United States
Environmental Protection
Agency
Office' of Pollution Prevention
and Toxics
Washington, DC 20460
EPA/774/R-92/002
November 1992
>EPA
Proceedings
International Roundtable on
Pollution Prevention and
Control in the Drycleaning
Industry
May 27-28, 1992
Falls Church, VA
Recycled/Recyclable
Printed on paper that contains
at least 50% recycled fiber
-------
-------
Proceedings of an
i .
EPA Design for the Environment
International Roundtable
i ,
ii
i :
Pollution Prevention and Control
in the Drycleaning Industry
May 27-28, 1992
Marriott Fairview Park
Falls Church, VA
Economics,
Office of PoUution
U.S. Environmental
Exposure, and Technology Division
Prevention and Toidcs
Protection Agency
Washington, DC
-------
1
Prepared by Eastern Research Group, Inc. for the Office of Pollution Prevention and Toxics,
U.S. Environmental Protection Agency. Points of view expressed in this proceedings document
do not necessarily reflect the view or policies of the U.S. Environmental Protection Agency or
any of the contributors to this publication. Mention of trade names and commercial products
does not constitute endorsement of their use.
Conference Planning Committee
Jean E. (Libby) Parker and Ohad Jehassi
Regulatory Impacts Branch
Economics, Exposure, and Technology Division (TS-779)
Office of Pollution Prevention and Tones
U.S. Environmental Protection Agency
401 M Street, SW.
Washington, DC 20460
(202) 260-0676
Jeff Cantin and Kate Schalk
Eastern Research Group, Inc.
110 HartweU. Avenue
Lexington, MA 02173-3198
(617)674-7200
Editor: JohnBergin
Typesetting: CarlBonvini
Cover Art David Cheda
Copies of this proceedings document may be ordered from:
National Technical Information Service
5285 Port Royal Road
Springfield, VA 22161
(703) 487-4650
-------
Contents
Foreword
Opening Remarks
MaryEHen Weber, Ph.D.
EXPOSURE REDUCTION
Overview of Exposure Pathways ."'. ..... ....... ........ ... ............... 5
JeffCantin , -• ,
German Drycleaning Regulations and Technology ....... ..... \ ........... .... 12
Josef Kurz. Ph.D.
Evaluation of "New Generation' Drycleaning Equipment ....... ........... 16
Walther den Otter i
Fabric-Solvent Interactions ....',! ................... ..... ............ .20
Hans-DIeMch Welgmann, Ph.D. , .......
Operating Drycleaning Equipmentto Minimize Exposures ..... . . . ! ........ ......... 23
JackD.Lauber
. ij. . . • , . .
Roundtable Discussion Summary . i.| . . . . ...... ....".. . .......... ..... ..... 31
i!
,|l . ;
RESIDUAL REDUCTION j ,
1 1 ; .
U.S. EPA Research on Drycleaning Residual Reduction ......... ............... . . 35
Bruce A. Tichenor, Ph.D. '
Industry Research on Drycleaning Residual Reduction ......... . . ...... / ...... 33
Thomas A. Robinson, Ph.D. | '
Drycleaning in Japan: Current Conditions and Regulations ...... ..... ...... ...... 40
JunjIKubota I ;
Roundtable Discussion Summary . . .................... ;, ................ 44
ii ' ' ......... '
FOOD AND RESIDENT EXPOSURE REDUCTION
Perchloroethylene Levels in Foods Obtained near Drycleaning Establishments . ............ 49
Gregory Diachenko, Ph.D. | .
Investigations of Indoor Air Contamination in Residences above Drycleaning Establishments .... 53
Judy S. Schreiber, Ph.D. . ,!
Roundtable Discussion Summary . .' ............. ....... . , . . ............. 58
HI
-------
GROUND-WATER CONTAMINATION
Investigations of Ground-Water Contamination
by Perchloroethylene in California's Central Valley ..,..- 63
Wendy L Cohen
Perchloroethylene Ground-Water Contamination in California:
The Drycleaning Industry's Perspective . 67
Barry LBunte
Roundtable Discussion Summary 70
f
CAPITAL FORMATION
Capital Availability and Profitability Impacts of Drycleaning Regulation .75
Brenda L JelKcorse
Cost Impacts on the Drycleaning Industry of Exposure Reduction Alternatives 79
L Ross Beard
Rnancing Options for the Drycleaning Industry 83
Thomas Gause
Roundtable Discussion Summary 85
REGULATORY ACTIVITIES m THE UNITED STATES
Proposed National Standards for Perchloroethylene Emissions from Drycleaning Facilities ...... 89
Georg&F. Smith
Response of the Drycleaning Industry to Recent Regulatory Activities 91
BMFteher , .
Air Regulations in California 94
Cynthia Marvin
Drycleaning ReguIatoryActivity in the Northeast 97
Margaret M. Round
Roundtable Discussion Summary 99
INFORMATION DISSEMINATION
Communicating about Environmental Risks Related to the Drycleaning Industry. . . . 103
Co/on Chess
The Drycleaning Industry's Perspective on Risk Communication 106
William Settz
Communication of Risk Associated with Drycleaning Operations in New York State 108
JudyS.Scttre}ber.Ph.D.
Roundtable Discussion Summary
IV
-------
ROUNDTABLE WRAP-UP
Roundtable Discussion Summary.
APPENDIX A. Attendees List
i
!
Panelists
Observers
115
121
123
APPENDIX B. Supplemental Material
Submissions from Judy Schreiber, New York State Department of Health 127
Submission from Elizabeth Bourque. Massachusetts Department of Public Health 161
Submission fromWalther den Otter, TNO Cleaning Techniques Research instil ute 169
Submissions from Joseph Kurz. Institute Hohenstein '. . 173
i •
Submissions from Cynthia Marvin, Cajifomia Air Resources Board . . . . '. 279
Select Bibliography of Materials Relating to Drycleaning . . 297
-------
-------
Foreword
e International Roundtable on Pollution Prevention arid Control in the Drycleaning
Industry was held on May 27-28, 1992, in Falls Church, Virginia. The roundtable
was sponsored by the U.S. Environmental Protection j^gency and was attended by
representatives of industry trade associations, various U.S. and international government
agencies, state agencies, and numerous research and academic: institutions. Approximately
70 individuals took part. !
^ !] ' . t
The roundtable focused 04 identifying exposures to pereftloroethylene, the primary
chemical solvent used in the ditycleaning process, and on ways to reduce or minimize such
exposures.* The idea for the roundtable grew out of the Design for the Environment (DfE)
Program, run by the EPA Office of Pollution Prevention and Toxics (OPPT), the sponsors of
the roundtable. DfE refers to efforts made by EPA to assist industry in designing products
and processes (including chemicals) so as to minimize their adverse human and environ-
mental impacts throughout the product lifecycle and across all environmental media (air,
water, solid waste). Thus, roundtable participants addressed exposures due to releases in
the drycleaning shop; to the ambient air and to water; and that: afifect workers, residents of
nearby apartments and businesses, consumers of drycleaning services, and users of
threatened ground-water supplies.
OPPTs objective for the roundtable was to assemble the most knowledgeable experts on
pollution issues in the drycleaning industry, to compare notes with them, and to attempt to
identify options for reducing chemical exposures. To that end, OPFT invited participants to
submit whatever technical information they had available so that it could be considered in
future EPA activities involving the drycleaning industry. Additio:oal materials or information
are welcome and should be forwarded to: Ohad Jehassi, Economics, Exposure, and Tech-
nology Division (TS-779), Office of Pollution Prevention and Toxics, U.S. Environmental
Protection Agency, 401 M Street, SW., Washington, DC 20460.
-nraughouttiese proceedings, authors refer to the chemical perchtoroethylene (CAS No. 127-18-4) by several alternate names or acronyms,
including perc, PCS, tetrachloroethylene. and tetrachloroethene. The terms are chemically equivalent and are used interchangeably.
VII
-------
These proceedings contain transcribed presentations and copies of the papers presented
during the roundtable. The roundtable format was adopted to encourage discussion and to
maximize interaction between participants. The program was divided into ten panels spread
over the two-day period. Each panel featured 3 to 5 speakers and an open discussion session
lasting 45 to 60 minutes. The proceedings reflect this format. The papers or transcribed
presentations for each panel appear together, followed by a written summary of the
discussion session.
A list of participants and their affiliations is included in Appendix A. Supplemental
materials provided by participants following the roundtable are included in Appendix B.
viii
-------
Opening Remarks
Mary Ellen Weber, Ph.D. j
Office of Pollution Prevention and Toxics* •
U.S. Environmental Protection Agency i
As director of the Economics, Exposure; and Technology Division in the
EPA's Office of Pollution Prevention and Toxics, Dr. Weber is responsible for
all engineering, exposure, industrial chemistry, and economic analyses car-
ried out by the EPA on toxic substances. Before joining the EPA, she taught
economics at Smith College and held a position as an economist at the World
Bank. She holds a doctorate in economics from the University of Utah.
ne of the most promising new activities at
' EPA Is the Design for the Environment (DfE)
Program. It embodies the concept of design-
Ing environmental considerations into products, proc-
esses, and even the basic building blocks— Chemicals—so
that the creation of pollution can be prevented instead
of requiring treatment. The program has! a number of
components including the Small Business Initiative,
under whose aegis this International Round-table on
Pollution Prevention and Control in this Drycleaning
Industry is being sponsored. Knowing albout the over-
all program provides a broader contact for EPA's
efforts to help the drydeaning industry,,
EPA believes that pollution prevention opportuni-
ties should be explored throughout the' lifecycle of a
product and therefore our DfE Program begins with
the design of the basic chemical. EPA 'has solicited
proposals on alternative approaches to synthetic
chemical pathway design from all the Ph.D.-granting
chemistry departments in the United Sitates and ex-
pects to award six research grants. EPA hopes that
this project will not only yield more environmentally
benign chemicals but raise awareness of environ-
mental considerations at the molecular level to de-
signing chemicals and microorganisms;,
Subsequent steps in the program's chronology
address the selection of chemicals, pirocesses, and
products and their ultimate packaging, juse, and dis-
posal. EPA had established a center at ttie University
of Michigan to foster the incorporation of pollution
prevention goals and a design-for-environment men-
tality in the curricula of graduate and undergraduate
courses in chemical engineering, business, and natu-
ral resources. It is our goal that as each new genera-
tion of graduates enters the workplace it will bring
along a design-for-environment approach to perform-
ing jobs. A number of other universities are working
with the center at the University of Michigan to Incor-
porate the DfE tenets into their activities.
Another component of the Design for the Environ-
ment Program is under development. That Is a pro-
gram for the large, well-financed, and technologically
sophisticated members of the U.S. economy to which
major value-added input will include information on
relative risk of alternative chemicals and technologies
and a protocol for conducting internal DfE inventories
to search for pollution prevention opportunities.
A DfE Program component that EPA Is particu-
larly excited about, however, is the Small Business
Initiative, which includes the Drydeaning Round-
table. There are several common elements to all EPA
small business initiatives. First, the DfE small busi-
ness initiatives include a •commitment to apprise the
industry of EPA's current and planned actions affect-
ing the industry. EPA believes that functioning as an
informal clearinghouse for regulatory and nonregula-
tory activity related! to a particular industry is a
valuable service that, can be provided to the drydean-
ing and the other Industries with whom the EPA Is
working dosely on EifE activities.
Second, the EPA Office of Pollution Prevention
and Toxics can provide industry with comparative risk
information on potential substitutes. In addition, it
can help develop protocols for businesses to inde-
pendently conduct their own design-for-environment
opportunity audits, i
Third, the DfE Program can act as a facilitator in
the creation and sharing of information through work-
shops, roundtables, and conferences.
Shortly the Design for the Environment Program
will be hosting the first in a series of meetings to
-------
MaiyElen Weber
address DIE opportunities in the printing industry.
EPAls further along In this Industry than In dryclean-
Ing because It has already Identified numerous po-
tential substitute chemicals and processes, and now
the printing group will be working on ways to test and
evaluate the most promising alternatives. Another key
element of that project will be the dissemination of
information to the many small printers In the Indus-
try. EPA expects to do this by creating a manual and
videotapes of alternative chemicals and technologies
in action, and by holding a televideo conference that
has the potential of economically reaching printers
throughout the country.
This drydeaning roundtable Is an exploratory
first step and it arises out of a long-standing interest
at EPA and In the drydeaning Industry In potential
occupational, consumer, and environmental expo-
sure to perchloroethylene (perc), and the search for
alternative chemicals, practices, and technologies.
Simply exchanging information could create some
exciting new ways to look at reducing exposure to
perc. For example, sharing engineering and economic
feasibility analyses is useful in jointly pursuing pollu-
tion prevention opportunities.
EPA has been looking at perc since 1986 when It
began the Interagency investigation of methylene
chloride—and several of its substitutes, including
perc—and identified the drydeaning industry as a
major user. Since then, industry and interagency
work groups have each investigated various aspects
of perc exposure. Drydeaning industry associations
have been attempting to publicize environmentally
sound chemical management and disposal practices
among members.
The purpose of this roundtable is to encourage
cooperation between the members of the diydeaning
industry and government. This roundtable offers both
EPA and the industry an opportunity to look at old
information in new ways, to think in new ways, and
to act in new ways. Your willingness to gather together
here today to begin to look at ways to cooperativdy
examine the various Issues surrounding the use of
perchloroethylene in the drydeaning industry is ap-
preciated. Thank you for joining us In this endeavor.
-------
-------
EXPOSURE REDUCTION
-------
Overview of Exposure Pathways
JeffCantin
Eastern Research Group, Inc. ;
Mr. Cantln is a senior economist with Eastern Research Group, an environ-
mental and economic consulting firm in Lexington, Massachusetts. ERG spe-
cializes in assisting federal regulatory agenciejs such as the Environmental
Protection Agency, the Occupational Safety arid Health Administration, and
the Department of Transportation in evaluating the economic impacts of their
regulatory proposals. ;
This presentation profiles the U.S. diryclean-
Ing industry, examines the industry's cur-
rent level of pollution prevention, identifies
human chemical exposure pathways, and estimates
the potential magnitude of such exposures, j
Demographics of the Drycleo ning
Industry
In the United States, the drycleaning industry is
composed of three different sectors. These are:
Commercial sector—consists primarily of neigh-
borhood-based shops that accept garments such
as suits, blouses, and dresses directly from the
. consumer for cleaning and treating. Many;of these
are family owned and operated, with a significant
percentage, perhaps 25 percent nationally, oper-
ated by owners of Korean descent Most shops
have one or more drycleaning machines onsite,
although sites that serve as drop-off locations
only are also common. Machines at these shops
are typically in the 30 to 60 ft) (13.5 to 27 kg)
capacity range, with facilities typically processing
75,000 to 100,000 Ib (33,750 to 45,000 kg) of
clothing each year. !
i
Industrial sector—consists of large facilities oper-
ating multiple high-capacity machines and proc-
essing high volumes of cleaning. Much of the
industrial sector concentrates on cleaning uni-
forms, rugs and mats, rags, and linens, which are
supplied on a rental basis to business, industrial,
or institutional customers. |
:
Coin-op sector—<»nsists of small capacity (8 to 12
Ib, or 3.6 to 5.4 leg) coin-operated machines (coin-
op), usually found in conjunction with coin-op
laundromat facilities. These machines allow the
consumers to have clothing drycleaned while they
wait, hi some cases the consumer operates the
machine directly, while in others an attendant is
charged with machine: loading and unloading.
Solvent Usage \
An estimated 82 percent olfall commercial drycleaning
shops use perchloroethylene (perc) as their primary
cleaning solvent. The reniainder use petroleum sol-
vents (15 percent), CFC-113 (3 percent), and 1,1,1
trichloroethane (less than 1 percent) (EPA, 199Ib). hi
the industrial sector, perc use has become less and
less common as new detergent-based formulations
have been adopted. Virtually all coin-op machines use
perc. ;
Definitive data on perc consumption in dryclean-
ing is not readily available. So-called bottom-up cal-
culations use information on the number and type of
machines in use, their capacity and throughput
(pounds of clothes cleaned annually), and estimates
of perc consumption per unit of throughput.1 Calcu-
lated in this manner, perc consumption in 1987 has
been estimated at 131,796 metric tons (SRRP 1990).
In the alternative, using, a top-down approach the
share of total domestic perc consumption used in
drycleaning is estimated at 132,000 tons. Thus, the
two approaches yield similar results. Recent calcula-
tions for 1991 estimate fresh perc consumption in
drycleaning at 124,000 tons (EPA, 199Ib).
In addition to fresh isolvent, the drycleaning in-
dustry consumes an estimated 6,100 tons of recycled
perchloroethylene (EPA. 199Ib). This quantity has
1 Perc consumption is estimated at 12 Ib (S.4 kg) per 100 Ib (45 Kg) of clothes
cleaned in the commercial, industrial, and coin-op sectors (SRRP, 1990).
-------
JeffCantin
been estimated by Safety Kleen, a major provider of
hazardous waste services to the drydeaning industry.
Table 1 shows the consumption of fresh and recycled
perc for the commercial, industrial, and coin-op sec-
tors In 1991.
Table 1. Consumption of perchloroethytene in the drycleaning
Industry, 1991 (metric tons).
Sector
Commercial
ImJuilitAl
Coin-Op
TOTAL
Consumption
Fresh
115,900
5.700
1.400
124.000
Consumption
Recycled
5,800
300
—
6,100
Total
122,700
6.000
1,400
130.100
Score*: EPA. 19916.
Machine Populations
Estimates of drycleaning machine populations in the
three sectors were recently developed as part of the
EPA's efforts under the 1990 Clean Air Act Amend-
ments to regulate the air emissions of perc from
drycleaning facilities. Table 2 indicates that in 1991
there were approximately 31,000 perc machines op-
erated by the commercial sector, 130 perc machines
operated by the industrial sector, and 3,000 perc
machines used. In the coin-op sector.
Table 2. Drycteaning machine populations, 1987-1991.
1939
1991
CnmnvTchl
31.575
31.433
31.434
1 ...Maaul
'* 162
145
.130
Coin-Op
4,013
3.493
3.044
35.750
35.071
Sourw:R*fan,1991a.
Growth in the commercial drycleaning sector is
currently flat or declining, with a slight decrease in
machine populations detected between 1987 and
1991. In the industrial sector, the number of perc
machines is declining as they are replaced with water-
based laundering machines (Radian. 199 la). Follow-
ing a period of rising popularity in the 1960s, coin-op
machines are being phased-out due to economic and
environmental factors (French and McNeilly, 1988).
Drycleaning machines are classified according to
whether the washing and drying units are separate
(i.e., transfer machines) or If both functions are per-
formed In one unit (i.e., dry-to-dry machines). With
the older transfer technology, the garments must be
physically transferred to the dryer following the wash-
ing and extraction cycles. In the newer, dry-to-dry
machines, the garments are washed and dried in a
single unit, thereby cutting down on vapor releases to
the workspace.
In the commercial sector, transfer equipment cur-
rently accounts for approximately one-third of the
equipment stock. All new equipment being sold in this
sector is of the dry-to-dry design, although some used
transfer equipment may still be available (Radian,
199 la). In the industrial sector, some 84 of 130 perc
machines (or 65 percent) are transfer-type units. All
coin-op machines are the dry-to-dry type.
Emissions from the Drycleaning
Process
The 130.100 tons of fresh and recycled perc con-
sumed annually either evaporate as process or fugi-
tive emissions, or are lost through disposal of industry
solid wastes. Using a solid waste generation factor of
2.5 kg perc per 100 kg clothes cleaned, the amount of
perc disposed offsite can be subtracted from total
consumption to estimate total annual emissions. Ta-
ble 3 indicates that of the 130,100 tons of perc
consumed annually, approximately 87,000. or 67 per-
cent, is lost through emissions. This quantity is re-
leased to the indoor air at drycleaning shops, vented
to the outdoors, or Is emitted from freshly cleaned
clothes into the homes of consumers. Offsite disposal
of perc in solid waste is estimated at 43,100 metric
tons.
Table 3. Emissions of perchloroethylene by the U.S. dryclean-
ing industry, 1991 (metric tons).
Sector
Commercial
Industrial
Coin-Op
TOTAL
Total
Consumption
122,700
6,000
1,400
130,100
Oflsite
40,900
1,700
500
43,100
81,800
•UOO
900
87,000
Note Emission estimates are derived by subtracting offsite disposal amounts from total
consumption amounts.
Source: EPA, 19911).
To reduce the amount of perc emitted, the indus-
try must find ways to further cut fugitive emissions
from the process equipment, to recover additional
perc from vented emissions, or to remove residual
perc from clothing prior to releasing the garments to
the customer.
Emissions Sources
Solvent losses In the drycleaning process may occur
through atmospheric releases, from the generated
wastes, or from the discharge of contact water to the
sewer system:
. • Atmospheric releases may be either process-
related (due to the venting of emissions) or
-------
: Drycteanhg
fugitive (due to equipment leaks, losses from
clothes during transfer operations, or losses
during solvent transfer).
» Generated wastes include stiij bottoms, filter
"muck,* and spent filter cartridges. These
wastes are normally considered hazardous and
are typically removed from the facility by a
hazardous waste processor for pffsite recovery
and disposal. ;
• A small amount of perc is contained in water
removed from the perc-water separator. Tradi-
tionally, this water has been discharged to the
sewer system.
!
Emissions Controls !
Two main technologies are available for controlling
drycleaningmachine emissions: refrigeratedcondens-
ers and carbon adsorbers. Refrigerabjd condensation
units cool the perc-containing vapors to recover sol-
vent, while carbon absorbers remove perc molecules
by passing the vapors over a bed of activated carbon.
The carbon bed is then desorbed using steam, and the
perc is recovered from the desorptiion liquid. Both
carbon adsorbers and refrigerated condensers are
available as original equipment or as add-on controls.
The effectiveness of these technologies in reduc-
ing fugitive and process emissions is;; shown in Table
4. hi general, refrigerated condensers will reduce
process emissions by 95 percent ori dry-to-dry ma-
chines and by 85 percent on transfer machines. Carb-
on adsorbers are somewhat moire effective in
controlling process emissions from transfer ma-
Table 4. Emissions factors for drycleaning machines (kg perc
per 100 kg clothes cleaned). ;
Type of Control
Uncontrolled
Process emissions
Fugitive emissions
Total emissions
Rtfrigeratal condenser
Process emissions
Fugitive emissions
Total emissions
Carbon adsorber
Process emissions
Fugitive emissions
Total emissions .
Dry-to-Dry Machines
Emissions Control
(kg) Effectiveness
3.1
25
5.6.
0.2 93.6%
2.5 0.0%
2.7 ' 51.7%
0.2 93.6% .
25 00%
2.7 51.7%
, Transfer Mtchines
Emlisiotu Control
(kg)1 1 Effectiveness
!
40
iih
I
(1.0
i
!).« 85.0%
.si> 0.0%
i.6 37.8%
'
02 95.0%
| .
S'j) 0.0%
S2 42.4%
chines, and will reduce these emissions by 95 percent
as well. . '
An additional control method used by a small
percentage of the industry is the Solvation™ process.
hi this system, the perc-laden vapors are passed
through a water bath, where they form an azeotropic
mixture of water and perc.2 The vapor pressure of this
mixture is lower than that of perc, which increases
the recovery efficiency of the machine's normal con-
denser. The effectiveness of this technology is believed
to be approximately equal to that of refrigerated con-
densers, but was not deemed sufficient for compliance
with EPA's National Emission Standards for Hazard-
ous Air Pollutants (NESHAP) (EPA. 1991b).
Table 5 indicates the level of adoption of the two
primary means of control in the commercial, Indus-
Table 5. Drycleaning machine populations and current levels
of pollution control, 11991.
Sector
Type of Machine
rind Level of Control Conimcrdiil
Tmuftr macftiner •
Uncontrolled
Refrigerated condenser •
Carbon adsorber ;
Total
Dry&'dry machines
Uncontrolled :
Refrigerated condenser
Carbon adsorber !
Total
TOTAL
5,253
2,529
2,529
10.3H
6.885
9,978
4,532
21395
31,706
Industrial
42
-
42
84
23
-
23
46
130
Coln-Op TOTAL
— 5,295
— 2^29
— 2571
— 10395
1,617 4525
— 9.97J
1,427 5.982
3,044 24,485
3,044 34.8SO
Source: Radian. 1991a.
trial, and coin-op sectors as of 1990. (Use of the
Solvation™ process iss believed to be currently limited
to less than 5 percent' of the industry.) The major
highlights from the table follow:
• Approximately half of all transfer machines in
the commercial sector are uncontrolled.
Among controlled machines, half are equipped
with refrigerated condensers and half with
carbon adsorbers.
• Some 32 percent of commercial dry-to-dry ma-
chines are currently uncontrolled. Forty-seven
percent are equipped with refrigerated con-
densers, sand the remaining 21 percent are
fitted with carbon adsorbers.
• In the industrial sector, 50 percent of all trans-
fer and diry-to-dry machines are estimated to
Source: EPA, 1991b.
2An azeotrope is defineclasaliquid mixture mat is characterized by a constant
minimum or maximum tailing point that is lower or higher than that of any of
' the components and th«it distills without change in composition.
-------
JeffCantin
be uncontrolled, while the other 50 percent arc
equipped with carbon adsorbers.
• As noted above, all coin-op machines are of the
dry-to-dry design. About half (53 percent) are
uncontrolled, while the remainder (47 percent)
are equipped with carbon adsorbers.
• Vented machines are equipped with fans that
pull air Into the machine and away from the
operator when the door is opened: Newer, no-
vent machines eliminate the Induction of fresh
airflow into the machine and therefore elimi-
nate these emissions. Approximately half of
dry-to-dry machines in the commercial sector
are vented, while the other half are of the
no-vent design.
Overall, 13,820 of 34.880 machines are uncon-
trolled (40 percent), 12,507 are equipped with refrig-
erated condensers (36 percent), and 8,553 feature
carbon adsorbers (25 percent).
Solid Wastes
Solid wastes in the drycleaning industry are generated
by the filtration and distillation processes integral to
the modern drycleaning machine.
FQtratton—Drycleaning machines recirculate
used solvent and employ continuous filtration sys-
tems to ensure the purity of the solvent supply to the
washer. The filters remove insoluble soil and other
contaminants from the perc during the cleaning cycle.
Cartridge-type filters are the most common, and are
now used by an estimated 90 percent of the commer-
cial industry (Wentz and Stucker, 1990). The car-
tridges must be changed following cleaning of between
450 and 700 Ib (202.5 and 315 kg) of clothing. Car-
tridges are normally removed, drained overnight, and
then discarded. The spent cartridges, however, can
retain as much as one gallon of perc. Steam stripping
may be used to remove additional solvent prior to
disposal.
A smaller number of drycleaners employ regen-
erative filters, which are either rinsed and reused or
which employ a rechargeable filter medium, such as
day or diatomaceous earth. The filter medium Is
removed and replaced with fresh medium. The spent
filter medium In rechargeable filters can also retain
significant quantities of solvent.
DtsWlatton—Distillation is a companion process
to filtration and serves to purity and recover the used
solvent Recovery Is performed for both economic and
environmental reasons, and distillation is practiced
by dose to 90 percent of commercial drydeaners 0FI,
1989). Distillation units are built into most modem
drydeanlng machines.
hi the distillation process, used solvent Is heated
in a still to its boiling point (250°F. or 121°C). The perc
and any water vaporize, leaving behind the nonvolatile
residues such as detergents, waxes, dyestuffs, sizing.
oils, and grease. The distilled perc/water mixture is
then left to stand in a gravity separator unit, where
the heavier perc separates from the water and is
drained from the bottom of the separator to the solvent
tank. The water, containing small quantities of perc,
is decanted from the top of the separator.
The sludge (or still "bottoms") that accumulates
in the bottom of the still is removed for disposal. Still
bottoms may contain as much as 50 percent perchlo-
roethylene (SRRP. 1990). To remove additional perc
prior to disposal, approximately 20 percent of the
industry utilizes "muck" cookers (IFT, 1989).
Under the 1984 Hazardous and Solid Waste
Amendments to the Resource Conservation and Re-
covery Act (RCRA), still bottoms and cartridge mate-
rials are considered hazardous wastes. Regulations
promulgated in 1986 under RCRA prohibit the land
disposal of wastes containing more than 1 percent (10
ppm) of chlorinated solvent (RCRA. 1986). All dry-
deaner wastes must be removed for disposal at an
appropriate facility (e.g.. Incineration) or be further
recyded. According to Industry sources, some 80
percent of waste solvent and residue is picked up and
recyded offsite (Meijer. 1988, cited in SRRP, 1990).
Chemical Exposure Pathways
Releases of perc from the drycleaning process have
the potential to impact various environmental media
including indoor air, ambient air, land, surface water
and ground water. This section describes potential
human exposure pathways for these releases and
provides estimates of the potential number of expo-
sures of each type.
Indoor air—Perc vapors released or emitted to
indoor air can affect drydeaning workers; resi-
dents of apartments in the vicinity of drydeaners;
patrons and employees of restaurants, food
stores, and other commercial establishments lo-
cated nearby; and consumers that bring dry-
cleaned garments into the home.
Ambient air—. Ambient air releases can impact gen-
eral air quality and may also be drawn into apart-
ments or other nearby establishments through
open windows, vents, or air conditioning systems.
Solid waste—Disposal of perc as solid waste can
affect ground or surface water as these materials
leach from landfills.
8
-------
Pollution Prevention: Drycfeanfog
i
Surface andground water—Disposal of perc through
seweis can affect the quality of nspeiving surface
•waters. When sewer pipes leak, ground-water and
drinking-water supplies may be endangered.
! i
Worker Exposures |
The U.S. Occupational Safety and Health Administra-
tion (OSHA) estimates that there are some 19,369
drycleaning establishments with payroll in the United
States.3 Of these, 85 percent or an estimated 16,464
use perc. Employment at these facilities is estimated
at 157,950 workers. i
OSHA's 1989 Permissible Exposure Limit (PEL)
for workers was set at 25 ppm over an 8 hour day.
Until December 1993, facilities can require employees
to us personal protective equipment to meet these
exposure limits. After this date, however, engineering
controls must be in place. The 25 ppm limit has been
challenged by both labor groups and the drycleaning
industry, and the entire PEL standarclfor air contami-
nants was recently remanded by the Courts.
Apartment Resident and Business
Exposures |
Residents of apartments located above or adjacent to
drycleaning establishments may be exposed to perc
emissions that enter their apartment. Likewise, em-
ployees of businesses situated near ^rycleaners may
also experience exposure to perc ;emissions. The
mechanisms by which perc can enter apartments or
nearby businesses include:
i-1
Dififusfon^-Perc can pass through floor, ceiling,
and wall materials from the drycleaning shop into
adjacent apartments or businesises.
Indoor ofr/Zou>—Perc can be carried through holes in
ceilings, pipe chases, vents, and other airflow paths
withtaanapartmmtormuM-estaljlishmentbuildJng.
PVom the outdoors—Perc emissions vented from
the shop to the outdoors can be drawn into apart-
ments or other businesses through open windows
or ventilation units. :
Studies in New York City and elsewhere in New
York State have found perc concentration levels aver-
aging 0.04 to 8.1 ppm in apartments located above or
adjacent to drycleaning shops, with a maximum read-
ing in one apartment of 28.6 ppm.4 Although these
__ _ -- !
3An additional 5,794 establishments are estimatecl:to operate without payroll,
that Is without paid employees. These are primarily smaller, family operated
facilities Non-payroll establishments are not covered under the 1970 Occupa-
tional Safety and Health Act, and hence are not included in the OSHA estimate.
*The New York studies are described in more detail in the two papers by
Schreiber found elsewhere in these proceedings, j
levels are generally below the OSHA worker st&sdard
of 25 ppm, it should be noted that some apartment
residents (e.g., invsalids, pregnant women) may have
longer exposure periods than workers and others
(e.g., infants) may IK more sensitive to exposure than
the average dryctesining worker.
Of the 29,718 drycleaning establishments in the
United States, those located in urban areas (and
especially older cities) are more likely to be located in
apartment buildings. Nationally, there are no esti-
mates of the numt»er of facilities in apartments. Sur-
veys of drycleaners in New York City suggest that 397
of 1,181 drycleaners (or 34 percent) are located within
apartment buildings (Schreiber, 1992). Elsewhere in
New York State, however, the percentage of cleaners
in apartment buildings is much lower-only 6 per-
cent Officials from California have indicated that
relatively few drycleaners are in apartment buildings
even in greater Los Angeles. In Michigan, drycleaners
have been prohibited from operating in apartment
buildings (and food stores) for several years, hence
resident exposures are believed to be minimal.
In both urban and rural areas, drycleaners are also
found in buildings; that house other businesses. These
include structures such as high-rise office buildings
and, more commonly, strip malls. In New York City.
approximately 43 percent of drycleaners surveyed indi-
cated they share a building with one or more other
businesses. Elsewhere in the State of New York (i.e..
excluding New York City), 47 percent of drycleaners are
located adjacent to other businesses (Schreiber, 1992).
ERG has developed estimates of the number of
apartment residents potentially exposed to dryclean-
ing emissions.-Nationally, 75 percent of the U.S.
population live in urbanized areas5 (Miller, 1992).
Consumer expenditure surveys indicate that urban
consumers spend twice as much on drydeaning as
rural consumers (Rogers, 1992). We assume that the
number of drycleaners in urban and rural areas is
proportional to the urban-rural population distribu-
tion, adjusted for the intensity of .use of drycleaning
services. If the urban-rural split of population is 3:1,
and urban consumers use drycleaning twice as much,
then the 29,718 drycleaning establishments can be
allocated using an urban-rural ratio of 6:1. Thus,
25,473 drycleaners are estimated to be located in
urban areas and 4,245 are located in rural areas.
Using Census Bureau data on the number of
apartment units in the United States and the esti-
mates derived above, the number of apartment resi-
dents potentially exposed to drycleaning emissions
can be estimated. If 20 percent of cleaners in urban
areas and 5 percent of rural cleaners were assumed
to be located in apartment buildings, then 857,000
'Defined by the Censiis Bureau as -one or more places ('central place') and
the adjacent surrounding territory that('urban fringe1) together haveaminimum
of 5,000 persons."
-------
JeffCantin
urban and 35,000 rural apartment residents could be
exposed to drycleanlng emissions.6
Consumer Exposures
Consumers maybe exposed to any residual perc that
remains in their garments following dry cleaning.
When drycleaning equipment is operated properly!
the amount of perc remaining in clothing should be
minimal. If the drycleaning equipment is not function-
ing well, however, or if the cleaner has not allowed
sufficient drying time, some garments may contain
substantial residual amounts of perc.
Freshly cleaned garments are normally brought
back into the home and hung in closets, which may
be located in the bedroom of the consumer. Studies
by EPA and industry have found that garments will
"offgas." or release, perc into the home over a period
of time. In an EPA indoor air test house, maximum
readings in various parts of the house ranged from
2.900 ppb in the closet to 195 ppb in the bedroom and
83 ppb in an adjacent den (as shown in Table 6}.7
Drycleaning is one of the most common types of
"personal services" used by consumers in the United
Table 6. Maximum concentrations of perchloroethylene in EPA
experimental test house.
Location
Maximum Concentration
Control Concentration
(ppb)
Clout
Bedroom
Den
2.500
195
83
no detect
no detect
no detect
Source: EPA. 1988.
States. Each year. U.S. consumers send approxi-
mately 600,000 metric tons of clothing and other
items to their drycleaner (EPA. 1991a). Consumer
expenditure surveys indicate that the average house-
hold spends approximately $66 per year cleaning 1 1
kg (22 Ib) of clothing (Rogers, 1992). Surveys by EPA
in 1987 found that 51 percent of respondents indi-
cated they had used drycleaning services within the
previous 12 months (EPA, 1987). Among users of
drydeaning services, the mean number of times dry-
cleaning was used per month was 1.87. Based on
these figures. EPA estimates that approximately 100
million consumers are exposed to perc residuals in
clothing every year.
*Tha Census daialndlcates the
---
s' "» number of units was divided
. " >5° *» dass- «» average size of
, "^ 1Tle number of <"ydeaners estimated to be tocated in
apartment structures (20 percent of urban cleaners and S perosntofrural
M «*«
bulWngs with 2-4 units; 5 percent In buildings with 5-9 units; 20 percent in
bulMnfls wm, 10-19 urfts; 30 percent in buikfings with 20-49 unlK 40
percent In bofldlnfls with >50 units. The number of structures with dryd
'
in urban and rural ireas
dscusses me findinss - *•
Food Exposures
Because perchloroethylene is somewhat lipophillc
(i.e.. absorbed by fatty cells and tissues), it has been
found in various food products by several researchers.
The potential for absorption of perc vapors by food is
highest in food stores, restaurants, and apartment
residences located adjacent to, above, or near dry-
cleaning establishments.8 The amount of perc ab-
sorbed by food depends on numerous factors such as
the concentration of vapors, the amount and type of
packaging, and the length of storage and exposure to
perc emissions.
Ground-Water Exposures
Ground-water contamination problems may arise if
there are frequent or large spills of perchloroethylene
during the transfer of solvent from delivery trucks to
the drycleaning machine. An additional source of
potential contamination, and one that has received
most attention of late, is the disposal of separator
water into the sanitary sewer system.
Although, drycleaning is a non-aqueous process,
water is still involved. Following the cleaning cycle, for
. example, used perc will contain a certain amount of
water that has been released from the garments (e.g.,
perspiration). Some drycleaning machines purpose-
fully introduce a small amount of water and detergent
into the washer to assist in removal of water-borne
contaminants. Condensed perc vapors from the re-
claimer unit also contain water.
Before this perc can be reused, the water must be
removed. Used perc and condensed vapors are usu-
ally pumped to a separator tank, where gravity serves
to separate the heavier perc from the lower density
water. The perc is drained from the bottom of the tank
and the water is decanted off the top (Radian, 1991).
Traditionally, the water coming off the top of the
separator is disposed of via the sanitary sewer system.
Operators either poured the water down the drain or
attached a hose to the machine and placed the hose
in the drain. The quantity of water generated depends
upon the type of vapor recovery unit in place. Ma-
chines with refrigerated condensers can generate ap-
proximately 250 gallons (950 liters) per year of water
(1 gallon, or 3.8 liters, per day), while those equipped
with carbon adsorption units can generate double
that amount, due to the higher volume of vapors that
are processed.
The solubility of perchloroethylene in water is
approximately 150 ppm. If the perc-water mixture is
at equilibrium, then the amount of perc contained in
separator water will range from 0.03 kg to 0.85 kg
(0.066 to 1.87 Ib) annually, depending on the control
^ee the presentation by Diachenko in these proceedings.
-------
Pollution Prevention: Drycleariing
device in place (Radian, 1991b). If the wa.ter is re-
moved before the perc has fully separated, however,
the water could contain substantial^/' greater
amounts of perc (CVRWQCB, 1992). ".]..'"'
Although the amounts of perc disposed to sewers
in separator water may appear small, investigations
in California have recently linked the disposal of this
water to sewers as a major source of groiind-water
contamination.9 There, several mechanisms have
been identified to explain the leakage of perc out of
sewers and into aquifers below. Legal acttaris against
several drycleaners, drycleaning equipment opera-
tors, and cities that constructed and operate the
sewer system are under way. |
Test wells drilled near drycleaning facilities in Mod-
esto, California, have found perc concentrations averag-
ing 3,470 ppb with a maximum of 32,000 ppb. Levels
measured in actual municipal wells inTurloek, Califor-
nia, ranged from <0.5 ppb to 7.2 ppb (Cohen, 1992).
Under the Safe Drinking Water Act the maximum
contaminant level (MCL) for percMoroethyleiije is 5 ppb,
and the maximum contaminant goal (MCG) is 0 ppb.
The extent of ground-water contamination or the
magnitude of the threat due to past disposal of sepa-
rator water by drycleaners is unknown. In addition to
the investigations occurring in California, similar
problems are under study in Florida (Morgan, 1991)
and Maryland (Haddad, 1991). j
In the United States, approximately ^23 million
people obtain their drinking water from ground-water
sources (EPA, 1988). ;
References
Cohen, W., 1992. Personal communication between
Wendy Cohen of the Central Valley Regional Water
Quality Control Board and Jeff Cantin of ERG. May.
CVRWQCB, 1992. Dry Cleaners—A Major Source oJPCE
in Ground Water. March 27. State of California Regional
Water Quality Control Board. Central Valley Region.
EPA, 1987. U.S. Environmental Protection Agency.
Household Solvent Products: A National UsageSurvey.
EPA-OTS 560/5-87-005. July. |
EPA, 1988. U.S. Environmental Protection Agency.
Environmental Progress and Challenges: An Update.
EPA-230/07-88-033. i
EPA, 199 la. U.S. Environmental Protection Agency,
Office of Air Quality Planning and Standards, Emis-
sion Standards Division. Economic Impact Analysis of
Regulatory Controls in the Dry Cleaning Industry. EPA-
450/3-91-021. October.
EPA, 199 lb. U.S. Environmental Protection Agency,
Office of Air Quality Planning and Standards, Emis-
sion Standards Division. Dry Cleaning Facilities—
Background Information Jar Proposed Standards.
EPA-450/3-91-020A. November. 56 Fed. Reg. 236 at
64, 382 (Dec. 9, 1991).
French, M.T.. and L.D. McNeilly, 1988. Economic Im-
pact Analysis of Regulatory Controls in the Dry Clean-
ing Industry. Prepared for the U.S. Environmental
Protection Agency. OAQPS. Economic Analysis
Branch by the Center for Economics Research, Draft
Report, March.
Haddad, 1991. "State s«?eks to recoup cost of ground-
water cleanup; officials negotiate over contamination
from dry-cleaner business," Baltimore Sun. Sunday,
February 17, 1991>
IFI, 1989. Internatiorail Fabricare Institute. Equip-
ment and Plant Operations Survey, Focus on Dryclean-
ing. Vol. 13(1). March.
Meijer, J., 1988. Personal communication between J.
Meijer of the International Fabricare Institute and A,
Yazdani of the Source Reduction Research Partner-
ship. February.
Miller, J.. 1992. Personal communication between Joel
Miller of the U.S. Bureau of the Census, Economic
Geography Division, and Jeff Cantin of ERG. June.
Morgan, C., 1991. "Dry cleaners' dirty legacy—Pollu-
tion in drinking water," Miami Herald. By Curtis Mor-
gan. Monday, December 2,1991.
Radian, 1991a. Documentotfono/Grotuth Rotes/or the
Dry Cleaning Industry. (Memorandum to drycleaning
NESHAP file.) Radian (porporation. March 29.
Radian, 199 lb. Evaluation of Separator Water Dis-
posal Practices. (Memorandum to drycleaning
NESHAP file.) Radian (Corporation. October 8.
RCRA, 1986. Resource Conservation and Recovery Act
Hozojrious Waste Management System: Land Disposal
Restrtet3on-FuwlRule.51 Fed,Reg.4O,572fFov. 7,1986).
Rogers. J., 1992. Personal communication between
John Rogers of the Division of Consumer Expenditure
Surveys, Bureau of Labor Statistics, and Jeff Cantin
of ERG. February.
Schreiber. J., 1992. Personal communication be-
tween Judy Schreiber of the New York State Depart-
ment of Health, Bureau of Toxic Substances
Assessment, and Jeff Cantin of ERG. September.
SRRP, 1990. Source Reduction Research Partnership.
Source Reduction of Chlorinated Solvents—Dry Clean-
ing of Fabrics. Final Draft, June.
Wentz, M.W., and J.F. Stucker, 1990. Removing Perc
Jrom Used Cartridges and Still Residues, American
Drycleaner, June.
9See the presentations by Cohen and Bunte in these proceedings, as well as
the CVRWQCB report cited in the References section, j
11
-------
German Diycleanlng Regulations
and Technology
Josef Kurz, Ph.D.
Research Institute Hohensteln
1 °n teXtUe ****** at the Institute
aSSSS £ nS^' *?s research **«* educational work have been docu-
mented In 15 books and approximately 200 other publications.
presentation provides information on
pollution prevention from the German dry-
cleaning industry. Germany has very strict
regulations on emissions into the air, the ground, the
workroom, and residential areas. I would like to high-
light what is Important from my point of view.
Regulation of Perc Vapor
Concentrations
Regulation requires that drydeaners combine and
optimize condensation and absorption. That means
that we have to combine the condensation cycle with"
the absorption cycle In a carbon filter. The require-
ment is that the concentration of perchloroethylene
(perc, or PCE) In the air leaving the cage may not
be higher than 2 g/m3. which is about a tenth of
the normal concentration from closed machines with
a condenser and refrigerator (Figure 1). This system
is very effective, but it needs a lot of time to reduce
the concentration of perc to 2 g/m3. Essentially, there
is a device to measure the concentration. Exhausting,
or open, machines, as we call them, have the same
perc vapor concentration after the cage, but the air
that has passed the carbon filters must not have perc
loadings of more than 20 mg/m3 or about 3 ppm
(Figure 2). So that means about three ppm, a value
that also has to be measured by our measuring
device. »
The impacts of this regulation are the following.
We have to monitor the concentration in the cage and
in the drying air, and the loading door is not to be
opened until the value of 2 g/m3 perc is reached. That
means the operator cannot open the door if the value
is higher than 2 g/m3.
Figure 3 presents three examples of the drying or
deodorization procedure. For instance, after a con-
densation cycle of zero to one minute, the concentra-
tion in the air after trousers have been cleaned is
about 2 g/m3. That means the loading door can be
opened, since the garments are cleaned and dried
according to the regulations. With silk, the concentra-
tion after the condensation phase Is about 1 g/m3,,
thus the door can be opened about two minutes
Source: Institute Hohenstein.
closed t"ycteanlna machlne -* «
Source: Institute Hohenstein.
Figure 2. Schematic of a drycteaning exhausing machine with
a carbon filter.
-------
Pdufion Prevention: Drycleaning
25
n
•*.
Ul 5
o
a.
OJ
2,0
£ Basic
drying cycle in
drycleaning
machine
Silk
V
^V
•*— Endof
condensation
cyde
Trousers
V]
N^^ ^S
«•— Endof
condensation
cycle
Down Jackets
%J
*»S»^
«— -Endof
corlde^sation
1 cyde
i
the displaced air goes back into the still. Thus, there
is an exchange of the air between the still residues
and the waste vessel, and no emissions are released
during the removal of the residues from the still. Since
liquids, semi-liquids, and even powder or paste can
be pumped, every type of residue can be removed from
the still without emissions..
It appears that the burden or load of perc released
into the workroom is partly caused by vent leaks from
0 minutes i
12
18
24
Source: Institute Hohenstein.
Figure 3. Perc concentrations in different types of garments
during drycleaning cycle. I
earlier. The third example uses down jackets, which
present a problem for drycleaners. Here two down
jackets were put in a 10 kg machine. After the drying
cycle and an absorption phase of 12 minutes, the perc
concentration was about 6 g/m3. The drydeaner has
to continue the absorption phase until a : value of 2
g/m3 is reached. Thus, the garments Have to be
cleaned another 12 minutes or more. If the machine
were loaded with 8-10 kg of down jackets, drying
might take two hours. So we see some difficulties with
this material in the drycleaning cyde. :
Removal of Still Residues arid Lint
The removal of still residues must be done without
releasing emissions. That means the door of the still
must not be opened by hand and the residues must
be removed using a waste vessel. In Germany we use
a closed system, with a piston pump (Figure 4). The
piston pump brings the residues into the vessel and
7 6
Source: System Multimatic.
Figure 4. Technology for removal of still residues;:
the button traps. As a result, the German government
requires that lint be removed in a dry condition. Figure
5 shows a schematic of the system used to dry this
lint. The air flows from the cage to the button trap,
dries the lint in the button trap, crosses the lint filter,
ventilator, condenser, and heater, and then follows
the normal cycle in the drydeaning machine. Emis-
sions into the workroom are avoided and diffusion into
the residential areas alaove the drycleaning room are
likely to be minimized.
Heater Condenser
Fan
Lint Filter
Source: Institute Hohenstein.
Figure 5. Schematic of system for removal of button trap
residues.
Handling of Perc
.Open handling of perc is prohibited. We have some
problems with this, however, because sometimes it is
necessary to handle perc in the open. It appears that
80 to 90 percent of the drycleaners in Germany are
working in accordance with this regulation.
Disposal of Separator Water
Ground-water protection is very important in Ger-
many. In the drycleaning process, contaminated
water from the water separator must be purified by
adsorption, stripping, or by absorption (Table 1). Nor-
mally we use absorption systems, and the threshold
value for the contaminated water is 0.5 mg perc in the
water going to the sewer. Before cleaning, the water
generally has about 200 mg or higher per liter.
13
-------
JosefKmz
Table 1. Water protection considerations relevant
to the drycleaning process.
PuicaSonofaxFtanv-
n*ted water of the
water separator by
• adsorption,
• strippng.
• absorption.
Threshold value:
OSmgpercperKcr
water
Regulation
• Law on Water
Protection
Storage of solvent and
solvent containing
detergents /aids and
distillation residues
in a safety trough
RegUabons
• Regulation on dean Air
• Law on Water
Protection
0'eposH
> Outet air of exhaust-
ing machines not
higher than 20 mg
perc/mi>(~3ppm)
• Outlet air from the
workroom less than
35mgperc/m'
(~Sppm)
Regulations
• RegUafion on Clean Aii
i Regulation of German
OSHA
Source: kwtkute Hohenstain.
Solvent Storage
Regulations also require that solvent be handled care-
fully to ensure It does not get Into the ground water.
Storage of the solvent Is an Important concern. Since
the penetration of solvent Into the ground is prohib-
ited, solvent and solvent-containing detergents, aids,
and residues must be stored in safety drums so that
leakage into the ground water is avoided.
Protection of Neighborhood Areas
Perc concentrations in gaseous exhaust from the
drycleaning plant—the outlet air of the exhausting
machines—must not exceed 20 mg/m3, and the outlet
air of the workroom cannot exceed 35 mg/m3 perc,
about 5 ppm. (Normally we have an occupational
exposure limit value of 50 ppm.)
Figure 6 shows a diffusion barrier used to protect
neighboring areas. The threshold value is 0.1 mg/m3
perc, or 0.015 ppm, for a neighboring apartment The
diffusion barrier is very useful for reducing diffusion
of emissions through walls and ceilings from the
workroom of the drycleaning plant.
t
o
Apartment
Threshold Value: 0,1 mg/m3
(0,015 ppm)
DRYCLEANING
Sppm
Diffusion;'
Barrier »
Measurement device < 2g PCE/m*
Butcher's
Threshold
Value:
0,1 mg/m3
(0,015 ppm)
Soure: Insttuto Hchenstein.
Figure 6. Diffusion barrier for confining drycleaning vapors.
Collection and Treatment
of Contaminated Water
The collection of contaminated water must be carried
out properly. This concerns contaminated water from
distillation, plus the water from the drying cycle in the
machine and from the carbon filter. All this water has
to be collected in a separator—a conventional separa-
tor like in other machines (Figure 7). Then the water
is directed to a safety separator—a bigger tank or
vessel. Finally, the water must be purified or treated
to reach a perc value of 0.5 mg/m3.
Distillation
Drying
Carbon Filter
Safety Separator
Purification
Equipment
Source: Institute Hohenstein. •
Figure 7. Schematic of system of handling water contaminated
by drycleaning process.
Figure 8 shows an example of a safety trough for
storage of barrels. The size of the safety trough must
be sufficient to hold the contents of the largest con-
tainer. Also, the drycleaning machine must be set over
a safety trough so that solvent can be collected if there
is any leakage from the machine.
U- Frame
Safety Trough
Source: Institute Hohenstein.
Figure 8. Collecting trough for containing solvent leakage.
Inspection and Training
The drycleaner must inspect drycleaning machines on
a daily or weekly basis for leaks (Table 2). A simple
method to control leakages must be employed, and
the activated carbon filter must be inspected regularly
to ensure that the value of 20 mg is not exceeded.
Designated plant personnel must be trained and
tested in environmental protection practices at certi-
fied schools (Table 3). Annual training is required for
14
-------
Pollution Prevention: Drycleaning
Table 2. Recommended frequency of inspection of dry cleaning
equipment
Leaks in
Drycleaning
machine
Activated
Carbon Filter
Contact water :
treatment device1
Table 3. Training and external inspection considerations for
drycteaning operations. i
Training
External Inspection
» Training and examination of
designated plant personnel
in environmental protection
by a training institute
(Corresponding course).
• Annual training in the
plant by the manager.
Once a year: ••
• Function and cafibrafon of
PCE measurement devices.
Every second year: ' i
• Compliance with i
Water Protection Last.
Source: Institute Hohanstein. '
the owner or the manager of the plant. Once a year
the measurement devices for perc must be tested for
proper functioning and calibration. Every second year
an inspection is required to ensure compliance with.
perc regulations and with the water protection laws.
Appendix
The following materials were submitted for title round-
table by Dr. Kurz, but were not referred to sjpecifically
in his presentation.
7.1
Purification Procedures
Adsorption
Filter
'•Stri'pjaing-:
EPA RounOtiblo
German Drycleaniny
Institute Hoh*nst«in
11
toss of PCE/ Yaar in Drycleaning Industry
'87 '88 '89 ^30 'SI 'SH |'93 '94 '95
Year
15
-------
Evaluation of "New Generation"
Drycleaning Equipment
Walther den Otter
TWO Cleaning Techniques Research Institute
Mr. den Otter is reseach manager and senior advisor at the Cleaning
Techniques Research Institute TOO in Amsterdam, where he is developing
the Dutch Internal Environmental Care System for the drycleaning and laun-
dry Industry. He is also developing cleanup methods for soil and ground-
water pollution. Mr. den Otter holds an engineering degree in physical
chemistry from the Technical CoUege in Amsterdam and has published over
25 papers concerning the environmental effects of the drycleaning industry.
Introduction
The 5.000 researchers at the Cleaning Techniques
Research Institute (INO) in Holland work on a variety
of fundamental and applied projects in this small,
densely populated European country of 15 million
inhabitants. The Institute TNO has a lot of experience
working with Dutch industries to solve their problems
and to develop new technologies.
The drycleaning branch covers 600 unit shops and
30 larger firms, most of which are laundry companies,
thnoughoutHolland. Since the late 1970s, the institute's
drycleaning environmental projects have included not
only research, but also advising and strategic planning.
As a result of our contact and positive relations with the
Dutch government, thelnstituteTNOwasoneofthe first
national branches to push through new environmental
regulations (the General Administrative Drycleaning Or-
der, GADO) and to develop an Internal Environmental
Care System.
Drycleaning machines, the focus of just one as-
pect of the institute's work, is covered Jn this presen-
tation. It includes results of various tests of
emission-reduction apparatus, along with a perchlo-
roethylene (perc) balance and the results of a "new
generation" machine called the BoWe P450 with Con-
sorba. Also covered is the correlation between leak-
ages and vapor concentrations, suggestions for
drycleaners, and a discussion of the new Internal
Environmental Care System.
Emission Reduction Apparatus
The goal of Holland's new environmental regulation,
the GADO, is to lower the level of solvent consumption
and exposure to workers and residents living near a
drycleaning operation. With a no-effect level of 136
mg/m3* and a safety factor of 50, the institute's official
toxicologlsts determined that the emission level
should be kept, under 2.5 mg/m3, with a maximum
peak of 25 mg/m3. Since the odor threshold for
perc—1 mg/m3—is critical, GADO sets the maximum
emission level for existing unit shops at 2.0 mg/m3,
and at 1.0 mg/m3 for new shops, with the same
maximum peak level for both—25 mg/m3 for up to
three minutes.
The maximum solvent loss is set at 3 percent,
based on the weight of cleaned garments and on
the terms of maximum emission concentration of
100 mg/m3 with a three-minute maximum of 25
mg/m3.
Table 1 shows different apparatus with their ef-
fects. Note that when solvent losses are kept below 3
percent, emissions are reduced 25 percent compared
to a machine with no apparatus. However, up to three
times as much energy is required for such apparatus.
When deciding how best to protect the environment,
a balance must be found between energy savings and
emission reduction.
Perc Balance
Figure 1 shows a sketch and material balance for both
a machine with an internal deepcooling system
(Scheme 1) and a machine with an external active
carbon recovery system (Scheme 2). In general, the
machine with the deepcooling system consumes less
*1 ppm = 6,890 mj/m3 or 6.89 mg/m3
16
-------
i Pollution Prevention: Drycleaning
Table 1. Losses of perc solvent In drycleaning machines with
various emission reduction apparatus. j
Type of emission-1« f'-i Solvent Emission^-poris'urrjptipji;
Environmental valve'"?'-.'
Waterlock ,_--[_' ^ : \\5^6%
Active carbon., recovery 4^5,% '
Deep cooling without .".:";;••. \,-i
heating pumprt '-,: j, '•
Deep cooling ',-: -' v
beep coolingi + v_: -''-J';:>-,~-s .
special lartivecSfbort•.'. ;2-3%i
Deep coolings :?.i-;. '•• i*'-V-;iV:""
specia;l activei carbon' , "- ,';;
•;;* ppwderlejss'f liter > >;p.5-1%
*300%r h>\4OT
Scheme 1 Drycleanmgirnachihe ; '"'•.?
!vvith ihternaj diepeooiing systom
;_•-...".,-' •-' (average solventjdss 3.2i55i} y
.-'"* vperc>
32.5' g/kg;----^.
--> 14.0g/kg-:
, Vaste residue'.
Scheme 2 Drycleanirig machine . •
.,''-.. with external active carbon recovery
(average sol vent loss ~4.p%) ' " ^
;(• aeration pipe)
--'"• loading/unloading
•:garments' • .-.- ,
• leakages
Figure 1. Various drycleaning equipment and emissions levels.
!• • -
II
energy than the one with only a carbon recovery
system. The amounts of the incoming solvent, after
entering the machine from the left, are shown as the
solvent flows into the compartment air, the waste-
water, and then the waste residue. The solvent left in
the waste residue, rather than entering the environ-
ment, is recycled by a specialized firm, as I'equired by
Dutch law. Thus, most of the solvent is lost to the
compartment air where it decomposed with a half-life
value of a few months.
The "New Generation" j
Drycleaning Equipment
Table 2 shows the effect on workers of a new-genera-
tion drycleaning machine called P450 ]36We with
Table 2. Perc vapor cbhcenllratlons in front of a new-generation
drycleaning machine (P450I BoWe with Consorba).
Type of ?
garrnentS'
jMen's clothing.
Quilted rainwear, 60%
SleepingJbajjs;..-"":•'5 piec^s
, fferc,\;apor:cbcjegrjtratiq.n irj;:.jjtJ
:
' (45 sec) j:;:ejr.utn \
Consorba. The concenlratlons are low because they
were measured directly above just-unloaded dry-
cleaned garments, which are difficult to get dry. Such
measurements must be taken very quickly, as there
is no mass flow coming from the garments. Soon after
the garments are removed, the measured concentra-
tion levels dropped dreimaticaliy, and thus show no
indication of the drying; effect
As a base, the Institute TNO set the target value
at less than 50 ppm, as measured above just-un-
loaded drycleaned garments. Achieving this target
value would indicate a proper drying effect expected
to a workplace with proper ventilation where perc
vapor concentrations are normally between 5 and 10
ppm.
Tables 3 and 4 show perc concentrations in the
workplace and during finishing. As expected, these
concentrations were very low:
• During finishing, which takes 15 minutes—2
to 12 ppm perc
a hi front of the drycleaning machine—3 to 7
ppm
Table 3. Perc vapor concentrations during finishing using a
new-generation drycleaning machine (P450 BoWe with Con-
sorba).
Table 4. Other measurements of perc vapor concentrations in
workplace using a new-generation drycleaning machine (P450
BoWe with Consorba).
Measgrjn
iirne ";;*,,
;Behind.P450
"AKSve P4507
(area: around?
In Gonsrb
shbkfjne Fcatlon
I ID-andSBoye; J5;fjpm-:
17
-------
Waltherden Otter
• Behind the machine—less than 5 ppm
• During loading and unloading, which takes up
to two minutes eveiy 45 minutes—10 ppm
In short, with such new-generation machines,
values between 5 and 10 ppm easily can be reached
in a drycleaning shop.
Leakages and Vapor Concentrations
When workers do not take environmental and safety
precautions, the low concentration levels cited above
are not attainable. The human factor always must be
taken Into account
To minimize loss of solvent, the use of refrigera^
tion and absorption technology must be accompanied
by good management techniques. Employee training
must include clear instructions and procedures for
using the equipment. Workers must know what to do
in case of equipment failure and understand basic
operating, checking, maintenance, and trouble-
shootingtechniques. The equipment must be checked
regularly for potential leaks of either vapor or liquid.
The Institute TNO does not have the measure-
ment technology to measure the correlation between
leakages and perc vapor concentrations from the
new-generation machines. However, based on data
from old machines, the Institute has found that the
more leakages a drycleaning machine has, the higher
the perc vapor concentrations in the workplace. Fig-
number of
leakages
ure 2 shows the correlation—based on hundreds of
measurements—between leakages and perc vapor
concentration of controlled machines in four catego-
ries, as well as measurements taken from behind the
machine and in the workplace. Notice that the work-
place vapor concentrations are lower, since the meas-
urements are taken farther from the machine.
Indications are that the correlation between leak-
ages and perc concentrations in regard to new-gen-
eration machines is less of an issue: first, the new
machine's more effective drying process leaves less
perc in the cleaned garments; second, the computer-
ized controls of these machines include pressure and
temperature sensors that allow early detection of opera-
tional failure.
The best way to monitor leakages is to keep a
logbook for tracking solvent consumption and leakage
checks. Such a logbook is required by the Internal
Environmental Care System.
Advice to Drycleaners
Table 5 lists advice Institute TNO gives Dutch dry-
cleaners to ensure a safe and environmentally accept-
able cleaning process.
Table 5. Recommendations for drycleaning operations from
Institute TNO.
Safe operator ajctiojni
Follow the operating and maintenance instructions provided:
by trie manufacturer of machine - 'f M,v •'-'•. v -)^f
Maintain the cleaning machine regularly;' ' •'.- -.'-. • • -•'. ',:-\ . '-:;
Switch the machine off 'duringimaihte'na'nce.wp'rk and.'when
the machine hasjto be cleaned ":'- ', '-'"". . * '\ • -, - ,'. ,
Run an automatif'rather than; a manually-operated cleaning
program .- f -, ' ;/\ ' V ••'''''•:~.~" ' VrX ". v
Do not open the loading.door during cleaning and'drying • ,
Do not skip'any Safety regU]atioris'(through shortage of
" ' ' "'''' ""
percentages
of «H
machines
Particular attention
correlation
leakages and
perc vapor
concentration
good
reasonable
moderate
number of leakages
behind machine
(without deep cobling)
number average
of cphc.
leakages in ppm •
in working place
good Q
reasonable 1-2
moderate 3-4
Figure 2. Perc vapor relative to machine leakage.
Good drying process ; .. ."7'••"•:'.' >.
Machine, both design and maintenance
Emission restriction device . ' ' ~(', ..
Removal of distillation residue; : '/--..
Topping of the cleaning macriihe1 • *C
Stain removal o I .'; "." , /•• •"";'."-• -"'{••
Adequate workplace1 ventilation ; '• :-5 .:
Internal Environmental Care
System
In addition to good technology and state-of-the-art
machines, the human factor always affects the dry-
cleaning process. Good environmental protection can-
18
-------
Poifufibn ftevfofion: Drycfeanhg
not be achieved simply by making capital invest-
ments. It results ultimately from making people envi-
ronmentally aware. Appropriate training fosters
better work involvement, higher productivity, and
improved product quality. In the end, hew the dry-
cleaning machines are operated may be a iinajor envi-
ronmental factor. i
-- 8 -:
auditing'
stateftijent'-
SfEARNG
reports
Committee
planning]
;cheefcing;
jAGCEPTANCE;
;(b
-------
Fiber-Solvent Interactions
Hans-Dietrich Weigmann, Ph.D.
JRI/Princeton
Dr. Weigmann Is associate director of research at TRI/Princeton, In New
Jersey, where he has served as a scientist for over 31 years. He has extensive
experience In fiber-solvent interactions, a subject area in which he has been
widely published. Dr. Weigmann holds degrees in organic chemistry from the
University of Heidelberg and the Technical University Aachen, Germany
TRI is a nonprofit organization loosely associ-
ated with Princeton University. TRI has a
Joint polymer materials program, and we
have been active in exploring interactions between
polymeric fibers and solvents for quite some time. We
approached this research from a specific point of view
originally. We looked at questions such as. What does
a solvent do? How does it penetrate? What properties
are required for a solvent to penetrate a particular
fiber? We wanted to look at these questions from a
dying point of view, andfromafinlshingpointofview,
and now we are looking at them from a drycleaning
point of view, which Involves approaching issues from
the opposite perspective. That is, how can we avoid
penetration of the fiber and yet achieve the cleaning
function that is required of the solvent?
In drycleaning we are removing essentially par-
ticulate and oily substances from the surface, and we
wish to avoid penetration of the solvent into the fiber
structure itself. As we all know, with the current
equipment and practices we cannot avoid penetra-
tion; we cannot avoid the fact that there is residual
solvent in the fabric that could conceivably give us
problems, especially if regulation progresses the way
it has been lately. So I would like to look at what is
Involved In absorptlon/desorption of solvents—the
fiber-solvent Interactions. What determines the pa-
rameters? When we took at solvents, what properties
or conditions will help us avoid this kind of penetra-
tion? And I'm going to restrict my remarks to polyester
(PET) and perchloroethylene (perc).
It Is well known that In the process of drycleaning
a rather effective physical separation of solvent and
fabric occurs. Then in the drying phase desorption
from the fabric occurs. There are actually two phases
involved here: One where the solvent is removed from
the surface, the surface head or solvent head in the
interstices of the fabric. Here the solvent is removed
by evaporation. The parameters involved here are the
heat of evaporation of the solvent, the solvent vapor
pressure under the conditions of removal, the solvent
air diffusion at the conditions of dry (of the removal
process), and the velocity of an airstream that is
generated.
The second phase of interest is much more diffi-
cult to analyze. The eventual time required for solvent
removal in the first phase can be predicted from the
properties and from the parameters and conditions of
removal. The second phase involves solvent removal
from the fiber itself; that is, internal diffusion of
solvent to the surface where It is then removed. So
here we are looking at solvent diffusion within the
polymer. There is a considerable amount of informa-
tion and a considerable amount of literature available
that deals with absorption and desorption of perc in
PET.
Figure 1 shows the sorption, in this particular
case, of perc by PET as a function of time, where the
temperatures of the conditions of sorption are 40 to
Source: Bredereck and Koch. 1974.
Figure 1. Temperature dependence of pere sorpiion by PET.
20
-------
! Pollution Prevention: Drycleaning
120°C. Granted we are not talking about 120°C or
anywhere near it in drydeaning operation^, but this
is the way these data have been collected. As the figure
shows, there is almost instantaneous equilibration at
the high temperature and a very slow sorption. which
eventually reaches an equilibrium conditions at 40°C.
Even at 40°C, which is well below the glasis transition
temperature of the polymer, absorption occurs. That
is because as the solvent front moves into the fiber, it
lowers the glass transition temperature of the poly-
mer. Under these conditions—40°C—some uptake in
the 1 to 2 percent range does occur. |
Of course, if wet material is subsequently used,
and it is heated in order to remove the solvent, we also
drive the solvent into the polymer itself. So we have a
situation where in the interest of speed of removal we
actually cause an effect that is undesirable.
In terms of sorption versus desorpttan, in Figure
2, where the sorption is at 80 and 100°C. rapid
equilibration results. When the solvent is desorbed at
100°C, it is considerably slower, but still reasonably
fast At 80°C that difference is much higher, and as
we move away from the glass transition temperature
of the polymer and the concentration this difference
in the rate of absorption/desorption becomes progres-
sively wider and it becomes more difficult to remove
solvent from the interior of the fiber. i
j
Figure 3 shows an equilibrium condition when the
material is treated eight hours at 60°C. We actually
intentionally looked for an equilibrium condition and
1.0
0.8
0.6.
0.4
0.2
Sorption:
Desorption
24 28 32 36
40
024 8 12 16 20
Source: Bredereck and Kodi. 1974.
Figure 2. Sorption-desorption of perc from PET at 80 and
100°C.
Perchlorathylengehalt (%)
.-! 40°C
-j 60°C
it—. 80°C
-\ 120°C
024 8 12
16 20 24 28
Source: Bredereck and Koch. 1974. •
Figure 3. Desorption of perc from PET after treatment for 8
hours at 60°C.
now we look at the effect of temperature on the
desorption rates. As shown, at 40°C. after what is
roughty 20 hours, only i50 percent of the perc has been
removed. Even at 120°C. although rapid desorption is
reached initially, as tile final value is approached,
desorption becomes progressively slower and then it
appears that total removal of solvent from the polyes-
ter is never achieved. Conceivably, this is because the
solvent at these high temperatures is entrapped in the
fiber structure.
At room temperature the situation is much worse,
of course. In Figure 4, the fibers were treated for one
hour at 80°C, at a draw ratio of 4. 1 . The fibers are fully
drawn polyester yarns. As shown, at approximately
50, 60, 80, 100 days, only 40 percent of the solvent
has been removed. The solvent comes out very slowly,
which is a problem from the point of view of desorp-
tion. It is a benefit on the other hand, if the perc has
penetrated the structure considerably. Looking at
room temperature desorption, we know that this
desorption is very slow. The accumulation of solvent
in a dosetor inagarmeritbag, for instance, is approach-
ing equilibrium values at a very, very slow rate.
ioor
/
>- 80
1
1
8 60
o
UJ
S4°
cc
te
V^
£ 20
3
n
/
PERCHIJOROETHYLENE S
1 hr ot £IO°C V ^^^
X ^""
L- ^'^
y ^4* • TETRACHLDROETHANE
s* < 1 hr at 80°C
, '^r
•* ^
t 1 __1
10
TIME; (days)
Figure 4. Storage loss of solvent retained by polyester yams
(draw ratio 4.1) after treatment in perc and tetrachloroethane
fort hour at 80°C.
Now the questions are, How can we predict what
solvents will penetrate the structure? And what sol-
vents will not penetrate the structure? These ques-
tions are considered irom the point of view of how do
the solvents enter the structure, rather than from the
point of view of drydeaning effectiveness of the sol-
vent The solvents that do not penetrate, or those that
have considerable difficulties in penetrating will have
to be looked at to determine their drycleaning capa-
bilities. ; ,
Figure 5 is a plot of the glass transition tempera-
ture—the shift in glass transition temperature of poly-
ester as a function of the solubility parameter of the
solvent. The figure shows the shift down to a very low
glass transition temperature, and shifts of up to
220°C. Although th(2se data were accumulated by
21
-------
Hans-Dietrich Weigmann
10 II 12 13
S. SOLUBILITY PARAMETER (col/cm3)"2
Figure 5. Glass transition temperature relative to the solubility
parameter.
dynamic shrinkage measurements and then extrapo-
lated, it appears that they have some validity. Note the
bimodal distribution of the delta TG. The glass tran-
sition temperature of the polymer itself Is 80°C, as we
know, which means that on both sides the 80°C value
is approached. The solubility parameter of PET is
10.7, and our maximum interaction levels are consid-
erably removed from this value
We have to look at polyester under these condi-
tions as a copolymer consisting of aromatic and ali-
phatic moitles that Interact with the solvent in their
own way. The aromatic branch here is Interacting on
the low level of the solubility parameter and the
aliphatic with the polarity of the solvent entering into
the picture.
Briefly, Figure 6 depicts equilibrium thermody-
namics through which the solubility parameter can
be determined. This parameter is described by the
cohesive energy density of the material, and the heat
of mixing is given by a value where we have the
polymer and the solvent (Table 1). As soon as the two
are very close or identical, we have a maximum of
interaction.
Figure 6. Sketch of typical volume of Interaction for Hanson's
three-dimensional solubility parameter concept
Table 1. Solubility parameter theory.
Heat of Mixing AHm
AH
m
Solubility Parameter 8
Three Dimensional Solubility
Parameter
R2 , j.2
5P + 8h
Source: HJdebrand, 1950; Scatchard, 1931.
References
Bredereck, K.. and E. Koch, 1974. Melliand Textilber.
55. 157.
Hansen, C.M., 1969. Ind. Eng. Chem., Prod. Res.
Dev., 8. 2.
Hildebrand, J.H., and R.L. Scott, 1950. Solubility of
Electrolytes. New York: Reinhold.
Ribnick. A.S., and H.-D. Weigmann, 1973. Textile Res.
J.. 43, 316.
Scatchard. G.. 1931. Chem. Rev. 8. 321.
22
-------
Operating Drycleaning Equipment
to Minimize Exposures
Jack D, Lauber
Division of Air Resources ••
New York State Department of Enwronmenfa/ Conservation
As a staff engineer for the New York State Department of Environmental
Conservation, Division of Air Resources (Bureau of Application and
Permitting), Mr. Lauber manages hazardous waste disposal projects and coor-
dinates the department's drydeanlng industry regulatory program. He is a
professional engineer and a diplomate in the Academy of Environmental
Engineers with 30 years of experience in the environmental area. He holds a
B.A. in chemical engineering from New York University.
In the State of New York there have been some
very serious problems with drycleaners impact-
ing the environmental quality in residential
apartments and also some general air pollution prob-
lems in urban areas. Problems have been most pro-
nounced in New York City, where there has been
severe contamination of apartments as well as other
ancillary air pollution problems concerning uncon-
trolled or poorly controlled emission!; of perchlo-
roethylene (perc) from drycleaning operations.
Judy Schreiber, from the State H?alth Depart-
ment, addresses residential exposure in one of her
presentations. My focus is on the tools needed to
property control emissions from dryckianers, recog-
nizing the ranges in technology. It is generally agreed
that proper operation and maintenance Is particularly
important for controlling emissions, along with the
selection of appropriate control technologies. Thus, I'd
like to present an overview of certain slate-of-the-art
control measures that we at the New York State
Department of Environmental Conservation believe
are necessary to property control emissions from dry-
cleaning equipment and offer our perspective on the
issue based on what we have discovered In our inves-
tigations of drycleaning operations in New York State.
Table 1 lists a selection of environmental stand-
ards for perc emissions. The Occupational Safety and
Health Administration (OSHA) standard limits expo-
sure to perc to eight hours at 25 ppm. OSHA also has
certain other standards, such as the 200 ppm short-
term exposure limit The Germans are using 10 ppm
as an occupational standard for perc. Generally
speaking, perc emits a detectable odor when the
concentration is about 50 ppm; however;, some people
can smell perc at lower levels.
Table 1. Selected perc exposure standards.
PERC,(TETRACHLOROETHYLENE)
C£ C£ ' :
II t
c = c
I I _ ;
' C& Cl V Potential Human Carcinogen
OSHA PEL
GERMAN -
25 ppm
10 ppm
1 ppm = 1 inch in 16 miles
= 1f in $10,000.
Odor Level —•— SOppm PERC.
- NYSDEC AGC for PERC.
(NESCAUM)
1.2 pg/m3 = 0.16 ppb
Ippb = 1 inch in 16,000 miles
- 1$ in $10,000,000.
We have proposed a very stringent ambient level
for perc emissions. The New York State Department
of Environmental (Conservation ambient guideline
concentration is 1.2: ng/m3, which is .17 ppb on an
annual average. This standard is based on cancer risk
and was developed ^yith guidance from the Northeast
States for Coordinated Air Use Management {NES-
CAUM) group. There is also the New York State Health
Department's indoor air guideline, which is identical
to the German guid
-------
JackD, Lauber
cleaning equipment are due to fugitive emissions from
the loading door and from other point sources. There
are many situations where at the end of the cycle even
the best refrigerated condenser machines give off
emissions of 500 to several thousand ppm, depending
on the condition of the refrigerated equipment We
believe that ventilation standards have to be estab-
lished to properly contain these emissions.
Local ventilation must be controlled so that when-
ever the door to a drycleaning machine is opened there
is an inward flow of air. We are using the 100 feet per
minute guideline suggested by the National Fire Pro-
tection Association (NFPA), the State of Michigan.
and others, and we believe that this is an effective
standard for minimizing exposures in the work room.
as well as ancillary emissions—fugitive emissions that
can impact on residential areas.
We have conducted extensive emission testing
using portable photoionization instruments. We have
found that when there is effective equipment mainte-
nance, reduction of leaks have been reduced, gaskets
are in good condition, and ventilation is effective, perc
exposure can be minimized. In general, we have found
that residual levels of perc can be kept to 1 to 2 ppm
In the work room with effective ventilation and process
controls. Recommended emission reduction meas-
ures are listed In Table 2.
Isolation of the drycleaning equipment and ade-
quate general ventilation is particularly important.
Guidelines used by the State of Michigan and recom-
mended by NFPA suggest an air change in the work
room every five minutes. In one case we studied, a
drycleaning operation In New York City was releasing
significant perc emissions Into an apartment above.
One of the basic control approaches recommended
was to enclose the drycleaning operation and build a
Table 2. Suggested perc reduction measures.
1. Repair Leaking Gaskets, Hoses, Machine
Leaks
2. Improve Garment Aeration, Don't
Overload Machine
3. Monitor PERC Solvent Mileage
20,000(good) -50,000(ideal)
Lbs. Fabric/Drum
4. Improve Separation of PERG & Water
From Condenser
5. Improve Filter Sludge Recovery
6. Check All Local Exhaust Systems
For Leaks
7. Check Pre-filter 81 Carbon Adsorber
(Sniffer) For Good Operation. Strip
Daily, Check PERC Cone. Often
(<25ppm PERC Feasible). Problem
if Much Greater.
small room or enclosure. Also, it was recommended
that the air be vented through one duct and exhausted
through another, achieving an air exchange in less
than 5 minutes. I understand that the system as
eventually set up was overdesigned and that the air
is being exchanged about every 2.5 minutes. Any
leaks of perc that occur, or any fugitive emissions, are
exhausted immediately to the outdoor air and cannot
leak into nearby apartments.
Also, diffusion-resistant materials were used in
making the enclosure. The materials consist of poly-
ethylene sandwiched between foam insulation. Perc
emissions had been tens of thousands of ng/m3 in the
work room from this uncontrolled drycleaning opera-
tion. The emissions have been progressively reduced
very significantly with these control measures—by
several orders of magnitude.
There are two types of ventilation: general ex-
haust ventilation of a work enclosure, and local ex-
haust ventilation of the drycleaning machines. A new
type of control device has been pioneered in New York
City that actually is adapted to a refrigerated con-
denser machine. This system controls perc by ex-
hausting the machine at the cage. The door is opened
at the end of the cycle to exhaust the perc vapors. The
gas stream can be vented to a dual-carbon absorber
and emitted to the outdoors. Tests of such a facility
have shown concentrations of up to 500 ppm perc
entering the carbon adsorption system and approxi-
mately 1 ppm leaving.
We believe that the German perc emission guide-
lines are appropriate, and we are suggesting an emis-
sion standard of 5 ppm, which is very close to the
German emission concentration limits, can be met
with this type of control system (Table 3). With a
Table 3. Efficiency of suggested emission control approaches.
EMISSION
SOURCE
Process
Vent
Fugitive
TYPE OF
CONTROL
Carbon Adsorb.
Ref rig. Conden.
Refrig. Cond. a
Carbon Adsorb.
CON'
EFFICIENCY (%)
ROL
95
85/95
99 +
Proper Oper. Pract* Unknown
Leak Detect. 8 Rpr. Unknown
Dry-to-Dry Mach.Use 50
Proper operating practices (e.g., covering solvent
containers, keeping lint traps clean, minimizing
open door times and adhering to machine
cycle times)
24
-------
Pollution Pr&v&ntion: Drycl&aning
refrigerated condenser machine, the system is only on
when the door is open and when the exhaust is
operating, which is only a short cycle of a few minutes
per machine door opening. ;
Another control concept Involves transfer ma-
chines. The vapor containment system for' a transfer
machine uses a total vapor enclosure made of clear
vinyl. With 100 feet per minute air velocity coming In
through the curtain there is complete ventilation of
the entire transfer machine operation enclosure. Only
one such system has been installed In New York State
to date. We tested this device system pn several
occasions, and found that it was very effective. We
measured perc concentrations of up to 50 ppm during
air transfer inside the vapor containment.'enclosure,
and 1 to 2 ppm In the work room. This system may
have promise for controlling emissions from transfer
machines In existing residential areas. \
I also want to discuss the environmental regula-
tion that we are currently drafting. Similar to EPA. we
are Including the enclosed refrigerated condenser and
the dry-to-dry machine with a carbon absorber as the
best available control technologies. The refrigerated
condenser, carbon absorbers, and azeotropic devices
with carbon absorbers are the principal control tech-
nologies. :
For existing sources we are also proposing high-
efficiency carbon adsorption systems with emissions
of 5 ppm or less. We believe It Is Important to have
strict control of a carbon adsorber In order to meet
our stringent ambient guideline value of 1.2 ng/m3 of
perc on an annual average. Our proposed emission
standard is very close to the German emission stand-
ard. We also believe that all drycleanlng facilities
should have 100 feet per minute of iflward local
exhaust velocity through the machine door opening.
This is a very important step for controlling fugitive
emissions from the loading door. We also believe that
more stringent control provisions are necessary for
drycleaning operations adjacent to residences and
other businesses, especially food service estab-
lishments. In such cases, general exhaust ventilation
with an air change every five minutes should be
required along with a vapor barrier. In 'general, we
have found that an adequate vapor containment sys-
tem and local and general exhaust ventilation systems
can effectively control perc emissions, if the operator
maintains and operates equipment property.
Appendix
The following tables and figures were submitted for
the roundtable by Mr. Lauber, but not referred to
specifically In his presentation.
BENEFITS OF USE OF
BACT DRY CLEANING
TECHNOLOGY AND
OPTIMUM OPERATION
• Lower Solvent Costs
• Reduction in Worker
Exposure
• Reduce Liability For
Toxic Emissions
CONTROL OPTIONS
TRANSFER :
99% Vent Control (very difficult)
95% Vent Control (immed.'orgradual)
85% Vent Control
No new transfer machines
DRY-TO-DRY
99% Vent Control (has been achieved)
95% Vent Control
25
-------
Jack D. Lauber
EMISSION SOURCES
VENTS
L Vented after
wash cycle
i Vented during aeration
1 and after drying cycle
FUGITIVE EMISSIONS
- equipment leaks
- storage
- exhaust damper malfunction
- residual solvent in clean garments
- "wet" garment transfer
CONTROL TECHNIQUES
\. PROCESS VENT CONTROLS
-Carbon adsorber
- Refrigerated condenser
2. FUGITIVE CONTROLS
- Emission & control data lacking
-OSHA PEL to 25ppm
3. REPLACEMENT of Transfer Machines
With Dry-to-Dry Machines
4. BACT, MACT
-Dry-to-Dry refrigerated condenser no vent
machine with machine door local exhaust
or
Same with internal aeration S supplemental
carbon adsorber
5. SOLVENT SUBSTITUTION ?
-petroleum distillates (fire hazard)
- CFC113 (none yet acceptable, CFC ozone probs.)
-1,1,1 -TCA (solvability, probs. ozone depletion)
- HCFCs 123,141 (further evaluation necessary
bylFI.etc.)
MACHINE SIZES
SECTOR
Commercial
Industrial
Coin-operated
Self service
Plant operated
RANGE OF
MACHINE SIZES
(Ibs. of clothes)
15-100
140-250
8-12
DESCRIPTION OF PERC
DRY CLEANING INDUSTRY
Types of Dry Cleaning Equipment
• Transfer-Separate Washer 8 Dryer;
Manual Clothing Transfer
Step
• Dry-to- Dry - Washer & Dryer Combined'
No Transfer Step
' UNREFRIGERATED- vented to carbon
adsorber (sniffer)
REFRIGERATED CONDENSER -
-no vent (BACT)
- vented at )00 fpm to
supplemental carbon
adsorber (MACT?)
PROPOSED PART 2X1
NEW ENCL. REFRG. CONSENSER OR DRY TO DRY + CARBON
ADSORBER, OR AZEOTROPIC DEVICE
EXISTING - HIGH EFFICIENCY CARBON ADSORBER - 5 FPM
GERMAN STD. - 3 FPM
ALL • 100 EPM LOCAL EXHAUST VELOCITY
WITH ADJACENT RESIDENCES AND FOOD SERVTrF.
GEN. EXHAUST VENT - Affi CHANGE PER S MIN. + VAPOR
BARRIER
Dry Cleaning facility compliance XMCUTM and cost*
GOBplianee Meaaur*-
Installation of a stat* of the art
totally *ncloned refrigerated
condenser dry-to-dry machine.
Addition of a total vapor contaminant
system to an existing transfer type
machine including a carbon absorber.
Adding a carbon absorber to an
existing dry-to-dry machine.
Adding an azeotropic control system
including a carbon absorber to an
existing dry-to-dry machine.
Adding an exhaust system and carbon
adsorber canister to a refrigerated
condenser machine (supplemental
control system) .
General ventilation of workroom
(air change every five minutes) and
vapor barrier, for facilities near
residential areas.
capital cost (includes •
installation - 1991 dollar*)
$40,000-$50,000
10,000-12,000
6,000
7,000
2,500-3,500
1,000-2,000
26
-------
Pollution Prevention: Dtycleaning
DRY CLEANING INSPECTION FORM
INSPECTED BY
DATE
FIRM
ADDRESS
4.
5.
Brand of Machine:
Type(s) of Machine:
A. Transfer
Vented;
B, Dry to Dry
C. Refrig. Condenser
D. Azeotropic Solvent Recovery System
Non-Vented
Number of Machines:
Sector Type:
Capacity
Dry Cleaning Solvent;Used:
A.
B.
C.
(Used with Transfer or Dry to Dry Machine.)
Commercial
Industrial
Coin Operated •
Ibs/machine
A. Petroleum
B. Tetrachloroethylerie (PERC)
C. Other(specify, e.g. Freon, TCTFE)_
D. Total Quantity of Solvent
Used/Year '.
(Ibs)
i E. Total Quantity of Solvent Type Hazardous
Waste Disposed/Year (Ibs)
How Are The Dry Cleaning Machine Emissions Vented &nd Controlled?
A. Vented without Control
B. Vented to outer air w/carbon-adsorber j_ '
•Above Roof |
•Through Wall or,:Window '
• I
C. Vented to carbon.adsorber, and exhaust recirculated to room
D. Minimum Inward Air Velocity (Ft/Min)
•Through Machine JDoor(s)
27
-------
Jack D. Lauber
•Through Exhaust Hood Openings
(Slot Hoods should achieve an equivalent 100 FPM at furthest machine
door opening point)
•Smoke Bomb Test (Yes or No )
Vapor Condenser:
A. Water cooled condenser (e.g. For Transfer, Dry To Dry or Azeotropic
Unit)
•Gauge Temperature at Inlet (e.g. 700F)*
B.
•Gauge Temperature at Outlet (e.g. - 80OF)*
Built-in refrigerated condenser
•Gauge Temperature of Outlet at Condenser (e.g. 40oF)
Dryer .
A. Lint Trap Door Gauge Temperature of (e.g. 140-150oF)_
Carbon adsorber
External
A.
•Full Size Unit (.e.g Dry to Dry Machine)
•Small Type (e.g. Azeotropic, Refrigerated Condenser)
•Number of Adsorber Units
•Series or Parallel
Rating
(CFM) of Fan
Number and size of exhaust
fans in room
B.
C.
Internal (built into machine)
Stripping of carbon:
•Steam
•Hot Air
10
D. Type of Adsorber Prefilter:
•Urethane Foam _
•Other (specify)
•Frequency of Replacement
General Ventilation of Workroom (Axial or Propeller Type Fans)
Number
A.
*Measured At Water Lines of the Condensing Coil on the Dryer
28
-------
* Pollution Prevention: Drycleaning
Per
11.
12.
B. Location:
•Ceiling __
•Window
•Wall '
C. Makeup Air Inlet (yes/no)
Type: Door, Window, Louver :;
D. Calculated Air Changes - (Volume of Room/Total CFM Exhaust - Minutes
Air Change) - _| Min.
Maintenance and Operation
A. Equipment Leaks (yes/no)
Where? (e.g.1:. water separator, still) j
Solvent Storage ! Tanks and Containers (covered/uncovered)
B.
C.
D.
Machine Exhaust Dsjnper (operating properly)
(Yes or No) ,|
Leak Test
Pass
Fail
E.
F.
G.
H.
I.
J.
Carbon Adsorber Stripping cycle i -
• (how often?'e.g. daily) .'
* ;Ibs clothes/lb carbon (3.0 recommended For Full
Size Unit) | ' .
•Steam Pressure (PSIG) :
Significant residual solvent in garments (yes/no) ___
Filter cartridges drained for 24 hours (yes/no) '
•Reclaimed iij still (yes/no) :
Perc/Water separator fugitive emissions (yes/no)
Machine Lint Filters Replaced Regularly (yes/no) '
How are Spent Solvents, Filters, and Other Wastes Disposed?
How is Waste Water 'Discharged?
•Sewer Untreated '
Treated :
•Evaporated in Workroom
, I ' . . i .-.— i
Monitoring Results j :
A. Instrument Used (e.g:,HNU, Photovac, etc.): ,
B. Average Workroom PERC Air Concentrations (ppm):
29
-------
Jack D. Lauber
•In front of machines
•Behind machines
•At Water Condenser Separator
•At Still Separator
•At machine door when opened
•At pressing station
•At carbon adsorber exhaust
•Outside at exhaust fan discharge
•Other (describe)
13.
Is there any occupied space directly above or adjacent to the Dry Cleaner,
ex., office, living space, restaurant, etc.? (explain).
14. Type of ceiling in Dry Cleaner '_
15.
Dif fusionResistant Construction (yes/no)
Are there any openings in the ceiling, ex., missing ceiling tiles, pipe
chases, etc.? (explain) :
16. Odor intensity in Dry Cleaners
•High :
•Medium
•Low
•None
17. Remarks
JDL/lms
4/30/92
90-1/2-167
30
-------
Roundtable Discussion Summary:
Exposure Reduction
Discussion about exposure reduction began
with several questions for Josef Kurz of In-
stitut Hohenstein concerning |the require-
ment in Germany for interlocks on new closed
machines that prevent the door of the:drycleaning
machine from being opened until the perc concentra-
tion in outlet air reaches 2 g/m3. Ken Adamson of the
Drycleaners and Launderers Institute of Ontario en-
quired about the development of instruments to per-
form continuous monitoring within the cage. Dr. Kurz
indicated that at first they had imported a device from
the United States that cost approximately $20,000
plus an additional $10,000 to modify it ;Later, a call
went out to the German instrumentation'industry for
innovation and one has been developed that costs
around $5,000.
!
Manfred Wentz of R.R. Street indicated that on a
recent trip to Germany he had taken measurements
inside the cage above the clothes and obtained read-
ings of up to 1,500 ppm in the air. He suggested that
this could indicate that the instruments are not re-
porting an equilibrium concentration. To;truly obtain
a very low equilibrium concentration, he believes that
the drying and aeration times would have to be sig-
nificantly increased, at the expense of machine capac-
ity and throughput. This led to considerable
discussion of the measurements reported by Dr. Kurz,
which were not resolved. Participants agreed to table
the debate so that other questions could.be raised.
Judy Schreiber of the New York State Department
of Health asked whether the Netherlands has a stand-
ard for apartments and if so what that levisjl is. Walther
den Otter of TWO Cleaning Techniques Research In-
stitute responded that there are three standards that
relate to apartment exposures: (a) 100 (i/m3 for air
leaving the shop, (b) 1 n/m3 for air outside the apart-
ments, and (3) zero or non-detect for air inside the
apartments. To achieve non-detect levels in apart-
ments they must use diffusion barriers, otherwise
levels of 25 to 50 ppm can be measured. Mr. den Otter
also responded to Dr. Schreiber's question concerning
standards for perc concentrations in food by indicat-
ing that a limit of ][00 ppm or 1 ng/kg has been
established.
Bill Seitz of the Neighborhood Cleaners Associa-
tion questioned Dr. Kurz on the types of diffusion
barriers that have been evaluated to reduce the infil-
tration of perc vapors into apartments and neighbor-
ing establishments. Dr. Kurz reported that
experiments were conducted to determine the thick-
ness of wall material that would be required to reduce
vapor concentrations! penetrating the wall from 50
ppm to 0.1 ppm. Researchers found that if conven-
tional building mateiials were used the walls would
have to be exceedingly thick; up "to 65 cm for brick
and 236 cm for plaster. Greater success was found
when special coatings were applied to conventional
wall material. For eacample, metal-containing paint
and aluminum-backed wallpaper were both effective
in virtually eliminating infiltration. Mr. Seitz asked if
polyethylene films had been tested and Dr. Kurz
answered that they had riot been.
Ross Beard of R.R. Street questioned Dr. Kurz on
the basis for setting such stringent regulations on
drycleaning in Genrainy. Dr. Kurz indicated that the
level of regulatory control had nothing to do with the
suspected carcinogerjicity of perc but rather was due
solely to the classification of perc in Germany as a
hazardous substance.
Bill Fisher of the International Fabricare Institute
asked about the current costs for setting up a dry-
cleaning shop in Germany or the Netherlands, given
31
-------
Exposure Reduction
the strict regulations that have been Introduced.
Walther den Otter of TWO responded that newer ma-
chines that meet' the regulations will certainly cost
more but also they •will save solvent, so there is a
payback. As a means of comparison, he gave the
example of solvent consumption for older vintage:
equipment versus new generation machines. Where
the solvent cost of cleaning one kilogram of clothes
was previously %€> Dutch guilders it Is now closer to
1.0 guilder.
Steve Risotto of the Center for Emissions Control
was interested to the ventilation retrofit that Jack
Lauber of New York Department of Environmental
Conservation had shown. If e asked whether DEC had
engineered the project br whether commercial firms
were doing such things jfl New York. Mr. Lauber
Indicated that there were a. number of firms In the New
York City area performing these types of retrofits, and
that the one shown was done by a private contractor.
32
-------
RESIDUAL REDUCTION
-------
-------
U.S. EPA Research on Drycleaning
Residual Reduction
Bruce A. Tichenor, Ph.D. |
Air and Energy Engineering Research Laboratory
U.S. Environmental Protection Agency
i
Dr. Tlchenor has 27 years of experience with the EPA and its predecessor
agencies and currently directs a comprehensive research program at the wA
laboratories at Research Triangle Park, to North Carolina, for evaluating
sources of indoor air pollution. He is a registered professional engtaeer with
the state of Oregon and holds a B.S. in civtt engineering and a Ph.D. m^rri;
tary engineering from Oregon State University. Dr. Tlchenor is on the ASTM s
Indoor Air Committee and has published over 40 technical papers on sources
of indoor air pollution. j
This presentation concerns a study that was
conducted about four years ago. It was car-
ried out cooperatively with EPA'S Office of
Toxic Substances, which is now called the Office of
Pollution Prevention and Toxics. The study had a
couple of objectives (Table 1). one of which was to find
out the effect that bringing drycleaned clothes—
freshly drycleaned clothes—into a residential environ-
ment will have on the levels of perchloroethylene (perc)
Inside the home. The second objective was to answer
the question of whether there is something the con-
sumer can do—for instance, hanging the clothes out-
side for a time—to reduce the levels of residual perc
before the clothes are brought in the home. That's
what we call airing out \
Our approach used small environmental test
chambers to evaluate the emission rates and the
decay rates of perc in fabrics. We conducted the study
at our laboratory in Research Triangle Park, North
Carolina. In addition. EPA has an indoor air quality
test house there. In other tests, we took drycleaned
Table 1. Experiment for testing emissions of ipjerc from dry-
cleaned clothes. :
i
Objectives: !
- Determine the increase in perc in residences due to dryjcleaned clothes
- Determine the effectiveness of "airing out" ;
Approach: ;
- Small chamber testing; emission rates & decay rates |
- Test house experiments; bag off, bag on, "airing out" • ,
- IAQ model evaluation
Results and Conclusions: ;
- Freshly dry cleaned clothing causes elevated levels of perc indoors
- "Airing out" of freshly dry cleaned clothing by the consumer is not
practical due to the slow decay of the perc emission rate ;
clothes, put them in a closset in the test house, and
then measured levels of perc at various locations
throughout the house. Then we did some indoor air
quality evaluation using a computer model.
Not surprisingly, we found that when you bring
freshly drycleaned clothing indoors, you can measure
elevated levels of perc:. The other thing we found—
which after this morning's presentation should also
not be surprising—is that due to the very slow decay
rate of perc in drycleaned fabrics, having the con-
sumer air them out lor some reasonable period of
time—in our case we used six hours—is probably not
worthwhile, since the decay rates that we measured
were quite slow.
The technology we used to conduct this research
is used to study a lot of indoor air pollutants. It
involves loading small environmental test chambers
into a constant temperature environment; clean air is
introduced, and then we are able to measure the
concentration of the pollutants coming out—in this
case perchloroethylene (Figure 1). Using gas chroma-
tography as our analytical technique, we obtain a
concentration versus time profile for the outlet from
the chamber. We assumed for this study that the
emission rate was goiJig to follow a first-order decay.
Thus, we solved the differential equation of the mass
CLEAN
AIR
SYSTEM
— &-
TEST CHAMBERS'
1:
2-1
3
4
5
6
•JsOBBENrTJ-
. »
•Ll SORBEufT-
GAS
"*" CHROM.
Figure 1. Small chambeir (53 liters) emissions testing facility.
35
-------
BtuceA. Ttchenor
balance of the chamber for this emission rate (Figure
2), and then presented the data using a nonlinear
curve-fit routine (which sounds complicated but is
easily accomplished on a personal computer). Figure
2 presents a portion of one of the curves firom the
study; it shows concentrations over a 48-hour period.
The tests we conducted in the small chambers gen-
erally ran from two to five days. Out of this we
calculated an initial emission rate (R-0) and a decay
rate (K). It turns out that the ratio of these two rates
is the total amount of emittable material; here perc
residuals are given in mg/m3.*
We looked at a number of different fabrics in-
itially— fundamentally for screening studies— and se-
lected three specific fabrics: polyester-wool blend,
100 percent wool, and a polyester-rayon blend fTable
2). These same fabrics were used as the primary
material in clothing that we had drycleaned and then
placed in the test house The studies in the test
chambers, however, were done with bolt material that
we had drycleaned.
Tabte 2. Small chamber test: Perc emission rates.
Fabric
Wool (Suit)
IOCS Wool
(Stau
Rayon (Blouse)
ACH
(/hr)
0.25
1.00
2.00
0.25
1.00
2.00
0.25
1.00
2.00
Ro
(mg/m2-hr)
1.50
2.40
0.80
0.93
1.20
0.80
0.56
1.10
0.47
k
(/hr)
0.028
0.045
0.028
0.041
0.028
0.052
0.022
0.038
0.027
Ro/k
(mg/m2)
54
54
29
23
43
15
26
28
17
t(1/2)
(hr)
27
16
20
26
19
34
19
25
One of the rates we studied concerned the effect
of air exchange—air changes per hour. (Although we
also looked at the effect of temperature, the data is
not provided here.) The study found the decay rate for
the three different fabrics to be slightly different, and
found some difference in the air exchange rate of
•1 ppm « 6.89 mg/m3 or 6,890 ng/m3
individual fabrics. We also were trying to determine
whether there is a consistent change in the decay rate
with the air exchange rate that would indicate evapo-
rative mass transfer. While the data do not indicate
that relationship, they do show that the evaporative
mass transfer did occur, hopefully back at the dry-
cleaners. The data show a desorption, which is why
the rate is so slow. We also looked for the total mass
of perc in the material. The data generally show that
the polyester-wool blend holds more perc than the 100
percent wool or the polyester-rayon. Additionally, we
looked for what are called hdif-lwes. This is the
amount of time required for the emission rate to divide
itself by two, or to go down by 50 percent. This is
measured in hours, so our findings are in the order of
days. Thus, hanging clothes out to air is not particu-
larly practical since it takes a number of days for the
perc level to drop.
Our indoor air quality test house is a conventional
three-bedroom house (Figure 3). For our study, we
hung a three-piece suit, a skirt, and two blouses in a
closet of the test house after all the garments were
drycleaned. We measured the concentration of perc in
(1) the closet, (2) the corner bedroom, and (3) the den
(the living room and den are connected). The house
was closed up during the test period, but the furnace
and air-conditioning systems were left operating. We
ran the experiment at 20°C. pretty cool, but not
unusually so. The results are presented in mg/m3.
Figure 4 shows levels of perc in the doset over a
© - Sampling Location
Figure 3. IAQ test house: Drycteaning experiment.
3
Day 1 Day 2 Day 3 Day 4 Day 5 Day 6 Day 7
Time (day)
Figure 4. Perc concentrations in test house closet
36
-------
Pollution Protection: DrycleanSng
seven-day period. We ran each test for a week under
a variety of conditions.
Let me explain that we had a condition called bag
off, which means we took the plastic bagoff the clothes
before we hung them in the closet. We had a condition
called bag on, where we left the plastic bag on the
clothes. We had a condition called aired out, where we
aired the clothes outside foraperiod of sixhours, and
a condition called bag off two. which was a, replicate
of this first condition. Figure 4 shows our predictions
made with our indoor air quality model, bassed on the
emission factors we observed in our small test cham-
bers. I
That data would seem to indicate that airing
clothes out actually increases the level of perc. Actu-
ally, we observed a normal rate of decay. We found a
fairly poor correlation, however, between these indi-
vidual experiments. In my opinion, this was simply
because when we took the clothes to the drycleaner
and brought them back, they had different amounts
of perc. This was probably the greatest variable in the
study. In terms of control, we took the clothes to the
same drycleaner—a local drycleaner near our labora-
tory—and asked that they be handled in a standard
way, including pressing.
We found levels nearly as high as 3 mg/m3, which
for an indoor pollutant is a fairly high level, especially
for organics. But that was in the closet: Figure 5
shows concentrations of perc in the adjoining bed-
room that were about an order of magnitude lower
than concentrations in the closet. The maslmum con-
centration was around 2 mg/m3, dropping below .05
mg/m3after a reasonable period. In the den (Figure
0,09
Day 1 Day 2
Day 3 Day 4 Day 5 Day 6 Day 7
Time (day) '
Dayl Day 2 Day 3 Day 4 Day 5 Day 6 Day 7
Time (day)
Figure 6. Perc concentrations In test house den.
6), the values were even tower. The maximum concen-
tration was less than, than. 1 mg/m3, and the average
values after a few days were around .02, or 20 tig/m .
So, we found that when you bring drycleaned
clothes into your home, you get elevated levels of perc
in the air. Levels are highest where you keep the
clothes—not surprisingly—next highest in the adja-
cent room, and the rest of the house also has some
measurable concentrations. Thus, anybody in this
house is going to have :some level of exposure to perc
from the drycleaned clothing. When the clothes in our
study were hung outside for a time, a perc decay rate
for most of the fabrics was on the order of .02 to .03.
This indicated that airing out drycleaned clothes—in
this case for six hours—will only reduce the amount
of perc in the drycleaned material by about 20 percent
(Figure 7). So. it's not a very effective way of reducing
perc concentrations.
2 ; 4
Time Aired Out (hours)
Figure 5. Perc concentrations in test house bedroom.
Figure 7. Effect on perc concentrations in garments after airing
out
37
-------
Industry Research on Drycleaning
Residual Reduction
Thomas A. Robinson, Ph.D.
Hdogenated Solvente Industry Alliance
Dr. Robinson is manager of regulatory affairs for Vulcan Chemicals of
Birmingham. Alabama, and chairperson of the Regulatory and Legislative
Affairs Committee of the Halogenated Solvents Industry AmancelS,28
years of industry experience include working as an analytical research chem-
611131
-------
Pollution Prevention: Drycleaning
Results i
A moving average (Le., average of current sample, two
preceding, and two subsequent samples) was used to
determine the 16-hour period with the highest con-
centrations within each testing week. The highest
average (peak exposure) for each five-day t<£t was
statistically contrasted with that of the control (i.e.,
zero seconds of steam or air, using the t-test). The
results are in Figure 2.
TOTAL FINISHISG TIME IH SECONDS
TOTn-u jriWi"****"* **«•* •"- —
Figure 2. Effect of total finishing time on maximum pen con-
centration. "
The hatched bars represent the perc concentra-
tion associated with each finishing regimen, while the
solid bars represent the perc that might be expected
from a single suit coat The perc emissions resulting
from the last two finishing regimens are significantly
lower than the control. It should be noted that thelevel
from the second finishing regimen (steam/air - 10/2O
seconds) is probably higher than would be expected
due to an error in the air changes/hour 0.1 for
second regiment versus 0.3 for the others. This error
is most obvious when the data is plotted on a curve
CFigure 3).
•nm*mom)
Figure 3. Comparison of fitted curves for different total finish-
ing times.
The finishing process applied to the clothes after
drycleaning reduced the amount of perc in the bed-
room of the test house. Ilie magnitude of reduction
for the longest finishing regimen was on the order of
25 percent A clear correlation between length of
finishing time and emissions does not look promising.
A significantly longer finishing time would appear to
be required to obtain any further significant reduction
in perc residuals. This solution would not be accept-
able to the average drycleaner because it would not
be cost-effective.
39
-------
Diyclecsning in Japan: Current Conditions
and Regulations
Junji Kubota
AH Japan Laundry and Diycleanlng Association
between
theJapan^pva^entaSdSri^^S'SSteSJtoZSTS
cS^Sf^.'S^^^^SSSSSS^-*
n Meiji Gakuin University.
In Japan, four iypes of diydeaning solvents are
used. Table 1 shows the number of diydeaning
madUnes In use In Japan during 1989 by type
of solvent used and the number of diydeaning estab-
lishments. As shown In this table, machines and
establishments that use petroleum-based solvents
make up 70 percent of the total, those that use
perchloroethylene (perc) account for 20 percent and
those that use CFC-113 or 1,1,1 trichloroethane ac-
count for 5 percent The large number of petroleum-
based-solvent madiines is particularly noteworthy.
Table 2 shows the estimated amount of dryclean-
Ing solvents used in Japan during the same year.
Table 3 provides a breakdown of garments dry-
deaned In Japan by type of solvent As shown, the
amounts of garments deaned with petroleum-based
solvents and perc were virtually the same. Table 4
shows the household market for dothing deaning
services from 1987 through 1991. It Indicates that
demand is Increasing year by year.
Table 3.
and
'« •*"*»>
Percaloroethvlene
letrlchlorofora
CFC-113
Total
Huiber of facilities
usiiw: drycleaninj eachines
33. 700
9. 700
1. 700
46. 900
Nuaber of unit of drycleaning
machines in use
35. 500
10. 700
. 1.800
. 1.900
49. 900
Table 2. Estimated deliveries of drycleanmg solvent (1989).
Pctroleua solvent
Perchloroethylene
CFC-113
Estiisted deliveries of drycleaning solvent
(ton)
7. 700
18. 000
2. 700 '
4. 1 00
Percent of garments cleaned by type of solvent
Petroleum solvent
Perchloroethylene
He tyl chloroform
CFC-U3
Conponent ratio of garaent according to solvent (X)
40.2
6. 3
13.3
The distinctive features of Japan's dothing clean-
ing industry are:
• Almost all dothing deaning establishments
provide both drycleaning and conventional
laundry services.
• Virtually all petroleum-based-solvent ma-
chines are of the transfer type. However, in all
establishments where the other three solvents
are used, equipment is of the dry-to-dry type.
• Relative to the size of the population, the num-
ber of dothing deaning establishments is
large. The number of pickup stations that do
not actually perform deaning is also large, as
is the number of small, "mom-and-pop" type
operations.
• Coin-operated drycleaning machines have not
been widely adopted in Japan.
In Japan, the deaning industry falls under the
administrative jurisdiction of the Ministry of Health
and Welfare (MHW) and is regulated under the Clean-
ing Business Law, which covers not only drycleaning
but also conventional laundry services. Notification
-------
Pollution Prevention; Diycleaning
concerning building construction, equipment and
other matters Is required to operate a clothing clean-
ing business, and facilities must be Inspected in
advance. In addition, the clothing cleaning estab-
lishment is responsible for formally securing certifica-
tion as a Registered Cleaning Supervisor, i
Regulation of Diycleaning \
Solvents
Petroleum -Based Solvents
Because of the flammabiiity of petroleum-based sol-
vents, building codes and fire regulations prohibit
their use in residential and commercial areas. In
addition, cleaning establishments must apply for ap-
proval to construct storage facilities of 1,000 liters
(260 gallons) or more of solvents, and must give notice
of the construction of facilitiesfor storing 200 to 1,000
liters (52 to 260 gallons). '•
No national regulations are applied to emissions
Into the atmosphere, but in some areas operators are
required by local ordinance to install isxhaust gas
recovery equipment to suppress photochemical smog.
Where the workplace environment Is concerned, how-
ever, operators must post precautions to be observed
when handling these cleaning fluids and must desig-
nate a person responsible for work involving organic
solvents, among other measures. i
Perchloroethylene (Perc) !
The problem of environmental pollution from perc In
Japan began with ground water in 1981^ when perc
was detected in the underground water sources for
several cities. In addition, perc was listed as a harmful
substance by the Water Pollution Control Law and
Sewerage Law, and an effluent standard,of 0.1 mg/1
and under for perc was implemented.
In March 1989. perc was designated a Class 2
Specified Chemical Substance on the basis of statutes
regulating the inspection and production of chemical
substances, resulting in restrictions on lx>th produc-
tion and imports. In line with this designation, the
MHW and the Ministry of International Trade and
Industry (MITI) announced a Guideline on Technical
Measures for Cleaners on Prevention of Environmental
Pollution by Perchloroethylene, which was intended to
eliminate perc pollution from drycleanlng operations.
This guideline recommended methods of storing sol-
vents, and of using, maintaining, and Inspecting dry-
cleaning machines, effluent treatment j equipment,
and facilities. Methods of using exhaust:'air recovery
equipment to control emissions and approaches for
handling sludge were also described. :
Where sludge containing perc is concerned, laws
governing the treatment and cleaning of wastes re-
quire that annual reports detail arrangements for
persons responsible for the treatment of industrial
wastes, notification regarding equipment and facili-
ties, and information on the status of treatment op-
erations. A manifest system is used to track the
treatment process when waste treatment is con-
tracted out to third parties. Moreover, following the
revision of laws last y<;ar, there is a strong possibility
that perc will be designated as a Specially Controlled
Industrial Waste.
In the organic solvent protection regulations in-
cluded In the Labor Safety and Health Law, the control
concentration for the workplace environment In
cleaning plants is stipulated as 50 ppm or less.
For further guidance, the All Japan Laundry and
Drycleaning Association has prepared a handbook
describing appropriate measures the industry should
take to prevent environmental pollution. Perc-using
cleaning operators In Japan are making active use of
this publication. :
CFC-113 and 7, J, 1-Trichloroethane
Although a decision has already been made to totally
eliminate the use of CFC-113 and 1,1,1-trichlo-
roethane in the near lliiture, a policy for rationalizing
the use of these substances has been announced, and
strenuous efforts are being made to minimize emis-
sions from machines still in service that use these
solvents.
Measures to Reduce Residual
Drycleaning Solvents in Garments
Although restrictive measures have been imple-
mented in all areas based on laws concerning direct
environmental pollution from cleaning plants and
equipment the indirect effect of trace amounts of
drycleaning solvents remsiining in garments after they
have been returned to the customer continues to be
a problem. -
Petroleum-Based Solvents
A number of cases of skin problems caused by resid-
ual solvents in garments cleaned with petroleum-
based cleaning fluids has been reported. Also,
complaints made to consumer centers regarding in-
complete drying are increasing. To prevent this prob-
lem, it is essential that garments be dried completely
before being returned to the owner. Figure 1 shows a
device that uses a semiconductor sensor to measure
whether a garment is actually dry. When the'Dry
Checker is applied to the garment, the sensor detects
41
-------
Pollution Prevention: Drycleaning
12-step LED indicators
Red lamp : Still wet
Yellow lamp: Half dried
Green lamp : Drying is finished
Figure 1. Cactus Dry Checker: Device to measure drycleaning
solvent
the vapor of residual solvent and measures the con-
centration (Table 5). If the residual amount Is 60 ppm
or less (green lamp), no danger of skin problems is
posed. With government support, the Industry is
working to ensure general use of this device.
Figure 2, for example, shows the transition of
residual solvents when drying a windbreaker with
Table 5. Relationship among the LED color, solvent vapor
concentration, and degree of dryness.
Color and position
of UK indicator boo
Greet
Yellow
Rtd
*
3
4
1
J'
}
4
?£££??£.
14 or lower
14-25
25-40
40-60
60-100
100-140
140-200
200-300
300-400
400-600
600-1,300
1 300 or over
*onSra
Drjtat
finish td
Half dried
Still wet
Referee
No odor
Very lisle odor
( «ry Ealc solved remains )
Odor (some solvem sdll remains.
which may oase odor)
ofaOhemaaireiaains, which '
Drying In nimbler (60"C. 20 mini-ret)
Drying lime at room temperance (hour)
cowhide parts. Care must be taken in natural drying
since the length of time required varies with tempera-
ture, humidity, and other conditions, and the speed
of drying varies for different parts of the garment.
Fabricated and natural leathers are particularly diffi-
cult to dry, and shoulder pads and linings tend to dry
slower than other parts.
Perchloroethylene
In recent years, indirect pollution of the immediate
living environment in Japan by residual chemicals in
garments has attracted attention. Reports indicate
that some atmospheric pollution in households is
attributable to garments that have been drycleaned
with perc. For this reason, the industry is conducting
research into ways of reducing the residual concen-
tration of perc in drycleaned clothing.
Results obtained from experiments conducted to
date include the following. Table 6 shows the amount
of perc remaining in various fabrics immediately after
they were taken from the drycleaning machine. Resid-
ual amounts ranged from 0.14 to 1.58 mg/g of fabric,
with acetate showing a particularly high concentra-
tion. The results do not seem to be related to the
air-permeability of the fabric.
Table 6. Relationship between fibers and residual amounts of
perc.
Fibers
Type
wool 100%
Wool 93%
Nylon 7%
Polyester 100%
Cotton 100%
Acetate fiber 100%
Polyester 100%
Texture
Twill weave
Twill weave
Circular knitting
Knitted
Plain weave
Twill weave
Mass
(g/m')
273
365
435
154
63
79
Air-permeability
(cm'/cm'/s)
13.4
36.3
185.0
150.5
37.5
27.3
Residual amount of
perc (mg/g)
0.427
0.119
0.139
0.202
1.576
0.515
Figure 2. Effect of drying time on emissions of petroleum-
based solvents from a windbreaker with cow leather (left
shoulder).
Another study considered the effect of finishing
processes on reductions in the residual amount of
perc in garments after they were removed from the
drycleaning machine. Figure 3 indicates that finishing
does reduce the perc content In wool. It was also found
that tumbler drying with heated fresh air followed by
steam-box finishing had approximately the same de-
gree of effectiveness in reducing the residual perc
content Further research is planned.
A simple measurement device capable of objec-
tively determining the residual amount of perc—like
the Dry Checker for use on petroleum-based sol-
vents—is needed. The industry has tested a simple
device that uses a semiconductor sensor, but the
measurement level for residual concentrations is con-
siderably lower with perc than with petroleum-based
solvents. As a result, perc concentrations cannot be
adequately detected with the current technology. It is
42
-------
Pollution Prevention: Drycteaning
I I • O Without preutn]
|4 A Wift prening
136 12
Leaving time (bout)
expected that structund Improvements will lead to the
development of a measurement device capable of
solving this problem.
It should be noted that the tests discussed above
were conducted with duct-system drycleaning ma-
chines. With the recently introduced nonducted,
closed-circuit-system machines, however, the con-
centration in the cylinder is higher, which may lead
to higher residual concentrations in garments at com-
pletion of drycleaning. Study of this drycleaning sys-
tem will be necessary iln the future.
Figure 3. Residual perc in wool fabric with and 'without finish
pressing.
43
-------
Roundtable Discussion Summary:
Residual Reduction
Discussion about residual reduction began
with an observation by Hans-Dietrich Weig-
mann of the Textile Research Institute con-
cerning the results presented by the EPA's Bruce
Tichenor. Dr. Weigmann noted that in the concentra-
tion time profiles from the EPA indoor air study, the
concentrations in the test closet were higher for sam-
ples that had been aired out prior to hanging in the
closet This appeared to be an anomaly. Dr. Weig-
mann hypothesized that if the samples were hung in
areas of higher humidity that this could increase the
rate of desorpUon occurring in the fabric. Dr. Tlchenor
agreed that this was an interesting observation and
that it might explain the results that were obtained.
Judy Schreifaer of New York State Department of
Health inquired about the guidelines for air and water
concentrations of perc in Japan, and whether prob-
lems of perc in food had been looked at. Junji Kubota
of the All Japan Laundry and Drycleaning Association
responded that the regulatory limits for indoor air for
workers are 50 ppm and 0.1 milligrams per liter (pg/1)
for water. To date, neither the authorities nor the
drycleaning industry has looked at concentrations in
food.
Dr. Schreiber then asked Dr. Tichenor if the EPA
had looked at the absorption and desorption of build-
ing materials such as wallboard. Dr. Tichenor re-
sponded that other EPA studies had looked at the
so-called sink effect and found that most organics are
absorbed by materials such as wallboard, carpet,
ceiling tile, and upholstery, and that it can take
months for these materials to release all of the per-
chloroethylene they may have absorbed. Dr.
Schreiber indicated that this is what had been found
in their studies in New York. Perc levels in apartments
took a long time to fall after drycleaning operations in
the buildings had been shut down.
Tom Robinson of the Halogenated Solvents Indus-
try Association reopened the debate from the previous
panel on whether increased airflow in the drying stage
is sufficient to reduce residuals in clothing. Dr. Weig-
mann responded that the rate-determining step
seems to be the diffusion of perc to the fiber surface,
not desorption from the surface. If this is true, then
boosting airflow will not help reduce residuals. Man-
fred Wentz of R.R. Street added the opinion that, even
if increased airflow could reduce residuals, the length
of time necessary to aerate the clothing would not be
practical.
Scott Lutz of the Bay Area Air Quality Manage-
ment District suggested that the key to consistently
low residuals is automation of the drying cycle with
inline continuous monitoring of air concentration
such as is required in Germany.
Jack Lauber of the New York Department of En-
vironmental Conservation wondered about the effec-
tiveness of the azeotropic vapor condensation
systems, which humidify the air passing over the
clothes to increase the amount of perc given up. Dr.
Weigmann agreed that raising the humidity will in-
crease the desorption rates of cellulosic fibers such as
cotton, wool, and, to a lesser extent, silk and nylon
(but not polyester). Dr. Wentz cautioned, however,
that by adding moisture and combining it with me-
chanical action there is an increased possibility of
fiber damage and shrinkage, which defeats the whole
purpose of drycleaning.
Elizabeth Bourque of the Massachusetts Depart-
ment of Health admitted some ignorance concerning
alternative solvents used for drycleaning and asked
for information on their advantages and disadvan-
44
-------
Pollution Prevention: Dryctearimg
tages. In particular, she wondered why in Japari'some
70 percent of drycleaning is done with petroleum
solvents, as shown in Mr. Kubota's slides. Shozo
Tamura of Nippon Mining Company explained liiat in
Japan the industry had historically used petroleum
solvents but that, due to the fire hazards, :lj: had
gradually switched to perc. Some 70 percent of ma-
chines in Japan operate with petroleum solvent; how-
ever, over 50 percent of clothes are cleaned usinig perc.
Dr. Wentz explained that petroleum solvent had been
and still is used in the United States, but that it has
been mostly phased out, for three reasons: (1) the fire
hazard, (2) the photochemical reactivity, and (8) the
presence of aromatics that are carcinogenic. Bill
Fisher of the International Fabricare Institute indi-
cated that approximately 15 percent of drycleaners in
United States still use petroleum solvents but that
their use is increasingly rare. In most urban areas it
would not be possible to establish a new petroleum-
based operation because of the stringent fire codes.
Mr. Fisher also pointed out that solvent substitution
is not just a matter of draining out the perc from the
machine and replacing it with an alternative. Since
perc substitutes cannot be used with the existing
equipment the operator woiild be looking at complete
equipment replacement as well.
Ken Adamson of the Launderers and Drycleaners
Institute of Ontario provided a final comment on the
operator's perspective concerning replacement of
equipment He suggested that the operators need to
know that the equipment they purchase will be suffi-
cient to satisfy regulatory lequirements for the next
10 to 20 years if there is to be any chance for payback.
No operator would replace: his equipment if it ap-
peared that the regulations would be changing again
in 4 or 5 years.
45
-------
-------
FOOD AND RESIDENT
EXPOSURE REDUCTION
-------
-------
Perchloroethylene Levels in Foods Obtained
near Drycleaning Establishments
,i \
Gregory W. Diachenko, Ph.D. |
Center for Food Safely and Applied Nutrition '
U.S. Food and Drug Administration ! [
Dr. Diachenko Is a branch chief in the FDA's Division of Food Chemistry and
Technology with 20 years of experience studying chemical contaminants in '•
food. He has been the lead FDA scientist on numerous food contamination :
incident investigations, including several dealing with volatile halocarbons
such as perchloroethylene. His research o:ci chemical contaminants and addi-
tives in food has been reported in more than 25 scientific publications and !
numerous presentations. Dr. Diachenko holds a Ph.D. in chemistry, with a i
specialization in environmental and analytical chemistry, from the University
of Maryland. "•
Findings of low levels (generally <100 ng/kg) of
volatile halocarbons (VHCs) such as chloro-
form, 1,1,1-trichloroethane, trichlo-
roethylene. and perchloroethylene (PCE) in foods have
been reported by several investigators {[Jhler and
Diachenko. 1987; Daft. 1988; Heikes. 1987; Entzet
al.. 1982). The data generated by Heikes (1987) on 231
different foods from the U.S. Food and Drug Admini-
stration's (FDA) Total Diet Survey indicate that back-
ground levels of PCE in foods are generally; less than
50 (ig/kg (Table 1). In 1988. Entz and Diachenko
reported finding PCE in four margarines at levels (500
to 4,000 jig/kg) significantly above the usual back-
ground levels (Table 2). Those margarines had been
obtained from a food store located immediately next
to a drycleaning establishment. A follow-up investiga-
tion was conducted by Miller and Uhler !(1988) to
determine the frequency of occurrence and levels of
PCE that may be present in fatty foods purchased
from stores located both near and distant from dry-
cleaners. !
Miller and Uhler (1988) examined 46 butters col-
lected from 14 retail outlets in the Washington, DC,
area to determine the incidence and levels of PCE.
Butter was chosen as a model food because it is a
uniform product with very high fat content that would
be expected to act as a good absorber of PCE. Butters
were purchased from food stores located next to or at
various distances from drycleaners as well as stores
located where there were no drycleaners irrthe vicin-
ity. As suspected from the previous work by Entz and
Diachenko (1988), butters obtained from stores lo-
cated near drycleaning establishments contained ele-
vated levels of PCE (Figure 1). The butters-; collected
from stores with no drycleaners nearby: generally
contained less than 50 ppb of PCE. However, many of
I No Dry Cleaner Near Store ts Stores)
£23 Dry Cleaner 1-2 Stores Away
629 (6 Stores)
| \ Dry Cleaner Next to Store (3 Stores)
:R-
-------
GregoryW. Diachenko
Table 1. Ten residues determined from 231 food samples examined.
Item
Amount determined, ng/g
Fat
content
Grain
based
(gb)
CSj CO,
CP
EDB EDC CHCIj
CH^CO, , PCE TCE
Cereals
Cornflakes non
Fruit flavored cereal non
Shredded wheat cereal non
Raisin bran cereal non
Krisped rice cereal non
Granola. plain non
Oat ring cereal non
Rolled oats, cooked non
Farina, cooled non
Corn grits, cooled non
O2s/dressings
Salad dressing, Italian 72.4
Vegetable oil, com 100.0
Mayonnaise, bottled 80X1
Vegetables
Pinto beans, boiled non
Pork & beans, canned non
Coo/peas; boiled non
rimi beans, mature non
T3m* beans, immature non
Navy beans, boiled ' non
Red beans, boiled non
Peas, green, canned non
Peas, green, boiled non
Rice, white, cooked non
Corn, boiled non
Com, f?nn*^ non
Com, cream style non
Spinach, canned • non
Spinach, boiled non
CoUards, boiled non
Lettuce, raw son
Cabbage, boiled non
Coleslaw, with dressing 15.7
Sauerkraut, canned noa
Broccoli, boiled non
Celery, raw non
Asparagus, boiled non
Cauliflower, boiled . non
Tomatoes, raw non
Tomato juice non
Tomato sauce non
Tomatoes, canned non
Green beans, boiled non
Green beans, canned non
Cucumber, raw non
Squash, summer, boiled non
Sweet pepper, green, raw non
Squash, winter, boiled non
Carrots, raw non
Onions, raw non
Mixed vegetables, canned non
Mushrooms, canned r non
Beets, r^pn*^ non
Radish, raw non
Onion rings, cooked 12.7
French fries, cooled 6.0
Mashed potatoes 5.0
Boiled potatoes non
Baked potatoes non
Scalloped potatoes 4jO
Sweet potatoes, baked non
Sweet potatoes, candied non
Cream or potato soup non
Vegetable beef soup non
Pickles, dill non
Catsup • non
Strawberry gelatin non
gb
gb
304
440
100
68
48
52
240
1440
4400
1760
920
4
6
22
6
35
8
3
760
1200
280
25
100
44
30
72
9
14
10
28
31
12
24
52
20
22
11
8
3
17
14
108
40
14
2
2
1
21
50
-------
PoJWion Prevention: Drycfearang
Table 1. Ten residues determined from 231 food samples examined (continued).
Bit
Gcun
Item
CO. CP EDB EDC CBO, CBfk CBjOO, KE ICE
Bated goods
Popcorn, popped 295
While bread, enriched 33
While rolls, soft 52
Combread. southern 9A
Biscuits, baiting powder 7A
•Whole wheat bread 23
Flour tortilla 42
Rye bread ZO
Muffins, blueberry &6
Sattine crackers 7.7
Com chips 283
Pancakes 6-7
Noodles, egg, cooled non
Macaroni, cooked non
Potato chips 28.4
Macaroni and cheese 5.4
Chocolate cake/king 163
Yellow cake 9.7
Coffeecake, frozen 126
Donuts, cake, plain 217
Sweet roll, Danish 13.7
Cookies, chocolate chip 225
Cookies, sandwich 19.8
Apple pie, frozen 105
Pumpkin pie, frozen 73
Nuts/nut products
Peanut butter, creamy 57.1
Peanuts, dry roasted 435
Pecans 63.1
Dairy products
Whole muk 3.7
LowfatmBk 2JO
Chocolate milk 2jfi
Skim milk non
Buttermilk non
Yogurt, plain 14
Milkshake, chocolate 3A
Evaporated milk 75
Yogurt, strawberry 14
Cheese, processed 2&0
Cottage cheese 43
Cheese, Cheddar 3L4
White sauce 125
Margarine, stick 80.0
Butter, stick SOuO
Cream, half & half 9.0
Cream substitute 215
Ice cream, chocolate 13j6
Instant pudding, chocolate 3.0
Ice cream sandwich . 95
Ice ™i"r, vanilla 3.4
Sugars, jams, candy
Sugar, white non
Syrup, cane non
Jelly, grape non
Honey non
Candy, milk chocolate 28j6
Candy, caramel . 8.1
Chocolate powder, sweet 2Jo
Meats/meat dishes
Beef, ground, fried 205
Beef, chuck roast , 20.1
Beef, round steak, stewed IZD
Beef, sirloin, cooked 16J8
Pork. ham. cured 105
Pork chop, cooked 18£
Pork, sausage, cooked 37.6
i-
2 12
44
52
96
X
It
16
56
128
136
132
76
56
40
48
60
32
72
40
84
10
14
9
96
52
312
15
79
130
124
«.
104
14
22
64
48
34
US
68
68
4CD
4CS
720
10(0
760
Wt
«4
72
320
228
11
7
9
3
8
2
40
40
14
17
29
8
28
14
10
24
228
1
5
152
2
8
16
10
13
18
4
4
1
15
520
15
If
3
14
6
4
12
6
7
48
8
30
6
3
16
4
18
6
6
20
12
8
12
16
6
3
120
2
2
17
6
2
3
21
2
30
2
15
2
28
2
20
94
8 2
6 4
- 9
10 9
5 1
76 3
7 19
Source: Heikes. 1387.
51
-------
GregoryW. Diachenko
the butters from stores located near diydeaners had
elevated levels of PCE ranging from 100 to 1,000
pg/kg. Generally, butters from stores located Imme-
diately next to drycleaners had higher PCE levels than
those from stores that were one or two stores removed
from drycleaning operations.
Similar elevated levels of PCE have been reported
by German Investigators (Vlethsetal., 1988, 1987) in
fatty foods collected from private apartments and
grocery stores located near drycleaning estab-
lishments or in the same building. The reported PCE
levels were highly variable, ranging from <2 to 41,850
Hg/kg In foodstuffs from apartments and from 5 to
18,750 Jig/kg in foodstuffs from grocery stores near
drydeaning establishments (Tables 3 and 4). Vleths
et al. (1988) demonstrated similar elevated PCE levels
(90 to 29,700 Ltg/kg) In synthetic fat exposed to the
air In these apartments for 14 days. He also noted that
the sealed packaging of a commercial margarine of-
fered no long-term protection against PCE contami-
nation by partitioning from air. Reinhard et al. (1989)
and other German investigators found that a signifi-
cant enrichment of PCE occurs in butter and sweet
cream with Increasing storage time in apartments
near drydeaning operations (Table 5). PCE concentra-
tions greater than the German Federal Health Office's
(EGA) allowable limit of 1.0 mg/kg for marketable
foodstuffs were exceeded in butter from four of the five
apartments after 7 days refrigerator storage.
The previously cited PCE findings, combined with
the widespread use of PCE as a drydeaning fluid,
suggest that aerial transport of the vapors from the
Table 3. Tetrachloroethylene (TCE) in food from retailers In the
Immediate vicinity of drycleaning establishments.
Case 4. Supermarket next to a drycleaner
4.1 Samples taken 3/5/87 at 4:40 p.m.
Table 4. Tetrachtoroethytene (TCE) levels In foodstuffs from
test locations.
Sample
TCE in /tg/kg
Margarine
Herb butter
110
7
42 Samples taken 3/25/87 at 4:40 p.m.
Sample
TCE in pg/kg
Cheese spread
Butter
Flour
Comstaich
36
21
25
36
Case 9. Drydeaning establishment
9.1 Samples taken 5/11/87 at 11:15 aun.
Sample
Fruit ice*
Chocolate-coated ice cream
Chocolate & nut-coated ice cream
Ice cream confection
2
1,330
4,450
18,750
Apartment
Sample
TCE Level
Storage
B
B
B
B
B
C
C
C
C
C
garlic butter
vegetable oil
margarine 1
oatmeal
flour
cocoa
flour
margarine 2
margarine 3
margarine
120
15
30
<2
<2
1,340
860
3300
5,070
41,850
a 2 months
several weeks
several weeks
several weeks
several weeks
several weeks
several weeks
10 days
several weeks
several weeks
Source: Vieths et aL. 1988.
Table 5. Concentrations of tetrachloroethylene (TCE) In Indoor
air and In fat-containing food after 1,3,5, and 7 days of storage
in test locations in the vicinity of drycleaning establishments.
Day
Outdoor
0
1
3
i
7
Outdoor
0
1
3
5
7
Apartment 1
Indoor Sweet
Air Butter . Cream
(Mta1) (n.s/18) (mg*g)
13.68
891.56 0.0012 0.0068
1.790.80 0307 OOIO
649J2 O54B 0.035
1,447.58 0.794 0062
2356.46 L67 O.U7
Ap^en.4
13834
1.049.04 00055 0.0016
19.46 27 O002
U6&34 0.205 0004
17065 0*77 0045
484.91 L491 O054
Apartment 2
Indoor Sweet
Air Butter Cream
(MgAn1) (ma*8)
-------
Investigations of Indoor
in Residences above
Establishments
Air Contamination
Drycleaning
Judy S. Schreiber, Ph.D.
Bureau of Toxic Substance Assessment j
New York State Department of Health ;
i i
Dr. Schreiber Is a senior research scientist at tiie New York State Department
of Health with extensive experience in assessing human exposure and health
risks related to chemicals. She is actively involved in efforts to improve the in-
door air quality in buildings where drycleaning establishments are located.
Dr. Schreiber holds a doctorate in environmental health and toxicology from
the State University of New York's School of Public Health.
I would like to begin this presentation with some
recommendations that the New York State De-
partment of Health made to the EPA ;on its
proposed regulation covering drycleaning operations
under the Clean Air Act In its 1987 report
-------
JudyS.Schret>er
environmental protection efforts should be targeted
by the EPA to reduce exposures and related risks.
We initiated the study as a result of finding ele-
vated tetrachlorethene concentrations measured in
an apartment above a drycleaning facility in Mahopac,
New York CTable 1). The results of our investigations
and studies in residences above drycleaning estab-
lishments provide the exposure data necessary to
assess the health risks to these residents. I believe
that the projected public health risks are significant.
We are particularly concerned because residents can
be exposed up to 24 hours a day. Certain segments of
the population that may be at increased risk—such
as the chronically ill. the elderly, infants, and chil-
dren, and pregnant or lactating women—tend to
spend a majority of their time at home. The degree to
which residents may be exposed to tetrachloroethene
in their homes is related to the practices of the dry-
cleaner, the types of machines used for cleaning,
building characteristics, and the proximity of the
residents to the drycleaning facility.
The small drycleaning establishment located in
Mahopac, New York, which is upstate, is located next
to a pharmacy with apartment units above. We first
looked into this situation as a result of complaints
received from the residents of the apartments. Sam-
ples were taken in the bedroom where an infant
resides directly above the drycleaning shop.
hi that bedroom we found a level of 197,000
mJ/m3* in indoor air based on a sample of about four
hours duration. On the window ledge outside of the
building we measured 1,900 pg/m3 and in the second
floor there was a lower level of 5,300 jig/m3 . For
comparison, in our Albany study we found a back-
ground level of tetrachloroethene in indoor residential
airof28ng/m3.
The first set of samples was taken in the apart-
ment while drycleaning machines were operating
downstairs. The next set of samples was taken when
drycleaning was not being carried out. The dryclean-
ing operations had stopped because the Putnam
County Health Department—acting on our recom-
mendation—had closed the drycleaning shop because
of the nuisance and health impact on the residents in
the building. A level of 14,500 ng/m3 tetrachlo-
roethene was measured while pressing but no active
drycleaning was being carried out in the facility below.
It happened that during the time we were gathering
our sample there was a small spill of tetrachlo-
roethene in the drycleaning facility that we detected
very clearly in the apartment above, where we meas-
ured 41,000 pg/ms several hours after. Clearly even
small spills can have a significant impact on the
indoor air quality of residences above a facility.
After measuring very high levels at this particular
location we became interested in whether our findings
were typical for apartments located in buildings where
drycleaners operate. Thus we decided to undertake a
study in the Albany area, looking at apartments lo-
cated above drycleaning establishments.
For this study we gathered two 12 hour samples,
using evacuated canister samples that our laboratory
set up so that when one canister had completed a 12
hour sampling it would automatically switch over to
the next one for the second 12 hour period. We took
samples consecutively from 7 a.m. to 7 p.m. (called
the daytime sample), and from 7 p.m. to 7 a.m. (the
nighttime sample).
At one of the drycleaning establishments that we
studied, the vent pipe was exhausting directly out of
the building at the first floor level, directly below
apartment units. It is easy to understand how such
an arrangement can contribute to the levels of con-
taminated air we found in the apartments above
drycleaners. As indicated in the report that was cir-
culated (see Supplemental Material appendix), the
Health Department worked with our State Depart-
ment of Environmental Conservation staff to make
various measurements and observations at dryclean-
ing establishments as well as in the apartments
above. We then tried to correlate the conditions in the
drycleaners (including, for example the type of ma-
chinery that was used) and the air quality results that
we found in the apartments above. In some locations
leaky vent pipes were held together with socks—not
quite an air-tight approach.
Table 2. Tetrachloroethene concentrations for study and con-
trol residences ((ig/m3).
Residence
itudv Hoaes
Residence 1 (0)
Residence 2 (T)
Residence 3 (T)
Residence 4 (T)
Residence S (0)
Residence 6 (0)
Control homes
Residence Cl
Residence C2
Residence C3
Residence C4
Residence C5
Residence C6
Tetrachloroethene
Indoor
AM
55,000
17,000
3,850
1,730
440
300
<6.7
103
<6.7
<6.7
44
9.7
PH
36,500
14,000
8,380
1,350
160
100
<6.7
77
<6.7
<6.7
56
22
Tetrachloroethene
Outdoor
AM
2,600
1,400
530
1,110
195
300
<6.7
21
<6.7
<6.7
<6.7
16
PH
360
1,400
812
441
66
400
<6.7
<6.7
<6.7
<6.7
<6.7
,6.9
*1 ppm - 6,890 \sglm3 or 6.89 mg/m3
Study residence above dry cleaner using:
0 = old dry-to-dry unit - '
D = dry-to-dry unit
T = transfer unit
Source: New York Slate Department rfHeiaJth. Bureau of Toxic Substance Assessment
54
-------
Pollution Prevention: Drycleaning
Table 3. Summary of tetrachloroethene concentrations for
study and control residences (fig/m3). :
Simple Type/Residence Type (number)
Indoor Air, AN
Study boats (6)
above 'transfer' cleaners (3)
above 'dry-to-dry' cleaner; (2)
ibove old dry-to-dry unit (1)
Control homes (6)
Indoor Air, FH
Study hows (6)
»bove 'transfer' cleaners (3)
above 'dry-to-dry1 cleaners (2)
above eld dry-to-dry unit (1)
Control horaes (6)
Outdoor Air, AH
Study tows (6)
outside "transfer1 cleaners (3)
outside 'dry to dry' cleaners (2'
outside old dry-to-dry unit (1)
Control hoses (6)
Outdoor Air, m
Study hoces (()
outside 'transfer1 cleaners (3)
outside 'drjrto-dnr' cleaners (2]
outside old dry to dry unit (1)
Control homes (6)
Tetrachlortietbene
Range
300-55,000
1,730-17,000
300-440
55,000
«8. 7-103
100-36,500
1,350-14,000
100-160
36,500
<6. 7-77.0
195-2.600
530-1.400
195-300
2,600
<6.7-21
66-1.400
441-1400
66-400
360
<8.7-6.9
Mean
i
'13,000
, 7.500
370
1 55,000
' 28
10,000
7,900
i 130
' 36,500
'28
1 1,000
'• 1,000
250
1 2,600
8.4
580
880
r 230
360
i3.9
Source: New York Stale Department of Health. Bureau of Toxic Substanto Assessment
A summary of the results from this study are
shown In Tables 2 and 3. The six study apartments
were the only units In the Albany area located In
buildings where active drycleaning operations using
tetrachlorethene are carried out. Several more that
are in buildings where drycleaners use Stoddard sol-
vent were not evaluated at the time because we were
specifically evaluating tetrachloroethene. The first
residence studied is located above a drycleaning es-
tablishment using an older model dry-to-dry unit in
very poor operating condition. The gaskets were not
functioning property, and it was a very poorly main-
tained and operated machine. The second, third, and
fourth residences are located above drycleariers using
transfer machines. The last two residences are above
drycleaning establishments using dry-to-dry machines.
Clearly the indoor air in the apartment building
with the old dry-to-dry unit (Residence 1) Had very
high levels of tetrachloroethene. In the daytime sam-
ple, we measured 55,000 ng/m3 tetrachloroethene,
which decreased to 36,500 pg/m3 at night This was
a consistent trend. Although the contaminant levels
decreased at night, the levels remained quite elevated.
In Residence 3, levels were higher at night thiin in the
daytime. We called back to this particular drycleaner
to see whether perhaps the owners were running some
loads of drycleaning in the evening, and were told they
were not; I do not have an explanation for why the
night sample is higher than the daytime sample. In
most residences the levels at night stayed about 40 to
80 percent of what they were in the daytime period.
At the time, we were very surprised by this finding,
since we had expected that levels in the apairtments
would be elevated during the daytime period, when
active drycleaning was being carried out, and would
drop substantially at night. For the most part, piis did
not occur. Table 3 shows some of the daytime and
nighttime average levels that we used as a basis for
our risk and exposure assessments.
Also of note is that the indoor levels were consis-
tently higher than the outdoor levels. While this alone
is not surprising, it is interesting that some of the
outdoor levels also were: considerably elevated. The
outdoor samples were taken using tubing extended
out of the apartment to. 3 or 4 feet away from the
building (the complete methodology is presented in
the report). In general, the contaminant levels followed
the same patterns outdoors as indoors.
It is important to understand that although a
particular drycleaning o;peration may consume very
small amounts of solvent compared to large industries
that consume tens of thousands of gallons of solvents,
drycleaners can have a significant impact on the
indoor air quality of nearby residences. Some dry-
cleaners may only use a few hundred gallons of
solvent per year, but the small solvent consumer can
have a very large local impact. Whether the drycleaner
operation is consuming 200 to 300 gallons per year of
solvent (the cutoffs in the proposed EPA regulations)
matters little with regard to the impact on residences.
Six control homes were evaluated at the same
time as the study residences using the same method-
ology—two consecutive 12 hour samples. Our detec-
tion level is 6.7 ng/m3. The contamination levels in
control residences were consistently and significantly
lower than in the study residences. The highest indoor
air tetrachloroethene measurement for the control
residence was 103 ng/mjl. The 24 hour mean for the
six control residences was 28 ng/m3. Table 3 shows
the range and mean values for the study residences
by machine type used in the drycleaning estab-
lishment. The three apartments located above clean-
ers with transfer machines had a 24-hour indoor
contaminant level of 7.300 tetrachloroethene. The
apartment over the one older model dry-to-dry unit
had levels of tetrachloroetherie of 45,750 ng/rn3 for
the 24 hour average. Apartments above the well-run
dry-to-dry cleaners had the lowest tetrachloroethene
levels of the study apartments, with a 24 hour mean
concentration of 250 pg/m3. Table 4 shows data from
studies conducted at apiartrnents in a Manhattan
high-rise building and Table 5 shows data from a
high-rise building in Yorikers. Both buildings were
found to have elevated tetrachlorethene concentra-
tions on floors well above the drycleaning operation.
In some cases residential levels were found to be
higher than levels measured in areas where workers
were pressing clothes and areas where others were
staffing the customer counter. A National Institute of
Occupational Safety and Health (NIOSH) study cites
an average exposure of about 40 mg/m3 (40.000
, Mg/m3) for those workers. .Apartment residents can be
55
-------
JudyS. Schieiber
Table 4. Results of Manhattan high-rise residential building
sampling (September 1991) (iig/nr).
Location AM PM
Second floor indoor
Second floor indoor
Fourth floor indoor
Seventh floor indoor
Twelfth floor indoor
Second floor outdoor
Twelfth floor outdoor
62,000
7,600
5,700
2,600
6,000
6,700
1,900
48,000
16,000
1,200
400
5,900
3,900
450
Tables. Results of Yonkers high-rise residential building sam-
pling (August 1991) (ng/m3).
Location
Study -First floor
Study -Third floor
Study -Fourth floor
Study -Outdoor
Control - Second floor
Control -Outdoor
AM
226
609
426 '
189
51
29
PM
157
918
271
174
44
47
subject to an exposure duration three times longer
than -workers experience in a drycleaning shop. Theo-
retically, people who work in drycleaning shops are
exposed eight to ten hours per day. Residents, how-
ever—possibly a mother and newborn—could have an
exposure period of 24 hours per day. Therefore, a
resident could have an occupational level of exposure
with three times the occupational exposure time. We
are concerned about the residential exposures in
apartments, especially those above drycleaning facili-
ties using transfer machines or older model, poorly
maintained dry-to-dry machines.
The control apartments in our study had an
average of 28 ng/m3, which is consistent with other
studies. For instance. Dr. Lance Wallace, who did a
lot of work on the TEAM studies looking at indoor and
outdoor levels of various contaminants in background
populations, found an average of 27 pg/m3 in the
several hundred homes studied across the country.
Our results are in agreement with his measurements
for control residents. Thus we feel confident that the
information that we generated In our study is accu-
rate. Indeed, we were surprised at the magnitude of
exposure in some apartments.
The odor threshold for tetrachloroethene is a very
unreliable indicator of exposure. It is cited as ranging
from 5 to 50 ppm, or about 35.000 pg/m3 and
greater—well above what we believe is acceptable in
apartments. If a person calls and complains about
periodic odors in an apartment, it is likely that the
average levels in the residence are at least over 1.000
pg/m3, and probably above 10,000 pg/m3. This
points out the insidious nature of exposure to emis-
sions from drycleaning operations. People may be
exposed to moderate to high levels of emissions but
not recognize that exposure is taking place since often
the odor is not detectable.
In the Albany study we looked at various routes
of transport for the tetrachloroethene from the dry-
cleaning establishment to the apartment and found
that building characteristics such as pipe chases, air
vents, stairwells, and missing ceiling tiles can be a
factor. Hot water pipes that go from one level of a
building to another level provide a very effective route
for the solvent vapors to follow. A chimney effect
results because air and heat travel up and throughout
the building. Among the parameters we measured,
the tetrachloroethene concentration at the pressing
station in the drycleaning facility was the best predic-
tor of the concentration found in the residence above.
Since we have not conducted studies on horizon-
tal mapping, I cannot show what the isopleth of
tetrachloroethene levels would look like if there were
20 apartments on each floor. Since each apartment
building and air management system is different, as
are the operation and maintenance practices in the
drydeaning establishments, it is very difficult to pre-
dict contaminant levels without direct measurement.
Unfortunately, the evaluation of individual dry-
cleaners and building characteristics is very time-
consuming. So far our investigations have involved
our county health departments and the health depart-
ment in New York City. It takes a lot of staff time to go
in, make an assessment of the drycleaning operation,
take a look at the apartments, and take some air
measurements. We really need some assistance—I
believe from the EPA—in organizing an effort to take
a closer look at some of these residential exposures.
Some of the drycleaning establishments—if they are
operated properly and have good controls, if the own-
ers don't leave open vats of solvent around, if they
change their filters and have a adequate ventilation
and a good machine—can be good neighbors. But
there also certainly is a problem with contamination
of air in apartments coupled with a large potentially
exposed population, and we believe that to be a very
critical area that we need to look at more closety.
Finally, with regard to Dr. Diachenko's presenta-
tion, I have done some work looking at maternal
airborne exposures and modeled what might result in
breast milk. Using pharmacokinetic techniques for
modeling a mother's inhalation of solvents and the
distribution through tissue, and making some esti-
mates of tissue concentrations, I have developed esti-
mates of levels of tetrachloroethene that might be
found in breast milk. These estimates are consistent
56
-------
Pollution Prevention: Drycleaning
with the results of two studies in which tetrachlo-
roethene was measured in breast milk. I think this is
another area deserving of investigation and study.
There are no studies that have looked,at neuro-
logical effects or other noncancer health effect end-
points in infants and children who live in apartments
where they are exposed to very high solvent emission
levels in the critical first two years of life, when there
is a very real possibility of both acute and chronic
central nervous system effects. I think environmental
and public health officials have an obligation to take
a look at this problem. I urge EPA to see if funding is
available for such a study.
57
-------
Roundtable Discussion Summary:
Food and Resident Exposure Reduction
Discussion about food and resident exposure
reduction focused on the means through
•which perchloroethylene vapors enter into
apartments and food establishments, and on the po-
tential risks to persons exposed in apartments.
Edward Stein of the Occupational Safety and
Health Administration (OSHA) asked whether the New
York State study had measured exposures of workers
in the drycleaning shop as •well as residents in up-
stairs apartments. Judy Schreiber of the New York
State Department of Health responded that worker
exposures had been measured as part of the study,
but that they were more interested in exposures of
apartment residents. Their focus on apartment resi-
dents was due to several factors, such as (1) residents
may be more sensitive than the average worker (e.g.,
pregnant mothers, invalids): (2) residents may be
exposed for longer periods than the average worker.
and (3) unlike most workers, apartment residents may
be unaware that they are being exposed.
Steve Risotto of the Center for Emissions Control
asked about the routes by which perc moves into
upstairs apartments. Dr. Schreiber indicated that
there are a variety of potential routes, including ven-
tilation shafts, stairwells, holes in ceilings, pipe
chases, and elevator shafts. The limited number of
facilities examined so far in the Albany study, how-
ever, did not permit any conclusions to be drawn. Mr.
Risotto also asked whether elevated concentrations in
upstairs apartments had been correlated with high
levels in the drycleaning shop, or whether solvent
spills may have been a factor. Dr. Schreiber re-
sponded that, based on some preliminary statistical
evaluation, the perc levels at the pressing station were
the best predictors of the levels measured in upstairs
apartments, and so they did correlate well with the
levels in the shop downstairs. More extensive sam-
pling and investigation to be conducted at facilities in
New York City with the New York City Department of
Health should provide better data.
Bruce Tichenor of EPA pointed out that studies
done in high-rise buildings had found elevated levels
of radon gas in upper level apartments. This indicates
a possible general tendency for airborne pollutants to
spread from lower levels throughout these types of
buildings.
Dr. Schreiber discussed risk modeling she had
performed based on concentrations measured in
apartments in Albany. Her models predicted average
concentrations of 6.2 n/1 to a maximum of 3,000 jo./l.
Previous studies of nursing mothers had found con-
centrations of perc ranging from non-detect to 43 ji/1.
Her models also indicate that occupationally exposed
women could accumulate breast-milk concentrations
of up to 8,000 JJ./L A paper based on this modeling will
soon appear in Risk Analysis Journal.
Dr. Stein asked whether any medial or health
surveys had been performed among residents living
upstairs from drycleaners. Dr. Schreiber responded
that, to her knowledge, none had been done so far.
She further suggested that there is a definite need for
such a study, particularly among children living in
such apartments, and that New York State would be
happy to work with any federal agency interested in
sponsoring such an investigation.
Bill Seitz of the Neighborhood Cleaners Associa-
tion pointed out that in all cases where drycleaners
had been shut down by the state because of concern
for apartment residents, the operators had been able
to make the necessary repairs or equipment modifi-
cations and had been permitted to reopen. Dr.
58
-------
Pollution Prevention: Drycleaning
Schreiber confirmed that this was in fact true, and
illustrated the fact that the problem can be solved
without major expenses.
Dr. Schreiber commented that one additional
finding of the New York State study concerned the
absorption of perc by carpeting, wallboard, tiles, and
other building materials. After shutting down several
facilities, elevated perc levels could still be detected
for some time, suggesting lhat building materials can
act as a sink for the solvent, vapors. She indicated that
it is also the case that elevated body burdens of perc
take some time to fall to background levels following
withdrawal from the exposure source.
59
-------
-------
GROUND-WATER
CONTAMINATION
-------
-------
Investigations of Ground-Water
Contamination by Perehloroethyleine
in California's Central Valley
Wendy L Cohen
California Regional Water Quality Confro/ Board
Ms. Cohen, a registered civil engineer, oversees inspections, investigations,
and the cleanup of leaking underground tanks at bulk fuel terminals for the
California Regional Water Quality Control Board, Central Valley Region. Re-
cently she directed a program for determining the sources of volatile organic
compounds in municipal water supply wells. She is chairwoman of the
American Society of Civil Engineers' Ground Water Committee, and holds an
M.S. in civil engineering and a B.A. in environmental sciences from the Uni-
versity of California.
There are nine Regional Water Quality Control
Boards in California divided along the state's
hydrologic boundaries, and I work for the
Central Valley Region, which covers the largest area.
The boards implement the state Porter-Cologne Water
Quality Control Act and the federal Clean Water Act
A 1984 state law required all municipal water
systems using ground water and serving moire than
five connections to test their water for volatile organic
compounds (VOCs). To date, more than 750 wells in
the Central Valley have shown confirmed levels of
VOCs. More than 35 percent of those wells contain
perchloroethylene (PCE), many of them with levels
above the drinking water standard of 5 ppb. The
polluted wells are found throughout the region in
cities that are totally dependent on ground water for
their water supply (Figure 1). i
We have investigated the sources of PCE, in sev-
eral of these cities by inspecting PCE users, conduct-
ing soil gas surveys, and sampling sewers arid have
identified the likely PCE source in 21 wells. For 20 of
those, the likely source is drycleaning operations,
which are the only large-quantity users of PCE in the
areas of these investigations. Most of these Central
Valley cities do not have industries that use large
volumes of PCE. Pollution in the twenty-first well,
however, was caused by an industrial facility:
We have conducted passive soil gas surveys in
several of these cities using a glass tube containing a
wire coated with charcoal adsorbent placed a.bout 12
inches below the ground, with the open end down, for
about six weeks (Figure 2). Vapors in the soil enter the
tube and adhere to the adsorbent. The sample is then
analyzed in the lab by gas chromatography/mass
spectrometry. Rather than yielding results In' actual
CHICO
OROVILLE
ROSEVILLE
SACRAMENTO
ROVE
LODI
STOCKTON
MODESTO
PATTERSON
TURLOCK
MERCED
LOS BANDS
FRESNO
VISAUA
PORTERVILLE
xBAKERSRELD
Figure 1. California Central Viilley cities with municipal wells
degraded by PCE.
concentrations, the tests provide PCE ion counts, with
higher counts correlating to higher concentrations.
Wherever ion counts exceed 100,000 and moni-
toring wells were installed,, PCE levels in ground water
have exceeded the drinking water standard. The soil
gas survey is used exclusively for screening. Once a
high PCE area is identified, more definitive investiga-
tive techniques are used, such as monitoring of the
well installation. :
63
-------
WendyL Cohen
PYREXTUBE
Figure 2. Illustration of soli gas tube device used for sample
gathering.
One of our surveys was carried out In Modesto,
where a third of the city's wells contain PCE (Figure
3). The darker shading on the map indicates areas of
higher PCE ion counts, and the crosshatchlng shows
the sewer lines. This and our other surveys were
conducted In residential and retail areas with little or
no industry, to eliminate the possibility that large
quantity users of PCE could have caused the pollu-
tion. If other PCE sources were present, they would
be found with the soil gas survey. However, the only
place we have found high PCE in soil gas is at dry-
cleaning establishments.
At one drycleaning establishment (Ideal Clean-
ers), the ground-water gradient is to the south, so we
would expect the pollution to migrate in that direction.
However, notice that an arm of high PCE that was
detected in soil gas testing is heading west. Looking
more closely, one can see that the PCE is following the
sewer line. At another drycleaning establishment, one
,
CITY OF MODESTO
WELL 11, 14 & 21
SOIL GAS SURVEY
AND .
SEWER LINE LOCATIONS
PCE ION COUNTS
(rntnowMIlM)
10-50
50-150
% ,150
© MunlcpalW.il
E Activa Dry CUanar
UJ Inactive Dry Cltwor
g OthtrBuildng*
Figure 3. Soil gas survey results for Modesto, California.
arm of the PCE plume is pulled to City Well 11, while
another one moves west along the sewer line.
Figure 4 shows four drycleaning operations in
downtown Merced. At Merced Laundry (far right on
CITY OF MERCED
WELLS 3&5
PCE
INVESTIGATION
SOIL GAS SURVEY - JANUARY 1991
• CITY OF MERCED WELL ' PCE COUNTS
0 GROUND WATER INVESTIGATION i I 5,000-10,000 ! S8W8f line
] 10,000-100,000
B > 100,000
KNOWN DISCHARGE OF PCE TO SOILS,
UNDER INVESTIGATION
1 Sewer Line
' Flow Direction i_
SCALE
Figure 4. Soil gas survey results for Merced, California.
64
-------
Pollution Prevention: Drydeaning
map), the ground-water gradient is southwest, as
indicated by the large plume on the map. There is also
an arm of the plume heading west along the sewer
line. At Simpson Cleaners (center of map), the ground-
water gradient is to the northwest, but an aim of the
plume heads the other way. The same pattern obtains
for the other two drycleaning shops, when; arms of
the plumes go in a direction opposite to the ground-
water flow. We have seen similar results from other
cities, and the results have been duplicated in surveys
done by other agencies. ;
, j
In sewer sampling, we take ambient Isamples
upgradient and downgradient of the drycleaning es-
tablishment lateral and then take a flush1 sample
(Figure 5). For the flush sample, a large quantity of
water is added to the upgradient sewer access to stir
up the bottom sediments, and the sample is taken at
the downgradient access when the surge of water
reaches that point. :
UPGRADIENT
SAMPUNG POINT
DRY CLEANERS
SEWER LATERAL
DOWNGRADIENT
SAMPLING POINT
FLOW BEFORE
CLEANERS SLUDGE
IN SAG
1
tral Valley cities, we often see low spots, cracks,
and/or separations at joints. Since PCE is heavier
than water, it tends to settle in these low spots. PCE
also is attracted to organic material, which also tends
to settles in the low spits. Sewer sampling results
confirm the presence of PCE in sewer lines.
PCE can leave a sewer line through cracks in the
pipe or through the pipe joints. Even in sewers with-
out cracks, PCE in the low spots can easily penetrate
the sewer pipe walls, which in the Central Valley are
mostly made of clay (Figure 6).
In the scenario shoiyn in Figure 7, PCE liquid
penetrates the pipe walls, then sinks through the soil
Fractures
from pipe bending
Spot
|PCEUquidandSliigges'B
PlpiWal
FLUSH
SURGE OF LIQUID
FROM FLUSH
Figure 5. Illustration of sewer pipe sampling points.
The results of the sewer sampling show that the
PCE concentration in the downgradient ambient sam-
ple always exceeded that in the upgradient sample. In
most of the testing, we found no PCE in the upgradient
sample. i
In the flush sample, since so much water is added,
one would expect the concentration to decrease be-
cause of dilution. Instead the PCE level in thfe flush
sample almost always exceeds that of the dowijigradi-
ent sample—sometimes significantly—indicating that
PCE liquids or sludges are sitting on the bottom of the
sewer line. ;
Based on our field work and research, there are
several likely methods by which PCE migrates; out of
the sewer. In sewer line videotapes from several Cen-
* PCE Liquid - refers to high PCE coiicentraBon liquids, may be pure product
Figure 6. Illustration of smali fractures caused by sewer oloe
bending.
, Pipe Wall
Liquid Containing High PCE Concentration
i
i
FLOW FROM PIPE TO GROUND WATER
Native Soils
PCE Denuded Ground Wstor
(around Water
Table
Figure 7. PCE sewer pipe exfiiti-ation: PCE in liquid phase.
-------
Wendy L Cohen
In liquid and vapor form to the ground water. In the
scenario shown in Figure 8, the PCE penetrates the
walls, then volatilizes off the outer edge and sinks
through the soil In vapor form to the ground water.
Finally (Figure 9), PCE can volatilize inside the pipe
and pass through the pipe walls as a gas, which sewer
pipes are not designed to contain.
.Pip* Watt
Liquid Containing High PCE Concantration
PCEGasPhasa
Native Sails
FLOW FROM PIPE TO GROUND WATER
i Water
• fCE Drf*d*l Grand W«r
Figure 8. PCE sewer pipe exfiltration: PCE enters the pipe wall
«s a liquid and the soil as a gas.
This describes just a few of the Central Valley
Regional Board's investigations. Similar studies have
been conducted in Modesto by EPA Region 9 and in
Chico by Cal/EPA, Department of Toxic Substances
Control. Both of these comprehensive, area-wide
studies reach the same conclusion: drydeaning op-
erations are the major source of PCE in ground water
in the study areas, and the PCE is reaching the ground
water by migrating out of the sewer.
Clearly a considerable amount of ground water is
polluted by PCE as a result of drydeaners discharging
Pipe
lower prtatui*
PCEVapor
Heavier Than
Air
\
High Concentration
PCE
Liquid* MdShidgn
Gmoral PCE Vapor Path
Figure 9. PCE sewer pipe exfiltration: PCE penetrates pipe as
a gas.
their wastewater to sewer systems—and it is not just
in California. Water supply wells have been shut down
in several cities in Florida, for instance, and many
more in other states where testing may not have been
carried out yet are likely to be polluted. There is
technology available to allow drydeaners to treat the
wastewater through evaporation and then treat the
vapors with carbon adsorption so that PCE is not
discharged to the water or air. There needs to be a
prohibition on discharges of drycleaning wastewater
to the sewer.
Even if such a prohibition is enacted, however,
past ground-water contamination from many years of
drycleaner discharges remains to be cleaned up. Pol-
luted water supply wells must be shut down or their
water treated, hi Turlock, California, City Well No. 5
was shut down due to PCE contamination. In Mod-
esto, California, the city spent $500,000 to install
treatment systems on two of its supply wells, because
no one else will dean up the ground water. Therefore,
at present, the task of deanup is falling to the water
supply agencies.
66
-------
Perchloroethylene Ground-Water
Contamination in California:
The On/cleaning Industry's Perspective
Barry L. Bunte
California Fabricare Institute !
In his role as executive director of the California Fabricare Institute Mr
?e^££nreHenhS ** dt^aatoS lndustiy °n a range of issues that Includes
regulation. He has over 25 years of business management experience, 14 of
which were spent working with trade associations. Mr. Bunte holds a B.A. in
State University and has carried
sul
Drycleaners In California have been
to administrative orders that n
to Investigate the extent of PCE contamina-
tion and to prepare remedial pi
of millions of dollars.
require
Jans at a potential cost
ibjected
them
The Regional Water Quality
Control Board Investigation
in the Central Valley
Agriculture has always been the dominant activity in
the Central Valley of California. Therefore, the Central
Valley Regional Water Quality Control Board was
somewhat surprised to find that certain industrial
solvents were present In a number of water supply
wells throughout the region when it initiated Its Well
Investigation Program in 1987. Tetrachloroethylene
(also known as perchloroethylene, PCE, or perc) was
one of the solvents detected. • .
PCE is a relatively simple chemical compound
consisting of two carbon atoms and four chlorine
atoms and is a very effective degreasing agent How-
ever, PCE is a suspected human carcinogen and in
recent years less-toxic substitutes have been found
for some applications. The drycleaning industry has
experimented with many alternative cleaning fluids,
but to date all potential substitutes have proven to be
environmentally dangerous and ineffective cleaning
agents. i
Despite other PCE sources in the region, such as
vehicle and agricultural equipment maintenance
shops and home use products, the Regional! Board
targeted drycleaners for its initial enforcement efforts.
The Regional Board conducted soil gas surveys
using simple buried devices that measure the relative
volatile organic compound (VOC) vapors in an area
over a period of time. The soil gas surveys indicated
that soil and/or ground-water contamination was
high in numerous commercial areas. However, this
apparent contamination was not limited to the imme-
diate vicinity of drycleaners.
The Sewer Leak Theories
To help explain the observed soil gas concentration
patterns, the Regional Board staff developed five
"theories on how PCE leaks from sewer lines": (1)
through breaks or cracks in the sewer pipe; (2)
through pipe joints and other connections; (3) by
leaching in liquid form directly through the sewer
lines into the vadose zone; (4) by saturating the bot-
tom of the sewer pipe with a high concentration of
PCE-containing liquid and then PCE volatilizing from
the outer edge of the pipe into the soils; and (5) by
penetrating the sewer pipe as a gas.
The Regional Board staff obtained soil and
ground-water samples at selected locations and sam-
pled sewer contents directly, both upgradient and
downgradient from suspected VOC dischargers. Pre-
dictably, there is some disagreement about the
strength of the technical case the staff has made given
its limited resources. However, the staff is sufficiently
convinced that discharges of VOCs from sewer collec-
tion systems is a leading cause of ground-water con-
tamination in the Central Valley.
67
-------
BonryLBunte
Notional Repercussions
This Issue transcends the Central Valley and the
diydeanlng Industry. If the technical case made by
the Central Valley Regional Board staff stands up
under further scrutiny, every discharger of VOCs and
those discharging heavy metals and other contami-
nants to sewers could be under investigation for
causing regional ground-water contamination prob-
lems. In fact, other dischargers already under inves-
tigation may seek to transfer their potential liability
to the "indirect dischargers"—the industrial users of
the local sewer system.
Proposed Cleanup
Order—Sacramento
In March 1991 the Regional Board considered issuing
a Cleanup and Abatement Order against past and
present owners of a drycleaning plant that discharged
waste water to the county sewer system. After an
emotional hearing that demonstrated that the dry-
cleaning industry does not have deep pockets from
which to fund ground-water remediation, the board
declined to take action but instructed its staff to
Investigate bringing drycleaning equipment manufac-
turers Into future cleanup and abatement orders.
Manufacturers Liability
In June 1991, the Regional Board staff met to discuss
extending liability to drycleaning equipment manu-
facturers and others with potentially deep pockets.
The staff inspected drycleaning facilities, reviewed
manufacturers service manuals and literature, and
concluded that "almost all drycleaning equipment,
Including that at (the drycleaner in Sacramento), is
designed to discharge wastewater to the sewer lines."
The staff then moved forward in its efforts to tie the
drycleaning industry to the ground-water contamina-
tion In the Central Valley. However, instead of adding
the manufacturers to the cleanup and abatement
order in Sacramento, they shifted their efforts to the
small city of Turlock.
Proposed Cleanup Order—Turlock
The Regional Board staff then circulated a proposed
cleanup and abatement order that named the past
and present owners of three drycleaning plants, three
equipment manufacturers, and the City of Turlock.
All those opposing the proposed order agreed on one
point- the Regional Board was exceeding its authority
in attempting to regulate discharges to sewers. The
manufacturers also argued that they could not be held
liable because they had neither knowledge or control
of any discharges. The city further argued that it was
providing a public service with recognized risks and
that the implications of holding local governments
strictly liable for any consequences of the services
they provide would eliminate many of these services.
Control of Wastewater Discharges
The Federal Clean Water Act forbids discharges to
surface water and to municipal and industrial sewers.
In California, the California Water Code governs dis-
charges to ground water. These regulatory schemes
are separate and distinct.
The Federal Regulatory Scheme
Federal EPA has jurisdiction over both the National
Pollutant Discharge Elimination System (NPDES) pro-
gram for surface water discharges and the pretreat-
ment program for indirect (sewer) discharges. In
California, EPA has delegated its authority over the
NPDES program to the State Water Resources Control
Board and the sewer regional boards. EPA has also
authorized various local governments to administer
approved sewer pretreatment programs. Regional
Boards do not have any authority under federal law
to regulate or in any way Interfere with discharges to
municipal sewers.
The California Regulatory Scheme
Section 13304 of the California Water Code provides
that: "Any person who has discharged or discharges
waste into the water of this State in violation of any
waste discharge requirement or other order or prohi-
bition issued by a regional board or the state board,
or who has caused or permitted, causes or permits,
or threatens to cause or permit any waste to be
discharged or deposited where it is, or probably will
be, discharged into the waters of the state and creates,
or threatens to create, a condition of pollution or
nuisance shall upon order of the regional board clean
up such waste or abate the effects thereof or, in the
case of threatened pollution or nuisance, take other
necessary remedial action."
A discharge directly to surface water or directly to
soil where the discharge is likely to leach to the
ground-water table could properly be the subject of a
cleanup and abatement order. However, the staffs
report on its study states that "in most dry cleaners.
the only liquid discharge of PCE-containing wastewa-
ter is to the sewer lines." With specific reference to
the Turlock drycleaners, the staff report confirms that
"the only obvious PCE discharges from the three
68
-------
Pollution Prevention: Drycleaning
drycleaners were to the sewer." The California Water
Code expressly precludes the Regional Board from
regulating those who discharge to sewers rather than
to surface waters. •
Industry Task Force
During the several days of testimony in Turlbck, the
staff recommended that the manufacturers be re-
moved from the proposed order, apparently convinced
they had not "caused or permitted" waste to be dis-
charged. Drycleaners testified that they had always
conformed to legal requirements and that discharges
had been permitted and approved. Both the city and
the drycleaners stated that they were being asked to
shoulder a burden that should be assessed against all
those who benefltted from the processes and tech-
nologies that led to the environmental degradation.
The Fabricare Coalition, a group made up of
drycleaning associations, has offered to sponsor a
task force consisting of representatives from Cal/EPA,
the various state regulatory agencies, and the dry-
cleaning industry. The task force would report to the
governor and legislature on the potential environ-
mental impacts of existing practices of the drycleaning
industry and on any recommendations for improve-
ments.
Who Pays for the Cleanup
Strict liability is nothing new in environmental en-
forcement. The basic rationale it that people engaged
in hazardous pursuits should be required to answer
for all consequences of these pursuits. This may be
appropriate when the activity involves nuclear weap-
ons, but the activities that may cause environmental
problems run to such mundane activates as dryclean-
ing and automotive repair.
The justification for making responsible large cor-
porations pay for cleanup ils that the cost could always
be passed on the consumer. However, when this
principle is extended to small businesses it breaks
down. In the Turlock case, a retired couple who owned
and operated one of the cleaners many years ago
would have no way to pass along any costs associated
with cleanup. Even current drycleaners (which in
California typically gross less than $200,000 per year)
would find it impossible to recoup million-dollar
cleanup costs through s;urcharges on drycleaning
services.
69
-------
Roundtable Discussion Summary:
Ground-Water Contamination
Discussion about ground-water contamina-
tion centered on remediation methods and
on establishment of mechanisms to cover
cleanup costs.
Walther den Otter of TNO Cleaning Techniques
Research Institute was asked to describe in more
detail the Dutch program for remediation of ground-
water contamination due to drycleaners. He explained
that the total cost of cleanup averages $50,000 to
' $100,000. Each cleanup project is broken up into 13
steps. The drycleaner is required to pay an equal
amount into a fund for 10 years that will cover the
cost of the cleanup. In that way, the costs of cleanup
are made more affordable out of typical cashflows. In
addition to the cleanup, the drycleaner is required to
take all available measures to prevent further pollution.
Jack Lauber of the New York Department of En-
vironmental Conservation asked Mr. den Otter about
the anaerobic decomposition process he had de-
scribed for removing perc from contaminated soil. His
concern centered on the finding in the United States
that anaerobic breakdown in landfills can lead to
formation of vinyl chloride and othervolatile organics.
Mr. den Otterresponded that the Dutch scientists had
overcome this problem and that complete mineraliza-
tion of perc has been demonstrated.
The potential costs of in-ground treatment were
raised by Manfred Wentz of R.R. Street Part of Dr.
Wentz's concern is that perc could reinfiltrate the
ground water following "cleanup." He raised the ques-
tion of whether treatment of water at the wellhead
(i.e., as it is withdrawn for drinking purposes) would
not be more reliable and cost-effective. Wendy Cohen
of the California Regional Water Quality Control
Board responded that this approach is being used in
Turlock, California, and that it is extremely expensive.
She prefers that treatment occur at or near the source
of contamination, where the volumes requiring treat-
ment would be considerably smaller, rather than
drawing the contamination across the aquifer.
hi a series of overheads (see Appendix B), Josef
Kurz showed three types of ground-water contamina-
tion that can occur (1) in the water unsaturated area
(e.g., in soil above the water table), (2) in water satu-
rated areas, and (3) below the water table in the water
impermeable area, hi Germany, 90 percent of the
contamination problems occur in the primary water
unsaturated areas. Cleanup in these areas can be
performed using relatively simple aeration equipment
costing approximately $5,000. The soil is aerated and
solvent is recovered from the exhaust stream using
activated carbon adsorption. Where contamination
occurs in the water saturated areas, remediation is
more expensive and involves pumping out the water,
purifying it and returning it to the aquifer.
hi response to questions from Bill Seitz of the
Neighborhood Cleaners Association, Dr. Kurz indi-
cated that aeration could take from one to one and a
half years to complete. The greatest expense is for
electricity to run the pump and motors. Costs for
maintenance of the carbon beds is not significant
Ms. Cohen pointed out that while in Germany
most of the contamination may occur in unsaturated
areas, in California they have found that perc can pass
through impermeable barriers such as clay. It may be
possible to dean up soil and shallow aquifers and still
have significant perc contamination in the deeper
water supplies. Dr. Kurz responded that this is not a
problem in Germany. Mr. den Otter indicated that in
Holland all of the contamination occurs in the water
saturated area and that they have developed a small
stripping system to remove it.
70
-------
Ground-Wafer Contamination
Tom Cause of the U.S. Small Business;; Admini-
stration enquired about the cost of stripper wells in
California. Ms. Cohen indicated that in Modesto the
wells cost $200,000 to $300,000 to install and
$100.000 per year to change the carbon beds. Again,
she stressed that cleaning up near the source of
contamination would mean much lower volumes to
treat and hence lower costs. i
Elizabeth Bourque of the Massachusetts Depart-
ment of Public Health referenced the comments made
by Barry Bunte of the California Fabricare Institute
concerning previous agricultural uses of pert in Cali-
fornia. Mr. Bunte responded that he was aware of perc
usage in agriculture but he did not have any refer-
ences available with him.
Elden Dickenson of the Michigan Department of
Public Health listed numerous uses of perc besides
drycleaning. Uniforms or rags brought In from ma-
chine shops or auto repair centers may have perc on
them If used for parts cleaning or degreasirig. When
laundered, the perc would be flushed out and dis-
charged with the wash water. Perc was also used at
one time for spraying orchards, and cases w|ere cited
of companies dumping perc because it could not be
used immediately due to weather conditions. Also,
perc has traditionally been used very heavily at air
bases for cleaning.
Tom Cortina of the Halogenated Solvents Industry
Alliance asked whether all Industrial pollutants dis-
charged to sewers would not lead to soil and ground-
water contamination, given the apparent proclivity of
sewers to leak. Ms. Cohen answered that not all
contaminants that may leak from the sewer have been
shown to penetrate clay and infiltrate ground-water
supplies. Heavy metals and VOCs for example, do not
do so.
Bill Fisher of the International Fabricare Institute
cited figures from the California Central Valley Re-
gional Water Quality Control Board's report suggest-
ing that leakage rates of 100,000 gallons per quarter
mile of six-inch pipe are considered "normal."
There was considerable discussion of the current
dilemma in the United States concerning disposal of
separator water. Manfred Wentz indicated that the
industry now recommends that drycleaners do not
dispose of separator water to the sewers. Under the
proposed NESHAP, however, separator water could
not be evaporated to the atmosphere. Scott Lutz of the
Bay Area Air Quality Management District pointed out
that the only current alternative is to treat the water
as hazardous waste and have it hauled away. Alan
Phillips of Air Quality Laboratories reported on dis-
cussions he had with hazardous waste treatment
facility operators in California who indicated that they
could not accept all of the separator water generated
by the drycleaners they serve. Their disposal capacity
could not handle it Bill Fisher Indicated that the
industry was trying to work with EPA to gain approval
for evaporation. According to him, the quantity of perc
involved would range firom 1/2 ounce to 5 to 20
ounces per year. Bill Seitz of the Neighborhood Clean-
ers Association stated that there are numerous de-
vices available to permit the operator to treat
separator water onsite, but that the activity would
classify the operator as si hazardous waste treatment
facility and trigger an expensive permitting process.
Mr. den Otter recommended that drycleaners pay
special attention to the delivery of perc to the facility
and the transfer process. In Holland, 50 percent of soil
and ground-water contamination problems were
traced to improper or sloppy transfer operations.
71
-------
-------
CAPITAL FORMATION
-------
-------
Capital Availability and Profitability Impacts
of Drycleaning Regulation
Brenda L Jellicorse
Center for Economics Research
Research Triangle Institute , \
Ms. Jellicorse is an economist at the Research Triangle Institute where she
has developed financial models for analyzing the impacts of the Clean Air Act
on drycleaners, municipal waste combustors, and landfill operations. She
holds a B.S. in economics from the Untvereity of Texas at Arlington.
Census data indicate that most drydeaning
firms—approximately 60 percent—are pro-
prietorships, another 30 percent, are corpo-
rations, and the remainder are partnerships (Figure
1). Proprietorships and partnerships, which are very
similar in structure, thus account for two-thirds of the
industry. This is worth noting since the legal form of
organization has an impact on the availability of
capital.
Corporations
(32.3%)
Proprietorships
(61.1%)
Partnerships
(6.6%)
Other
(0.1%)
Figure 1. Types of business ownership in the drycteaning
industry.
I
There are approximately 30,000 drydeaning fa-
cilities in the United States, and we estimate about
27,000 firms. Thus there are a large number of pro-
prietorships and partnerships in this industry. From
the lender's perspective, under a sole proprietor or a
partnership form of ownership, the individual is not
significantly distinct from the firm. The lender looks
at the financial statements and the financed well-being
of the individual in conjunction with the business
(Table 1). An individual who operates a'financially
viable drydeaning business but has a problematic
personal financial statement may have difficulty ob-
taining capital. In the same sense, an individual, or
partnership, with a strong personal financial state-
ment who owns and operates a drydeaning business
that is in financial difficulty may be able to get funding
on the basis of personal financial status.
Table 1. Basis of credit woirthlness by type of business owner-
ship.
Type of
Ownership
Basis lor Credit Personal Assets
Worthiness at Risk
Proprietorship Owners personal Yes
financial status
Partnership Owner1:; personal Yes
financial status
Corporation Corporation financial Maybe
- status
Legally, the individual or the proprietor or the
partner is responsible for all of the debts of the firm.
Since the owner receives all of the profits and is
responsible for the lossses, it is not inappropriate for a
lender to look at the owner's personal financial state-
ment. While technically lenders do not have legal
grounds for attaching tfie personal assets of an owner
when a business is a corporation, some lenders will
require the owner or the founder of a corporation to
put personal assets on the line as a condition prece-
dent to obtaining a loan. Indeed, this is fairly common
for small businesses iihat are corporations. Thus, it
may be that in the drydeaning industry in particular,
owners may be less likely to be protected financially
by being incorporated.
Another factor germane to any analysis of the
availability of capital is the size of the entities under
consideration. According to Census Bureau data, a
large number of drycleaning firms are making less
than $100,000 in annual receipts (Figure 2). It is
75
-------
Bfenda L JeKcorse
Number of Firm*
(thousand*)
18 T
16.039
0-100 100-250 250-500 SOO-1.000 OveM.OOO
Annual Receipt!
(tthousands)
Figure 2. Average annual receipts of drycleanfng firms.
difficult to understand how a business can continue
to operate with such a low level of receipts. Perhaps a
couple supplementing their income or someone who
Is operating several businesses at once could manage
to operate with such low revenues.
When evaluating the ability of drycleaning firms
to obtain financing, ratio analysis is useful. It is a
conventional way of looking at the financial viability
of a business. Dun & Bradstreet (D&B) report finan-
cial ratios for drycleaning firms, and in our analysis
of the proposed National Emission Standards for Haz-
ardous Air Pollutants (NESHAP) regulation, we looked
at these ratios as a way of determining the number of
drycleaning firms or the portion of the industry that
is likely to have a problem securing funds for financing
pollution control equipment.
We examined four categories of ratios. The first is
liquidity, which is the measure of the ability of a firm
to meet its currently maturing financial obligations.
The particular ratio that we used was current assets
divided by current liabilities. Most bankers are look-
ing for a ratio of approximately 2 to 1. The average
drycleaning firm, however, does not even come up to
that level. It appears that above-average firms, at least
according to this liquidity' ratio, would not have diffi-
culty obtaining conventional financing. Below-aver-
age firms apparently would have difficulty meeting
their current obligations. If more obligations are
added to the currently maturing obligations, these
firms are going to experience financial difficulty.
Another way of looking at financial viability is
activity. As used here, activity is the ratio of sales to
fixed assets. It indicates how effectively or how effi-
ciently the firm is using its resources—in essence, a
measure of capacity utilization. Firms with particu-
larly low activity ratios may not be using their equip-
ment to the fullest extent.
Leverage ratios are a bit more complicated be-
cause Dun & Bradstreet's criteria indicate that, in
terms of advancing a loan to these businesses, less
debt is better. Yet too little debt may be an indication
that the firm is underutilizlhg less-expensive methods
of financing. Equity financing is typically more costly
in terms of the return that is required by the investor.
Leverage here is calculated as the ratio of total debt
to total assets.
Finally, profitability is measured as the ratio of
profit to sales. Below-average firms keep only 1 per-
cent of their revenues, whereas average firms net 7
percent and above-average firms net almost 14 per-
cent Variations on this profit ratio are included in
Table 2. These include profit-to-assets and profit-to-
net-worth ratios. These measures provide the same
kind of information as profit-to-sales ratios.
Table 2. Baseline financial ratios of drycleaning firms.
' ' Financial Condition
Below " Above
Average Average Average
liquidity
Currant ratio (times) 0.80 1.73 5.10
Activity
Fixed asset turnover 2.30 5.56 7.54
ratio (times)
Leverage •
Debt ratio (parcent) 60.00 45.90 15.00
ProdtaoOty
pronto sales (pwcent) 1.00 7.00 13.00
pronto assets (pnreem) 1.40 14.50 : 32.50
pfOfttoNWflMfcefll) 3.60 26.80 38.20
Source: Duns Analytical Services, 1990.
Profitability indicates not only the ability of a firm
to cover the cost of complying with a regulation, but
also speaks to the incentive that a firm has to stay in
business when faced with the purchase of pollution
control equipment. Above-average firms, of course,
will have considerable incentive to purchase the
equipment and stay in business.
In any industry there are generally two broad
sources of funds: debt and equity CTable 3). Debt is
typically thought of as less risky for the lender be-
cause it involves an actual contractual agreement
between the borrower and the lender, and the lender
has first rights to repayment. That is, if the business
is liquidated, debt holders will receive repayment
before equity holders. There are factors as well that
Table 3. Sources of funds for capital investment
Debt
• Trade Credit
• Bank Loans
• SBA Loans
• Mortgage Loans
• Loans or Credit from
Equipment Sellers
• Small Business
Investment Company
Loans
• Government
Sponsored Business
Development Loans
Equity
• Personal funds/
retained earnings
• Loans from
relatives or
friends
• Loans from
partners
• Venture capital
funding
76
-------
PoSution Prevention: Drycleaning
make debt attractive to the borrower—it costs less and
is tax deductible. Consequently, debt financing is
common in the drycleaning industry.
Typically, equity financing does not involve a
contractual obligation for repayment Examples of
equity include personal funds, loans from relatives,
loans from partners, and venture capital,, '• Equity in-
vestors tend to require a higher rate of return as
compensation for assuming a higher level of risk.
Equity funds also may be raised by issuing stock or
selling shares in the company, but this is a source of
financing that is not generally available to drycleaning
firms.
In general, banks will not loan to a drycleaning
firm in below-average financial condition. Commercial
banks have indicated that they will not loan funds to
drycleaning firms unless they are fully confident of the
firm's ability to repay the loan. i
I
We calculated the cost of capital for drycleaning
firms, using historical weights for the mix of debt and
equity that such firms have typically used fTable 4).
For above-average firms, the Weighted average cost of
capital in real after-tax terms is 11 percerijt. The cost
of capital for average firms typically is 12:5 percent,
and 15.4 percent for below-average firms. \
Table 4. Cost of capital for drycleaning firms.
Financial Status
Debt
WACC
Equity
Below Average
Average
Above Average
5.3%
4.7%
4.3%
15.4%
12.5%
11%
20%
16%
14%
(O&B)
31%
68%
Interestingly, in my discussions with, bankers I
found them concerned about environmental contami-
nation. Consequently, many banks require that an
environmental audit be conducted before a loan to a
drycleaning facility is even considered. Ah environ-
mental audit, however, can cost as much as the pollu-
tion control equipment that the drycleanei: plans to
install. !
Figure 3 shows a flow chart of the decision process
that an owner would go through when deciding
whether to invest in equipment necessary to achieve
compliance with a regulation. The first question the
owner must answer is, Do expected returns following
the compliance expenditures exceed expected costs?
If the answer is yes, the owner will not likely dose
down the facility. If it is no, however, the owner is left
with two options: make the investment and keep the
facility operating, or sell the business. Either way, the
E- expected ;
R - periodic revenues (Price x Quantity)
C • periodic costs (va/fe ble co*t plus periodic repayment
at principal and return on investment)
Figure 3. Decision tree for clrycleaning operator faced with cost
of complying with proposed environmental regulation.
facility must be brought in compliance with the regu-
lation if operations are to continue.
After the investmesnt Is made the question be-
comes, Do actual revenues exceed actual costs? If the
answer is yes, then it is likely the facility will stay in
operation. If the answer is no, then it is likely the
owner will either close the facility or sell it Thus, there
are several points where the owner has to make a
decision on whether to continue operations.
In the final analysis, when we look at the profit-
ability impacts and the capital availability impacts,
the question becomes. Is it profitable to stay open? Is
financing available to cover the cost of complying with
the regulation? Or, is there cash on hand to cover the
cost if financing is not available?
Based on our studies, as a result of the NESHAP
there will be ownership impacts in the drycleaning
industry, and ownership changes are likely— such as
bankruptcy or forced ssale under unfavorable condi-
tions. We projected these impacts based on two finan-
cial scenarios. The first assumes that small firms
represented the firms in the leastfavorable financial
condition (Figure 4). Indeed, there is a large number
of potential changes in ownership under the proposed
NESHAP regulation without a size cutoff. With no
7.000 —
&000 , .
5.000 .
4.000 .
PoMntu
Ownership
Changes 3i00o
1X00 • •
0 .
E33 CepittlAviitablByCcnttrsinB
r~l PreWsDMy Inputs
9 Culofl In Annual Receipts (SOOO)
Figure 4. Financial scenario 1: Capital availability and profit-
ability impacts projected under the proposed NESHAP.
77
-------
Brenda L Jettcorse
small-entity exemption, approximately 5,000 firms
would be In financial difficulty, according to our esti-
mates. Although EPA did introduce a cutoff for this
proposed NESHAP corresponding to $100,000 in an-
nual receipts, the cutoff is not shown here because it
would result in zero closures under this financial
scenario.
In another financial scenario we assumed that 25
percent of firms in all receipt-size classes were in poor
financial condition (Figure 5). Under this scenario—
which does not seem quite as likely—with a $100,000
7.000 T
FIXED RECURRING COSTS AS A PERCENTAGE OF ANNUAL SALES
8,000 .
low-
4JXO •
1000.
£000 •
azn
s*«s
23SO
U2
___
1^««
i' " i C^axJAwltabBlyCflMtralnta
F"~l PfoTitjblStylnvacta
1,t»7
ness
|?WJ _^L,,
No Cutoff 25 SO 75
50» Cutofl In Annual RKalptt 0000)
Figure 5. Financial scenario 2: Capital availability and profit-
ability Impacts projected under the proposed NESHAP.
receipts cutoff, 669 firms would have difficulty financ-
ing the cost of the regulation.
It has been reported that there were approxi-
mately- 500 bankruptcies in the drycleaning industry
in 1990, even without proposed regulations pending.
If we are projecting 669 failures, no doubt some of
those would already be having serious financial prob-
lems.
References
Bass, A., 1991. Commercial Loan Officer, Central
Carolina Bank, March 22, 1991. Personal Communi-
cation with Donald W. Anderson, Research Triangle
Institute.
Behrens, R.H., 1985. Commercial Loan Officer's Hand-
book. Boston: Banker's Publishing Company.
Bowlin, O.D., J.D. Martin, and D.F. Scott, 1990. Guide
to Financial Analysis, pp. 229-233. New York:
McGraw-HilL
Duns Analytical Services, 1990. Industry Norms and
Key Business Rations. Dun & Bradstreet Business
Credit Services 1989-1990.
Appendix
The following materials were submitted for the round-
table by Ms. Jellicorse but not referred to specifically
in her presentation.
Cost
Category
Wages-fixed component (40%)
Rent or building overhead
Depreciation
Interest and bank charges
Insurance
Administrative expense
Payroll taxes-fixed component (40%)
Total
S100KIOS200K
19.97%
7.42%
7.17%
4.39%
3.25%
1.36%
1.22%
44.78%
Annual Sales
S200KWS300K
20.62%
8.59%
821%
4.29%
3.72%
1.95%
1.41%
48.80%
OverSJOOK
26.87%
6.89%
3.92%
1.04%
2.56%
1.32%
1.64%
44.24%
Source: International Fabricare Institute 1988 Operating Cost Survey
VARIABLE COSTS AS A PERCENTAGE OF SALES
Cost
Catetory
Wages-variable component (60%)
Total supply cost
Outside work
Miscellaneous
Advertising
Utility costs-gas & oil
Payroll taxes-variable component (60%)
Repairs & maintenance
Utility costs-electricity
Office expense
Utility costs-water & sewage
Claims
Total
S100KtoS200K
17.05%
8.69%
8.10%
5.12%
2.45%
2.03%
1.83%
1.76%
1.51%
1.46%
0.66%
0.52%
51.18%
Annual Sales
S200K10S300K
18.04%
7.82%
5.39%
2.40%
1.95%
2.27%
2.12%
Z54%
1.54%
1.19%
0.58%
0.34%
46.17%
OverSSOOK
19.31%
7.62%
5.22%
3.55%
3.60%
2.19%
2.46%
2.24%
2.76%
1.15%
1.06%
0.41%
51.57%
Source: International Fabricare Institute 1988 Operating Cost Survey
OPERATING COSTS FOR TYPICAL DRY CLEANING FACILITIES
Annual Sales
150,000
250,000
400,000
Annual Output
(kg of clothing cleaned)
Fixed Recurring Costs
Dollars/kg
Dollars/year
As Percentage of Revenues
Variable Costs
Dollars/kg
Dollars/year
As Percentage of Revenues
Total Costs
Dollars/kg
Dollars/year
As Percentage of Revenues
23,659
2.84
67,167
44.78%
3.24
76,773
51.18%
6.08
143,940
95.96%
. 39,432
3.09
121,990
48.80%
'
2.93
115,435
46.17%
6.02
237,425
94.97%
63.091
2.80
176.968
44.24%
3.27
206,272
51.57%
6.07
383,240
95.81%
Source: International Fabricare Institute, 1988 Operating Cost Survey
Average Costs For Dry Cleaning Facilities
o
7-r
6..
100-200 200-300 OVOrSOO
Annual Receipts Ptr Facility (SOOO)
78
-------
Cost Impacts on the Dp/cleaning industry
of Exposure Reduction Alternatives
L. Ross Beard
R.R. Street & Co. '
Mr. Beard is chief executive officer of RR Street & Co., a major supplier of
chemicals, filtration products, and solvent maintenance equipment to the dry-
cleaning industry, and a member of the drycleaning industry's regulatory
strategy group. Prior to joining RR. Street in 1982, Mr. Beard was at Arthur
Andersen & Co.'s Management Consulting Division, in Washington, DC, con-
sulting on the cost of federal regulation for the Business Roundtable, the En-
vironmental Protection Agency, Department of Treasury, Small Business
Administration, and several major U. S. corporations. Mr. Beard also served
as an advisor to the Joint Economic Council and Office of Technology Assess-
ment on the cost impacts of federal regulation.
In order to discuss the cost of complying with
federal regulation of the drycleaning industry
several basic premises and facts related to the
regulation of this industry must be understood.
• While protecting the safety and health of Indi-
viduals and the environment is rational, desir-
able, and essential, we must remember that
the impetus and organization of programs to
achieve these goals is political, and as is the
case with most politically driven programs,
emotional and political expedience are fre-
quently substituted for balanced, sound policy.
a The process for the development of regulation
is an unbalanced and inequitable variant of
our civil legal system. Setting aside the increas-
ing criticism of the adversarial approach as the
basis of our civil legal system, critical elements
to ensure fairness and representation have
been omitted in its transfer to the regulatory
system. Not the least of these inequities is that
when the seemingly unlimited resources of the
regulator are pitched against the regulated, an
industry like drycleaning—in contrast to the
auto industry, for instance—does not have suf-
ficient economic or political power to secure a
fair hearing. This regulatory process under
which the regulator is judge and jury,,, instead
of objective inquirer, also permits other parties
with self-serving interests to intervene to their
profit or political advantage with no public
record of such intervention.
• The layers and types of costs imposed on this
little industry are far greater in scope and
magnitude than the cost of equipment. The
absence of any accountability of those who
regulate or stimulate regulation enables costs
to be imposed far greater than intended by the
political goals. Even the occurrence of a meet-
ing like this International Roundtable, which
incorrectly characterizes the drycleaning in-
dustry as polluters;, results in costs being Im-
posed on our industry, in addition to the costs
to the American ta:cpayer of conducting such a
conference. .. ' " |
In this presentation, I will address the drycleaning
industry's efforts to minimize waste and the incre-
mental costs imposed on the industry by regulators,
intentionally or not I will also suggest solutions that
would minimize the impact of regulation on this in-
dustry. If my assessment of the impact of regulation
or the drycleaning industry seems critical, it is in-
tended to be so. There is no need for the achievement
of desirable social goals to have such an impact As
the representatives of EPA's Air office can attest it is
possible to achieve the goals of well-intentioned regu-
lation at an acceptable economic cost, if the regulators
and regulated cooperate in the formation of regula-
tion. At a state level, MicMgan can be held up as an
example for its well-balsmced regulation, and even
California, through a government/industry task
force, may achieve a simfiar goal.
Before considering costs, let us also understand
what has driven the increasing regulation of the dry-
cleaning industry—the substance perchloroethylene
(perc), which is used by more than 80 percent of the
25,000 family-owned and operated drycleaners in this
country. Perc was introduced to,the U.S. drycleaning
industry more than 45 ye^rs ago and quickly gained
acceptance because it performed as well or better than
any other solvent and also eliminated fire hazards. For
79
-------
L Ross Beard
many years, transfer machines were used that caused
exposure to perc vapors far in excess of the levels of
exposure today and levels of exposure contemplated
by the Occupational Safety and Health Administra-
tion (OSHA) or EPA. There Is no persuasive evidence
that this exposure resulted in the Incidence of cancer
or other ailments beyond levels experienced by the
general population. Furthermore, faced with the alle-
gations of this substance having serious adverse
health effects, families remained in the business of
drydeaning using this substance. If there is no con-
clusive evidence to support the proposition that perc
is a probable human carcinogen, coupled with the fact
that it is not an ozone depleter or a volatile organic
compound (VOC), why then is there so much regula-
tion of the users of the substance?
Like every other industry prior to the 1970s, the
drydeaning industry was generating emissions to the
atmosphere. Unlike most other industries, the U.S.
drydeaning industry has for many years taken a
position in support of the social goals promoting a
dean environment and safe and healthy working
conditions. Drycleaners, distributors, and manufac-
turers of products used by drycleaners have voluntar-
ily incurred substantial costs to guard the safety and
health of the people who work in drydeaning plants
(predominantly owners and their families), to protect
the environment, and to implement sound work prac-
tices. In reaction to public policy against emissions,
frugal drycleaners have Implemented processes to
filter, distill, and reclaim solvent for reuse. As a result,
in the past 15 years, the drydeaning Industry has
implemented measures that have reduced its annual
consumption of perc by half. Federal, state, and local
governments, however, have established regulations
formalizing many beneficial practices already in place
and have added a number of regulations—sometimes
overlapping, sometimes conflicting with others—that
have resulted in substantial capital, operating, and
secondary costs.
The drydeaning industry acknowledges that
some government intervention in the economy Is nec-
essary to achieve desirable social goals. Well-con-
ceived and carefully implemented regulations can be
beneficial In establishing standards and codes of
practice. The recent cooperative efforts of the dry-
deaning Industry, Congress, and EPA in the forma-
tion of stringent but responsible application of the
Clean Air Act is a model of good regulatory govern-
ance. As a result, environmental objectives are met at
a tolerable cost to the industry. This demonstrates
that the devdopment of regulation generally requires
far greater forethought and analysis to ensure that the
social goals and benefits are attainable at an accept-
able cost and that the particular regulation is the best
and most effldent way of achieving the social goal.
As an industry, we are concerned that the costs
imposed by federal regulations are often excessive
related to regulatory goals. The framework for regula-
tory impact analysis at the federal level does not
address many secondary costs and, therefore, the real
costs of compliance are often understated. More often
than not state and local regulatory agencies com-
pound the effects of federal regulation by enacting
their own regulations that are more stringent and far
reaching than was the intent of the federal regulation.
Furthermore, there are numerous examples of state
and local authorities implementing regulations and
imposing costs for the purpose of generating revenues
to sustain their bureaucracies. For example, the State
of California is currently seeking to impose a $1,100
per annum license fee on drydeaners who purchase
a $2,000 piece of equipment to evaporate waste water,
a process that the state favors.
Most troublesome to the drydeaning industry is
the flood of regulation at the federal, state, and local
levels driven by the mischaracterization by regulators
of the health effects of perc. The consequence of
regulations arising from this mischaracterization will
be the imposition of costs on the drydeaning industry
far beyond its capability to absorb them, which forces
the industry to attempt to pass them on to the con-
sumer of its services. If this seems like a rhetorical
doomsday assessment of the cost of regulation, con-
sider the very strenuous efforts of the California Re-
gional Water Boards to hold drydeaners responsible
for the cleanup of contaminated soil resulting from
leaks in the municipal sewer systems. As we all know,
the preferred method for handling industrial waste-
water throughout the United States has been through
municipal water treatment facilities. This method pro-
vided an economically sensible and reliable means of
managing the discharge and cleanup of contaminated
industrial wastewaters. This method is accepted and
endorsed in federal environmental legislation and
regulation as a matter of policy. However, it is and
apparently has been known by government authori-
ties that California's sewer systems are designed to
leak. Presumably those systems will leak almost'any-
thing that is discharged into them, including house-
hold waste containing chlorinated solvents such as
perchloroethylene.
The attempts to get drycleaners to finance this
cleanup is bizarre in the sense that the contamination
was allegedly caused by the discharge of minute
concentrations of perc in wastewater specifically per-
mitted to be discharged under federal regulation. It is
also bizarre to suggest that such contamination is
solely the responsibility of the drycleaner, and it is not
even remotely conceivable that a drycleaner could
bear the costs of cleanup of such contamination. Even
the costs of investigatory work in preparation for
cleanup would run into decades worth of the average
80
-------
Pollution Prevention: Drycleaning
I
diycleaner's profits. Philosophically, attempts to im-
pose costs of this magnitude on a small business are
irrational and offensive. This attempt to force the
diycleaning industry into eradicating all perc present
in the environment, even if approved by the courts, is
"tilting at windmills." There is not enough wealth in
the industry either to comply or incur the legal costs
of defending such actions.
Drycleaners and their suppliers are small compa-
nies whose assets and values are dwarfed by this
potential liability. These entities also have very limited
liability insurance coverage, most of which 'will not
include such liabilities. While lawyers may prosper as
a result of this endeavor, entities in the industry that
are involved will be left bankrupt—and the Ccdifornia
soil will still not be cleaned up. As a matter of princi-
ple, it is also improper to impose costs retroactively.
After all, society received these services at :a cost
consistent with accepted operating practices of the
day. Drycleaners made profits consistent with the
operating costs of their business when those services
were provided. If the intent is to apply the philosophy
of Superfund, it is yet one more inappropriate appli-
cation of a law intended to address an emergency
situation. The use of ex post facto law is odious at any
time but particularly so when applied to smstll busi-
nesses like drycleaners. :
The ability of the drycleaning industry to generate
the capital required to invest in equipment for mini-
mizing emissions in compliance with the Clean Air Act
is a significant issue, as is the industry's ability to
absorb the costs of operating that equipment and
maintaining records. This is shown in the regulatory
impact analysis. A number of plant closures is pro-
jected as a result for those plants with annual reve-
nues of less than $100,000 that would be unable to
comply. That same analysis proposes that the average
plant with annual revenues greater than $100,000
that is currently profitable will not be affected due to
the savings in solvent consumption. This of course
assumes that the manufacturers and sellers, jof perc
will not increase the selling price to maintain existing
profitability at a reduced level of supply. If that hy-
pothesis does not hold true, the projected number of
plant closures may have to be supplemented, by the
number of plants that would be unable to continue or
unwilling to accept the lower returns of staying in
business. Consider the fact that this is the projected
impact of only one area of regulation, and on6 where
there was a careful and cooperative effort to minimize
the economic impact When the compounded cost
impact of compliance with existing, planned, and
proposed regulation at all levels is estimated, it will be
seen that the average drycleaner cannot comply with-
out passing those costs directly to its customer. As
illustrated in the regulatory impact analysis, for the
Clean Air regulations, the relative costs of drycleaning
in the last 15 years have increased consistent with
changes in the consumer price index. Tliere is no
evidence to suggest that substantial additional costs
due to regulation can be recovered in the marketplace
for drycleaning services.
Even if it were possible to pass on the directly
attributable costs imposed by regulation, no consid-
eration is given to the costs of secondary effects of
regulation. These include but are not limited to:
B Loss of productivity
B Disincentive to invest in drycleaning
B Resource misallocalUon
B Loss of value and equity built in existing dry-
cleaning businesses;
a Costs incurred by government in regulating the
industry '
If the rate of increase of regulation of this industry
is left unchecked it is not difficult to contemplate a
scenario of large-scale plant closures, unemployment,
and loss of capital investment in this industry sector.
The people who own and operate drycleaning busi-
nesses are typically members of small families. Their
skills, abilities, and availability are not automatically
transferable to other market sectors, and therefore the
real economic costs could be far greater and longer
lasting than ordinarily expected.
When the potential contribution of the dryclean-
ing industry to emissions in the U.S. environment is
put in perspective, the de|;ree of attention to regulat-
ing this industry appears disproportionate to the size
of the alleged problem. This is not an industry that
emits to such a degree that heavy regulation should
be used to attempt to force technological change at an
accelerated pace. Furthermore, it can be demon-
strated that the drycleaning industry as it is struc-
tured in the United States does not have the financial
ability to accommodate rapid technological change.
If the potentially catastrophic effects of overregu-
lation of the drycleaning industry are to be avoided it
will be necessary to: j
B Recognize the disparate impact of regulation
on a predominantly "mom and pop'-owned
industry in the regulatory impact analysis
methodology and incorporate secondary effect
assessment I
B Restrict the ability of regulators to form regu-
lation based on inadequate, incomplete, and
uncertain risk assessment data
B Implement a comprehensive cross-media regu-
latory system at the federal and state levels
81
-------
L Ross Beard
that avoids overlapping and conflicting regula-
tions
» Establish a mechanism that facilitates coop-
eration between the diycleaning industiy and
regulators in the achievement of social goals at
a socially acceptable cost
It is not naive to expect that these measure can
be taken. Our industry educated and worked with
Congress and EPA's Air Office in the development of
Clean Air Act legislation and regulation. As a result,
we have tough but fair regulations that will achieve
the social goals of that legislation.
Similarly, at a state level, cooperative efforts such
as those of the State of Michigan and the Michigan
Institute of Laundry and Drycleaning have resulted in
a more balanced regulatory environment, where the
parochial social goals of that state can be achieved at
an economically reasonable cost.
Third, in California—albeit that legislation was
required to accomplish the goal—a joint drycleaning
industry and regulatory task force is being estab-
lished to study the potential pollution effects of the
drycleaning industry on the environment and to adopt
practices that minimize pollution at acceptable eco-
nomic cost This task force includes participation of
all sectors of the drycleaning Industry In California
and all major regulatory agencies in the state involved
with the industry, and it is chaired by the newly
formed California EPA. Regulators at the federal level
should consider this mechanism carefully.
•• Finally, although this International Roundtable is
an Interesting format for learning about what is oc-
curring In the drycleaning industry elsewhere in the
•world, the U.S. regulatory agencies must be extremely
cautious about the automatic adoption of "solutions"
from Germany or Japan. The social, demographic.
and economic structure of the U.S. drycleaning indus-
try is not the same as that of the German or Japanese
industries. Furthermore, Germany's and Japan's de-
cisions involving environmental regulation are driven
by their own political and economic motivations. Let
us also not forget that most European perc is pro-
duced outside Germany. Both Germany and Japan
are major manufacturers of drycleaning machines
and could benefit from a mandated re-equipping of
U.S. industiy.
Remember also that a meeting similar to this.
roundtable was held in the 1970s when EPA made its
first attempt to address the perceived problem of the
drycleaning industry's use of perc. The "solution" was
to mandate a process using the Solvent 113 (chlo-
rofluorcarbon) advocated by its vendor DuPont, which
had not been successful in introducing it in the free
market. Despite the efforts of an eager EPA office over
many months, drycleaning industry leaders, some of
whom are here today, were persuasive in arguing that
the idea had no merit. Had the drycleaning industry
been forced to adopt the solvent and purchase the
equipment necessary to use it the economic conse-
quences would have been disastrous. Even so, the
legal and other costs of enlightening EPA were large
for this industry. In addition, the environmental con-
sequences, according to today's thinking, would be
serious. Our industry would now be facing another
mandated change of solvent—but to what?
One only needs to look to other countries whose
more compliant industries adopted 113 to see the
result A major chain of drycleaners in the United
Kingdom who did convert to 113 now has major
financial problems as a result of having to replace its
equipment twice within a ten year period. Had it not
been for its ability to finance these problems with the
profits from other lines of business, it probably would
not exist even today.
82
-------
Financing Options;
Industry
Thomas Cause
Small Business Administration
for the Drycleaning
Mr. Cause, a director of business development for the U.S. Small Business
Administration, has worked as both a loan officer and program director in
SBA offices throughout the country. Before entering the public sector in
1965, he worked in sales, sales management, and public communications for
private industry in the United States and in South America.
Will, we have a dilemma: It looks; as if we
ire concerned with the environment and
vater—which is essential to all life—and
on the other hand we are concerned with the .impor-
tance of a very significant part of our economy, an
industry that represents some 30,000 businesses.
So how does the Small Business Administration
(SBA) fit in? SBA, of course, provides financial, man-
agement, and procurement assistance to new and
established small businesses. In terms of procure-
ment assistance, SBA tries to make sure that small
businesses get a share of the billions and billions of
dollars that are spent each year by the government—
from, contracting to our set-aside programs. SBA's
management assistance attempts to use< the re^
sources of universities and retired executives to pro-
vide training programs and counseling that might
assist an industry such as drydeaning. For SBA
financial assistance, most of our loans are made
through the banks. The banks put up the money, and
SBA guaranties up to 90 percent to $150,000. Beyond
that, SBA will guaranty up to 85 percent. The limit,
for the most part, is $750,000, but for pollution
control facilities SBA goes up to $1 million. Some have
said that $200,000 for pollution control equipment is
well beyond what is affordable for many industries.
and that it would take most drycleaning estab-
lishments many years to realize that kind of profit
But the SBA pollution control loan program makes
money available for planning, designing, or installing
a facility (see Appendix). The pollution control facility
can be real or personal property that helps to prevent,
reduce, abate, or control water, air, or noise jpollution
or contamination. Recycling programs are also
eligible. ,
To be eligible, a small, business must put together
financial statements that cover two or three years,
including statements for1 any person who has a 20
percent interest or more in the business. The appli-
cant must also provide information on how the funds
would be used and the anticipated repayment sched-
ule. Indeed, any lender is going to want to look at
repayment as the prime criterion for making the
loan.
The applicant also should provide plans or speci-
fications as appropriate for the pollution control facil-
ity and any cost estimates to ensure that the project
can be completed using the Loan. Additionally, appli-
cants should provide copies of any local, state, or
federal environmental regulations that relate to the
proposed facility. •
The advantage to a bank in making a guarantied
loan is that the bank can set the terms for a longer
period than for a conventional loan. Most business
loans are for one to three: years. But with a guaranty
of the SBA, the loan can be extended to as many as
30 years. That kind of an extended payout might make
such a control facility affordable. Not only is the bank
able to extend the loan period with the SBA guaranty,
but its exposure to loss is minimized by 10 or 15
percent, which enables banks to make loans with the
SBA guaranty that they might not make otherwise on
a direct basis. Thus, the SBA pollution control loan
program is possibly the answer to the expense di-
lemma for the drycleaning industry.
83
-------
Thorn as Goose
Appendix. Pollution Control Loans
(PCL) (Guaranty Only)
a. Program Purpose
Section 7(a) U2) of the Small Business Act author-
izes SBA to provide financial assistance to eligible
small business companies for the financing of the
planning, design, or installation of a pollution
control facility.
b. Applicant Eligibility
Applicants must meet the eligibility criteria appli-
cable to all 7(a) loans.
Use of Proceeds
The only allowable use of proceeds are the planning,
design, or installation of a pollution control facility. A
pollution control facility is real or personal property
which is likely to help prevent, reduce, abate, or
control noise, air. or water pollution or contamination
by removing, altering, disposing, or storing pollut-
ants, contaminants, wastes, or heat and such real or
personal property which will be used for the collection,
treatment, storage, utilization, processing, or final
disposal of solid or liquid waste. Any related "resource
recovery" property (recycling) is also eligible when it
is stated to be useful for pollution abatement by a
local, state, or Federal environmental regulatory
authority.
Loan Amounts
The maximum guaranty is $1,000.000, SBA share.
less the amount outstanding of any existing SBA 7(a)
exposure.
Interest Rates
Interest rates are the same as for other 7(a) guaranty
loans.
Submission Requirements
In addition to general submission requirements, ap-
plicants must provide plans and/or specifications, as
appropriate, for the pollution control facility and writ-
ten, realistic cost estimates to assure that the project
can be completed with the available sources of funds,
including loan proceeds. Applicants should provide
copies of any focal, state, or Federal environmental
regulations that relate to the proposed facility with the
application.
Loan Identification
Identify Pollution Control Loans with the prefix PCL
on the docket number..,
-------
Roundfable Discussion Summary:
Capital Formation
Discussion about capital formation centered
on clarifying the conditions of Small Busi-
ness Administration-backed loans and on
small business definitions and cutoff levels in the
proposed EPA NESHAP regulation for perchlo-
roethylene. :
Jerry Levine of the Neighborhood Cleaners Asso-
ciation asked Tom Cause of the SBA to provide further
information on the interest rate limits on SBA-backed
loans. Mr. Cause responded that on loans for less
than 7 years the banks are limited to 2.25 percent
over the prime lending rate. On loans for over 7 years,
the limit is 2.5 percent over prime.
John Meijer of the International Fabricate Insti-
tute asked for clarification on the difference between
the pollution control loan program and the general
SBA section 7A program. Tom Cause explained that
the financial eligibility requirements would ;be the
same under both programs. The primary difference is
in the loan amount that would be guaranteed under
the two programs. Under the 7A program, the maxi-
mum amount guaranteed is $750,000. Under the
pollution control loan program, the loan guarantee is
raised to $1 million.
Mr. Meijer then asked about the eligibility require-
ments for the loan program and whether they would
differ from those faced by a lender applying for a
conventional bank loan. Mr. Cause reported that the
eligibility requirements would be similar, and that the
bank would be looking at the borrower's ability to
repay. The SBA discourages banks from rejecting loan
applications for pollution control equipment based on
collateral limits alone; however, SBA has no control
over the lender's decision.
Tom Cause suggested ithat if the extent of ground-
water contamination wamtnted it a petition could be
filed to have the situation declared a national disaster.
Were this to occur, the disaster loan program could
then be accessed. This program offers much lower
interest rates.
Judy Schreiber of the New York State Department
of Health had several comments concerning cost im-
pacts of drycleaning exposures. She suggested, first,
that drycleaners should be aware of possible liabilities
associated with exposure of apartment residents and
other nearby businesses that may arise. At some
point, she indicated, the real estate industry will be
affected by concerns over resident exposures. Finally,
she suggested that health impacts of resident expo-
sures should be included among the costs avoided
under further regulation.
Margaret Round of th« Northeast States for Coor-
dinated Air Use Management asked whether the
$100,000 annual receipts cutoff used to define small
businesses for purposes of the EPA NESHAP regula-
tion corresponded to a tow level of emissions. Brenda
Jellicorse of Research Triangle Institute and Bill
Fisher of International Fabricare Institute both indi-
cated that drycleaning emissions would be correlated
with size of facility.
85
-------
-------
REGULATORY ACTIVITIES
IN THE UNITED STATES
-------
-------
Proposed National Standards
for Perchloroethylene Emissions
from Drycleaning Facilities
George F. Smith
Office of Air Quality Planning and Standards •
U.S. Environmental Protection Agency
Mr. Smith is an environmental engineer at EPA's Research Triangle Park facil-
ity involved with the National Emission Standards for Hazardous Pollutants
Jvl* S^,r PercWoroethylene use in the drycleaning industry. An officer in the
U.S. Public Health Service, Mr. Smith's experience also includes working as a
mechanical engineer in the electric power industry and as a civil engineer
and construction contractor. He holds a B.S. in engineering from theUniver-
sity of Central Florida.
Introduction
National emission standards for hazardous air
pollutants (NESHAP) covering perchloroethylene
(PCE) used in drycleaning facilities were proposed in
the Federal Register on December 9, 1991 (£>6 Fed.
Reg. 64,382). PCE is a listed toxic air pollutant under
Section 112 of the amended Clean Air Act (CAA) ,of
1990. The drycleaning industry emitted 83,700;mega-
grams (Mg), or 92,300 tons, of PCE into the air in the
United States in 1991. In 1996, when compliance with
the final rule is expected to take place, drydeaning
facilities are expected to emit 45,300 Mg (49,900 tons)
of PCE if controlled to the level of the proposed
NESHAP.
Rationale for Regulation I
EPA is concerned with PCE because exposure to this
compound has resulted in cancer in laboratory ani-
mals. The Agency has consulted with its Science
Advisory Board (SAB) on this matter. The following is
SAB's view on the cardnogenicity of PCE: "It Js the
Committee's view that the major issues arising from
the assessment of perc have not changed over the past
four years, and that the SAB's previous response
remains appropriate. The available scientific evidence
confirms that perchloroethylene should be considered
as an animal carcinogen, based on three endpolnts in
two species: liver tumors in male and female mice,
kidney tumors in male rats, and possibly, mononu-
clear cell leukemia in male and female rats. Compli-
cations within each study and in their biological
interpretations have made it difficult to categorize this
compound. We do not consider the evidence strong
enough to classify this compound as a probable hu-
man carcinogen; on the other hand, evidence for
carcinogenidty is stronger than for most other com-
pounds dassified as possible human carcinogens.
Therefore, in the spirit of the flexibility encouraged by
the Guidelines, our best judgement places this com-
pound on a continuum between these two categories."
Therefore, given the available evidence on the
potential health effects of PCE, the Administrator has
proposed, in response to a iiourt-ordered schedule, to
regulate the drydeaning industry's major and area
source categories and subcategories.
The Proposed Regulation
As for all sources of air pollution in the CAA, major
sources are defined as those emitting more than 10
tons per year of hazardous air pollutants (HAPs) and
area sources as those that emit less than 10 tons per
year of HAPs. PCE is a HAP, and 98 percent of PCE
drydeaning facilities are area so urces. Under the CAA
of 1990, major sources are: subject to regulation by
maximum achievable control technology (MACT) and
area sources, with few exceptions, are subject to
regulation by generally available control techniques
(GACT). MACT is always at l<;ast as stringent as GACT,
and for the most part MACT requires state-of-the-art
control of sources. GACT is determined by balancing
costs and benefits. Since almost all drycleaning facili-
ties are area sources with regard to both population
and the amount of HAPs emitted, it is dear why
Congress and the Administration had drydeaning
facilities in mind when they passed and enacted this
legislation. Drycleaning facilities are typicalfy small
businesses, and as such were given special consid-
eration for regulation under, GACT.
89
-------
George F. Smith
The proposed standard requires the use of a
carbon adsorber, refrigerated condenser, or equiva-
lent control device (95 percent control) for both major
and area source dry-to-dry machines. For new, recon-
structed, or uncontrolled major and area source
transfer machines, the proposed standard requires
the use of a refrigerated condenser or equivalent
control device (85 percent control).
Pollution prevention practices, such as conduct-
Ing weeldy leak Inspections, storing all PCE and PCE
wastes In tightly sealed containers that are Impervi-
ous to the PCE and do not react with the PCE, and
minimizing machine door opening time, are required
to control fugitive PCE emissions.
New drycleaning facilities must achieve compli-
ance upon startup. Existing drycleaning machines
that have a capacity greater than 50 lb, or 22.7 kg,
must achieve compliance within 18 months of the
date of promulgation (November 15* 1992). Existing
drycleaning machines with a capacity of 50 lb (22.7
kg) or less must achieve compliance within 36 months
of the date of promulgation.
Dry-to-dry machines consuming less than 220
gallons per year of PCE and transfer machines con-
suming less than 300 gallons per year are exempt
from the requirements of the standard, except that
operators must submit an initial consumption report
to show that their operation qualifies for exemption
status.
90
-------
Response of the Drycleanjng industry
to Recent Regulatory Activity
BILL FISHER
Vice President
International Fabricare Institute
I want to begin by making sure we understand the
drycleaning Industry's position on perchlo-
roethylene (perc). Because that's really the cen-
tral issue that we're talking about We're really not
talking about Fl 13 and we're not realty talking about
petroleum solvent. Let's be clear about that Our
position, and the industry's position, and the position
of drycleaners themselves is this: information and
evidence suggests that perc may be a carcinogen. The
International Fabricare Institute (IFD and the industry
believe that in totality the evidence most likely says
that perc is probabty not a human carcinogen. How-
ever, the industry also recognizes that this is not
something that can be stated absolutely. And for that
reason, until further scientific testing is done;—some-
thing that we encourage very strongly—the industry
must continue to reduce emissions and to reduce
exposures. That is where we are coming from. That
statement, that position, forms the basis for the ac-
tions the industry has taken.
I'd like to add one thing to that. When; we are
looking at the drycleaning industry, we are not dealing
with General Motors. We're not dealing with some
other large firm. We're not dealing with a corporate
office that is located on the tenth floor of a building
many miles from the production floor. We are dealing
with the people that are my members. This means an
owner, his or her spouse, and typically their children
working In the drycleaning plant operating the equip-
ment, and being subjected to exposures. They are part
of this. They are not absentee owners, and for that
reason we owe our members the most accurate infor-
mation that we can give them on science, toxicology,
carcinogenicity. It would be immoral for us to act in
any other fashion, and for that reason we have pub-
lished information that you have never seen come out
of any other industry.
WeVe all watched the type of stonewalling that
has gone on in other cases with other chemicals. Go
back and look at the Information the drycleaning
industry has published for its members, saying, "Here
are the latest tests, these are the questions that have
been raised, this is what we've got to look at And here
Is the next set of tests, this is what this indicates."
The publication of such Information started In the
late 1970s, at a time v?hen there was significant
pressure not to make the statements that I just made.
But the question is there and our industry must act
responsibly. It's a position that weVe taken and we
have maintained for over 15 years. Our industry has
tried to work with the system.
We worked very clossely with U.S. EPA on the
development of the original control technique guid-
ance document for perc. That work began in the late
seventies. At that time we asked the EPA's Air Office,
"Are you certain that peichloroethylene is in fact a
precursor to oxidant formation in the lower atmos-
phere? We're not atmospheric chemists, we don't
have access to them, are you certain? If you're cer-
tain, we will proceed with you." The EPA's answer
was: absolutely. So we worked with them. That stand-
ard was issued. We help<;d get it out to the states,
helped ensure that there v/as rapid compliance in the
drycleaning industry. Of course in 1981 the EPA's
chief atmospheric chemist, working in EPA's own
labs, found that perc is not a precursor, it does not
contribute to oxidant formation. The following year, in
1982. EPA proposed a recllassffication of perc to neg-
ligibly reactive. That was :iO years ago—that classifi-
cation has never been finalized. I wonder why that
happened? ,
91
-------
KIRsher
We worked with EPA on the new source perform-
ance standard for petroleum solvent. We had our ups
and downs on that The Agency was convinced that
moving to vapor absorbers for petroleum was a good
course. We fought hard on that. We told them that if
they were really committed to that they needed to test
it first. The Agency did, and found it was going to cost
between $80,000 and $100,000 per petroleum plant
to put In a carbon absorber, and instead went with an
alternative standard with the Industry's support
In 1985 the Hazardous and Solid Waste Act
Amendments were passed by Congress. If you took at
the record you will find that the drycleaning industry
is one of the few small businesses that actually sup-
ported virtually all provisions. Today approximately
80 percent of all drycleaners In the United States use
hazardous waste disposal. Given the federal small-
size exemption of 100 kilos, but factoring in those
states that have lower or no exemptions, and melding
all that together Indicates that only 50 percent of the
drycleaning Industry needs to use hazardous waste
disposal, yet 80 percent of the industry does. And I'm
talking about complete waste disposal—no land dis-
posal of any sort Why Is that figure 80 percent? I think
also that If you speak to officials dealing with hazard-
ous waste disposal at any level of government you'll
find that the drycleaning industry, in terms of Its use
of hazardous waste disposal, stands head and shoul-
ders above any other small business industry in the
United States.
The Clean Air Act—weVe just gone through the
amendments to that. Early on our industry made the
decision to support that, to work with the system, to
go with good, tight standards. We met with Congress
and said, "These are the types of standards that have
been developed, these are the types of things that EPA
has been looking at; we not only support that but we
feel that the standard could be a little tighter. This is
what we would envision as a standard for dryclean-
ing—a combination of the best available control tech-
nology (BACT) and the maximum achievable control
technology (MACT)—and we will support the Clean Air
Act In moving forward toward a standard of that
nature." That In fact is exactly what Congress did. Til
take that back. Congress, as they passed the Clean
Air Act ended up with legislative language that only
requires the generally available control technology
(GACT). Consistent with our position with Congress—
and thatwas In writing—we have told theAgency, told
the Air Office, that the proposal in fact while good In
many respects, should be tighter. And our official
comments to the Air Office say that that standard
should be tightened up. ,
You may find It Interesting to know for those of
you who are particularly familiar with the air pro-
posal, that some seven months ago, there was a very
strong push within EPA—I'm not saying within the Air
Office itself, but within EPA—to raise the exemption
level to $250,000 equivalent There was also a push
from another agency—I won't mention which one—to
go with that $250,000 cutoff. We adamantly opposed
that as unjustified and unrealistic, as a cutoff that
would result In exemptions that are unacceptable. I
will also tell you that as the November date last year
came up, this unnameei other agency just about
stopped the proposal of the perc NESHAP (National
Emission Standards for Hazardous Air Pollutants). In
fact there was an article in Inside ERA two days ago
noting—incorrectly—that no air toxics Title 3 regula-
tions had been proposed by EPA's Air Office as a result
of stoppage by this other group. And of course Inside
EPA was wrong in that the drycleaning NESHAP had
been proposed. We had to make telephone calls and
send a letter saying that the standard is workable,
that our industry supports Jt that it is exactly in line
with what Congress said was to be done under the
Clean Air Act and let's move forward.!
We are concerned as an Industry. We're con-
cerned about being whipsawed. The people out there
that belong to us—members that we see, customers
that others here see—are concerned. Their concern is
not that they want to pollute. Their concern is to do
the right thing environmentally. That may be difficult
in some places to believe and, let's face it I'm not
speaking for 100 percent of the people out there. There
are some plants, just as there are anyplace, that are
just poorly operated, where the people don't care. But
across the board in this industry, that's not the case.
We have people that want to do the right thing. We see
a lot of cases where owners may not have been aware
of a problem. And when they learn of the problem,
sometimes through an inspection, they themselves
are aghast and typically move rapidly to try to correct
the problem.
But where they're coming from is that this is their
environment too; they want to know what to do and
how they can do it without going out of business.
Because to them the plain, simple economic fact is a
crucial one. If doing something puts them out of
business, what sense is there to any of this.
Turlock, California—we've had some discussions
of the plants there. Let me lay out a little of that
scenario very quickly. Take an average drycleaning
plant that is grossing about $100,000 to $150,000 In
sales and they have a net profit that is around 6 to 7
percent. We have an issue where you have contami-
nated soil on your property or you have contaminated
a well. And where there may be some questions about
the facts involved, tell me, how are we going to ensure,
both as drycleaning industry spokespeople and as
regulators, that we get to the central issue of cleaning
up that contamination?
The drycleaning plant does not have the financial
resources to do It One could say, "Fine, it's going to
92
-------
be your problem." But the owners don't have insur-
ance ttiat will pay for this. You say, "Fine, let's jSt
dose them down. They were bad actors. They should
have known. Let's force them to sell their assets Let's
see if we can get $100,000 or $150,000 dollars from
ftat drycleaning plant" THat's not going to work. If
that drycleaningplanthas that liability, there are zero
assets, there is a zero worth to that plant.
We have to move forward to some solutions that
will take us to cleanup. We're going to have to do it in
an atmosphere that is a little more rational and
reasoned, and that is a two-way street It's a two-way
street from our side and your side. We get pretty
excitedaboutbeingpilloried in thepress-Wi, had talks
yesterday about EPA's original test-house work and
the determination that garments need not be hung
outside. Unfortunately, I can count at least 50 or 60
• poH"tion Prevention: Drydeaning
,« artfcfc8 ^ have aPPeared in six years
ctting EPA as the sour<:e-and occasionally EPA peo-
ple by name-saying that the consumer should hang
garments outside for 1 to 2 days after they come back
from the drycleaner because of the bad health effects.
• Not even ayear ago there were a few news articles
in the San Francisco ana occasioned by a major press
conference held by the Bay Area Air Quality Manage-
ment District concerning the top "Dirty 30" toxicair
polluters in the Bay Area. Dow Chemical's facility in
the Bay Area came in lower than the 17 drycleaners
who were on that list. «««*
If we continue to go through a trial by press on
issues such as this, we will not get anyplace. As an
industry we want to work together, and we have a
track record of doing this. But weVe got to move
forward, and we are at a critical time now.
93
-------
Dryclecming Regulatory Activities
in California
Cynthia Marvin
California Air Resources Board
Ms Marvin Is an associate air pollution specialist for the California
Environmental Protection Agency's Air Resources Board. Along with leading
a team of scientists and engineers in the development of a state regulation for
perchloroethylene emissions from drycleaning operations, she coordinates
analysis of the federal Clean Air Act's toxics provisions at the state level. Pre-
viously she led the development of California's best available control technol-
ogy standards for ethylene oxide "cold" sterilization facilities. She also has
contributed to development of the state's Low-Emission Vehicles and Clean
Fuels Program and regulation of cooling tower emissions. Ms. Marvin holds
a B.S. in environmental toxicology from the University of California at Davis.
Regulation of Air Toxics
in California
In California, air toxics are regulated at two levels.
The Air Resources Board (CARB) of the state's Envi-
ronmental Protection Agency Is responsible for devel-
oping regulations that establish the minimum
requirements statewide for identified air toxics. Once
control regulations are adopted by CARB, they are
then adopted, implemented, and enforced by 34 local
air pollution control and air quality management
districts throughout the state. These districts have
the primary responsibility for permitting and regulat-
ing all stationary sources. The districts may also
adopt toxics regulations ahead of CARB and may
adopt stricter regulations as well.
Several districts have adopted drycleaning regu-
lations as part of their volatile organic compound
(VOC) control strategy. These regulations typically
require drycleaners to control their emissions by 90
percent or install a carbon adsorber that limits the
concentration of perchloroethylene (perc) In the outlet
air to less than 100 ppm. Many of these regulations
also allow a facility to Install a refrigerated condenser
on a machine so long as the outlet temperature is less
than 45°F (7°C). Some of the regulations prohibit the
use of new transfer machines as well, and many
npt drycleaners that use less than 320 gallons of
«•««_ _ _At_ A_•»*«.••* 4-lt«*+ >I-*-«y/-»1*»oi-»*aTpC tTtftV V)(*
exemt
CtfkClllMli UX Y \jt\stl n i**-^" w*v»». »***»*• •—— — ty
perc per year. The other way that drycleaners may be
regulated in California is through new source review
regulations and policies for toxics. If the source emits
a compound that is on the district's toxics list—like
perchloroethylene—typically all but the smallest
sources must apply toxics best available control tech-
nology (BACT) and perform a risk assessment. If the
estimated maximum individual risk is less than 10 in
a million, the source generally receives a permit. Most
new facilities applying for a permit in California gen-
erally obtain it.
The San Francisco Bay Area district is proceeding
with a new toxics-based regulation for drycleaning
operations. The district released a draft regulation in
April that would require all drycleaners to use dry-to-
dry, non-vented machines equipped with a refriger-
ated condenser and a drying sensor.
Based on the recommendation of ithe state Office
of Environmental Health Hazard Assessment and our
independent Scientific Review Panel, CARB identified
perc as a toxic air contaminant last year. With this
identification, we now are gathering and evaluating
the technical information needed to develop a state-
wide perc regulation for drycleaners. Relevant data
include: information on emissions; exposure and po-
tential risk from drycleaning: emission reduction op-
tions, including control technology, solvent
substitutes, and process changes; costs; and a de-
tailed analysis of the potential economic and environ-
mental impacts of regulation.
We are developing this information with the as-
sistance of drycleaners in the state, drycleaning asso-
ciations, equipment and chemical vendors and
recyclers, environmental groups and concerned citi-
zens, other state and federal regulatory agencies, and
the 34 local air districts. Our goal is to develop a
regulation that protects public health and minimizes
impacts on drycleaners.
94
-------
Pollution Prevention: Drycleaning
Survey Information*
11
The basis for our emission inventory is an on-going
CARB survey of the drycleaning industry. The survey
is a simple, two-page form, in both English and Ko-
rean, that addresses equipment type and equipment
life, solvent usage, the amount of material cleaned per
year, waste operations, and gross receipts. The survey
also asks about residences in the building;.
We mailed surveys to 5,500 potential drycleaning
facilities and over 500 hotels and motels. These
facilities include commercial and industrial dry-
cleaners, linen and uniform suppliers, jails, military
bases, and textile producers. Of these 6,000 surveys,
about 3,000 responses have come back, as; of August
1992. Of those 3.000, approximately 500 respondents
are not involved in the drycleaning business at all,
approximately 500 are agency shops, and about 2,000
are facilities where drycleaning is carried out onsite.
About 95 percent of the operators in this survey
use perc; the other 5 percent use Stoddaitd solvent.
CFC. and TCA. Of the perc users, more than half of
the respondents use dry-to-dry, non-vented ma-
chines, most of which are equipped with a refrigerated
condenser. About one-third use dry-to-dry, vented
equipment and less that 10 percent of the respon-
dents use transfer equipment. ,
The total pounds of clothes cleaned per year at a
facility ranged from 1.500 pounds to over a million.
Annual perc usage ranged from 5 gallons; to 3,600
gallons. We also looked at the perc "mileage," or
pounds of clothes cleaned per drum of perc. We found
perc mileages of about 2,500 to 75,000 pounds per
drum.
Testing for Perchloroethylene
Vapor*
We have seven tests that are nearly complete, and four
more scheduled. We are sampling stack or vent emis-
sions from the drycleaning equipment or;controls,
emissions from the workroom exhaust vent, and the
ambient concentration at a location upwind and a
location downwind of the drycleaning facility. In ad-
dition, we are measuring perc in the process residue
and in the separator water.
Preliminary results are not yet available: however,
I can tell you about the type of equipment we are
testing.
The equipment includes:
• Three transfer machines, with capacities from
30 to 70 pounds, equipped with a carbon ad-
•Updated in September 1992. See Appendix B, Supplemented Materials, tor
additional updated data.
sorber or refrigerated condenser and using
from 200 to 1,300 gallons of perc per year.
« Three dry-to-dry, vented units, with capacities
from 30 to 190 pounds, equipped with a carbon
adsorber or refrigerated condenser and using
. from 130 to 3,600 gallons of perc per year.
B Three dry-to-dry, non-vented machines, with
capacities from 35 to 70 pounds, equipped with
a refrigerated condenser, alone or in combina-
tion with a carbon adsorber, and using from 70
to 100 gallons of perc per year.
• Two converted, 30-pound, dry-to-dry, non-
vented units, w,lth a refrigerated condenser,
and using 160 to 300 gallons of perc per year.
I
Our testing is based on grab sampling with analy-
sis by gas chromatography. We are also using con-
tinuous emission monitoring at the stack and at the
workroom exhaust vent. Once we have completed our
preliminary technical evaluation, we will develop
regulatory concepts for discussion.
Development of Regulations
We expect to consider several regulatory concepts,
including a phase-out of transfer equipment: a phase-
in of dry-to-diy, non-vented (close-looped) equipment;
stricter requirements for new machines than for ex-
isting machines; and a tiered standard with stricter
requirements for larger ^sources or shorter compliance
times.
We are also very interested in pursuing a perform-
ance-based standard, s;uch as a "mileage" require-
ment or an emission; limit, that provides more
flexibility and encourages pollution prevention. While
developing these concepts, we will also evaluate the
potential for indoor eaqposure and non-inhalation
routes of exposure.
By legislation, the regulation that is eventually
proposed by the CARB staff must be designed "to
reduce emissions to the lowest level achievable
through application of BACT," considering risk and
cost The regulation, olF course, must be at least as
stringent as the standard promulgated by the U S
EPA.
t
We expect to release the results of our technical
evaluation and regulatory concepts and to discuss
them at a series of public workshops in September
1992. After this open discussion, we will draft a
regulation and analyze the potential impacts. These
materials will be published before we hold another
series of workshops in early 1993. We expect to
'publish our final staff proposal and all supporting
95
-------
Cynthia Marvin
documentation, before the GARB public hearing, in
mid-1993.
Conclusion
We are currently in the midst of our technical evalu-
ation and expect to propose a new statewide perc
drydeaning operations regulation for consideration in
mid-1993. If that regulation is adopted, it will then
be implemented at the local level.
References
Bay Area Air Quality Management District Proposed
Rule 2-5 and Rule 8.27 (Sept 5, 1990).
California Air Resources Board. Staff presentation for
second public meeting on perc and drydeaning opera-
tions. Sept 18, 1992. Stationary Source Division,
Toxic Air Contaminant Control Branch, Los Angeles,
CA
California Health and Safety Code. Section 39002
and Sections 39660-39666.
Monterey Bay Unified Air Pollution Control District.
Rule 1000 (March 19, 1986).
Sacramento Metropolitan Air Quality Management
District. Rule 445-3 (Nov. 6, 1990).
San Diego County Air Pollution Control District Rule
67.8 (Aug. 30, 1990).
San Joaquin Valley Unified Air Pollution Control Dis-
trict Rule 467.1 (April 11, 1991).
South Coast Air Quality Management District. Rules
1102.1 and 1401 (Dec. 7, 1990). ;
-------
Drycleaning Regulatory Activity
in the Northeast
Margaret M. Round •
Northeast States for Coordinated Air Use Management
Ms. Round is the toxics coordinator for Northeast States for Coordinated Air
Use Management (NESCAUM). In this role she oversees the development of
pollutant assessments and regional air toxics health evaluations and facili-
tates the review and exchange of informaition on air toxics risk assessments
conducted by the EPA. Ms. Round also provides technical support and coordi-
nates the activities of NESCAUM's Air Toxics Committee. She holds a B.S. in
toxicology from Northeastern University.
Background on NESCAUM
Northeast States for Coordinated Air Use Manage-
ment (NESCAUM) is a regional air quality planning
organization that was formed in 1967 to facilitate
regional evaluation of air quality problems and the
development of consistent regulation to address them.
The NESCAUM Board of Directors consists of the most
senior state air quality officials from the six New
England states and the states of New York and New
Jersey.
The Air Toxics Committee was established by the
NESCAUM board in 1983 to develop basic program
elements related to the control of noncritieria air pol-
lutants. In general, each member state has a repre-
sentative from both its public health department and
air quality division on NESCAUM committees. The
reason being that the air toxic control programs in the
Northeast are based on a combination of control
technology requirements, acceptable ambient levels
for air toxics, and residual risk assessments.
In the mid-1980s the states recognized the need
to develop regional risk assessment documentation in
support of regulatory decisions to control major air
toxics emissions. The regional assessments reduce
duplication of effort in setting air toxics standards and
encourage consistency in the regulation bf air toxics
emissions. In addition, two other conditions existed:
One was that the EPA had promulgated only seven
National Emission Standards for Hazardous Air Pol-
lutants (NESHAP), and the other was that recent
knowledge in the area of health effects from exposure
to air toxics provided additional methodologies for
establishing health-based standards.
The Air Toxics Committee has completed regional
risk assessments for tetrachloroethylene (1986),
trichlorethylene (1988), and gasoline vapors (1990)
that includes benzene, toluene, and xylene. The com-
mittee is currently revising its tetrachloroethylene
document a task that is expected to be completed by
the end of 1992. ;
NESCAUM State Regulations
for Drycleanere;
In general, members of NESCAUM regulate dryclean-
ing operations by requiring construction and operat-
ing permits and a demonstration that the best
available control technology (BACT) is being used to
minimize perchloroethylene (perc) emissions. Seven
out of the eight NESCAUM states have promulgated
regulations for drycleaners. The remaining state. New
Hampshire, is in the process of developing regula-
tions. A total of 22 states throughout the country have
promulgated regulations to control drycleaning emis-
sions. Common elements of these regulatory pro-
grams are: . , ' -.
• Refrigerated, no-vent condensers or dry-to-dry
machines with activated carbon adsorption or
the equivalent aie considered the BACT.
• The installation, of new transfer machines is
prohibited. '
• Ventilation standards must be complied with
to minimize fugitive emissions.
• Perc discharge from drycleaning machines
must be limited to 100 ppm.
• Prompt repair of leaks is required.
97
-------
MotgaretM. Round
• The processing of contaminated waste, includ-
ing reducing the residues In both the filter and
In the still bottoms. Is required.
• Visual Inspection of hoses, tank, storage con-
tainers, and nondlffusive construction materi-
als Is carried out
• Exemptions are made for coin-operated ma-
chines and facilities lacking space or steam
capacity, hardship cases, and small sources.
Some specific elements of the state programs are
•worth mentioning:
• In Connecticut emissions must be vented
above the roofllne from a stack with a height in
keeping with good engineering practice (GEP).
• In Maine, where the state only recently prom-
ulgated Its regulation, emissions at the doors
and at the hood of the drycleanlng machine
must be exhausted at a velocity of 100 feet per
minute. Additionally* Maine requires that
automatic fans at the door opening vent emis-
sions to carbon absorbers: also, spare parts
must be stocked on the premise and records of
maintenance and malfunctions must be kept
• New Yorkrequires the use of carbon absorbers
with a solvent vapor discharge of less than 5
ppm and nondlffusive construction material
for operations near apartments, food service
establishments, and nonindustrial facilities.
• In Rhode Island, drycleaning facilities that can
demonstrate an acceptable ambient level of
perc emissions using modeling are exempt
from BACT and stack height requirements.
In general, all states that have control technology
regulations incorporate pollution prevention and
maintenance requirements Intended to reduce the
generation of emissions and waste. These include leak
detection, proper storage of materials, ventilation.
standards, and minimization of fugitive emissions.
NESCAUM Review of EPA NESHAP
NESCAUM has reviewed the EPA's proposed maxi-
mum achievable control technology (MAC!) standard
for perc, and we have several pages of comments. I
will highlight some of them.
EPA proposes to regulate certain drycleaning ma-
chines based on solvent consumption rate and ma-
chine size. We believe that these characteristics are
not appropriate surrogates for determining perc emis-
sions because the emissions come from several
sources during the drycleaning process, including
uncontrolled vents and pipes, auxiliary equipment
evaporation during the transfer and drying process,
and equipment leaks.
NESCAUM also believes it is appropriate to apply
MACT to all drycleaning machines for the following
reasons. First, the toxiclty and exposure potential of
perc from drycleaning operations is extensive. Sec-
ond, the economic analysis that was conducted by
EPA does not account for the air quality-related health
and environmental impacts. Specifically, EPA does
not account for the local public health impacts for
relatively high levels of exposure to perc emissions in
the vicinity of drycleaning establishments. The eco-
nomic impact analysis should also take Into account
the cost of installing control equipment the cost
savings from reduced solvent usage, and the health
costs associated with exposure to uncontrolled perc
emissions.
EPA modeled a population living near a plant as
a basis for estimating perc reductions on a national
basis. We believe this is Inappropriate because the
major impact of perc emissions is right in the vicinity
of the drycleaning operation itself.
By not taking these factors Into account EPA
limits the MACT applicability to only the largest
sources. NESCAUM also recommends that perform-
ance standards and emission limits be prescribed to
ensure that the control technology is working properly
and that maintenance is being carried out
Finally, NESCAUM believes that the generally
available control techniques (GACT) requirement for
existing transfer machines is not sufficiently justified
by the economic analysis, given the potential Impact
of the remaining 50 percent of uncontrolled emissions
from the transfer machine. Other control alternatives
that are less expensive have been demonstrated for
these machines, and we believe that it is necessary for
EPA to revise its current proposal to take into account
many of the existing control technologies that are in
use, particularly in the Northeast
98
-------
Roundtable Discussion Summary: ;
Regulatory Activities in the United States
Discussion about U.S. regulatory activities
addressed the methods used to evaluate
regulatoiy costs, the establishment of regu-
latory standards, and the potential impact pf addi-
tional exposures on regulations currently under
development. '
The panel began with a comment from Walther
den Otter of TNO Cleaning Techniques Research In-
stitute concerning the costs of ground-water cleanup
that had been, discussed by Ross Beard of R.R. Street.
Mr. Beard had indicated that it is impossible to expect
a small drycleaner to come up with $50,000 to clean
up perc contamination due to sewer leakages. Mr. den
Otter agreed that this amount is large, but if paid for
over a period of time it may be possible for the cleaner
to afford the cleanup. This has been the experience in
Holland. He used the example of a site where the
initial survey cost $9,000 and the cleanup cost
$50,000. In this case a cleanup over a period of 10
years has proved manageable.
A discussion then took place about how; the sav-
ings due to regulation are balanced against the costs
of compliance. Jack Lauber of the New York Depart-
ment of Environmental Conservation cited an un-
named study that found a 60 percent difference in
"cost per kilogram cleaned" between a state of the art
drycleaner and an older transfer operation "'when you
incorporate solvent saving, power utility costs, and
everything." This type of calculus seemed to be miss-
ing in the EPA analyses, he suggested. In response,
Bill Fisher of International Fabricare Institute assured
Mr. Lauber that solvent savings had been balanced
against the cost of control in "every EPA economic
analysis ever done on the drycleaning industry." He
then explained that, while the cost of solvent saved
should be examined, "supplies," which includes, for
instance, solvent bags, and hangers, represents only
4 percent of total costs in the industry, the implication
being that solvent savings will only have a marginal
impact on total costs. Then, Mr. Fisher discussed
calculations he had done indicating it would take a
drycleaner between 10 and 15 years to pay back the
cost of changing over to new dry-to-dry, no-vent re-
frigerated equipment !
Margaret Round of the Northeast States for Coor-
dinated Air Use Management addressed the issue of
the technology specified to the federal MACT (maxi-
mum achievable control technology) standard. Ac-
cording to her, the technology requirements are
inferior to those in place in several NESCAUM states.
The MACT technology requirement for existing facili-
ties is supposed to be that in place at the top 12
percent of the best-performing facilities.
Ms. Round stated she is not aware of a single
drycleaner in the seven 1'JESCAUM states that had
gone out of business due to state requirements for
controls even more stringent than the federal MACT.
She gave the example of Rhode Island, where the cost
of upgrading was estimated to be $4,000 to $6,000,
resulting in solvent savings of approximately 50 per-
cent For a 5-ton per year facility the solvent savings
amounted to $3,200 per year and the upgrade had a
payback period of 2 to 3 years.
Bill Fisher of IFI responded that the issue with the
federal MACT standard is not $4,000 to $6,000 for an
add-on vapor adsorber but rather the $35,000 to
$40,000 for total replacement of equipment Mr.
Fisher also responded to Ms. Round's comment con-
cerning the appropriateness of the technology se-
lected for the NESHAP regulation by indicating that
Congress had specified that the proper technology
99
-------
Regulation/Activities in the United States
level was GACT (generally available control technol-
ogy) and not MACT.
Ms. Round then raised the Issue of the perceived
fairness of a federal regulation that is less stringent
than existing state regulations. Understandably, the
promulgation of a federal regulation with less-strict
technology requirements would lead drycleaners to
question the authority of the state to enforce more
stringent rules.
Judy Schreiber of the New York State Department
of Health argued that the small business exemption
under the federal NESHAP was too liberal. According
to her, half of the drydeaning shops in New York City
would be exempted. Given her findings concerning
exposures of apartment residents, this exemption is
"unconscionable." There is no evidence that smaller,
exempted cleaners have a lesser impact on apart-
ments than larger ones.
Dr. Schreiber then asked George Smith of EPA's
Office of Air Quality Planning and Standards whether
these findings would influence the future direction of
the NESHAP. Mr. Smith indicated that EPA had re-
ceived copies of the New York State comments and
that they were considered "very serious" comments.
Dr. Schreiber asked Bill Fisher for an opinion on
the significance of these findings on the direction of
the NESHAP regulation. Mr. Fisher responded that.
first, the level of exemption included in the NESHAP
was indeed a concern to the industry and that IFI had
supported a lowering of the small business cutoff
number. Second, in regard to the potential future
direction of the NESHAP, Mr. Fisher expressed a
personal opinion that EPA would be on "very shaky
legal ground" to address indoor air concerns under
the Clean Air Act Amendments.
A final question came from Elizabeth Bourque of
the Massachusetts Department of Public Health con-
cerning whether any of the states had looked at, or
had plans to look at, the number of drycleaners that
are adjacent to food stores or restaurants. Bill Seitz of
the Neighborhood Cleaners Association responded
that they are taking a look at this issue.
100
-------
INFORMATION
DISSEMINATION
-------
-------
Communicating about Environmental Risks
Related to the Drycleaning Industry
Caron Chess
Environmental Communication Research Program
Rutgers University/Cook College j
Ms. Chess is director of the Environmental Communication Research
Program at Rutgers University. The focus of the program is to conduct re-
search and provide consulting services and training to industry, government
and nonprofit organizations on effective communication of environmental
health issues. Ms. Chess is coauthor of a book and author of numerous arti-
cles on risk communication. Previously she coordinated the New Jersey
Department of Environmental Protection's implementation of a Right to Know
law, which gave the public access to taformation about toxic substances.
A number of years ago I learned what those
outside the risk communication field
thought about the evolving field of rjsk com-
munication when I got a call from a trade association
asking me to be the after-dinner speaker at its annual
meeting. It seems the organizers of the dinner usually
got a magician for that slot but he couldn't make it
this particular year. So they turned to me.
I find that people still want the abracadabra ap-
proach to risk communication. That is, they are look-
ing for some magic words that will soothe all of those
unduly alarmed and wake up all of those unduly
apathetic.
Of course, those magic words don't exist for the
issue that is the focus of this roundtable, or for any
other environmental issue that IVe dealt with. Risk
communication—like pollution prevention or good
science—requires research, planning, and evaluation.
1 have not done original research on risk communica-
tion in the drycleaning industry, and to my knowledge
no other researchers have focused on this area. So
what I will do in this presentation is review some of
the false assumptions that people in government and
industry tend to make about risk communication,
summarize the realities as they have applied to other
risk communication issues, and then raise some con-
cluding questions.
Ptrst myth; When explaining risk, sound more
certain than you are.
Reality: When government officials or industry
representatives yield to the pressure to sound more
certain than they are, they become vulnerable to
charges of inaccuracy at best or cover-up at worst.
Learning to acknowledge uncertainty oii environ-
mental risks may be one of the toughest risk commu-
nication lessons, but it also may be one of the most
important for controversies like those that have been
swirling about at this rotindtable.
Am I suggesting that in response to relevant
questions that you shrag your shoulders and say,
"Darned if I know?" Absolutely not But I do suggest
that you (1) say what you do know, (2) indicate the
bounds of your certainty, (3) state what has been done
to reduce the uncertainty, and (4) announce what will
be done to reduce it further.
Let's take an example from the materials IVe read
on the drycleaning indusitry. Before I read this state-
ment, I should say that I am not going to debate its
accuracy: I know that would be out of bounds for this
forum. I want you to listen to the statement and think
about whether you think: it enhances readers' trust in
the drycleaning industry. This is the quote, taken from
a letter to the editor writi en by the head of a dryclean-
ing association: "The best evidence that exists is that
mice and rats sometimes contract cancer, but there
is no evidence that there is any danger to people."
Now we don't have siny research on this, but the
assumption that I've often heard from people in the
drycleaning industry is that acknowledging uncer-
tainty and being forthright about the controversial
issues is only going to alarm people. My hypothesis,
instead, is that this statement leads to an industry
spokesperson sounding defensive, rather than sound-
ing like someone interested in telling people the entire
truth. I suspect that such a statement might lead
readers to think that the drycleaning industry is more
concerned about deflecting blame than solving prob-
lems. Having participated in this roundtable, I don't
think that's the case in the drycleaning industry, and
I don't think that's the (impression that spokespeople
for the drycleaning industry want to convey. So the
questions that you should ask are. How can you give
103
-------
Caron Chess
people an understanding of the apparent environ-
mental risks? and. How can you assess the affect of
that information on consumers and people living near
drydeaning facilities, as well as on people who work
in the industry?
Second myth: When preparing presentations or
materials for the public, focus on what you think is
important
Reality: What you think is important and what
your audience considers important may be quite dif-
ferent I often suggest to people in workshop groups
that they should develop materials—and this includes
materials for people in the regulated community as
well as consumers—that answer three questions.
• What do I want to get across? fine question
most presenters ask themselves.)
• What does my audience want to know? tine
question presenters tend to leave out)
" What is my audience likely to get wrong if I
don't correct the misconceptions ahead of
time? {The question most presenters never
consider.)
The materials that I was sent in advance of this
gathering include some very useful information. Yet
some bottom-line issues are not adequately ad-
dressed. Consider the kinds of questions that might
be asked by people Irving near a drydeaning estab-
lishment Such as. "How do I know if I should be
concerned?" "How do I find out what I can do?" "And
what are you—drydeaning industry leaders and gov-
ernment officials—doing to protect my health?"
The kinds of questions that consumers might ask
include: "How do I know if I have a good drycleaner?"
That Is, not Just a drydeaner who can get my white
silk shirt dean, but a good drycleaner in the environ-
mental sense?
I was very pleased to find some guidance in regard
to such questions from one of the drydeaning trade
associations in the roundtable advance materials.
Again, I don't know whether the guidance is sound,
but I was pleased nonetheless that information is
being provided for consumers so that they can begin
to distinguish between "responsible" drycleaners and
those whom they should be concerned about. One
trade association suggestion is for consumers to look
for notification at the drydeaning shop Indicating
membership in a professional association. The second
is to use your nose when you go into a drydeaning
establishment And the third is to useyour nose when
you take your dothes home. What I understood from
this Is that If things smell bad. it might indicate that
the deaner Is somewhat less than environmentally
responsible.
Thirdrnyth: Disdosing data is likely to alarm people.
Reality: Withholding data is likely to cause people
to question you and everything you stand for. In the
face of the uncertainty about many drydeaning is-
sues, it would be tempting to say, "Let's wait to
communicate with the public, until we know exactly
what is going on and what we are going to do about
it." I commend the roundtable organizers for putting
communication on the agenda, and I urge partici-
pants to take a lesson from the chemical manufactur-
ing industry. A 1990 public opinion poll gave the
industry a 27 percent approval rating, which was next
to the lowest above only the tobacco industry. Many
leaders in the chemical industry now acknowledge
that they hid for too long behind the factory gates and
that withholding information, even when it was with
the best of intentions, led to an erosion of the public
trust.
I suspect—although I have no data on this issue-
that neighborhood drycleaners are accorded a fair
amount of trust from their customers and are seen as
a fixture in the neighborhood. In the suburbs, the
drycleaner's shop may be one of the few commercial
establishments where somebody knows your name.
That trust is the Industry's capital to invest or squan-
der. If you are not the source of the Information,
someone else will be, and then the question will be,
"Why didn't you tell us?"
Fourth myth: Risk communication can wait until
we've dealt with the substantive issues.
Reality: The result of this type of thinking is that
resource-intensive attempts must be undertaken to
put out communication fires, which might have been
averted with effective planning. It does not work to do
years of study on an issue and then hurriedly plan the
communication effort, particularly on an issue like
this that involves so many people and such diverse
audiences, including small business owners (who
may only know English as their second language),
consumers, and neighborhood residents. I would urge
that when you conduct or are' involved in
epidemiological studies, that communication with
subjects before, during, and after the study be de-
signed into the plan. Monitoring studies need to deal
with the businesses involved and the people poten-
tially exposed.
In conclusion, I've heard your concerns about
communicating to the public regarding the potential
risks of drydeaning operations. Implicit in those con-
cerns is a lot of fear about how the public will respond.
It is important for industry and agency officials to
examine their fears about the public and how those
fears are influencing how they deal or don't deal with
the communication of risk. I ask finally: Are you
planning to communicate to the public? And if not.
Are you dooming yourself to failure regardless of your
104
-------
PoSi.iHon Prevention: Drycteaning
technical expertise or your policy development ef-
forts? :
Appendix i
The following figure was submitted for the roundtable
by Ms. Chess but not referred to specifically in her
presentation.
LADDER of CITIZEN PARTICIPATION
Citizens act without
communicating with
government
• volunteer fire department;
• citizen investigation; •
• citizen development and
implementation of programs
Citizens and government
solve problems together
• funding of citizen groups to
hire technical eonsultiints
and/or implement projects;
• citizen oversight and ,
monitoring;
• meetings called jointly by
government and cilizi in groups
Government asks citizens
for meaningful input and
intends to listen
• citizen advisory committees;
• informal meetings;
• on-going dialogue;
• some public hearings
Government asks citizens
for limited input and
would prefer not to listen
• most public hearings;
• most requests for responses to
formal proposals;
* pro-forma meetings Jind
advisory committees
Government talks;
citizens listen
• some public meetings;
• press releases and other
informational slratcj jles:
newsletters, brochure, etc.
Government acts without
communicating with
citizens
• some investigations; '
»legal and enforcement actions
105
-------
The Drycleaning Industry's Perspective
on Risk Communication
William Seitz
Neighborhood C/eaners Association
Bill Seitz is the executive director of the Neighborhood Cleaners Association
(NCA), -which has 4,000 members in nine states. Mr. Seitz began his 47 years
In the drycleaning industry as a journeyman learning the different phases of
the business. He has been with the NCA since 1949, working as a garment
analyst, field representative, and instructor. He is a consultant to the
Metropolitan Museum of Art in New York and to the Textile Conservation
Workshop. Mr. Seitz is a graduate of the StraubenmueUer School of Textiles
and the National Institute of Drycleaning.
The question of the drycleaning operator's per-
spective on information dissemination
and/or risk communications is really a much
broader subject than it would seem. The reality is that
there are actually four distinct areas of information
dissemination that affect the operator and they vary
substantially as to the impact they can have on the
particular business.
The four areas are:
• Intra-Industry
• Drycleaning operator to customer
• Governmental agency to drycleaning operator
• Governmental agency to the drycleaning op-
erator's customers
Infra-industry
To understand and appreciate why the drycleaning
Industry has progressed as rapidly as it has in accept-
ing and complying with government regulations, look
to the work of the trade associations, allied trade
firms, and the drycleaning trade press. Prom the very
Inception of the regulatory process, the trade associa-
tions have been In the forefront of this important and
positive program. Areas of activity have Included
analyzing regulations, disseminating information,
and assisting in getting the operators to comply. Trade
associations have acted as a conduit for various gov-
ernmental agencies in order to bring the industry into
compliance—from hazardous waste "milk-run"
pickup programs to inspecting operators' plants or
giving operators the tools for self-inspection. Trade
associations have held hundreds of seminars, meet-
ings, and workshops to educate operators. The asso-
ciations and the industry press have written regularly
and often on the subject of compliance and the need
for the operator to act in a responsible manner in
regard to the business and the community. Rather
than positioning themselves as adversaries of the
government and the regulatory process, the trade
associations have been a positive and powerful force
in working with the various federal, regional, state,
county, and city agencies.
Drycleaning machinery manufacturers have de-
veloped technology that has substantially improved
the performance of equipment, whether through fa-
cilitating retrofits for existing equipment or continu-
ing to develop the state of the art in drycleaning
technology. Solvent manufacturers have participated
in the process by developing technical information
and procedures regarding the safe handling of per-
chloroethylene (perc).
Obviously these efforts should be continued, al-
though in a closer working relationship with EPA and
the various other agencies that interact with the
drycleaning industry.
Drycleaning Operator to
Customer
This is a relatively new area of risk communications
where the operator and the industry need assistance
and expertise. What the operator needs to do and
wants to do is to explain the drycleaning operation
and the areas of potential risk. The operator wants the
customer and the community to understand the ef-
forts being' made and the precautions and safety
measures being taken, without creating unnecessary
106
-------
Pollution Prevention: Orycteanaig
concern, and more importantly, fear and rejection of
the drycleaning service. Perc has a history of almost
60 years of safe use in the drycleaning industry,
usually in residential and retail shopping areas, with-
out any serious hazards or repercussions. What the
drycleaner wants to do is to continue to improve where
possible and to maintain credibility and customer
goodwill in the community.
The drycleaning operator also needs the coopera-
tion of the various governmental agencies, especially
in regard to how the general media is reporting on the
industry.
Governmental Agency
to the Drycleaning Operator
Given the history of cooperation between the industry
and governmental agencies, the drycleaning operator
would hope for a reasonable and cooperative attitude
on the part of the governmental agencies that interact
with the drycleaning industry.
!
Permits and Fees
There have been steady increases in the rate: of various
fees for licenses, permits, and compliance services. In
some cases, these fees are duplications, for example,
a county requiring the same permit or license already
being paid to the state. In many cases the; fees have
been increased to the point of being unreasonable, as
in New Jersey where the fee for a routine inspection
of a drycleaning establishment has been increased to
$1,330. If the inspector deems it necessary to return
to the establishment an additional $700 Is charged.
Previously, the charge for this inspection was $500.
i
Penalties for Violations \
Neither warnings or a sufficient opportunity to comply
with even minor infractions of EPA or Occupational
Safety and Health Administration (OSHA) iregulattons
are provided for drycleaning operators. Ariel the pen-
alty for some of these infractions are
-------
Communication of Risk Associated
with Drycleaning Operations
in New York State
Judy S. Schreiber, Ph.D.
Bureau of Toxic Substance Assessment
New York State Department of Health
Dr. Schreiber Is a senior research scientist at the New York State Department
of Health with extensive experience in assessing human exposure and health
risks related to chemicals. She Is actively involved in efforts to improve the in-
door air quality In buildings where drycleaning establishments are located.
Dr. Schreiber holds a doctorate in environmental health and toxicology from
the State University of New York's School of Public Health.
As a result of the study the New York State
Department of Health conducted in Albany
confirming suspicions about the high level of
tetrachloroethene levels in apartments located above
drycleaning operations (see earlier presentation), the
Bureau of Toxic Substance Assessment began an out-
reach program to Identify what we consider "high-risk"
drycleaning facilities and to assess the impact these
operations have on residential areas.
We believe that the levels found in these apart-
ments confirmed a previously unrecognized, very high
magnitude exposure for people living near drycleaning
establishments. We found residential exposure levels
that are orders of magnitude higher than a person
would be subject to, for example, living in the proxim-
ity of a hazardous waste site.
I have a lot of experience in different areas of
environmental health, and. in all candor, these expo-
sure levels are really of a much higher magnitude than
Ihave seen in any other environmental area, including
exposure related to contaminated water supplies,
hazardous waste sites, and pesticides. If you compare
residential exposures from drycleaning establishments
to what one would be exposed to living on the same
block as a Superfund hazardous waste site, I doubt you
would find any exposures that would come close.
The outreach program that we undertook has
been very successful, and we had a great deal of
cooperation from the Neighborhood Cleaners Associa-
tion (NCA). The NCA let us use their membership list
to send out our survey requesting information about
the proximity of businesses to residences. The list
comprises about 3.100 drycleaning businesses lo-
cated throughout New York State. The NCA went
further still by sending a letter to members as well as
nonmember drycleaners about a week before we
mailed our survey, encouraging cooperation so that
we could get a better sense of where the problem
drycleaners are located.
Figure 1 shows the survey, which was accompa-
nied by a cover letter explaining some of the results
from the Albany study indicating that there are high
emission levels associated with apartments located in
buildings with drycleaning establishments.
We designed the survey so that it would be very
easy to fill out. Rather than asking for exact numbers,
we used a checkoff system that is set up on a data
base at the State Health Department offices in Albany.
MY CLEANW SURVfV
HOI* CHKX1W AFWtOMtCATf tOX MGARSWa YOU* OTOMTKW.
J. SMMMUMtt
Mhyttfw) Soiwni
D O
Trantltr
.0
Otn.r
a
(no vint} Olher
a ;a
leu HIM 1000 to Craittr in in
t.OOO eetmo* 1000 ooun« 1.000 oownai
a a a
a
«n(M
"a"
Oti«*r
Sttunm
a
Oltitr
a
50 to tOO Ore'at*rinin
=«1 100 FMI
D O .
D
"a"
Our
count nia
Figure 1. Survey form used to solicit information from dry-
cleaning operators In New York State.
108
-------
Pollution Prevention: Drycleanhg
We have gotten a high rate of response for a survey of
this type, considering there is no legal requirement for
participation. I think the NCA contributed signifi-
cantly to the success of the survey by encouraging
members to cooperate. Out of the 3,100 surveys that
were sent out, to date we have gotten back over 1,700,
which is a greater than 50 percent response rate. At
the beginning, I would have been surprised if we
obtained a response rate of 10 or 20 percent.
The program in New York State has been quick to
identify establishments that pose the greatest risk to
the public. The Albany study was conducted in the
summer of 1991. Since that time we have analyzed
the results, published a report, initiated our survey,
and have gotten a fair idea of the location of the
"high-risk" drycleaning operations. :
The distribution of drycleaning operations cov-
ered by our survey is close to evenly split between New
York City and the rest of the state, which is in keeping
with our earlier estimates (Table 1). There may be a
slightly higher percentage in New York City. It should
Table 1. Summary of preliminary results of New York State
drycleaning operations survey (as of May 1,1992).
Location
Bronx
Kings (Brooklyn)
New York
Queens
Richmond
Total NK
Total Statewide,
excluding NYC
Grand Total
Total «
Responses
138
231
218
251
44
882
983
1765
Total 1
Residential
29 (21*)
111 (48*)
113 (52*)
57 (23*)
5 (IB)
315 (36X)
66 (7*)
381 <22X>
Total f
Business
93 (67*)
82 (36*)
69 (32*)
159 (63S)
25 (57*)
428 (491)
50S.(S7X)
933 (53%)
Other or
No Use ;
" <8X) !
28 (12V
8 (4*) !
26 (10*) ,
10 (23*) i
83 (9*)
232 (26X)
315 (18*) '
Dropstore,
Out of Business
5 (4*)
10 (4X)
28 (13*)
9 (4*)
4 («)
56 (6*)
80 <9X)
136 (8*)
Note: Percentages indicate portion of total response. ;
Source: New York Stale Department of Health, Bureau of Toxic Substance Assessment.
be pointed out that we do not know the imputation of
nonresponders, and there could be a'bias in the
responses that we have, compared to the actual dis-
tribution. :
In New York City, 315 of 882 drycleaners who
responded are located in buildings with residences—
about 36 percent. The total number of drycleaning
establishments located in buildings where there are
other businesses (including offices, schopls, and res-
taurants) is close to 50 percent. Thus, the combined
residential and business exposures related to these
New York City operations is about 85 percent. When
we began planning the survey, we assumed that 85 to
90 percent of New York City drycleaners are operating
out of buildings that also house either other busi-
nesses or residences.
The "Other or No Use" column lists data that
includes respondents for whom it was unclear from
the survey information what the drycleaner. intended
to indicate and respondents that operate where there
is no other use of the building (about 9 percent of the
respondents). ;
The last column--"Dropstore, Out of Business"—
lists the number of respondents who indicated that
there is no active drycleaning operation on the prem-
ises (i.e., distribution-point shops) or that drycleaning
services are no longer offered at that location.
Outside of New York City, the distribution of
drycleaning establishments is quite different. Al-
though we surveyed about the same number of dry-
cleaners, we found that only about 7 percent of
respondents operate in the proximity of residences.
Some 57 percent of respondents, however, are located
in buildings that also house other businesses. A large
portion of these operations are located in small malls
where they tend to be next to other service-type
businesses. In many cases, we find that these opera-
tions do have problems with air quality because often
small malls have a single ventilation and circulation
system, which distributes emissions from the dry-
cleaning shop throughout the mall enclosure. We are
particularly concerned about exposures in situations
where a drycleaning shop is near a restaurant or other
food service establishment, since, as we heard in Dr.
Diachenko's presentation, Food and Drug Admini-
stration studies found that butter and margarine
absorb perchloroethylene (perc).
About 30 percent of survey respondents in New
York City operate transfer drycleaning equipment in
buildings with other businesses (Table 2). The per-
centage of New York City respondents operating
transfer machines in the proximity of residences is
Table 2. Preliminary results of New York State drycleaning
operations survey: Drye leaning establishments located in a
building with other businesses (as of May 1,1992).
Location
Bronx
Kings (Brooklyn)
New York
Queens
Richmond
Total HlfC
Total Statewide,
excluding NYC
Grand Total
Total # of Dry Cleaners
in Bldgs. with Businesses
93
82 •
69
159
' 25 '
428
505 !
933 :
MACHINE TYPE
Transfer
31 (33*)
29 (35X)
11 (161)
54 (34X)
2 (8*)
127 (30*)
100 (20*)
227 (24*)
Ory-to-Ory
Ve««
-------
JudyS. Schreiber
Table 3. Preliminary results of New York State drycleaning
operations survey: Drycleaning establishments located In resi-
dential buildings (as of May 1,1992).
Uculon
Broni
King! (BrMMyn)
Kn York
-------
Roundtable Discussion Summary:
Information Dissemination
Discussion about information dissemination
focused on the media coverage of environ-
mental issues (including drycleaning), and
on the industry's approach to dealing with informa-
tion dissemination. The ownership of drycleaning es-
tablishments by members of ethnic group® who may
not speak English as their first language was also
discussed.
The discussion began with an exchange concern-
ing the differences between transfer and :dry-to-dry
machines in terms of their emissions problems.
George Smith of EPA's Office of Air Quality Planning
and Standards asked Bill Seitz of the Neighborhood
Cleaners Association and Judy Schreiber of the New
York State Department of Health to discuss whether
they feel transfer machines are necessarily worse than
dry-to-dry and if so, why. '• .
Bill Seitz explained that in the transfer process,
solvent-laden garments are physically transferred to
a separate reclaimer unit. During this transfer there
is a release of solvent vapors from the cage of the
machine and the garments. In the dry-to-dry opera-
tion, washing and reclaiming operations tike place in
a single closed unit If run properly, the garments
come out dry with only a small residual of perc left in
them. ,,
Dr. Schreiber felt that the problem is not so much
in the type of machine but in the way that it is
operated. A poorly operated dry-to-dry machine can
be as problematic as a transfer machine. She added,
however, that she has yet to see a properly operated
transfer machine.
Bill Seitz noted that of the nine drycleaners shut
down by New York State over concern for apartment
resident exposures, five were operating so-called
state-of-the-art closed-loop dry-to-dry machines. Of
the four transfer operations that had to close, two
were allowed to reopen iafter performing the necessary
maintenance and repairs. If properly maintained,
then, older transfer equipment can operate safely and
effectively, he suggested.
Jack Lauber of the New York State Department of
Environmental Conservation added that a problem
with transfer operations is that clothes may be re-
moved before they are sufficiently dried. Cleaners may
reduce the residence time in the reclaimer unit to
achieve greater production. Also, with older transfer
machines, he added, it can be difficult to obtain
replacement parts. i
Ken Adamson of the Ontario Drycleaners and
Launderers Institute suggested that few transfer ma-
chines anywhere are likely to be operating at maxi-
mum efficiency simply, due to the age of the
equipment He indicated that it is much easier to
achieve low emissions with state-of-the-art dry-to-dry
equipment Nevertheless, some operators of new dry-
to-dry equipment may shorten the drying cycle to
obtain a higher rate of cleaning throughput. >'
The discussion th.en turned to the questionxof
communication with facility operators concerning op-
erational and environmental issues. Ross Beard of
R.R. Street spoke first and addressed the fact that
marry owners do not speak English as their first
language. He estimates that perhaps 25 percent of
facilities nationwide are owned and operated by Kore-
ans. In New York City, lie claims, the figure is probably
higher and may be Increasing. Dr. Schreiber re-
sponded that the regulatory officials in New York, at
least are aware of this. Her office has been in touch
with the Korean Drycleaners Association, and she will
be attending one of their meetings shortly to explain
111
-------
Information Dissemination
the survey that Is being conducted to assist In the
evaluation of apartment resident exposures.
Cynthia Marvin of the California Air Resources
Board estimated that about half of the drycleaners in
California are owned and operated by Koreans. Due
to the language barrier that may exist for these opera-
tors, state officials are considering preparing a com-
pliance assistance program manual that would use
simple "comic book" style diagrams to explain regula-
tions and proper operating procedures.
Elden Dlckenson of the Michigan Department of
Public Health added that about 25 percent of facilities
in that state are Korean-owned and operated.
Attention then turned to the video clip shown by
Bill Seltz of a CBS News report on the hazards asso-
ciated with drycleaning. Lynn Luderer of EPA asked
Caron Chess of Rutgers University for her reaction to
this particular piece of media reporting. Ms. Chess
began by observing that it appeared to be the assump-
tion of most Industry participants that the public's
reaction to the news report would be one of hysteria.
Her own reaction, however, was that there may be
some reason for concern, particularly for those living
above drycleaners. yet she said she did not get the
impression that she should immediately stop taking
her clothes to the cleaners. Industry In general seems
to believe that providing information is dangerous.
Her experience with industry communication issues,
though. Is that public reaction is at its worst when it
appears that Industry may have had information con-
cerning a problem but either dismissed the problem
or failed to reveal the Information. When this happens,
she feels. Industry is perceived as being "uncaring"
and "callous." This Impression is one that they likely
do not wish to convey, she suggested.
Dr. Schrelber agreed that the actual reaction
provoked by the CBS report was much less than the
state officials expected. A total of 50 to 70 calls were
received at the telephone number broadcast with the
report, whereas they were anticipating the possibiliy
of hundreds of calls. Most of those who called were
people living above drycleaners, not drycleaning cus-
tomers. In a diy of 11 million, this seemed to her to
be a very small number of calls. John Meijer of the
International Fabricare Institute responded that 70
calls did seem like a lot Most consumers, he sug-
gested, do not complain, they just don't come back.
Several participants from the New York area
(Jerry Levine, Margaret Round, Bill Seitz) gave testi-
monials as to the general sensationalist nature of the
New York media. Jerry Levine of NCA described how
the CBS reporter had been taken through a state-of-
the-art facility to see an operator that was running a
good shop. Nothing from that visit, however, was ever
shown In the broadcast.
Elden Dickenson provided another anecdotal ex-
ample of inaccurate reporting that hurts the dryclean-
ing industry. An article appearing in one of the Detroit
papers recommended that customers ask their dry-
cleaner when they change their solvent, because that
was the best time to get clothes cleaned, hi reality,
drycleaners do not "change" solvent. They are con-
stantly purifying, recycling, and reusing it.
Scott Lutz of the Bay Area Air Quality Manage-
ment District then addressed the reporting that had
surrounded the district's release of a list of facilities
that had been evaluated using the rtek assessment
methodology required under the Hot Spots Informa-
tion Act, a light-to-know law enacted recently in
California. State officials held a public meeting to
discuss the methodology, the results, and the uncer-
tainties associated with the methodology. Much of the
reporting on the meeting was balanced and non-
alarmist in nature. One paper, which happened to be
in some financial difficulty, had decided to sensation-
alize the issue. It reported the results under the
heading of Top Dirty Thirty"; the dirtiest 30 facilities
in the Bay Area. Of these 30 facilities; 17 were dry-
cleaners. Naturally the industry resented what it felt
was an irresponsible use of the state's analysis to
create a scare concerning drycleaners that may not
have been warranted. i
Faye Dworldn of the Consumer Product Safety
Commission suggested that the industry work with
her office on a joint communication project for con-
sumers. Bill Seitz accepted her offer of assistance and
indicated that NCA would be happy to work with
CPSC.
112
-------
ROUND1 ABLE WRAP-UP
-------
-------
Roundtable Wrap-Up:
Discussion Summary
The wrap-up discussion session provided an
opportunity for participants at the round-
table to generate ideas to address exposure
issues related to drydeaning and to consider options
for follow-up to the roundtable.
The session was organized into three parts. The
first task was to develop a list of issues that had been
raised, or that participants otherwise felt should be
addressed in follow-up activities. The group then
spent time developing a list of Ideas, or ways to
address these issues. Finally, time was allowed for
discussion of potential follow-up activities by EPA.
The bulleted items below represent the issues or
ideas raised during the wrapup session discussion.
The originator of each issue or idea is identified in
parentheses (refer to Appendix A, Attendee List, for
full name and affiliation).
Issues :
• Epidemiological study (Ruder) ,
- National Institute of Occupational Safety
and Health is looking for population to study
• Compendium of risk assessments (Round)
• Total exposure assessment (Schreiber)
- focus on local effects •
- foods, fats, water, air
• Solutions for indoor air problems (Seitz)
• Contact-water disposal through presently
available technologies (Seitz)
• Real estate issue
- land use as affected by drycleaners
• Industry not an adversary, but a partner in
solutions (Seitz)
• Exposure (Bourque)
- cooperation :
- benefits to industry
• Future technologies and regulations (Dworkin)
• Residual perc in clothing needs more study
(Adamson) '
- also in building materials (Schreiber)
• Regulatory coordination—federal, state
(Meijer) .
• Training and certification for drycleaners; Can-
ada's environmental code of practice (Por-
tugais) i
• Sharing of communication materials among
agencies, governments (Portugais)
Ideas
• Form an industry advisory group (Fisher)
- Joint industry/government advisory group
(Bourque)
• Gather information on exposure levels associ-
ated with different types of machines (Bourque)
115
-------
Roundtable Wrap-Up
« Perc emission controls encouraged with tax on
perc (Phillips)
» Develop communication strategy by both gov-
ernment and industry
- should be done separately to enhance credi-
bility of each (Chess)
» Conduct research on risk communication
(Chess)
- effectiveness, target audiences
• Develop funding mechanism for cleanup, espe-
cially for ground water (Cohen)
• Devise alternative incentives for cooperation
(Dworkln)
- example: certification program
• Develop ventilation standards (Lauber)
- What are good standards?
• Involve key environmental organizations in
risk communication effort (Lauber)
• Consider whether drycleaners should be lo-
cated next to homes, food establishments, and
other businesses (Bourque)
• Develop communication program for dry-
cleaners (Chess)
- recommend to association members that
they avoid locating In residential areas or
next to stores, if possible
• Encourage use of pollution prevention to fur-
ther reduce emissions (Round)
• Develop methods for enforcement of more flex-
ible regulatory approaches that can increase
compliance (Marvin)
• Communicate with local and municipal gov-
ernments (Dickinson)
• Solicit OSHA's involvement In the issues
(Schreiber)
• Involve health agencies (ATSDR, CDC, etc.) in
future discussions (Schreiber)
• Hold follow-up roundtable to build on key is-
sues (Bourque)
• Advocate tax on perc or drycleaning services to
pay for cleanup of contamination (Cohen)
• Develop Inexpensive Instrument to monitor In-
door air emissions (Schreiber)
• Reduction of small-size exemption in EPA
NESHAP (Bill Fisher)
• Amend EPA NESHAP to require dry-to-dry re-
frigerated "no-vent" (or equivalent) for new or
reconstructed facilities
• Control/prohibition of new facilities in residen-
tial buildings
- needs to be discussed
• Industry needs to be allowed to eliminate sepa-
rator water discharges
- general permit to allow evaporation should
be sought
• Need multimedia/multiagency coordination on
regulation
• Joint work between agencies and industry on
methods of reducing/eliminating vapor trans-
fer
• Develop financial mechanism for cleanup of
contamination
» Develop joint industry/government position on
cardnogenicity and toxicity
Follow-Up Activities
Finally, several participants, led by Ross Beard and
Margaret Round, asked the EPA organizers to discuss
their expectations for the roundtable and the type of
follow-up to expect. Bob Lee of the Office of Pollution
Prevention & Toxics (OPPT) explained that the round-
table is an example of some of the new non-regulatory
activities that his office is working on to foster com-
munication on pollution prevention issues. Llbby
Parker, alsoofOPPT, added that one of the main goals
was to bring together a diverse group of experts that
would ordinarily not get a chance to discuss ideas for
pollution prevention related to drycleaning. This ob-
jective was applauded by the roundtable participants,
who indicated that the roundtable format had fostered
a unique and valuable exchange of views.
Libby Parker also discussed, to the extent possi-
ble at the time, the follow-up activities that EPA would
be pursuing. The first of these, of course, Is publica-
tion of the proceedings from the roundtable, complete
with a summarized report on each discussion session.
116
-------
Pollution Prevention: Drycleaning
Following the toundtable, EPA managers at the office
director level and higher would be briefed on the two
days of meetings, to see what types of follow-up they
may wish to commit resources to. Bob Lee added that
while little could be said immediately concerning po-
tential follow-up to the round table, OPPT would make
an effort to keep the participants informed about any
activities pursued.
117
-------
-------
APPENDIX A
Attendees List
-------
-------
: Pollution Rrevenfibn: Orycfearing
Attendees List
Ken Adamson
Drydeaner-Launderers Institute of Ontario
P.O. Box 91128 - Effort Square
Hamilton, Ontario L8N4G3
CANADA
(415)522-4651
(415) 529-5856 FAX
Yoshitado Aoyama
Japan Cleaning Machinery Association
Tokyo Sensun Kikai
Seisakusho Company, Ltd.
6-2, Ohashi 1-chome
Megrc-ku, Tokyo 153
Japan
81-3-3780-8783
81-3-5489-7075 FAX
L. Ross Beard
R.R. Street & Company
625 Enterprise Drive
Oak Brook, IL 60521
(708)571-4242
(708) 571-4248 FAX
Dr. Elizabeth Bourque
Massachusetts Department of Health
305 South Street
Jamaica Plain, MA 02130
(617)522-3700
Scott Brumburgh
Roundtabte Facilitator
2801 Spencer Road
Chevy Chase, MD 20815
(301)589-4237
PANELISTS
Barry Bunte
Executive Director
California Fabricare Association
10615 South De Anze Boulevard
Cuitettino, CA 95014-4456
(403)252-1746
(403) 242-5951 FAX
JeffCantln
Sr. Economist
Eastern Research Group, Inc.
110 Hartwell Avenue
Lexington, MA 02173-3198
(617)674-7315
(617) 674-2851 FAX
Carpn Chess
Environmental Communication Research
Program
Rutgers University
122: Ryder Lane
New Brunswick, N J 08903
(903) 932-8795
(908) 932-7815 FAX
Wendy L Cohen
Senior Water Resource Control Engineer
California Regional Water Quality Control
Board
3443 Routier Road - Suite A
Sacramento, CA 95827-3098
(916)361-5676
(916) 361-5686 FAX
Torn Cortina
Halogenated Solvents Industry
Association (HSIA)
* 122519fi Street, NW - Suite 300
Washington, DC 20036
(202!) 223-5890
(205!) 223-5979 FAX
WaKher den Otter
TNC) Cleaning Techniques
Research Institute
P.O. Box 70 (2600 AB)
Schoemakerstraat 97
Delft, the Netherlands
31-15-6977-74
31-15-5602-58 FAX
Dr. Gregory Diachenko (HFF-413)
U.S., Food and Drug Administration
200 C Street, SW
Washington, DC 20204
(2021)205-4319
Elden Dickinson
Michigan Department of Public Health
Occupational Health Division
3423 North Logan Street
P.O. Box 30195
Lansing, Ml 48909
(517) 335-8250
Faye Dworfcin
Econmic Analysis Branch
Consumer Product Safety Commission
5401 West Bard Avenue
Bethesda, MD20816
(301) 504-0962
(301) 504-0124 FAX
121
-------
William (Bill) Rsher
International Fabricare Institute (IFI)
12251 Tech Road
Silver Spring. MD 20904
(301)622-1900
(301) 236-9320 FAX
Tom Cause
Business Development Division
Washington District Office
U.S. Small Business Administration
111118th Street, NW-6th Floor
P.O. Box 19993
Washington, DC 20036-9993
(202)634-1500x280
(202) 634-1803 FAX
OhadJehass!(TS-779)
Economics, Exposure & Technology Division
Office of Pollution Prevention & Toxics
U.S. Environmental Protection Agency
401 M Street, SW
Washington. DC 20460
(202)260-6911
(202)2600981 FAX
Brenda L Jellicorse
Economist
Research Triangle Institute
P.O. Box 12194
Research Triangle Park, NC 27709
(919)541-6116
(919) 541-5945 FAX
Pauline Johnston (ANR-445W)
Indoor Air Division
U.S. Environmental Protection Agency
401 M Street, SW
Washington, DC 20460
(202)233-9051
(202) 233-9555 FAX
Patrick Kennedy (TS-779)
Environmental Assessment Branch
Office of Pollution Prevention & Toxics
U.S. Environmental Protection Agency
401 M Street, SW
Washington, DC 20460
(202)260-3916
Rajlb Khottry
Waste Management Branch
Ontario Ministry of the Environment
14th ROOT
2 StClalr Avenue West
Toronto, Ontario
M4V1 IS Canada
(415)323-5226
Junji Kubota
All Japan Laundry & Drydeaning
Association
5-4 Ginza 7-Chome
Chuo-ku, Tokyo 104
Japan
81-3-3571-2391
81-3-35740866 FAX
Jack Lauber
New York State Department
of Environmental Conservation
50 Wolf Road
Albany. NY 12233-3254
(518)457-7688
(518) 457-0794 FAX
Dr. Josef Kurz
Director of Research
Forschungsinstitut Hohenstein
Schloss Hohenstein
D-7124 Boennkjheim
Germany
49-7143271-0
49-7143271-51 FAX
Robert E. Lee (TS-779)
Economics, Exposure & Technology Division
Office of Pollution Prevention & Toxics
U.S. Environmental Protection Agency
401 M Street, SW
Washington. DC 20460
(202)260-1670
(202) 260-0981 FAX
Jerry Levlne
Associate Director
Neighborhood Cleaners Association
116 East 27th Street
New York, NY 10016-8998
(212)684-0945
(212) 725-4714 FAX
Lynn Luderer (PM-233X)
Office of Policy, Planning & Evaluation
U.S. Environmental Protection Agency
401M Street
Washington, DC 20460
(202)260-6995
Scott Lutz
Bay Area Air Quality Management District
939 Ellis Street
San Francisco, CA 94109
(415)749-4676
(415) 749-5030 FAX
Cynthia Marvin
California Air Resources Board
P.O. Box 2815 (SSD)
Sacramento, CA 95812
(916)327-5981
(916)327-5621 FAX
John Meljer
International Fabricare Institute (IFI)
12251 Tech Road
Silver Spring, MD 20904
(301)622-1900
(301) 236-9320 FAX
Dr. A.A. Munshi
New York City Department of Health
346 Broadway - Room 707E
New York, NY 10013
(212)566-3075
(212)566-3331 FAX
Jean E. (Libby) Parker (TS-779)
Economics, Exposure & Technology Division
Office of Pollution Prevention & Toxics
U.S. Environmental Protection Agency
401 M Street. SW
Washington, DC 20460
(202) 260-0686
(202) 260-0981 FAX ,
Josee Portugais
Environment Canada
Place Vincent Massey
Ottawa, Ontario K1AOH3
(819)953-1136
(819) 953-5595 FAX
Scott Prothero (TS-779)
Economics, Exposure & Technology Division
Office of Pollution Prevention & Toxics
U.S. Environmental Protection Agency
401 M Street, SW
Washington, DC 20460
(202) 260-1566
Stephen Risotto
Executive Director
Center for Emissions Control
1225 19th Street, NW - Suite 300
Washington, DC 20036
(202) 785-4374
(202) 223-5979 FAX
Dr. Thomas Robinson
Halogenated Solvents Industry Alliance
Suite 300
1225 19th Street NW
Washington, DC 20036
(202) 223-5890
(202) 223-5979 FAX
Margaret Round
Northeast States for Coordinated Air Use
Management ;
129 Portland Street
Boston, MA 02114
(617)367-8540
(617) 742-9162 FAX \
122
-------
Pollution Prevention: Drycleaning
Avima M. Ruder
National Institute for Occupational Safety
and Health (NIOSH)
4676 Columbia Parkway (R16)
Cincinnati, OH 45226
(513)841-4481
(513) 841-4540 FAX
Dr. Judith Schreiber
Bureau of Toxic Substance Assessment
New York State Department of Health
2 University Place - Room 200
Albany, NY 12203-3313
(518)458-6405
(518) 458-6434 FAX
BillSettz
Executive Director
Neighborhood Cleaners Association
116 East 27th Street
New York, NY 10016-8998
(212)684-0945
(212) 725-4714 FAX
George Smith (MD-13)
Office of Air Quality Planning
and Standards
U.S. Environmental Protection Agency
Research Triangle Park, NC 27711
(919)541-1549
(919) 541-5661 FAX
Dr. Edward Stein (N3718)
Occupational Safety and Health
Administration (OSHA)
U.S. Department of Labor
200 Constitution Avenue, NW
Washington, DC 20210
(202)523-7111
(202) 523-7125 FAX
Shozo Tamura
General Manager
Nippon Mining Company
Six East 43rd Street
New York, NY 10017
(212)682-5060
Dr. Bmce Tichenor
Air & Energy Engineering
Research Laboratory
Indoor Air Division
U.S. Environmental Protection Agency
Research Triangle Institute
Research Triangle Park, NC 27711
(919)541-2991
(919) 541-2157 FAX
Dr. Mary Ellen Weber (TS-779)
Director, Economics, Exposure &
Technology Division
Office of Pollution Prevention and Toxics
U.S. Environmental Protection Agency
401 M Street SW
Washington, DC 20460
(202)260-0667
(202) 260-0981 FAX
Dr. Hans-Dietrich Weigmann
Associate Director of Research
TRI/Princeton
601 Prospect Avenue
P.O. Box 625
Princeton, NJ 08542
(609)924-3150
(609) 683-7836 FAX
Dr. Msmf red Werrtz
Vice Pres. Technology &
Environmental Affairs
R.R. Street & Company
625 Enterprise Drive
Oak Brook, IL 60521
(708)571-4242
(708) 571-4248 FAX
Robert Alfrey
Underwriters Laboratories
333 Pfingsten Road
Northbrook, II 60062
(708) 272-8800 (X3135)
(708) 272-7030 FAX
Joyce Chandler (EN-341W)
Stationary Source Compliance Division
Office of Air and Radiation
U.S. Environmental Protection Agency
401 M Street SW
Washington, DC 20460
(703)308-8713
(703) 308-8738 FAX
Jesica DavIs-O'Hay
National Clothes Line
717 East Chelten Avenue
Philadelphia, PA 19114
(215)843-9795
(215) 843-8511 FAX
OBSERVERS
UmesJi Dhalakia (2AWM-AC)
Air Programs Office
U.S. EPA Region 2
26 Federal Plaza
Room 100
New York, NY 10279
(212) 234-6676
Jane l-ngert (EN-341 W)
Stationary Source Compliance Division
Office of Air and Radiation
U.S. Environmental Protection Agency
401 M Street SW
Washington, DC 20460
(703)308-8677
(703) 308-8738 FAX
Earl Fisher, Editor
American Drycteaner
Crane (Enterprises
500 North Dearborn Street - Suite 1100
Chicago, IL 61610
(312) 337-7700
Elizabeth Leppin
International Fabricare Institute
12251 Tech Road
Silver Spring, MD 20904
(301)622-1900
(301)236-9320 FAX
Fred Ntetz
Economics, Exposure & Technology Division
Office of Pollution Prevention and Toxics
U.S. Environmental Protection Agency
401 M Street SW
Washington, DC 20460
(202) 230-0684
Marian Mudar
New York Facilities Corporation
50 Wolf Road
Albany, NY 12205
123
-------
Alan J. Philips
Air QuaSty Laboratories
928 Seventh Street - Unite
Santa Monica. CA 91403
(310)395-3888
(310)393-5606 FAX
Dan Restalll
Underwriters Laboratories
333 Pfingsten Road
Northbrook, II 60062
(708) 272-8800
(708) 272-7030 FAX
Shari Zuskin
Office of Water
U.S. Environmental Protection Agency
401 M Street SW
Washington, DC 20460
(202)260-7130 ''
124
-------
APPENDIX B
Supplemental Material
-------
-------
Submissions from
Judy Schreiber
New York State Department
of Health
127
-------
-------
Investigation of
Indoor Air Contamination in
Residences Above Dry Cleaners
October 1991
New York State Department of Health
Bureau of Toxic Substance Assessment
i .
I 2 University Place
Albany, New York 12203-3399
New York State Department of Environmental Conservation
Division of Air Resuorces
! 50 Wolf Road
Albany, New York 12233-7010
129
-------
EXECUTIVE SUMMARY
In response to a complaint, in 1990, an investigation in Mahopac, New York found
elevated air concentrations of tetrachloroethene in apartments above a first floor dry
cleaning facility. The highest level measured exceeded the Occupational Safety and Health
Administration (OSHA) workplace standard (25 ppm or 170,000 mcg/cu.m). The present
study was carried out to ascertain whether similar situations might exist elsewhere in the
State.
The objective of this investigation was to determine if tetrachloroethene levels in the
indoor air of residences located in the same building as dry cleaning facilities were higher
than levels in residences not near a dry cleaner. Data were also collected to evaluate what
cleaning equipment or other factors might be contributing to air contamination in the
dwellings.
Dry cleaning facilites in the Capital District were surveyed. Of 102 dry cleaners listed
in the yellow pages of the telephone book, 67 cleaned or pressed on the premises. Dwelling
units located in the same building as a dry cleaner were considered potential study homes.
Twenty apartments located above 14 dry cleaning establishments that clean or press on
premises were identified. Of the fourteen dry cleaning establishments, six were eliminated
from consideration because the apartments were vacant or used for storage purposes only.
Another dry cleaner was eliminated from the study because only pressing was conducted
on the premises, and one dry cleaning establishment did not use tetrachloroethene. Thus,
six. of 102 surveyed dry cleaners (6%) had occupied apartments above facilities which clean
on premises using tetrachloroethene. :
These six apartments were'evaluated. Six additional apartments that had similar
building and neighborhood characteristics without a nearby source of tetrachloroethene
were selected as controls. At each location, both indoors and outdoors, two consecutive
twelve-hour air samples'were collected: the first from 7 AM to 7 PM (AM sample) and the
second from 7 PM to 7AM (PM sample). All samples for a study residence and its control
were collected concurrently. Each dry cleaning operation was also inspected on the same
day. The type of dry cleaning equipment, the volume of tetrachloroethene used, the
presence or detection of odors, building characteristics and other features of the dry
cleaning operation were noted.
A wide variety of conditions within the dry cleaning establishments were found. Three
of the dry cleaners use machines which require the clothes to be transferred between the
wash and dry cycles (transfer machines). Two of the dry cleaning establishments use
machines that conduct both wash and dry cycles in one machine and do not require transfer
of clothing between cycles (dry-to-dry machines). Lastly, one dry cleaner used a Very old
dry-to-dry machine in poor operating condition. This dry-to-dry was considered separately.
Significantly elevated levels of tetrachloroethene were found in the indoor ajr of the
apartments located above each of the dry cleaners in the AM samples (range 300 to 55,000
mcg/cu.m) compared to the control residences (range <6.7 to 103 mcg/cu.m). Similar
results were found in the PM samples where concentrations of tetrachloroethene in the
study residences (range 100 to 36,500 mcg/cu.m) also greatly exceeded the concentrations
in the control residences (<6.7 to 77 mcg/cu.m). Although air concentrations in the .
apartments were usually less at night than during the day, the study residences always had
higher concentrations of tetrachloroethene than the control residences. The
tetrachloroethene concentrations in outdoor air near the dry cleaners were also significantly
elevated compared to control locations away from the dry cleaners, and these levels were
less than the indoor levels.
130
-------
The type of dry cleaning machine was significantly associated with the concentration
of tetrachloroethene found in the apartment above, even though only six residences were
evaluated. The tetrachloroethene levels in the apartments above dry cleaners using transfer
machines are significantly elevated (AM range 1730 to 17,000 mcg/cu.rn and PM range 1350
to 14,000 mcg/cu.m) compared to those using dry-to-dry machines (AM range 300 to 440
mcg/cu.m and PM range 100 to 160 mcg/cu.m). The apartments above the old dry-to-dry unit
had the highest concentrations of all (AM 55,000 and PM 36,500 mcg/cu.m).
Among the dry cleaner characteristics noted or measured, the best predictor of the
level of tetrachloroethene in the apartment was the tetrachloroethene level at the pressing
station in the dry cleaning establishment. However, this correlation and the lack of other
significant correlations may be spurious, the result of small numbers of samples A strong
correlation was also found between AM and PM tetrachloroethene levels in the apartments
131
-------
REPORT ON AN INVESTIGATION OF INDOOR AIR IN RESIDENCES
ABOVE DRY CLEANERS
List of Tables, Appendices and Attachments
Table 1. Dry cleaner Survey Operations Information
Table 2. Tetrachloroethene Concentrations for Study and Control Residences (mcg/cu.m)
|
Table 3. Summary of Tetrachloroethene Concentrations for Study and Control Residences
(mcg/cu.m) " ;
Table 4. Range and Mean Volatile Organic Chemical Concentrations in Indoor Air (AM)
Compared to Other Studies (mcg/cu.m) ;
Table 5. Range and Mean Volatile Organic Chemical Concentrations in Indoor Air (PM)
Compared to Other Studies (mcg/cu.m) [
Table 6. Range and Mean Volatile Organic Chemical Concentrations in Outdoor Air (AM)
Compared to other Studies (mcg/cu.m).
Table 7. Range and Mean Volatile Organic Chemical Concentrations in Outdoor Air (PM)
Compound to other Studies (mcg/cu.m).
Abbreviations:
mcg/cu.m - micrograms per cubic meter
ppb - parts per billion
ppm - parts per million
VOC - volatile organic chemical
Appendices and additional copies of this report are available on request from the NYS
Department of Health, 2 University Place, Albany, N.Y. 12203-3399. '•
Appendix A. Survey of Capital District Dry Cleaning Facilities
Appendix B. Resident Information
Appendix C. Field Data Forms
Appendix D. Variables Used for Data Analysis
#12050660
132
-------
Indoor Air Contamination in Residences
above Dry Cleaners
Introduction , j
Two recent New York State Department of Health (NYSDOH) investigations of indoor
air in residences near dry cleaners found tetrachloroethene levels above the levels typically
found in indoor air. In one case, the level of tetrachloroethene in an apartment above a dry
cleaner was higher than the standard for workplace air. j
NYSDOH conducted the present investigation to determine if these situations are
widespread. The objective of this study was to determine if tetrachioroethene levels in the
indoor air of residences located in the same building as dry cleaning facilities were higher
than levels in residences not near a dry cleaner. Data were also collected to evaluate what
cleaning equipment and practices might be contributing to air contamination in the
dwellings. :
In 1990, an investigation in Mahopac, New York, found elevated levels of
tetrachloroethene in second and third floor apartments located directly above a first floor dry
cleaning facility. A laundromat with dry cleaning equipment was also located in an adjacent
building. The highest tetrachloroethene level detected in one apartment was 197,000
micrograms of tetrachloroethene per cubic meter of air (mcg/cu.m) measured over a twelve
hour period, which is above the Occupational Safety and Health Administration (OSHA)
standard (8-hour time weighted average) for workplace exposure (170,000 mcg/cu.m).
Elevated tetrachloroethene levels in the apartment above the cleaners were observed even
when the dry cleaning machines were not being-operated (Putnam Co. Health Dept., 1990).
In West Seneca, New York, a level of 85 mcg/cu.m was detected in a home next door
to a dry cleaning facility. The outdoor level was 140 mcg/cu.m (NYS Department of Health,
1989). Although these levels are below levels measured in Mahopac, they are well above
the mean values reported in national studies of tetrachloroethene levefs (USEPA, 1987- Shah
and Heyerdahl, 1988). |
I •
In Germany, a number of studies have also found elevated levels of tetrachloroethene
in residences near dry cleaners. The International Fabricare Institute,, an association of
professional drycleaners and launderers, also reports concentrations of tetrachloroethene
in buildings near dry cleaning establishments. The results of these studies are presented
in the Discussion Section of this report. ;
Methodology "
Site Selection ; •' •
i .
In the summer of 1990, Capital District dry cleaning facilities were surveyed
(Appendix A). The Yellow Pages of the telephone book listed 102 dry cleaners. A telephone
survey identified 67 facilities with cleaning or pressing on the premises. Fourteen of these
facilities were in buildings that also'.contained dwelling units and 15 others were within 50
feet of buildings with dwelling units. Thus, forty-three percent (29 of 67) of Capital District
dry cleaners surveyed who clean or press on the premises are proximate to dwelling units.
Of all the 102 dry cleaners surveyed, twenty-eight percent (29 of 102) are proximate to
dwelling units.
Page 1
133
-------
Dwelling units located in the same building as a dry cleaner we're considered potential
study homes. The dry cleaner survey identified 20 apartments located above the 14 dry
cleaning establishments that clean or press on the premises. Since most apartments above
the dry cleaning establishments are owned by the proprietor of the dry cleaners, cooperation
for sampling was first secured from the owner of the dry cleaners and then from the
apartment dwellers. Six dry cleaning establishments were eliminated from consideration in
the study because the apartments located above them were either vacant or only used for
storage purposes. Also eliminated from the study were one dry cleaner where only pressing
was conducted on the premises and one dry cleaning establishment that did not use
tetrachloroethene. Thus, six of 102 surveyed dry cleaners (6%) had occupied apartments
above facilities which clean on premises. Samples were collected at these six units, where
the owners and residents agreed to participate.
Prior to sample collection, the dwelling was surveyed and the resident interviewed to
determine the best room for sampling. Based on possible conduits to the dry cleaners
(stairways, pipe chases, etc.) and the location of odors that residents had noticed previously,
the room most likely to have the highest tetrachloroethene levels was chosen for sampling.
A control home, located at least 100 meters away from each dry cleaner was sampled
at the same time. The control home was similar to the study home in building type, age and
neighborhood (where possible), and was not near any obvious source of tetrachloroethene.
The sample in the control home was collected in the living room or dining room. Outdoor
air samples were taken near the dry cleaner and near the control home concurrently with
indoor samples.
!
Initial Survey and Contact With Residents
Residents of dwelling units above dry cleaners and potential control homes were
contacted by NYSDOH personnel initially using a door-to-door survey. A fact sheet on the
study and a letter of introduction were provided to the residents to explain the purpose of the
investigation (Appendix B). If residents were willing to participate, a permission form and
a preliminary questionnaire (Appendix B) were completed with basic information (name,
address, telephone number, availability). If residents were not at home, the written
materials were left at the home. Names of residents not at home were determined from
mailboxes or neighbors and telephone numbers were obtained from the telephone book. A
second attempt to contact residents not at home was made by telephone or door-to-door.
Investigation of Dry Cleaner Operation
Staff of the New York State Department of Environmental Conservation (NYSDEC)
accompanied the NYSDOH sampling team and inspected the dry cleaning operation on the
sampling day. NYSDEC personnel noted the type of dry cleaning equipment, the volume of
tetrachloroethene used, the presence of odors or detection of tetrachloroethene with a PID
(photoionization detector), the relative quality of housekeeping operations involving
tetrachloroethene, the location of emission points from the dry cleaning process and
activities in the cleaner at the time air samples were collected in the apartments. Also noted
were types of ceilings, openings in ceilings, missing ceiling tiles, pipe chases and other
potential conduits. Table 1 summarizes this information for the six facilities. The field data
are detailed in Appendix C.
Air Sampling
When residents were contacted to schedule a sampling date, an explanation of the
sampling procedure was provided. They were requested not to introduce any freshly
Page 2
134
-------
the week before the -mpling
tho o/ithOUgh -h! samP'in9 Pr°tocol specified that windows and doors should be closed for
the 24-hour period prior to sampling, there were differences in ventflation at the study and
dosed wtdeonwrwe?PUV0 ^ hOt Weath<7.r' the residen* were not asked ?o keVp wiLows
HnS' .W'nd°ws were °Pen dur'ng sampling periods at study residences No 4 and 5
cosed at study res.dences No. 3 and 6, and not specified for study residences No 1 I nd 2
Windows were open during sampling periods at control residences N C1 C2 and C5
closed at control res.dences No. C4 and C6, and not specified for control residence No! C3.
All samples for a study residence and its control were collected concurrently hv
equipment mstalled by NYSDOH personnel and operated by efeSSnic t ^mers A feach
hrSVromT'AMToS3^^^^
referred \to B* I PM ^ P.M^ierrhed to f AM samples) and the second from 7 PM to 7 AM
j
Sample Analysis and QA/QC ,j !
h h ln some cases- «n,ple dlkwas required to
ntho t V6ry h'gh levels of tetrachloroethene. When this situation occurred the
other analytes were not analyzed (NA) because the detection limits werelinac^bTy high.
Statistical Methods : '
C°effiCientS 3nd °ther Statistics were generated using SPSS/PC+ .
Page 3
135
-------
The Mann-Whitney non-parametric test can be used to compare two groups having a
small number of samples. In this statistical test, all the tetrachloroethene results for a
sampling period for study and control residences are combined into one group and ranked.
If the study residences and control residences had similar tetrachloroethene levels, we
would expect to find homes from each group located throughout this ranking. If there were
a significant difference between the tetrachloroethene levels in the two types of residences,
more residences in one group would be ranked higher than the other group. A p-value equal
to or less than 0.05 indicates there is a significant difference between the two groups.
The strength of an association between continuous variables is assessed by the
correlation coefficient R2. The closer the R2 is to 1.0, the more closely associated are the two
variables. The strength of the association between a discrete variable and a continuous
variable is assessed by the analysis of variance (ANOVA). A p-value of equal to or,less than
0.05 indicates statistical significance for both correlation coefficients and ANOVA •
relationships.
Results
Facility Operating Characteristics
A wide variety of conditions were found within the dry cleaning establishments (See
Table 1). Three of the dry cleaners (No. 2, 3 and 4) use machines which require the clothes
to be transferred between the wash and dry cycles. These are referred to as transfer
machines. Two of the dry cleaning establishments (No. 5 and 6) use machines that conduct
both wash and dry cycles in one machine and do not require transfer of clothing between
cycles. These are referred to as dry-to-dry machines. Lastly, one dry cleaner (No, 1) used
a very old dry-to-dry machine in poor operating condition. Because the results of ;air
sampling at the dry cleaning facility using this machine and the adjacent study residence
were so different than their counterparts, this dry-to-dry machine is considered separately
from the other dry-to-dry machines. ,
Tetrachloroethene Levels
Tetrachloroethene results for study homes, control homes and ambient air are
summarized in Tables 2 and 3. The results indicate clearly elevated levels of
tetrachloroethene in the indoor air of the apartments located above each of the dry cleaners
(range from 300 to 55,000 mcg/cu.m) compared to the control residences (range from <6.7
to 103 mcg/cu.m) for AM 12-hour samples (Table 2). Similar results were found for the
indoor air PM 12-hour samples where concentrations ranged from 100 to 36,500 mcg/cu.m
in apartments above the dry cleaners while the control residences ranged from < 6.7 to 77
mcg/cu.m. Outdoor air near the dry cleaners for the AM and PM samples were also elevated
compared to controls (Table 2).
A comparison of PM and AM indoor air concentrations of tetrachloroethene in the
study residences indicates that the PM air concentrations are almost always lower than the
concentrations measured in the corresponding AM samples. It is notable that the levels of
tetrachloroethen'e in the study residences do not decrease to control residence levels in the
PM sampling period, but remain substantially elevated despite the discontinuation of the
active use of the dry cleaning machines during the PM sampling period. Interestingly, at
study residence No. 6, the levels of terachloroethene actually increased in the PM sampling
period for both indoor and outdoor sample locations. According to the dry cleaner at this
location, no dry cleaning was conducted there during the PM sampling period.
Page 4
136~
-------
tn
•
transfer"
n 7 f
nnn f lfn°nS
had °
YPe
^ oroetnene leve|s in indoor and ambient samples grouped
d-ry Cleamn9 unit in the dry cleaners below the study residencps
°f ^ hlo™«thene of residences located above dry c^ners
much higher (1730 to 17,000 mcg/cu.m) than the
residences 'ocated above dry cleaners using dry-to-dry machines
ab°ve dry cleaner No'1 with ^e old dry-L day un*,
had
Other Volatile Organic Chemicals (VOCs)
n/no 5 prese"t the ran9e and mean concentrations of all the volatile organic
ni ?thS) analyzed in the indoor AM ^d PM air samples, respectively. TablX 8
AM and PM 1 s6 ran,9e 8"d "T concentrations of all the VOCs analyzed in the ambient
elevated^vp.^ 3 h P ' resp^'f '^ One ambfent sample at control residence No. 4 had
elevated levels of benzene and toluene, possibly related to gasoline. ; With the exceotion of
mstudv a^ont30,01 ^ tetra^loroethe- -su.ts at stu'dy residences the VoSLted
LI thJ r \i ^ SamP'!S WSre comParable to findings of the National VOC
Studv the L S FnJmn P?1UDe f^essment Met"°d°'ogy (TEAM) Studies. In the TEAM
for indnnr ^ Af in 7 ? 3 Pr°tect.on Agency reported a mean tetrachloroethene level
CDA M *° , f I J mc9/cu-m and a mean outdoor level of 6.04 mcg/cu.rn (EPA 1987) The
EPA National Ambent Volatile Orgahlc Chemicals (VOCs) Database reports a me'an'
tetrachloroethene level in indoor air of 20.7 mcg/cu.m (Shah and Heyerdahl, 1988)
Discussion
a"alysis of *h? data from tn's study is hindered by the small number of
res.dences and 6 control residences) and by the lack of
in t v r atam, \he SlUdy residences- The 'ack of normal distribution of results
Student's tytpl ThoM VIolaA^ the statistical assumptions underlying the use of the
non nnrm VS?; If- Ma"n-Whltney inon-parametric test, however, avoids the problem of
non-normal distribution by assigning ranks to the concentrations measured.
stnHvnHt, differences in mean; tetrachloroethene concentrations between
study and control reSIdences, as evaluated by the Mann-Whitney test, were found for indoor
sampTef 8Sl ^ PM Sampfes' outdoor air AM samP'es and outdoor air PM
f
** "***, *u 6ValUat8 3 measure^ent made at an individual study
°f the C°ntr°' residences' because the control data are
i
the tetrhrnoth cnaracteristics of the dry cleaning facility which potentially impact
Somf nfth I e,C°.nCentratl°n in the indoor air of the ^artment above the facility
Some of these characteristics may be expressed quantitatively, such as the number of
£n?J 5 '" USe 3nd the concentration of tetrachloroethene at various locations In the
^eseynce an^InT' ^ fcharacter,istics are subjective and/or qualititive such as he
presence and intensity of odors, the existence of conduits to the upstairs residence and the
maintenance and upkeep of the facility. The small number of dry cleaning Sies and
Page 5
-------
residences evaluated in this study limits the conclusions that can be extrapolated to the
larger population of dry cleaning facilites and adjacent apartments.
Statistical comparisons were made to see if correlations exist between
tetrachloroethene levels in the study residences and the type of dry cleaning equipment or
operating characteristics of the dry cleaning facility. The variables used for these analyses
are shown in Appendix D. This study included the measurement of continuous variables
(such as the concentrations of tetrachlorethene and othe VOCs) and discrete variables (such
as the type of dry cleaning equipment). Discrete variables are those that have an assigned
arbitrary value to represent a category. The discrete variables evaluated in this study are
dry cleaner type, ceiling type and vent locations. :
The six dry cleaning facilities were categorized into three groups: those with transfer
machines (3), those with dry-to-dry units (2) and one with a poor quality dry-to-dry unit.
Despite the small number of facilities in each category, a statistically significant association
was found between both the AM and PM indoor air concentrations of tetrachloroethene in
the apartments above the dry cleaner and the type of dry cleaning machine used in the
facility, as evaluated by ANOVA.' The residences above dry cleaners using transfer
machines had significantly higher tetrachloroethene concentrations in the AM and PM indoor
air samples compared to those above dry cleaners using dry-to-dry machines. The
residence above the old dry-to-dry unit had the highest tetrachloroethene level of any
residence studied.
The location of the exhaust vents in a dry cleaning facility with respect to the
tetrachloroethene levels in the study apartments was also assessed by ANOVA. The
association was not significant. The type of ceiling in the dry cleaning establishment with
respect to the tetrachloroethene levels in the study apartments was also not significant by
ANOVA. The lack of significance for these variables (vent location and ceiling type) may be
a function of the very small numbers available in each category. Of the three discrete
variables studied, only dry cleaner machine type had a statistically significant association
with the level of tetrachloroethene detected in the apartment above.
The continuous variables which were found to be highly correlated with AM indoor air
tetrachloroethene concentrations at statistically significant levels (p<0.05) were 1) jndoor
air PM tetrachloroethene concentrations (R2 = 0.98), and 2) the maximum tetrachloroethene
concentrations at the dry cleaner pressing station (R2 = 0.93). Variables which were not
correlated with indoor air tetrachloroethene concentrations included the tetrachloroethene
concentrations measured at the front of the dry cleaning machine (washer or dryer) at the
exhaust fan, and at the garment area. All of the associations as well as lack of associations
should be considered tentative at best since the small numbers of samples and wide range
of tetrachloroethene concentrations weaken the conclusions which can be drawn.
Other Studies
Several studies conducted in Germany have evaluated indoor air quality in residences
near dry cleaners. Schaefer and Hohmann (1989) found a range of indoor air
tetrachloroethene concentrations of 30 to 28,000 mcg/cu.m in apartments adjacent to dry
cleaners. Fifty percent of the 38 apartments studied were found to contain tetrachloroethene
concentrations greater than 1,000 mcg/cu.m based on a 7-day air sample. Buildings with
concrete floors separating the dry cleaner from the apartments had lower concentrations in
the apartment than buildings with wood beam floors. Of seventeen buildings with wood
beam floors separating the dry cleaners from the apartments, seventy-six percent exceeded
1,000 mcg/cu.m tetrachloroethene in the indoor air of the apartment. Of twenty one buildings
Page 6
-------
with concrete floors separating the dry cleaners from the apartments, twenty nine percent
exceeded 1,000 mcg/cu.m tetrachloroethene in the indoor air of the apartment.
Six residences were monitored before and after cleanup measures were taken in the
dry cleaner. Cleanup measures included installation of exhaust devices between floors,
covering floors with aluminum foil, control of leaks and disposal of distillation residues.
Tetrachloroethene levels in the indoor air of apartments decreased after cleanup: the mean
tetrachloroethene level was 7,000 mcg/cu.m before cleanup and 2,500 mcg/cu.m after .
cleanup measures. However, fifty percent of the residences still exceeded 1,000 mcg/.cu.m
tetrachloroethene in the indoor air after cleanup measures. I
i • !
Reinhard, Dulson and Exner (1989) collected 10-minute air samples every half hour
from 8 AM to 7:30 PM in five apartments near dry cleaners and one control apartment. Mean
concentrations of tetrachloroethene in indoor air of the study apartments ranged from 200 to
1,400 mcg/cu.m (5 of the 6 means were below 1,000 mcg/cu.m). The mean tetrachloroethene
level in the control apartment was 2 mcg/cu.m. Concentrations within each apartment
varied considerably at different times of the day.
! i1
The International Fabricare Institute (1990) recently studied the impact of
tetrachloroethene from dry cleaners on adjacent locations. Passive monitoring badges were
used to measure 8-hour time-weighted average (TWA) concentrations in locations adjacent
to 21 dry cleaning plants. Fifteen of the plants used transfer equipment and six used
dry-to-dry equipment. The mean TWA for tetrachloroethene for all 21 adjacent locations was
73,900 mcg/m3. The International Fabricare Institute reported that the most common causes
of tetrachloroethene levels in adjacent areas included problems with the ventilation system,
accumulation of tetrachloroethene over suspended ceilings and locations of buildings in
relation to wind currents (IFI, 1990). . ''
'. i .
Several studies (Schaefer and Hohman, 1989; Reinhard, Dulson and Exner, 1989; Vieths
et al., 1987; Vieths et al., 1988) found that fat-containing foods (such as butter, cream,
vegetable oil, margarine, sausage and cheese) can become contaminated with
tetrachloroethene when stored in residences or food stores near dry cleaners.
Tetrachloroethene levels in such foods increased with the amount of time that they were
stored near a dry cleaner. | ' •
• ' \
Tetrachloroethene has been found in butter and margarine samples obtained from
retail stores located next to or near dry cleaners in the United States (Miller and Uhler, 1988;
Entz and Diachenko, 1988). The samples were .analyzed as part of a U.S. Food and Drug
Administration monitoring program. .The samples from stores with no dry cleaning
establishments nearby generally contained less than 50 parts per billion (ppb) of
tetrachloroethene. Samples from stores near dry cleaning establishments had
tetrachloroethene concentrations ranging from 100 to more than 1,000, ppb. (Food was not
analyzed as part of this NYSDOH study.)
Conclusions , ]
i
l
Although based on a small number of samples, the following conclusions can be made:
1. The tetrachloroethene levels in air in the apartments above dry cleaners were
significantly elevated (AM range 300 to 55,000 mcg/cu.m; PM range 100 to 36,500
mcg/cu.m) compared to locai'cpntrol apartments (AM range <6.7 to 103 mcg/cu.m; PM
range <6.7 to 77 mcg/cu.m). Although air concentrations were usually less at night
Page 7
139"
-------
than during the day, the study residences always had higher concentrations of
tetrachloroethene than the control residences.
2. Tetrachloroethene concentrations in outdoor air near the dry cleaners were also
significantly elevated (AM range 195 to 2600 mcg/cu.m; PM range 66 to 1400 mcg/cu.m)
compared to control locations away from the dry cleaners (AM range <6.7 to 21
mcg/cu.m; PM range < 6.7 to 6.9 mcg/cu.m). !
3. The tetrachloroethene levels in the apartments above dry cleaners using transfer-type
dry cleaning machines are significantly elevated (AM range 1730 to 17,000 mcg/cu.m;
PM range 1350 to 14,000 mcg/cu.m) compared to those using dry-to-dry machines (AM
range 300 to 440 mcg/cu.m; PM range 100 to 160 "mcg/cu.m). One dry cleaner using an
old dry-to-dry machine, however, had the highest levels of all (AM 55,000 mcg/cu.m;
PM 36,500 mcg/cu.m). !
4. Among all the dry cleaner characteristics noted or meaured, the best predictor of the
level of tetrachloroethene in the apartment was the tetrachloroethene level at the
pressing station in the dry cleaner establishment. Due to very small numbers of
samples, few associations could be made between the conditions at the dry cleaner and
the level of tetrachloroethene in the apartment air.
Page 8
140~
-------
References: !
Entz, R. and G. Diachenko. 1988. Residues of volatile halocarbons in margarines Food
Addit. Contam. 5: 267-276. ;
International Fabricare Institute (IFI), 1990. Monitoring Solvent Vapors In Dry Cleaning
Plants. Focus on Dry Cleaning. 14: 6. . ••
Miller, L and A. Uhler. 1988. Volatile Halocarbons in butter: Elevated Tetrachloroethylene
levels in samples obtained in close proximity to dry cleaning establishments. Bull. Environ.
Contam. Toxicol. 41: 469-474. ,
New York State Department of Health, 1989. Interoffice Memorandum to Charles Hudson
from Stanley House; October 12, 1989; Subject Air Sampling of Home in West Seneca, New
York. . ;
i
i
New York State Department of Health. 1990. Quality Assurance Project Plan: Staten
Island/New Jersey Indoor Air Study. ;
I .
Norusis, M. 1988. SPSS/PC+ Studentware. SPSS Inc., Chicago III. '•
Putnam County Health Department, New York State Department of Environmental
Conservation, New York State Department of Health, 1990. Investigation of tetrachioroethene
in the Mahopac Business District.
i
Reinhard, K., W. Dulson and M. Exiher. 1989. Concentrations of tetrachloroethylene in indoor
air and food in apartments in the vicinity of dry cleaning shops. Zbl, Hyg. 189: 111-116. (In
German) i I
Schaefer, J. and H. Hohmann. 1989. Tetrachioroethene pollution of residents adjacent to
dry cleaners. Off. Gesundh.-Wes. 51; 291-295. (In German)
1 j
Shah, JJ. and E.K. Heyerdahl, 1988. National Ambient Volatile Organic Compounds (VOCs)
Data Base Update. U.S. Environmental Protection Agency. Research Triangle Park, NC:
: t
U.S. Environmental Protection Agency, 1987. The Total Exposure Assessment Methodology
(TEAM) Study: Elizabeth and Bayonne, NJ, Devils Lake, ND and Greensboro, NC: Volume II
PB88-100078. Research Triangle Park, NC. !
j
Vieths, S., W. Blaas, M. Fischer, C. Krause, I. Mehlitz and R. Weber. ; 1987. Contamination
of foodstuffs by emission of tetrachioroethene from a dry-cleaning unit. Z. Lebensm. Unters
Forsch. 185: 267-270. (In German) j
Vieths, S., W. Blaas, M. Fischer, C. Krause, R. Matissek, I. Mehlitz arid R. Weber. 1988.
Contamination of foodstuffs by emissions from dry cleaning units. Z,; Lebensm. Unters.
Forsch. 186: 393-397. (In German) |
91263PRO0260
Page 9
141-
-------
Table I .
Dry Cleaner Survey Operations Information
July, 1991
Dry Cleaner
Machine Type •
No. Machines (cleaning)
Capacity (Ibs/ machine)
Total solvent used
(gal/month)
Local exhaust (from
machine) to outdoors
General exhaust (room
exhaust)
Maintenance
Equipment leaks
Perc/water separator
fugitive emissions
Open containers
Building characteristics
Ceiling type
Pipe chases in ceiling
Odor intensity
No. I
dry to dry
(old)
2
10
NR1
vent in first
floor wall
(both
machines)
2 window
fans (12")
yes
yes
no
suspended
yes
low
(machines
not
operating)
No. 2
transfer
1
35-40
50
vent in first
floor wall
2 fans in
walls (24")
1 fan in
ceiling
(18")
yes
no
no
metal (tiles
missing)
yes
medium
No. 3
transfer
I
20
12
vent in first
floor wall
2 window
fans
yes
yes
no
suspended
yes
medium
No. 4
transfer
1
20
25
dryer-vent
infirst floor
wall
washer-vent
to roof
5 fans in
windows
and walls
(12" and
18")
no
yes
no
plaster
yes
medium
No. 5
dry to dry
1
35
17
carbon
adsorber on
vent which .
exhausts to
room
7 wall fans ,
(22" and
10") |
yes
yes
no
plaster
\
no
lo\v
No. 6
dry to dry
1
50
NK1
no vents
(rec.ir-
culated to
machine)
2 fans in wall
(24" and
48")
no
no
no
tin
no
low
1 NR — not reported by owner
3 NR = not reported by field staff"
§12040124
142
-------
Table 1 (continued)
Dry Cleaner Survey Operations Information
Real-time Tetrachloroethene Air Measurements (ppm)c
July, 1991
Dry Cleaner
Instrument
Front of machine (s)a
Behind machines(s)"
Front mach(sj/door open?
Carbon adsorber
Outside @ exhaust fan
Washer
Dryer
Room
Pressing station
Garments
No. I"
Photovac
ISO
>200"
100
NA
1
60 (fan off)
30-80
NR
No. 2
HNU
12
200
300
NA
190
. 9-10
7-15
No. 3
HNU
100
100
320
NA
8-15
320-400
2-3
5-12 .
No. 4
HNU
i
50 i
i
350
400
\
NA '
I
250 !
10-13'
7-10
No. 5
HNU
10
!50
3
2-3 (at vent)
2-10
1-2 •
-------
Table 2
Tetrachloroethene Concentrations for
Study and Control Residences (mcg/cu.m)
Residence
Study Homes
Residence 1 (O)
Residence 2 (T)
Residence 3 (T)
Residence 4 (T)
Residence 5 (D)
Residence 6 (D)
Control homes
Residence C1
Residence C2
Residence C3
Residence C4
Residence C5
Residence C6
Tetrachloroethene
Indoor
AM
55,000
17,000
3,850
'1,730
440
300
<6.7
103
<6.7
<6.7
44
9.7
PM
36,500
14,000
8,380
1,350
160
100
<6.7
77
<6.7
<6.7
56
22
Tetrachloroethene
Outdoor
AM
2,600
1,400
530
1,110
195
300
<6.7
21
<6.7
<6.7
<6.7
16
PM
360
1,400 :
812
441 ;
66 ;
400 ;
<6.7 ,
<6.7
<6.7
<6.7
< 6.7 '
6.9
Study residence above dry cleaner using:
O = old dry-to-dry unit
D = dry-to-dry unit
T = transfer unit
cvm/91205PRO0286
144
-------
i Table 3 i
Summary of Tetrachloroethene concentration:;
for Study and Control Residences (mcg/cu.m)
Sample Type/Residence Type (number)
Indoor Air, AM
Study homes (6)
above 'transfer' cleaners (3)
above 'dry-to-dry' cleaners (2)
above old dry-to-dry unit (1)
Control homes (6) '.,'•
Indoor Air, PM
Study homes (6)
above 'transfer' cleaners (3) :
above 'dry-to-dry' cleaners (2)
above old dry-to-dry unit (1) ;
Control homes (6)
Outdoor Air, AM '<
Study homes (6)
outside 'transfer' cleaners (3):
outside 'dry to dry' cleaners (2)
outside old dry-to-dry unit (1) '•,
Control homes (6) •;
Outdoor Air, PM :
Study homes (6) >
outside 'transfer' cleaners (3)
outside 'dry-to-dry' cleaners (2)
outside old dry to dry unit (1)
Control homes (6)
Tetrachloroethene
Range
300-55,000
1,730-17,000
. ,300-440
55,000
< 6.7-1 03
.. - . .
100-36,500
1,350-14,000
100-160
36,500
< 6.7-77.0
.
195-2,600
530-1,400
195-300
2,600
' < 6.7-21
66-1,400
441-1400
66-400
360
< 6.7-6.9
Mean
13,000
7,500
370
55,000
28
I
', 10,000
I 7,900
! 130
36,500
i 28
| 1,000
: 1,000
250
:. 2,600
i 8.4
58.0
880
" 230
360
i 3.9
cvm/91205PRO0286
145
-------
II
I*
. S
« J;
il
ss
3
5 1)
O Co
o .
§ s
i
c
«
987,
he
ate
s
1
•
5to
a
S
^2 S
Q *Q
"a 5
O U
« *
8 .S
146
-------
•s^
II
eal Concentn
Studies (mcgl
"K
•3 I
P
il
s
3
fe
•s
"t
g.
3
•=0
s£
II
3
l!
!
Control H
H
1
i
!
1
1
•
rs > v^ cx| ^ c^ -£[ ^ -s ' cv^ ^,
< « * \Q O O Co \Q »OOC5*N
*^ <^i <^^ <^ ^^ ^^ ^^ ^^ ^^
t t t II t t » t
1 ' ' *s*i CQ • '*"s
* ' M 1 :! g J
I'hilhhUH
i
\
\
I 00
— .,
; 1
It s
\ Ji On ft}
; .b 5 S
' 'i ^ ^
? b 5
• 1 •& S
: J . ig . g
"Q Q *"*
\ f S I 1
. i * i- i
i^ * y «
\ 1 i i i
:' t "S. A. %
1 § 1 $ -3 .
^ "S N «J
; ^ | •£> "S
^ "5 a "*
^ .y § sj
s §
1 • t -s .-s ^
i lag-0
S § § «
' i • .j; o .5, ^
• 3 ^3 E! "^*
1 M 1 }
1 1 1 1 1
i 41 i ! . i
1 5 a § ^ 1 ^
'* a a <" fe *» S
„ CJ CS ^ fc, ^ ^
;*• II II II H II 1"
*s, Q ««Q u ^o ^ C
-------
.5-5.
8*
.2 a
I-5*
«!
s£
Jl
o>i
i1
ii
^!
jj's S
all
l^s
£t
I*
^
!|
s?a
As
f
f
^
"P
a
f
vq
>o
"i
o
R
§
3
CS O
§ s s s
o c> o o
V V V
V VV
V V VV
-------
Z *
•S a
J|
•g
II
r
h
S 5"
a, 13
|
a?
"g
f
=0
§ 1
,vvv
vvvv
*:
1
3 1
3
I
I
£
55 £ 4
6. "g J2
££• *•- *?!
it ^ *"**
*5 -C
§ ^
f *
:•« 2
I I
(§ •«
i a
S
1
-Q
•§
I
U9
-------
STATE OF NEW YORK
DEPARTMENT OF HEALTH
Center for Environmental Health
2 University Place
Lorna McBamstta
Executive Deputy Commissioner
August 2. 1991
Albany, New York 12203-3399
OFFICE OF PUBLIC HEALTH
Linda A. Randolph. M.D.. M.P.H.
Director
Sue Kelly
Executive Deputy Director
William N. S|asiuk. P.E.. Ph.D.
Centar Director
William Grattan. M.D. ;
Commissioner :
Albany County Health Department :
South Ferry & Green Streets \
Albany, New York 12201
Dear Dr. Grattan:
This letter summarizes the toxicologic and epidemiologic data for |
tetrachloroethene that we discussed previously. The target organs for toxic effects
following exposure to tetrachloroethene are the central nervous system, livef and
kidneys.
In evaluating the health risks from .tetrachloroethene exposure, we've followed
the procedures outlined by the National Academy of Sciences (MAS. 1S77. 1987) and
federal agencies such as the U.S. Food and Drug Administration, the U.S.
Environmental Protection Agency, and the Agency for Toxic Substances and; Disease
Registry (Dourson and Stara, 1983: US EPA 1988. 1989). We've identified either
no-observed-effect levels or lowest-observed-effect levels for target organs in humans
and animals. When developing exposure guidelines for long-term exposure of the
general population from human data, uncertainty factors are used because effect or
no-effect levels can be based on studies using healthy adults (frequently only men),
short exposure times, small sample sizes and limited information on exposure levels.
These same limitations may exist when using animal data, but additional uncertainty
is introduced when extrapolating results from animals to humans. Uncertainty factors
that are usually applied include a factor of ten for a short-term study, ten for' using a
lowest-observed-effect level rather than a no-observed-effect level and ten in going
from a limited study in adults to the general population. Consideration may also be
made for the quality and quantity of the available data. ,
Information on central nervous system effects comes from human ,
controlled-chamber exposures and from epidemiological studies. The controlled
studies used healthy adults and short exposure times. The epidemiological studies
involved longer exposure times, but the exposure levels are less certain than for the
controlled studies.
In,controlled exposure studies, Stewart et al. (1970) and Hake and Stewart (1977)
reported central nervous system effects when adult males and females were exposed
to 100 ppm (690 milligrams per cubic meter~mg/m3) for 7 or 7.5 hours per day for five
days. Effects were .not detected in adults exposed to 20 ppm (140 mg/m3).for7.5 hours
per day for 5 days. '
-s — 150 » '——— '
-------
Workers exposed to tetrachloroethene have also been evaluated for possible
central nervous system effects. A study by Lauwerys et al. (1983) did not detect
adverse effects on the central nervous system of Belgian workers at dry cleaning
shops who were exposed to a time weighted average (TWA) tetrachloroethene level
of 21 pp'm (145 mg/m3). Seeber (1989) summarized a series of studies which
evaluated such endpoints as perceptual speed, digit reproduction and sensorimotor
and coordination functions in German dry cleaning workers. The performance of both
the high-exposed (reported TWA |360 mg/m3) and low-exposed (reported TWA 83.
rng/ni3) groups differed significantly from the control group for some tests: however,
the two exposed groups did not differ from each other.
A guideline for central nervous system effects for the general population can be
derived from the no-observed-effect level in controlled chamber experiments or from
the worker studies. The no-observed-effect level for central nervous system effects in
the controlled chamber- studies is 20 ppm (140 mg/m3). Because this study was on
healthy adults and of limited duration, an uncertainty factor of 100 is applied after
averaging the concentration over ;24 hours. This suggests a guideline of 0.4 mg/m3.
The lowest effect level in the worker studies was 83 mg/m3. Because effects were
observed and the study was on healthy adults, an uncertainty factor of 100 is needed
after averaging the concentration over 24 hours. This suggests a guideline of 0 25
mg/m3. ; .
The liver is also a target organ for tetrachloroethene, particularly in mice. Case
reports of liver effects have also been reported in humans who were exposed to high
concentrations, sometimes under severe circumstances. The Ipwest-observed-effect
level for mice is 60 mg/m3, when continuously exposed for 30 days (Kjellstrand et al.,
1984). Liver weights were significantly elevated. Using an inhaled dose to extrapolate
the results from mice to humans and applying a thousand-fold uncertainty factor
wouid suggest a guideline of about 0.25 mg/m3 for liver effects.
The kidney is also a target organ in rats. Effects were seen in rats exposed to
200 ppm (1,400 mg/m3) for 6 hours per day. 5 days per week for 2 years (NTP. 1986).
These effects included nucleus enlargement and tubular cell hy.perplasia. Using an
inhaled dose to extrapolate from rats to humans and applying a thousand-fold
uncertainty factor would suggest a guideline of about 0.5 mg/m3 lor kidney effects.
Exposure to tetrachloroethene caused liver tumors in mice and mononuclear
cell leukemias and kidney tumors In rats. The exact mechanisms by which these
tumors were induced are not known. Because of the uncertainty, a conservative
estimate of the tetrachloroethene air concentration corresponding to the upper bound
on risk and associated with a one in one million excess lifetime human oncogenic risk
is 0.05 micrograms per cubic meter (mcg/m3). This estimate is based on the
assumptions that the delivered dose of the active carcinogenic agent is linearly
proportional to inhaled dose of tetrachloroethene across all doses and that surface
area is the appropriate parameter for dose extrapolation. Confidence in this estimate
is limited by the data which indicate that linearity across all doses does not hold for
the potential oncogenic agents (tetrachloroethene or its metabolites) and by the
degree to which the results of empirical observations on the toxic effects of
anti-neoplastic drugs (the source of the surface area rule) are applicable to chemicals
which are metabolized differently. •
151
-------
Correlations between the metabolic and carcinogenic data can be used to
support the hypothesis that the metabolic products^ of the mixed function oxidase
pathway for tetrachloroethene are responsible for its carcinogenicity in mice.: If the
available data are used with physiologically-based pharmacokinetic modeling, an
estimate of the air level corresponding to the upper bound on risk and associated with
a one in one million excess lifetime human carcinogenic risk is 0.5 mcg/m3 (if humans
and mice'are assumed to be equally sensitive to the same delivered dose).
Confidence in this estimate is limited by the validity of the initial assumptions :and the
accuracy of the model in compensating for non-linearity when extrapolating from high
to low doses and in compensating for differences in the capacity of mice and humans
to metabolize tetrachloroethene by the mixed function oxidase pathway. i
Correlations using urinary excretion data for tetrachloroethene metabolites can
also be used to estimate an excess human cancer risk from the mouse liver tumor
data. Using this method (US EPA. 1990), the tetrachloroethene air concentration
corresponding to an upper bound on risk and associated with a one in one million
excess lifetime human cancer risk is 2 mcg/m3. \
The NYS Department of Health recommends, based on an evaluation of the
non-carcinogenic effects of tetrachloroethene. that the average ambient air level in a
residential community not exceed 250 mcg/m3 for adults, considering continuous
lifetime exposure. If a child's inhalation rate and body weight are used, the guideline
becomes 100 mcg/m3. Furthermore, we recommend that the uncertainty factor not be
reduced by more than an order of magnitude when considering the need to take
immediate action. We also recommend that exposure to tetrachloroethene be
minimized to the extent practical; e.g. regardless of the levels, solvent containers
should not be left opened. The potential carcinogenic risks of tetrachloroethene will
be considered further as regulations are developed for the dry cleaning industry.
Enclosed with this letter are the results for the other apartments in Albany
County that were evaluated in the dry cleaner study and the draft report for the study.
The results for both of these apartments exceed the criterion that we recommend for
undertaking immediate action to reduce tetrachloroethene levels. We would
appreciate any comments on the draft report by Friday August 9. 1991.
Please let us know when you are able to provide study participants with results
for their homes. We will provide extra copies of the report when it is finalized for you
to send to the study participants.
Sincerely,
Nancy Kim, Ph.D.
Director
Division of Environmental Health
Assessment
12030153
152
-------
REFERENCES
Dourson, M.L. and Stara, J.F. 1983. Regulatory History and Experimental Support of
Uncertainty (Safety Factors). Regulatory Toxicol. Pharmacol.. 3: 224-238.
Hake, C.L. and Stewart, R.D. 1977. Human Exposure to Tetrachloroethylene:
Inhalation and Skin Contact. Environmental Health Perspectives, 21: 231-238.
Kjellstrand, P., Holmquist. B., Kanje, M., Aim, P., Romare. S.. Jonsson. I., Mansson,
L., and Bjerkemo, M. 1984. Perchloroethylene: Effects on Body and Organ
Weights and Plasma Butyrylcholinesterase Activity in Mice. Acta Pharmacol.
Toxicol., 54: 414-424.
Lauwerys, R., Herbrand. J., Buchet. J.P., Bernard, A., and Gaussin, J. 1983. Health
Surveillance of Workers Exposed to Tetrachloroethyiene in Dry-cleaning Shops.
Int. Arch. Occup. Environ. Health, 52: 69-77. :
National Academy of Sciences. 1977. Drinking Water and Health, Volume 1. National
Academy of Sciences, Washington, D.C. ,
f
National Academy of Sciences. 1987. Drinking Water and Health. Volume 7, National
Academy of Sciences, Washington, D.C.
National Toxicology Program. 1986. Toxicology and Carcinogenesis Studies of
Tetrachloroethylene (Perchloroethylene) (CAS no. 127-18-4) in F344/N Rats and
B6C3F( Mice (Inhalation Studies). NTP Technical Report Series No. 311. NTP,
Research Triangle Park, NC. NIH Publication No. 86-2567..
Seeber, A. 1989. Neurobehavioral Toxicity of Long-Term Exposure to
Tetrachloroethylene. Neurotoxicology and Teratology, 11: 579-583.
Stewart, R.D., Baretta, E.D.. Dodd, H.C., Torkelson, T.R. 1970. Experimental Human
Exposure to Tetrachloroethylene. Arch. Environ. Health, 20: 224-229.
U.S. Environmental Protection Agency. 1990. Health Effects Assessment Summary
Tables, Fourth Quarter, FY - 1990. Environmental Criteria and Assessment Office,
Cincinnati, OH. NTIS No. 1=690-921104.
U.S. Environmental Protection Agency. 1989. Interim Methods; for Development of
Inhalation Reference Doses. EPA/600/8-88/066F. Office of Health and
Environmental Assessment, Washington, D.C.
U.S. Environmental Protection Agency. 1989. Risk Assessment Guidance for
Superfund, Volume 1, Human Health Evaluation Manual (F'art A). Interim Final.
EPA/540/1-89/002. Office of Emergency and Remedial Response, Washington,
D.C. ! !
12130371
-153
-------
154
-------
Fact Sheet
BBBBBBI
AIR CONTAMINATION
ABOVE DRY CLEANERS
February 1992
Prepared by
New York State
Department of Health
155
-------
SUMMARY:
I--., w f*wi HI I J 1 I U||
6800 mcg/cu.m
New York State Department of Health
New York State Department of Environmental Conservation
156
-------
INTRODUCTION
]ahnnav c?mPIain!i' an investigation conducted in 1989 and
1990 in Mahopac, New York, found elevated air -concentrations of
tetracnloroethene in three of four apartments located in the same
building as a dry cleaning facility. As a result of this finding a
study was conducted to determine if this situation is widespread The
objective of the study was to determine if tetrachloroethenP levels in •
residences located in the same building as a dry cleaner: were higher
than levels in residences not near a dry cleaner. In 1991, the indoor
air of six apartments located above six dry cleaners in the Albany New
HnLar6a IT; ;vaJUat?d' 'Uter in 1991' three aP*rtments abov^a dry
cleaner in Westchester County and five apartments above a dry cleaner in
New York City were tested. Control apartments, located in slmll"
neighborhoods but not near a dry cleaner, were tested at the same time.
Data were ^ also collected to evaluate what cleaning equipment or other
factors might be contributing to air contamination in the apartments.
QUESTIONS AND ANSWERS
What Is tetrachloroethene? ! :
Tetrachloroethene (also called perc or perchloroethylene) is a colorless
liquid at room temperature. Tetrachloroethene is commonly used for dry
cleaning fabrics -Dry" cleaning machines use the liquid to wash y
clothes. Some of the liquid can evaporate into the air, producing an
ether-like odor. It is also;used in degreasing metals and is found in
™,o0nSUmer Prod"ctsTsuch as P^^t removers, water repellants, spot
removers, auto brake cleaners, adhesives and suede protectors. Because
?±arh ?r°etEene 1s s° w^ely used, it is commonly found in outdo" "d
Ih0 Sn-ai^M?aSUre?fnts have bden made in air 1uality studies across
the United States. The average outdoor air levels in these studies
.ranged from 1.9 to 4.0 micrograms of tetrachloroethene per cubic meter
fro*" J'tf 13-haVerage ^^ tetrach1o™ethene levels ranged
What were the results of the sampling? j
j.
The test results show that te.trachloroethene was found in 'the indoor air
?pv3Pc ff njs.above d7 cleaners at levels considerably higher than the
levels found in control apartments not near dry cleaners i The
concentration in apartments above dry cleaners ranged from 100 to 62 000
6C7 t 103 '/ apartments away from dry Cleaners ranged from less than
157
-------
How am I exposed to tetrachloroethene and can It affect my health?
Tetrachloroethene can enter the body in food we eat, in water we drink
and in the air we breath. With exposures from dry cleaners, the
greatest amount is from breathing air containing tetrachloroethene.
Health effects that may'result from breathing air containing
tetrathloroethene are shown in the attached diagram. Exposure to Ihigh
levels of tetrachloroethene (680,000 mcg/cu.m and greater) can cause
immediate health effects such as dizziness, headaches and sleepiness.
Health effects from exposure to low levels of tetrachloroethene are less
well known. Animal studies suggest that exposure for months or years to
elevated levels of tetrachloroethene may cause liver and kidney damage,
effects on the unborn, liver cancer and leukemia. There is not enough
information to show if tetrachloroethene exposure can increase the risk
of cancer in humans. i
Based on an evaluation -of the information from humans and laboratory
animals, the NYSDOH has recommended that average levels of :
tetrachloroethene in indoor air not exceed 100 mcg/cu.m.
What action is being taken?
NYSDOH and NYSDEC have met with representatives of the dry cleaning
industry. With their cooperation, the NYSDOH is conducting a survey of
all'dry cleaners in New York State to assess the different operations,
building uses and types of equipment. This information will be used by
local health departments to determine which dry cleaning facilities will
be investigated next. The NYSDEC and industry professionals will work
with dry cleaners to take steps to reduce emissions. These actions may
include good housekeeping measures such as storing solvents properly and
insuring that emission control equipment is working effectively. It may
also include changes in building ventilation or the installation of new
equipment, if necessary. The NYSDEC has .prepared draft regulations to
limit air emissions from dry cleaners. The regulations are designed to
require proper yentilat'on and control in the dry cleaner workrooms and
to reduce emissions to residential areas and outdoor air. There will be
opportunity for public comment on these draft regulations when they are
formally proposed later this year. i
FOR FURTHER INFORMATION
If you think you are being exposed to tetrachloroethene, or if you smell
odors from a dry cleaner in your area, call your local county or state
health department. The telephone number is listed in the Blue Pages of
your telephone book. If you are concerned about possible health effects
you think may be related to tetrachloroethene exposure, consult your
physician. For more information about the dry cleaners program, or for
a copy of the dry cleaner study, contact the NYSDOH at 1-800-458-1158,
extension 405. More information on the draft regulations on dry cleaner
emissions is available from Mr. Jack Lauber of NYSDEC at 518-457-7688.
20020619 - •
158
-------
HEALTH EFFECTS FROM BREATHING TETRACHLOROETHENE***
Short-term Exposure
(less than or equal to 14 days)
Effects in
Animals
Air
Level*
Effects in
Humans
Long-turm Exposure
(greater than 14 days)
Effects in
Animals
Air
Level*
Effects in
Humans
7,000,000— severe eye and
7,000,000
effects on .
the unborn^\_
\i\tar 4rtvi/M4w
effects on 700
nervous '
system
nose irritation
after 1 -2 minutes
kidney tumors, ^
leukemia \.
000 — dizziness, headache. kidney toxicity, — 700,
sleepiness, mild nver tumors
eye, ncse, throat ;
irntaticn effects on brain ^"
no effecrts • chemistry ;
000
/OSHA" workplace
/ standard (8 hours)
// no effects on
r>^ liver or kidneys
70,000 i . 70 QQ^- effects on nervous
n.«» ;fw,ww system
7.C
7C
toxicity
00 7,C
i
'0 . 7C
; i
00
I0
—indoor air range
in study apartments
above drycleaners
KIX/O r\/*\u
70 ; 70 guideline for
indoor air
* micTograms per cubic meter of air ~
** OSHA - Occupational Safety and Health Administration
"** Effects are listed at the lowest level at which they were first observed.
They may also be seen at higher levels. I
159
-------
-------
Submission from
Elizabeth Bourque
Massachusetts Department
of Public Health
161
-------
-------
tf/M^owiowe^
William F. Weld
Governor
David P. Forsberg
Secretary
David H. Mulligan
Commissioner
(64 7j 727 -2670
14, 1992
Arthur J. Beebe, Director
Northeast Region
Food and Drug Administration
One Montvale Avenue
Stoneham, MA 02180
Dear
We
£ 5^=- «..
S"
FDA already has perforr^ a nuntoer of studies identifying PCE as a
contaminant in food:
Richard C. Bfe and Gregory W. Diachenko, Division of Focd Chemstry and
Ttechnolocr// FDA, Washington, DC . -
!
1.
2.
I^e J Miller and Allen D, Uhler, Division of Contami.iante Qiemistry,
3 David L. Helkes, Food ard Drug
Center, 1009 Cherry St., Kansas
venc*at' - - Method for Determination of
Total
Diet Research
Balocarbons and
163
-------
St. , Ktosas
32
Entz and Diacheriko found levels of 500 to 5,000 ppb in
of
1.
3.
"butters collected from stores with no
dry-cleaning establishments nearby generally
contained less than 50 ppb of PCE, . . . .However,
many of the butters from stores located near
dry-cleaning establishments had elevated levels
of PCE (100 to greater than l,00ppb) .» p. 473
°n the contamination
Stefan Vieths, Werner Blaas, Manfred Fischer, Christian Krause
Jena lautz Rudolf Weber and Max vort PettenkofeJ? S£SS'
of _the Federal Department of Health; institute for Clean Water
°f ** Federal Department of Health, D-Sbo
Contamination of Foodstuffs via the Gaseous Phase by ;
^fS^1^ ^f ions °f a ** leaning Establishment
, Z Lebensm ISiters Forsch 185:267-270. -
' Fishcsr' Christian;Krause,
Reinhard Matissek, Irena Mehlitz and Rudolf Weber, Max von
SSSS^1**113*8 of ^ Federal Apartment of HealS?
^stitaite of Water, Soil, and Air Quality of the Federal
Department of Health; Institute of Food Chemistry of the
Technical University of Berlin
examination of Foodstuffs by Emissions from Dry Cleaning
JtstaojLisnments ;
1988, Z Lebensm Unters Forsch 186:393-397. '
K. Reinhard, W. Dulson and M. Exner, Institute for
Environmental Studies of the Office of Environmental Protection
f the
°£
Ifetrachloroethylene fa
4" ^J^^^ and H* HohmanrV Principal Public Health Officer
Tfetrachloroethylene Pollution of Residents Adjacent to Dry
Cleaners .„;'•*
1989, Off Gensundh-Wes 51:291-295. ,. :
As described in the above papers, in 1989 Germany propagated a PCE -
guiding value of 100 micrograms per kilogram of food. t>ropagscea a ^ .
-------
x
batter and/or margarine
£
: sincerely, ,
Richard D. Waskiewicz, M.S.
Deputy Director
Division of Food and Drugs
NR:rw:eab
181:drycleal
165
-------
... , .
••>•»•' ; •-• ' • • •••-•- -"• -..••'• • - .••.:••••••. . ••,' • •.;.-.• •: ;
1 . •—"'••^•••••••J .»___ • ••'•,, '' --.-..
..',: V-':.-':..'i;l',""'-' ..-.--. I™M™ m .•.....„. „,
.; ;. •„ •;. ^:,^;>:v.;4,
' •' ~/Vx>^-'^sfe;va^J
THE OF AUSRT: Surveillance
• ., ,, •: . Olive Oil,,.virgin Grades or Cold.Pressed Grades
r«";r S Pe^chloroethylene (PCE) and
NO«7 2fi ** AO "'"'^•r-i'X
Pate: August 17;. i<" '
: All Countries
JBNDEacimREfr/-
SH1W»KR • : /All
:,[j|j JUL I 4^92
' ' ''
RECOMMENDING
OFFICE
FOR
ALERT
. Section 402
' Perchloroethyl
-. .. , within the
HFC-131
toxicoiocrtsts
to
Ift IN 89-00 (01-31-891
-------
Page 2 - IA §26-03
r- ~" . -fc* . /.—•••-• . " : _ • ^;^.,*^<.Sjo.->»'VU.^:i*;«>^5*--^'v;j*«i*.j;i.i.«wM%''V?p?.-:-. -^ :,;• -.• •.
•..—^.~.irf~»-k—i~r-~-—°-v"'f~•"• —^"V^.^T .-•, ---\- •- •-..: - -.- Vsi*»5.*.,-~VsSs^". •"«•••—-'^
• -• • . •."•'•• .•-. ... • • . • ' ,.'.''-.".,- v.-f..-.';.;:..,-..:^/1.:/. - -r -
. ...^;>;-^:.j.u-" '^-.V-l'^-f-- ^^-vi^-s^s^^^^^;.^;
JNSTKCJCTIQNS
FOI
ors- *.« *-ost for oil content"- in the -Foss-Let test andrusevas-ra> ^
oil as unsafe fo
-------
-------
Submis^ion/rom
Walther den Otter
TNO Cleaning Techniques
Research Institute
-------
-------
Biorestoration of soils and grouindwater
contaminated by chlorinated ethylenes
Chlorinated organic solvents as tetrachloroethylene (PCE) and trichloroethylene (TCE) are widely
used for dry cleaning and in other industrial degreasing processes. Due to accidental spillage
many sites all over the world have been contaminated with these persistent organic compounds.
In soil and groundwater PCE and TCE are degraded very slowly or not at all. Biotechnolog.cal m-
situ treatment is an attractive alternative for remediation. TNO has developed such a
Thtreat mEconsist of a two-stage process. By creating the right anoxic Conditions
PCE (and TCE) can be dehalogenated (Table 1). In the second, aerated stage the remaning TCE
and the dichloroethylenes are completely mineralized by a microbial co-oxidation process. The
technology can be applied for on site treatment and in situ bioremediation. ;
Table 1 Concentrations (ug/l) of chloroethylenes in the efiluent of anoxic reactors fed with groundwater contaminated
wfth telracWoroelhylene. Tests w*re performed using 5 laboratory scale reactor* of 2.5 Irter workmg volume.
reactor
A
B
c
D
E
In
PCE
573
506
370
388
442
PCE TCE
<1 19
<1 27
<1 151
<1 . 5
<1 6
Out i
1,2cls1> 1,2 trans1)
88 245
101 ; 143
86 44
75 207
108 ' 36
1> 1,2 cis/trans dichloroethylene
The application of bioremediation should always start
with:
1. A description of the local geohyclrological
circumstances.
2. A test programm for defining the conditions
(temperature, nutrient requirement) by which the
chloroethylenes degrading microorganisms at that
particular site can be stimulated.^
The Netherlands organization for applied scientific research (TNO) has the experience and the
facilities to further develop the method to pilot scale. For further information, please contact:
Dr. H. Doddema
TNO Institute of Environmental Sciences
Department of Environmental Biotechnology i
P.O. Box 6011 i
2600 JA Delft, The Netherlands
Fax:+31 15616812
Phone:+31 15696022
17
-------
-------
Submissions from
Joseph Kurz
Institute Hohenstein
173
-------
-------
27. /28.05.1992
-•^.••'-.^•^•^.^^^••^v-^^^f^t^^^^^^^^^^
Ground
Water
Protection
Copyriglit: |
Research Institute Hohenstein
Schloss Hohenstein
D - 7124 Bonnigheim (Germany)
EPA68KU
EPA Rdundtable
Josef Kurz
Institute
Hohenstein
175
-------
Survey
Ground Water Protection
1.1. Sources of Contamination
1.2. Contamination
2. Degree of Contamination
• 3. Avoidance of Contamination
4.1. Contaminated Water
4.2. Storage of Barrels
. 4.3. Storage of Containers
4.4. Storage in Machine
5. Purification Procedures
6. Purification by Adsorption
7. Field Tests
8. Controlling after Purification
9. Purification of Contaminated Ground
and Ground Water
10. Progress of Decontamination
EPA25KU
EPA Roundtable
Josef Kurz
Institute Hohenstein
176
-------
-------
CD
to
^^
*^
•_£.
c
"O
J5
CD
.13
"o
CO
0)
CD
c
JJ>
£
2
jO
•g D)D)
CD ^-^*
Q. Qj 10 m
0) 3,. SI'S!.
& :a— .— =
ii m *— o o
& ^111^'
CO O Q Q g ^|-
2 ii ii ii ii ii
£: CD C3)
^ -i C
j> -<.c: 0) D) Q)
CO O Q O O -*
.— o X ^ ^ ^D
O i- ^- ? .2 T-"
•g J> H II II II II
ra &iii o> fe
C^ IIJ CL T- T- 1- T^
^_
£
O
f\J
TJ
CD
Q.
1
CD
Q.
T—
•5
.O
^UJ
fi,
I
8
1
, i
0)
; 5
w
i
!'
!
•
i
1
8
o
;CO
CD
CO Q.
§0
-------
179
-------
1 r^^
3« PI
^ QL
co
CD
.C C
•B8
•T^— «MBM ««^^
3SSS
C
CD t0
£ *- n
r- CO C
C « -fe.
II8
!8t
CO
o
O)
13
CO "O
^ _ c co
C O) CO §> ,_
Si«3§
S 3 5 S O
B c 'ft - *•
0
-
CD -ti 4=-
0)15 tO
in
CO
3
O)
i
8*= T_
c»_ n
•82
C 0
CO ^
O -n
1 3
Q. C
1
& ^
•i 8.
> UJ
T3 O
•"O °-
CO fr
0 C
i «l
h- O
co
c
Q
'S
CD
£
< C !
C g
MJ Ita«. |
O— ® 1
O
C -i
0 0
c c
Q .Q
3 1$
D) O)ri;
CD © vJ
DC DC Q
® 9
N
S
CO i
3
£ CD ;
ri 2j
• Heguiaxiom
> Law on Wai
Protection
• 9 \
\
®
CO
5 g
r— T~ i i
o t>
i t5
-J QL ;
c
•
to
c
Q>
O
I
0)
•f-*
"c
C
.2
o
k»
2
i
c
3
O
O
1
c
m
S
LU
180
-------
-------
4.2
Storage
Collecting Volume of Safety Troughs
200 liter = volume of one barrel !
EPA
Roundtable
Ground Water Protection
Institute
Hohenstein
182
-------
4.3.
torage
(EPA52KU)
EPA
Roundtable
Ground Water Protection
Institute
Hohenstein
183
-------
4.4.
Storage in Machine
:
-------
-------
Purifieat^
| -'"...' " .-, . • .:.-"=•• "•".-' ]• J;i4te'aX2iteS;';;.k '. •
Purification device for 5 liter per day
Sizes: 70 cm x 54 cm x 30 cm
(EPAZ1KU)
Ground Water Protection
186
-------
LU LU
o o
CL CL
0) O)
E E
to in
2
LU
LJJ ir o uu
-------
188
-------
Purifidatidri of Gbntam«natpd
Grourid lil Ground Water
Exhaust Air
Purification
Cartoon Filter
Ground Air
Purification
Filter
Ground
Air _
Exhauster
Ground Water
Purification
Filter
\\tvv\\
in situ
Stripper
\ \
\ Welter \ \
Unsaturated
\
Stripping Device
for Ground Water
Purification
/n fvv
imTD
iilil
ill!
UNI
Geo-Shock v
Water
^Saturated \
\ Area
Water Impermeable Area Hydro-Shock
(EPA14KU)
Ground! Water Protection
189
-------
-------
27. / 28.05.1992
Resident
Exposure
Reduction
Copyright:
Research Institute Hohenstein
Schloss Hohenstein
D - 7124 Bonnigheim (Germany)
EPA Roundtable
EPA54KU
Josef Kurz
191
Institute
_tk>he nstp i n
-------
survey \
Resident Exposure Reduction
1.
2.
3.
Definition of the Problem
Diffusion Barrier
Test: Perchloroethylene in Appartment
Buildings ;
4.
5.
6.
7.
8.
Diffusion Barrier
Diffusion Inhibiting
Diffusion Barrier
Prevention
PCE Levels in Residential Areas
i
EPA35KU
EPA Roundtable
• *. *s 1 Institute
JOSef KurZ I Hohenstein
192
-------
193
-------
CVJ
a>
0)
o
w
LLJ
194
-------
I
I
I
I
CO
CO
O)
E
O
c£
CO
CO
C CM
A
V
c
'3
(0
0)
o
z
0)
+*
O
T3
Q)
tr
£
eo
o
a
o
QC
o
DC
£
UJ
195
-------
Q.
.a
uug'Z
CO
0)
o
tO
CM
fl
a.
a.
m
CM
c
o
0
CO
"5
03
~0
LLJ
0
CO
0
b
ii ii
o"
0)
(0
.
01
196
-------
Diffusion Inhibiting'
Necessary thickness of walls to inhibit contamination of a
neighbouring room higher than 0,1 mg/m3.
Building Material
Brick
Aearated Concrete
Interior Plaster
Lime Sandstone
Concrete
Diffusion Coefficient
8
160
150
150
80
10
Ne
Thicls
>2«
>23
j
. >23
>13
>1S
Necessary
t5,6/.65
',8 / 350
;,7 / 40
EPA Roundtable
EPA71KU
Resident Exposure Reduction
_L
Institute
Hohenstein
197
-------
Diffusion-inhibiting
layer
Paint on a
polyurethane basis
Metal-containing
paint on a
polyurethane basis
Paint on a
polyurethylene basis
Water-soluble paint
on a mineral basis
Woodchip paper, butt
joint overlap with
plastic adhesive
Woodchip paper, butt
joint overlap with
resin adhesive
Insulating wallpaper
butt joint overlap with
paste
ffusion Coefficient
A
<5
>175
>5000
<10
<15
<10
<25
Difi
ef
DiffusionHnnibiting
effect sufficient?
yes
no
no
yes
yes
yes
yes
EPA72KU
EPA Roundtable
Resident Exposure Reduction
Institute
Hohenstein
198
-------
Prevention
1. Ventilation of the work room
2. Exhausting of the PCE- containing steam / air
coming out of the finishing equipments.
• Alternatives in discussion:
Aeration of cleaned garments in a box during
and adsorption of PCE with activated carbon.
i
3. Measurement device in the outlet air of closed circuit
• ' ' 3
machines to ensure the threshold value bf 2 g / m in
order to minimize the transport of PCE by textiles
into the workroom.
4. Barrier to prevent diffusion through walls
and ceilings.
EPA29KU
EPA Roundtable
Resident Exposure Reduction
Institute
Hohenstein
199
-------
PCELeve/s in Resident/a/Areas
Emissions from DrvcleanJngs
Threshold value = 0,1 mg PCE/m3(0,015 ppm)
Maximum PCE freight per week f7days)
in respiration air of an adult resident:
• Volume per respiration = 0,5 liter
• Respiration frequence = 16 times / minute
• Respiration volume =16x0,5
, ; : = 8 liter / minute x 60
= 480-500 liter/hour x 24
= 12m3/dayx7 |
. , = 84m3/weekxO,1
= 8,4 mg PCE in 7days
Comparison : Employees in drvcleaning
Threshold value: 345 mg PCE/m3 (50 ppm) .;
• Respiration volume = 0,5 (liter) x 16 (frequence)
x 60 (hour) x 8 (day) x 5 (week) x 345
=6900 mg PCE in 5 days
Conclusion:The relation between residential exposure
value and employees exposure is about 1:1000:
According to present knowledge there is no danger
to health of residents and employees. :
EPA53KU
EPA Roundtabie I Resident Exposure Reduction
Institute
Hoh^nstein
200
-------
27. /28.05.1992
Prevention
of
Emissions
Copyright:
Research Institute Hohenstein
Schloss Hohenstein
D - 7124 Bonnigheim (Germany)
EPA70KU
EPA Roundtable
Josef Kurz
Institute
Hohenstein
201
-------
Survey
1. Classification
2. Regulations
3. Regulations (continued)
4. Perchloroethylene in Work Rooms
5.1. Leakage Check, daily
5.2. Recordings
5.3. Handling
*******
Charts already given in the presentation and
discussion contribution
• Check of the Carbon Filter, daily
• Recordings
• Check of the Contact Water Purification, weekly
• Recordings
• Check of the Machine by an Expert, yearly
• Test of the Measurement Device Calibration,
yearly \
• Training of the Employees
• General Recordings
EPA75KU
EPA Roundtable
Josef Kurz
Institute
Hohenstein
202
-------
I
i
1
1
I
1
I
1
I
Classification
•
•
I
H
\
• *
QQ
^f
V)
c
CO
•HB <»
•a C5
H|^~Bg| s%—^
mgsm 9>
RSa 0
ions laid down by a public scientific committ
1
^
PerGhioroethylene 50 ppm
11
" ¥
c
0
CO
0
O
•
; S
According to experience in humans
ii
^"
<;
CO
c
o
"4=3
""D
C
8
v_
fe
*tn
\L
0
T3
c:
According to experience with animals, but ui
u
CM
<;
as the exposition of humans
" .
]ro
*• •
rell-founded suspicion of cercinogenicpotert
?
CD
s:
s
c
b
0
£
0
.c
^>
0
T3
'0
0
2
0
C
O
T3
a
3
i
1
1
0
0
0
O
^
i
f •
i
i
t
i
•
§r
CD
Tw
C
0
IZ
b
JC
r3*
i
a
s
c
'3
~ OT
1C
(Q
Mr
0
X
o
*•*
•|
jC
I^HBB
jbstances in this classification has OEL
co
Prevention of Emissions
.2
^
(0
TJ
3
0.
Ill
203
-------
50 ppm (=345 mg/rn3)
No danger to health, if 50 ppm is
reliably not exceeded
(exceptions: short - term exceedings)
continuous measuring with a technical device
• 3 measurements within 3 months:
12,5 ppm (86 mg/m 3) when measured
discontinuously i.e. test tubes
(threshold for the beginning of danger)
• 1 measurement a year:
5 ppm (=34 mg/m3)
EPA Roundtable
(EPA30PI)
Prevention of Emission
Institute
Hohenstein
204
-------
r
I
I
1
1
I
.S2
O)
.£
CD
eu
£
0
.g.
0
o
o
o
0
8
0
.E
0
O
o
0
Q.
0
* -a -e
0)
I
2
o
0 o>
if
3 4=3
•MV *•••••
8 |
0 .£
0 3
8 °
o >»
a
Q.
o
c
0)
a
Q
LJJ
O
0)
O
T3
CO
T3
CD
CO
D)
0
0
.Q
O
"D
CD
CD
C
CO
0
0
Q.
0
0
C
O
"is
c
1
(0
0
B'S-
0)
o
X
i-
CO
o
'35
§w
LU
o
CO
O
{£
£
LJJ
205
-------
i
f
f
CM
o>
(0
LJJ
0
00
o
(0
CO
in
111
206
-------
1
I
(0
Q
o
c
0
D
CT
0
O
0
6
O
O
OJ
Q
I
LU
o
Q.
LU
c
•Mi
05
«*
(0
c
o
X
<0
(0
O
'53
.52
LJJ
.o
"^
I
o
! II !••
I % * ill
2 o o •* I I
LO
.0
(Q
*-
TJ
3
O
C
£
UJ
207
-------
cvj
CD
o
CO
0
CD
05
T3
CD
O
&
to
CO
CD
0)
8
CO CD
CO
O
CD
CO
o
I
o
(0
CO
CO
CO
111
CO
•»-«
13
CO
CD
DC
E
to
^>^
CO
O)
c
"c
co
CD
0
.*•* •
t_
'• '
0
o
t> ^.
c
"?R
'*J
J7
* -js
c
o
*•
0
o o
±i
CO
0
DC
1
'
o o o o
i
0)
HI
208
-------
Hand/ing
CO
LO
" j;'"''. .' '
0)
Spotting without
solvent containin
mixtures
«= fe : 8
co £ -2
°^ s
•Perchloroethylen
no longer be use(
nroQnnttinn
f^i '^'•f^*^ kt.il i^.
•1,1,1 -Trie is proh
for post-spotting
4_l
©
>
O '_
eo w
fl
c ^
O
£
, JZ
c 'S'l
*.+ CD ^, ^
vu > jjJ
O
i
.1±
O)
1 •
CD
JD
CD
O)
c
CO
1
CD
CO
CO
o
^ CD
•— C^
CO _
•p 2
L^ •»-•
9 CD
-9 O)
£ o
fe^
n «
C *•*
C J2
^ CO J^
4-1
.22 ®
CZ "~"
CD
to , co
c ==
O (0 *D
"S :3 :£ Q •
00 CO -D S C
§)El^i
8 i 1 to 5
0 41 Q. g ^
Q j> o E co
c
0>
c>
c
Q)
1 Institute Ho
(0
,2
CO
Prevention of Emis
PA Roundtable
LLJ
209
-------
27. 728.05.1992
Measuring Devices
and
Test Results
Copyright:
Research Institute Hohenstein
Schloss Hohenstein
D - 7124 Bonnigheim (Germany)
EPA73KU
EPA Roundtable
Josef Kurz
Institute
Hohenstein
210
-------
Survey
1.1. Necessity
1.2. Necessity
2. Activating the Industry
3. Test and Research Programs
4. Test Arrangement
5. Task
6. Composition of the Drycleaning Air in
Drycleaning Machines
7.1. Components in the Drying Air
7.2. List of Components in the Drying Air
7.3. Important Components in Drying Air
8. Valve Control
9. Evaluation ;
10. Tested Measuring Devices
EPA74KU
EPA Roundtable
Josef Kurz
Institute
Hohenstein
211
-------
f»IOt'Vd3
Ifcln^f
r^wjR^
>
II
•is
O CO
£- t
'o
o
0'5
0
O)
CO
4_: O
•5 ®
O .C
O) O
•E*
CO
£:
0
0
D TD
1 2
> o
0
CM
%UI f—
p- 00
o °?-Q
S'o3 ^88
cc *- •§ 3> °
x
LU
w
O)
o
CM
O)0_0 g_i=
Tt —* s'r=
vJ -rs CO »*—
0)0 CO ^, *te
^ O -C 0 ••
^ « O -(I)
53 y r- -=£
CO
o
C
0)
o
0
0
Q.
111
4-rf
0
o
3
0)
03
0
.Q
I
O
DC
£
LL1
212
-------
room
o
^^i
3>
s
j
1
0
inuously measurem
^rf
o
0
•
n
MS
ro
E
0)
E
in
CO,
c
a
a
o
in
1
ipational exposure
3
o
o
O
•
>
o
JO
3
CL
i
;uring equipment is
CM
0
t
0
wtinuous measure
^*
o
CO
Q
. *
i
:
jr-v:
£ ,
o
E
CO
^
!E
^^^H
C
ppm (3 measureme
in
•h
CM
i
1
'
§
i
'
"^
05
0
OB
TI ( 1 measurement
••
a
a
in
_c
•§
C
0)
o
n:
(D
3
•i
B
0
E
.a,
cr
Lil
•— •
Measurement
-------
214
-------
CO
O)
O j.
Q.'CD
0
CO
•«-»
CO
• a>
o>
C
0
T3
CO
c
0 •==
to CT
C CD
-0
asked Institu
able and
ava
desamt
the
test
er to
Umweltbun
in ord
-g s
B <
EQQ
C3)=>
•§-§"
CO -Q
CD CD
T3 O
£ !
O *=
II
fl
CO 0
•§£
started with 8 measuremei
the following charts.
n on
It was
give
c\i
CO
.CO
o
1
;
£ CD .£
dy is 5
nn 1 Q
« «JJ • tr
prog
O)
I
JD
O
^
•o
(0
0)
o
2
"3
I
*j
0
a
'5
or
UJ
Measureme
m
I
LU
215
-------
>__ LLJ
S)OC
O)=;
5o
CO
o
0)
0)
i
Q_
Q.
(0
Lit
216
-------
lS3£*£»~«?£s==iaj-'Ssis=K=K3s
3TK«i<^3?JnS;'SS3SKS3rwE
=ra--ggTCras»Mig5=
^rjNKSrKS-rSSMKSSWS"*
_
= o .
217
-------
0
O)
ii
Q.
I
(0
U.
•v*
J
CO
C T3
I?
^ CD
.
"50
S 2
o
8
o>$
co
0.1 »
"N • tS
- =:
c O
0 ±e
O) 2
CO
15
8 "6
2-i
0
c
0
O
0
CO
8
8
0
0
0
i
0
0
S
i
0
0
CO
CO
O)
0
I
0
o
0)
(0
CO
"6
O)
0
8-i.
CO
0
I
CO
0
218
-------
1
O
"E
CO
D)
0
O
£
CO
0)
O)
CO
O)
O
CO
•
K
tr
OS
O
0
0
CO
CV
•d
(0
"6
I-
II
*s. >
8
0)
J7
I
o
z
•
I
2
I
D5
0
1i
£
I
0
0
i
219
-------
7-2-1 List of Components in Drying Afr
C h I o r i ne Free Sotvents
Ethanol
n - Propanol
2 - Propanol
Amylalkohol
Cyclohexanol
Diethyleneglycol
Butyldlglycol
Acetone
Ethylmethylketone
Ethylacetat
n - Butylacetat
" • !
2 - Butylacetat
i
Amylacetat
Butyldiglycolacetate
Hydrocarbons:
n - Aliphatic compounds
jso - aliphatic compounds
Cycloaliphatic compounds
with 8 to 10 C-atoms
i
Aromatic hydrocarbons
Gaseous Water
. :->(fi%p£M^ v" i
^ii^^tli^HiWl^ty^yj-^^rvv^^l1-^::i;f;r :.-'..L.-'- .'.
" • •' ' " •• "- •"-"*'* -•"""™"S'\v,':**-..V*".-:-".-"..' '-' •••*•' ..:...'
Dichloromethane
Chloroform
Tetrachloromethane
Dichloroethane
1,1,1-Trichloroethane
1,1,2,2-Tetrachloroethane
i
Trichloroethylene
1,1,2-TrichIorotrifluoroethane
(EPA3Pi)
EPA Roundtable
Institute
Hohenstein
220
-------
CO
liil
CO
o
CO
CO
o
o
o"
0s-
CM
O
i»*
O
0)
£
o
(0
e
JS
^
(B
O
cc
£
LJJ
221
-------
CO
(0
73
O
CO
<
Q.
00
>-
O)
CO
O Q
O E
IT)
{{{{(EH
CO
>-
O
i
CO
0
cC
O
z
(0
c
"if
>-
(9
4-
"O
c
O
EC
CL
LU
222
-------
PC
Rough
Measurement
Data
Concentration
time graphs
Correlation
Measurement/
Concentration
Correlation
coefficients
Long - term
reaction
EPA Roundtable
Eva/uat/on
LOGGER
Measurements
Measuring time
Concentration (g/cbm)
Measuring time
Measurement
Correl.
Concentration
Correl.
Measurement (Ref.) Concentration (Ref.)
Correlation coefficient
Mashine running No.
Measurement reference 2 g/m3
* » » **
Mashine running No.
(EPA6PO
Institute
Hohenstein
223
-------
1
I
wm ^
Kfl rT1! m
CD
o o
CO CO
'LU
CO
LU
CO
O
o
o
LU
E
O =
U. O5
O O
-------
27. 728.05.1992
Measuring Devi
and
Test Results
Copyright:
Research Institute Hohenstein
Schloss Hohenstein
D - 7124 Bonnigheim (Germany)
EPA73KU
EPA Roundtable
Josef Kurz
Institute
Hohenstein
225
-------
Survey
1.1. Necessity
1.2. Necessity
2. Activating the Industry
3. Test and Research Programs
4. Test Arrangement
5. Task
6. Composition of the Drycleaning Air in
Drycleaning Machines
7.1. Components in the Drying Air
7.2. List of Components in the Drying Air
7.3. Important Components in Drying Air
8. Valve Control
9. Evaluation
10. Tested Measuring Devices
EPA74KU
EPA Roundtable
Josef Kurz
Institute
Hohenstein
226
-------
G
S c
.£ o
•<=•£!
0
a>
CO
3 -S ~
0 .±
|£
o'i
a) o
•its
03
0)
..
si
l§
"O S
a>
CM
1
co
(01 c
00
Illl*
&
CO
O)
04
CD
8
03 «=
(6
UJ (Q.E
0)
.c
o
I
0)
C
I
0
a
'5
D"
UJ
+•*
O
0
(0
CD
.2
J3
CD
|
I
2
LLJ
227
-------
0)
c
0>
CO
-------
q
© co to
co
Ho
229
-------
§
E
2 i=
Q/CD
CO £
CD
• CD
. ®
•s j
-
CD
®
iii
2 o g
CO
Q)
O
X
0)
S
-«-rf
"c
I
0
a
"5
cr
ill
4-*
o
£
CO
CO
o
c\i
able
Rou
230
-------
I
1
Q)DC
O)=>
og
CO
o
(L.
o
4ft
1
0)
§
a.
I
c
i
£
UJ
231
-------
232
-------
$
•5
<
i
^
'^
§
Sj
^
i
•k.
Drying Air fa
S>
^
^
^
fc
Composition
••••f
CO
ID)
0 '^3
*t— o
T3 Q.
m O
\w 3t
* <0 -^
11 8
o w k
£ c •§
s£ 0 <*~~* f\
0 CD o ^-
"22 ' • •* *S5 ^^^ ^^
Co 03 _ CI -ssg^j a) i
i §iHi.
-!P'4 oj C 0 |C|K| 0
IS s
8 "8
*- B
•co "H
o ~^
CCj
.-^ c~
^ li
^
i
i
•»=:-- ;
c
0)
E
0
CO
0
0
-t->
•9
b
to
T3
"•"•--- n^
g .£
5 £<
*^^ '_ »—
S -D
§: ^
Or c
L |
c
0
c - ;
O;
—
Q-^'
£0 *
c
O m
/hich gaseous c
f perchloroethyll
> o
i
£
I .£
L1J Q)
"* 4->
c
o
o
X
£
^J
0
•
CO 1
t± IH
03 H^H
0 •
ll
....,_: •. ^ ^^H
| Answer:
results on folk
u B&
s Hi
s •
cc H9
^n
jg
«
c
o
QC
§
Hi
L_
233
-------
I
I
I
•o
0
•g
CO
o>
0
|
£
OJ
0
O)
o
TJ
(0
0
O)
Jf
O
CO
r^
•c
CO
o
o>
o
CO
CVj
K
•e
(0
o
CD
CD
CO
s
01
8
i
(D
Q.
CO
T3
>*
t
O)
1
|
CO
CD
T3
CO
•s
I
1
CD
9>
iD
CO
ico
CD
+*
w
0)
o
I
0)
•3
£
UJ
234
-------
7.2.
List of Components in Drying A/r
GhIorine Free Soive n ts
Ethanol
n - Propanol
2 - Propanol
Amylalkohol
Cyclohexanol
Diethyleneglycol
Butyldjglycol
Acetone
Ethylmethylketone
Ethylacetat
n - Butylacetat
2 - Butylacetat
Amylacetat
Butyldiglycolacefete
Hydrocarbons:
n - Aliphatic compounds
iso - aliphatic compounds
Cycloaliphatic compounds
with 8 to 10 C-atoms
.- \
Aromatic hydrocarbons
Gaseous Water
Dichloromethane
Chloroform
Tetrachloromethane
Dichloroethane
1,1,1 -Trichloroethane
1,1,2,2-Tetrachloroethane
Trichloroethylene
1,1,2-Trichlorotrif!uoroethane
EPA Roundtable
-------
CO
CO
o
o
o
c
Q)
O
X.
CO
O
CM
O
0
CO
Q_ CD
.2
.o
(B
4>*
•o
o
cc
Q.
LLJ
236
-------
1
1
1
1
I
L.
"(S
•o
(D
CO
D
1
'
0*
PH uj a, 1-—,
: j:x CD
n >~^Qk >^
<
0.
a
C
'«
|
0)
o
I
237
-------
Rough
Measurement
Data
Concentration
time graphs
Correlation
Measurement/
Concentration
Correlation
coefficients
Long - term
reaction
EPA Roundtable
Evaluation
LOGGER
Measurements
Measuring time
Concentration (g/cbm)
Measuring time
Measurement
Correl.
Concentration
Correl.
Measurement (Ref.) Concentration (Ret.)
Correlation coefficient
* * % t
•**
Mashine running No.
Measurement reference 2 g/m
3
* * * **
Mashine running No.
(EPA6P!)
Institute
Hohenstein
238
-------
239
-------
27. 728.05.1992
Residual
Reduction
Copyright:
Research Institute Hohenstein
Schloss Hohenstein
D - 7124 Bonnigheim (Germany)
EPA26KU
EPA Roundtable
Josef Kurz
Institute
Hohenstein
240
-------
Survey
Residual Reduction
1. Residues in Textiles
2. Fundamental Facts
3. Deodorisation System
4.1. Perchloroethylene in Textiles
i
4.1.1 .Machine Technology
4.2. Retention of Different Fibres/Textiles
5.1. Distribution of Perchloroethylene
5.2. Residues in Finished Textiles ([Examples)
5.3. Retention of Fused Interlinings
5.4. Retention of Fused Interlinings (continued)
6. Finishing Treatments
7. Retention of Finish on Cotton
EPA25KU
EPA Roundtable
Josef Kurz
Institute
Hohenstein
241
-------
|
i
O)
y Deutsche Forschi
JL_ J-J
>»^
m
T^
11
Dr.C.Verkoyen.
. .
b
to
c
"o
o
o
O
^^^
|—
U^
wO)
3s 5
C.O)
_CO ci
Q."CD
Q)r=
c "5<
"c ®
CO «™"
CD 0
O =
•n ^
W (/)
CD O)
emissions out of th
IBA) and Forschun
f perchloroethylene <
mweltbundesamt (L
0^
c >*
O "^
"•« "o
O CD
^ O
T3 C
CD CO
QC C
= u=
•
CM
• a
1 £
f LU
'
!
! '
1
|
!
|
'
;
1
Dr.H.Brackemann
• *
o
to
C i
t?
o
o
o
i
c
1
S
0)
-2
(0
iidual Reduction
£
a)
«
1
IM«
i
IE
242
-------
UL
CO
LL
CM
0
CD
o
o
o
Q.
0
*-»
0
C/5
0
co
O
O
ift
'•ggasagr
'
o <»
:Q E .
**~ - O
— » ,-^^ ^J
.is r 0
JZ >* CO
-
0
O
i CS
OTZ
n :3
.2 co
"ij?
0 -*3
«*
^co-
ID £
1>*5
o
0
CO
05 JZ«=
OIS^
^rMIHI'^
li^Swj-^JM-q '
CD OT
® c
c
o
1
$
• • ^*
"co c
> o
Q'co
CCQ
.2
CO
o
o
c
o
to
0)
CO
75 I
§ "CO
E g
o -
.12
(0
o
0)
- .c c
D-'f S g
8*81
^t8-1
O "CD
O
CD
CO
o co
E S
CD -^
o
o
o
0>
o
X
c
c
o
I
cc
15
3
p
'53
.Q
(0
•*-*
TJ
I
243
-------
CO
244
-------
iii
O:
OOOOOOOO
00000000
(oidd)
601
C
-------
4:1.1
Machine Technology
D-1
D-2
Closed Circuit Machine
+ Integrated Carbon Filter
Exhausting Machine
+ integrated Carbon Filter
t
CARBON
' "*' "
—-+•= Deodorisation Phase
• = Drycleaning Cycle
EPA18KU
EPA Roundtable
Residual Reduction
Institute Hohenstein
246
-------
CM
o
o
O
O
00
CD
LO
CO
(oidd) 6 >| /
Si 2
601
o
JD
^3
(0
o
DC
247
-------
r
248
-------
CO
0)
'35
QC
CM
JIO
Q
•o
o
ca
CO
T-
Q)
Q.
1
oooooooo
00000000
OlOOiOO.lOOlO
^- CO CO CM CM T- T-
(uidd) 39|!JX9j_ 6>j / 30^ 6uu
(0
1
I
111
249
-------
C
0)
o
I
O
3
P
"55
o
cc
_
.0
(0
I
I
UJ
(uudd) 6>|/6uj
250
-------
I I
CO <
II li
o
o
o
o
o
o
CO
o
o
o
o
o
o
o
CO
CM i-
(tudd) 6>j/6uj
-------
to
C
0)
"S
o
CD
ooooooooooo
'
CO
c
o>
o
Q)
«#-»
.t:
"eo
C
o
I
0
QC
"(0
"w
CD
CC
CO
.Q
OS
I
g
3Od 10 uoijonpey%
252
-------
o
I
O
• MH^M
jyy
3|
a>
cc
o
o
oo
o o
|/6ai 30d
C
0)
o
c
O
0
GC
"co
p
'w
o
cc
(0
•«-<
T3
1
LJLJ
253
-------
27. /28.05.1992
Dioxins
and
Furans
Copyright:
Research Institute Hohenstein
Schloss Hohenstein
D - 7124 Bonnigheim (Germany)
EPA59KU
EPA Roundtable
Josef Kurz
Institute
Hohenstein
254-
-------
Survey
1. Fundamental Information
2. Research Programs
3. Chemistry of Dioxins and Furans
4. Chemistry of Dioxin
5. Forming of Congeners
6. Toxicity Equivalents
7.1. Pathes
7.2. Fundamental Consideration
7.3. Fundamental Consideration (Continued)
8.1. Screening Tests
8.2. Screening Tests (Continued)
9. Results
10. Results (Continued)
11. Comparison
12. Conclusion
13. Distillation Tests and Results (without dirt)
14. Dioxins / Furans in CFC / White Spirit
15. Further Conclusions
16. Origin of Dioxin and Furan Burden
17. Final Conclusion
18. Sources :
19. Removal of PCDD / F by Drycleaniing
20 Further Experiments: Redistillation
EPA58KU
EPA Roundtable
Josef Kurz
Institute
Hphenstein |
255
-------
§
CO
CO
CO
CO
c
i
CO
CO
5
CO
CO
CO
CD CO
o
0
O)
T3
CO
CO
O
13
LL.
OC
0
C
CO
^
Q-S
0 O)
CO
0
o
a.
cvi
CD
»_ ^
co Q
$^
-
CO
"
CO
co
JP. DO
o
"So
0 0
to^
.
S
0 CO
> 0
CO CO
•D
'o .^ .c
"°:i co
?? 8
S^ 2
CO "D v,
0 0 C*
T3 J^ CO
c £S 52
13 CO CO
Sp 8
0 £ g>
E ==
^S8
nS P c
l
c
"0
0
O
1
•+-'
"co
o
a>£
.E^
ISJ
^ d
I O
08
p
(0 o
O
8
CO
CO T3
II
0
c
'3
to
c
o
z
(0
Roundtable
0_
LU
256
-------
.
'
Programs
I
^
i
*
1^
• • • • ' •;:• • - •' 'i
«\t
: , §
UJ
~
0
T3
C
Q)
S c .Q
*O 'o ^
c w ^
o c o
•& 0 Q.
fl -E -s?
*- O .S5
CL to
O 0) ^
^^ •I"' Cl
0 .i -E
.si - g
OT — '^
E T3 -D
CO C ^)
? f- §
25 -"^
"o >» o>
i1" 1
WM- •*=
^^^^ - VMB
|) 0 g
E > 0
C\i ±J r-
m w '5
S? fe o
k_ fll v-»
CO > ^
o 'E *b
© D 0
j£ o
1"™ CO
T5
1
CM
•
0
C
1
»v
O)
C
P .c
LL. *~» CO
^j ^ 0
m § £
••i^ *HPB
>* *""" "O
g> I c "6
-=r CO O *-•
i 8 'S 3
o E = g
^ JD 3 2
CO
•o
D
O
Q.
E
o
o
0
'c
tn
1U
o
'i_
o
:s
*B
b
III 1
ff- "S .S co
^ Q 0 £
^ . ^I CO
"c - «S c
2 s .ffl '1
.. o co E
C? c ^ 0
"2^7 • ^^m «^ •^•^
B -E a A
CO O CO CO
C- O "c O
LL. O P Q.
*
T3
0
.CO
c
"3
»
c
o
o
X
0)
3
*«*
1
^^_ *^ ^ffiB
< 0 HI
CD ^ BH
"^ 5 HH
== ? •
i S 1
!~ ^ ^H
Ii 1
eg. •
(0 "0
E t
~o to .
^^^ ^1S ^^^% BffrffiBff*B
CD C35 EffiSiiltifl
± -Q ^
Q jc ,_
jj E °°
i ^ &
J5 O) CO
.5= o 3
"0 Q_ £
i- >-£- CO
R -® ~*
O c~ c~
0 P o
^- CM
it
0)
^
(B
€
C
i
2
UJ
2B7
-------
1
I
1
t
a
CO
§
LJ_
O=Q
\
O—O
I""
^v
I
Q
O
— O
I
Q
S
I
Q
c
'S
(0
•o
i
111
258
-------
1
e
"©
I
C
g
b
I
CD
.Q
Q
.
I
O
c
i
LU
.259
-------
1
CO
Eg
£.0
-------
I
•sr
."K>
•^
I
CO
fi
•s
CO
0
b)
0
T3
_co
CO
£
0
CO
T3
D
LL
Q
O
O
g
"x
= Q
LU Q
^ o
c
"co
0
I 'I
!i CT
O •'S
§
a
T3
CO
'S
O
T3
S2
0
0
O)
8 S
0
0
.0
o ^:
"x o
.o *
o o
x co
Q §
0
CO
O) co
0 CO
T3 &
0 O
O O
C
x
Q
Q
O
O
9
6
:Q
Q
<30
««
IN-
o o
LJU
261
-------
,262
-------
I
1
I
I
I
CSJ
o o
o o
o
d
-o
O
CO
O
O
d
o
o
CD
Q_
sre
O.Q
/0v
d
Jj
d
O
s
i
Q_
§
CD
o-o 1
•Q
CD
0
2
o.
o
I
o
X
CM
C
'55
I
o
<£
O
•8
I
£
LLJ
263
-------
[
Jo
i
•£§
I
$
CO
8
.o
o
cleaning
O)
I
I
CD
5
"8
o
T3
CD
.D
32
O =
CD "CO
o
Q. 73
Q>
Q
1
CO
">
C
"x
fi
I
CD ,
n
P"o
§1
CD S-
E
h- CO
0
c
CD
CD
O
CO
05
.C
CO
I
8
c
f
0)
CD
O)
05
E
CO
CO
o
CO
to
ft
'
To
i
CO
-
CD
Q_
it ii
(0 "m -C CD XI t>
^ 0) F CO
«
0)
o
X
0)
*•>
undtable
• • f •
264
-------
£
I
s;
£
00
CO
.2?
Q.
E
05
CO
O
O
c
"0
•*-»
CO
c:
CD
JC
O
I
CD
s
«+—
O
tf
CD
d
X
LU
CO
E
O
CD
T3
(D
CO
0
.r: 'CD
•ge-
£3
|&
.•&5
m n-T
&S
CO §
0 1
O5~;r
J^ (D
12 W .^
£ ^ ^~
J5 r- C
QL| 0)
O) > -
.g w jo
S c (3)
CO .i= -=
0 SI CO
^co fc
£E o
Q -^ c
>>
•«-»
'o
CO
Q.
co
Q
S CD
S--^
.gin
^ CM
*f C
c jo
3,-S
to to
o to
o-9>
-S 8
CD.C
c x:
1 §
o E
^
^.-i=f
Q ^
CO U
13 o
O CD
"E =
1^
X= CO
-c c
0) O
:5 "tO
1- to
_C CD
O *J=:
2
CD
C
CO
J>
o
CD
1
CO
T3
CO
CD
i
3
0 =
c c
CD 13
12
CD t5
-
0 CO
IJ
t/) CO
=: CO
< ^
! LE
W
<0
o
z
®
n
I
a
!5
(0
O
QC
Q.
LU
265
-------
CsJ
CO
CO
o
0
0
to
CO
0
O CO
.Q>
CO
o
0
CO
CO
§2
CD O
•£ c
.£ O
fi'S
-S E
0 *
-S io
CO =
&•
0 CO
.- CD
CD
N
10
CO
CD
CO _ CD
E co c
D iS
U- C
0 ^
0
CO
0
o cP^To
o
O ^* is T
CO
0 =5
•
UJ
266
-------
8-88838°
9QQQQQOOO
267
-------
268
-------
269
-------
o
O
0
co
Q. Q-
O «
0
co 0
o co
co
co
^ D
"
Q •
O
Q.
0
O
(D
CO c
I- CO
CD ,co
§1
—Z. •*—
O «r
CD
"Bd
13 O
CO CL
to
CD
0)
C "^ 'CO
CO S O
>% o_
^^^^ _^^_^ " ^^^^^
CD 'cl co
UJ
270
-------
c
I
8
Q.
•5
CO
CD
•JO
"co
CD
9
I
LL.
Q
Q
O
Q.
o
CO
Q
O
O
ci
O
CO
O5
CO
n nun nil ni
CO
si
o
.10
CM
0
O
CM
0
O
O
•r—
' •
O
ID
f
jfi
89
®
©
X
©
271
-------
272
-------
m
1
I
1
1
1
i
§
1
i
1
1
i
i
1
Further Conclusions
Wiium11
CO
C CD
05 .Q
few
.5 "5
CO £
r: C
•— CB
X Q
O
=5 g
§i
OtJ
«*— d
o o
is O
1 c
CO O
O 05
ible - even under extreme conditi
drycleaning machine. The destill
formation of dioxins/furans.
CO 05 CD
CO »*» £1
o ^5 -r
^^N ^^B
.5 to ^
CO Q O
S5 •£• to
g 3= 05
«
0
. 0
CO c~
= CD
"d •*-•
•^ CD
S- o
co £i
0 ^
•"— — f^"
•^ P
> ^_
^ CD
*i^
•0 CL
05 *S
0 g
LL. ^
O cB
M- CO
0 JD
CO . Sal
> 1
jz
o ®
•-i=i ^
CO (8
CD ^
o |
(£
£
LU
273
-------
CO
suiojv SUUOILJO p jequinN D
274
-------
Final Conclusions
isor1
N-
«MM
•+-*
f)
^^j
0
D
CO
0
0
CO
JO
•5
CO
O)
c
rans in the residue of drycleani
out of the cleaned textiles.
•ST3
•a §
1 1
8 tf
b =5
0
__
•i-*
0
O
i_
JO
-TT
J^
0
a
*S
c
03
\w
c
rans are not formed by transfo
>.
^1
-o 1o
w£
8 S
o'i
S
S
O
CO
^N
0 T3
0. C
^>% 13
^"* O
0 *-
^1 0
•fr™' ^
«+- 0
P ^
C CO
T3 fO
C — T
of dioxins and furans is indepe
3 and white spirit dioxins and fi
c £1
"iS ^
||
*® 8
£ 16
•
275
1 1
i — C
Q5
O
X
®
1
"5
£
\ . 1&&M
H
i H
t S^B
o ^H
0 HH
o mm
•ans were only found in presen
^
T3 ®
CO "i
CO ^
C E
's 1
s =
CL
LU
.
-------
276
-------
*
t
S
1
.i
CO
c
o
e
o
O
CO
CD
- : ^•.wy.\. M^tctftfi
OO
o o o o o o
K- 5WW**c«-J«
." '^W*^J»r»Fft)*WW?<'7^'¥«-Tuiv
qooooo
cjqc»-*- CM CM t- i- t- t-
O O Q O O
CD
CO
0
I
~O
1
O)
CO
i
1
I
c
'3
I
u)
o
i
UJ
277
-------
8OOOOOOOOO
OOCO-^CMOOOCO^CM
CM T- 1- T- T- T-
278
-------
Submissions from
Cynthia Marvin
California Air Resources Board
279
-------
-------
ARB Surveys
Date
Sent
April 1992
June 1992
July 1992
Survey
Type
Original
Hotel/Mote!
Foliowup
Number
Sent
5,500
500
3,700
Response
i Rate
32%
65%
23%
Overall response rate
50%
9/92
Breakdown of Solvent
Used at Surveyed Facilities
(Percent of Total)
H Pere:84%
C3 CFC-113:<1%
|3 Petroleum Sovents: 15%
| 1,1,1-TCA: .<1%
Q Other: <1%
Total: 464,000 gallons
9/92
281
-------
Total Survey Response for
Perc Dry Cleaning Operations
Number of Responding Facilities: 1,980
Number of Machines in Use: 2,205
9/92
Types of Perc Dry Cleaning Machines
at Surveyed Facilities
Transfer: 9%
Dry-to-Dry Vented: 36%
Dry-to-Dry Non-Vented: 52%
Converted: 3%
9/92
282
-------
Perc Emission Reduction/Reclamation
Devices at Surveyed Facilities
Device Type
Number of Machines
Refrigerated Condenser
Carbon Adsorber
Other
No Device
1,450
430
1,090
100
9/92
Average Perc Mileage By Machine Type
For Surveyed Facilities
Machine Type
Average Mileage
fibs/gall fibs/drum*)
Transfer 130
Dry-to-Dry Vented 180
Dry-to-Dry Non-Vented 370
Converted 260
* Based on a 52-gaIIon drum
283
6,800
9,400
19,200
13,500
9/92
-------
Perc Machines: Over 20 Years Old
100
At Surveyed Facilities
Transfer (-| gg2)
%
of
90 machines
(4% of total)
Dry-to-Dry
Vented
Dry-to-Dry
Non-Vented converted
4%
1%
Machine Type
9/92
100 -r
Perc Machines: 10-20 Years Old
At Surveyed Facilities
(1992)
Dry-to-Dry
Vented
59%
300 machines
(14% of total)
Dry-to-Dry
Non-Vented
14% Converted
7%
Machine Type
9/92
284
-------
Perc Machines: 5-10 Years Old
At Surveyed Facilities j
of
Total
100
90.
80-
70-
60-
50-
40-
30-
20-
10-
0
(1992)
Dry-io-Dry
Vented
59%
670 machines
(32% of total)
Transfer
3%
Dry-to-Dry
Non-Vented
32%
Converted
6%
Machine Type
9/92
Perc Machines: Under 5 Years Old
At Surveyed Facilities
100 ,
%
of
Total
Dry-to-Dry
Non-Vented
82%
1,030 machines
(50% of total)
Dry-to-Dry
Vented
16%
Machine Type
9/92
235
-------
50-
40-
Surveyed Facilities By Annual
Gross Receipts (1991)
42%
of
Total
$25k $SOk $100k $250k $5C
Range of Annual Gross Receipts
9/92
Hotel and Motel Survey:
Preliminary Results
20 surveyed facilities dry clean on-site
About 75% have dry-to-dry non-vented machines
About 25% have dry-to-dry vented machines
9/92
286
-------
en
Z
O
HH
k-
Ul
a.
o
o en
Z Ul
»»« H*
Z 1-
< 1-
Ul -1
0 0
>- u.
K
o a
Ul
o K
z o
< Ul
u ut
te. in i
Ul I
Q. Z 1
Z *-
O Z O
O k.
CS i-O
Z 1-
•-• < X
k_ 2 k.
ui 0:0
ui o e
3 U.—
Z E
O >•« —
M —
OJ .. k.
3 30.
O. *< 1
te i
a o t
z o
0 K.
u a.
ut
in o
CO M
* 1™
u. en
u. ui
l-
cn ui
O
03 te.
te. o
< o
CO
cr
o
u.
k»
3
O
a
z
-j.
•»,
£
-N
<>&
csN:
^S
^^
k.
00 X
UIW —
0.3 0
TO
'-'
j*~t
COO k.
UIUI X
H-< e
oui ja
j j —
o o ^*
^
>•
Ul H™
1-1 O Ul
OflL<
3O
A.
-^
l1^
/Sr
tXJS)-
^N^Ae*^
^^^5^>
^SwXJj^*1^
o*^^^^3*
^**^^s^TSi
^v^^s^
sJ^^QVfc^it
^x7 0
5r^ ui
5> o.
> t
H-
mJ
»-l
0
U.
*
/f
^
V
^
• a
a a
c c
k. k.
O) TO
O O
lv VH
O. Q.
Q
m c c
»--!>-
o o
•*• •**
C 0
•» «•
* a. a.
O E E
moo
1- O O
s s s
n o to
»o »-
OSS
s o o
in CM to
V
SOS
s s s
SOS
• » *
(OSS
*• CO ^
C4
*
*
CO ^C 49 ^C A O
J3Z JQZ -Q »-
I 1 !
O 10 O<0
»O »O ^
y£
vxx.
/£*} ^*^
^^^T\t
^vi?^^^^
^^^/^^
y^I^k Xw*^*^
s5^fcj^**O7 ^
^XJ^^^ ' ^*
•^S^*^^ 4*
•sT^V\ C
sx)y *
V/ -O
a
k. k. O
> « • o
ja xi'
k. k. -O
O O C
a • •*•
T3 73 O
e
k, C k. C k. TO
« O « O « —
Ok. Ok. •<»
CO CO C C
oo o o o\ •• >\ *••
i i i
s ca s in s
w •«*• o
^F"
k.
e
a
C 79
e « •
•o *•
e e
•Ok. 79 O C k,
• e co > •
•f A *• ja
e u c-o xt.
CO C C WO
> » >*• 0 «
79 O 1 -O
X< X k, 0 <
k. k. O *•
o c a o> ic
10 1 — XO
OJO O k. k.jQ
*• k. *«*. Ok,
I o i « e
xo xtr — *o
o * o * •»-'»
^•V ^"^ X^k
o ui u.
N.X ^^ X^
a
« ;
c ;
TO
O
Im
CL '
a o
m m c
H* H* i^ i
0
*•
O
•" i
a.
a o E •
m m o
H- i- o ;
.
•
i
s s <
s co z
IO CO
I
s s <
s h> z
*• ! '
|
S S <
s s z
OS
• •
0 0
in co
1
;
A k. A < A k:
— X — Z — X
t 1 1
n co s in »••
w ««• r-.
79
k. © U k;
C *• O «l
• C * «>
•o c « c 79 e:
c c > c co
*«79 1 79 *«T) k.-
c c c c e e: «
« o o o e o A
> 0 Z O > 0 •-
1 1 O
c-o x-o CTSI a
O « k. C O «> 79
z *• o •*• z *• <
010 Cl
xv. ok. x>» e
k. C *• C k. «) O
O 0) l TO o c»ja
1 — X— 1 — k.
Ok. k. k. O V. O
*• «fc O •»• *• »• O
1 « e i o
xte <-*« xo: 79
0 * ^ * 0 3t" 0
x"^ x^ ^^
OX*"4
X^ ^X %i^
o a
m m
k- k.
a a
o> a
o o
k. k.
TO TO
0 0
k. k.
Q. O.
e c
1-1 "-1
s s
CO O
CM
S S
CO S
»-. n
s s
s s
S 0
•> . •
CN S
»• CO
00 0 •
• A k. .A k,
— X — X
1 t
SCM SCO
W »- fO A
•o -o
« . *
^* ^^
C k, c k.
o o c c
^ 0 ?^ 0
1C 1C
e « e e
O 79 O 73
Z c Z e
o o
xo xo
k. k.
O79 O79
10 .10
O 4^ O ^
•*• o +• o
Ik. Ik.
xc xc
k. TO k. TO
O'— d —
i. k.
• <^ • ^*
> C > C
CK CK
0 * OX
^™\ ^"^t
^ ^
^^ ^^
1
•
o
•••>•
«o
0
«H
•—
0
>
^f
^»
0
z
e
« o
C •"•
o •+*
0 0
6
« k.
m o
o e
1 I
o< o>
mz ^«
J- CO
^™
* ^^
» » TO
287
-------
Preliminary Testing Results:
Measured Concentrations of Perc
Facility
(B)
(C)
(F)
Machine
Exhaust
(ppm)
830
7,600-
9,700
5.7-
9.4
Room
Vent
(ppm)
3.5
3.6-
34
12-
31
Upwind
Monitor
(ppb)
2.4
0.77-
10
3.1-
3.2
Downwind
Monitor
(ppb)
26
8.9-
140
124
Q/Q'
Staff Presentation
Background
Preliminary Technical Evaluation
Economic Analysis
Regulatory Schedule
Regulatory Concepts
288
-------
Economic Impacts
to be Evaluated
Compliance costs for dry cleaners
Other business impacts
Impacts on small businesses
Costs to districts and state agencies
Compliance Costs
Compliance Costs = any additional costs to a dry cleaner.to
comply with the requirements
Capital and/or conversion costs for equipment
• Added operation and maintenance costs
Added labor costs
Added permit fees
Added financing or other costs
,289
-------
Capital Costs for Selected Equipment
Equipment Type
New Closed Loop with RG*
-35 Ibs capacity
~50 Ibs capacity
~75 Ibs capacity
Converted Closed Loop w/ RC*
Add-on refrigerated condenser
Add-on carbon adsorber
*RC=refrigerated condenser
Range of Cdsts
(includes installation)
$35-48k
$48-59k
$55-70fc
$6-1 OR
$8-16k
$6-1 Ok
9/92
Staff Presentation
Background
Preliminary Technical Evaluation
Economic Analysis
Regulatory Schedule
Regulatory Concepts
290
-------
Tentative Schedule
For Future Meetings
Third public meeting: January 1993
i-
• Draft regulation
• Complete draft Technical Support Document
(TSD)
ARB hearing and possible adoption: May 1993
- Proposed regulation
- Staff Report
- Revised TSD
Tentative Implementation
Schedule
ARB adoption
Administrative Review
Effective Date
District Adoption
Compliance
*A district may act sooner
May 1993
Late 1993
Early 1994
Mid 1994*
1994* or later as
stated in regulation
9/92
291
-------
Staff Presentation
Background
Preliminary Technical Evaluation
Economic Analysis
Regulatory Schedule
Regulatory Concepts
Design of the Regulation
State law requires us to design the regulation
"...to reduce emissions to the lowest level achievable
through application of best available control
technology..."
considering the potential risk, cost, and impacts.
9/92
.292
-------
Regulatory Concept Objectives
1. Establish good operating practices for all dry
cleaners
2. Move cleaners into better equipment (if applicable)
3. Provide a quantitative standard to evaluate
performance
4. Balance public health protection and costs
i. Good Operating Practices
(for ALL facilities)
1. Operator training/certification j
2. Education/compliance assistance
3. Operation, maintenance, and inspection
requirements
4. Pollution prevention incentives
5. Recordkeeping and reporting
9/92
9/92
293
-------
II. New Dry Cleaning Operations
A. Equipment:
Closed-loop machine w/refrigerated condenser-
drying sensor; control device for machine door:
overflow trough
B. Operation and Performance;
Ventilation/exhaust requirements;
mileage/performance standard
C. Residential Locations;
Siting advisories to local agencies; additional
containment/control of fugitive emissions
9/92
III. Existing Dry Cleaning Operations
Small, medium, and large, based on amount of
clothes cleaned
B. Equipment. Operation, and Performance;
For SMALL, MEDIUM, and LARGE facilities:
phase out transfer machines and replace with
closed loop machines w/ refrigerated
condenser
9/92
294
-------
Hi. Existing Dry Cleaning Operations
(cont.)
B. Equipment- Operation, and Performance fconU:
1. SMALL facilities: control dry-to-dry vented
machines
2. MEDIUM facilities: control OR phase out
dry-to-dry vented machines; drying sensor;
mileage/performance standard
3. LARGE facilities: phase out dry-to-dry vented „
machines; drying sensor; control device for
machine door; ventiiation/exhaust
requirements; mileage/performance standard
9/92
III. Existing Dry Cleaning Operations
(cont.)
C. Hflaldentlai Locations:
Additional containment/control of fugitive emissions
D. Compliance Schedule OPTIONS:
- One date for ail facilities
- Two dates based on status under EPA's standard
- Three dates based on facility size category
- Multiple dates based on facility Perc use
- Multiple dates based on facility Perc mileage 9/92
295
-------
-------
Select Bibliography
of Materials
Relating to Drycleaning
297
-------
-------
Setected and .Annotated BMographies of Materials
Alliance of Textile Care Associations. 1988. Analysts
of Dry Cleaning Variables on Perchloroethytene
Residues. Washington, DC. August.
Barnes, D.G. and M.L. Dourson. 1988. Reference
Dose (RfD): Description and Use iii Health Risk
Assessment. Reg. ToxicoL PharmacoL 8:471-486.
Barry Lawson Associates Inc. 1991. Dry Cleaning
Business. New England Interstate Water Pollu-
tion Control Commission. Fall.
Brackemann, H. 1990. Revised Version of the Second
Federal Emissions Safety Regulation and Its Effect
on the Operation of Dry Cleaning Plants. Federal
Office of the Environment, Berlin. Translated by
SCITRAN, Santa Barbara, CA.
Brown, D.P., M.P.H., and S.D. Kaplan, M.D. 1987.
Retrospective Cohert Mortality Study of Dry
Cleaner Workers Using Perchloroetbylene. June.
Brown, P. 1991. Dry-Clean Chemical Targeted, Al-
bany Times Uhfon. Monday, July 22, 1991.
Buben, J.A. and E. J. O'Flaherty. 1985. Delineation of
the Role of Metabolism in the Hepatotoxicity of
Trichloroethylene and Perchloroethylene: ADose-
Efiect Study. ToxfcoL Appl Pharmacol 78:105-
122.
CaMfomia Department of Health Services. 1991. Pro-
posed Identification of Perchloroethylene as an Air
Contaminant Technical Support Document. Au-
gust.
CARB, 1991. State of California Air Resources Board.
Proposed Identification of Perchloroethylene as a
. Toxic Air Contaminant Staff Report, August.
Carpenter, C.P. 1937. The Chronic Toxicity of
Tetrachloroethylene. J. Ind. Hyg. Toxicol 19:323-
336.
CEC. 1992. Center for Emissions Control. Dry Clean-
ing—An Assessment of Emission Control Options.
Final Draft, March.
Daft, J.L. 1988. Rapid Determination of Fumigant
and Industrial Chemical Residues in Food. J.
Asscc. Off. AnaL Chem. 71(4).
Derosa, C.T., M.L Dourson, and R. Osbome. 1989.
Risk Assessment Initiatives for Noncancer End-
points: Implications for Risk Characterization of
Chemical Mixtures. ToxfcoL Ind. Health 5:805-
824.
Dmitrieva, N.V. 1968. Bioelectric Activity and Electric
Conducting Properties of Muscles Exposed to
Chlorinated Hydrocarbons. Farmakdlogiya t Tok-
sikologiya 31(2):228-230.
Entz, R.C., K.W. Thomas, and G.W. Diachenko. 1982.
Residues of Volatile Halocarbons in Foods Using
Headspace Gas Chromatography. J. Agrfc. Food
Chem. 30:846-849.
Entz, R.C. and G.W. Diachenko. 1988. Residues of
Volatile Halocarlbons in Margarines. Food Addf-
tives and Contaminants 5(3):267-276.
EPA, n.d. U.S. Environmental Protection Agency.
Investigation of Non-Occupational (Consumer) Ex-
posure to Perchlcn&rqjlenefrornDry-CleanedFab-
rics. Washington, DC.
EPA. 1985. U.S. Environmental Protection Agency.
Health Assessment Document for Tetrachlo-
roethylene (perchloroethylene). EPA/600/8-
82/005F. Office of Health and Environmental
Assessment ORD, Research Triangle Park, NC.
EPA. 1988a. U.S. Environmental Protection Agency.
Reference Dose (RfD): Description and Use in
Health Risk Assessments. Integrated Risk Infor-
mation System iffRIS). On-line. Intra-Agency Ref-
erence Dose (RID) Work Group, Office of Health
and Environmental Assessment, Environmental
Criteria and Assessment Office. Cincinnati, OH.
EPA. 1988b. U.S. Environmental Protection Agency.
Air and Energy Engineering Research Laboratory.
Evaluation of Perchloroethylene Emissions from
Dry Cleaned Politics. EPA/600/2-88/061. Octo-
ber.
EPA. 1988c. U.S. Environmental Protection Agency.
Evaluation of Iterchtoroethylene Emissions Jrom
Dn; Cleaned Fabrics. Air and Energy Engineering
Research Laboratoxy. Research Triangle Park,
NC. EPA/600/2-88/061. October.
EPA. 1989. U.S. Environmental Protection Agency.
Risk Assessment Guidance for Superfund. Vol 1.
Human Health Evaluation Manual (Part A).
EPA/540/1-89/002. OERR. Washington, D.C.
EPA. 1990a. U.S. Environmental Protection Agency.
Drydeaning and Laundry Plants. EPA/530/SW-
90/027b. HazJirdous waste fact sheet.
EPA. 1990b. U.S. Environmental Protection Agency.
Dry Cleaning andLaundry Plants. EPA/530/SW-
90/027b.
EPA. 199 la. U.S. Environmental Protection Agency,
Office of Air Quality Planning and Standards.
Economic Impact Analysis of Regulatory Controls
in the Dry Cleaning Industry. EPA/450/3-
01/021. Final,, October.
EPA. 199 Ib. U.S. Environmental Protection Agency,
Office of Air Quality Planning and Standards. Dry
Cleaning Faculties—Background Information for
Proposed Standards. EPA/450/3-9 l/020a.
Draft, Novembiar.
299
-------
tor
Selected and Annotated Biographies of Materials
^^M_
EPA. 1991c. U.S. Environmental Protection Agency,
Region I Groundwater Management Section and
U.S. Environmental Protection Agency Headquar-
ters, Office of Ground Water and Drinking Water.
Preventing PoUuJtion in the Drycleaning Business.
Brochure, Fall.
EPA. 199 Id. U.S. Environmental Protection Agency.
Cleaning Industry. Office of Air Quality Planning
and Standards. Research Triangle Park, NC Oc-
tober.
EPA. 1991e. U.S. Environmental Protection Agency.
Dry <^anir^FaciItHesBacT^roundInforrnationfor
Proposed Standards. Office of Air Quality Plan-
ning and Standards. Research Triangle Park, NC.
November.
EPA. 199 If. U.S. Environmental Proetectlon Agency.
Proposed Rules for Perchloroethylene. Federal
Register 56(236). December.
French. M.T. and L.D. McNeffiy. 1987. Economic Im-
pact Analysts for the Replacement of Transfer Dry
Cleaning Machines with Dry-to-Dry Machines.
Center for Economics Research. Research Trian-
gle Institute Park. NC. Jury.
Gove, J. 1992. Summary of State Regulations on
Perehloroethylsne Dry Cleaners. Memorandum
from John Gove, Bureau of Air Management,
Planning and Standards to members of the NES-
CAUM Air Toxics Committee. Januarys.
Quo, Z., BJL Tichenor, M.A. Mason, and C.M.
Plunket 1990. The Temperature Dependence of
the Emission of Perchloroethylene from Dry
Cleaned Fabrics. Environmental Research
52:107-115.
Haddad, A. 1991. State Seeks to Recoup Cost of
Ground-water Cleanup: Officials Negotiate Over
Contamination from Dry-Cleaner Business, The
Baltimore Sun. Sunday, February 17, 1991.
Hake. C.L. and R.D. Stewart 1977. Human Exposure
to Tetrachloroethylene: Inhalation and Skin Con-
tact Environ. HealthPerspt 21:231-238.
Halogenated Solvents Industry Alliance, n.d. The
Safe Handling of Perchloroethylene Dry Cleaning
Solvent
Helkes,D.L. 1987. Pesticide arid Industrial Chemical
Residues: Purge and Trap Method for Determina-
tion ofVolatlle Halocarbons and Carbon Bisulfide
In Table-Ready Foods. J. Assoc. Off. Anal Chem.
70(2).
Hertzberg, R.C. and M. Miller. 1985. A Statistical
Model for Species Extrapolation Using
Categorical Response Data. Toxicol Ind. Health
l(4):43-63.
Hertzberg. R.C. 1989. Extrapolation and Scaling of
Animal Data to Humans: Fitting a Model to Cate-
gorical Response Data with Application to Species
Extrapolation and Toxicity. Health Physics
57(Suppl. 1): 405-409.
HEW, n.d. U.S. Department of Health, Education and
Welfare. Tetrachlaroethylene(Perchloroethylene).
National Institute of Safety and Health.
HEW. 1976. U.S. Department of Health. Education
and Welfare. Criteria for a Recommended Stand-
ard: OccupationalExposure toTetrachloroethylene.
Jury.
International Fabricare Institute. 1975. Experimental
Study on Solvent Discharge from Dry Cleaning
Establishments to the Environment Field Study of
California Dry Cleaning Plants. International Fab-
ricare Institute-Research Center. Silver Spring,
MD. May.
Izzo, Victor J. 1992. Dry Cleaners—A Major Source of
PCE in Ground Water. California Regional Water
Qualify Control Board, Central Valley Region.
March.
Jensen, S.A. and C. Ingvordsen. 1977. Tetrachlo-
roethylene Content in Garments Which Have Been
Cleaned in Coin-operated Dry Cleaning Machines.
Danish Institute of Technology. January.
Kjellstrand, P., B. Holmquist, M. Kanje, P. Aim, S.
Romare, I. Jonsson, L. Mansoon, and M.
Bjerkemo. 1984. Perchloroethylene: Effects on
Body and Organ Weights and Plasma Butrylcholl-
nesterase Activity in Mice. Acta PharmacoL Toxi-
coL 54:414-424. <
Klein, P. and J. Kurz. 1990. Studies of Solvent-Reten-
tion Capacity of Textiles When Dry Cleaned. SCI-
TRAN. Santa Barbara, CA. November.
Kylin, B., H. Reichard, I. Sumegl. and S. Yllner. 1963.
Hepatotoxicity of Inhaled Trichloroethylene,
Tetrachloroethylene. and Chloroform—Single Ex-
posure. Acta PharmacoL Toxicol 20:379-385.
Larsen. N.A., B. Nielsen, and A. Ravin-Nielsen. n.d.
Perchloroethylene Intoxication—A Risk When Us-
ing Coin-Operated Dry Cleaning Machines.
Ugeskr. Laeg. '<
Lauber, J.D., P.E., n.d. Best Available Control Tech-
nology and Exposure Reduction for Dry i Cleaning
Operations. New York State Department of Envi-
ronmental Conservation.
300
-------
Selected and /Annotated Bibliographies of Materials
Laundry & Cleaning News. 1991. Environmental
Costs Balance Out Well, Laundry & Cleaning
News International March 8, 1991, 13(4):34. ,
Levelton, B.H. & Associates. 1991a. Environmental
Code of Practice for the Reduction of Solvent Emis-
sions Jram Dry Cleaning Facilities. Prepared for
Environment Canada, Industrial Programs
Branch. Draft, December.
Levelton. B.H. & Associates. 199 Ib. Background In-
formationfor an Environmental Code ofPracticefor
Dry Cleaning Facilities. Prepared for Environment
Canada, Industrial Programs Branch. Draft, De-
cember.
McGrath, S. 1992. One of Seattle's Perks: A Dry
Cleaner with Minimal Perc. Seattle Times. Sun-
day. January 26.
Metropolitan Water District of Southern California
and the Environmental Defense Fund. 1990.
Source Reduction of Chlorinated Solvents. June.
Miller, L.J. and A.D. Uhler. 1988. Volatile Halocar-
bons in Butter Elevated Tetrachloroethylene
Levels in Samples Obtained in Close Proximity to
Dry-Cleaning Establishments. Butt. Environ. Con-
tarn. TaadcoL 41:469-474.
Morgan. R. 199 la. Consumer Problems with the Dry
Cleaning of Textiles. Australian Textiles. March.
Morgan. C. 199 Ib. Dry Cleaners Working to Tidy Up
Their Image. Miami Herald. Monday, December
2.
Morgan, C. 199 Ic. Dry Cleaners* Dirty Legacy: Pol-
lution in Drinking Water. MiamlHerald. Monday,
December 2.
Myers, RH. 1986. Classical and Modem Regression
with Applications. Boston: Duxbury Press.
National Analysis. 1987. Attitudes and Problems in
Compliance with VOC Regulations. April.
Navrotskii. V.K., I.L. Kashin, L.F. Kulinskaya. L.M.
Mikhaylovskaya, Z. Shuster, N. Burlaka-Vouk.
and B.V. Zadarozhniy. 1971. Comparative As-
sessment of theToxiciiy of a Number of Industrial
'Poisons When Inhaled in Low Concentrations for
Prolonged Periods. Trudy S'ezda Gigen Vkramkoi
SSS 8:224-226.
NCI. 1977. National Cancer Institute. Bioassay of
Tetrachloroefhylene for Possible Cardnogenlcity.
DREW Pub. No. (NIH) 77-813. U.S. Department
of Health, Education, and Welfare, Public Health
Services. National Institutes of Health, Bethesda,
MD.
NESCAUM. 1992. Northeast States for Coordinated
Air Use Management. Proceedings for Workshop
on Emission Control Strategies for Dry Cleaners.
January 8. Boston.
NTP. 1986. National Toxicology Program. Toxicology
and Carctnogenesis Studies of Tetrachloroethylene
in F344/N Rats and Female B6C3F1 Mice (Inhala-
tion Studies). Tech. Report Series No. 311. U.S.
Health and Human Services, National Institutes
of Health, Bethesda, MD.
NYSDH. 199 la. New York State Department of
Health. Status Report on Use and ReplaceabWty
of Tetrachloroethylene (PERC) In the Federal Re-
public of Germany. Translated by SCITRAN,
Santa Barbara. CA.
NYSDH. 199 Ib. New York State Department of
Health. Tetrachloroethylene Pollution of Resi-
dents Adjacent to Dry Cleaners. Translated from
OffGesundh-Wes., 1989. Translated by Rockland
Technical Services. New York, NY.
NYSDH. 1991c. New York State Department of
Health. Contamination of Foodstuffs by Emis-
sions from Dry Cleaning Establishments. Trans-
lated from Z Lebensm Unters Forsch, 1988.
Translated by Rocklamd Technical Services, New
York. NY.
] -
NYSDH. 199 Id. New York State Department of
Health. Investigations of the Presence of
Tetrachloroethylene in Indoor Air and Food in
Dwellings in the "Vicinity of Dry Cleaning Shops.
Translated from Zbl Hoy... 1989. Translated by
Rockland Technical S<5rvices, New York, NY.
NYSDH. 199 le. New York State Department of
Health. Tetrachloroethylene Exposure in the
Neighborhood of Dry Cleaners. Translated from
OffGesundh-Wes., 1989. Translated by Rockland
Technical Services, N«w York, NY.
NYSDH. 199 If. New York State Department of
Health. Bureau of Trade Substance Assessment.
Investigation of Indoor Atr Contamination in Resi-
dences above Dry Cleaners. Albany, NY. October.
Ontario Ministry of the Environment. 1990a. Hazard-
ous Waste Managemtznt Practices of the Ontario
Dry Cleaning Industry. December.
Ontario Ministry of the Environment 1990b. An Eco-
nomic Study on Improved Management of Dry
Cleaning Industry Wastes, December.
Pfeiffer, M.B. 1992. Cleaned Out: The State is Finally
Moving Against Dry Cleaners for Air Pollution—
But It May Be Too Little Too Late, VHZoge Voice.
January 14.
Rao, V.R. 1992. Noncancer HealthRisksfor Residents
Located in the Vicinity ofDrycleaners. Report sub-
mitted to OPAR (EPA]l and AAAS, August.
301
-------
Selected and Annotated BMographies of Materials
Relnhard. K.. W. Dulson. and M. Exner, n.d. Itwestt-
gattonson Concentrations ofTetrachloroethylene in
Indoor Afr and Food in Residences in the Vicinity of
Dry Cleaning Shops. Institute for Environmental
Research of the Office for Environmental Protec-
tion of the City of Cologne.
Rosengren. L.E.. P. KJellstrand. and K.G. Haglid.
1986. Tetrachloroethylene: Levels of DNA and
S-100 In the Gerbll CNS after Chronic Exposure.
NewvbehaviomLToxicoL andTeratoL 8:201-206.
Rowe, V.K. D.D. McCollister. H.C. Spencer. E.M.
Adams, and D.D. Irish. 1952. Vapor Toxicity of
Tetrachloroethylene for Laboratory Animals and
Human Subjects. Arch. Ind. Hyg. Occup. Med
5:566-579.
Schrelber. J. 1992. New York State Department of
Health. Tetrachloroethene Health Effects. Ab-
stract Booklet for International Roundtable on
Pollution Prevention and Control In the Diydean-
Ing Industry. U.S. EPA/OPPT. May 27-28.
Seeber. A. 1989. Neurobehavloral Toxlcily of Long-
Term Exposure to Tetrachloroethylene. Neurotaxi-
col Teratol 11:579-583.
SRRP, 1990. Source Reduction Research Partnership
(Metropolitan Water District of Southern Califor-
nia/Environmental Defense Fund). Source Re-
duction of Chlorinated Solvents—Dry Cleaning of
Fabrics. Final Draft. June.
Stewart. R.D.. E.D. Baretta. H.C. Dodd. and T.R.
Torkelson. 1970. Experimental Human Exposure
to Tetrachloroethylene. Arch. Environ. Health
20:224-229.
Stewart. R.D.. C.L Hake. A. WU, J. Kaldfldsch. P.E.
Newton. S.K Marloro. and M.V. Salama. 1977.
Effects of Perchloroethytene/Divg Interaction on
Behavior and Neurological Function. Final Report.
National Institute for Occupational Safety and
Health. April.
TRI/Princeton. 1989. Development of Analytical Pro
cedurefor Perchloroethytene Residues 61 Textiles.
Princeton, NJ. January.
Tsuruki. K. and N. Keitaro. 1989. Residual
Tetrachloroethylene in Dry-Cleaned Clothes. En-
vironmentalResearch48:2Q6-301.
Turk, R. 1991. Living Green and Refusing to Dry-
Clean. Los Angeles Times. Saturday, March 9.
Tuttle. T.. C.D. Wood, C.B. Gretlier. B.L. Johnson, and
C. Xintaras. 1977. A Behavioral and Neurological
Evaluation of Dry Cleaners Exposed to Perchlo-
roethylene. Department of Health Education and
Welfare (NIOSH). Pub. No.77-214. Washington,
DC.
United Nations Environment Programme. 1989.
Technical Progress on Protecting the Ozone Layer.
Electronics. Degreasing and Dry Cleaning Sol-
vents Technical Options Report; June.
Van den Berg. J.H. and WJLJ.L. den Otter. 1989.
Test BciweP54OSteam-heatedwithCONSOPBA.
Prepared for B6we Reinigungstechnik GmbH by
histituut voor Reinigungstechnieken TNO. Re-
port, December ;
302
------- |