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EPA744-S-98-001
June 1998
Cleaner Technologies Substitutes Assessment for
Professional Fabricare Processes: SUMMARY
4^25*
US. EPA
Design for the Environment Program
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
The information in this document is based entirely upon the full technical report titled
Cleaner Technologies Substitutes Assessment for Professional Fabricare Processes (EPA 744-B-
98-001, June 1998). That document has been subject to U.S. Environmental Protection Agency
(EPA) 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 EPA approval, endorsement, or recommendation.
Information on sales, costs, performance, and product usage was provided by individual
product vendors, or by EPA Garment and Textile Care Program stakeholders, and was not
independently corroborated by EPA.
Discussion of selected 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.
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Acknowledgments
The overall Project Manager for the full technical document, titled Cleaner Technologies
Substitutes Assessment for Professional Fabricare Processors (EPA 744-B-98-001) was Lynne
Blake-Hedges. In addition to being responsible for the 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 Katherine 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 Associated 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 Cleaninghouse (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
11
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TABLE OF CONTENTS
Eage
DISCLAIMER i
ACKNOWLEDGMENTS ii
TABLE OF CONTENTS iii
INTRODUCTION 1
Background 1
The Design for the Environment Garment and Textile Care Program 1
Road Map to the Document 2
THE PROFESSIONAL CLOTHES CLEANING INDUSTRY 3
OVERVIEW OF PROFESSIONAL FABRICARE TECHNOLOGIES 4
Perchloroethylene Processes and Equipment 4
Equipment and Process Terminology 4
Machine Types 7
Perc Equipment for Spill Containment 8
Perc Equipment for Fugitive Emissions Control 8
Hydrocarbon (petroleum-based) Processes and Equipment 9
Hydrocarbon Flammability Hazards 12
Professional Wetcleaning Processes and Equipment 12
EMERGING TECHNOLOGIES 14
RELEASE AND EXPOSURE 14
Perc and Hydrocarbon Releases 15
Wetcleaning Releases 15
Exposure 17
HEALTH AND ENVIRONMENTAL RISK 19
Risk Assessments 19
Perchlorethylene Solvent 20
Hydrocarbon Solvents 21
Wetcleaning Detergent 22
SELECTED FEDERAL REGULATORY REQUIREMENTS 23
COSTS 25
Assumptions 25
Cost Factors 28
Capital Equipment 28
Maintenance 28
Energy 28
Installation 28
Solvent and Other Material 29
Filters/Cleaning Supplies 29
in
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TABLE OF CONTENTS (continued)
Eage
Hazardous Waste Disposal 29
Regulatory Compliance 30
Labor 30
PERFORMANCE 30
Establishing the Protocols for Performance Testing 31
Physical and Chemical Characteristics of Clothes Cleaning 31
Summary of Performance 33
PROCESS TRADE-OFFS 33
ENVIRONMENTAL IMPROVEMENT APPROACHES , 33
Perc and Hydrocarbon Drycleaners 34
Wetcleaning Processes 34
CONCLUSION 37
Fabricare Industry Trends 37
I
REFERENCES '. 38
List of Figures
Eigure P-age
i
1 Solvent Usage in the Commercial Sector of the Drycleaning Industry 4
2a Simplified Process Flow Diagram for Perc Transfer Machinery
("First Generation") 5
2b Simplified Process Flow Diagram for Perc Dry-to-Dry Closed Loop Machinery
with Integral Carbon Adsorber ("Fifth Generation") 5
3a Simplified Process Flow Diagram for Hydrocarbon Transfer Solvent
Machinery 11
3b Simplified Process Flow Diagram for Hydrocarbon Dry-to-Dry
Solvent Machinery 11
4 Simplified Process Flow Diagram for Machine Wetcleaning 13
5 Estimated Releases from Perc Model Facilities with Various Machine
Types and Emission Controls 16
IV
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Figure
6
TABLE OF CONTENTS (continued)
List of Figures (continued)
Eage
Estimated Releases from Hydrocarbon Model Facilities with Various Machine
7
8
9
10
11
12
Types and Emission Controls
Exposure Scenarios Evaluated for Human Health Effects
Summary of Regulations Related to Fabricare Technologies
Potential Operating Factors Associated with Fabricare Facilities
Summary of Estimated Process-Dependent Cost Components for Selected
Fabricare Technology Options ,
An Overview of Trade-Off Factors for Alternative Cleaning Technologies
Maintenance Schedule for Drycleaning Equipment ,
17
18
24
26
27
35
36
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Introduction
Background
Chemical solvents have been used for cleaning clothes since the mid-19th century, and
perchloroethylene (perc) has been the solvent of choice for drycleaners since the 1960s. Although the
volume of perc used by drycleaners has declined significantly over the past decade, a variety of
health and safety issues and increased regulation of the chemical have compelled the U.S.
Environmental Protection Agency (EPA), industry, and environmental groups to address
concerns about perc emissions. As part of an effort to explore opportunities for pollution
prevention and reduce exposures to traditional drycleaning chemicals, the EPA's Design for the
Environment Garment and Textile Care Program developed the Cleaner Technologies
Substitutes Assessment for Professional Fabricare Processes (CTS A) which was published in
June 1998. The current report is a summary version of that document.
The CTS A is a compilation of information on the relative risks, costs, and performance of
clothes cleaning operations. It 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. Assumptions used to develop the
information are presented in the CTS A to assist users in determining the applicability of the
information to various clothes cleaning operations. Because of these assumptions and the
limitations of available data, it is reasonable to expect that actual risks, costs, and performance
may vary for specific clothes cleaning operations.
The fabricare industry is characterized by small companies that rarely have the time or
resources needed to do the type of complex technical analysis in the CTS A. EPA's goal in
undertaking this assessment was to provide cleaners with information that can be used to inform
business decisions and to encourage their consideration of environmental issues along with cost
and performance factors. In addition to professional cleaners, the audience for the fabricare
CTSA includes technically informed individuals such as environmental health and safety
personnel, owners, equipment manufacturers, and other decision makers.
The Design for the Environment Garment and Textile Care Program
"Design for the Environment" means building in pollution prevention aspects when
industry is developing or making changes to a product or process. The EPA Design for the
Environment (DfE) Program harnesses EPA'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.
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» 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.
I
Drycleaning was selected as the first DfE project in response to concerns raised at a May
1992 International Roundtable on Pollution Prevention and Control in the Drycleaning Industry.
Researchers, industry representatives, and government officials met to exchange information on
exposure reduction, regulation, and information dissemination. Numerous other topics were also
discussed, such as potential health and environmental considerations related to exposures to
drycleaning solvents. Key stakeholders were committed to exploring ways to prevent pollution,
choose safer substitutes, and reduce exposures to traditional drycleaning chemicals and included
the Neighborhood Cleaners Association-International (NCAI), International Fabricare Institute
(EFI), Federation of Korean Drycleaners Associations (FKDA), Greenpeace, New York State
Departments of Health and Environmental Conservation, Fabricare Legislative and Regulatory
Education Organization, EcoClean, The Dow Chemical Company, Center for Emissions Control
(now the Halogenated Solvents Industries Alliance), American Clothing and Textiles Workers
Union (now the Union of Needletrades, Industrial, and Textile Employees), Center for
Neighborhood Technologies (CNT), and the Toxic Use Reduction Institute at the University of
Massachusetts.
The DfE Garment and Textile Care Program's (GTCP) mission is to assist in providing
professional garment and textile cleaners with a wider range of environmentally friendly
technology options that they can offer to their customers, while maintaining or increasing
economic viability. Much progress has been made as evidenced by both dramatic reductions in
perc use by the drycleaning industry as well as the growing commercialization of several new
cleaning technologies. The CTSA is intended to further that progress by providing extensive
detailed technical information to inform business decisions.
In recent years, the GTCP focus has expanded with the recognition that drycleaning is at
the terminal end of an elaborate chain of industries in the garment and textile industry sectors,
and that decisions made by these "upstream" industries can directly affect the cleanability of
garments in new cleaner processes. As a result, the GTCP has adopted a "systems" or industrial
ecology approach to pollution prevention and is soliciting participation from a wider group of
stakeholders than was involved in the development of the fabricare CTSA. The objective is to
promote not only cleaner production in the design and 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.
Road Map to Document
Recognizing that not all professional cleaners have the time to read the full fabricare
CTSA, EPA prepared this summary document which was abstracted directly from the June 1998
publication. Information that has become available since June 1998 is not included in this
summary and will be made available through fact sheets and case studies.
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In this summary report, the reader is first introduced to the clothes cleaning industry and
provided an overview of professional fabricare technologies. New and emerging technologies
are also covered including liquid carbon dioxide (CO2), ultrasonics, and solvents based on
chemicals such as glycol ethers, although there is much less information available on these
systems. Summary information is presented on release, exposure, health and environmental
relative risk, selected federal regulations, costs, performance, process trade-offs, environmental
improvement approaches, and industry trends. A complete list of references is included.
The Professional Clothes Cleaning Industry
The professional clothes cleaning industry, includes approximately 36,000 facilities that
generate a total revenue of $7.2 billion annually (Seitz, 1997; Faig, 1998; Wong, 1998). Clothes
cleaning volume for these facilities is estimated to be 871 million kilograms (1.9 billion pounds)
of clothes per year (Faig, 1998; Wolf, 1998). More than 90 percent of the 36,000 commercial
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 cleaning processes under development,
drycleaning and wetcleaning are the primary clothes cleaning processes that are commercially
available at this time. Drycleaning uses organic solvents to clean soils from clothing.
Commonly-used solvents are perchloroethylene (perc) and hydrocarbon solvents. Perc
drycleaning solvents are used by approximately 30,600 (85%) fabricare facilities in the U.S.,
while hydrocarbon solvents are used by approximately 5,400 (15%) facilities. Hydrocarbon
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 the flashpoint. In 1994, Exxon introduced a synthetic
hydrocarbon 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). Figure 1 provides details of solvent usage in the commercial sector of
the drycleaning industry.
Professional wetcleaning is a relatively new process that uses water as the primary
solvent to clean fabrics. It has been in commercial use since 1994 and is more often used in
combination with other cleaning methods, although there are a small number of 100 percent
wetcleaning shops. Equipment sales data and anecdotal information indicate that the use of
wetcleaning is steadily increasing.
Although perc holds the largest market share of the clothes cleaning industry, between
1981 and 1996, there was a 72 percent decrease in perc use by the fabricare industry (Risotto,
1997). There were a number of reasons for this decline including regulatory pressure, the growth
in the production of wash-and-wear fabrics by the garment industry (Levine, 1997), and concerns
regarding the human health and environmental hazards associated with perc. Until recent years,
the drycleaning industry had focused on designing new perc-using equipment with more
effective solvent recovery and recycling systems, as well as developing safer solvents. There is
growing interest in alternatives to perc in order to reduce exposures from perc use.
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Figure 1: Solvent Usage in the Commercial Sector of the Drycleaning Industry
Fabricare Solvent Type
Number of Facilities
Drycleaning Volume (kg/yr)
Solvent Consumption (MM kg/yr)
Perch loroethylene
30,600a
741,818,181°
45d
Hydrocarbon
Solvents
5,400a
130,909,091°
8.3 to 34e
Wetcleaning
38b
NA
NA
NA = Not available.
Estimate based on 85% perc and 15% hydrocarbon use; data provided by the California Air Resources Board (Wong, 1998).
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 (EPA, 1998).
0 Estimated from revenue (Faig, 1998; Seitz, 1997), and based on 85% perc and 15% hydrocarbon use.
* 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 hydrocarbon solvent options presented on pages 15-17.
Overview of Professional Fabricare Technologies
Perchloroethylene Processes and Equipment
Perc use in drycleaning became prevalent in the 1960s, and several of perc's desirable
characteristics have helped it become the most common drycleaning solvent in the United States.
As the use of perc in drycleaning has proliferated, a combination of financial factors, regulations,
and environmental concerns has given drycleaners incentives to reduce perc releases. As a result,
perc drycleaning equipment has evolved considerably. This summary report describes the
equipment through use of the most common terminology.
Equipment and Process Terminology
Machines used to clean garments and other articles may be classified into two types:
transfer and dry-to-dry. Figures 2a and 2b illustrate how perc transfer and dry-to-dry
configurations work. Like home clothes washing equipment, transfer machines have a unit for
washing/extracting and another unit for drying. Following perc extraction, articles that had been
immersed in perc 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
perc vapor recovery machinery.
The following are terms that describe the primary equipment used to clean garments for
the technologies covered in this document. The reader should note that some of the terms listed
below also apply to hydrocarbon and emerging technologies configurations as well as perc
configurations.
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Figure 2a
Simplified Process Flow Diagram for Perc Transfer Machinery ("First Generation")
Source: Adapted from USEPA, 199 Ib, for the U.S. Environmental Protection Agency's Office of Pollution
Prevention and Toxlcf.
With coniultttion from Bill, 1998.
Figure 2b: Simplified Process Flow Diagram for Perc Dry-to-Dry Closed Loop
Machinery with Integral Carbon Adsorber("Fifth Generation")
Source: Adapted from NIOSH, 1997.
With conniltatlon &om Hill, 1991.
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 that are not represented on these diagrams.
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Primary controls are devices that can either recover perc from vented aeration air
or eliminate the aeration step from first and second generation machines (CEPA,
1993).
Carbon adsorbers are the most commonly used primary controls along with
refrigerated condensers. Once the carbon adsorber reaches its capacity for
adsorbing perc from the aeration stream on a daily basis, the perc is usually
removed (desorbed) from the carbon adsorber by passing steam through the
carbon adsorber. Steam containing perc exits from the carbon adsorber and is
routed to a condenser, which liquefies the perc and water vapors. The liquid perc
and water mixture from the condenser is routed to the water separator. The
carbon adsorber must dry thoroughly before it is ready for reuse (CEPA, 1993).
Spin disk filters consist of fine-mesh disks in a tube. During filtration, perc
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 perc, 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, perc contaminated with insolubles
passes through the screen, depositing the insolubles on the outside of the screen
(CEP A, 1993).
1
Bump-style filters are modified tubular filters that are "regenerated" after each
load of clothes (CEPA, 1993).
Cartridge filters, unlike other filter types that are reusable, are used and discarded.
Perc 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 perc, which then exits the filter. Usually, the
spent filters are then removed from the facility as hazardous waste (CEPA, 1993).
Still bottoms are the concentrated waste material (usually 20% to 80% perc)
resulting from distillation. Most drycleaners use distillation to keep the solvent
clean enough to avoid odors and the darkening of articles. Without distillation,
oils, soils, dyes, detergents, and other perc-soluble impurities would build up in
the solvent (CEPA, 1993).
Muck cookers are a special type of still that is used with machines that use powder
filters (usually spin, tubular, and bump-style filters). Muck cookers have several
features that stills do not: a special intake opening and valve from the air 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, which results in a "dry" powder muck. The "dry" muck,
which contains used filter powder and other soluble and insoluble impurities from
the perc, is then removed from the cooker (IFI, 1994).
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Water separators are devices that receive perc and water mixtures from many
sources and separates them. The mixtures enter the separator and are separated
into perc and water layers, with the heavier perc 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 perc is usually drained from
the bottom of the separator to either the perc storage tank or the machine cylinder
(CEP A, 1993).
Machine Types
Perc machines can have various configurations. Some of these configurations are
described below:
Perc-Al: 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.
Perc-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 perc before emitting the air stream.
Perc-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 perc from the drying air stream, resulting in lower emissions than would occur
from a machine with a non-refrigerated condenser.
Perc-Bl: 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.
Perc-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 perc before emitting the air
stream.
Perc-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. Internal conversion includes converting the internal
condenser from an 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
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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.
Perc-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 which
exhausts drying air back to the machine as input air in a "closed-loop" cycle (i.e.,
third generation equipment). Some of these machines have a fan intended to
reduce exposures; when the machine door is opened after the drying cycle, the fan
draws air through an exhaust and sometimes to a small carbon adsorber. These
small adsorbers, sometimes known as "OSHA fans," are not believed to have
much effect on emissions.
Perc-D: Dry-to-Dry Closed-Loop with Unvented Integral Secondary Carbon
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 and while the door is closed, air
from the drum circulates to a large carbon adsorber (40- to 60-pound carbon
capacity for a 50-pound clothing capacity machine), which may remove most of
the perc before the door is opened (i.e., fourth generation equipment). Some
machines may have an integral perc sensor, which will not allow the door to be
opened until the perc level has fallen to a maximum allowable level (i.e., fifth
generation machine).
Perc Equipment for Spill Containment
Spill containment is a control that reduces perc 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).
Perc Equipment for Fugitive Emissions Control
A variety of fugitive emissions recovery, ventilation, and containment systems have been
employed to reduce emissions and/or exposure to perc vapor in the facility. The "OSHA fans"
described earlier under Machine Types (pg. 7) are one of these systems. Other local and general
exhaust systems may be used to remove and sometimes recover perc vapor from air in the
facility. Floor vents can be effective at removing and recovering perc, especially in the event of
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spills. In some of these systems, air containing perc can be directed to carbon adsorbers to
recover some of the perc vapor.
Perc 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 perc and can be used to achieve minimum ventilation rates
or other requirements. The walls and ceiling are made of materials that are impermeable to perc.
The enclosures have negative air pressure relative to the facility to prevent perc migration. The
air collected from the vapor barrier may be exhausted outside the facility or to a control device
such as a carbon adsorber to recover some of the perc vapor (CEP A, 1993). Similarly, particular
coatings and wallpapers used as perc 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 National Emissions Standards for Hazardous Air Pollutants
(NESHAP), a dry-to-dry machine used in conjunction with a dryer/reclaimer is considered to be
a transfer machine. Articles are damp with perc when they are physically transferred from the
washing machine to the dryer, and some evaporation occurs during this transfer. The NESHAP
identified 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 associated with 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 perc emissions relative to
the older transfer machine. Another alternative to reduce transfer emissions 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 carbon adsorber. 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 perc-damp articles. A fan can draw room air into the enclosure, and air and perc
vapor are routed to a control device, usually a carbon adsorber, attached to the hamper enclosure.
Hydrocarbon (petroleum-based) Processes and Equipment
Prior to perc, hydrocarbons dominated the drycleaning industry in the United States.
The most commonly used hydrocarbons are two petroleum solvents: Stoddard solvent and 140°F
solvent (IFI, 1994). However, synthetic hydrocarbon and other alternatives to petroleum
solvents are being marketed. Regarding the process equipment, hydrocarbon equipment has not
undergone the evolution which perc machinery has, so fewer variations and options exist in
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hydrocarbon equipment. Also, hydrocarbon processes and equipment seem to have received
little attention, as indicated by scant coverage in the literature. Therefore, information presented
in this document is based on aging literature sources and some more recent personal contacts.
Like perc machines, 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 hydrocarbon
extraction, articles that had been immersed in hydrocarbon 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.
ii
Three hydrocarbon machine configurations utilizing emission control technologies follow
some of the same perc configurations. They are described below:
H.C.-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 hydrocarbon from the
wet clothes, and exits the drying tumbler directly to the atmosphere. (All
hydrocarbon that is not extracted from the clothes is emitted to air.)
H.C.-A2: Transfer with Recovery Dryer (with Condenser): Washing and extraction
in one machine, drying hi 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 hydrocarbon 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.
H.C.-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,
which cools the air and recovers some of the hydrocarbon 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.
Figures 3 a and 3b illustrate how two hydrocarbon configurations work.
10
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Figure 3a: Simplified Process Flow Diagram for Hydrocarbon Transfer So (vent Machinery
Source: Adipted from USEPA, 1991b, for the U.S. Environmental Protection Agency'i Office of Pollution
Pieveation and Toxics.
WHh couulufion from Hill, 1991.
Figure 3b: Simplified Process Flow Diagram for Hydrocarbon Dry-to-Dry Solvent
Machinery
Sourcei: Ad«pttd from OTEC, Swill Clcin Hydiocubon Diyolunlng Inftucdon Hindbook.
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 that are not represented on these diagrams.
11
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Hydrocarbon Flammability Hazards
,i
A major hazard identified with the hydrocarbon solvents is their potential flammability. The
National Fire Protection Association (NFPA) ranks chemicals on a scale of 0 to 4 for flammability.
NFPA gives hydrocarbon solvents a grading of "2," indicating that they must be moderately heated
or exposed to relatively high ambient temperatures before ignition can occur. For comparison, perc
receives a grade of "0" for flammability, which indicates that it will not burn.
Of the hydrocarbon chemicals examined, DF-2000 has the highest flashpoint, followed by
140°F solvent and Stoddard solvent. 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 has been found in the
published literature for these systems. The following descriptions are based upon limited personal
contacts and assumptions. The nitrogen injection and oxygen vacuum is expected to be used only
during the drying cycle when air containing hydrocarbon vapor is heated.
Drycleaning equipment with nitrogen injection injects nitrogen into the cleaning chamber
in combination with hydrocarbon. 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).
Professional Wetcleaning Processes and Equipment
!
During the 1990s, several aqueous-based processes were explored as substitutes for
drycleaning of some garments. One of these processes, previously called "multiprocess
wetcleaning," relied heavily on hand labor to remove soil from garments. This process used a
variety of different techniques depending on the individual characteristics of the garment. These
techniques included steaming, immersion and gentle hand washing in soapy water, hand
scrubbing, tumble drying, and 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 commercially viable cleaning method. However,
some of its techniques have been used to supplement the second, more widely-accepted aqueous
process, which is called wetcleaning (Environment Canada, 1995).
The currently-employed wetcleaning process differs from 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 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
12
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equipment functions for this system are expected to be generally applicable to other 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 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 discharged to the sewer. After the garment rinsing step, rinse
water may be discharged to the sewer or may be recovered and reused using storage and filtrating
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 drying air is recycled, and
automatic drum reversal is intended to dry the load evenly and help prevent creasing. Figure 4
below illustrates the process for wetcleaning.
Figure 4: Simplified Process Flow Diagram for Machine Wetcleaning
Sources: Adapted from EPA, 1997, for the U.S. Environmental Protection Agency's Office of Pollution
Prevention and Toxics. Training Curriculum for Alternative Clothes Cleaning.
With consultation from Star, 1998.
13
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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. This document briefly describes liquid carbon dioxide (CO2), aqueous ultrasonic
fabricare technologies, and new solvents in development. There may be others, but these are the
only ones for which EPA had information in June of 1998, at the time the CTSA was published.
These technologies are in various stages of commercial development, therefore, information is
limited and may be speculative.
Carbon dioxide (CO2) processes that use CO2 in a liquid state have been developed for
fabric cleaning. Since the publication of the CTSA, at least one liquid CO2 process has become
commercially available. [EPA has developed a case study summarizing available information on
this new technology.] Ongoing studies should eventually present a clear determination of the
actual capabilities of drycleaning with liquid CO2 (Williams et al., undated).
Extensive information on CO2 processes is not yet available. However, initial
information indicates that the closed-loop machine configuration significantly reduces CO2
emissions by recovering and recycling the solvent in which the garments are washed (Chao,
1994; Micell, 1997). In addition, research has shown that liquid CO2 processing had no
deleterious effects on test fabrics, had acceptable shrinkage, and removed more soil than standard
perc drycleaning. Because the liquid CO2 technologies under development are proprietary,
complete process operating parameters are not available.
i
Aqueous-based ultrasonic washing processes have been used in industrial cleaning
applications for many years. They are now being researched for garment cleaning. Ultrasonic
cleaning uses a high-intensity sound wave in a fluid medium to create mechanical forces that
dissolve and displace contaminants on clothing. Detailed descriptions of ultrasonic process
equipment are not available.
Surfactants, detergents, and/or ozone theoretically may be used in an ultrasonic aqueous
solution to clean stationary garments. Free-floating items tend to reduce ultrasonic energy in
solutions, and this reduction would not allow for the sound wave energy needed to create
mechanical agitation. A combination of blended detergents and ultrasonics may allow polar and
non-polar contaminants to be removed at temperatures between 90°F and 122°F (32°C to 50°C)
without damage (Abt, 1994). If developed, a machine that could accomplish cleaning in this way
would be an alternative to the washer in the wetcleaning system, and extraction and drying would
need to be incorporated into this system.
Other new solvents are being developed. One, based on glycol ethers, has been in
development for some time. It is intended to be a drop-in substitute for perc in modified perc
equipment. There are other solvents in development. EPA has no independent data on any of
these processes other than manufacturers' claims.
Release and Exposure
Releases occur when chemicals are no longer contained within the process or are no
longer under the control of the facility using those chemicals. The assessment of releases
14
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involves the estimation of magnitude, frequency, and medium (e.g., to air, to water, or in solid
waste for off-site disposal to landfill, incineration, or recovery processes) of releases.
Perc and Hydrocarbon Releases
Because perc is defined as a hazardous air pollutant by the Clean Air Act (CAA) and a
hazardous waste by the Resource Conservation and Recovery Act (RCRA), releases from perc-
based systems are a significant concern. Drycleaners can release perc and hydrocarbons to the
air, as both vented and fugitive emissions, and to water mainly as separator wastewater. In
addition, certain perc and hydrocarbon waste waters can be discharged to sewers and may leak to
ground water before reaching a publicly owned treatment works (POTW) for treatment (Wolf,
1992). Some facilities also dispose of separator water as hazardous waste. Facilities generating
more than 220 pounds per month of hazardous waste are required to dispose of such waste
through a RCRA-approved waste handler. Hydrocarbon solvent wastes generated from certain
cleaning processes are also defined as a hazardous waste.
Both processes also create chemicals that are discarded by drycleaners in the form of
solid wastes, such as distillation still bottoms and used cartridge filters. Amounts of these
releases vary widely between individual facilities and may be affected by equipment differences,
such as cleaning machine capacity, vapor recovery devices, operating temperatures, separator
size, filter type, number of cleaning machines, and still type. In addition, differences in operating
conditions, such as number of articles cleaned per load, number of loads per day, drying time,
residence time in water separator, and differences in maintenance and general housekeeping, all
affect releases. Both perc and hydrocarbon processes have a multitude of machine
configurations for which EPA has developed release estimates. Figure 5 and Figure 6 outline
some of the major configurations and their release estimates.
Wetcleaning Releases
Clothes cleaners using the wetcleaning process are expected to release detergents,
finishes, water softeners, and other cleaning and processing aids primarily to water during the
wash and rinse cycles of the machines. Most chemical constituents in the various wetcleaning
formulations are likely to be non-volatile. Releases of chemical constituents such as fragrances
to air and chemicals from the formulations in solid wastes would also be expected to be relatively
small.
Because wetcleaning technologies are relatively new to commercial cleaning, no actual
environmental release data are available for these processes. However, two existing studies
contain enough information to calculate formulation use rates (Environment Canada, 1995;
Gottlieb et al., 1997). In these studies, modeling was used to estimate releases of detergents from
15
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Machine Type and Control
Technology
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a Based on emission factors in EPA, 1982. Total air emissions are the sum of vented emissions and fugitive emissions. The
CTSA's "model facility" throughput of 53,333 Ib/yr clothes was used to estimate these releases. Air release from dry-to-dry
closed-loop is based on air release from transfer with recovery dryer multiplied by the ratio of perc dry-to-dry closed-loop to
perc transfer with refrigerated condenser.
b Based on 3.4 Ib water recovered per 100 Ib clothes for a system with a recovery dryer, and the same recovery assumed for
dry-to-dry; hydrocarbon losses based on 0.036 ppm hydrocarbon average in waste water, 3.78 kg/gal water and 3.0 kg/gal
hydrocarbon, and 10% of total water volume recovered from a system with no condenser relative to recovery from a system
with a condenser.
c Based on emission factors in EPA, 1982. Total solid waste loss includes spent cartridge filters and vacuum still bottoms.
Hazardous waste is assumed to average 40% hydrocarbon by weight (EPA, 1982) and to average 1.71 kg/gal (assuming that
the non-hydrocarbon portion has the density of diatomaceous earth, 0.834 kg/gal).
two model facilities. It was assumed that all detergents were released to water. Only one
primary factor affecting release quantities was found, that is, the percentage of clothes cleaned by
immersion in water. The Environment Canada study estimated a detergent release of 29.5
gallons per year from a model facility that machine washes less than 100 percent of the clothes
cleaned. The study by Gottlieb et al. estimated a detergent release of 95.4 gallons per year from
a model facility that machine washes 100 percent of the clothes cleaned. It is not known whether
the estimated releases are representative of the universe of wetcleaning processes. As is similar
to perc and hydrocarbon processes, the modeling indicates that wetcleaning releases will vary
between individual facilities.
Exposure
Exposure is defined by EPA as contact between a chemical and the skin, nose, or mouth
of a person over a given period of time. The assessment of exposure is the estimation of the
magnitude, frequency, duration, and route of exposure. The exposure assessment describes who
comes into contact with the chemicals used in the various cleaning processes and, thus, who may
experience the effects related to the chemicals.
17
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18
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Populations exposed to clothes cleaning chemicals include workers, co-located residents,
and the general public. People who have the highest rate of exposure include workers in an
establishment that uses a solvent, such as perc, and children and other people who live in the
same building or adjacent ("co-located") to an establishment that uses a solvent such as perc.
The general population is also thought to come into contact with clothes cleaning chemicals to a
lesser degree. Environmental exposures for the general population are not generally high,
therefore, this document emphasizes human health concerns for workers and co-located
populations.
Health and Environmental Risk
The full CTSA provides a review of the relative human health, environmental, and other
(e.g., flammability) hazards or effects of various fabricare technologies, and provides a basic
description of those potential effects. In short, adverse outcomes can include the ability of a
chemical to cause cancer, developmental and/or neurological effects, respiratory illness, or injury
such as repetitive stress syndrome. Effects can also be environmental in nature, such as the
ability of a chemical to cause harm to aquatic organisms.
The CTSA does not contain estimates of the absolute level of risk for various
technologies. Relative risk assessments for the various cleaning technologies were conducted at a
"screening level" of review, using readily available information and standard analyses for
comparison purposes only. The risk assessments and characterizations present an idea of the
relative risks to human health and the environment, offer a basis for comparison, and give a
rough idea of the potential risks associated with each of the processes. Careful interpretation is
necessary given that the extent and type of hazard, exposure data, and uncertainties associated
with each process differ widely. Also, the absence of information on a technology does not mean
that it has no risks.
Risk Assessments
This summary organizes information on the relative health, environmental, and property
risks of clothes cleaning processes so that they can be compared. Characterizing these risks
involves gathering a variety of information. A risk assessment is an interactive process that
generally includes the following components of analysis:
Hazard assessment and characterization to determine if exposure to a chemical can
cause adverse health effects in humans and the environment.
Dose-response assessment and characterization to define the relationship between
the dose of a chemical and the incidence and severity of adverse health effects in the
exposed population. From the quantitative dose-response relationship, toxicity
comparison values are derived and are used in the risk characterization step to
estimate the likelihood that adverse effects will occur in humans at a variety of
anticipated exposure levels.
19
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Exposure assessment and characterization to identify populations exposed to a
chemical, describe their composition and size, and present the types, magnitudes,
frequencies, and durations of exposure to the chemical.
Risk characterization to integrate hazard, exposure, and dose-response information
into qualitative 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.
Perchloroethylene Solvent
Human data indicate that perc is absorbed into the body via inhalation, from the
gastrointestinal tract following ingestion, and through the skin. There is human evidence that
perc can cause neurotoxicity and kidney effects. Perc has been shown to cause other effects,
including cancer, developmental toxicity, and liver effects in laboratory animals.
The results of a number of monitoring studies indicate that the concentrations of perc in
indoor air can be elevated hi dwellings located in the same building as drycleaners, but are not as
high as concentrations found in drycleaning workplaces (BAAQMD, 1993; NYSDOH, 1993;
Schreiber et al., 1993; Wallace et al., 1995). The excess cancer risk over a lifetime is estimated
to be higher than 1 in 1 million for residents living in co-location with drycleaning
establishments, particularly if they live in such dwellings for more than a few years. Risks
appear to be higher for residents living above transfer machines and poorly maintained dry-to-dry
machines than for the general population. Children, infants, and the elderly who spend most of
their day within the residence are thought to be at a slightly greater risk for both cancer and non-
cancer effects due to increased exposure duration relative to adults in general. The cancer risk
analysis approach used to derive these conclusions is tied to an upper bound lifetime excess
cancer risk estimate, and there is the possibility that the lifetime excess cancer risk is as low as
zero. \
Co-located residents are also at risk through a variety of perc exposures that the general
public experiences, in addition to their exposures related to co-location with drycleaning
facilities. Risks potentially experienced by the general population, such as drinking perc-
contaminated water, would be added to the risks due to co-location.
There is a reasonable basis for concluding that there could be a health risk for cancer and
some non-cancer effects to workers from the relatively high perc 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 dermal exposures in the
workplace and the absorption potential of perc through the skin, combined with evidence from
animal studies. The risk analysis approach used to derive these conclusions 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.
In a recent study conducted by the National Institute for Occupational Safety and Health
(NIOSH), researchers found that operator/cleaners generally have higher exposures relative to
most non-operators (e.g., pressers, spotters). NIOSH observed a general decreasing trend in
exposure levels and permissible exposure limit (PEL) excursions over time. In the study,
operators in facilities with transfer machines tended to have higher exposures than workers in
I
20
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facilities with dry-to-dry machines. Closed-loop machines with integral carbon adsorbers
resulted in significantly lower worker exposures than all other machine configurations currently
available (NIOSH, 1997). The researchers found that as the number of machines increased,
exposure levels also increased.
Although no studies or data are available that quantify dermal exposures to perc for
drycleaning workers, models have been developed to estimate dermal exposure. Results of these
models suggest that dermal exposure is not a significant source of perc exposure for drycleaning
workers. Workers are usually exposed during routine activities that include, but are not limited
to, transferring wet articles from the washer to the dryer and cleaning the bottom trap and still (or
muck cooker) (EPA, 1991b).
Several EPA studies have suggested that the general public's exposure to perc (via
inhalation and ingestion) presents low risks for cancer and non-cancer toxicity. The risk analysis
approach used to derive these conclusions 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.
Risks to aquatic organisms are expected to be low if drycleaning wastewater effluents are
sent to publicly-owned treatment works (POTWs). This is expected to be the case for most
drycleaning establishments. If wastewater effluent is not sent to a POTW, there would be health
risks to aquatic organisms from high perc concentrations in surface waters.
Hydrocarbon Solvents
In the full CTSA, the health risks for hydrocarbon solvents are based upon findings for
Stoddard solvent. There are no data suitable for drawing conclusions concerning carcinogenic
potential. [Since the June 1998 publication of the full CTSA, EPA has attempted to obtain
carcinogenic testing information for newer hydrocarbon solvents, and it appears that no such
testing has been conducted.]
Hydrocarbon solvents are used much less often than perc in commercial drycleaning, and
less information is available for them. According to a NIOSH study, the number of workers
exposed to hydrocarbon solvents in facilities that dryclean clothes is estimated to be between
21,000 and 49,000. The most significant route of exposure for workers is expected to be
inhalation, although they may also be exposed through dermal (skin) absorption (NIOSH, 1980;
OCIS, 1994, 1998).
There is evidence indicating that Stoddard solvent is absorbed into the body via
inhalation, the gastrointestinal tract, and the skin. Some human data indicate that this chemical
can cause neurotoxic effects and is an irritant to the eyes, mucous membranes, and skin. Kidney
toxicity has also been reported in animal studies (ATSDR, 1995).
Weighing this information, there is a reasonable basis for concluding that there is a health
risk for non-cancer toxicity in workers due to the relatively high hydrocarbon solvent exposures
observed in the drycleaning industry. This conclusion is based on monitored workers' inhalation
exposure data from several sources, information about the circumstances for dermal exposures in
the workplace, the potential for Stoddard solvent to be absorbed through the skin, and evidence
that Stoddard solvent can be toxic in laboratory rodents.
21
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Chronic health risks to the general population from estimated inhalation exposures to
hydrocarbon solvents are considered low. Risks from ingesting drinking water contaminated
with hydrocarbon solvents are also considered low, given the very low projected releases of
hydrocarbon solvents to surface waters. These conclusions are based on modeled exposure
scenarios, combined with evidence indicating that Stoddard solvent can cause toxicity in
laboratory animals. However, conclusions about these risks are hampered by the lack of actual
exposure data.
It is possible that co-located residents have ambient air exposures to hydrocarbon
solvents, and therefore would have health risks, although no data are available for this exposure
scenario.
]
As is the case with perc, the data available do not indicate whether health risks due to
hydrocarbon solvent exposures differ significantly between special sub-populations (such as
infants, children, and the elderly) and average adults. Therefore, risks to special sub-populations
due to hydrocarbon solvent exposures should be treated the same as those for other adults.
There is a potential flammability hazard associated with hydrocarbon solvents. The Fire
Protection Guide to Hazardous Materials 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 discussed here are ranked 2, meaning that they have a low flashpoint (that
is, they must be moderately heated before ignition will occur) and that they give off ignitable
vapors. Stoddard solvent is also considered ignitable based upon the standard outlined in EPA
regulations (Protection of Environment, RCRA, Identification and Listing of Hazardous Waste,
Characteristic 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.
Although fire potential is a commonly recognized hazard of hydrocarbon solvents, data
are not available to assess the potential for the hydrocarbon solvents to ignite and cause a fire
(Ahrens, 1998).
!
The potential risk to the environment from hydrocarbon solvents is estimated to be low.
The projected releases of hydrocarbon solvents to surface water are very small. The resulting
concentration of hydrocarbon solvents in surface water is also small and is not expected to
exceed the toxicity concern concentrations for aquatic organisms. Thus, there is a low risk of
toxicity to aquatic species.
Wetcleaning Detergent
Very little toxicity data are available on the chemical constituents of the formulations
(detergent) used in most wetcleaning processes. Workers are expected to be the population most
highly exposed to wetcleaning 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 the
22
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chemicals are in an aqueous solution. Dermal exposures to wetcleaning formulations can be
modeled, and the results suggest that dermal exposures are relatively low for wetcleaning
workers. However, there could be possible risks to workers of eye and skin irritation from wet
process formulations based upon findings associated with the example detergents.
In general, several characteristics of surfactants may affect the likelihood of human health
and environmental effects. 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 persist in the environment.
Selected Federal Regulatory Requirements
Professional clothes cleaners may be subject to numerous Federal requirements, including
the following Federal air, water, waste management, and occupational health and safety
regulations: Clean Air Act (CAA); Clean Water Act (CWA); Safe Drinking Water Act -
Underground Injection Control Regulations (SPWA-UICR); Resource Conservation and
Recovery Act (RCRA); Comprehensive Environmental Response, Compensation and Liability
Act (CERCLA); Occupational Safety and Health Act (OSH); and the Federal Trade
Commission's Care Labeling Rule. Compliance with these requirements will affect operational
costs. Owners and operators of drycleaning facilities are encouraged to consult EPA's Plain
English Guide for PercDrycleaners: A Step by Step Approach to Understanding Federal
Environmental Regulations and Multimedia Inspection Guidance for Drycleaning Facilities for a
more detailed discussion of perc drycleaning regulations.
In addition, cities and municipalities have enacted 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 may affect costs and liabilities.
The chart below lists Federal regulations that may affect clothes cleaning operations
covered in the CTSA for Professional Fabricare Processes. The two most prevalent technologies,
perc cleaning and hydrocarbon (petroleum) cleaning are most affected by Federal regulations.
Wetcleaning currently has fewer requirements that are directly applicable. There currently are
few Federal regulations governing the use of the emerging cleaning technologies (e.g., liquid
CO2 and ultrasonic cleaning). It is unclear how requirements may change as industry use of
these technologies changes.
23
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Figure 8: Summary of Regulations Related to Fabricare Technologies"
Fabricare Option
Perc Cleaning
Hydrocarbon Cleaning
Wetcleaning
CAA
/
^
NA
CWA
/
^
/
RCRA
/
/
NA
CERCLA
/
/
NA
OSH
^
/
NA
Care Labeling
Rule
^
/
/
Other
NFPA-32
NFPA-32
NA
/ Indicates that a technology is regulated specifically by the statute.
NA Indicates that although the statute applies to the technology, there are no specific regulatory requirements.
The list of regulations covered in this booklet should not be considered exhaustive and may not cover all regulated aspects of
the fabricare industry.
i
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 of the
CAA established new source performance standards and best achievable technology standards
for sources of specific volatile organic chemical compounds (i.e., 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.
The Clean Water Act (CWA) is the Federal law designed to protect trie chemical,
physical, and biological quality of surface waters in the United States. The original statute and
subsequent amendments evolved from the Federal Water Pollution Control Act of 1972 (PL 92-
500). The CWA regulates both waste water 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 bacteria, fats/oils/greases, and pH; and
Non-conventional Pollutants - any pollutant not identified as priority or conventional.
1
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 EPA 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.
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
24
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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.
The Comprehensive Environmental Response, Compensation and Liability Act
(CERCLA), known more commonly as Superfimd, is the Federal statute that established a
variety of mechanisms to clean up sites contaminated with improperly discarded chemical
wastes. This 1980 statute authorizes EPA to respond to releases, or threatened releases, of
hazardous substances that may endanger public health, welfare, or the environment. CERCLA
also enables EPA to force responsible parties to clean up environmental contamination or
reimburse EPA's Superfimd for emergency response costs. The Superfimd Amendments and
Reauthorization Act (SARA) of 1986 revised various sections of CERCLA, extending the taxing
authority for the Superfimd and creating an additional free-standing Federal law (SARA Title III
- Emergency Planning and Community Right to Know 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 Act (OSH) enabled OSHA
to promulgate existing Federal and national consensus standards as OSHA standards. Under the
authority of this provision, the Health Standards program of OSHA established exposure limits
for general industry air contaminants (29 CFR 1910.1000 Subpart Z).
The Care Labeling Rule (16 CFR 423) was promulgated by the Federal Trade
Commission 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 upon either the historical success with a particular cleaning
technology or actual test results that take into consideration fiber, fabric, and garment
construction variables.
Costs
Assumptions
The costs of running a professional clothes cleaning business include rent, basic operating
expenses, equipment, and labor. The equipment capacity, equipment type, and location of the
facility will affect the costs and economic viability of a professional cleaning operation. While
some fabricare 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).
25
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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. Figure 9 presents
operating factors that are associated with fabricate operations, many of which are outside the
scope of this document.
j
Figure 9. Potential Operating Factors Associated with Fabricare 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: EPA, 1997
i
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 EPA, state and local governments, and industry). If prices were 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. Figure 10 lists cost and revenue elements associated with fabricare facilities.
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. 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 Product. All other cost estimates are adjusted to 1997 dollars using the Producer Price
Index for Capital Equipment (BLS, 1997).
26
-------
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27
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The cost estimates for the hydrocarbon 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 solvent machines are assumed to operate at 80 percent 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 percent capacity, resulting in a daily throughput of six loads per day.
Cost Factors
Capital Equipment
Capital costs for equipment and the costs of retrofitting machines with control
technologies are converted to annual cost equivalents using a 7 percent real cost of capital and a
15-year lifespan (equivalent to using a capital recovery factor of 0.1098), to be consistent with
previous clothes cleaning analyses (EPA, 1993).
Maintenance
The International Fabricare Institute (IFI) estimates annual equipment maintenance costs
for perc-based operations to be 2.27 percent to 3.26 percent of total annual revenue, based on an
annual sales volume of $100,000 to $300,000 (IFI, 1992). For the purpose of the CTSA, perc
and hydrocarbon annual equipment maintenance costs are calculated as 3 percent of total annual
revenues.
Energy
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.
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.
installation
In this summary, 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 perc and
'the tola! throughput of the model plant is 66,666 pounds, of which 80% is dry cleaning or another process and 20% is washing (Faig, 1998). It is assumed that the revenue per
pound a centum at S3. generating > revenue per facility of $200,000,
I
28
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hydrocarbon solvents in the commercial sector (1.92 billion pounds) by the number of firms
using perc and hydrocarbon solvents in the commercial sector (36,000) (Wolf, 1998; Wong,
1998). Facilities are assumed to operate 312 days annually [6 days per week and 52 weeks per
year (Shaffer, 1995)] and to have an average daily throughput of approximately 171 pounds of
clothing.
The cost estimates for perc 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 (EPA, 1991c). The price of retrofitting machines with
emission control equipment is estimated for the same cleaning capacity. It is assumed that the
perc machines operate at 90 percent capacity (EPA, 1993) and that six loads per day are needed
to process the throughput.
Solvent and Other Material
Solvent costs may vary based on per-gallon and bulk prices. Perc solvent costs range
from $5.50/gallon to $8.01/gallon, based on estimates provided by manufacturers and
distributors. A median perc solvent price of $6.83/gallon is used for the purposes of this
analysis.
Hydrocarbon 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 hydrocarbon solvent costs, although it should be recognized that costs will vary
depending upon which hydrocarbon solvent is used.
Water for wetcleaning costs $2.73/100 cubic feet in 1993 dollars or $3.06/100 cubic feet
in 1997 dollars (BLS, 1997; EPA, 1993). This price includes the average cost of water and
sewerage fees.
Filters/Cleaning Supplies
Perc filters are estimated to cost $606 annually, and detergents and spotting chemicals for
perc machine configurations are calculated to cost $1,307 annually, for a total of $1,913 (BLS,
1997; EPA, 1993). For the hydrocarbon 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, 1994a). Annual costs for 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).
Hazardous Waste Disposal
Because perc is a hazardous waste, this document compares the costs of hazardous waste
disposal. For the purposes of this analysis, all hazardous waste cost estimates include only the
cost of disposal and do not include the cost of associated paperwork and other regulatory
29
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compliance activities noted in Figure 10. The cost of disposing of potentially hazardous spotting
chemicals is not included in this analysis. Hazardous waste disposal costs for perc- and
hydrocarbon-based equipment are calculated using a cost of $6.94 per gallon and engineering
estimates of volume.
Regulatory Compliance
Compliance with government regulations imposes industry-specific costs upon the
private sector. Figure 9 lists many of the regulatory compliance cost categories pertinent to the
fabricare industry, including expenditures for waste management. The range of equipment age
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. The use of spotting agents is not
factored into the regulatory cost estimates.
Labor
i[
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 or her 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 associates with fabricare operations are not included.
Performance
;i
Several performance demonstrations and laboratory studies have been performed to
assess wetcleaning technologies in both the U.S. and Canada. They have provided useful
information comparing wetcleaning to more traditional drycleaning technologies. These studies
also contain information on consumer perceptions of the cleaning process, as well as information
on the costs to run the performance demonstration sites. The reader should note that this
document is not intended to derive conclusions about the suitability for individual drycleaners of
the alternatives that have undergone the performance testing. When evaluating cleaning
performance, it is also important to note that variations in technology and the knowledge base of
operators will cause a range of results (Blackler et al., 1995). Also, not all of the criteria used in
this assessment are universally applied or accepted by the public and private sectors. Indeed,
other performance considerations may become apparent as clothes cleaning studies expand to
include additional emerging technologies.
30
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Establishing the Protocols for Performance Testing
The following organizations have established protocols used in conducting performance
testing and measuring:
International Fabricare Institute - Established drycleaning control standards.
The American Association of Textile Chemists and Colorists (AATCC) -
Developed historical criteria for "troubleshooting" drycleaning problems and test
methods for standard soil and fabric combinations (Patton, 1994).
The American Society of Testing and Materials (ASTM) and AATCC -
Developed performance specification and test methods, respectively, for
acceptable dimensional change (shrinkage and stretching) after laundering and
drycleaning. In general, the maximum allowable shrinkage is 2 percent after three
drycleanings and 3 percent after five launderings (CNT, 1996). Scientists at both
the ASTM and the AATCC have developed performance criteria regarding
colorfastness, soil removal, odor, fiber damage, shrinkage, and hand (fabric
texture). These standards are linked to care labeling guidelines and will inevitably
affect specifications for soap and detergents, as well as clothes cleaning
equipment (ASTM, 1998).
The European Wetcleaning Committee (EWCC) - 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).
Physical and Chemical Characteristics of Clothes Cleaning
Several industry sources have recommended that all professional clothes cleaning
technology should strive to achieve the following goals, which are based on a variety of fabricare
characteristics (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:
soil chemistry,
textile fiber type,
transport medium (aqueous vs. non-aqueous),
31
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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 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,
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 yams, 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). '
i
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).
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.
32
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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).
Summary of Performance
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 cleaning process for a significant
fraction of consumer garments. There continues to be debate as to the actual percentage of
clothing types traditionally drycleaned that can be safely and effectively wetcleaned.
Researchers note that the debate should focus not necessarily on what percentage of clothing, but
on which types of clothing and fabrics can be successfully wetcleaned (Adamson, 1996; Riggs,
1998).
Given the limited number of performance studies available for comparing clothes
cleaning processes, 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. Greater use of these cutting-edge
technologies in the fabricare industry will produce advancements in equipment design and
operator skills, resulting in increased cleaning performance.
Process Trade-Offs
In order to implement pollution prevention and possibly reduce exposures and/or risks
associated with the chemicals used in clothes cleaning, clothes cleaners may consider either
controlling emissions from their current technology and/or adding a different technology.
Cleaners must consider the costs of running an operation, the service that they can provide to
consumers, and at what cost. Choices made may be limited by regulatory requirements and
levels of necessary capital investment. Such decisions involve numerous trade-offs among
relative costs, performance, health and environmental risks related to a particular process, and
other factors unique to each drycleaning shop. These trade-offs are summarized in Figure 11.
Environmental Improvement Approaches
There are certain techniques that may be employed by fabricare operations to prevent
pollution, reduce chemical consumption, and minimize waste, particularly for perc and
hydrocarbon technologies.
33
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Perc and Hydrocarbon Drycleaners
On September 22, 1993, EPA finalized the NESHAP for perc drycleaners (58 FR 49354)
This regulation set standards for the reduction of perc 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 proper operation and
maintenance. Owners or operators are required to keep a copy of any manufacturers'
specifications or operating and maintenance recommendations at the drycleaning facility.
EPA realized 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, EPA's Office of Air
Quality Planning and Standards has developed many recommendations for operating and
maintenance practices for owners and operators of perc drycleaning machines and emission
control devices. Many of these recommendations are summarized in Figure 12.
For more comprehensive details on this very important subject, please refer to Chapter 9
of the Cleaner Technologies Substitutes Assessment (CTSA)for Professional Fabricare
Processes.
Wetcleaning Processes
Information on pollution prevention opportunities, best management practices, and
control options for these emerging technologies 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.
i
Good housekeeping practices, such as keeping detergent storage containers tightly
closed to reduce chance of spillage.
i
Recycling/recovery of rinse water/steam condensate.
34
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Figure 11: An Overview of Trade-Off Factors for Alternative Cleaning
Technologies3
Characteristic
Health and
Environmental
Risks
Costs"
Potential
Liability Costs
Capital Costs0
Hazardous
Waste Disposald
Annual
Operating
Costs6
Total Annual
Costs'
Perchloroethylene
Health: Risk of cancer to workers,
co-located residents. Risks of non-
cancer effects, including potential
for developmental and reproductive
effects for workers. Possible
cancer and non-cancer risks to co-
located children.
Environmental: Potential risk to
aquatic organisms for effluent not
treated by POTW.
Hydrocarbon
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.
Wetcleaninq
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.
Groundwater contamination and
worker illness.
$38,511
$4,594
$14,077
$ 18,305
Fire damage.
$37,432
$9,820
$19,607
$23,717
Damaged clothing labeled
"Dryclean Only."
$11,102
NA
$5,089
$6,308
Market Considerations
State of
Technology
Dominant in market.
Well-established in market; use
of some hydrocarbons may be
limited by local fire codes.
Commercial use since
1994 in U.S.; numerous
detergent suppliers.
Consumer Issues
Odor
Cleaning
Performance
Yes
Wide range of clothes.
Yes; may be less for particular
hydrocarbons
Wide range of clothes.
No
Wide range of clothes.
NA means that the cost category is not applicable for the technology or that data are not available at this time.
Configurations for fabricare technology include perc dry-to-dry closed-loop with no carbon adsorber or with door fan and small carbon
adsorber (Perc-C), as required by the perc NESHAP regulation; hydrocarbon transfer with recovery dryer and condenser (Hydrocarbon-
A2); and Unimac UW30 washer and DTB50 dryer.
" The values include the price of equipment and services directly related to the various fabricare cleaning processes, but exclude costs
for pressing, storefront operations, and rent. All values are in 1997 dollars and all calculations assume a 53 333-pound (24 191-kq)
annual volume of clothes cleaned per facility.
List price of 35-pound perc drycleaning system includes control equipment, distillation unit, and filters; list price of 35- to 40-pound
hydrocarbon drycleaning system includes control equipment, filters, and an explosion kit.
Hazardous waste disposal costs for perc and hydrocarbon based on $6.94-per-gallon disposal cost (Beedle, 1998) and volume
calculations from EPA engineering estimates, hydrocarbon solvent waste may not be considered hazardous waste under the Resource
Conservation and Recovery Act, therefore, this is a high-end estimate. Hazardous waste costs associated with spotting chemicals or
certain detergent components are not included.
e 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.
' Includes all operating costs and annual capital costs.
35
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Figure 12: 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
Cofls
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, and
check ductwork for lint build-up.
Dryclean or launder lint bag.
Auxiliary Equipment
Filters
Distillation Unit
Muck Cooker
Water Separator
Pumps
Tanks
a
Bi-weekly
Monthly
Semi-
annually
Monthly
Semi-
annually
Annually
Weekly
Monthly
a
a
Clean and change filters (filters drained and muck stored in
sealed containers).
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 perc in exhaust air stream or in
machine drum, clean all lint filters, and check gaskets and
ductwork.
Source: EPA, 1994.* Maintain according to manufacturer's or media supplier's specifications or recommendations.
36
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Conclusion
Fabricare Industry Trends
Although the use of perc-based technologies continues to dominate the U.S. professional
fabricate industry, the industry is undergoing significant change. Until as recently as 5 years ago,
there were few to no hydrocarbon dry-to-dry machines or wetcleaning machines in use. Today,
the major U.S. hydrocarbon equipment manufacturer is producing 60 percent hydrocarbon
clothes cleaning machines and more than 30 commercial fabricare facilities are performing
wetcleaning only.
The development of new and emerging solvents and cleaning processes was motivated by
stricter state and federal regulation of perc, as well as by increasing evidence of perc's negative
impact on human health and the environment. For example, many drycleaners are faced with the
financial liability stemming from the cleanup of perc-contaminated soil and ground water
surrounding their facilities. These concerns have made many property owners reluctant to renew
leases or to rent to drycleaners (Lummis, 1996). Also, many states have imposed taxes on perc,
resulting in as much as a twofold increase in perc prices.
The extensive adoption of wetcleaning and hydrocarbon solvents in Germany, in response
to strict perc regulation, may perhaps indicate the level of adoption likely to occur in the U.S.
However, direct comparisons among countries must be gauged within the context of differences
in garment type, fabric type, lifestyle, geography, and climate. Further, differing perceptions of
cleaning quality among countries will affect customer acceptance of new and emerging cleaning
technologies.
Increasingly, fabricare professionals are proving that many garments that were traditionally
drycleaned can now be wetcleaned effectively. Most professional cleaners possess a wetcleaning
washer and dryer and wetclean a larger fraction of the clothing stream than 5 years ago (Seitz,
1995). A major challenge facing the professional fabricare industry is the continuing decline in
the total volume of clothing being drycleaned. Several reasons have been cited for this decrease,
including the increase in casual wear among office workers (Levine, 1997). The fabricare
industry is addressing this phenomenon by attempting to broaden the services offered to
customers. For example, some facilities emphasize pressing and finishing services rather than
cleaning services.
The professional fabricare industry is also collaborating with clothing designers and
apparel manufacturers in an effort to make fabricare considerations an integral part of textile and
garment manufacturing decisions. By encouraging the use of fiber types, textile types, and
garment construction methods that are compatible with all professional clothes cleaning
techniques, the fabricare industry hopes to maintain and increase its economic viability.
Through the Agency's Design for the Environment (DfE) Program and its Garment and
Textile Care Program (GTCP), EPA plans to continue partnering with the fabricare industry,
textile manufacturers, and garment designers. EPA hopes that the efforts of the GTCP
partnership will encourage improvement and expansion of new fabricare choices and remove
barriers that prevent the adoption of economically viable cleaning processes that also offer
environmental benefits.
37
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42
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50272-101
REPORT DOCUMENTATION
PAGE
1. REPORT NO.
EPA 744-S-98-001
3. Recipient's Accession No.
Not Applicable
4. Title and Subtitle
Cleaner Technologies Substitutes Assessment for Professional Fabricare Processes: SUMMARY
5. Report Date June 1998
6.
7. Author(s) The following people were major contributors to the study upon which this document is
based, to the full fabricare CTSA, and to this this summary document itself: 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 Rept. No. EPA
744-S-98-001
9. Performing Organization Name and Address
U.S. Environmental Protection Agency
Office of Pollution Prevention and Toxics (7406)
401 M Street, S.W.
Washington, D.C. 20460
10. Project/TaskAVork Unit No.
Task No. 2-01-01
11. Contract(C) or Grant(G) No.
(C) 68-W7-0025
12. Sponsoring Organization Name and Address
U.S. Environmental Protection Agency
Office of Pollution Prevention and Toxics (7406)
401 M Street, S.W.
Washington, D.C. 20460
13. Type of Report & Period Covered
Final Report
14.
15. Supplementary Notes
Management and general support were provided by EPA staff, including: 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 was conducted by Abt Associates under the direction of Alice Tome. The
independent technical peer review of the full fabricare CTSA, upon which this summary document is based, was conducted by Battelle Columbus
Laboratories under the direction of Bruce Buxton. Technical editing and general support were also provided by Westat under the direction of Karen Delia
Torre.
16. Abstract (Limit 200 words)
Recognizing that not all professional cleaners have the time to read the full fabricare CTSA, EPA prepared this summary document which was
abstracted directly from that June 1998 publication (EPA 744-B-98-001). In this summary report, the reader is first introduced to the clothes cleaning
industry and provided an overview of professional fabricare technologies. New and emerging technologies are also covered including liquid carbon
dioxide (CO2), ultrasonics, and solvents based on chemicals such as glycol ethers, although there is much less information available on these systems.
Summary information is presented on release, exposure, health and environmental relative risk, selected federal regulations, costs, performance, process
trade-offs, environmental improvement approaches, and industry trends. A complete list of references is included.
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.
17. Document Analysis
a. Descriptors: Drycleaning, wetcleaning, clothes cleaning, perchloroethylene, PCE, perc, chlorinated solvents, hydrocarbon solvents, garment care,
petroleum solvents, alternative solvents, alternative technologies, fabricare processes, fabricare technologies, dry cleaning, wet cleaning, propylene
glycol ether, liquid carbon dioxide, DF 2000, ultrasonic cleaning, wetcleaning cost, drycleaning cost, Stoddard solvent, Rynex, drycleaning performance,
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 44
22. Price
(SeeANSI-239.18)
OPTIONAL FORM 272 (4-77)
(Formerly NTIS-35)
Department of Commerce
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