML
ranging in concentrations from 0.3 to 3.0%, and to 2.0% aqueous solut.ons of HEC, HPC, and MC. A
sSocclusive patch containing 5.0 g/kg HPC (a dermal dose 500 times the expected human exposure),
applied to each of six rabbits, resulted in no deaths, no irritation, and no gross effects.
Repeated application (5 days/week for 4 or 6 weeks) of CG (1.0, 4.0, or 10% in aqueous solution)
to the shaved backs of rabbits was observed to be either nonirritating or "slightly irritating and relatively
well tolerated" (CIR, 1986a).
No or minimal eye irritation was seen in rabbits exposed to various cosmetic products containing
CG or CMC ranging in concentrations from 0.3 to 3.0%. The majority of tests, using a vanety of d.fferent
C-20
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Appendix C
Health Hazard Summaries
protocols, showed no eye irritation following exposures of rabbits to various levels of HEC, HPC, MC,
CMC, HPMC, and CG, although some showed slight irritancy.
Subchronic/Chronic Toxicity
The CIR panel found oral exposures to cellulose derivatives in both humans and animals (rats,
chicken, dogs, rabbits, mice, and guinea pigs) to be basically non-toxic. Only two dermal studies were
reported, both 13 weeks in rats; neither showed significant adverse systemic or dermal toxicity.
Humans
Humans ingesting 10 g CG daily over a 6-month period exhibited no hematological or other toxic
effects and no mucosal irritation. Cellulose gum given as a laxative to 250 subjects in twice-daily doses of
2.0-18 g over a period of 3 years produced no toxic effects.
Although no clinical inhalation studies have been conducted, occupational long-term exposure to
the dust of cellulose ether generated in manufacturing operations has not led to any known adverse effects.
Animals
No effects with reference to survival rates, body weights, hematological endpoints. urinary
function analysis, or gross or microscopic examination of tissues were noted in rats receiving daily
applications of 886 mg/kg of a 3% CG product in a vehicle containing sodium silicate (groups of 15) or
receiving daily applications of a 1.1% CG lotion, 2,900 mg/kg (male and female groups of 10) for 13
weeks. As cited by Clayton and Clayton (1982) no evidence of toxicity was seen in either rats or dogs
(unspecified numbers) fed 6.0% MC or 10% HPMC for 90 days.
Neurotoxicity
No behavioral or other toxic effects were observed in rats fed 0.2, 1.0, or 5.0% HPC (three groups
of 10) or HEC (three groups of 20) for 90 days. No other information has been located regarding the
neurotoxicity of cellulose derivatives in animals or humans.
Developmental/Reproductive Toxicity
No significant developmental or reproductive effects were found in studies in which cellulose
derivatives were administered orally to rats, rabbits, mice, and hamsters.
Mutagenicity
Cellulose gum and its derivatives have not been found to be mutagenic. In a series of short-term
tests for CG using several strains of Salmonella, Bacillus, and silkworm for assessing mutations, and
hamster lung fibroblast cells (without metabolic activation) for assessing chromosomal aberrations, all
results were negative. Carboxymethyl cellulose gave negative results in several strains of Salmonella, with
and without metabolic activation. Using the dominant lethal assay, MC was non-mutagenic in rats dosed
with up to 5,000 mg/kg.
C-21
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dixC
Health Hazard Summaries
Carcinogenicity
No animal studies on the carcinogenicity of CG were reported.
Cocamidopropyl Betaine (CAPS)
The CIR panel (CIR, 1991) concluded, based on the data available at the time of its report, that
CAPB is safe for use in rinse-off cosmetic products at the current levels of use. They recommended that
the concentration of use for products designed to remain on the skin for prolonged periods of time should
not exceed 3 0%. The latter is expressed as 10% dilution of a full-strength cocamidopropyl betame
solution that has an activity of 30%. The main toxic effect by dermal application or ingestion is irritation.
A number of studies in both animals and humans have been conducted by the manufacturers of
products containing cocamidopropyl betaine in concentrations as high as 50% of full strength (which is
considered to be 30% activity). Results of these studies have been voluntarily submitted to the CTFA and
reviewed by the CIR panel. The following information (studies and conclusions) used to compile this
health hazard review was adapted from the published materials of the CIR panel, unless otherwise cited.
Summary
CAPB, primarily used in hair shampoos but also in formulations used as hair conditioners, hair
dyes and colors, bath soaps/detergents, skin cleansing preparations, and bubble baths, is reported as a
potentially irritating substance. Concentrations of CAPB in these formulations range from 0.1 to 50%
(expressed as a percent dilution of commercially supplied CAPB that is 30% active). CAPB does not
appear to have undergone any studies of reproductive or developmental toxicity or neurotoxicity or chronic
studies of systemic effects. The single carcinogenicity study employed CAPB in a formulation. Without
any remarkable response, its results suggest that CAPB does not increase systemic tumors above
background, but are not enough to be conclusive. Although no dermal subchronic toxicity testing appears
to have been performed, results of a 28-day oral test suggest a CAPB potential for irritation, which is
consistent with outcomes from a collection of patch and ocular animal tests.
A bsorption/Metabolism
No studies were found on the absorption, distribution, metabolism, and excretion of CAPB. It is
unclear whether the amide bond of CAPB can be hydrolyzed to yield the fatty acids and
3-aminopropylbetaine. No metabolism data are available on the latter compound.
Acute Toxicity
Humans
No studies have been located discussing acute effects of CAPB in humans by any route of
administration.
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Appendix C
Health Hazard Summaries
Animals
All reported studies are by gavage or intubation, in mice or rats. An oral LD50 of 6.45 ml/kg was
calculated for mice from a study of a full-strength CAPB solution, 30% active, administered by gastric
intubation. For rats, the acute oral LD50 for full-strength CAPB was 4.91 g/kg. Gross necropsy findings in
rats showed redness of the stomach and intestinal mucosa, suggesting irritation.
Irritation/Sensitization
Responses of humans to dermal exposure have ranged from none to moderate in voluntary test and
case report contexts. More recently than CIR (1991), there have been several reports of apparent contact
dermatitis, but these instances are not necessarily exclusively the result of CAPB exposure, and the
amounts of any compound that may have sensitized the individuals are uncertain. Consequently, while
irritation occurs at certain levels of exposure, sensitization initially attributed to CAPB has since been
identified with another chemical in the same surfactant.
Humans
A 1.0% aqueous dilution of a product formulation containing 6.0% active CAPB was tested for
skin irritation using a single insult occlusive patch and 19 panelists. The formulation was considered
"practically nonirritating."
Daily doses of 0.2 ml of an 8% aqueous dilution of a liquid soap formulation containing 6.5%
active CAPB were applied via occlusive patches to the forearms of 12 subjects for 5 days. An erythema
score of 0.48 (scale 0-4) was calculated.
In a study of cumulative irritation, 0.3 ml of two soap formulations, described as "cream colored"
or "white liquid," were applied to skin sites on the backs of 10 panelists using occlusive patches. Each
contained 1.9% active CAPB. Daily 23-hour patches were applied for 21 consecutive days. Across all
applications, the total irritation scores for all subjects were 588 and 581, respectively, of a maximum of
630. The average irritation times were 1.48 and 1.69 days, with medians of 2 days.
A repeated open application procedure was performed with a 10% aqueous dilution of a shampoo
containing 18.7% active CAPB using 30 volunteers to determine skin sensitization. The same procedures
were performed on additional subjects with another test substance containing an identical concentration of
CAPB. No sensitization was seen in any of the 88 subjects exposed to the test materials in a shampoo base
under any open patching conditions in both the induction and challenge applications.
Other skin sensitization potential studies similar to the above study were performed. Induction
applications generally were repeated to the same site and scored following a 48-hour period. An alternate
site was used for the challenge test and was scored after 48 and 96 hours. In one study, a 0.9% active
aqueous solution of CAPB was tested on 93 volunteers who had slight responses to the test material.
These responses were attributed to primary irritation, rather than sensitization, during both the induction
and challenge tests. In another similar study, the skin sensitization potential of a formulation containing
10% active CAPB was tested on 100 volunteers. No evidence of sensitization was observed with the test
material.
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Health Hazard Summaries
An investigation of the potential of CAPB to induce contact skin sensitization was conducted
using 141 subjects. All applications initially contained a concentration of 1.5% active CAPB in distilled
water until a protocol modification changed the concentration to 3.0% active CAPB Subjects who began
the study a week earlier received two applications at a concentration of 1.5%, and all other applications of
the test material at a concentration of 3.0%. Induction applications were made to the same, previously
untreated site on the back three times per week for 3 successive weeks. Gauze patches were applied and
then removed after 24 hours. A challenge application was applied to a previously untreated site for 24
hours 10-15 days later, and the site was scored 24 and 72 hours after patch removal. No responses were
observed during either the induction or challenge tests.
Subsequent to CIR (1991), several case studies of individuals apparently presenting with contact
dermatitis based on exposure to CAPB were reported (Korting et al., 1992, 1% aqueous, activity
unspecified, standard patch; Fowler, 1993, 1% aqueous, activity unspecified, standard patch; Peter and
Hoting 1992, standard patch, and 5% aqueous, 0.1-0.2% active; Camelietal., 1991, 1 % aqueous patches;
and Ross and White, 1991, standard patch). Several instances were initiated by contact lens solution
exposure, others were in hairdressers or recipients of shampoo exposure over extended periods (Tamguch.
et al 1992) Peter and Hoting (1992) used their findings to hypothesize that the increased apparent
allergenic activity could be attributed to some recent manufacturing process change that introduced
impurities. Subsequently, it has been confirmed that the major allergen is the impurity
dimethylaminopropylamine used in the synthesis of CAPB (Angelini et al., 1995; Pigatto et al., 1995).
In another study, five dilutions (0.15, 0.30, 0.75, 1.5, and 3.0% w/v) of three quality levels of
CAPB (ranging from 29 5 to 29.8% active) were applied simultaneously to separate dorsal locations ot up
to 67 volunteers using a 48-hour occlusive patch (Vilaplana et al., 1992). The study's purpose was to
examine three different noninvasive evaluative methods. The qualities were based on amounts ot tree
amidoamine and sodium monochloro-acetate. None showed excessive irritant response, but the
formulation with greatest free amidoamine content showed a statistically significantly greater
preponderance of higher responses at 0.75% w/v and above. The authors concluded that the response can
be described as an irritant contact dermatitis but not as an allergic contact dermatitis."
An additional study investigated the potential of a 3.0% active solution of CAPB to induce contact
photoallergy. There was no response to the challenge tests except for those exposed to both UVA and
UVB radiation, who had mild to moderate erythemic responses that were not uncommon and were said to
have resulted from the sunburn derived from UVB exposure (CIR, 1991).
Animals
Six studies applied occlusive patches with CAPB solutions of various activity (7.5% to 30%) to
intact and abraded sites on the backs or abdomens of groups of rabbits. The responses ranged from no
irritation (7.5% active) to a Primary Irritation Index of 3.75 (scale 0-8) with eschar (scab) formation (30/o
active).
Ten ocular irritation studies in rabbits, employing concentrations ranging from 2.0% to 30% active
in water or in soap formulations, showed mostly conjunctival irritation and mild to moderate corneal
irritation to treated, unrinsed eyes.
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Appendix C
Health Hazard Summaries
Two studies in guinea pigs followed intradermal injections with topical induction and challenge
applications to identify the potential for skin sensitization. Fifteen male guinea pigs were injected (at three
separate sites) with 0.1 ml of 0.5% (v/v) CAPB dilution in saline, 0.1 ml in saline and Freund's complete
adjuvant, and 0.1 ml of 50% Freund's complete adjuvant in water, followed by a 48-hour occlusive patch
on each site of 60% (v/v) CAPB 1 week later (induction). Five control animals received the treatment
series without CAPB content. Two weeks following induction, a 10% (v/v) CAPB challenge patch
showed no evidence of delayed contact hypersensitivity.
In another similar test, 20 guinea pigs (sex unspecified) received a 10% aqueous dilution of a 30%
active CAPB sample in a 48-hour patch, following a 0.1% dilution injection. The challenge was a 10%
aqueous dilution. Microscopic changes in the treated skin indicated slight delayed-type contact
sensitization.
Subchronic/Chronic Toxicity
In a 28-day gavage short-term study in rats, with full-strength solution (30% CAPB), treatment-
induced lesions were produced in the nonglandular portion of the stomach in the high-dose group but not
in the low-dose group.
No other studies discussing subchronic effects of CAPB in humans or animals have been located.
Neurotoxicity
No studies have been located discussing neurotoxic effects of CAPB in humans or animals.
Developmental/Reproductive Toxicity
No studies have been located discussing reproductive or developmental effects of CAPB in
humans or animals.
Mutagenicity
The mutagenic potential of a 31% active CAPB formulation was tested in five strains of the
Salmonella/mammalian microsome mutagenicity assay, with and without activation, and the L5178Y TK
+/- mouse lymphoma assay. CAPB was nonmutagenic in these assays.
Corcinogenicity
CAPB was not carcinogenic in a skin-painting study in mice. An aqueous preparation of a non-
oxidative hair dye formulation containing an unspecified grade of CAPB at a concentration of 0.09%
active CAPB was tested for carcinogenicity using groups of 60 male and female mice. The formulation
also contained 5% propylene glycol, 4% benzyl alcohol, 0.6% Kelzan, 0.9% lactic acid, and less than 0.5%
or each of fragrance and the disperse brown, red, yellow, and blue dyes. A dose of 0.05 ml per mouse was
applied three times weekly for 20 months to clipped, shaven interscapular skin. Mortality, behavior, and
physical appearance of the mice were observed daily. Dermal changes in particular were noted. Body
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Health Hazard Summaries
weights were recorded weekly. Ten males and 10 females from each group were killed at 9 months for a
hematological study and necropsy. Urinalysis was also performed.
At termination, all mice were necropsied, and the tissues were examined microscopically. No
adverse effects were noted on average body weight gains, survival, hematological, or urmalysis values in
any group Varying degrees of chronic inflammation of the skin were seen in all groups, including
controls Other lesions occurred, but were considered unrelated to treatment. Pulmonary adenomas,
hepatic hemangiomas, and malignant lymphomas were observed in the 60 treated female mice and in the
59 treated male mice (no information was given on whether any were observed in the early sacrifice).
However, the incidences of these systemic neoplasms did not differ statistically significantly from those in
the two control groups (numbers unspecified) that were shaved and received no topical treatment.
Ethoxylated Sorbitan Monodecanoate (Polysorbate 20 or P-20)
The information (studies and conclusions) used in preparing this health hazard section has been
adapted from a report issued by the CIR panel (CIR, 1984), unless cited otherwise.
Summary
Polysorbates are commonly used as surfactants in a variety of cosmetic products at concentrations
ranging from less than or equal to 0.1% to greater than 50% for polysorbate 20 (P-20). The majority of
product formulations (95%) fall into the range of less than 0.1 % to 5.0% P-20. In both animals and
humans P-20 has been found to be essentially nontoxic following acute and long-term oral mgestion and to
exhibit little or no potential for skin irritation or sensitization. No inhalation studies are available;
however, this is not an expected route of exposure. LD50s in animals range from 18 to 36.7 ml/kg and
greater than 5.0 to 38.9 g/kg following oral exposure, and from 0.7 to 3.5 ml/kg and 1.45 to 3.85 g/kg
following injection routes of exposure. By analogy to other polysorbates, P-20 is not expected to be
mutagenic. While not carcinogenic itself, P-20 has been shown to enhance the activity of known chemical
carcinogens and to inhibit tumor growth activity under certain conditions. No animal or human data
regarding reproductive, developmental, or neurotoxic effects associated with P-20 exposures were located.
A bsorption/Metabolism
The most common routes of exposure are oral and dermal. There is little likelihood of inhalation
exposure of this substance. P-20 is one of a series of polyoxyethylenated sorbitan esters. It is hydrolyzed
by enzymes in the pancreas and blood. The fatty acid moiety (the ester portion of the molecule) is readily
absorbed and metabolized, whereas the other portion of the molecule (the polyoxyethylenated sorbitan
moiety) is very poorly absorbed and excreted unchanged. Clinical tests have shown essentially the same
pattern in humans as in rats.
Acute Toxicity
No acute toxicity data are available on dermal exposures.
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Appendix C
Health Hazard Summaries
Humans
For therapeutic reasons, 13 premature and 2 full-term infants with steatorrhea (abnormal fecal fat
loss) were given four daily doses of 200 mg undiluted P-20. Although no increase in fat absorption was
observed, it was noted that P-20 produced no adverse effects with respect to anorexia, vomiting,
defecation, or growth.
Animals
A 24-hour occlusive patch containing 3.0 g/kg of P-20 was applied to the clipped intact or abraded
skin of the back and flank of six albino guinea pigs and observed for 7 days. No deaths occurred and no
adverse effects were observed before and after necropsy.
Oral LD50s for rats, mice, and hamsters range from greater than 5.0 to 38.9 g/kg.
Irritation/Sensitization
There is no evidence of sensitization in humans following P-20 exposures. No dermal irritation
was observed in humans exposed to a 100% concentration of P-20, whereas some product formulations
containing P-20 produced a range of irritancy, but no sensitization. It is impossible to interpret the
meaning of these results, however, without knowledge of the other ingredients in the formulations. P-20
produced no or mild eye irritation and no to moderate skin irritation in rabbits, depending on the length of
the study, and moderate or strong skin sensitization in guinea pigs.
Humans
No evidence of irritation or sensitization was observed in several human studies: 50 persons
administered two 72-hour occlusive patches containing undiluted P-20 (applied 7 days apart); two groups
of 10 persons receiving two 48-hour occlusive patches containing undiluted or 30% aqueous
concentrations of P-20; or among 19 persons tested in 24-hour single insult patch tests exposed to 40%
aqueous dilutions of P-20. In three separate tests, no to mild irritation was observed in subjects (18, 19, or
20) tested with a 24-hour single insult patch of unspecified product formulation containing 2.0, 6.0,'or '
8.4% P-20. Cumulative irritancy tests (daily 23-hour occlusive patches applied for 21 days), in 10 to 12
subjects, of a bubble bath containing 6.0% P-20 produced moderately to highly irritating results. CIR
(1984) concluded that these results cannot be interpreted due to the absence of information regarding other
ingredients in the formulations.
No photosensitization reactions were observed in 103 persons exposed (open and closed 48-hour
patches, repeated after 2 weeks) to a bubble bath containing 0.3% P-20.
Animals
In three separate studies, undiluted (100% concentration) 0.5 ml patches of P-20 occluded for 24
hours produced no or only minimal skin irritation in the one, six, or nine rabbits tested. The same results
were seen for rabbits (one to six) receiving 0.1 ml sample of 100% P-20 instilled in the eye either with or
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c
Health Hazard Summaries
without a water wash and observed for 7 days. No inflammation was seen when P-20 was applied to the
cheek pouch mucosa of hamsters (unspecified number of animals, volume, and concentration of P-20).
Polysorbates 20, 60, 80, and 85 were applied undiluted or diluted in water, petrolatum, or a
hydrophilic ointment (1.0, 5.0, or 10%) daily to the backs of rabbits (unspecified number) for 30 days. For
the undiluted P-20, erythema was observed by day 3, skin thickening by day 10 accompanied by minimal
to mild irritation, and mild to moderate inflammation with acanthosis by day 30. At all dilutions, the
polysorbates tested induced erythema and minimal irritation by day 10 and minimal to marked irritation at
day 30, depending on the polysorbate.
To determine the sensitization potential of P-20, five guinea pig assays (unspecified number of
animals per assay) were performed with three different batches of P-20. Following one to three
challenge(s) with undiluted P-20, four of the five assays evoked responses indicative of moderate
sensitization, and one batch of P-20 produced strong sensitization under the test conditions.
Subchronic/Chronic Toxicity
Humans
No dermal studies are available. There have been a number of long-term human feeding studies
evaluating the use of polysorbates for therapy in liquid malabsorption syndromes (CIR, 1984). Many
studies are reviewed in CIR (1984), and CIR concluded that long-term use (up to several years) of
polysorbate 20 or polysorbate 80 for this purpose was not harmful to humans.
Animals
No dermal studies are available. In several long-term studies (7 weeks to 2 years), levels from less
than 1 up to 25% P-20 in the diet were fed to chickens, rats, monkeys, and hamsters, in some cases over
multiple generations. No adverse effects were seen in chickens, monkeys, or rats with the exception of a
single fatality in rats (1/10) fed 25% P-20 for 21 weeks. Hamsters, on the other hand, fed diets containing
15% P-20 showed numerous gross and histopathologic findings in the bladder, kidney, spleen, and
gastrointestinal tract. Results of these and other studies led the FOA/WHO Committee on Food Additives
to conclude that polysorbates cause no toxicological effects in the animals at daily dietary levels of 5.0/o
(CIR, 1984).
Neurotoxicity
No data have been located discussing the neurotoxic potential of P-20 in either humans or animals.
Developmental/Reproductive Toxicity
No data have been located in humans or animals regarding developmental/reproductive toxicity
associated with P-20 exposures.
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Appendix C
Health Hazard Summaries
Mutagenicity
While there are no data available for P-20, polysorbate 80 was negative in both the micronucleus
and Ames assays for mutagenicity.
Carcinogenicity
From studies of limited duration,, there was no evidence of carcinogenic activity following oral
exposure to P-20. In one study, benign tumors with a tendency to regression were reported following
dermal exposure; however, the overall evidence suggests that P-20 is not carcinogenic when applied to the
skin. On the other hand, polysorbates have been shown to be both tumor enhancers (i.e., involved in tumor
promotion and cocarcinogenesis) and, under certain experimental conditions, tumor growth inhibitors.
Thus, they are able to enhance the activity of known chemical carcinogens although they may not be
carcinogenic themselves.
No tumors were observed in rats (groups of 10 or 14) or hamsters (groups of 10 or 36) fed diets
containing 5.0 to 25.0% P-20 for periods ranging from 8 to 21 weeks. In two separate studies, groups of
50 mice received dermal applications of 100% P-20 (unspecified dose) 6 days/week for 24 or 52 weeks. In
the 24-week study, no tumors were produced. In the 52-week study, one mouse developed a benign skin
tumor at 36 weeks. Both studies, however, are of short duration for determining cancer effects. After
reviewing these results, as well as those of several other studies, Setala (1960, as cited in CIR, 1984)
concluded that polysorbates are not carcinogenic when applied to the skin.
Dermal application of 0.125 mg 1,2-dimethylbenz[a]anthracene (DMBA), a carcinogenic agent,
followed by repeated applications of 0.2 ml 0.3-3.0% P-20 (duration not provided) in ICR Swiss mice (no
number given) resulted in weak tumor promotion. In another study of Wistar rats (no number given) given
drinking water containing 50 mg/L of the carcinogen N-methyl-N'-nitro-N-nitrosoguanidine (MNNG) and
0.4% P-20 for 26 to 30 weeks, an increased incidence of stomach tumors as compared to MNNG controls
was observed.
In vitro tests with P-20 on mouse carcinoma cells showed tumor growth inhibition activity,
whereas in vivo tests with P-20 did not exhibit tumor growth inhibition activity when tested on the same
mouse cancer cells.
Laurie Acid Diethanolamide (Lauramide DEA)
There is limited information available on the toxicity of lauramide DEA. A number of
formulations (soaps, shampoos and bubble baths) containing concentrations ranging from 4.5 to greater
than 50% lauramide DEA have been tested by the manufacturers in both animals and humans. Results of
these tests have been voluntarily submitted to the CTFA and reviewed by the CIR panel (CIR, 1986b),
which was used to compile this health hazard section, unless otherwise cited.
Summary
Acute dermal exposures of humans to various concentrations (4.0 to 10%) of lauramide DEA were
found to result in no to moderate skin irritation depending on the formulation. No evidence of dermal
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idixC
Health Hazard Summaries
sensitization, regardless of the formulation or dose, was observed. No human studies were located
regarding the potential toxicity of lauramide DEA following oral or inhalation exposure. In rats, LD50s
ranging from 2 7 to 9.63 g/kg were identified following single oral dose exposures; and NOAELs of 50
and ->50 mg/kg/day were reported following subchronic exposure to lauramide DEA. No systemic effects
were observed following dermal exposures in animals, although a dose-related increase in both skin and
eye irritancy was reported in animals following exposure to solutions containing 1.0 to 25% lauramide
DEA Lauramide DEA was not found to be mutagenic. The carcinogenic potential of lauramide DEA is
currently being investigated (NTP, 1998). No data were located regarding reproductive, developmental or
neurological effects of lauramide DEA in animals or humans.
Absorption/Metabolism
No human or animal studies were located discussing absorption or metabolism of lauramide DEA
by any route of exposure.
Acute Toxicity
Humans
No studies have been located discussing acute effects of lauramide DEA in humans.
Animals
A 24-hour patch containing 6.0 ml/kg of 50% lauramide DEA in a corn oil vehicle was applied to
the shaved backs of six guinea pigs. Body weights, apparently reduced on day 7, were back to, or above,
expected values by day 14 (CTFA, 1978b). Authors concluded that lauramide DEA was nontoxic by
percutaneous absorption, following skin patch testing in guinea pigs.
In a series of acute studies (CTFA, 1977a, 1978a, 1979a,b,c), groups of five rats each were
administered a single oral (gavage) dose ranging from 0.252 to 15 g/kg of lauramide DEA (0.25% in corn
oil 10% aqueous solution, or formulations containing 6.0 to 8.0%). LDJ0s of 2.7, 9.63, and greater than 15
g/k'g were reported. Based on their findings, investigators concluded that lauramide DEA was nontoxic or
slightly toxic, depending on the dose.
Irritation/Sensitization
Humans
Compared to an equal number of controls, human subjects (17, 18 or 19) exposed to products
containing 5.0, 6.0, or 8.0% lauramide DEA (tested as a 1.0 or 1.25% aqueous solution below an occlusive
patch) were found to have mild to minimal skin irritation (CTFA, 1977c, 1979d, 198la).
Each of three soaps containing 10% lauramide DEA (tested at 8% aqueous solutions) were applied
to the forearms of groups of 12 or 15 subjects for 5 consecutive days (CTFA, 1980b, 1982b,c). Two soaps
were determined to be mild skin irritants, and the third was non-irritating.
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Appendix C
Health Hazard Summaries
In a 21-day cumulative irritation study, a 25% solution of a soap containing 5% lauramide DBA
applied daily under an occlusive patch was found to be moderately irritating in the seven persons tested
(CTFA, 1977d).
Several products containing 4.0 to 10% lauramide DEA were tested for sensitization in humans
(41, 52, 86, or 159 subjects) using multiple 24- to 72-hour occlusive patches over 6 weeks, followed by a
48-hour challenge. No products were shown to be sensitizers (CTFA, 1977d, 1979e 1980c d- RTL 1978
•1980). .
Animals
Concentrations of 1.0, 5.0, and 25% lauramide DEA in water were applied (5.0 ml each) to the
shaved abdominal area (at one intact and one abraded site) of rabbits (number not specified). A dose-
related increase in severity (i.e., no, moderate or severe irritation for 1.0, 5.0, and 25% lauramide DEA,
respectively) was observed following 10 or 3 applications over a period of 14 days to the intact sites and
abraded areas, respectively. A similar dose-related increase in severity (practically non-irritating to slightly
irritating to markedly irritating) was observed in five groups of rabbits (nine per group) administered a
single 24-hour occlusive patch containing 1.25, 10, or 20% aqueous lauramide DEA (CTFA, 1976, 1977b,
1979e) and observed 2 and 24 hours following patch removal.
Aqueous emulsions of 1.0, 5.0, and 25% lauramide DEA in the unwashed compared to washed
eyes of rabbits (three/group) showed no to slight effects (some conjunctival irritation), disappearing within
24 hours following exposure to the 1.0% emulsion; slight to moderate effects (appreciable conjunctival
irritation and superficial corneal injury with no vision loss) disappearing within a week following exposure
to the 5.0% emulsion; and moderate to severe corneal and conjunctival injury with some vision impairment
after exposure to the 25% emulsion.
Subchronic/Chronic Toxicity
Humans
No studies have been located discussing chronic effects of lauramide DEA in humans.
Animals
NOAELs of 50 mg/kg/day (equivalent to 0.1% lauramide DEA) and 250 mg/kg/day were
identified for rats orally exposed to lauramide DEA for 90 days in the following studies, respectively In
the first study, groups of 15 male and 15 female rats were fed diets containing 0 (controls), 0.1, 0.5, 1.0 or
2.0% lauramide DEA for 90 days. Growth was normal in the 0.1% group, slightly reduced in the o's%'
group, and moderately reduced in the 1.0 and 2.0% groups. Growth retardation associated with a decrease
in food intake and some hematological differences was observed at and above the 0.5% level (statistical
significance not provided). Test animals were comparable to controls for bone marrow cytological values
kidney function tests, and gross and microscopic findings. In the second study, groups of 20 male and 20 '
female rats were fed diets containing 0 (controls), 25, 80 or 250 mg/kg/day lauramide DEA for 13 weeks
With the exception of a transient increase in blood glucose concentrations noted at 6 weeks in male rats fed
250 mg/kg/day, all other endpoints measured were comparable to controls (general health, body weight,
- C-31 " "
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Health Hazard Summaries
food consumption, hematologic values, organ weights, mortality (no deaths), and gross and microscopic
findings) (CIR, 1986b).
In the first of two subchronic dermal studies, a medicated cleanser containing 50% lauramide
DBA (2 0 ml/kg applied as a 4.8% aqueous solution) was applied to the shaved backs of 10 male and 10
female rats 5 days/week for 13 weeks (CTFA, 1980a). With the exception of minimal skin imtetion in
females during the first week only, all other indices measured were reported comparable to controls (e.g.,
body weight, appearance, behavior, survival, gross necropsy, and histology). Blood and urine samples
analysed at 7 and 10 weeks, were within the normal range. In the second study, 15 female rats recewed a
daily 2 0 ml/kg dose of a cream cleanser containing 4.0% lauramide DBA administered as a 0.45 aqueous
solution 5 days/week for 13 weeks (CTFA, 1982a). No deaths occurred. As in the previous study, gross
and histopathologic findings were reported comparable to the untreated controls, and blood and urine
levels were within normal limits. The investigators concluded that there was no evidence of dermal or
cumulative, systemic toxicity associated with either of these products.
Neurotoxicity
No studies have been located discussing the neurotoxic effects of lauramide DBA in either humans
or animals.
Developmental/Reproductive Toxicity
No studies have been located discussing developmental or reproductive effects of lauramide DBA
in humans or animals.
Mutagenicity
Lauramide DBA was not found to be mutagenic in four separate Ames-type Salmonella assays, a
DNA-damage assay or in two studies on in vitro transformation of hamster embryo cells. In a spot test
performed with and without metabolic activation in five strains of bacteria, 50 ug lauram.de DBA was
judged to be mutagenic in two of five strains without metabolic activations, but quantitat.ve results were
not provided.
Carcinogenicity
The National Toxicology Program has recently completed a 2-year skin painting bioassay using
rats and mice to determine the carcinogenicity of lauramide DBA condensate (NTP, 1998). Although the
technical report is not yet published, NTP (1998) reports that post-peer review results indicate no evidence
of carcinogenicity in either mice or rats. No other carcinogenicity studies were located in the publ.shed
literature.
Sodium Laureth Sulfate
There is limited information available on the toxicity of sodium laureth sulfate. A number of
studies in both animals and humans have been conducted by the manufacturers of products containing
sodium laureth sulfate ranging from concentrations of less than or equal to 0.1% to greater than 50 /„.
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Appendix C
Health Hazard Summaries
Results of these studies have been voluntarily submitted to the CTFA and reviewed by the CIR panel (CIR,
1983). The following information (studies and conclusions) used to compile this health hazard review was
adapted from the published materials of the CIR panel, unless otherwise cited.
Summary
Sodium laureth sulfate is a commonly used component in bath and hair preparations. Products
containing sodium laureth sulfate may be expected to remain in contact with the skin up to an hour and are
likely to be used repeatedly over a period of several years. Sodium laureth sulfate has been shown to
produce eye and skin irritation at concentrations above 5% in animals and skin irritation at concentrations
as low as 0.7% repeated over 21 days in humans.
Sodium laureth sulfate, following oral exposures, is "moderately to slightly toxic" (CIR, 1983) in
acutely exposed animals and virtually non-toxic in chronically exposed animals. The severity of the effect
shows a trend to increase with increasing doses, although there are some unexplained inconsistencies in
this observation. Oral LD50s range from greater than 0.28 to 3.55 g/kg. A NOAEL of 1000 ppm was
identified for a 13-week study in rats fed dietary levels of 24% w/w sodium laureth sulfate. Sodium
laureth sulfate does not appear to exhibit any reproductive, developmental or carcinogenic effects in
animals. No data were located discussing the neurological or mutagenic effects of sodium laureth sulfate
exposure in humans or animals.
Absorption/Metabolism
Sodium laureth sulfate is poorly absorbed through the skin. CIR (1983) suggests that the
ingredient's ethoxylation decreases its biological activity. When oral exposures occur, the majority of
compound is excreted in the urine, with small amounts appearing in the feces and in expired CO2. In rats
given sodium laureth sulfate by oral intubation or parenteral injection (unspecified length of time), the
urine contained high concentrations of the compound, and the carcass retained less than 1% of the'dose.
Acute Toxicity
Humans
Acute toxicity studies of sodium laureth sulfate in dilute solution have not been identified for
dermal exposure routes.
Animals
In 10 studies of albino rats (groups of 5 or 10) orally exposed to 2.0 to 64 ml/kg test solution
(unspecified dosing regime) containing concentrations of 5.6 to 58% sodium laureth sulfate, effects ranged
from no effect to moderate effects. At high doses (16-64 g/kg) observed effects included unkempt coats,
lethargy, diarrhea, rectal and nasal hemorrhage, and impaired locomotion; however, in all cases, the
animals showed no gross or microscopic abnormalities attributable to the test compound. Oral LD50s for
sodium laureth sulfate identified from these studies range from greater than 0.28 to 3.55 g/kg.
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Health Hazard Summaries
Irritation/Sensitization
Dermal exposure to sodium laureth sulfate appears to cause mild to severe irritation to both
humans and animals (somewhat dependent on the dose), but not sensitization. Eye irritation was observed
in animals, but there were no human studies addressing this endpomt.
Humans
In two studies, 24-hour occlusive patches containing a 60% aqueous solution of 30% sodium
laureth sulfate (18% active sodium laureth sulfate) produced mild irritation in 2/20 and 11/20 ot test
subjects A repeat insult patch test of a dandruff shampoo containing 0.5% sodium laureth sulfate
produced minimal irritation and no sensitization in 196 test subjects. No evidence of contact sensitization
was seen in 25 persons exposed to a product containing 14.3% sodium laureth sulfate.
In two separate 21-day cumulative irritancy tests, products containing 0.7 or 1.25% active
concentrations of sodium laureth sulfate were tested in 10 (although only 4 completed the study) and 13
subjects, respectively. Daily applications of 1.25% sodium laureth sulfate resulted in severe irritation,
whereas the 0.7% sodium laureth sulfate produced mild irritation.
Animals
In a number of studies sharing similar protocols, one 0.5 ml sample each of various test solutions
containing concentrations of 5.0 to 58.0% sodium laureth sulfate was applied to intact and abraded skin of
albino rabbits for a period of 2, 3, or 7 days. No irritation was observed at concentrations of 5 0-5 6/0;
mild erythema and edema, sometimes transient in nature, were seen at concentrations of 6.0, 7.5. 10, 1 /.i,
and Wo whereas severe irritation occurred in test solutions containing 15, 25, 28, and 30/o sodium
laureth sulfate. In the tests using a concentration of 58% sodium laureth sulfate, no irritation occurred. The
discrepancy in these findings seen at higher doses (greater than 15%) was not discussed. No deaths were
reported at any dose or concentration.
A 0 *>5 molar solution of sodium laureth sulfate (approximately 5.0-10.0% solution by weight)
applied for 3 consecutive days to the shaved skin of weanling rats produced no irritat.on after 1 day and
slight erythema and edema after 3 days.
The ocular toxicity of sodium laureth sulfate was tested in groups of three, six, or nine albino
rabbits using a standardized Draize test. In 18 separate studies, 0.1 ml of test material instilled in the eyes,
with or without rinse, and observed for 1 week produced responses ranging from no irritation to severe eye
damage independent of the concentration range (1.3 to 58%) of sodium laureth sulfate in the test solution.
No discussion was provided for these findings.
To test for skin sensitization, a 0.1% aqueous solution of sodium laureth sulfate was applied
topically (3 times/week for 3 weeks) to 10 guinea pigs. Ten days after the final administrate, when
topically challenged, no skin sensitization was evident; however, when challenged by mtradermal
injections the animals showed a positive reaction 1 hour following the challenge, which increased in
intensity in three of the animals. At 48 hours six of the animals continued to show a positive reaction,
while the other four demonstrated only a slight reaction.
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Appendix C
Health Hazard Summaries
Subchronic/Chronic Toxicity
Humans
No studies of sodium laureth sulfate in solution have been identified for dermal exposure routes.
Animals
A subchronic study on the effect of an anion-active sodium laureth sulfate detergent on the skin
and hair cycles of rats was conducted. Various concentrations of the detergent dissolved in tap water were
applied daily for 65 days to the shaved backs of five groups (totaling 65) 7- to 8-week-old male rats.
Concentrations were as follows: Group-1 received pure detergent (60% sodium laureth sulfate); group-2,
30% sodium laureth sulfate; group-3, 9.0%; group-4, 0.9%; group-5 (controls), 0%. The group exposed to
the 60% solution experienced inflammatory changes, epidermal hyperplasia, epidermoid cyst formation,
and diffuse hair loss. Seven animals died between days 12 and 15. The 30% solution group had similar,
though less severe, skin changes, but had no deaths. No effect was seen for any other concentration.
A NOAEL of 1,000 ppm was identified for a study of rats fed dietary levels of 24% w/w sodium
laureth sulfate. Groups of 12 male and 12 female 5-week-old rats were fed diets containing 40, 200, 1,000,
or 5,000 ppm of active material for 13 weeks. Compared to controls (18 male and 18 female rats receiving
a standard diet), the behavior, body weights, food intake, hematological results, plasma proteins, urinary
findings, and urea concentrations were within normal limits. No pathology changes were observed at
necropsy. Kidney weights in males, and heart, liver, and kidney weights in females were increased in rats
fed 5,000 ppm, but increases in relative organ weights were not found to be statistically significantly
elevated.
In a long-term study (105 weeks) in groups of 30 rats fed diets containing 0 (controls), 0.5, or
0.1% sodium laureth sulfate, findings were essentially normal. There were no differences between treated
animals and controls with respect to appearance, behavior, organ weights, organ to body ratios, growth
rates, food consumption, and survival, with the exception of the male rats who had an unexplained weight
loss in the last 8 weeks of the study. Clinical laboratory studies, gross and microscopic pathology, and the
appearance of tumors assessed at 52 weeks (10 rats sacrificed from each group) and 105 weeks (the
remaining rats were sacrificed) were comparable between treated and control animals.
Neurotoxicity
No data have been located regarding the neurotoxic potential of sodium laureth sulfate exposure in
humans or animals.
Developmental/Reproductive Toxicity
Ten male and 10 female rats were fed diets containing 0.1% or no sodium laureth sulfate for 14
weeks, then mated. Their offspring (F, generation) were maintained on the same diet as their parents, and
mated at approximately 100 days old. Their (F,) progeny (F2 generation) were also kept on the same diet
for 5 weeks after weaning. No adverse effects on fertility, litter size, lactation, or survival of offspring, no
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Appendixj
Health Hazard Summaries
changes in the blood or urine of the F, and F2 generations, and no gross or microscopic changes that could
be attributable to the test compound were observed.
Mutagenicity
No data have been located regarding the mutagenic or genotoxic potential of sodium laureth
sulfate exposure in humans or animals.
Carcinogenicity
The carcinogenicity potential of sodium laureth sulfate was tested in mice (two groups of 30 each).
A dose of 0.1 ml of 5.0% aqueous solution of sodium laureth sulfate (5.0 mg) was applied twice a week for
105 weeks to the skin of 30 female mice. The total quantity of sodium laureth sulfate applied to each
mouse was approximately 1 g. No skin tumors appeared, and the mortality did not differ substantially
between the two groups of mice, but sample sizes were too small to detect most elevations.
Additionally, the long-term dietary study described above (see Chronic Toxicity section) found no
differences in tumor prevalence at 52 or 105 weeks between treated groups and controls.
Sodium Lauryl Isethionate (SLI)
Summary
The limited information on sodium lauryl isethionate suggests that this chemical may not be a skin
irritant and is not mutagenic. No other data were located on any other health endpoints for this compound
(CCRIS, 1995).
Absorption/Metabolism
No data have been located regarding the absorption/metabolism potential of SLI exposure in
humans or animals.
Acute Toxicity
No data have been located regarding the acute toxicity of SLI in humans or animals.
Irritation/Sens itization
One in vitro penetration cell experiment is reported, mentioning the irritancy of several surfactants;
no enzymes were released from rat skin slices (stratum corneum) following 3-5 hours of exposure to SLI
(24 hours incubation). The authors reported this was consistent with their prior knowledge that SLI does
not have irritant potential (CCRIS, 1995). No other data are reported regarding any dermal properties or
toxicity of SLI.
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Health Hazard Summaries
Subchronic/Chronic Toxicity
animals.
No data have been located regarding the subchronic/chronic toxicity of SLI exposure in humans or
Neurotoxicity
No data have been located regarding the neurotoxic potential of SLI exposure in humans or
animals.
Developmental/Reproductive Toxicity
No data have been located regarding the developmental/reproductive toxicity of SLI exposure in
humans or animals.
Mutagenicity
SLI tested negative in the Ames test using several strains of Salmonella with and without
metabolic activation at dose ranges of 16 to 2000 ug/plate (CCRIS, 1995).
Carcinogenicity
animals.
No data have been located regarding the carcinogenic potential of SLI exposure in humans or
C.2.2 Surfactant Aids
Acetic Acid
Summary
Acetic acid is a common substance added directly at 5% dilution to human food (i.e., baked goods,
cheeses, dairy product analogs, chewing gum, condiments, relishes, fats, oils, gravies, sauces, and meat
products). It is Generally Recognized As Safe (GRAS) for food use by the Food and Drug Administration
(FDA).
All studies reported relate to concentrations at least twice and as much as 16 times as great as
acetic acid in vinegar (typically under 6% dilution). Acute exposures to strong solutions (10-20%) of
acetic acid resulted in physiologic effects in humans. Splashes of vinegar (4-10% acetic acid solution)
have been reported to cause ocular pain and injury. At high concentrations dermal contact with acetic acid,
depending on the length of exposure, resulted in severe irritation in both humans and animals. At low
concentrations (under 10%) no dermal irritation was seen. Effects such as bronchitis, pharyngitis, erosion
of the teeth, conjunctivitis, palpebral edema and conjunctival hyperemia, digestive disorders, dry skin, and
blackening and hyperkeratosis of the skin have been reported in workers chronically exposed to high air
concentrations of acetic acid. No chronic effect was noted in animals. No neurologic effects were reported
in the literature used for this review. There is no evidence of mutagenicity related to acetic acid exposure.
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Health Hazard Summaries
Although no direct information on the carcinogenicity of acetic acid was located, one chronic study in rats
that were fed 350 mg/kg sodium acetate found no evidence of tumors. No reproductive studies were
located.
Absorption/Metabolism
Undiluted acetic acid is absorbed from the gastrointestinal tract and through the lungs (Clayton
and Clayton, 1982). It is readily metabolized by most tissues and may give rise to ketone bodies as
intermediates (Clayton and Clayton, 1982). No discussion is available regarding dermal absorption at 5%
solution.
Acute Toxicity
Humans
Splashes of vinegar (4-10% acetic acid solution) have been reported to cause ocular pain and
injury (HSDB, 1994).
Animals
Data are not reported on results of exposures to solutions of less than 10%.
Irritation/Sensitization
Humans
Acetic acid (undiluted) is caustic to the skin. It can cause dermatitis, ulceration and burns. Based
on animal experiments and industrial exposure, it is believed that human exposure (8 hours) to 10 ppm
could produce some eye, nose, and throat irritation, and exposure to 100 ppm could produce lung irritation
and possible damage to the lung, eyes, and skin (Clayton and Clayton, 1982). Skin sensitization, though
rare, has been reported in humans at as low as 1% (HSDB, 1994).
Immediate pain, conjunctival hyperemia, and sometimes injury to the cornea have resulted from a
splash of vinegar (4-10% acetic acid) to the eye. Exposures to air concentrations below 10 ppm have
resulted in conjunctivitis in some exposed persons (HSDB, 1994). Permanent corneal anesthesia and
opacity occurred in two individuals with accidental exposure of glacial (100%) acetic acid to the eyes, even
though they were immediately rinsed with water after the exposure occurred (HSDB, 1994).
Animals
No effect was seen following an application of 10% acetic acid to intact or abraded skin patches in
guinea pigs or rabbits (unspecified numbers and study length) (Clayton and Clayton, 1982). No discussion
is available regarding dermal exposures at 5% solution. Dermal application of 20 mg undilute acetic acid
applied to guinea pigs and rabbits (unspecified numbers) for 24 hours produced mild irritation (Clayton
and Clayton, 1982). A larger application of 0.5 ml of 525 mg undilute acetic acid in rabbits (unspecified
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Appendix C
Health Hazard Summaries
number) showed no corrosive effects after 4 hours but produced severe irritation (with necrosis) after 24
hours (Clayton and Clayton, 1982).
Subchronic/Chronic Toxicity
Human
All reports relate to high concentrations in the workplace. The principal finding among five
workers exposed for 7-12 years to high concentrations (80-200 ppm at peak concentration) of acetic acid
was blackening and hyperkeratosis of the skin (HSDB, 1994). In another study, bronchitis, pharyngitis,
erosion of the teeth and conjunctivitis were reported among workers (unspecified number) exposed for
7-12 years to concentrations of 60 ppm, plus 1 hour daily to concentrations in the range of 100-200 ppm
(HSDB, 1994). Other effects reported among workers (unspecified numbers) exposed for a number of
years to air concentrations of up to 200 ppm include palpebral edema, with hypertrophy of lymph nodes,
and conjunctival hyperemia (HSDB, 1994). Digestive disorders and dry skin have been reported in
workers (unspecified numbers or occupation) following repeated exposures (unspecified levels) (HSDB,
1994).
Animals
No information is reported on dermal exposures to solutions of less than 10%. Rats (unspecified
number) receiving daily doses of up to 390 mg/kg acetic acid in their drinking water (up to 5.0%) for 2 to 4
months, were found to experience weight loss (apparently due to anorexia) at the highest dose. The
NOAEL was 195 mg/kg/day; no deaths occurred in any dose group. Gastric lesions, forestomach wall
thickening, and inflammatory changes were observed in some (proportion unspecified) rats fed 4.5
g/kg/day for 30 days.
Neurotoxicity
No data regarding neurologic effects related to acetic acid exposures in humans or animals were
located.
Developmental/Reproductive Toxicity
No studies focusing on reproductive effects were located. Pregnant rats (unspecified number)
administered 1.6 g/kg/day apple cider vinegar (5.0% acetic acid) showed no increased mortality or fetal
abnormalities compared to sham-treated controls (unspecified study length and number of animals)
(Clayton and Clayton, 1982).
Mutagenicity
Acetic acid was not found to be mutagenic in two in vitro mutagenicity tests with or without
metabolic activation preparations from mice, rats, or monkeys (Clayton and Clayton, 1982).
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Health Hazard Summaries
Carcinogenicity
Male rats (unspecified number) fed 350 mg/kg sodium acetate, a salt of acetic acid, three
times/week for 63 weeks, followed by a dose of 140 mg/kg three times/week for 72 days (10+ weeks)
showed no histological evidence of tumors (Clayton and Clayton, 1982). This is insufficient to conclude
anything about the carcinogenicity of acetic acid.
Citric Acid and Sodium Citrate
Summary
Citric acid is a normal metabolite in humans and occurs naturally in many foods. It is generally
considered to be largely innocuous except in the case of ingestion of large quantities (i.e., levels well above
500 mg/kg, the estimated average daily intake) or chronic exposures. Chronic oral exposures in humans
may result in tooth erosion, local irritation, and some ulceration. Gastrointestinal irritation has also been
observed following ingestion of sodas containing citric acid. Citric acid dust may also be irritating to the
nose and throat. Citric acid has been shown to be a mild to moderate skin and eye irritant in humans
following inhalation or dermal exposures. Acute high dose exposures in animals have resulted in mild skin
and severe eye irritation. Limited animal data suggest that exposure to citric acid does not result in
developmental or reproductive effects. No information has been located discussing neurotoxic, mutagenic,
or carcinogenic effects associated with citric acid exposures in animals or humans.
The alkaline salt of citric acid, sodium citrate, is expected to behave chemically like the acid
systemically. Unlike the acid, however, this alkaline salt may not have irritant properties.
Absorption/Metabolism
Citric acid is a normal metabolite and an intermediate in cellular oxidative metabolism. It is
formed in the mitochondrion and successfully degraded to a series of four-carbon acids used in the
oxidative process of the cell (Clayton and Clayton, 1982). Sodium citrate is oxidized to bicarbonate in the
body and excreted in the urine (HSDB, 1994; no other details provided). No absorption by the skin is
expected following dermal exposures (USEPA, 1994).
Acute Toxicity
Humans
No reports relate to dermal exposure.
Animals
No tests reported relate to dermal exposure.
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Appendix C
Health Hazard Summaries
Irritation/Sensitization
Humans
Citric acid, in humans, may be a mild to moderate irritant if inhaled as an aerosol, or if in direct
contact with the eyes or skin (HSDB, 1994). Citric acid dust may also be irritating to the nose and throat
(HSDB, 1994). Citrate, about 1-2 g/day usually prescribed for ingestion in the form of citric acid and
sodium citrate solution, has been reported occasionally to result in gastrointestinal irritation (i.e., irritant
effect on the oral mucosa and necrotic and ulcerative lesions) (HSDB, 1994).
Animals
In rabbits (unspecified number), a moderate reaction was observed at 24 hours following a 500 mg
application of citric acid to the skin, whereas a severe eye effect was seen after a 750 fig application
(relation of amounts in application to potential amounts in formulation unknown) (Clayton and Clayton,
1982). In another study, a single drop of 2.0 to 5.0% solution of citric acid in water caused little or no
injury to rabbit eyes (unspecified .number); however, irrigation of a 0.5 to 2.0% solution resulted in severe
eye injury (HSDB, 1994). .
Subchronic/Chronic Toxicity
Humans
Frequent or excessive intake (unspecified) of citric acid in humans may result in tooth erosion and
local irritation (Clayton and Clayton, 1982) and some ulceration (HSDB, 1994). These have been seen
with lemon juice, about 7% citric acid (Clayton and Clayton, 1982). No dermal exposure responses are
discussed in the literature used for this review.
Animals
No dermal exposure studies are discussed in the literature used for this review.
Neurotoxicity
No data have been located regarding the neurotoxic potential of citric acid exposure in humans or
animals.
Developmental/Reproductive Toxicity
Citric acid has not been shown to be a reproductive hazard (HSDB, 1994). No studies involving
dermal exposure are reported. No reproductive effects were found in a study where two successive
generations of rats (unspecified number) were fed diets containing 1.2% citric acid over a 90-week period
(Clayton and Clayton, 1982). No effect was detected on litter size or survival up to weaning age in young
rats or mice (unspecified numbers) fed diets containing 5.0% citric acid (no study length provided)
(Clayton and Clayton, 1982).
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Health Hazard Summaries
Mutagenicity
No data have been located regarding the mutagenic or genotoxic potential of citric acid exposure
in humans or animals.
Carcinogenicity
No data have been located regarding the carcinogenic potential of citric acid exposure in humans
or animals.
Sodium Carbonate
The information (studies and conclusions) used in this health hazard have been adapted from a
report issued by the CIR panel (CIR, 1987), unless otherwise stated.
Summary
Sodium carbonate is a commonly used component in bath, skin, and hair preparations. Products
containing sodium carbonate may be expected to remain in contact with the skin up to an hour and are
likely to be used repeatedly over a period of several years. Sodium carbonate is also used as a GRAS
(generally regarded as safe) direct food ingredient. The CIR panel concluded that due to its alkaline
nature, sodium carbonate is a skin and eye irritant. Human skin exposures to products containing 0.0025%
active sodium carbonate were not considered to be strong irritants or sensitizers.
Repeated exposure of humans (a dockworker study) to dusts of sodium carbonate resulted in
severe skin irritation, as well as upper respiratory irritation. Repeated exposure to high concentrations of
aerosols containing sodium carbonate resulted in pathological changes to the lungs and respiratory tract of
mice, rats, and guinea pigs. LC50s ranging from 0.8 to 2.3 mg/1 (aerosols) were identified in rats, mice, and
guinea pigs. Sodium carbonate was not developmentally toxic to mice, rats, or rabbits. No information
was available discussing reproductive, neurotoxic, mutagenic, or carcinogenic toxicity following sodium
carbonate exposure to humans or animals.
Absorption/Metabolism
Because it is a solid, sodium carbonate is not expected to be absorbed through the skin but is
expected to be absorbed (in dissociated form) from the lung. In the stomach, the compound will react with
stomach acid to produce carbon dioxide, which is released in expired air (USEPA, 1994). In general,
solids such as sodium carbonate with high melting points (851 °C) do not penetrate the skin unless present
as very fine particles. In addition, inorganic salts, such as sodium carbonate, are generally considered not
to penetrate the skin (Schaefer et al., 1982).
Acute Toxicity
Acute toxicity studies of sodium carbonate in dilute solution have not been identified for dermal
exposure routes.
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Appendix C
Health Hazard Summaries
Humans
Available acute toxicity data on humans indicate that sodium carbonate may be irritating to
mucous membranes. Kamaldinova et al. (1976; as cited in Rom et al., 1983a) report an irritancy threshold
(presumably irritation to the upper respiratory tract) of 40 mg/m3 sodium carbonate in 14 volunteers
exposed by inhalation for 1 minute.
Animals
Sodium carbonate aerosols are moderately toxic to rodents (USEPA, 1994). Whole-body
inhalation exposure of adult male rats, mice or albino guinea pigs (unspecified numbers) to aerosols of
sodium carbonate (91-95% pure) for 2 hours resulted in LC50s of 2.3 mg/1 for rats, 1.2 mg/1 for mice, and
0.8 mg/1 for guinea pigs (Busch et al., 1983, as cited in USEPA, 1992). .Immediately after exposure,
clinical signs included dyspnea, wheezing, excessive salivation, and distention of the abdomen. Within 3
to 4 hours post exposure, all clinical signs subsided. Animals that died during or shortly after exposure
showed accumulation of mucus in, and vesiculation and mucosal edema of, the pharynx and larynx.
Edema and vesiculation of the anterior trachea, hemorrhage in the lungs, and severe gastric tympany were
also observed. Basal epithelial cells of the posterior pharynx and anterior trachea had enlarged
mitochondria following exposures of 1 hour or more. Clinical signs and pathologic changes in all animals
were similar regardless of dose level.
Irritation/Sensitization
Humans
The irritancy potential of three bar-soap products containing 0.25% sodium carbonate at a
concentration of 1.0% were tested in three groups of 107 to 109 male and female volunteers (CIR, 1987).
In all studies, following applications of two occlusive 24-hour patches (induction patch and challenge
patch) applied 24 hours apart, investigators concluded that observed reactions indicated weak, nonspecific
irritation; thus, this soap was neither a strong irritant nor contact sensitizer. Clayton and Clayton (1982)
summarize a human study in which a 50% solution of sodium carbonate was applied to the intact and
abraded skins of the volunteers. The solution produced no erythema, edema, or corrosion of intact skin.
Abraded skin showed moderate erythema and edema, and one-third of the human volunteers showed tissue
destruction at the abraded areas. Rom et al. (1983b, as cited in CIR, 1987) identified no further irritation or
sensitization by 10% aqueous sodium carbonate applied to miners suffering pruritic, erythematous lesions
from exposure to dust of trona ore (sodium sesquicarbonate, about 45-50% sodium carbonate).
Animals
A 50% (weight/volume) aqueous solution of sodium carbonate was applied to the intact, and
abraded skin of rabbits and guinea pigs, (CIR, 1987). The sites were examined at 4-, 24-, and 48-hours.
The solution produced no erythema, edema, or corrosion of intact skin. Abraded skins of guinea pigs were
negligibly affected, but abraded rabbit skins showed moderate erythema and edema.
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Appendix
C
Health Hazard Summaries
Sodium carbonate produced ocular irritation in rabbits (two groups of six or more) administered
0.1 ml powdered sodium carbonate, although observed opacities and iritis were transient in the group that
received eye rinses after exposure (CIR, 1987). Conjunctivitis persisted in both groups.
Subchronic/Chronic Toxicity
Humans
Kamaldinova et al. (1976, as cited in Rom et al., 1983a) reported that dockworkers exposed to
soda ash (sodium carbonate) in ship holds and freight cars at dust levels greater than 300 mg/m3 exhibited
"soda ash burns," a 1.5-fold increase in the incidence (unspecified comparison group) of skin diseases
(ulcers, erosion, eczema), and lost work days due to skin inflammation. Rhinitis, pharyngitis, and
conjunctivitis were also reported.
Animals
Male rats (number unspecified) were exposed to an aerosol of a 2.0% aqueous solution of sodium
carbonate (particles less than 5.0 \im diameter) 4 hours/day, 5 days/week, for 3.5 months. A concentration
of 10 to 20 mg/m3 did not cause any pronounced effect. Histological examination of the lungs of animals
exposed to higher doses (approximately 70 mg/m3) showed thickening of the intra-alveolar walls,
hyperemia, lymphoid infiltration, and desquamation (Clayton and Clayton, 1982).
In another study, 10 rats, 20 mice, and 10 guinea pigs were exposed for 2 hours to aerosols
consisting predominately of sodium carbonate at the following respective concentration ranges: 800-4,600
mg/m3, 600-3,000 mg/m3, and 500-3,000 mg/m3. For all aerosol concentrations, all animals show clinical
sign of toxicity (respiratory impairment, dyspnea, wheezing, excessive salivation, and distention of the
abdomen) immediately after exposure, sometimes resulting in death (unspecified number) (CIR, 1987).
Respiratory lesions in those that died were observed in the pharynx, larynx, trachea, and lungs. For
animals that survived the study, respiratory lesions were limited to the laryngeal mucosa.
Neurotoxicity
There are no data on the neurotoxicity of sodium carbonate.
Developmental/Reproductive Toxicity
Humans
There are no data on the reproductive or developmental toxicity of sodium carbonate in the
literature used for this review.
Animals
There are no data on the reproductive toxicity of sodium carbonate. Available data on
developmental toxicity in animals indicate that the compound is not a developmental toxicant.
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Appendix C
Health Hazard Summaries
Pregnant mice (number not specified) were dosed daily by oral intubation with aqueous solutions
of sodium carbonate at levels of 3.4 to 340 mg/kg during days 6 through 15 of gestation (Clayton and
Clayton, 1982; CIR, 1987). There were no effects on implantation or survival of the dams or fetuses. The
numbers of abnormalities in soft and skeletal tissues in the experimental group did not differ from those for
sham-treated controls. Similar results were observed in rats and rabbits dosed at 245 mg/kg and 179
mg/kg, respectively (CIR, 1987).
Mutagenicity
No data on mutagenicity as it related to sodium carbonate exposure were located in the literature.
Carcinogenicity
No human or animal studies were available to assess the carcinogenic potential of sodium
carbonate.
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Health Hazard Summaries
REFERENCES
ACGIH. 1986. American Conference of Governmental Industrial Hygienists. Committee on Threshold
Limit Values: Documentation of Threshold Limit Values. Cincinnati, OH.
Ahlborg Jr., G. 1990. Pregnancy outcome among women working in laundries and dry-cleaning shops
using tetrachloroethylene. Am J Ind Med 17:567-575. [As cited in ATSDR (1993).]
Alden, C.L. 1986. A review of unique male rat hydrocarbon nephropathy. Toxicol Pathol 14:109-111.
[As cited in ATSDR (1995).]
Anderson, C., K. Sundberg, and O. Groth. 1986. Animal model for assessment of skin irritancy. Contact
Dermatitis 15:143-151. [As cited in ATSDR (1995).]
Angelini, G., C. Foti, L. Rigano, and G.A. Ven. 1995. 3-Dimethylaminopropylamine: A key substance in
contact allergy to cocamidopropylamine? Contact Dermatitis 32:96-99.
Anttila, A., E. Pukkala, M. Sallmen, S. Hernberg, and K. Hemminki. 1995. Cancer incidence among
Finnish workers exposed to halogenated hydrocarbons. J Occup Med. In Press. [As cited in
IARC(1995).]
API. 1977. American Petroleum Institute. Teratology study in rats. Stoddard solvent final report.
Washington, DC. [As cited in ATSDR (1995).]
API. 1982. American Petroleum Institute. Mutagenicity study of thirteen petroleum fractions. Project no.
U-150-14(EA-1). Washington, DC. [As cited in ATSDR (1995).]
API. 1987. American Petroleum Institute.' Mutagenicity of API 8501, Stoddard solvent (CAS 8052-41-3)
in a mouse lymphoma mutation assay. Final report. Washington, DC. [As cited in ATSDR
(1995).]
Arlien-S6borg, P., P. Bruhn, C. Gyldensted, et al. 1979. Chronic painters' syndrome: Chronic toxic
encephalopathy in house painters. ActaNeurol Scand 60:149-156. [As cited in ATSDR (1995).]
Aschengrau, A., D. Ozonoff, C. Paulu, et al. 1993. Cancer risk and tetrachloroethylene-contaminated
drinking water in Massachusetts. Arch Env Hlth 48:284-292.
ATSDR. 1993. Agency for Toxic Substances and Disease Registry. Toxicological profile for
tetrachloroethylene. USDHHS, Agency for Toxic Substances and Disease Registry, Public Health
Service. Atlanta, GA.
ATSDR. 1995. Agency for Toxic Substances and Disease Registry. Toxicological profile for Stoddard
solvent. USDHHS, Agency for Toxic Substances and Disease Registry, Public Health Service.
Atlanta, GA.
C-46
-------
Appendix C
Health Hazard Summaries
Bagnell, P.C., and H.C. Ellenberger. 1977. Obstructive jaundice due to a chlorinated hydrocarbon in
breast milk. J Can Med Assoc 117:1047-1048. [As cited in USEPA (1985).]
Birner, G., A. Rutkowska, and W. Dekant. 1996. AMLcetyl-S-(l,2,2-trichlorovinyl)-L-cysteine and 2,2,2-
trichloroethanol: Two novel metabolites of tetrachloroethene in humans after occupational
exposure. Drug Metabolism and Disposition 24:41-48.
Blair, A., P. Decoufle, and D. Graumen. 1979. Causes of death among laundry and dry-cleaning workers.
Am. J. Public Health 69(5):508-511. [As cited in USEPA (1985).]
Bosco, M.G., I. Figa-Talamanca, and S. Salerno. 1987. Health and reproductive status of female workers
in dry cleaning shops. Int Arch Occup Environ Health 52:295-301. [As cited in ATSDR (1993).]
Braunstein, L.E. 1940. Subacute yellow atrophy of the liver due to solvent. J Am Med Assoc 114-136-
138.
Brodkin, C.A., W. Daniell, H. Checkoway, D. Echeverria, J. Johnson, K. Wang, R. Sohaey, D. Green, C.
Redlich, D. Gretch, and L. Rosenstock. 1995. Hepatic ultrasonic changes in workers exposed to
perchloroethylene. Occup. Environ. Med. 52:679-685.
Busch, R.H., K.E. McDonald, J.K. Briant, J.E. Morris, and T.M. Braham. 1983. Pathologic effects in
rodents exposed to sodium combustion products. Environ Res 31:138-147 [As cited in USEPA
(1992).]
Brown, D., and S. Kaplan. 1987. Retrospective cohort mortality study of dry cleaner workers using
perchloroethylene. J. Occup. Med. 29(6):535-541. [As cited in ATSDR (1993).]
Cameli, N., G. Tosti, N. Venture, and A. Tosti. 1991. Eyelid dermatitis due to cocamidopropyl betaine in
a hard contact lens solution. Contact Dermatitis 25:261-262.
Carpenter, C.P. 1937. The chronic toxicity of tetrachloroethylene. J Ind Hyg Toxicol 19-323-336 [As
cited in ATSDR (1993).]
Carpenter, C.P., E.R. Kinkead, D.L. Geary Jr., et al. 1975a. Petroleum hydrocarbon toxicity studies:
I. Methodology. Toxicol AppI Pharmacol 32:246-262.
Carpenter, C.P., E.R. Kinkead, D.L. Geary Jr., et al. 1975b. Petroleum hydrocarbon toxicity studies: III.
Animal and human response to vapors of Stoddard solvent. Toxicol Appl Pharmacol 32:282-297.
CCRIS. 1995. Chemical Carcinogenesis Research Information System. Built and maintained by the
National Cancer Institute; reviewed by expert consultants and qualified contractors.
CIR. Cosmetic Ingredient Review Expert Panel. 1983. Final report on the safety assessment of sodium
laureth sulfate and ammonium laureth sulfate. J. Am. Coll. Toxicol. 2(5): 1-34.
C-47
-------
iixC
Health Hazard Summaries
CIR Cosmetic Ingredient Review Expert Panel. 1984. Final report on the safety assessment of
polysorbates 20, 21, 40, 60, 61, 65, 80, 81, and 85. J. Am. Coll. Toxicol. 3(5):l-82.
CIR Cosmetic Ingredient Review Expert Panel. 1986a. Final report on the safety assessment of
hydroxyethylcellulose, hydroxyproplycellulose, methylcellulose, hydroxyproplymethylcellulose,
and cellulose gum. J. Am. Coll. Toxicol. 5(3):l-59.
CIR. Cosmetic Ingredient Review Expert Panel. 1986b. Final report on the safety assessment of
lauramide DBA, linoleamide DEA, and oleamide DEA. J. Am. Coll. Toxicol. 5(5):415-454.
CIR. Cosmetic Ingredient Review Expert Panel. 1987. Final report on the safety assessment of sodiurn
sesquicarbonate, sodium bicarbonate, and sodium carbonate. J. Am. Coll. Toxicol. 6(1):121-138.
CIR. Cosmetic Ingredient Review Expert Panel. 1991. Final report on the safety assessment of
cocamidopropyl betaine. J. Am. Coll. Toxicol. 10(l):33-52.
Clavton G D and F.E. Clayton. Eds. 1982. Patty's Industrial Hygiene and Toxicology; Third revised
edition" Volume 2C Toxicology. John Wiley and Sons, New York, pp. 3059-3061, 4386-4389,
4358-4359, 4909-4911,4946-4948.
Coler, H.R., and H.R. Rossmiller. 1953. Tetrachloroethylene exposure in a small industry. Ind Hyg
Occupa Med 8:227. [As cited in USEPA (1985).]
Conaway C C., C.A. Schreiner, and S.T. Cragg. 1984. Mutagenicity evaluation of petroleum
hydrocarbons In: Advances in Modern Environmental Technology. Vol. 6: Applied toxicology
of petroleum hydrocarbons. H.N. MacFarland, C.E. Holdsworth, J.A. MacGregor, et al., Eds.
Princeton Scientific Publishers, Inc., Princeton, NJ. pp. 89-107. [As cited in ATSDR( 1995).]
CTFA Cosmetic Toiletry and Fragrance Association. 1976. Submission of unpublished data. Primary
" skin irritation study on 20 percent aqueous lauramide DEA. CIR, Washington, DC. No. 2-32-82.
CTFA Cosmetic, Toiletry and Fragrance Association. 1977a. Submission of unpublished data. Acute
oral toxicity of a bubble bath containing 6 percent lauramide DEA. CIR, Washington, DC. No.
2-32-47.
CTFA Cosmetic, Toiletry and Fragrance Association. 1977b. Submission of unpublished data. Primary
skin irritation study on 10 percent aqueous lauramide DEA. CIR, Washington, DC. No. 2-32-56.
CTFA. Cosmetic, Toiletry and Fragrance Association. 1977c. Submission of unpublished data. Human
primary skin irritation study on a bubble bath containing 6 percent lauramide DEA. CIR,
Washington, DC. No. 2-32-51.
CTFA. Cosmetic, Toiletry and Fragrance Association. 1977d. Submission of unpublished data. Repeat
insult patch test on a medicated liquid cleanser containing 5 percent lauramide DEA. CIR,
Washington, DC. No. 2-32-63.
C-48
-------
Appendix C
Health Hazard Summaries
CTFA. Cosmetic, Toiletry and Fragrance Association. 1978a. Submission of unpublished data. Acute
oral toxicity of 25 percent lauramide DBA in corn oil. CIR, Washington, DC. No. 2-32-53.
CTFA. Cosmetic, Toiletry and Fragrance Association. 1978b. Submission of unpublished data. Acute
dermal toxicity of 50 percent lauramide DBA in corn oil. CIR, Washington, DC. No. 2-32-54.
CTFA. Cosmetic, Toiletry and Fragrance Association. 1979a. Submission of unpublished data. Acute
oral toxicity of a noncoloring shampoo containing 8.0 percent lauramide DBA. CIR, Washington
DC. No. 2-32-72. '
CTFA. Cosmetic, Toiletry and Fragrance Association. 1979b. Submission of unpublished data. Acute
oral toxicity of a noncoloring shampoo containing 8.0 percent lauramide DBA. CIR Washington
DC. No. 2-32-73. '
CTFA. Cosmetic, Toiletry and Fragrance Association. 1979c. Submission of unpublished data. Acute
oral toxicity of a noncoloring shampoo containing 8.0 percent lauramide DBA. CIR, Washington
DC. No. 2-32-74.
CTFA. Cosmetic, Toiletry and Fragrance Association. 1979d. Submission of unpublished data. Human
primary skin irritation test on a noncoloring shampoo containing 8 percent lauramide DBA CIR
Washington, DC. No. 2-32-79.
CTFA. Cosmetic, Toiletry and Fragrance Association. 1979e. Submission of unpublished data. Repeat
insult patch test on a skin cleanser containing'^ percent lauramide DBA. CIR, Washington DC
No. 2-32-32. , , ' '
CTFA. Cosmetic, Toiletry and Fragrance Association. 1980a. Submission of unpublished data.
Subchronic dermal toxicity study on a medicated liquid cleanser containing 5.0 percent lauramide
DBA. CIR, Washington, DC. No. 2-32-64.
CTFA. Cosmetic, Toiletry and Fragrance Association. 1980b. Submission of unpublished data. Human
soap chamber test on a liquid soap containing 10 percent lauramide DBA. CIR, Washington DC
No. 2-32-104. •. ' . ' '
CTFA. Cosmetic, Toiletry and Fragrance Association. 1980c. Submission of unpublished data. Repeat
insult patch test on a liquid soap containing 10 percent lauramide DBA. CIR, Washington DC
No. 2-32-150. , '
CTFA. Cosmetic, Toiletry and Fragrance Association. 1980d. Submission of unpublished data. Repeat
insult patch test on a liquid soap containing 10 percent lauramide DBA. CIR Washington DC
No. 2-32-105. . ' '
CTFA. Cosmetic, Toiletry and Fragrance Association. 1981a. Submission of unpublished data. Human
primary skin irritation test on a product containing 5 percent lauramide DBA. CIR Washington
DC. No. 2-32-70. '
C-49
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Appendix C
Health Hazard Summaries
CTFA. Cosmetic, Toiletry and Fragrance Association. 1982a. Submission of unpubished data
Subchronic dermal toxicity study on a cream cleanser containing 4.0 percent lauramide DBA.
CIR, Washington, DC. No. 2-32-33.
CTFA. Cosmetic, Toiletry and Fragrance Association. 1982b.
soap chamber test on a liquid soap containing 10 percent lauramide DBA. CIR, Washington, DC.
No. 2-32-103.
CTFA. Cosmetic, Toiletry and Fragrance Association. 1982c. Submission of unpublished ^ta. Human
soap chamber test on a liquid soap containing 10 percent lauramide DBA. CIR, Washington, DC.
No. 2-32-102.
Daniell, W.E., W.G. Couser, and L. Rosenstock. 1988. Occupational solvent exposure and
glomerulonephritis: A case report and review of the literature. J Am Med Assoc 259:2280-2283.
[As cited in ATSDR (1995).]
Davidson IWF and R.P. Beliles. 1991. Consideration of target organ toxicity of trichloroethylene in
terms of metabolite toxicity and pharmacokinetics. Drug Metabolism Reviews 23:493-599.
Dice W.H., G. Ward, J. Kelley, et al. 1982. Pulmonary toxicity following gastrointestinal ingestion of
kerosene. Ann Emerg Med 1 1:138-142. [As cited in USEPA (1993).]
Duh RW. and N.R. Asal. 1984. Mortality among laundry and dry cleaning workers in Oklahoma. Am
Pub Health 74(11): 1278-1280. [As cited in USEPA (1985).]
Eberhardt, H., and K.J. Freundt. 1966. Tetrachloroethylene poisoning. Arch Toxikol (Berlin) 21:338-
351. (In German; English translation). [As cited in USEPA (1985).]
ECETOC, 1990. Technical Report No. 37. Tetrachloroethylene assessment of human carcinogenic
hazard.
Echeverria, D., R.F. White, and C. Sampaio. 1995. A behavioral evaluation of PCE exposure in patients
and dry cleaners: a possible relationship between clinical and preclinical effects. JOEM
37(6):667-680.
Eskenazi, B., A.J. Wyrobek, L. Fenster, et al. 1991a. A study of the effect of perch loroethylene exposure
on the reproductive outcomes of wives of dry cleaning workers. Am J Ind Med 20:575-691 .
Eskenazi, B., A.J. Wyrobek, L. Fenster, et al. 1991b. A study of the effect of perchloroethylene exposure
on semen quality in dry cleaning workers. Am J Ind Med 20:593-600.
Flodin U C Edling, and O. Axelson. 1984. Clinical studies with psychoorganic syndromes among
' workers with exposure to solvents. Am J Ind Med 5:287-295. [As cited in ATSDR (1995).]
Fowler, J.F. 1993. Cocamidopropyl betaine: the significance of positive patch test results in twelve
'patients. Cutis 52:281-284.
-------
Appendix C
Health Hazard Summaries
Friberg, L., B. Kylin, and A. Nystrom. 1953. Toxicities of trichloroethylene and tetrachloroethylene and
Fujiwara's pyridine-alkali reaction. Acta Pharmacol Toxicol 9:303-312. [As cited in ATSDR
(1993).]
Gamberale, F., G. Annwall, and M. Hultengren. 1975. Exposure to white spirit: II. Psychological
functions. Scand J Work Environ Health 1:31-39.
Gennari, P.M., M. Naldi, and R. Motta. 1992. Gamma-glutamyltransferase isoenzyme patter in workers
exposed to perchloroethylene. Am JInd Med 21:661-671.
Gochet, B., C. de Meester, A. Leonard, et al. 1984. Lackof mutagenic activity of white spirit. Int Arch
Occup Environ Health 53:359-364. [As cited in ATSDR (1995).]
Gold, J.H. 1969. Chronic perchloroethylene poisoning. Can Psychiatric Assoc J 14:627-630 [As cited in
USEPA (1985).]
Goldsworthy, T.L., et al. 1988. Assessment of chlorinated hydrocarbon-induced genotoxicity and cell
replication in rat kidney cells. Env Mol Mu (11)(11):39. [As cited in USEPA (1991).]
Green, T., J. Odum, J.A. Nash, and J.K. Foster. 1990. Perchloroethylene-induced rat kidney tumors: An
investigation of the mechanisms involved and their relevance to humans. Toxicol Appl Pharmacol
103:77-89. [As cited in ECETOC (1990).]
Gregersen, P. 1988. Neurotoxic effects of organic solvents in exposed workers: Two controlled follow-up
studies after 5.5 and 10.6 years. Am J Ind Med 14:681-702. [As cited in ATSDR (1995).]
Gregersen, P., B. Angelsoe, T.E. Nielson, et al. 1984. Neurotoxic effects of organic solvents in exposed
workers: An occupational, neuropsychological, and neurological investigation. [As cited in
ATSDR (1995).]
Hake, C.L., and R.D. Stewart. 1977. Human exposure to tetrachloroethylene: Inhalation and skin contact
Environ Health Perspect 21:231-238. [As cited in ATSDR (19,93).]
Hane, M., O. Axelson, J. Blume, et al. 1977. Psychological function changes among house painters.
Scand J Work Environ Health 3:91-99. [As cited in ATSDR (1995).]
Hardin, B.D., G.P. Bond, M.R. Sikov, F.D. Andrew, R. Beliles, and R.W. Niemier. 1981. Testing of
selected workplace chemicals for teratogenic potential. Scand J Work Env Health (Suppl 4V66-
75. [As cited in ATSDR (1993).]
Hastings, L., G.P. Cooper, and. W. Burg. 1984. Human sensory response to selected petroleum
hydrocarbons. In: Advances in Modern Environmental Toxicology. Vol. 6: Applied toxicology of
petroleum hydrocarbons. H.N. MacFarland, C.E. Holdsworth, J.A. MacGregor, et al., Eds.
Princeton Scientific Publishers, Inc., Princeton, NJ. pp. 255-270.
C-51
-------
idixC
Health Hazard Summaries
HSDB. 1994. Hazardous Substance Data Bank. Developed and maintained by the National Library of
Medicine, Washington, DC.
I ARC 1995 International Agency for Research on Cancer. I ARC Monographs on the Evaluation of
Carcinogenic Risks to Humans, Vol. 63, Dry cleaning, Some Chlorinated Solvents and Other
Industrial Chemicals. Tetrachloroethylene, pp. 159-221. Lyon, France.
Kamaldinova etal. 1976. The study of the effect of soda ash aerosol on the organism (natural and
experimental investigations). Gig TR Prof Zabol 11:55-57 (Russian). [As cited in Rom, et al.
(1983a).]
Kaplan SD 1980. Dry-cleaners workers exposed to perchloroethylene: a retrospective cohort mortality
' study Contract No. 210-77-0094. U.S. Department of Health, Education, and Welfare, National
Institute for Occupational Safety and Health. Washington, DC. [As cited in USEPA (1985).]
Katz R.M., and D. Jowett. 1981. Female laundry and dry-cleaning workers in Wisconsin: a mortality
analysis. Am J Pub Health 71:305-307. [As cited in USEPA (1985).]
Korting, H.C., E.M. Parsch, F. Enders, and B. Przybilla. 1992. Allergic contact dermatitis to
cocamidopropyl betaine in shampoo. J Amer Acad Derm 27:1013-1015.
Kyyroenen,P.,H.Taskinen,M.L.Lindbohm,etal. 1989. Spontaneous abortions and congenital
malformations among women exposed to tetrachloroethylene in dry cleaning. J Epidemiol
Community Health 43:346-351. [As cited in ATSDR (1993).]
Levine, B., M.F. Fierro, S.W. Goza, et al. 1981. A tetrachloroethylene fatality. J Forensic Sci 26:206-
' 209. [As cited in ATSDR (1993).]
Lin, R.S.. and I.I. Kessler. 1981. A multifactorial model for pancreatic cancer in man. J Am Med Assoc
245:147-152. [As cited in USEPA (1985).]
Litovitz, T., and A.E. Greene. 1988. Health implications of petroleum distillate ingestion. State Art Rev
Occup Med 3:555-567.
Lob,M. 1957. Dangers of perchloroethylene. Arch Gewerbepath Gewerbehyg 16:45-52. (In German;
English translation). [As cited in USEPA (1985).]
Lukaszewski, T. 1979. Acute tetrachloroethylene fatality. Clin Toxicol 15:411-415. [As cited in ATSDR
(1993).]
Mann, M.D., D.J. Pirie, and J. Wolfsdorf. 1977. Kerosene absorption in primates. J Pediatr 91(3):495-
498. [As cited in USEPA (1993).]
McDonald, A.D., B. Armstrong, N.M. Cherry, et al. 1986. Spontaneous abortion and occupation.
J Occup Med 28:1232-1238. [As cited in ATSDR (1993).]
C-52
-------
Appendix C
Health Hazard Summaries
McDougal, J.N., G.W. Jepson, H.J. Clewell III, M.L. Gargas, and M.E. Anderson. 1990. Dermal
absorption of organic chemical vapors in rats and humans. Fund. Appl. Tox. 14:299-308.
Mergler, D., S. Belanger, S. de Grosbois, et al. 1988. Chromal focus of acquired chromatic discrimination
loss and solvent exposure among printshop workers. Toxicology 49:341-348. [As cited in
ATSDR(1995).]
Mikkelsen, S., M. Jorgensen, E. Browne, et al. 1988. Kerosene "burns": A new case. Contact Dermatitis
19(4):314-315. [As cited in ATSDR(1995).]
Morgan, B. 1969. Dangers of perchloroethylene (Letter). Br Med J 2:513. [As cited in ATSDR( 1993).]
Mutti, A., R. Alinovi, E. Bergamaschi, C. Biagini, S. Cavazzini, I. Franchini, R.R. Lauwerys, A.M.
Bernard, H. Roels, E. Gelpi, J. Rosello, I. Rams, R.G. Price, S.A. Taylor, M. DeBroe, G.D. Nuyts,
H. Stolte, L.M. Pels, and C. Herbert. 1992. Nephropathies and exposure to perchloroethylene in
dry cleaners. The Lancet. Vol. 340 (8813):189-193.
Narotsky, M.G., and R.J. Kavlock. 1995. A multi-disciplinary approach to toxicological screening:
developmental toxicity. J of Env Tox and Env Health 45:145-171.
NCI. 1977. National Cancer Institute. Bioassay of tetrachloroethylene for possible carcinogenicity. U.S.
Department of Health, Education, and Welfare. Pub. NIH 77-813. Washington, DC. [As cited in
USEPA(1985).]
NESCAUM. 1989. Northeast States for Coordinated Air Use Management. Evaluation of the health
effects from exposure to gasoline and gasoline vapors. Final report.
Nethercott, J., J.M. Pierce, G. Likwornik, et al. 1980. Genital ulceration due to Stoddard solvent. J
Occup Med 22:549-552. [As cited in ATSDR (1995).]
NTP. 1986. National Toxicology Program. Toxicology and carcinogenesis of tetrachloroethylene
(perchloroethylene) (CAS No. 127-18-4) in F344/N rats and B6C3F, mice (inhalation studies).
NIH pub. 86-2567. NTP TR 311. National Institutes of Health. Bethesda, MD [As cited in
ATSDR (1993).]
NTP. 1998. National Toxicology Program. Division of Toxicology Research and Testing; Management
Status Report. April 13. p. 22.
Odum, J., T. Carean, J.R. Foster, and P.M. Hext. 1988. The role of trichloroacetic acid and peroxisome
proliferation in differences in carcinogenicity of perchloroethylene in the mouse and rat. Toxicol
Appl Pharmacol 92:103-112. [As cited in ECETOC (1990).]
Olsen, J., K. Hemminki, G. Ahlborg, et al. 1990. Low birthweight, congenital malformations, and
spontaneous abortions among dry-cleaning workers in Scandinavia. Scand J Work Environ Health
16:163-168.
C-53
-------
sndix C
Health Hazard Summaries
Olson, B.A. 1982. Effects of organic solvents on behavioral performance of workers in the paint industry.
Neurobehav Toxicol Teratol 4:703-708.
Pedersen, L.M., K. Larsen, and C.-H. Kohr. 1984. Kinetics of white spirits in human fat and blood during
short-term experimental exposure. Acta Pharmacol Toxicol 55:308-316. [As cited in ATSDR
(1995).]
Pedersen L.M., S. Rasmussen, and C.-H. Kohr. 1987. Further evaluation of the kinetics of white spirits
in human volunteers. Pharmacol Toxicol 60:135-139. [As cited in ATSDR (1995).]
Peter, C., and E. Hoting. 1992. Contact allergy to cocamidopropyl betaine (CAPB). Contact Dermatitis
26:282-283.
Pfaffli.P., H. Harkonen, and H. Savolainen. 1985. Urinary dimethylbenzoic-acid excretion as an
' indicator of occupational exposure to white spirit. J Chromatography, Biomedical Applications
337:146-150.
Phillips, R.D., and G.F. Egan. 1981. Teratogenic and dominant lethal investigation of two hydrocarbon
solvents. Abstract. Toxicologist 1:15.
Pigatto, P.D., A.S. Bigardi, and F. Cusano. 1995. Contact dermatitis to cocamidopropylbetaine is caused
'by residual amines: Relevance, clinical characteristics, and review of the literature. Am J Contact
Dermatitis 6:13-16.
Prager, D., and C. Peters. 1970. Development of aplastic anemia and the exposure to Stoddard solvent.
' Blood 35:286-287. [As cited in ATSDR (1995).]
Regulatory Toxicology and Pharmacology. 1994. Interpretive review of the potential adverse effects of
chlorinated organic chemicals on human health and the environment. Report of an expert panel.
Reg Tox & Pharm, 94: August.
Riley, A.J., A.J. Collings, N.A. Browne, et al. 1984. Responses of the upper respiratory tract of the rat to
white spirits vapor. Toxicol Lett 22:125-132. [As cited in ATSDR (1995).]
Riihimaki, V., and P. Pfaffli. 1978. Percutaneous absorption of solvent vapors in man. Scand. J. Work
Environ. Health 4:73-85.
Rom, W.N., W. Greaves, K.M. Bang, M. Holthouser, D. Campbell, and R. Bernstein. 1983a. An
epidemiologic study of the respiratory effects of trona dust. Arch Environ Health 38:86-92.
Rom, W.N., A. Moshell, W. Greaves, K.M. Bang, M. Holthouser, D. Campbell, and R. Bernstein. 1983b.
A study of dermatitis in trona miners and millers. J. Occup. Med. 25(4):295-9.'[As cited in CIR
(1987).]
Ross, J.S., and I.R. White. 1991. Eyelid dermatitis due to cocamidopropyl betaine in an eye make-up
remover. Contact Dermatitis 25:64.
C-54
-------
Appendix C
Health Hazard Summaries
Rothman, N., and E.A. Emmett. 1988. The carcinogenic potential of selected petroleum-derived products.
State Art Rev Occup Med 3:475-494. [As cited in ATSDR (1995).]
Rowe, V.K., D.D. McCollister, H.C. Spencer, E.M. Adams, and D.D. Irish. 1952. Vapor toxicity of
tetrachloroethylene for laboratory animals and human subjects. Arch Ind Hyg Occup Med 5:566-
579. [As cited in ATSDR (1993).]
RTL. 1978. Research Testing Laboratories. Submission of unpublished data. Repeat insult patch test on
a bubble bath containing 6 percent lauramide DBA. CIR, Washington, DC. No. 2-32-52.
RTL. 1980. Research Testing Laboratories. Submission of unpublished data. Repeat insult patch test on
a noncoloring shampoo containing 8 percent lauramide DBA. CIR, Washington, DC No
2-32-71.
Ruder, A.M., E.M. Ward, and D. Brown. 1994. Cancer mortality in female and male dry-cleaning
workers. JofOcc Med 25:867-874.
Saland, G. 1967. Accidental exposure to perchloroethylene. NY State J. Med. September 1:2359-61.
Sallmen, M., M.L. Lindbohm, P. Kyyroenen, E. Nykyri, A. Anttila, H. Taskinen, and K. Hemminki. 1995.
Reduced fertility among women exposed to organic solvents. Am. J. Ind. Med. 27:699-713.
Schaefer, H., A. Zesch, and G. Stuettgen. 1982. Skin permeability. Springer-Verlag, London.
Schumann, A.M., T.F. Quast, and P.G. Watanabe. 1980. The pharmacokinetics of perchloroethylene in
mice and rats as related to oncogenicity. Toxicol Appl Pharmacol 55:207-219. [As cited in IRIS
(1993).]
Schwetz, B.A., B.K. Leong, and P.J. Gehring. 1975. The effect of maternally inhaled trichloroethylene,
perchloroethylene, methyl chloroform, and methylene chloride on embryonal and fetal
development in mice and rats. Toxicol Appl Pharmacol 32:84-96.
Scott, J.L., G.E. Cartwright, and M.M. Wintrobe. 1959. Acquired aplastic anemia - an analysis of thirty-
nine cases and review of the pertinent literature. Medicine 38:119-172. [As cited in ATSDR
(1995).]
Setala, K. 1960. Progress in carcinogenesis, tumor enhancing factors. A bio-assay of skin tumor
formation. Progr. Exp. Tumor Res. 1:225- 278. [As cited in CIR (1984).]
Siemiatycki, J., R. Dewar, L. Nadon, et al. 1987. Associations between several sites of cancer and twelve
petroleum-derived liquids: Results from a case-referent study in Montreal. Scand J Work Environ
Health 13:493-504.
Smith, M.K., J.L. Randall, E.J. Read, and J.A. Stober. 1989. Teratogenic activity of trichloroacetic acid.
Teratology 40:445-451. [As cited in Davidson and Beliles (1991).]
C-55
-------
idixC
Health Hazard Summaries
Stewart, R.D. 1969. Acute tetrachloroethylene intoxication. J Am Med Assoc 208(8): 1490-1492. [As
'cited in USEPA (1985).]
Stewart R D., C.L. Hake, M.V. Forster, et al., 1981. Tetrachloroethylene: development of a biologic
standard for the industrial worker by breath analysis. NIOSH Contract No. HSM-99-27-84. NT1S
No. PB82-152166. Cincinnati, OH.
Taniguchi, S., J. Katoh, T. Hisa, M. Tabata, and T. Hamada. 1992. Shampoo dermatitis due to
cocamidopropyl betaine. Contact Dermatitis 26:139.
Tepe, S.J., M.K. Dorfmueller, R.G. York, and J.M. Manson. 1982. Teratogenic evaluation of
perchloroethylene in rats. Unpublished. [As cited in USEPA (1985).]
Tinston, D.J. 1995. Perchloroethylene: A multigeneration inhalation study in the rat. Report No.
'cTL/P/4097. Study performed by Zeneca Central Toxicology Laboratory, UK. Sponsored by the
Halogenated Solvents Industry Alliance (HSIA). Unpublished.
Tuohimaa P., and L. Wichmann. 1981. Sperm production of men working under heavy-metal or organic
solvent exposure. In: Occupational Hazards and Reproduction. K. Hemminki, M. Sorsa, and H.
Vainio, Eds. Hemisphere Publishing Corp., Washington, DC. pp. 73-79. [As cited in ATSDR
(1995).]
USEPA. 1984. U.S. Environmental Protection Agency. Summary of histopathology findings for dermal
carcinogenesis lifetime skin painting study of solvent-cutback type rust preventative. Document
no. 88-8400629. USEPA, Office of Toxic Substances. Washington, DC.
USEPA 1985 US Environmental Protection Agency. Health assessment document for
tetrachloroethylene (perchloroethylene). EPA/600/8-82/005F. PB-85-249704/AS. USEPA,
Office of Health and Environmental Assessment. Washington, DC.
USEPA. 1986. U.S. Environmental Protection Agency. Addendum to the health assessment document
for tetrachloroethylene (perchloroethylene). Updated carcinogenicity assessment for
tetrachloroethylene (Perchloroethylene, PERC, PCE). Review Draft. EPA/600/8-82/005FA.
USEPA. 1988. U.S. Environmental Protection Agency. Health effects assessment for
tetrachloroethylene. EPA/600/8-89/096. USEPA, Office of Research and Development, Office of
Health and Environmental Assessment, Environmental Criteria and Assessment Office.
Cincinnati, OH.
USEPA. 1991. U.S. Environmental Protection Agency. Response to issues and data submissions on the
carcinogenicity of tetrachloroethylene (perchloroethylene). EP A/600/6-91/002F.
USEPA. 1992. U.S. Environmental Protection Agency. External review draft: Aqueous and terpene
cleaning: Interim report. USEPA, Office of Toxic Substances. Washington, DC. September 16.
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Health Hazard Summaries
USEPA; 1993. U.S. Environmental Protection Agency. Dry cleaning industry MACT standard. Briefing
for the Deputy Administrator. USEPA, Office of Air and Radiation. May 24.
USEPA. 1994. U.S. Environmental Protection Agency Structure Activity Team. Washington, DC.
Unpublished.
Verkkala, E., P. Pfaffli, and H. Savolainen. 1984. Comparison of local neurotoxicity of three white spirit
formulations by percutaneous exposure of rat tail nerve. Toxicol Lett 21:293-299.
Vernot, E.H., R.T. Drew, and M.L. Kane. 1990. Acute toxologic evaluation of unleaded motor gasoline.
Abstract. Acute Toxic Data 1:28. [As cited in ATSDR (1995).]
Vilaplana, J., J.M. Mascaro, C. Trullas, J. Coll, C. Romaguera, C. Zemba, and C. Pelejero. 1992. Human
irritant response to different qualities and concentrations of cocoamidopropyl-betaines: a possible
model of paradoxical irritant response. Contact Dermatitis 26:289-294.
Wolfsdorf, J., and H. Kundig. 1972. Kerosene poisoning in primates. S AfrMed J 46(20):619-621. [As
, cited in USEPA (1993).]
Zielhuis, G.A., R. Gijsen, and J.W.J. Van Der Gulden. 1989. Menstrual disorders among dry-cleaning
workers. Scand J Work Environ Health 15:238. [As cited in ATSDR (1995).]
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APPENDIX D
DOSE-RESPONSE ASSESSMENTS
This appendix presents dose-response assessments for drycleaning (perchloroethylene and
hydrocarbon solvents) and for machine wetcleaning chemicals.
D.I DRYCLEANING
This section presents dose-response assessments for perchloroethylene (PCE) and hydrocarbon
(HC) solvents (specifically, Stoddard solvent).
D.I.I Perchloroethylene
Cancer
A specific cancer dose-response assessment is developed under the assumption that an agent is a
human carcinogen. The dose-response assessment is intended to quantitatively define the relationship
between the dose of the agent and the likelihood of a carcinogenic effect. First, an attempt is made to
predict the relationship from epidemiologic studies. In the case of PCE, the epidemiology is insufficient to
define the relationship.
Turning to the animal data, hepatocellular adenomas and carcinomas were produced in PCE-
exposed mice of both sexes (NTP, 1986) and mononuclear cell leukemia and kidney tumors were seen in
male and female rats (NTP, 1986). As discussed in the hazard assessment, the mechanisms by which PCE
induces these endpoints are not clearly understood. More than one mechanism has been proposed by
which PCE might cause each of these responses; the available data do not clearly support any of the
various mechanistic views. The leukemia and liver responses in rodents suggest a general, accelerating
influence on underlying neoplastic processes. The kidney tumors in male rats might be associated with the
toxic effects of PCE in the kidney and/or with mutagenic activity of a secondary (mutagenic) metabolite of
PCE, dichloro-vinyl cysteine; the data do not reveal an answer. As a whole, the data do not point to the
linearity at low doses generally expected of mutagenic compounds, although the elevated responses in high
background tumors could suggest an activity that builds on background processes. This would give the
appearance of linearity at doses producing responses close to background rates, regardless of mutagenic
activity.
Although the data are not strongly linear, they are also not strong enough to describe how PCE
might have a threshold or a non-linear dose-response relationship at low doses, nor do they assist in
building an alternative model for response in that range. Consequently, the Cleaner Technologies
Substitutes Assessment presents two assessments of dose response: one uses a procedure that assumes
linearity at low doses; the second a procedure that stops short of projecting response to low doses and
examines the extent to which anticipated exposures differ from study levels (sometimes called margins of
exposure or MOEs) to characterize human risk. This latter utilizes a quantity called the EDIO (see
explanation below).
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This section uses several existing analyses, supplemented by analyses along the philosophy of the
recent proposed revision (USEPA, 1996) of USEPA's Carcinogen Risk Assessment Guidelines (USEPA,
1986b). Both approaches use the animal data in hand (NTP, 1986) and rely on analyses carried out and
published in the Addendum to the Health Assessment Document (USEPA, 1986a). These analyses first
examined the data in the experimental range. Following the approach used in the Addendum, exposure
concentrations for the experimental animals were transformed to human equivalent metabolized dose.1
Owing to the date of the Addendum's analyses, these equivalents are based on a species proportionality
with (body weight)2*.2
The CTSA uses human equivalent metabolized doses with the mouse and rat tumor responses to
establish predicted dose-response relationships in the range of the experiment. The tumor prevalence data
are the same as in USEPA (1986a) but the slope factor is not, since USEPA (1986a) averaged results from
six data sets using a geometric mean. To avoid double counting animals with adenomas and carcinomas,
the mouse carcinoma-only data sets have been omitted for this assessment. Thus, the analyses are based on
incidence of male and female mouse liver adenomas and/or carcinomas and male and female rat
mononuclear cell leukemia by taking the geometric mean of the unit risks of the four individually modeled
species-sex combinations.3
The first step in establishing a predicted relationship is to fit a model to the data. As mentioned at
the outset of this section, data are insufficient to support an agent-specific model reflecting a presumed
mode of action. In the range of observation, most quantal models used for curve-fitting will be equivalent
and USEPA used a so-called multistage model in its earlier analyses (USEPA, 1986a; USEPA, 1991).4
Linear-at-Low-Doses Approach
Linear-at-low-doses approaches address the range in which excess risk is expected to be at most
1%. Historically, USEPA has estimated an upper bound for low-dose risk by incorporating an appropriate
linear term into the statistical bound to the multistage curve. At sufficiently small exposures, any higher-
order terms in the polynomial will contribute negligibly, and the graph of the upper bound will look like a
straight line. That gives a unit risk that can be multiplied by exposures to estimate upper bounds on excess
'This transformation represented a direct transformation from a human study with urinary metabolized dose. The Addendum
also presents results based on crude use of a four-compartment model, with no allowance for variability or uncertainty. Subsequent
work in the literature (e.g., Hattis et al., 1986; Chen and Blancato, 1987; Bois et al., 1996) has expanded the horizons for transformation
and incorporation of variability and uncertainty.
2USEPA is considering the use of an alternate factor, proportional with (body weight)3'4 (USEPA, 1992) but has not yet
adopted it (although it was proposed in USEPA [1996]). Because many technology options and scenarios as well as several dose-
response relationships will be considered in the PCE risk characterization, this alternate factor has not been applied here. Its effect on
comparisons is expected to be less than half an order of magnitude.
3That is, the geometric mean of female and male mouse liver adenomas and carcinomas and female and male rat
mononuclear cell leukemia. An alternate view could consider the female results corroboratively or in conjunction with the more
sensitive male results within species. As an example, despite the higher background rate in male mice that contributes to differences in
response shapes, the results are within an order of magnitude for the two sexes.
4This is an exponential model approaching 100 percent risk at high doses with a shape at low doses described by a
polynomial function.
. D-2
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lifetime cancer risk for specific scenarios. This "linear-at-low-doses" unit risk would be 7.1 x 10"7 per
ug/m3 of PCE in air. This unit risk should not be used for lifetime average daily exposures greater than 1.4
x 10" ug/m3 (risk of 1%). (These values may be compared to the unit risk of 5.78 x 10'7 per ug/m3 of PCE
in air and its corresponding use ceiling of 1.7 x 104 ug/m3 from the double-counting calculations in
USEPA [1986a], Table 4-6.)
Nonprojection Approach
The method that does not project response to low doses or exposures relies on an ED,0. or the dose
associated with an estimated excess tumor response in 10% of an experimental group. A multistage model
(here, a two-stage model, or exponential with quadratic argument model, as used in the linear-at-low-doses
approach) is used to obtain the ED]0. Response rates below this percentage are beyond the resolution of
most experiments, and the various possible model shapes that might have been fitted to the data begin to
diverge.
In addition to the ED10, a lower bound on that 10%-response-dose is calculated to provide a sense
of some of the properties of the experiment(s)/studies from which risk is characterized. Because the PCE
modeling used units of human equivalent metabolized doses, the ED10 and its lower bound are divided by
7.83 x 10'6 mg/(body weight)2/3/day5 to obtain units of the inhaled concentration (ug/m3, human exposure)
equivalents (details in USEPA, 1986a). The ED,0 is 2.7 x 105 ug/m3; the lower bound on the EDIO is 1.4 x
105 ug/m3. These figures are compared to projected exposures to assess the MOE ratios as described in
Chapter 5. A recent proposal (USEPA, 1996) would take a straight line from the response at the EDIO to
the background response.6 There is still discussion about this proposed approach and it has not been
adopted for this assessment.7
Effects Other Than Cancer
Non-cancer effects vary widely in the characteristics of their manifestation. To provide a common
vocabulary for comparing substances, regardless of the effect that may be of most concern, a value called
the Reference Dose (RfD: for ingested or dermally applied substances) or Reference Concentration (RfC:
for inhaled substances) is derived. The standard approach to the RfD/RfC calls for the identification of the
spectrum of effects associated with a given chemical, typically giving primary attention to a "critical
effect" exhibiting the lowest No-Observed-(Adverse-)Effect Level (NOAEL or. since this is really an
experiment-related term, its conceptual equivalent from epidemiology, studies of humans). Effects are
identified using ''principal studies." which "are those that contribute most significantly to the qualitative
assessment of whether or not a particular chemical is potentially a systemic toxicant in humans. In
addition, they may be used in the quantitative dose-response assessment phase of the risk assessment"
(IRIS, 1998).
This is the estimated amount metabolized over a 24-hour period when an individual is exposed to 1 ug/m3 continuously.
Whether a line is drawn to background from the ED,,, or a ''linearized'' upper bound on a multistage model is utilized, the
estimated risks are presumed to be upper bounds on risks owing to the way a straight line will include most S-shaped curves.
The ED,,,-line would give a unit risk of 3.7 x 10'7 per ug/m3: its bound would give 6.9 x 10'7 per ug/m?. These differ by
approximately less than one order of magnitude from the "linearized multistage procedure" result.
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An RfD for PCE is published in IRIS (1998). A value of 0.01 mg/kg/day, in which there is
medium confidence, is based on the critical effect, hepatotoxicity in mice, from a study by Buben and
O'Flaherty (1985). The NOAEL for this effect is corroborated by weight gain in rats at the same level in a
study (Hayes et al., 1986) where rats lost weight at higher doses.
For the CTSA, USEPA has derived a provisional RfC of 0.17 mg/m3, in which there is medium
confidence, based on the critical effect, mild renal tubule damage, as reported in Franchini et al. (1983).
This RfC is provisional because it was derived by a single USEPA program office with limited cross-office
review. Vu (1997) describes the derivation in standard USEPA format.
The RfD/RfC is based on the assumption that thresholds exist for certain toxic effects such as
cellular necrosis, but may not exist for other toxic effects such as carcinogenicity. In general, the RfD/RfC
is an estimate (with uncertainty spanning perhaps an order of magnitude) of a daily exposure without an
appreciable risk of deleterious effects during a lifetime. RFDs/RfCs can be derived for the non-
carcinogenic health effects of compounds that are also carcinogens.
Discussion of Principal and Supporting Studies
Detailed discussion of the data contributing to derivation of the RfD appears in IRIS (1998). All
the studies available for derivation were carried out in animals. Buben and O'Flaherty (1985) exposed
Swiss-Cox mice to PCE in corn oil by gavage at six doses (20, 100, 200, 500, 1,000 or 1,500 mg/kg) and
control, 5 days/week for 6 weeks. The NOAEL from this study was 20 mg/kg/day or 14 mg/kg/day when
adjusted for continuous exposure. Hayes et al. (1986) also established 14 mg/kg/day as a NOAEL.
Administered PCE in drinking water, the group of Sprague-Dawley rats receiving the least of three positive
doses (14, 400, or 1,400 mg/kg/day) showed no difference from the control group.
The CTSA has identified Franchini et al. (1983), Lauwerys et al. (1983), and Solet and Robins
(1991) as the principal studies for the RfC. These studies have been carried out in drycleaning workers.
The basis for the RfC is (Franchini et al., 1983), a cross-sectional study carried out across four exposure
venues relating to organic solvents, including 57 workers exposed to PCE in 29 drycleaning shops. Their
average exposure time was 13.9 years (standard deviation 9.8). The exposure intensity was assessed by
measuring the end-shift excretion of trichloroacetic acid (TCA). The study authors converted the mean
TCA level for the group to a breathing-zone, time-weighted average (TWA) of about 10 ppm (PCE) in air.
Renal function impairment indicators (four types of urinalysis outcome) were compared between these
subjects and control subjects selected to be biologically and socially similar, but unexposed. Controls were
drawn from factories associated with the other three exposure types (painters/benzene in metal working,
styrene workers, workers exposed to short-chain alkanes) and considered as two reference groups, one
predominantly female, one predominantly male.
The subjects showed mean values of lysozymuria and urinary p-glucuronidase significantly
elevated above both reference groups. This testing was carried out by a statistical method that may have
identified sources of group differences incorrectly. The authors suggested that increased urinary (3-
glucuronidase might be related to a faster cellular turnover in tubular epithelium due to a mild toxic effect,
whereas lysozymuria might be a marker of more definite lesions throughout the renal tubules. Thus the
level of 10 ppm is considered as a Lowest-Observed-Adverse-Effect-Level (LOAEL) equivalent.
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The Lauwerys et al. (1983) study is also cross-sectional, including 26 drycleaning workers (24
female) who had been exposed to PCE over a 6-year period in six shops. Certain urinary enzymatic levels
were measured, albeit not the same ones as Franchini et al. (1983), as were certain plasma enzymatic
levels. Three psychomotor tests were administered. No differences were attributed by the investigators to
exposure to PCE. Average exposure was approximately 20 ppm PCE.
Solet and Robins (1991) studied 197 drycleaning workers and found no evidence of adverse
effects on renal function, as measured by levels of urinary protein, albumin, and n-acetyl-glucosaminidase
(NAG). They did not look at urinary p-glucuronidase. These workers were exposed to a mean PCE
concentration of 14 ppm. No control group was studied; thus, the investigators concentrated their effort on
modeling the variability among exposed individuals.
Derivation ofRfD
The steps to derive the RfD from the principal study include: (1) selecting a critical effect, (2)
identifying the highest level consistent with the resolution of the study at which that effect is not seen or
the level at which that effect first appears, taking possible confounding factors into account, (3) associating
a measure of exposure with that level, and (4) applying scientific judgment to select uncertainty factors
(UFs). If the measure of exposure is not an applied or potential dose for the individual, some relationship
between that measure and applied/potential dose is needed.
USEPA's RfD/RfC Workgroup carried out these steps, which are reflected in the IRIS (1998)
discussion of uncertainty and modifying factors, additional comments, and confidence pertaining to the
RfD. Uncertainty factors were incorporated reflecting intraspecies variability, interspecies variability, and
inference from a subchronic (6-week) study to chronic exposures. Although confidence in the Buben and
O'Flaherty (1985) study was low, owing to incomplete histopathology at the NOAEL, no single study had
the necessary combination of desirable characteristics for derivation; confidence in the database as a whole
was medium, contributing to a medium confidence in the RfD.
Derivation of Provisional RfC
The steps to derive the RfC from the principal study include the same four as for the RfD: (1)
selecting a critical effect, (2) identifying the highest level consistent with the resolution of the study at
which that effect is not seen or the level at which that effect first appears, taking possible confounding
factors into account, (3) associating a measure of exposure with that level, and (4) applying scientific
judgment to select UFs. Again, if the measure of exposure is not an applied or potential dose for the
individual, some relationship between that measure and applied/potential dose is needed. For an RfC,
however, internal dosimetric considerations may be related to several classes of inhaled substances.
For PCE, the study from which a critical effect was selected was Franchini et al. (1983), and that
effect is mild renal tubule damage. It was reported to have been seen at exposures as low as 10 ppm (in
air, TWA over work-shift) based on authors' calculations from TCA. The reported derived average level
of 10 ppm is equivalent to 70 mg/m3; this is a LOAEL-equivalent for this study. Adjustment to continuous
exposure, assuming no dose rate effects, involves averaging the duration of occupational exposure (40
hours) over the 168 hours in a week, and gives an adjusted daily exposure of 17 mg/m3. Because this is an
occupational study, a 10-fold factor is applied to account for sensitive individuals, and a factor of 10 is
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Dose-Response Assessments
applied in order to use a LOAEL as a NOAEL. For use in the CTSA in an occupational setting, only the
factor of 10 to adjust a LOAEL to a NOAEL was used.
Additional Comments/Studies for the RfC
Another human study provided a possible explanation for some of the differences among the three
principal studies, concerning the appropriate metric of PCE exposure for the RfC. Stewart et al. (1981)
studied volunteers exposed 5 days/week for 1 month to PCE concentrations of 20, 100, and 150 ppm.
Their subjects were mostly sedentary during exposure except for brief periods of exercise, presumably less
active than if they had been exposed occupationally. Based largely on one individual's observed exercise
experience and post-activity measurements, the study authors concluded that TWA concentrations may not
reflect an individual's true body burden from PCE exposure. The apparent discordance among the three
principal studies may be partly due to different approaches to estimating cross-sectional PCE exposure, as
well as to misclassification of exposure due to a lack of direct measurements of historical exposure.
The Stewart et al. study could be used to estimate an approximate RfC. The study, however, is
especially small. Individuals served as their own control subjects in an experimental context, where
volunteers were exposed for a varied number of hours. The study authors stated that exposure to 100 ppm
PCE led to major changes in electroencephalogram results of three of four male subjects and four of five
female subjects, and that the altered EEG pattern was similar to that seen in healthy adults during
drowsiness, light sleep, and the first stages of anesthesia. Application of the same uncertainty factors as
above, for using a LOAEL as a NOAEL and to account for sensitive individuals, as well as an uncertainty
factor to allow for chronic exposure, leads to an RfC lower than using the Franchini et al. study. By the
study authors' arguments, however, this TWA of 100 ppm reflects a lower PCE body burden than would
be expected of workers exposed at 100 ppm, suggesting a further adjustment would be necessary.
Use of the TWA of 10 ppm from the Franchini et al. study requires assuming that the TWA
represents the typical range of exposures the subjects experienced. If the TWA had been higher than 10
ppm in earlier years of the subjects' exposures, and this higher TWA were more causally linked to the
increase in urinary enzymes than the TWA measured in the study, then the RfC here would be overly
protective. On the other hand, because no measure of variability in exposure concentrations is available,
the UF adjustment for sensitive populations may be an insufficient reflection of the range of human
response. No additional UF was applied for extension to lifetime exposure; the inhaled PCE exposures are
unlikely to accumulate indefinitely to produce this endpoint, the duration of exposure of 13.9 years with a
standard deviation of 9.8 years applied to the mean age of 43 (standard deviation 9.1) covers a substantial
part of the subjects' adult lives, and the modifying factor is less than the variability in the derived
exposure.
Several more recent studies (Altmann et al., 1990, 1992, 1995; Ferroni et al., 1992; Cavalleri et
al., 1994) have examined neurobehavioral endpoints. These have included cognitive deficits, deficits in
visual evoked potentials and visual acuity, and prolonged reaction times. Difficulties in using these studies
for deriving a provisional RfC include an experimental setting in which the control group was exposed at
10 ppm (the derived mean level at which effects were seen in Franchini et al., 1983) or occupational
exposures at means above 10 ppm, large standard deviations on reported exposure levels, and poor
association of the exposure levels with the effects. The New York State Department of Health (NYSDOH,
1997) used a collection of studies including these and several others together with its own methods to
D-6
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Appendix D
Dose-Response Assessments
derive several endpoint-specific criteria for evaluating non-carcinogenic effects for adults and children. Its
possible adult values range from 0.28 mg/m3 to 0.36 mg/m3, with an overall recommendation that the
criterion for ambient air be 0.1 mg/m3. This value is consistent with the above derived provisional RfC.
Animal data support the endpoint choice and conclusions from human data. NTP (1986) reported
renal and hepatic effects, including tumors, in rodents exposed by inhalation for 2 years to high levels of
PCE (100 and 200 ppm in mice, and 200 and 400 ppm in rats). It reported that 100 ppm (approximately
700 mg/m3), the lowest concentration tested, was a LOAEL for mice. Exposure to 100 to 1,600 ppm for 6
hours/day, 5 days/week, for 13 weeks was associated with hepatic and renal effects; a concentration of
1,600 ppm was fatal to 20-70% of rats and mice and was associated with reduced body weights. Exposure
of rats to 0, 200, or 400 ppm, and of mice to 0, 100, or 200 ppm for 2 years was associated with a dose-
related decrease in survival in male rats and both sexes of mice. Long-term exposure to PCE was
associated with leukemia in rats at 100 and 200 ppm and in rats at 200 and 400 ppm, karyomegaly (in rats
of both sexes), and hyperplasia in renal tubular cells (in male rats). No tumors of the respiratory tract were
reported. A NOAEL was not established by this study. Although the appearance of increased mortality at
100 ppm in male mice could suggest this as a Frank Effect Level (PEL), this increase was not in evidence
until after 74 weeks.
Discussion of Confidence in the RfC
PCE has.been studied for a variety of endpoints, and human and animal studies are available
relating to systemic toxicity and reproductive and developmental effects. The animal literature is
extensive; the human literature has gaps. On balance the database is of medium quality. This RfC is based
on humans, exposed in a most typical setting. The Franchini et al. (1983) study does not permit a
quantitative dose-response relationship to be derived and does not characterize the variability of the
exposure concentrations. Thus, some lower exposures may still demonstrate effects, and the Solet and
Robins (1991) study, lacking a control group, cannot be used to establish a NOAEL in lieu of the
Franchini et al. (1983) LOAEL. A rough calculation of an RfC from Stewart (1981), based on a
neurotoxicity outcome, is slightly lower than the RfC derived from Franchini et al. (1983), based on renal
function, suggesting the magnitude is reasonable. An RfC based on the (animal) NTP (1986) study
without any dose conversions would be of the same order of magnitude (based on a LOAEL of 100 ppm,
or approximately 125 mg/m3 for continuous exposure, and applying an uncertainty factor and a modifying
factor of 1,000 and 1, respectively).
D.1.2 Hydrocarbon Solvents
No oral RfD, inhalation RfC, cancer unit risk, or slope factor has been established to date for
Stoddard solvent or any other hydrocarbon solvent. ATSDR (1995) determined that it did not have human
or animal studies suitable for developing what it calls Minimum Risk Levels, which resemble RfD/RfCs,
for intermediate- or chronic-duration exposures to Stoddard solvent in air.
For purposes of the CTSA, a non-cancer comparison value has been derived from Carpenter et al.
(1975a, 1975b). As discussed for PCE, the standard approach to the RfD/RfC calls for the identification
of the spectrum of effects associated with a given chemical, with primary attention given typically to a
"critical effect" exhibiting the lowest NOAEL (or, since this is really an experiment-related term, its
conceptual equivalent from epidemiology, studies of humans). Effects are identified using "principal
D-7
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Dose-Response Assessments
studies," which "are those that contribute most significantly to the qualitative assessment of whether or not
a particular chemical is potentially a systemic toxicant in humans."
The spectrum of effects that has been associated with Stoddard solvent is described in Chapter 3
and Appendix C. Because the human observations provide poor exposure information when
occupational^ based and are at relatively high levels when experimental, a comparison value was selected
from the animal literature. Rather than develop a provisional level for the CTSA without critical review, a
level was chosen directly from a study. A 13-week study (Carpenter et al., 1975a, 1975b) in dogs showed
no statistically significant clinical and histopathological differences as low as 480 mg/m (84 ppm) and as
high as 1,900 mg/m3 (330 ppm). Because a parallel study in male rats showed kidney tubular regeneration
at both 1*100 mg/m3 (190 ppm) and 1,900 mg/m3 (330 ppm), but none at 480 mg/m3 (84 ppm), 480 mg/m
is identified as aNOAEL, with the recognition that it is from a subchronic study.
D.2 MACHINE WETCLEANING CHEMICALS
No oral RfD, inhalation RfC, cancer unit risk, or slope factor has been established to date for any
of the sample machine wetcleaning chemicals reviewed for the CTSA, and their data do not provide the
necessary information to derive provisional levels for the CTSA. This makes quantitative assessment of
their risks moot. Nonetheless, the principles in quantitative considerations of mixtures are pertinent to
their qualitative assessment.
Under ideal circumstances, information would be available for the mixture or formulation as a
whole. More typically, information is available on the ingredients (components) or on just some of them
(in this case, on none). Often, certain components are exchangeable, with selection based on their function
in the process, but with exposure and toxicity properties unique to the selection. In Section 3.3, some
information on examples of these selections was provided for the wetcleaning process. Many of the
aqueous-based ingredients have, themselves, been tested in mixtures that may resemble the formulations
for use in machine wetcleaning. Such tests are helpful to the extent that the tested mixture is known and
resembles the expected wetcleaning formulation. Details of the tested formulations, unfortunately, were
not available for most of the components described in the CTSA.
Quantitative assessment of mixtures using their components in the absence of specific interaction
information would typically rely on an assumption that the components produce their toxicities
independently; information on ways one or more components may modify others is incorporated
qualitatively. Mixtures with just a few ingredients may be characterized quantitatively and qualitatively
more readily than mixtures with many dissimilar ingredients.
D-8
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REFERENCES
Altmann, L., H.-F. Neuhann, U. Kramer, J. Witten, and E. Jermann. 1995. Neurobehavioral and
neurophysiological outcome of chronic low-level tetrachloroethene exposure measured in
neighborhoods of dry cleaning shops. Environ Res 69:83-89.
Altmann, L., H. Wiegand, A. Bottger, F. Elstemeier, and G. Winneke. 1992. Neurobehavioral and
neurophysiological outcomes of acute repeated perchloroethylene exposure. Appl Psych 41:269-
279.
Altmann, L., A. Bottger, and H. Wiegand. 1990. Neurophysiological and psychophysical measurements
reveal effects of acute low-level organic solvent exposure in humans. Int Arch Occup Environ
Health 3:493-499.
ATSDR. 1995. Agency for Toxic Substances and Disease Registry. Toxicological profile for Stoddard
solvent. USDHHS, Agency for Toxic Substances and Disease Registry, Public Health Service.
Atlanta, GA.
Bois, F.Y., A. Gelman, J. Jiang, D.R. Maszle, L. Zeise, and G. Alexeef. 1996. Population toxicokinetics
oftetrachloroethylene. Arch Toxicol 70:347-355.
Buben, J.R., and E.J. O'Flaherty. 1985. Delineation of the role of metabolism in the hepatotoxicity of
trichloroethylene and perchloroethylene: A dose-effect study. Toxicol Appl Pharmacol 78:105-
122. [As cited in IRIS (1998).]
Carpenter, C.P., E.R. Kinkead, D.L. Geary Jr., et al. 1975a. Petroleum hydrocarbon toxicity studies:
I. Methodology. Toxicol Appi Pharmacol 32:246-262. [As cited in ATSDR (1995).]
Carpenter, C.P., E.R. Kinkead, D.L. Geary Jr., et al. 1975b. Petroleum hydrocarbon toxicity studies: 111.
Animal and human response to vapors of Stoddard solvent. Toxicol Appl Pharmacol 32:282-297
[As cited in ATSDR (1995).]
Cavalleri, A., F. Gobba, M. Paltrinieri, G. Fantuzzi, E. Righi, and G. Aggazzotti. 1994. Perchloroethylene
exposure can induce colour vision loss. Neurosci Lett 179:162-166.
Chen, C.W., and J.N. Blancato. 1987. Role of Pharmacokinetic Modeling in Risk Assessment:
Perchloroethylene as an Example. In Pharmacokinetics in Risk Assessment. Drinking Water and
Health. Volume 8. National Academy Press. Washington, DC. pp. 369-390.
Ferroni, C., L. Selis, A. Mutti, D. Folli, E. Bergamaschi, and I. Franchini. 1992. Neurobehavioral and
neuroendocrine effects of occupational exposure to perchloroethylene. Neurotoxicology 13-243-
248.
Franchini, L, A. Cavatorta, M. Falzoi, S. Lucertini, and A. Mutti. 1983. Early indicators of renal damage
in workers exposed to organic solvents. Int Arch Occup Environ Health. 52:1-9.
D-9
-------
Aooendix D
Dose-Response Assessments
Hattis D S Tuler, L. Finkelstein, and Z.-Q. Luo. 1986. A pharmacokinetic/mechamsm-based analysis
' of the carcinogenic risk of perchloroethylene. Center for Technology, Policy and Industrial
Development, Massachusetts Institute of Technology. Cambridge, MA. CTPID 86-7.
Hayes, J.R., L.W. Condie Jr., and Borzelleca Jr. 1986. The subchronic toxicity of tetrachloroethylene
' (perchloroethylene) administered in the drinking water of rats. Fund Appl Toxicol 7:119-125.
[As cited in IRIS (1998).]
IRIS. 1998. Integrated Risk Information Database. Chemical files. Background document 1 A.
Washington, D.C. Available through TOXNET on line.
Lauwerys, R., J. Herbrand, J.P. Buchet, A. Bernard, and J. Gaussin. 1983. Health surveillance of workers
exposed to tetrachloroethylene in dry-cleaning shops. Int Arch Occup Environ Health 52:69-77.
NTP 1986 National Toxicology Program. NTP technical report on the toxicology and carcinogenesis
studies of tetrachloroethylene (perchloroethylene). U.S. Department Health and Human Services,
NIH, Publ. No. 86-2567.
NYSDOH. 1997. New York State Department of Health. Tetrachloroethene Ambient Air Criteria
Document. Final Report. October 1997.
Solet, D., and T.G. Robins. 1991. Renal function in dry cleaning workers exposed to perchloroethylene.
Am J Ind Med 20:601-614.
Stewart R.D., C.L. Hake, H.V. Forster, et al. 1981. Tetrachloroethylene: Development of a biologic
'standard for the industrial worker by breath analysis. Contract no. HSM 99-72-84. PB82-152166.
National Institute for Occupational Safety and Health. Cincinnati, OH.
USEPA. 1986a. U.S. Environmental Protection Agency. Addendum to the health assessment document
for tetrachloroethylene (perchloroethylene). Updated carcinogenicity assessment for
tetrachloroethylene (perchloroethylene, PERC, PCE). Review draft. EPA /600/8-82/005FA.
USEPA. 1986b. U.S. Environmental Protection Agency. Risk assessment guidelines. EPA/600/8-
87/045. Washington, DC.
USEPA. 1991. U.S. Environmental Protection Agency. Response to issues and data submissions on the
carcinogenicity of tetrachloroethylene (perchloroethylene). EPA/600/6-91/002F.
USEPA. 1992. U.S. Environmental Protection Agency. A cross-species scaling factor for carcinogen
risk-assessment based on equivalence of mg/kg3/4/day. Draft report. (57(109) FR 24152-24).
USEPA. 1996. U.S. Environmental Protection Agency. Proposed guidelines for carcinogen risk
assessment. EPA/600/p-92/003Ca. April.
D-10
-------
Appendix D
Dose-Response Assessments
Vu, V. 1997. Memorandum titled "Provisional RfC for perchloroethylene." From Vanessa Vu, Acting
Director, Health and Environmental Review Division, to William Waugh, Acting Director,
Chemical Screening and Risk Assessment Division, OPPT, USEPA.
D-ll
-------
-------
APPENDIX E
RELEASE AND EXPOSURE METHODOLOGY AND DATA
Exhibit E-1. PCE Emissions by Machine Type8
Machine Type with Typical Controls
Transfer
Vented
Converted
Closed-loop
Emissions for a Typical
Cleaner (gal/yr)
330
220
170
80
' Source: CEPA, 1993. These emissions data were used in estimating releases to air in Exhibit 4-1
E-1
-------
Appendix E
Release and Exposure Methodology and Data
Exhibit E-2. Emission Factors Used to Estimate Releases of Solvent
from Hydrocarbon Dry Cleaning Facilities8
Dryer -18 kg VOC is released to air per 100 kg dry weight of articles cleaned based on an
average of three studies conducted between 1975 and 1980. The rate of emission is highly
dependent on the amount of solvent absorbed and subsequently released during extraction (e.g.,
loose weaves absorb and release solvents more readily), the efficiency of the extractor, and the
size of the dryer load. 3.5 kg VOC is released to air per 100 kg dry weight of articles cleaned with
a condenser/solvent recovery dryer.
The recovery dryer also generates separator water which is discharged to the sewer and received
by a POTW Water enters the solvent bath, through adsorption from the clothes and the air, at a
rate of 0.004 - 0.02 gals/lb articles cleaned (USEPA, 1982). This water may be recovered in the
recovery dryer separator or in the distillation separator.
Filter - After draining a diatomaceous earth filter, the filter muck contains approximately 8 kg
solvent per 100 kg dry weight of articles cleaned (USEPA, 1982). This average depends on the
type of filter used (i.e., the amount of diatomaceous earth required by the filter), and the soil
loading of the clothes. When cartridge filters are used, less than 1.0 kg solvent per 100 kg dry
weight of articles cleaned is found in the spent filter medium.
Settling Tanks - No emission factor available'. Settling tanks may be used instead of filters for
highly contaminated solvent. The solvent content may be from 80 to 200 percent, by weight, of
settling tank waste. Settling tank waste may be burned in a boiler, discarded with general
drycleaning waste, or sold to a solvent reprocessor. It is generally too contaminated to treat in the
vacuum still.
Vacuum Stills - 1-7 kg solvent per 100 kg dry weight of articles dry cleaned (average of 3 kg
solvent) is disposed with the still residue. Solvent is also discharged with the wastewater
generated from the still overhead separator, though the quantity is unknown.
Fugitive Emissions - At least 1 kg of VOC emissions per 100 kg dry weight of articles. This factor
is assumed to be the total emissions per 100 kg articles less all other emission factors.
•Source: USEPA, 1982.
E-2
-------
Appendix E
Release and Exposure Methodology and Data
Exhibit E-3. Environmental Release Estimates of Example Detergent #1 Constituents3
1
2A
2B
3
4
5
6
7
8
9
10
Constituent
water
methyl 2-sulfolaurate, sodium salt
sodium lauryl isethionate
ethoxylated sorbitan monodecanoate
lauryl polyglucose
Aveda's fragrance
sodium citrate
cellulose gum
acetic acid
citric acid
diazqlidinyl urea
totals
Weight
Percent15
54
3.75
3.75
7.5
7.5
1
2.5
5
5
2.5
7.5
100
Density0
(g/cm3)
1
1
1
1.1
1
1
1
0.75
1.049
1.542
1
1.01
Releases to water1*
(kg/site-day)
0.195-0.631
0,013-0.044
0.013-0.044
0.027 - 0.088
0.027 - 0.088
0.004 - 0.012
0.009 - 0.029
0.018-0.058
0.018-0.058
0.009 - 0.029
0.027 - 0.088
0.360-1.169
Total release minus water 0.165 - 0.538
a These release estimates correspond to 29.5 to 95.4 gallons/year total detergent use and release
rates (from the Machine Wetcleaning Release Assessment in Section 4.2.2) and are based on
assumptions that: example detergent #1 contains the constituents listed for All-Purpose Cleanser
(Aveda, 1992) from the Multi-Process Wetcleaning Report (USEPA, 1993); all of the formulation used
is released to water; and, a CTSA model facility operates for 312 days/year and the annual estimated
release to water is divided equally over the operating days.
b Assumed based on assumed function of constituent.
c From Chemical Properties and Information tables in Appendix A; if no data available, assumed 1
g/cm3.
d For the risk assessment, these total detergent releases were converted from volume (gallons per
day) to weight (kilograms per day [kg/site-day]) using the total formulation density. The total weight
was then distributed among the constituents using the weight percents of the constituents.
E-3
-------
Appendix E
Release and Exposure Methodology and Data
Exhibit E-4. Environmental Release Estimates of Example Detergent #2 Constituents3
1
2
3
4A
4B
5
6
7
8
9
10
11
12
Constituent
water
laurvl polvqlucose
lauric acid diethanolamide
methvl 2-sulfolaurate, sodium salt
sodium lauryl isethionate
sodium laureth sulfate
sodium citrate
cocamidopropy! betaine
Aveda's fragrance (orange)
cocoamphocarboxyproprionate
sodium carbonate
citric acid
diazolidinyl urea
totals
Weight
Percent"
54
4.28
4.28
2.14
2.14
4.28
2.5
4.28
1
4.28
10
2.5
4.28
100
Density0
(g/cm3)
1
1
0.979
1
1
1
1
1
1
1
2.53
1.542
1
1.17
Releases to Water"
(kg/site-day)
0.225 - 0.728
0.018-0.058
0.018-0.058
0.009 - 0.029
0.009 - 0.29
0.018-0.058
0.010-0.034
0.018-0.058
0.004-0.013
0.018-0.058
0.042-0.135
0.010-0.034
0.018-0.058
0.417-1.350
Total releases minus water 0. 1 92 - 0.622
• These release estimates correspond to 29.5 to 95.4 gallons/year total detergent use and release rates (from
the Machine Wetcleaning Release Assessment in Section 4.2.2) and are based on assumptions that: example
detergent #2 contains the constituents listed for Fabric Cleanser (Aveda, 1992) from the Multi-Process
Wetcleaning Report (USEPA, 1993); all of the formulation used is released to water; and, a CTSA model facility
operates for 312 days/year and the annual estimated release to water is divided equally over the operating
days.
b Assumed based on assumed function of constituent.
0 From Chemical Properties and Information tables in Appendix A; if no data available, assumed 1 g/cm .
a For the risk assessment, these total detergent releases were converted from volume (gallons per day) to
weight (kilograms per day [kg/site-day]) using the total formulation density. The total weight was then
distributed among the constituents using the weight percents of the constituents.
E-4
-------
Appendix E
Release and Exposure Methodology and Data
Summary of Dry Cleaning Worker Population and Subpopulation
Exhibits E-5, E-6, and E-7 contain data and assumptions used to estimate the numbers of workers
in perchloroethylene and hydrocarbon dry cleaning facilities and percentages of these workers by job title.
Exhibit E-5 shows the original data that were the bases for final CTSA estimates of numbers of workers.
This exhibit also shows the calculation of estimated number of drop-off/ pick-up sites.
Exhibit E-5. Summary of American Business Information (ABI) 1994 Dry Cleaning
Worker Population Dataa>b
Size Category
(number of shop
workers)
1 to 4
5 to 9
10 to 19
20 to 49
50 to 99
100 to 249
250 to 499
500 to 999
unknown
Totals
Number of
Shops
33,853
8,252
3,482
1,095
175
62
6
i
1,161
48,087
% Age of
all Shops
70
17
7
2
0.4
0.1
0.01
0.002
2
100
Fraction of
Known Shops
0.72
0.18
0.07
0.02
0.004
0.001
0.0001
0.00002
NA
1
Minimum
Workers
33,853
41,260
34,820
21,900
8,750
6,200
1,500
500
1,161
149,944 .
Maximum
Workers
135,412
74,268
66,158
53,655
17,325
15,438
2,994
999
1,161
367,410
1 Source: ABI (1994) as cited in NIOSH (1997).
E-5
-------
Appendix E
Release and Exposure Methodology and Data
Exhibit E-6. Summary of Estimated Dry Cleaning Worker Population Data8
Size Category
(number of shop
workers)
1 to 4
5 to 9
10 to 19
20 to 49
50 to 99
100 to 249
250 to 499
500 to 999
Number of
Shops
22,604
8,456
3,568
1,122
179
64
6
1
Percent of all
Shops
63
23
10
3
0.5
0.2
0.02
0.003
Minimum Workers
22,604
42,281
35,681
22,442
8,966
6,353
1,537
512
Revised Total
Allotted to PCE
(85% PCE)
Allotted to HC
(15% HC)
Number of
Shops
36,000
30,600
5,400
Percent of all
Shops
100
Average number of employees per site
Minimum
Workers
140,377
119,320
21,057
3.9
Midpoint
Workers
233,670
198,619
35,050
6.5
Maximum
Workers
90,414
76,105
67,795
54,982
17,754
15,820
3,068
1,024
Maximum
Workers
326,962
277,918
49,044
9.1
• For the CTSA, the ABI data from Exhibit E-4 were adjusted: (1) to exclude drop-off/pick-up (DO/PU)
sites; (2) to proportionally distribute the 1,161 shops in "unknown" size category above into the known
size categories. DO/PU sites were assumed to be the difference between the total number of shops
(48,087) from Exhibit E-4 and the total number of shops (36,000) estimated for the CTSA to perform
drycleaning. Therefore, 12,087 sites are estimated to be DO/PU sites. DO/PU sites are all assumed to
be in the 1-4 size category. Adjustment (1) was then accomplished by subtracting the 12,087 DO/PU
sites from the 33,853 shops in the 1-4 size category. Adjustment (2) was accomplished for each size
category by adding to the number of shops for that category the product of 1,161 times the fraction of
known shops for the category. The results of these adjustments are in Exhibit E-5. The numbers of
workers from this exhibit were rounded before being reported in the text (Section 4.4.1 for PCE and
Section 4.4.2 for HC).
E-6
-------
Appendix E
Release and Exposure Methodology and Data
Exhibit E-7. Dry Cleaning Worker Subpopulation Estimation*'"
Job Title
Mgr/Admin
Bookkeeper
Clerk
Foreman
Installer
Engineers
Tailors
Presser
Seamstress
Operator
Sewer
Driver
PEI Total
Estimated Number of Workers
1,655
208
8,068
84
86
23
4,306
6,759
246
21,240
296
644 '
43,615
Percent of al! Workers0
3.8
0.5
18.5
0.2
0.2
0.1
9.9
15.5
0.6
48.7
0.7
1.5
100
a Source: PEI, 1985.
b Exhibit E-6 shows the data used to estimate percentages of dry cleaning workers by job title. The
percentages of workers for the job titles from this exhibit were reported in Section 4.4.1 for PCE and
Section 4.4.2 for HC.
c Note: 3.6 is the percent of workers other than those titled manager, operator, presser, tailor, and
clerk.
E-7
-------
Appendix E
Release and Exposure Methodology and Data
Exhibit E-8. Determination of Estimated Dermal Exposure Durations
for Potential Liquid PCE Contact8
Activities
1. loading/ unloading machine
(transfer machines)
2. waterproofing (not all shops)
3. changing filters
4. cleaning still
5. emptying button trap
6. filling storage tank
7. changing rag filter (not all shops)
8. cleaning muck cooker
(powder filters only)
Avg. Frequency, Duration
6/day (CTSA), 2 min/event (NIOSH)
1-2/day (assumed*), 2 min/event (NIOSH)
demand (NIOSH); 5 min/event (NIOSH)
1/day (NIOSH); 5 min/event (NIOSH)
1/day (NIOSH); < 1 min/event (assumed*)
demand (NIOSH); < 1 min/event (assumed*)
1/week (IFI); < 1 min/event (assumed*)
assume same as still cleaning
Assumptions: Assumed* in above list indicates no source of estimate was found, and the value was based
on an assumption of the amount of time to complete the activity. Operators are primary workers who
perform the above activities which have potential for liquid PCE contact. For each transfer contact, add
two minutes to account for time prior to total PCE evaporation; for each non-transfer contact, add 1
minute.
Summation (estimated total time of contact plus post-contact evaporation of liquid PCE)
Transfer machine operators:
Dry-to-dry operators:
Non-routine add-ons:
Transfer operators:
Dry-to-dry operators:
6x4+5+2 = 31 min/day daily routine
5+2 = 7 min/day daily routine
5-6 min/week = 1 min/day avg. assumed
< 32 min/day total (routine plus non-routine)
< 8 min/day total
•Source: NIOSH, 1997; IFI, 1994.
E-8
-------
Appendix E
Release and Exposure Methodology and Data
Exhibit E-9. Exposure Assessment Methodology- Background on Worker Exposure
The USEPA/OPPT/Chemical Engineering Branch (CEB) standard methods and procedures for
assessing worker exposure were used for this CTSA and are presented in Preparation of Engineering
Assessment, Volume I: CEB Engineering Manual (USEPA, 1991). For many worker exposure
assessments, data are unavailable or incomplete, and screening-level methods must be used. Screening-
level assessments rely on the use of readily available information and data and are generally considered
to be conservative (protective) in nature. However, screening-level estimates are often quite uncertain
and may over- or under-estimate exposures by one or more orders of magnitude.
Key elements of the worker exposure assessment include, for a given worker population, such as
perchloroethylene process operator: the number of workers in that population; routes of exposure;
measures of amounts of exposure to a chemical or set of chemicals, such as potential dose rates
(PDRs)(e.g., milligrams per day [mg/day]), or the amounts of chemicals to which a worker may be
exposed over a given period of time via a given route), of, alternately, exposure concentrations
(ECs)(e.g., parts per million (ppm) time-weighted average [TWA]), which may be translated to PDRs; and,
the frequency of exposure (e.g., days/yr) for each dose rate. The following paragraphs briefly describe the
assessment methods.
The National Occupational Exposure Survey (NOES) database is frequently used to estimate the
number of workers potentially exposed to substances during industrial and commercial operations. The
survey was conducted in 1980 -1983 and information was extrapolated to make national estimates of
numbers of workers potentially exposed and numbers of facilities where the substance is present.
Because of the age of the data, the survey itself, and the extrapolation to national averages, there are
several uncertainties associated with the data. NOES estimates are fairly uncertain estimates . The
NOES survey data were not used to estimate the numbers of workers for established cleaning processes
because a number of other data sources indicated .that the NOES data were extremely inaccurate for this
industry. Data documented in other sources were used to estimate the number of workers per site
because those sources were expected to be more up-to-date and accurate than the NOES data.
There are two primary routes of worker exposure assessed in this CTSA. Inhalation exposure, or
workers breathing workplace air containing significant concentrations of volatile solvents, is expected to be
the most significant route for solvents used in dry cleaning. Dermal exposure, or workers getting solvent
and detergents on the skin during various work activities, is expected to be the significant route of
exposure for non-volatile chemicals, such as most detergent components. Dermal exposure is also a
route of worker exposure for solvents. Ingestion may be a route of exposure for workers who may, for
example, eat food contaminated with cleaning chemicals from the workers' hands. However, no data or
estimation method is known to make an estimation of worker exposure via this route, and this route would
be generally expected to be a much less significant route relative to the inhalation and dermal routes.
When assessing the amounts of chemicals to which workers are exposed, an order of preference
of data or methods is used. The first preference is personal monitoring data on chemical being assessed
for the population being assessed, and this type of data was available for the worker inhalation exposures
assessed in the Cleaner Technologies Substitutes Assessment. Given that monitoring data was not
available for worker dermal exposures, modeling was used. The models used are based on some limited
studies conducted on retention of liquids.
E-9
-------
Appendix E
Release and Exposure Methodology and Data
Exhibit E-10. Worker Exposure - Inhalation
Regarding worker inhalation exposures, several monitoring data sets were found for airborne
solvent exposure concentrations (ECs) in dry cleaning facilities. Only personal (not area, bulk or other)
samples were included and short-duration (< 1 hour) measurements were not included in the CTSA. To
include non-detect (i.e., zero) measurements in the mean EC estimates based on OSHA OCIS data, non-
detects were assigned the value of the detection limits (DLs) divided by the square root of 2 (reflecting that
these data sets appear to be skewed) (OCIS, 1994, 1998). However, DLs were not provided with these
data sets. Therefore, the lowest measured value in each data set was assumed to be slightly higher than
the DL for that set, resulting in the following assumed DLs: 0.01 ppm for PCE, 5 mg/m3 for Stoddard
solvent. All inhalation ECs to solvent vapors (PCE and HC processes) may be converted to potential dose
rates (PDRs) based on the assumption that workers may be exposed to the measured time-weighted
average (TWA) concentrations of the solvent for eight hr/day and that the workers have an average
breathing rate of 1.25 m3/hr. It should be noted that a number of the monitored data points are less than
8-hour TWAs, but it was assumed that these observed TWA were the same as an 8-hour TWA.
Example calculation for inhalation EC conversion is presented below.
Inhalation Exposure
For EC units conversion from ppm to mg/m3, we use the ideal gas law. The general equation is
ppm (PCE in air) x MW PCE x 1,000 mg/g / Vmol x 1,000 L/m3 = mg/m3 (PCE in air)
where
ppm = g-mol PCE per 1,000,000 g-mol air;
MW = molecular weight of PCE in g/g-mol (165.8);
Vmol = molar volume at ambient conditions (1 atmosphere and 25°C) (24.45).
The general equation reduces to ppm x MW / Vmol = mg/m3. For example, the exposure
concentration for workers in facilities using transfer machines before 1/1/87 from Exhibit 4-6 is 55.3 ppm.
The following calculation shows the conversion:
55.3 ppm PCE x (165.8/24.45) mg/m3/ppm
= 375 mg/m3 PCE.
E-10
-------
Appendix E
Release and Exposure Methodology and Data
Exhibit E-11. Worker Exposure - Dermal
Dermal PDRs to solvents and detergents were estimated using standard assumptions, as
described in Preparation of Engineering Assessment, Volume I: CEB Engineering Manual (USEPA,
1991). Dermal PDRs are presented as bounding estimates based on limited data and engineering
judgment. These estimates assume: 1 contact per day for low-volatility chemicals and that workers wash
up at meal times and/or end of the shift; contact or immersion of 1 or 2 hands depending on the activity;
no use of protective clothing, such as gloves, or other controls to mitigate exposure. For a given worker
activity, this method assumes a specific surface area contacted by chemical and a specific surface density
of that chemical to estimate a PDR. Only one contact per day is assumed for low-volatility chemicals
because, the surface density for those chemicals is not expected to be significantly affected either by
wiping excess from skin or by repeated contact(s) with additional chemical; i.e., wiping does not remove a
significant fraction of the small layer of chemical adhering to the skin, and additional contacts with the
chemical do not add a significant fraction to the layer of chemical on the skin.
Example calculation for dermal PDR estimations is presented below.
Dermal Exposure
Potential dose rates for occupational dermal exposure to PCE on pages 4-21 and 4-22 are based
upon OPPT's Occupational Dermal Exposure Model and. are calculated as follows:
(1)
(2)
Article transfer from washer to dryer: 1300 cm2 (skin area exposed) x 14mg
solvent/cm2/contact x 1 mg PCE/mg solvent = 18,000 mg/contact
Other Activities: 1300 cm2 x 3 mg solvent/cnrVcontact x 1 mg PCE/mg solvent = 3,900
mg/contact
For wet cleaning detergent components, the above potential dose rates estimated for PCE are
simply assumed to be the same for the detergent formulation multiplied by 1 contact per day (this
assumption is discussed above) and the weight fraction of the component in the formulation (or diluted
formulation). An example using "constituent 2" of the detergent formulation is as follows:
3,900 mg detergent/contact x 1 contact/day x 0.5 mg constituent Z/mg detergent = 2,000
mg constituent Z/day ' ;
E-11
-------
Appendix E
Release and Exposure Methodology and Data
Exhibit E-12. Exposure Assessment Methodology - Non Worker Populations
Exposures to non-worker populations were estimated using Agency guidance published in the
Federal Register (USEPA, 1992). Exposure estimates were developed based on available data from
monitoring studies as well as exposure models. Monitoring data were used wherever possible.
nhalation, dermal, and ingestion exposures to PCE were estimated for various exposed populations.
These populations include co-located residents, children, the elderly, persons wearing dry cleaned
clothing, and persons exposed to ambient levels of PCE.
Much less information was available for use in assessing hydrocarbon exposures. In this case, a
model was used to estimate chronic exposures received by members of the general public. In the case of
machine wet cleaning (MWC) chemicals, there were no human health concerns. However, in this case
releases to surface water were used to estimate predicted environmental concentrations in water.
The equations used to estimate human exposures are shown below:
(D
Inhalation Exposure
Inhalation exposures to non-worker populations are expressed as potential doses in the form of
LADCs (for PCE) or ADCs (for hydrocarbons).
(1)
LADCorADC(mg/m3) =
[C (mg/m3) x ED (days)]/ [AT (days)]
where C = Chemical concentration
ED = Exposure duration
AT = Averaging time (for LADC: number of days per lifetime, 25550 days; for ADC,
one day)
(2) Ingestion Exposure
Exposure to clothes cleaning chemicals via ingestion of contaminated drinking water is presented,
where relevant, as a potential dose rate expressed as a Lifetime Average Daily Dose (LADD). LADDs
are averaged over a person's lifetime. The equation for drinking water ingestion is as follows:
(2) LADD (mg/kg/day) = [C (ug/L) x 0.001 ug/mg x Am (L/day) x ED (days)] / BW (kg) x AT (days)
where C = Chemical concentration (ug/L)
Am = Amount of water ingested per day; 2 Liters
BW = Body weight
ED = Exposure Duration
AT = Averaging Time; 70 years '
E-12
-------
Appendix E
Release and Exposure Methodology and Data
Exhibit E-13. Estimates of Workers' Dermal Exposures to Example Detergent #1 Constituents3
1
2A
2B
3
4
5
6
7
8
9
10
Constituent
water
methyl 2-sulfolaurate, sodium salt
sodium lauryl isethionate
ethoxylated sorbitan
monodecanoate
lauryl polyglucose
Aveda's fragrance
sodium citrate
cellulose gum
acetic acid
citric acid
diazolidinyl urea
Weight
Percent"
54
3.75
3.75
7.5
7.5
1
2.5
5
5
2.5
7.5
Contacting Dilute
Formulation via Wet
Clothes Transfer0
(mg/day)
18,000
0.05
0.05
0.10
0.10
0.01
0.03
0.06
0.06
0.03
0.10
Contacting
Full-Strength
Formulation
(mg/day)
2,100
150
150
290
290
39
98
195
195
98
290
a These estimated dermal PDRs correspond to the estimates presented in section 4.4.3.1 and are
based on assumption that example detergent #1 contains the constituents listed for All-Purpose
Cleanser from the Multi-Process Wet Cleaning Report (USEPA, 1993).
b Assumed based on assumed function of constituent.
c Detergent weight fraction of 0.00007 in rinse water based on 150 mL detergent per 20 Ib clothes,
wash and rinse volumes of 1.35 L water per Ib clothes, 5% of wash water remaining in clothes after
extraction.
E-13
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Appendix E
Release and Exposure Methodology and Data
Exhibit E-14. Estimates of Workers' Dermal Exposures to Example Detergent #2 Constituents3
1
2
3
4A
4B
5
6
7
8
9
10
11
12
Constituent
water
lauryl polyglucose
lauric acid diethanolamide
methyl 2-sulfolaurate, sodium salt
sodium lauryl isethionate
sodium laureth sulfate
sodium citrate
cocamidopropyl betaine
Aveda's fragrance (orange)
cocoamphocarboxyproprionate
sodium carbonate
citric acid
diazolidinyl urea
Weight
Percent"
54
4.28
4.28
2.14
2.14
4.28
2.5
4.28
1
4.28
10
2.5
4.28
Contacting Dilute
Formulation via Wet
Clothes Transfer0
(mg/day)
18,000
0.05
0.05
0.03
0.03
0.05
0.03
0.05
0.01
0.05
0.13
0.03
0.05
Contacting
Full Strength
Formulation
(mg/day)
2,100
170
170
83
83
170
98
170
39
170
390
98
170
• These estimated dermal PDRs correspond to the estimates presented in section 4.4.3.1 and are
based on assumption that example detergent #2 contains the constituents listed for 100% Fabric
Cleanser from the Multi-Process Wet Cleaning Report (USEPA, 1993).
b Assumed based on assumed function of constituent.
0 Detergent weight fraction of 0.00007 in rinse water based on 150 mL detergent per 20 Ib clothes,
wash and rinse volumes of 1.35 L water per Ib clothes, 5% of wash water remaining in clothes
after extraction.
E-14
-
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Appendix E
Release and Exposure Methodology and Data
Exhibit E-15. Exposure to Co-located Residents: Information on Monitoring Studies -
Capital District Survey (Schreiber et al., 1993)
Background: The Capital District Survey was undertaken by the New York State Department of
Health in the summer of 1990 to determine if elevated PCE concentrations were present in residences
above dry cleaners. When the 102 dry cleaners in Capital District, New York (this is the area around
Albany) were surveyed, it was found that 6% (six facilities) used PCE on the premises and were located
below occupied apartments (Schreiber et al., 1993). Measurements of PCE concentrations were taken in
the room in each building "most likely to have the highest PCE levels" (Schreiber et al., 1993).
Methodology: Dry cleaning facilities were located through the telephone book. The Capital
District Yellow Pages listed 102 dry cleaners. Sixty-seven of these facilities cleaned or pressed clothing in
the facility. Fourteen drycleaners were located in residential buildings with a total of twenty apartments
above them. However, in some of these buildings the apartments were empty or were only used for
storage. In two other cases, dry cleaning using PCE did not occur on the premises. This left a total of six
co-located drycleaners that used PCE.
In each of these six buildings, the rooms were surveyed to determine where the highest
concentrations of PCE were likely to be found. These determinations were made based on location of
pathways through which PCE emissions could travel from the drycleaners to the apartments, and the
locations of PCE odors in the apartments, if any.
PCE concentration samples were taken during the day (A.M. concentrations, 7:00 A.M. to 7:00
P.M.) and in the evening (P.M. concentrations, taken between 7:00 P.M. and 7:00 A.M.). Sampling in the
six control homes was done at the same time. Each control home was located at least 100 meters from
one of the six dry cleaning facilities and they were chosen based on their similarity to the study homes.
Stainless steel evacuated canisters were used to collect the samples. Samples were analyzed by gas
chromatography/mass spectrometry. The detection limit was 0.0015 mg/m3.
Results: Concentrations in these six apartments (referred to as 'study homes') were compared
with measurements taken at the control homes. Average daily PCE concentrations in the study homes
ranged from 0.100 to 55.0 mg/m3. The highest concentrations were measured above an old dry-to-dry
unit "in poor operating condition" (Schreiber et al., 1993).
In three of the control homes, average measured concentrations were less than 0.0067 mg/m3.
A resident of one control home worked in a chemical laboratory; measured concentrations in this home
ranged from 0.077 to 0.103 mg/m3. Another control home resident worked in a dry cleaner's; measured
concentrations in this home ranged from 0.044 to 0.056 mg/m3. These persons lived in the two control
homes with the highest PCE concentrations. In the sixth control home, measured concentrations ranged
from 0.0097 to 0.022 mg/m3 (Schreiber et al., 1993).
Outdoor PCE concentrations were measured near the study homes and the control homes. The
outdoor concentrations near the study homes were almost always lower than concentrations measured
inside them. In some instances, outdoor concentrations were one to two orders of magnitude lower.
Concentrations outside the study homes ranged from 0.066 to 2.6 mg/m3. Corresponding concentrations
inside the study homes ranged from 0.16 to 55.0 mg/m3. The highest PCE concentration outside a
control home was 0.021 mg/m3. Most PCE concentrations outside control homes were less than 0.0067
mg/m3 (Schreiber et al., 1993).
E-15
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Appendix E
Release and Exposure Methodology and Data
Uncertainties: Apartment residents were asked not to bring newly dry cleaned items into the
home in the week prior to sampling. Most residents complied with this request. However, there may have
been some individuals who did not. Measured concentrations for such individuals' residences could be
higher than for others. Additionally, because sampling occurred during the summer, residents were not
asked to keep their windows closed. In two of the study homes windows were open during the sampling
period (Schreiberet al., 1993). This could have lowered measured concentrations by introducing a
downward bias.
E-16
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Appendix E
Release and Exposure Methodology and Data
Exhibit E-16. Exposure to Co-located Residents: Information on Monitoring Studies -
Consumers Union (Wallace et al., 1995)
Background: In 1995, Consumers Union published a study of PCE concentrations in 29
apartments above dry-to-dry non-vented machines. These apartments were located in 12 residential
apartment buildings, each with one dry cleaner. Measurements were taken from December 1994 to May
1995. Sampling in each apartment occurred over four 24-hour periods, with Sundays included if possible.
Results were averaged over the four days of sampling in each apartment. Samples were also taken in
control apartments, located at least one block from a dry cleaner (Wallace et al., 1995).
Methodology: Consumers Union identified 12 dry cleaners who used dry-to-dry, nonvented
machines. Each cleaner was located in a separate residential building in Brooklyn or Manhattan.
Residents of these 12 apartment buildings were asked to participate in the study. In each residential
building, Consumers Union attempted to sample in different locations at varying distance from the dry
cleaner. Samples were taken in twenty-nine apartments using a passive personal monitor. According to
Consumers Union, "Samplers were placed in areas with good air circulation, and usually in heavily used
rooms (living room, kitchen, bedroom). If residents said they had smelled solvent odors, the monitors
were sited in a room where odors had been smelled, or near a likely entry point for vapors" (Wallace et al.,
1995). Samples were analyzed using gas chromatography coupled with electron capture detection, with a
carbon disulfide eluent. Samples were also taken in ten control apartments, located at least one block
from a dry cleaner.
Results: A total of 116 individual 24-hour samples were taken in co-located apartments. Single-
day measured concentrations ranged from 0.0007 mg/m3 to 38.0 mg/m3. Four-day average
concentrations ranged from 0.007 mg/m3 to 25.086 mg/m3. The four-day average concentrations
represent the average PCE measured value in each apartment over the four days of sampling. In 83% of
the apartments, average concentrations exceeded 0.1 mg/m3; in 28% of the apartments average
concentrations exceeded 1 mg/m3; in 10% of apartments, average concentrations exceeded 5 mg/m3.
The median value for these four-day average PCE levels in co-located apartments was 0.441 mg/m3. The
mean value was 1.85 mg/m3. Consumers Union concluded that "more modern dry-cleaning equipment
does not adequately protect the health of apartment residents from the risks perc poses" (Wallace et al.,
1995).
The highest PCE concentrations were measured above a dry cleaner using a dry-to-dry vented
machine that had been modified to function like a non-vented machine. Consumers Union concluded that
the machine "had been described as an unvented dry-to-dry machine, but probably did not represent the
modern equipment that was our focus" (Wallace et al., 1995). The lowest measured concentrations were
measured in apartments at some distance from the dry cleaners, even though they were in the same
building. In one case in which measured PCE concentrations were low, the apartment was located "on
the far side of a large building from the cleaner, essentially a block away from it" (Wallace et al., 1995).
Concentrations in the control apartments were much lower, ranging from less than 0.0007 mg/m3
to 0.0305 mg/m3 for the single-day average values. The overall average PCE concentration, based on
values from all control apartments, was 0.006 mg/m3 (Wallace et al., 1995).
E-17
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Appendix E
Release and Exposure Methodology and Data
Uncertainties: Residents of the apartments tested volunteered for the study and it is possible that
people who thought their apartment was polluted with PCE were more likely to volunteer for the testing.
However, Consumers Union concluded that there is nothing about the buildings or cleaners chosen to
suggest that they were more likely to find perc problems in the tested buildings than any other.
Testing was limited to one location in each apartment, and testing was limited to only four (usually
consecutive) days, which does not provide a complete picture of a resident's exposure over an entire year,
or longer. It is not known whether the monitor was placed in the best spot to measure perc exposure in
each apartment. CU commented on possible limitations of its monitor placement and study duration.
Results appear to apply to unvented dry-to-dry equipment, although there are numerous variations
in the design and type of machines in this class. It was not possible to differentiate among varieties of
modern unvented dry-to-dry equipment.
Finally, the study did not attempt to determine whether additional control strategies (e.g.,
installation of vapor barriers) could consistently keep perc levels in apartments at or below 0.100 mg/m3,
which Consumers Union chose because it is the New York State Department of Health guideline for non-
cancer health effects.
Other Uncertainties: Residents were instructed not to bring any drycleaned clothes into the tested
apartment during the sampling periods. It is not stated whether all of the apartment dwellers complied
with this request. Additionally, New York City Department of Health (NYCDOH) officials had investigated
complaints in six of the 12 drycleaners before the study began, and five of those were inspected several
times. However, Consumers Union argued that this is not unusual, because the NYCDOH investigates
many facilities each year (for example, 133 facilities were investigated in 1993). Therefore, CU claimed it
is not unreasonable that six of the 12 drycleaners were investigated before the study began. Four other
dry cleaners were investigated by NYCDOH after the study began; Consumers Union provided residents
with a copy of the results, and encouraged them to call the NYCDOH if measured concentrations were
above 0.100 mg/m3.
E-18
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Appendix E
Release and Exposure Methodology and Data
Exhibit E-17. Exposure to Co-located Residents: Information on Monitoring Studies -
New York State Health Department Data, Unpublished
Background: Data on PCE concentrations have been collected in New York State by the New
York City and State Departments of Health (NYCSDOH) in response to residential complaints. These
data consist mainly of four-hour samples taken during the daytime, although a few sets of twenty-four hour
samples are also available.
Methodology: Because these data have not been published by their collectors, they are
accompanied by minimal descriptive information. More than fifty samples above 23 machines were taken
in New York in response to residential complaints between 1991 and 1993 (NYSDOH, 1993).
Results: PCE concentrations ranged from less than 0.02 mg/m3 to 2.5 mg/m3.
Uncertainties: These samples were based on complaints. That means, among other
considerations, sampling was not carried out due to machine characteristics, which varied tremendously.
Several of the dry cleaners were closed down after these concentrations were measured. They were
allowed to reopen after they made improvements to their facilities. Resampling after remediation efforts
were made generally showed a decrease in PCE concentrations in co-located apartments.
E-19
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Appendix E
Release and Exposure Methodology and Data
Exhibit E-18. Exposure to Co-located Residents: Information on Monitoring Studies -
San Francisco Bay Area (BAAQMD, 1993)
Background: The Bay Area Air Quality Management District in San Francisco, CA, measured
PCE concentrations in the hallways of apartments above four non-vented dry-to-dry machines with
refrigerated condensers. These measurements were made to determine if new machines with advanced
controls also caused co-located residents to be exposed to high levels of PCE.
Three of the four drycleaners had taken other precautions to minimize fugitive emissions. Two of
the dry cleaners had isolation rooms with fans. Emissions were vented into these isolation rooms, which
enclose the back of the machines. The fans vent to a stack which exhausts the emissions 10 feet above
the building, which minimizes PCE concentrations in the neighborhood.
The other dry cleaner had "a double layer of gypsum board on the ceiling with all joints sealed with
aluminized tape to minimize diffusion" (BAAQMD, 1993). The room also contained a window fan.
Methodology: Four buildings were chosen for analysis. Each building contained a new dry-to-dry
non-vented machine which had been installed fewer than two years prior to the study. The dry cleaners
were located in residential buildings. Two concurrent samples in each building were taken during
consecutive drying cycles, which lasted for about 40 minutes. Samples were taken using evacuated
stainless steel canisters and analyzed using gas chromatography. No comparison values were taken in
unexposed residences (BAAQMD, 1993). These samples were taken over two 40-minute periods; the
arithmetic mean was reported (BAAQMD, 1993). PCE concentrations were also measured in the
corresponding dry cleaning shops.
Results: PCE concentrations ranged from 0.00224 mg/m3 to 0.673 mg/m3. The highest PCE
concentrations was taken above a drycleaner that was the subject of a prior PCE odor complaint. This
facility did not have room enclosures or fans. Its ventilation was effected by opening the windows and
doors (BAAQMD, 1993).
Uncertainties: This study is based on a small sample size, and sampling occurred over a limited
duration. In estimating exposure to co-located residents, the assumption is made that PCE
concentrations measured in hallways could represent actual exposures to co-located residents. Because
these cleaners were selected subjectively from new dry-to-dry machine facilities including one that had
already been the subject of an odor complaint, it is not clear whether the group reflects likely exposure
levels for properly installed and operating machinery.
E-20
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Appendix E
Release and Exposure Methodology and Data
Exhibit E-19. Exposure to Co-located Residents: Information on Monitoring Studies -
Concentrations Measured in Germany and Netherlands
(Fast, 1993; USEPA, 1992; Staub et al., 1992)
Additional data are available on PCE concentrations in residences above drycleaners in Germany
and the Netherlands. Unlike the US data, which appear to show that PCE concentrations are lower above
non-vented dry-to-dry machines than above transfer and vented dry-to-dry machines, the European data
show no difference in PCE concentrations above vented and non-vented dry-to-dry machines. (Transfer
machines are not used in Europe.) Concentrations measured in Baden-Wurttemberg, Germany, ranged
from less than one mg/m3 to 130 mg/m3, with more than 70% of the measured values less than 5 mg/m3.
The median concentrations measured in co-located apartments in Amsterdam was from 2.2 mg/m3; the
90th percentile concentration was 17.8 mg/m3, and the maximum measured concentration was 29.9
mg/m3. These data were not used in this assessment, which is limited to assessing exposures in the
United States.
E-21
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Appendix E
Release and Exposure Methodology and Data
Exhibit E-20. Inhalation Exposure From a Hypothetical Hydrocarbon Facility
Releases to air result from evaporation of chemicals during the drycleaning process.
Hydrocarbon vapors released from dry cleaning facilities are then carried by and mixed with outside air.
The resulting air concentration will depend on weather conditions. Stagnant conditions will not move
vapors away quickly, so local concentrations of the chemical will be higher than the concentrations farther
rom the plant. Under windy conditions, the vapors will be carried away faster, reducing the local
concentrations. The number of people may increase or decrease with distance from the facility.
For our model facility, we assume a building height of three meters, and a width of 10 meters.
This is a building approximately the size of a one-car garage. We then pick sample weather conditions to
determine what the air concentration of a chemical will be at a set distance from the printing facility. Los
Angeles is used because the weather conditions there will result in the highest average concentrations
around the facility of any of the approximately 500 weather stations in the United States. The average
concentrations around Los Angeles are within an order of magnitude (power of ten) of concentrations
expected anywhere else in the country. If the Los Angeles average concentration were estimated as 10
jg/m3, then the average concentration anywhere in the country would be greater than 1 ug/m .
The model used is called Industrial Source Complex Long Term (ISCLT). It was developed as a
regulatory model by USEPA's Office of Air and Radiation. The Office of Pollution Prevention and Toxics
uses an implementation of ISCLT in the Graphical Exposure Modeling System (GEMS). Except for items
dentified, the parameters entered are the regulatory defaults.
In order to obtain the concentration at 100 meters, a special polar grid was entered. The ring
distances specified were 100 meters, 200 meters, 300 meters, 400 meters, 500 meters, 600 meters, 700
meters, 800 meters, 900 meters and a kilometer. The air dispersion model calculates the average air
concentrations of the chemical vapors in the specified sectors. The sectors are defined by the rings and
the compass points, forming an arc-shaped area. There were three calculations per sector. The
compass point with the highest concentration at 100 meters was then used to determine exposure. The
location was at 90°, that is, east.
The following table, shows the conversion of air releases from kg/site/day to g/m2/s.
Variable
Release in kg/site/day
Days/year
Release in kg/site/year
Release in g/site/second
Conversion of Air Releases
Transfer Machine ;
With Conventional Dryer With Recovery Dryer
17.8 6.6
312 312
5,554 2,059
0.18 0.07
Dry-to-Dry Machine
1.9
312
593
0.02
From the concentration in the air, the amount with which an individual may actually come in
contact can be calculated by knowing the breathing rate. A moderately active adult breathes 20 m3 per
day. The formula for an annual dose is:
Annual Dose = Concentration x Daily Inhalation Rate x Days per year
E-22
.
-------
Appendix E
Release and Exposure Methodology and Data
where the concentration is in (jg/m3, and the breathing rate is in cubic meters per day. The potential dose
normalized for body mass calculated per day for the entire lifetime, is called the Lifetime Average Daily
Dose or LADD (Table 3-3). The formula for this dose rate is:
Concentration x Daily Inhalation Rate x 0.001 mg/ug
LADD =
Average Body Weight
The average body weight used in this assessment is 70 kg (an average adult). Since there is no
ratio for the percentage of days spent breathing air containing evaporated blanket wash chemicals, this
calculation assumes that a person will be breathing this concentration every day of their life.
E-23
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Appendix E
Release and Exposure Methodology and Data
Exhibit E-21. Estimating Concentrations in Surface Water
Aquatic life is exposed to PMN substances that are dissolved or suspended in surface waters
including rivers and streams, bays and estuaries, and lakes and ponds. Calculations of concentrations in
surface water depend on the nature of the water body. Estimated concentrations in surface water are
calculated using the rate of release of the MWC chemicals and the flow rate of the stream into which they
are discharged.
For the CTSA, generic releases have been estimated for the use of MWC chemicals in wet
cleaning facilities. These estimates do not contain any information on specific sites at which those
processes will occur. When releases are expected to occur from an unidentified group of processors or
users, the assessor must identify the general industry to which that group belongs. These industries and
their flow rates are grouped by Standard Industrial Classification (SIC) code. The SIC code for discharges
to Publicly Owned Treatment Works (POTWs) is used in this assessment.
Removal of the PMN substance from water can occur during treatment. Two frequently
encountered removal mechanisms are adsorption to sludge and hydrolysis. Others include
biodegradation and volatilization. Exhibit A-3, which shows the estimated removal of MWC chemicals in
wastewater treatment is shown on page A-17. To calculate concentrations after discharge under these
circumstances, the quantity released after treatment in kilograms per site per day is multiplied by a
conversion factor of 1,000 and the result is divided by the stream flow in million liters per day (MLD), as
shown below:
Release after treatment in kg/site/day x 1000
Stream Concentration =
Streamflow in million liters per day
To assess the potential impact of MWC chemicals on aquatic life, a conservative streamflow
estimated is provided. Because facility sizes vary, there are variations in stream flows, and stream flows
vary with time. In this CTSA, concentrations which occur under low flow conditions in small streams were
estimated. Specifically, low flow is the lowest flow that continues for seven consecutive days in ten years.
This provides conservative estimates of stream concentrations that are compared with Concern
Concentrations. The low flow value used in this assessment was 0.7 million liters per day.
E-24
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Appendix E
Release and Exposure Methodology and Data
Exhibit E-22. Description of the Storage and Retrieval of U.S. Waterways Parametric Data System
(STORET)
A search strategy was implemented to determine if there were any additional information available
for perchloroethylene concentrations in groundwater. The search statement consisted of
"Perchloroethylene or PCE or tetrachloroethylene" and "concentrations or levels" and groundwater.
Dialog, STORET, and the Internet were searched (Schaeffer, 1998).
Information found in STORET (all taken from Schaeffer, 1998):
The Storage and Retrieval of U.S. Waterways Parametric Data System (STORET) is the National
repository for water quality information on ambient levels of contaminants in water bodies, sediments, fish,
and groundwater. It was decided that the emphasis on this STORET retrieval should be placed on public
water supplies. The retrieval was based on the terms: municipal, intake, nonambient, ambient, well and
supply. All observations across the continental United States from 1988 to 1998 for the following station
types were retrieved:
Nonambient spring and wells (groundwater) that are municipal water supplies/treatment facilities.
Ambient springs and wells (groundwater) that are municipal water supplies/treatment facilities.
Data are not available perse in STORET for Public Water Supplies (STORET Support). The
majority of the data is for monitoring. However, using the appropriate keywords, data for
tetrachloroethylene (total) was retrieved from STORET for the period 1988 to present in the Continental
United States.
266 Stations in Utah - 318 observations were identified from 1988 to 1994 but
quantifiable concentrations of PCE were only found in 2
of the samples (at 4.8 and 5.7 /^g/L). The other 316
observations had PCE at or below the detection limits,
with a maximum of 2.9 ^g/L, a minimum of 0.07 ^g/L,
and a mean of 0.66 fj,g/L.
- 247 observations were identified from 1988 to 1997, with
quantifiable levels of PCE found in 5 samples. These
detected samples ranged in concentration from 1.50
/^g/L to 8.0 //g/L with a mean of 4.34 /u.g/L. Of the
remaining samples, 13 were at or below detection limits,
with a maximum of 0.5 ,ug/L a min of 0.07 /^g/L, and a
mean of 0.33 ^g/L. The 229 remaining samples were
non-detected for PCE.
Information found on the Internet (all from Schaeffer, 1998):
ATSDR Toxicological Profiles (copyright 1997) stated that results from an EPA Groundwater
Supply Survey of 945 water supplies from groundwater sources nationwide showed tetrachloroethylene in
79 water supplies. The median concentration of the positive samples was about 0.75 ^g/L (0.75 ppb),
with a maximum level of 69 /ag/L (69 ppb). ' I
56 Stations in Utah and Georgia
E-25
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Appendix E
Release and Exposure Methodology and Data
Massachusetts Military Reservation, Cape Cod, Mass, (dated March 28, 1997) - The Air Force
Center for Environmental Excellence (AFCEE) announced that perchloroethylene (PCE) had been
detected at 18 ppb (parts per billion) in a groundwater monitoring well in East Falmouth, MA. Residential
private well sample collection was proceeding. As of March 27, 1997, samples from 76 residences were
collected in the area.
City of Los Angeles Water Services (copyright 1996) - The North Hollywood Operable Unit
(NHOU) began routine full-time operation of their facility January 1 , 1990. The NHOU treats 2000 gpm
(gallons per minute) groundwater with typical contaminant levels of 120 ^g/L trichloroethylene (TCE) and
5.0 vgll of PCE. The effluent water has about 2 ^g/L of TCE and non detectable levels of PCE.
As discussed in Chapter 4, these data were not used in the exposure assessment, because the
source of the PCE contamination is unclear. However, these data further document PCE contamination of
qroundwater supplies. _ _ _ _ _ _ -
E-26
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Appendix E
Release and Exposure Methodology and Data
REFERENCES
American Business Information. 1994. Business America on Disk. (CD-Rom disk) Omaha, NE: ABI. [As
cited in NIOSH, 1997]
Aveda. 1992. Fax from Aveda Corp. to USEPA/Office of Pollution Prevention and Toxics/Economics,
Exposure, and Technology Division. October.
BAAQMD. 1993. Bay Area Air Quality Management District. An Investigative Survey of
Perchloroethylene in Residential Areas above Dry Cleaners in San Francisco.
CEPA. 1993. California Environmental Protection Agency. Proposed airborne toxic control measure and
proposed environmental training program for perchloroethylene dry cleaning operations. Staff
report. CEPA, Air Resources Board. August.
Fast, T. 1993.' Municipal Health Service (MHS), Amsterdam, the Netherlands. "Exposure to
Perchloroethylene in Homes Nearby Drycleaners Using Closed Systems and the Effect of
Remedial Actions," Proceedings of Indoor Air '93, Vol. 2.
IFI. 1994. International Fabricare Institute. Drycleaning Fundamentals. A Self Study Course. October.
NIOSH. 1997. National Institute for Occupational Safety and Health. Control of Health and Safety
Hazards in Commercial Dry Cleaners- Chemical Exposures, Fire Hazards, and Ergonomic Risk
Factors. U.S. Dept. Of Health, Education, and Welfare, Public Health Service, Centers for
Disease Control, NIOSH. Washington, DC. December.
NYSDOH. 1993. New York Department of Health. Survey of dry cleaning facilities in Capital District,
New York and New York City. Previously unpublished.
OCIS. 1994. OSHA Computerized Information System. Set of 3 data reports generated by OCIS staff for
USEPA. January.
OCIS. 1998. OSHA Computerized Information System. Set of 2 data reports generated from OCIS for
USEPA. January and March.
PEL 1985. PEI Assoc., Inc. Occupational exposure and environmental release assessment of
tetracholorethylene. USEPA, Office of Pesticides and Toxic Substances. Washington, DC.
December.
Schaeffer, Teri. 1998. "Technical Directive #1 Deliverable - PCE in Groundwater Literature Search
Summary." Attachment to a memorandum from Teri Schaeffer, Versar, Inc., to James Darr,
USEPA. May 7.
Schreiber, et al. 1993. An investigation of indoor air contamination in residences above dry cleaners.
Risk Analysis, Vol. 13, No. 3.
E-27
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Appendix E
Release and Exposure Methodology and Data
Staub. W. et al. State Environmental Protection Agency, Hertzstrasse, Germany, 1992. The
Measurements of Tetrachloroethylene Concentrations in the Work Rooms of Dry Cleaning
Establishments and in Rooms Adjacent to Dry Cleaners in the German state of Baden-
Wurttemberg. Final Report. Translated by Abt Associates for the US EPA.
USEPA. 1982. U.S. Environmental Protection Agency. Guideline series: Control of volatile organic
compound emissions from large petroleum dry cleaners. EPA-450/3-82-009. USEPA, Office of
Air Quality Planning and Standards. Research Triangle Park, NC.
USEPA. 1991. U.S. Environmental Protection Agency. IT Corporation for the USEPA/OPPT. Chemical
engineering branch manual for the preparation of engineering assessments. Prepared for USEPA,
Office of Toxic Substances, Chemical Engineering Branch. Washington, DC. February.
USEPA. 1992. U.S. Environmental Protection Agency. Guidelines for exposure assessment. (57 FR
22932).
USEPA. 1993. U.S. Environmental Protection Agency. Multiprocess wet cleaning cost and performance
comparison of conventional dry cleaning and an alternative process. EPA 744-R-93-004.
USEPA, Office of Pollution Prevention and Toxics. Washington, DC. September.
Wallace, D. et al. 1995. Perehloroethylene in the air in apartments above New York City dry cleaners: A
special report from Consumers Union.
E-28
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APPENDIX F
SUMMARY OF EXTERNAL TECHNICAL PEER REVIEW
In January 1993, responding to recommendations in the report Safeguarding the Future: Credible
Science, Credible Decisions, Administrator William Reilly issued an Agency-wide policy for peer review.
Administrator Carol Browner confirmed and reissued the policy on June 7, 1994. As a result, USEPA
established a Standard Operating Procedure (SOP) for the organization and conduct of peer reviews. This
peer review procedure is contained in the Standard Operation Procedures for Peer Review of Major
Scientific and Technical Documents, Office of Prevention, Pesticides and Toxic Substances, U.S.
Environmental Protection Agency, October 1, 1996 - September 30, 1997.
The objective of the peer review is to uncover any technical problems or unresolved issues for use
in revising a preliminary work product so that the final work product will reflect sound technical
information and analyses. Peer review is also considered a process for enhancing a scientific or technical
work product. A peer review is an objective, critical review of an Agency scientific and technical work
product by an independent peer reviewer or reviewers. An independent peer reviewer is an expert who
was not associated with the generation of the specific work product either directly, by substantial
contribution to its development, or indirectly, by consultation during the development of the specific
product. The Agency chose 'a balanced ad hoc panel of independent experts from outside the Agency' as
the mechanism for obtaining a peer review panel. The objective of a 'well balanced panel of independent
peer reviewers' is to assure an objective, fair, and responsible evaluation of the work product.
Over the past six years, the EPA Design for the Environment Garment and Textile Care Program
(GTCP) has collaborated with a group of key stakeholders, including representatives of industry, research,
environmental, labor and public interest groups. At EPA's request, these stakeholders nominated technical
peer reviewers that had expertise in one or more areas: Technology and Economics; Exposure
Assessment; Hazard Assessment; and Risk Assessment. Thirty-nine reviewers were selected from the list
and the official peer review period began on June 24, 1997 with a conference call with stakeholders. All
of the stakeholders' first and/or second and/or third choice nominees in each area of expertise were chosen
for the review. The reviewers were given four weeks to complete their review and return comments.
Thirty-six reviewers provided comments on the draft CTSA. In the course of the review, four reviewers
withdrew from the panel. Reasons for withdrawal from the peer review process included lack of available
time for a thorough review, or lack of specialized expertise necessary to adequately review the material
presented in the CTSA document.
This report presents the general approach and considerations taken into account for conducting the
peer review of the Cleaner Technologies Substitutes Assessment for Professional Fabricare Processes.
The objective of the peer review was to uncover any technical problems or unresolved issues so that the
final will reflect sound technical information and analyses. The peer review was also used to enhance the
scientific and technical content of the CTSA. According to the Standard Operating Procedures for Peer
Review of Major Scientific and Technical Documents, the Cleaner Technologies Substitutes Assessment
was considered to be a major scientific and technical work product, and as such required an independent
peer review. A multi-disciplinary group of experts corresponding to the disciplines that contribute to
complex Agency decisions was necessary for a full and complete peer review. This Appendix describes
the procedures used for obtaining the expert review of the CTSA.
F-l
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Appendix?
Summary of External Technical Peer Review
During the development of the CTSA, EPA's Design for the Environment Garment and Textile
Care Program collaborated with a group of stakeholders, including manufacturers of chemicals used in the
dry cleaning process, formulators, dry cleaners, and others to assist EPA in characterizing the hazards,
uses, exposures, and risks of substances used in the dry cleaning industry, as well as economic
considerations and the identification of pollution prevention opportunities. The group of stakeholders
(Exhibit 2-1) which contributed to the development of the CTSA document were contacted in late May and
early June of 1997. Stakeholders were asked to submit a list of peer review panelists in order of preference
for each of the major technical areas of the CTSA: Technology and Economics; Exposure Assessment;
Hazard Assessment; and Risk Assessment. Each proposed candidate peer reviewer was required to have
training and/or experience in one or more of the following areas: 1) occupational and general exposure
assessment; 2) exposure modeling techniques; 3) chemical monitoring; 4) occupational health; 5) industrial
hygiene; 6) toxicology, including environmental (aquatic); 7) environmental epidemiology; 8) risk
assessment; 9) economics, finance, accounting; 10) marketing; 11) comparative cleaning technologies
(e.g., wet methods); 12) the dry cleaning industry, including equipment and processes used, practices
employed, etc.; and 13) chemistry (product, engineering, environmental fate).
At a minimum, candidate peer reviewers were required to be free of conflict of interest, be
considered experts within their respective fields of study, have specific knowledge of the methodologies
employed in the development of risk assessments (e.g., modeling techniques), have specific knowledge of
the chemicals of concern (e.g., PCE), and, where appropriate, have some knowledge of the dry cleaning
industry. EPA attempted to contact candidate peer reviewers to confirm their interest in reviewing the
document and their availability throughout the months of July and August. For each stakeholder group
that nominated candidate peer reviewers and ranked their nominees, at least their first, second, and third
ranked nominees in each area of expertise were called. Candidate reviewers were contacted to determine
their availability and willingness to take part in the peer review process. The CTSA peer review panel
consisting of 40 peer reviewers was finalized by EPA on July 21, 1997. A list of the individuals on the
peer review panel is contained in Exhibit F-l. This final peer review panel incorporated a large and well
balanced independent panel of experts from the dry cleaning industry and the environmental and scientific
communities.
EPA prepared a separate packet of documentation for the peer reviewers, including a confirmation
letter and non-disclosure agreement. Packets were sent out to all 40 peer reviewers by Federal Express on
July 21, 1997. All reviewers were requested to fax their signed non-disclosure agreements to USEPA by
July 24, 1997.
A conference call took place on July 24, 1997. Participants included EPA and key stakeholders
listed in Exhibit F-2. During the call, EPA announced the release of the CTSA document for peer review.
In the call, EPA stated that a well-balanced panel was chosen since all of the stakeholders' first and/or
second and/or third choice nominees in each area of expertise were chosen for the review.
F-2
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Append ixF
Summary of External Technical Peer Review
Exhibit F-1. Final CTSA Peer Review Panel
Mr. Ken C. Adamson, General Manager
Langley Parisian
Frank Arnold, Ph.D.
Charlene Bayer, Ph.D.
Georgia Tech Research Institute
Arnold Brown. M.D.
Pamela Christenson
Wisconsin Dept of Dev .
Dick Clapp, Sc.D., M.P.H.
Boston University School of Public Health
Dept of Environmental Health
James Cone, M.D., M.P.H.
Elden Dickinson
Michigan Department of Environmental Quality
Paul Dugard, Ph.D.*
ICI Americas, Inc. ,
Diane Echeverria
Battelle Seattle Operations
Adam Finkel, Ph.D.
Director, OSHA Health Standards Directorate
US Department of Labor
George Gray, Ph.D.
Harvard Center for Risk Analysis
Harvard School of Public Health
Dale Hattis, Ph.D.
Center for Technology, Environment, &
Development (CENTED)
Clark University
Ms. Chris Hayes
Greater Chicago P2 Program, MWRD
Denny Hjeresen, Ph.D.
Los Alamos National Labs
Rudolf Jaeger, Ph.D.
Environmental .Medicine, Incorporated
Ellen Kirrane
Hunter College Center for Occup & Envir Health
Dr. Josef Kurz *
Schloss Hohenstein
Jack Lauber, P.E.-D.A.A.E.E.
• Consulting Engineer
James Melius, M.D., Ph.D.
Director
NY State Laborer's Health & Saftey Trust Fund
Frank Mirer, Ph.D.
Director, Health & Safety Dept., UAW
' Kenneth Mundt, Ph.D.
Umass, Dept. Of Biostatistics & Epidemiology
School of Public Health & Health Sciences
D. Warner North, Ph.D.
Decision Focus Inc.
Peter Orris, M.D.
Div. Of Occup. Med/Cook County Hospital
David Ozonoff, M.D., M.P.H.
Boston University School of Public Health
Dept of Environmental Health
Andrew Persily, Ph.D.J
NIST
Routt Reigart, M.D.*
Medical University of South Carolina
Charles Riggs, Ph.D.
Texas Women's University, Department of Fashion
& Textiles
Judy Schreiber, Ph.D.
NY Dept of Health
Tom Starr, Ph.D.
Environ Corp.
F-3
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Exhibit F-1. Final CTSA Peer Review Panel (Continued)
Mike Tatch
Tatch Technical Services
Kimberly Thompson, Sc.D.
Consultant
Harvard Center for Risk Analysis
Joel Tickner
MSC/U Massachusetts Lowell
Greg Traynor
T. Marshall Associates
Arthur Upton, M.D.
Environmental & Occupational Health Sciences Inst.
David Votaw
Education and Information Division (C15)
National Institute for Occupational Safety and Health
Deborah Wallace
Consumers Union Technical Division
* Reviewer did not submit peer review comments to EPA.
Note: No conflicts existed with any peer reviewers.
Clifford Weisel, Ph.D.
Associate Professor
Deputy Director
Exposure Measurement and Assessment Division
Environmental and Occupational Health Sciences
Institute
Noel Weiss, M.D., Dr. P.H.
University of Washington
School of Health & Comm. Med.
Department Of Epidemiology
Manfred Wentz, Ph.D.
Chairperson, AATCC Research Committee
RA43: Dry Cleaning
Kathleen Wolf, Ph.D.
Institute for Research and Technical Assistance
F-4
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Exhibit F-2. Teleconference Attendees for CTSA Announcement - Held July 24,1997
Name
Mary Scalco,
Bill Fisher
Bill Seitz
Ross Beard
Steve Risotto '.
Gary Baise E
Eric Frumin
David DeRosa,
Jack Weinberg
Moon Jong Chun
Cindy Stroup,
Lynne Blake-
Hedges, Mary Ellen
Weber
Melinda Armbruster,
Brandon Wood
Affiliation/Address
International Fabricare Institute
Neighborhood Cleaners Assoc., Intnl.
Fabricare Legislative & Regulatory
Centers for Emission Control
Baise & Miller
Union of Needletrades, Industrial and Textile
Employees
Greenpeace
Federation of Korean Drycleaning Association
U.S. Environmental Protection Agency
Battelle Memorial Institute
Copies of the peer review CTSA document were sent to peer reviewers by Federal Express on July
24, 1997. Enclosed in each package sent to the peer reviewer was a letter of transmittal, a reminder to
return their signed non-disclosure agreement, a peer review guidance document, and an alphabetized list of
CTSA references. The peer review guidance document was a statement of work seeking informed
comment on identified issues to properly focus the efforts of the peer reviewers and to assist them in their
review.
Peer reviewers were asked to return their comments by August 25, 1997. Verbatim comments
from peer reviewers were compiled and sorted by reviewer and by CTSA chapter to which they referred.
Attribution of each reviewer's comments was kept anonymous. In a few cases, text was omitted from the
original comment in order to facilitate reviewer anonymity. Where a comment cited a reference that was
not complete, the reference was listed in square brackets following the comment.
In order to ensure correct transcription of all comments, all comments were checked against the
original reviewer's submission to ensure that the text remained unchanged.
F-5
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During the course of the review, four reviewers withdrew from the panel. Dr. Routt Reigart
withdrew from the peer review process on August 1, 1997, Dr. Andrew Persily withdrew on August 22,
1997, Dr. Josef Kurz withdrew on August 28, 1997, arid Dr. Paul Dugard did not respond. It was not
possible to replace these four reviews since there was not adequate time remaining in the review cycle for
replacements to complete a substantive review. Because the peer review panel was so large, the attrition of
the four reviewers during the review process did not affect the balance of the panel nor the integrity of the
review.
Exhibit F-3 presents summary statistics on the number of comments and number of pages of
comments received. These statistics are separated into the following categories: general comments on
CIS A document, comments on the executive summary, Chapters 1-8, arid Appendixes A-D. There was a
total of 1,855 comments comprising 340 pages. Of these 1,855 comments, there was a total of 208
editorial comments. The editorial comments included spelling changes and other minor structural
modifications to the document.
The reviewers were given 4 weeks to complete their review and return comments to USEPA. Peer
reviewer comments were compiled and sent to the USEPA CTSA Workgroup for disposition. The
USEPA CTSA Workgroup reviewed all comments to determine the necessary changes to the CTSA as a
result of the comments. The workgroup drafted responses to every peer review comment. The peer review
comments and responses are included in the USEPA document, Response to Technical Peer Review
Comments, EPA 744-P-98-001, June 1998.
USEPA feels that this extensive and rigorous technical review by a stellar panel of stakeholder-
nominated reviewers has improved the quality of the CTSA and ensured that its conclusions are valid and
based on sound science.
F-6
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Exhibit F-3. Summary Statistics on CTSA Comments from CTSA Peer Review Panel
Section
General
Executive
Summary
Chapter 1
Chapter 2
Chapters
Chapter 4
Chapter 5
Chapter 6
Chapter 7
Chapter 8
Appendix A
Appendix B
Appendix C
Appendix D
Total
Complete Set of Comments
# of Pages
49
12
56
32
60
61
12
17
10
12
13
1
4
1
340
# of Comments
181
67
328
194
357
375
61
82
50
71
62
6
20
1
1855
F-7
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50272-101
REPORT DOCUMENTATION
PAGE
1. REPORT NO.
EPA 744-B-98-001
3. Recipient's Accession No.
Not applicable
4. Title and Subtitle
Cleaner Technologies Substitutes Assessment: Professional Fabricare Processes
5. Report Date June 1998
7. Author(s) The following people were major contributors to the study: Lynne Blake
Hedges, EPA Project Manager, and the EPA Workgroup members Andrea Blaschka,
Lois Dicker, Ph.D., Elizabeth Margosches, Ph.D., Fred Metz, Ph.D., Ossi Meyn, Ph.D.,
Mary Katherine Powers, and Scott Prothero.
8. Performing Organization Kept.
No.
EPA744-B-98-001
9. Performing Organization Name and Address
U.S. Environmental Protection Agency
Office of Pollution Prevention and Toxics (7401)
401 M Street, S.W.
Washington, D C. 20460
10. Project/Task/Work Unit No.
11. Contract(C) or Grant(G) No.
(C) 68-W-98005;68-W6-0021;
68-D5-0008; 68-D7-0025
(G)
12. Sponsoring Organization Name and Address
U.S. Environmental Protection Agency
Office of Pollution Prevention and Toxics (7401)
401M Street, S.W.
Washington, D.C. 20460
13. Type of Report & Period
!overed
Final Report
14.
15. Supplementary Notes
Management and other general support were provided by EPA staff: David Lai, Ph.D., Robert E. Lee, Ph D Cindy Stroup
Mary Ellen Weber, Ph.D., and Vanessa Vu, Ph.D. Research, editing, and document preparation were conducted by Abt
Associates under the direction of Alice Tome. The independent technical peer review of the document was conducted by
Battelle Columbus Laboratories under direction of Bruce Buxton. Technical editing and general support were also provided by
Westat, Inc. under the direction of Karen Delle Torre.
16. Abstract (Limit 200 words)
The Cleaner Technologies Substitutes Assessment (CTSA): Professional Fabricare Processes was developed as part of an
effort to explore opportunities for pollution prevention and reduced exposure to traditional drycleaning chemicals (primarily
perchloroethylene [PCE]). The intended audience for the CTSA is technically informed and might consist of individuals such as
environmental health and safety personnel, cleaning facility owners, equipment manufacturers, and other decision makers It is
expected to be used as a technical supplement by USEPA and stakeholders to develop information products suitable for a broad
audience. These products will help professional cleaners make informed technology choices that incorporate environmental
concerns.
The CTSA compares the cost, human health and environmental risks and performance of professional fabricare technologies
based on readily available information and using simplified assumptions and conventional models to provide general
conclusions. Eight PCE technology alternatives, three hydrocarbon technology alternatives and machine wet cleaning are
evaluated in depth. Qualitative information is provided on four emergent technologies, liquid carbon dioxide drycleaning,
propylene glycol etlier (Rynex) solvent, ultrasonic wetcleaning, and Biotex solvent.
17. Document Analysis
a. Descriptors: Drycleaning, wetcleaning, clothes cleaning, perchloroethylene, perchloroethene, PCE, Perc, Stoddard
solvent, chlorinated solvents, petroleum solvents, hydrocarbon solvents, alternative solvents, dry cleaning, wet cleaning, DF
2000, liquid carbon dioxide, Rynex, propylene glycol ether, Biotex, ultrasonic cleaning, drycleaning cost, drycleaning '
performance, wetcle:aning cost, wetcleaning performance.
b. Identifiers/Open-Ended Terms: Possible carcinogens, pollution prevention
c. COSATI Field/Group: Not applicable
18. Availability Statement
Unlimited Availability
19. Security Class (This Report): Unclassified
20. Security Class (This Page): Unclassified
21. No. of Pages: 474
22. Price
'See ANSI-239.18)
OPTIONAL FORM 272 (4-77)
(Formerly NTIS-35)
Department of Commerce
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