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. 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" .-, . • .:.-"=•• "•".-' ]• 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 ? 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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 ! 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' 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 -------