&EPA
United States
Agtency
Profile
I
SECTOR
*''''-"
NOTEBOOKS
-------
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 20460
THE ADMINISTRATOR
Message from the Administrator
Over the past 25 years, our nation has made tremendous progress in protecting public health and
our environment while promoting economic prosperity. Businesses as large as iron and steel
plants and businesses as small as the dry cleaner on the corner have worked with EPA to find
ways to operate cleaner, cheaper, and smarter. As a result, we no longer have rivers catching on
fire. Our skies are clearer. American environmental technology and expertise are in demand
throughout the world.
The Clinton Administration recognizes that to continue this progress, we must move beyond the
pollutant-by-pollutant approaches of the past to comprehensive, facility-wide approaches for the
future. Industry by industry and community by community, we must build a new generation of
environmental protection.
Within the past two years, the Environmental Protection Agency undertook its Sector Notebook
Project to compile, for a number of key industries, information about environmental problems and
solutions, case studies and tips about complying with regulations. We called on industry leaders,
state regulators, and EPA staff with many years of experience in these industries and with their
unique environmental issues. Together with notebooks for 17 other industries, the notebook you
hold in your hand is the result.
These notebooks will help business managers to better understand their regulatory requirements,
learn more about how others in their industry have undertaken regulatory compliance and the
innovative methods some have found to prevent pollution in the first instance. These notebooks
will give useful information to state regulatory agencies moving toward industry-based programs.
Across EPA we will use this manual to better integrate our programs and improve our compliance
assistance efforts.
I encourage you to use this notebook to evaluate and improve the way that together we achieve
our important environmental protection goals. I am confident that these notebooks will help us to
move forward in ensuring that — in industry after industry, community after community —
environmental protection and economic prosperity go hand in hand.
Carol M. Brownor
Recycled/Recyclable • Printed with Vegetable Based Inks on Recycled Paper (20% Postconsumer)
-------
Sector Notebook Project
Dry Cleaning
EPA/310-R-95-001
EPA Office of Compliance Sector Notebook Project
Profile of the Dry Cleaning Industry
September 1995
Office of Compliance
Office of Enforcement and Compliance Assurance
U.S. Environmental Protection Agency
401 M St., SW (MC 2221-A)
Washington, DC 20460
For sale by the U.S. Government Printing Office
Superintendent of Documents, Mail Stop: SSOP, Washington, DC 20402-9328
ISBN 0-16-048268-2
September 1995
SIC 7216
-------
Sector Notebook Project
Dry Cleaning
This report is one in a series of volumes published by the U.S. Environmental Protection Agency
(EPA) to provide information of general interest regarding environmental issues associated with
specific industrial sectors. The documents were developed under contract by Abt Associates Inc.
(Cambridge, MA), and Booz-Allen & Hamilton, Inc. (McLean, VA). This publication may be
purchased from the Superintendent of Documents, U.S. Government Printing Office. A listing of
available Sector Notebooks and document numbers is included at the end of this document.
All telephone orders should be directed to:
Superintendent of Documents
U.S. Government Printing Office
Washington, DC 20402
(202) 512-1800
FAX (202) 512-2250
8:00 a.m. to 4:30 p.m., ET, M-F
Using the form provided at the end of this document, all mail orders should be directed to:
U.S. Government Printing Office
P.O. Box 371954
Pittsburgh, PA 15250-7954
Complimentary volumes are available to certain groups or subscribers, such as public and academic
libraries, Federal, State, local, and foreign governments, and the media. For further information, and
for answers to questions pertaining to these documents, please refer to the contact names and
numbers provided within this volume.
Electronic versions of all Sector Notebooks are available on the EPA Enviro$en$e Bulletin Board
and via the Internet on the Enviro$en$e World Wide Web. Downloading procedures are described
in Appendix A of this document.
Cover photograph by Steve Delaney, EPA
September 1995
SIC 7216
-------
Sector Notebook Contacts
The Sector Notebooks were developed by the EPA's Office of Compliance. Particular questions regarding the
Sector Notebook Project in general can be directed to:
Seth Heminway, Sector Notebook Project Coordinator
US EPA, Office of Compliance
401 M St., SW (2223-A)
Washington, DC 20460
(202) 564-7017 fax (202) 564-0050
E-mail: heminway.seth@epamail.epa.gov
Questions and comments regarding the individual documents can be directed to the appropriate specialists listed
below.
Document Number
EPA/310-
EPA/310-
EPA/310-
EPA/310-
EPA/310-
EPA/310-
EPA/310-
EPA/310-
EPA/310-
EPA/310-
EPA/310-
EPA/310-
EPA/310-
EPA/310-
EPA/310-
EPA/310-
EPA/310-
EPA/310-
EPA/310-
EPA/310-
EPA/310-
EPA/310-
EPA/310-
EPA/310-
EPA/310-
EPA/310-
EPA/310-
EPA/310-
•R-95-001.
•R-95-002.
•R-95-003.
.R.95-004.
•R-95-005.
•R-95-006.
•R-95-007.
•R-95-008.
•R-95-009.
•R-95-010.
•R-95-011.
•R-95-012.
•R-95-013.
•R-95-014.
•R-95-015.
•R-95-016.
•R-95-017.
•R-95-018.
•R-97-001.
•R-97-002.
•R-97-003.
.R_97_004.
-R-97-005.
•R-97-006.
-R-97-007.
-R-97-008.
•R-97-009.
•R-97-010.
EPA/310-B-96-003.
Industry
Dry Cleaning Industry
Electronics and Computer Industry
Wood Furniture and Fixtures Industry
Inorganic Chemical Industry
Iron and Steel Industry
Lumber and Wood Products Industry
Fabricated Metal Products Industry
Metal Mining Industry
Motor Vehicle Assembly Industry
Nonferrous Metals Industry
Non-Fuel, Non-Metal Mining Industry
Organic Chemical Industry
Petroleum Refining Industry
Printing Industry
Pulp and Paper Industry
Rubber and Plastic Industry
Stone, Clay, Glass, and Concrete Industry
Transportation Equipment Cleaning Ind.
*Air Transportation Industry
Ground Transportation Industry
* Water Transportation Industry
Metal Casting Industry
Pharmaceutical Industry
Plastic Resin and Man-made Fiber Ind.
*Fossil Fuel Electric Power Generation Ind.
* Shipbuilding and Repair Industry
Textile Industry
* Sector Notebook Data Refresh, 1997
Federal Facilities
Contact
Joyce Chandler
Steve Hoover
Bob Marshall
Walter DeRieux
Maria Malave
Seth Heminway
Scott Throwe
Keith Brown
Suzanne Childress
Jane Engert
Keith Brown
Walter DeRieux
Tom Ripp
Ginger Gotliffe
Maria Eisemann
Maria Malave
Scott Throwe
Virginia Lathrop
Virginia Lathrop
Virginia Lathrop
Virginia Lathrop
Jane Engert
Emily Chow
Sally Sasnett
Rafael Sanchez
Suzanne Childress
Belinda Breidenbach
Seth Heminway
Jim Edwards
Phone (202)
564-7073
564-7007
564-7021
564-7067
564-7027
564-7017
564-7013
564-7124
564-7018
564-5021
564-7124
564-7067
564-7003
564-7072
564-7016
564-7027
564-7013
564-7057
564-7057
564-7057
564-7057
564-5021
564-7071
564-7074
564-7028
564-7018
564-7022
564-7017
564-2461
*Currently in DRAFT anticipated publication in September 1997
This page updated during June 1997 reprinting
-------
Sector Notebook Project
Dry Cleaning
Industry Sector Notebook Contents: Dry Cleaning
EXHffilTS INDEX iv
LIST OF ACRONYMS v
I. INTRODUCTION TO THE SECTOR NOTEBOOK PROJECT 1
A. Summary of the Sector Notebook Project 1
B. Additional Information 2
II. INTRODUCTION TO THE DRY CLEANING INDUSTRY 3
A. Introduction, Background, and Scope of the Notebook 3
B. Characterization of the Dry Cleaning Industry 3
1. Industry size and geographic distribution 4
2. Product characterization 11
3. Economic trends 12
HI. INDUSTRIAL PROCESS DESCRIPTION 13
A. Industrial Processes in the Dry Cleaning Industry 13
B. Raw Material Inputs and Pollution Outputs 24
IV. CHEMICAL RELEASE AND TRANSFER PROFILE 27
A. EPA Toxic Release Inventory for the Dry Cleaning Industry 29
B. Summary of Selected Chemicals Released 30
C. Other Data Sources 31
D. Comparison of Toxic Release Inventory Between Selected Industries 34
V. POLLUTION PREVENTION OPPORTUNITIES 37
A. Pollution Prevention Opportunities for the Dry Cleaning Industry 37
VI. SUMMARY OF APPLICABLE FEDERAL STATUTES AND REGULATIONS 43
A. General Description of Major Statutes 43
B. Industry Specific Regulatory Requirements 54
C. Pending and Proposed Regulatory Requirements 57
September 1995
SIC 7216
-------
Sector Notebook Project
Dry Cleaning
VII. COMPLIANCE AND ENFORCEMENT HISTORY 59
A. Dry Cleaning Industry Compliance History 63
B. Comparison of Enforcement Activity Between Selected Industries 65
C. Review of Major Legal Actions 70
1. Review of major cases 70
2. Supplementary Environmental Projects (SEPs) 70
VHI. COMPLIANCE ASSURANCE ACTIVITIES AND INITIATIVES 71
A. Sector-related Environmental Programs and Activities 71
B. EPA Voluntary Programs 73
C. Trade Association/Industry Sponsored Activity 75
1. Environmental programs 75
2. Summary of trade associations 75
IX. CONTACTS/ACKNOWLEDGMENTS/RESOURCE MATERIALS/BIBLIOGRAPHY 78
APPENDIX A A
September 1995
SIC 7216
-------
Sector Notebook Project
Dry Cleaning
EXHIBITS INDEX
Exhibit 1: Commercial Dry Cleaners Dominate Industry 5
Exhibit 2: Very Small and Very Large Establishments Dominate Commercial Dry Cleaning 6
Exhibit 3: Medium-Sized Establishments Dominate Coin-operated Dry Cleaning and Laundries . . 7
Exhibit 4: Dry Cleaning Facilities (SIC 7216) 8
Exhibits: Geographic Distribution of Dry Cleaning Facilities Corresponds to Population in U.S. . 9
Exhibit 6: Top U.S. Companies with Dry Cleaning Operations 11
Exhibit 7: Number of Dry Cleaning Facilities by Process and Industrial Sector 14
Exhibit 8: Process Flow Diagram for Perchloroethylene Solvent Transfer Dry Cleaning Machines 15
Exhibit 9: Flow Diagram of a Carbon Adsorber 17
Exhibit 10: Flow Diagram of a Refrigerated Condenser 20
Exhibit 11: Process Flow Diagram of Multiprocess Wet Cleaning 22
Exhibit 12: Process Flow Diagram of Machine Wet Cleaning 24
Exhibit 13: Pollution Releases from Dry Cleaning Operations 25
Exhibit 14: Pollutant Releases 32
Exhibit 15: Summary of 1993 TRI Releases and Transfers by Industry 35
Exhibit 16: Toxics Release Inventory Data for Selected Industries 36
Exhibit 17: Five-Year Enforcement and Compliance Summary for Dry Cleaning 64
Exhibit 18: Five-Year Enforcement and Compliance Summary for Selected Industries 66
Exhibit 19: One-Year Inspection and Enforcement Summary for Selected Industries 67
Exhibit 20: Five-Year Inspection and Enforcement Summary by Statute for Selected Industries . . 68
Exhibit 21: One-Year Inspection and Enforcement Summary by Statute for Selected Industries . . 69
September 1995
111
SIC 7216
-------
Sector Notebook Project
Dry Cleaning
LIST OF ACRONYMS
AFS - AIRS Facility Subsystem (CAA database)
AIRS - Aerometric Information Retrieval System (CAA database)
BIFs - Boilers and Industrial Furnaces (RCRA)
BOD - Biochemical Oxygen Demand
CAA - Clean Air Act
CAAA - Clean Air Act Amendments of 1990
CERCLA - Comprehensive Environmental Response, Compensation and Liability Act
CERCLIS - CERCLA Information System
CFCs - Chlorofluorocarbons
CO - Carbon Monoxide
COD Chemical Oxygen Demand
CSI - Common Sense Initiative
CWA - Clean Water Act
D&B - Dun and Bradstreet Marketing Index
ELP - Environmental Leadership Program
EPA - United States Environmental Protection Agency
EPCRA- Emergency Planning and Community Right-to-Know Act
FIFRA - Federal Insecticide, Fungicide, and Rodenticide Act
FINDS - Facility Indexing System
HAPs - Hazardous Air Pollutants (CAA)
HSDB - Hazardous Substances Data Bank
IDEA - Integrated Data for Enforcement Analysis
LDR - Land Disposal Restrictions (RCRA)
LEPCs - Local Emergency Planning Committees
MACT - Maximum Achievable Control Technology (CAA)
MCLGs - Maximum Contaminant Level Goals
MCLs - Maximum Contaminant Levels
MEK - Methyl Ethyl Ketone
MSDSs - Material Safety Data Sheets
NAAQS - National Ambient Air Quality Standards (CAA)
NAFTA - North American Free Trade Agreement
NCDB - National Compliance Database (for TSCA, FIFRA, EPCRA)
NCP - National Oil and Hazardous Substances Pollution Contingency Plan
NEIC - National Enforcement Investigation Center
NESHAP - National Emission Standards for Hazardous Air Pollutants
NO2 - Nitrogen Dioxide
NOV - Notice of Violation
September 1995
IV
SIC 7216
-------
Sector Notebook Project
Dry Cleaning
NOX - Nitrogen Oxides
NPDES - National Pollution Discharge Elimination System (CWA)
NPL - National Priorities List
NRC - National Response Center
NSPS - New Source Performance Standards (CAA)
OAR - Office of Air and Radiation
OECA - Office of Enforcement and Compliance Assurance
OPA - Oil Pollution Act
OPPTS - Office of Prevention, Pesticides, and Toxic Substances
OSHA - Occupational Safety and Health Administration
OSW - Office of Solid Waste
OSWER - Office of Solid Waste and Emergency Response
OW - Office of Water
P2 - Pollution Prevention
PCS - Permit Compliance System (CWA Database)
POTW - Publicly Owned Treatments Works
RCRA - Resource Conservation and Recovery Act
RCRIS - RCRA Information System
SARA - Superfund Amendments and Reauthorization Act
SDWA - Safe Drinking Water Act
SEPs - Supplementary Environmental Projects
SERCs - State Emergency Response Commissions
SIC - Standard Industrial Classification
S02 - Sulfur Dioxide
SOX - Sulfur Oxides
TOC - Total Organic Carbon
TRI - Toxic Release Inventory
TRIS - Toxic Release Inventory System
TCRIS - Toxic Chemical Release Inventory System
TSCA - Toxic Substances Control Act
TSS - Total Suspended Solids
UIC - Underground Injection Control (SDWA)
UST - Underground Storage Tanks (RCRA)
VOCs - Volatile Organic Compounds
September 1995
SIC 7216
-------
Sector Notebook Project
Dry Cleaning
I. INTRODUCTION TO THE SECTOR NOTEBOOK PROJECT
LA. Summary of the Sector Notebook Project
Environmental policies based upon comprehensive analysis of air, water and
land pollution are an inevitable and logical supplement to traditional single-
media approaches to environmental protection. Environmental regulatory
agencies are beginning to embrace comprehensive, multi-statute solutions to
facility permitting, enforcement and compliance assurance, education/
outreach, research, and regulatory development issues. The central concepts
driving the new policy direction are that pollutant releases to each
environmental medium (air, water and land) affect each other, and that
environmental strategies must actively identify and address these inter-
relationships by designing policies for the "whole" facility. One way to
achieve a whole facility focus is to design environmental policies for similar
industrial facilities. By doing so, environmental concerns that are common to
the manufacturing of similar products can be addressed in a comprehensive
manner. Recognition of the need to develop the industrial "sector-based"
approach within the EPA Office of Compliance led to the creation of this
document.
The Sector Notebook Project was initiated by the Office of Compliance within
the Office of Enforcement and Compliance Assurance (OECA) to provide its
staff, and managers with summary information for eighteen specific industrial
sectors. As other EPA offices, states, the regulated community,
environmental groups, and the public became interested in this project, the
scope of the original project was expanded. The ability to design
comprehensive, common sense environmental protection measures for specific
industries is dependent on knowledge of several inter-related topics. For the
purposes of this project, the key elements chosen for inclusion are: general
industry information (economic and geographic); a description of industrial
processes; pollution outputs; pollution prevention opportunities; Federal
statutory and regulatory framework; compliance history; and a description of
partnerships that have been formed between regulatory agencies, the regulated
community and the public.
For any given industry, each topic listed above could alone be the subject of
a lengthy volume. However, in order to produce a manageable document, this
project focuses on providing summary information for each topic. This
format provides the reader with a synopsis of each issue, and references where
more in-depth information is available. Text within each profile was
researched from a variety of sources, and was usually condensed from more
detailed sources pertaining to specific topics. This approach allows for a wide
coverage of activities that can be further explored based upon the citations
and references listed at the end of this profile. As a check on the information
September 1995
SIC 7216
-------
Sector Notebook Project
Dry Cleaning
included, each notebook went through an external review process. The Office
of Compliance appreciates the efforts of all those that participated in this
process and enabled us to develop more complete, accurate and up-to-date
summaries. Many of those who reviewed this notebook are listed as contacts
in Section IX and may be sources of additional information. The individuals
and groups on this list do not necessarily concur with all statements within this
notebook.
I.B. Additional Information
Providing Comments
OECA's Office of Compliance plans to periodically review and update the
notebooks and will make these updates available both in hard copy and
electronically. If you have any comments on the existing notebook, or if you
would like to provide additional information, please send a hard copy and
computer disk to the EPA Office of Compliance, Sector Notebook Project,
401 M St., SW (2223-A), Washington, DC 20460. Comments can also be
uploaded to the Enviro$en$e Bulletin Board or the Enviro$en$e World Wide
Web for general access to all users of the system. Follow instructions in
Appendix A for accessing these data systems. Once you have logged in,
procedures for uploading text are available from the on-line Enviro$en$e Help
System.
Adapting Notebooks to Particular Needs
The scope of the existing notebooks reflect an approximation of the relative
national occurrence of facility types that occur within each sector. In many
instances, industries within specific geographic regions or states may have
unique characteristics that are not fully captured in these profiles. For this
reason, the Office of Compliance encourages state and local environmental
agencies and other groups to supplement or re-package the information
included in this notebook to include more specific industrial and regulatory
information that may be available. Additionally, interested states may want
to supplement the "Summary of Applicable Federal Statutes and Regulations"
section with state and local requirements. Compliance or technical assistance
providers may also want to develop the "Pollution Prevention" section in more
detail. Please contact the appropriate specialist listed on the opening page of
this notebook if your office is interested in assisting us in the further
development of the information or policies addressed within this volume.
If you are interested in assisting in the development of new notebooks for
sectors not covered in the original eighteen, please contact the Office of
Compliance at 202-564-2395.
September 1995
SIC 7216
-------
Sector Notebook Project
Dry Cleaning
H. INTRODUCTION TO THE DRY CLEANING INDUSTRY
This section provides background information on the size, geographic
distribution, employment, production, sales, and economic condition of the
dry cleaning industry. The type of facilities described within the document are
also described in terms of their Standard Industrial Classification (SIC) codes.
Additionally, this section contains a list of the largest companies in terms of
sales.
n.A. Introduction, Background, and Scope of the Notebook
This notebook covers the entire dry cleaning industry which includes three
distinct types of operations: commercial, industrial and coin-operated. The
dry cleaning industry is covered by three Standard Industrial Classification
(SIC) codes, the codes the Department of Commerce uses to track the flow
of goods and services. The commercial sector is included in SIC 7216 (dry
cleaning plants except rug cleaning). Commercial plants typically receive
small quantities of clothes from individuals and usually do not clean furs or
leathers although they offer non-dry cleaning services, such as refreshing
garments. The industrial dry cleaning sector is included in SIC code 7218
(industrial launderers). According to the 1987 Census of Service Industries,
there are 1,379 industrial laundry facilities. Of these, the Agency estimates
that 325 have dry cleaning capacity (USEPA, 1993 a) while the remainder are
exclusively wet laundries. Industrial dry cleaners primarily clean uniforms and
may also rent uniforms and other industrial clothing such as gloves. Coin-
operated dry cleaning is included in SIC 7215 (coin-operated laundries and
dry cleaning). The Census of Service Industries indicates that there are
27,180 coin-operated laundries (with and without payroll) in 1987. Of these,
the Agency estimated that about 3,000 offer dry cleaning services of some
kind (USEPA, 1993 a) although some estimate that there are fewer than 100
of such cleaners in operation. Coin-operated dry cleaners may be self-service
units located in laundromats or may be run by an attendant but located in a
self-service laundromat.
n.B. Characterization of the Dry Cleaning Industry
The dry cleaning industry provides garment cleaning services and in most
cases will provide related services such as clothes pressing and finishing. The
dry cleaning process is physically very similar to the home laundry process,
except that clothes are washed in dry cleaning solvent instead of water.
Fabric or garment cleaning consists of three basic functions: cleaning, drying
and finishing. Garments are pre-treated for stains, and then machine washed
in a solution of a solvent, soaps and detergents. The solvent is extracted by
first draining, and then spinning the clothes. Finally, the garments are dried
September 1995
SIC 7216
-------
Sector Notebook Project
Dry Cleaning
through a combination of aeration, heat and tumbling, and then they are
pressed.
These functions are the core of any fabric cleaning process, although the
details vary and steps may be minimized or even omitted. All three functions
are readily recognizable in the full-service dry cleaning process. Dry cleaners
will also "refresh" a garment, concentrating mainly on finishing.
II.B.l. Industry size and geographic distribution
The number and size of dry cleaning firms varies within the three basic
categories of dry cleaning operations. The commercial facilities are by far the
most prevalent and include full service, retail operations located in shopping
centers and near densely populated areas. The industrial dry cleaners operate
the largest facilities which are often part of a business that rents uniforms,
towels or other garments. The coin-operated sector of the market is typically
associated with a laundromat that may provide either full-service retail dry
cleaning similar to the commercial sector, or customer operated dry cleaning
equipment. All sectors, however, provide a single basic service, clothes
cleaning.
Commercial dry cleaning accounts for the majority of the firms with 30,494
facilities, as well as the majority of dry cleaning volume, 630,520 tons of
clothes per year as shown in the exhibit below. The average commercial
facility cleans approximately 19.7 tons of clothes per year. Industrial facilities
while fewer in number, 325, have a larger average cleaning output of 578 tons
of clothes per facility per year. Total dry cleaning volume of the industry
sector is 187,991 tons per year. The coin-operated sector accounts for the
smallest portion of the industry with 3,044 facilities processing 4,914 tons of
clothes per year for an average 1.6 tons per facility.
September 1995
SIC 7216
-------
Sector Notebook Project
Dry Cleaning
Exhibit 1: Commercial Dry Cleaners Dominate Industry
# of Facilities3
Volume of Clothes
Cleaned0
(Tons/Year)
Mean Output per
Facility11
(Tons/year)
Sales6
Commercial
30,494
630,520
19.7
$4.8 billion
Industrial
325
187,991
578
$385 million
Coin- Operated
3,044"
4,914
1.6
$29 million
Total
33,863
825,425
not applicable
$5.2 billion
a USEPA, 1991b
b The number of coin-operated dry cleaning facilities estimated in USEPA, 1 99 1 b is high compared to a more
recent estimate of <100 (Torp, 1994).
c Estimated values based on USEPA, 1 99 la and USEPA, 1 99 Ib.
d Volume/Number of facilities.
e USEPA, 1991b, some values were rounded (1993 dollars). Values indexed from 1989 dollars using the CPI for
Apparel and Upkeep.
The size of dry cleaners varies by industrial sector. Most commercial dry
cleaners are single facility "mom and pop" operations, although there is
considerable variation in the size of these businesses. Classic family-owned-
and-operated commercial cleaners typically have two or three full-time
employees (including the owner) and perhaps some additional part-time
employees. A typical firm might consist of a single small store front
operation, with customer pickup and delivery in the front, and cleaning and
finishing in the back. The store usually has one or two dry cleaning units
(either a separate washer and dryer, or a combined "dry-to-dry" machine), and
perhaps a water-based laundry machine for shirts and other washables.
Commercial dry cleaning is not a high profit business, and many dry cleaners
are barely able to stay in business. Typical start-up costs in 1993 were
$113,000, and over 60 percent of dry cleaners had annual revenues below
$113,000; however, there is wide variation in the receipts. Official Census
figures indicate one-quarter of the firms had annual revenues which were less
than $28,000, and six percent had receipts over $564,000 in 1993 dollars
(USEPA, 1991). The exhibit below shows the revenue distribution for
commercial dry cleaners. The receipts must cover labor costs (by far the
largest cost category), rent, capital depreciation, solvent and other supplies.
Wages are typically low; the industry average operator wage is less than $7.00
September 1995
SIC 7216
-------
Sector Notebook Project
Dry Cleaning
per hour. Many dry cleaners have difficulty paying competitive wages and
earning any profit.
Exhibit 2: Very Small and Very Large Establishments
Dominate Commercial Dry Cleaning (1993 dollars)
Annual Receipts
($/year) per
Establishments
0-28,000
28,000-56,000
56,000-85,000
85,000-113,000-
>1 13,000
Total
Number of
Establishments
8,026
5,024
3,096
3,096
11,251
30,494
Percent
26% .
17%
10%
10%
37%
100%
Total Annual
Receipts
($l,000/year)
160,474
229,611
233,950
327,530
3,857,651
4,809,217
Percent
53%
5%
5%
7%
80%
100%
Source: USEPA, 1993a
Coin-operated dry cleaners are gradually being phased out of the dry cleaning
market. New coin-operated equipment is reported to be no longer available
on the market (SRRP, 1990). The coin-operated segment of the dry cleaning
industry resides in laundromats. There are two basic types of operations,
including: commercial dry cleaners operating a laundromat and self-service
dry cleaning operations. Commercial dry cleaners operating at a laundromat
are classified as coin-operated because the dominant business at the location
is the coin-operated laundromat. The dry cleaning side of the business can be
fully staffed and provide the full services of a commercial dry cleaner.
Alternatively, it can provide more limited service, with an operator receiving,
cleaning, and returning batches of clothes to the customer, but not providing
pressing, spotting or other services. The second type of coin-operated dry
cleaning facility is the self-serve dry cleaning machine. These are truly coin-
operated, with the customer operating the dry cleaning equipment. The
exhibit below shows the total dry cleaning output and the average output per
establishment as categorized by the coin-operated sector income. Comparing
the total coin-operated dry cleaning sales from the first exhibit to total coin-
operated sales below, shows that dry cleaning makes up only about 10 percent
of the receipts in this sector, a much smaller fraction than for commercial or
industrial laundries (USEPA, 1993 a).
September 1995
SIC 7216
-------
Sector Notebook Project
Dry Cleaning
Exhibit 3: Medium-Sized Establishments Dominate
Coin-operated Dry Cleaning and Laundries
(1993 dollars)3
Annual Receipts
($/year) per
Establishment
0-28,000
28,000-56,000
56,000-85,000
85,000-113,000
>113,000
Total
Number of
Establishments'5
523
1,451
475
169
426
3,044
Percent
17%
48%
16%
5%
14%
100%
Total Annual
Receipts
($l,000/yr)
10,425
66,180
35,888
17,664
158,468
288,627
Percent
4%
23%
12%
6%
55%
100%
a Based on payroll converted to 1993 dollars using the CPI for Apparel and Upkeep.
The distribution of establishments is based on the distribution of all coin-operated laundries
with payroll (including those without dry cleaning capacity) reported in the 1987 Census of
Service Industries.
Source: U.S. Environmental Protection Agency. 1993a. Economic Analysis of Regulatory
Controls in the Dry Cleaning Industry. Final. EPA 450/3 -91 -02 Ib. September.
Industrial dry cleaners tend to be larger than commercial establishments. They
service institutional, professional and industrial customers by providing
cleaning services for uniforms, restaurant linens, wiping towels, floor mats and
work gloves. In many cases industrial dry cleaning firms offer rental as well
as cleaning services. According to Census data, 1,379 industrial laundry
facilities were operating in 1987 of which 325 were estimated to have dry
cleaning operations. While sales for all operations at these facilities totaled
$1.1 billion, only about 35 percent ($385 million) of the receipts were related
to dry cleaning. The balance of receipts were from water washing or other
activities (USEPA, 1993 a).
Dry cleaners are spread throughout the United States although their location
depends on both the type of operation and the solvent used. Commercial dry
cleaners are distributed in a six to one ratio of urban to rural as a result of the
greater demand for dry cleaning in urban settings. Their distribution roughly
follows the population as shown in the exhibit below. Industrial laundries,
however, tend to be located in medium to small cities to take advantage of the
lower capital and labor costs. Industrial laundries are also less reliant upon
being in their customer's immediate neighborhood. Coin-operated laundries
tend to be in rural areas where commercial dry cleaning is not available. The
September 1995
SIC 7216
-------
Sector Notebook Project
Dry Cleaning
type of solvent used for dry cleaning also varies by geographic region.
Petroleum dry cleaners are concentrated in the Gulf states, particularly Texas
and Louisiana, partly due to the availability of petroleum in these locations
and partly because local fire regulations prohibit petroleum cleaners in many
other regions.
Exhibit 4: Dry Cleaning Facilities (SIC 7216)
Number of Drycleanmg
Establishments
I-H 100 to 300
300 to 600
600 to 1,000
> 1,000
Miles
=•1
0 100 200 300 400
Source: 1992 Census of Service Industries, Geographic Area Series
September 1995
SIC 7216
-------
Sector Notebook Project
Dry Cleaning
Exhibit 5: Geographic Distribution of Dry Cleaning Facilities
Corresponds to Population in U.S.
State
California
New York
Texas
Florida
Illinois
New Jersey
Ohio
Pennsylvania
Georgia
Michigan
Virginia
North Carolina
Massachusetts
Maryland
Missouri
Indiana
Washington
Tennessee
Alabama
Colorado
Louisiana
Connecticut
South Carolina
Kentucky
Minnesota
Arizona
Oklahoma
Wisconsin
Arkansas
Mississippi
Oregon
Percent of
Facilities3
11.8
8.9
7.9
5.8
4.5
4.1
3.9
3.8
3.5
3.2
3.0
2.9
2.6
2.1
2.0
2.0
1.9
1.9
1.8
1.8
1.6
1.5
1.5
1.3
1.3
1.2
1.2
1.2
1.0
1.0
0.9
Receipts
($1,000)
629,747
346,412
448,292
273,109
231,475
186,588
208,832
196,682
161,054
161,270
165,446
172,653
136,666
107,265
98,485
102,078
79,471
110,116
93,949
77,212
80,484
90,111
78,297
61,293
72,772
73,290
70,665
63,964
45,053
46,756
40,728
Facilities
Rank
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
Population
Rank
1
2
3
4
6
9
7
5
11
8
12
10
13
19
15
14
18
17
22
26
21
27
25
23
20
24
28
16
33
31
29
1990 Pop.
(l,000)b
29,760
17,990
16,987
12,938
11,431
7,730
10,847
11,881
6,478
9,295
6,187
6,628
6,016
4,781
5,117
5,544
4,867
4,877
4,041
3,294
4,345
3,287
3,487
3,685
4,375
3,665
3,146
4,891
2,351
2,573
2,842
September 1995
SIC 7216
-------
Sector Notebook Project
Dry Cleaning
State
Kansas
Iowa
Utah
Nevada
New Mexico
Nebraska
West Virginia
Rhode Island
D.C.
New Hampshire
Idaho
Delaware
Montana
Maine
Hawaii
Vermont
South Dakota
North Dakota
Wyoming
Alaska
Total
Percent of
Facilities3
0.9
0.8
0.6
0.5
0.5
0.4
0.4
0.3
0.3
0.3
0.3
0.2
0.2
0.2
0.2
0.2
0.2
0.2
0.1
0.1
100
Receipts
($1,000)
41,941
36,487
26,191
34,118
22,225
22,339
19,301
17,081
13,898
17,519
12,558
13,530
6,576
9,623
21,141
7,680
4,481
8,280
4,168
17,679
5,069,031
Facilities
Rank
32
33
34
35
36
37
38
39
40
41
42
43
44
45
46
47
48
49
50
51
Population
Rank
32
30
35
39
37
36
34
43
48
40
42
46
44
38
41
49
45
47
51
52
1990 Pop.
(l,000)b
2,478
2,777
1,723
1,202
1,515
1,578
1,793
1,003
607
1,109
1,007
666
799
1,228
1,108
563
696
639
454
550
248,710
* Number of facilities comes from the 1992 Census of Service Industries. Drycleaning plants, except rug cleaning (SIC
7216).
b Populations are from 1990 Census, Summary Population and Housing Characteristics, Table I: US Summary. Total
may vary due to rounding.
Ward's Business Directory of U.S. Private and Public Companies, produced
by Gale Research Inc., compiles financial data on U.S. companies including
those operating within the dry cleaning industry. Ward's ranks U.S.
companies, whether they are a parent company, subsidiary or division, by sales
volume within the 4-digit SIC codes that they have been assigned as their
primary activity. Readers should note that: 1) companies are assigned a 4-
digit SIC that most closely resembles their principal industry; and 2) sales
figures include total company sales, including subsidiaries and operations not
related to dry cleaning. Additional sources of company specific financial
September 1995
10
SIC 7216
-------
Sector ISiotebook Project
Dry Cleaning
information include Standard & Poor's Stock Report Services, Dun &
Bradstreet's Million Dollar Directory, Moody's Manuals, and annual reports.
Exhibit 6: Top U.S. Companies with Dry Cleaning Operations
Rank"
1
2
3
4
5
6
7
8
9
10
Company"
Initial USA, Inc. - Atlanta, GA
Concord Custom Cleaners - Richmond, KY
Dryclean USA, Inc. - Miami, FL
Pride Cleaners, Inc. - Leawood, KS
Fashion Care, Inc. - Atlanta, GA
Spic and Span, Inc. - Milwaukee, WI
Al Phillips the Cleaner, Inc. - Las Vegas, NV
Admiral, Inc. - Annapolis, MD
Walker, Inc. - Omaha, NE
WH Christian and Sons, Inc. - Brooklyn, NY
1993 Sales
(millions of dollars)
170
25
25
16
10
10
8
7
3
3
Note: a When Ward's Business Directory lists both a parent and subsidiary in the top ten, only
the parent company is presented above to avoid double counting. Not all sales can be
attributed to the companies dry cleaning operations.
b Companies shown listed SIC 7216 as primary activity.
Source: Ward's Business Directory of U.S. Private and Public Companies - 1993.
II.B.2. Product characterization
The dry cleaner's product is the service of cleaning clothes conveniently. The
products may also include services such as pressing and finishing. The market
is divided into two parts, those customers who shop for price and will accept
adequate quality and those who are buying quality cleaning with price being
less of a concern. The latter are more steady dry cleaning customers while the
former will forego dry cleaning during financial downturns.
September 1995
11
SIC 7216
-------
Sector Notebook Project
Dry Cleaning
II.B.3. Economic trends
In 1992, the total dry cleaning market generated $5.2 billion in revenues, with
$4.8 billion generated by the commercial sector and $385 million and $29
million generated by the industrial and coin-operated sectors respectively.
Current industry estimates indicate a zero growth rate for the commercial
sector through 1996 while both the industrial and coin-operated sectors are
anticipated to continue their decline during this period. More clothes are
being made of launderable fabrics which reduces the demand for commercial
dry cleaning. Self-service coin-operated dry cleaning machines are no longer
manufactured and those currently in use are being phased out as they age.
The trend toward launderable fabrics will inevitably reduce the need for
industrial dry cleaning as well.
Convenience is the driving force in commercial dry cleaning. Location near
the consumer and fast turnaround on their clothes as well as the cleanliness of
the item are important to dry cleaning success. Consumers care little about
what solvent is used to clean their clothes as long as the cleaning service is
convenient, fast and effective. While the switch to launderable fabrics reduces
the need for dry cleaning, the other services such as laundering, pressing and
finishing may still be in demand.
September 1995
12
SIC 7216
-------
Sector Notebook Project
Dry Cleaning
HI. INDUSTRIAL PROCESS DESCRIPTION
This section describes the major industrial processes within the dry cleaning
industry, including the materials and equipment used, and the processes
employed. The section is designed for those interested in gaining a general
understanding of the industry, and for those interested in the inter-relationship
between the industrial process and the topics described in subsequent sections
of this profile — pollutant outputs, pollution prevention opportunities, and
Federal regulations. This section does not attempt to replicate published
engineering information that is available for this industry. Refer to Section IX
for a list of reference documents that are available.
This section specifically contains a description of commonly used production
processes, associated raw materials, the byproducts produced or released, and
the materials either recycled or transferred off-site. This discussion, coupled
with schematic drawings of the identified processes, provide a concise
description of where wastes may be produced in the process. This section
also describes the potential fate (via air, water, and soil pathways) of these
waste products.
in.A. Industrial Processes in the Dry Cleaning Industry
Dry cleaning processes garments in a way that avoids saturating fabrics with
water. If thoroughly saturated with water, agitated and heated, certain fabrics
(especially wool, silk and rayon) may shrink or the dye may run. Other
garments that are constructed from several materials can be damaged if the
various layers react differently to the cleaning process. Because dry cleaning
solvents do not saturate the fibers of the fabric, the swelling and shrinking
from water saturation is avoided, allowing nearly all types of fabrics and
garments to be safely dry cleaned.
Four solvents dominate the dry cleaning market: perchloroethylene (PCE),
petroleum solvents, chlorofluorocarbons (CFC-113) and trichloroethane
(TCA). The manufacture of the latter two will be banned in 1995 under the
Clean Air Act Amendments. The exhibit below shows that PCE dominates
the commercial sector while petroleum solvent is used in the majority of
industrial machines.
One important characteristic of the dry cleaning industry is that the machinery
used with these solvents has evolved over time. The development
encompasses four "generations" of machines, all of which are still in use. The
first generation of equipment has separate washers and dryers, thus the
operator must transfer the clothes between the two. The second generation
machine design eliminates the stand-alone dryer and combines both washing
and drying into a single machine. The third generation of equipment includes
September 1995
13
SIC 7216
-------
Sector Notebook Project
Dry Cleaning
added control technology to reduce the vapor emissions. The fourth
generation of machine design modifies the third generation by recycling the
air in the machine to further reduce emissions. Each generation is described
further below.
Exhibit 7: Number of Dry Cleaning Facilities
by Process and Industrial Sector3
Process Solvent
PCE
Petroleum
CFC-113
Trichloroethane
Total
Industrial Sector
Commercial
24,947
4,548"
949"
50°
30,494
Industrial
130
195
0
0
325
Coin-operated
3,044
0
0
0
3,044
Total
28,121
4,743
949
50
33,863
" USEPA, 1991b, unless otherwise indicated.
b Estimate based on USEPA, 1991a.
c Wolf, 1992.
First Generation Machines
The first generation of dry cleaning machines had separate washers and
dryers. These transfer machines (so-called because the wet clothes were
transferred from the washer to the dryer) were the predominant type of
machine used until the late-1960s, when dry-to-dry machines were developed
that reduced solvent loss and improved dry cleaning economics. In a typical
transfer process, the clothes are loaded into the washer, where the solvent is
combined with a water and detergent charge, and the clothes and solvent are
agitated by rotation of the washer's drum. After washing, the drum is rotated
at high speeds to extract the residual solvent. The clothes are then manually
transferred to a dryer where recirculating warm air causes most of the
remaining solvent to vaporize. To reduce wrinkling, the drying cycle is
followed by a brief cool-down cycle during which unheated air is circulated
through the clothes (USEPA, 1991). A flow diagram for a typical PCE
transfer machine is shown below. The advantages of using transfer equipment
are: (a) more production since a new load is being washed while the previous
one is being dried; (b) less complicated construction with less automation and
thus greater ease of repair; and (c) reduction of fabric damage since the
cylinder remains cool after the prior load is removed. The disadvantages are:
September 1995
14
SIC 7216
-------
Sector Notebook Project
Dry Cleaning
(a) the additional labor required to handle the heavy volume; (b) the solvent
vapors that escape to the atmosphere during transfer; (c) exposure of the
worker to the solvent; and (d) the garments that can fall on the floor during
transfer. Currently, about 34 percent of dry cleaning machines in the U.S. are
transfer units (Brown, 1993). However, the National Emissions Standards for
Hazardous Air Pollutants (NESHAP) for PCE dry cleaning facilities will not
allow new transfer machines that use PCE (USEPA, 1993b). Transfer
machines cannot be converted to dry-to-dry machines, but they can be
retrofitted with vapor control devices and with impermeable enclosures to
capture fugitive emissions. Two technologies that can capture the solvent that
escapes during clothing transfer are hamper enclosure and room enclosures.
Hamper enclosures consist of a hood or canopy usually made of polyethylene
— impervious plastic that encloses the clothing hamper and the open door of
the washer when clothing is removed from the washer of a transfer machine
and placed in the dryer. The same canopy is used when transferring the
clothes from the hamper to the dryer (Environmental Reporter, 1992).
Room enclosures usually consist of a metal frame covered with clear
impervious plastic that encloses both the washer and dryer of a transfer
machine. During clothing transfer, a fan is turned on to draw air from outside
the room enclosure through louvered door openings in the enclosure and then
to a vapor emission control device.
September 1995
15
SIC 7216
-------
Sector Notebook Project
Dry Cleaning
Exhibit 8: Process Flow Diagram for Perchloroethylene Solvent
Transfer Dry Cleaning Machines
Source: Adapted from USEP A, 1991b
Second Generation Machines
Transfer units were used exclusively until the late 1960s, when a second
generation of equipment was introduced to reduce the amount of space the
machines occupied and to decrease solvent consumption. Called "dry-to-dry"
machines, these units integrate the washing and drying into the same unit.
This saves space, requires less labor (because the operator does not have to
transfer garments), reduces the amount of solvent vapor that escapes, lowers
worker exposure to solvent vapor, and generates a higher solvent mileage (the
quantity of solvent needed to clean a quantity of clothes). The disadvantages
are lower production and less flexibility, since each machine is committed to
a single load during its entire wash-dry cycle. Dry-to-dry machines currently
comprise 66 percent of the units used in the U.S. (Brown, 1993). Of these,
32 percent are the vented units (2nd generation machines) that are designed
September 1995
16
SIC 7216
-------
Sector Notebook Project
Dry Cleaning
to send residual vapors to the atmosphere or an external control device
(Brown, 1993). The remainder are third or fourth generation machines as
described below. Second generation machines can be retrofitted with control
devices such as carbon adsorbers (not allowed under current regulations) and
refrigerated condensers.
Carbon adsorbers recover solvent by sending contaminated air through a bed
of activated carbon that then adsorbs3 the solvent vapors as shown below.
The adsorbed solvent is recovered by passing low-pressure steam (new
designs use hot air) through the carbon bed. The mixed steam and solvent
vapors are then passed through a water-cooled condenser and are collected
in a phase separator.13 The carbon is dried and reused while the recovered
solvent is returned to the dry cleaning system (SKRP, 1990). Carbon
adsorbers can be retrofitted to both dry-to-dry and transfer machines. In tests
of carbon adsorbers, the removal efficiencies were above 95 percent (USEPA,
1991). However, subsequent data from the California Air Resources Board
led the Agency to believe that in actual practice the removal efficiencies are
much lower. As a result, the NESHAP does not allow them as an option for
primary control except in certain large facilities where carbon adsorbers were
installed prior to the promulgation of the regulation, September 22, 1993.
a The system will hold molecules on its surface (adsorb) and then release them (desorb) when steam is passed through
the bed.
b PCE and water are reasonably insoluble in the liquid phase. The cooled PCE/water mixture will enter the phase
separator where two layers will form. The PCE will then be drawn off for recycling.
September 1995
17
SIC 7216
-------
Sector Notebook Project
Dry Cleaning
Solvent Vapor-laden
Air "IN"
Condenser
Waste Water
Solvent to
Storage
Water
Separator
Pneumatic Dampers
Steam
ADSORPTION CYCLE
DESORPTION CYCLE
Source: USEPA 1991a
Exhibit 9: Flow Diagram of a Carbon Adsorber
Refrigerated condensers have both an advantage and a disadvantage when
compared to carbon adsorbers. They require less maintenance because the
refrigerant only needs to be replaced yearly while carbon adsorbers must be
desorbed daily.0 The disadvantage of refrigerated condensers compared to
carbon adsorbers is that they cannot be used to control low concentration
emission streams (USEPA, 199la).
c The desorption of solvent is accomplished by passing steam (or hot air) through the carbon bed.
September 1995
18
SIC 7216
-------
Sector Notebook Project
Dry Cleaning
Refrigerated condensers remove vapors from the exhaust stream by cooling
them to below their dew points. Most new machines have built-in refrigerated
condensers, but the condensers can be retrofitted to both transfer and dry-to-
dry machines (USEPA, 199la). Refrigerated condensers achieve about 95
percent control of HAPs when compared to uncontrolled machines (Smith,
1995). The figure below shows a typical refrigerated condenser that can
accommodate two HAP (hazardous air pollutant such as PCE)-laden streams.
In transfer machines, a stream (Stream A) from the exhaust fan used when the
washer door is opened will feed through the condenser and be vented (Stream
B) and a stream from the dryer (Stream C) passes through the condenser, and
after separation and recovery of the solvent returns the air stream to the dryer
(Stream D). Dry-to-dry machines only have the second stream. In transfer
machines, the exhaust vapors from the washer are vented (in one pass)
through the condenser to the atmosphere, and thus the system can achieve
only about 85 percent control of HAPs compared to an uncontrolled machine
(USEPA, 1991a).
September 1995
19
SIC 7216
-------
Sector Notebook Project
Dry Cleaning
Exhibit 10: Flow Diagram of a Refrigerated Condenser
Solvent-Laden Vapors
from Washer
Solvent-Laden
Vapors from
Dryer
D
Refrigerated
Condensing
Coils
Stream A = Solvent-laden vapors
from washer open door cycle.
Stream B = Open door cycle
emissions vented after one
pass through condenser.
Stream C = Solvent-laden vapors
from dryer.
Stream D = Air stream returned
to dryer after solvent separation
and recovery.
A refrigerated condenser as applied to a
transfer dry cleaning machine.
Source: USEPA 199la
September 1995
20
SIC 7216
-------
Sector Notebook Project
Dry Cleaning
Third Generation Machines
The third generation of machines that were designed in the late 1970s and
early 1980s are dry-to-dry with built-in refrigerated condensers. These are
closed loop machines. A closed-loop machine does not vent air to the
atmosphere but recycles it continuously throughout the dry cleaning cycle.
The only air exchange with the atmosphere occurs during loading and
unloading. Thirty-four percent of the machines currently in use in the U.S.
are of this design (Brown, 1993). The advantage is a single unit that will
release smaller amounts of vapor. The disadvantage is the greater
complexity of machine design which could lead to higher maintenance costs
and more frequent breakdowns. The principles of operation are the same
as for the second generation machines that use refrigerated condensers.
Fourth Generation Machines
The fourth generation machine is a non-vented, closed loop process with an
additional internal vapor recovery device. The control technologies used
in these machines are refrigerated condensers and carbon adsorbers. In
non-vented, closed loop machines, refrigerated condensers can match
carbon adsorber's 95 percent control efficiency (USEPA, 199la).
Technological Trends
The recent technological trends have been to increase mileage and to reduce
emissions. The increased mileage decreases solvent costs for the facility while
the reduced emissions are driven by both environmental and worker
protection laws. In September, 1993 the Agency promulgated a National
Emission Standard for Hazardous Air Pollutants (NESHAP) for
Perchloroethylene Dry Cleaners. These regulations require both existing and
new facilities that meet certain size requirements to use designated vapor
control technologies and undertake leak detection and equipment repair to
prevent fugitive emissions. Occupational Safety and Health Act regulations
have imposed limits on worker exposure to perchloroethylene which has led
to machine designs that reduce emissions from opening the door after
operation. For petroleum solvents the trend has been towards development
of solvents with higher flash points to reduce the explosion potential and to
solvents with lower volatile organic compound content to reduce VOC
emissions.
One of the most important current developments in the industry is the
commercialization of aqueous alternatives for a portion of the clothes
currently dry cleaned. Multi-process wet cleaning is a method of hand
cleaning clothes using a controlled application of water. It is called "multi-
September 1995
21
SIC 7216
-------
Sector Notebook Project
Dry Cleaning
process" because a number of different steps can be included in the process
depending upon the fabric type and the soil and stains on the garment. A
cleaning technician inspects incoming garments for the degree of soiling and
based on that and the fiber type a cleaning process is chosen. The process
could be spotting, localized steaming, hand washing or machine washing. A
flow diagram of multi-process wet cleaning is shown below. The second
aqueous alternative is machine wet cleaning. This process uses a specially
designed washing machine that reduces the agitation the clothes are subject
to in a traditional laundering process and adds proprietary chemicals (that
satisfy the German environmental regulations) to reduce fiber swelling. These
machines have been used profitably in Europe (primarily Germany) and are
now being introduced into the U.S. market by several manufacturers. The
process is diagramed below. The critical test for market acceptance will be
the percent of the current U.S. dry cleaning clothes stream that these
processes can clean effectively without damaging the garments. Two firms
in New York City currently are using a combination of the two aqueous
processes and report eighty percent repeat business.
September 1995
22
SIC 7216
-------
Sector Notebook Project
Dry Oeaning
Exhibit 11; Process Flow Diagram of Multiprocess Wet Cleaning
Water
Spot & Stain
Remover
Cleaner &
Degreaser
Conventional Solvents (e.g. amyl
acetate, oxalic acid, peroxide,
sodium perborate, ammonia)
Source: Developed for USEPA Office of Pollution Prevention and Toxics' Design for the Environment Program.
September 1995
23
SIC 7216
-------
Sector Notebook Project
Dry Cleaning
Exhibit 12: Process Flow Diagram of Machine Wet Cleaning
Source: Developed for the USEPA Office of Pollution Prevention and Toxics' Design for the Environment Program.
HI.B. Raw Material Inputs and Pollution Outputs
The primary dry cleaning releases are to air (through both fugitive emissions
and direct release at the end of the cycle), water (from water that was
contained in the clothes and from regenerating carbon adsorbers) and solid
waste (such as the muck from stills used to evaporate solvent-contaminated
water, the residue remaining after contaminated solvent is filtered, and the
carbon from an adsorber). There is an active recycling market for solvent
recovered from dry cleaning facilities, although the overall percentage of
solvent recovered is not known.
September 1995
24
SIC 7216
-------
Sector Notebook Project
Dry Cleaning
Exhibit 13: Pollution Releases from Dry Cleaning Operations
Release Medium
Air
Water
Hazardous/Solid Waste
Emissions
Solvent spills
Fugitive leaks from piping
Vapor released with transferring or
from machines
Vapor release from clothes dryers
Residual vapor release from clothes
removed from the dryer
removing clothes
after they are
Water from separator
Residue from solvent still
Filters
September 1995
25
SIC 7216
-------
-------
Sector Notebook Project
Dry Cleaning
IV. CHEMICAL RELEASE AND TRANSFER PROFILE
This section is designed to provide background information on the pollutant
releases that are reported by this industry. The best source of comparative
pollutant release information is the Toxic Release Inventory System (TRI).
Pursuant to the Emergency Planning and Community Right-to-Know Act,
TRI includes self-reported facility release and transfer data for over 600 toxic
chemicals. Facilities within SIC Codes 20-39 (manufacturing industries) that
have more than 10 employees, and that are above weight-based reporting
thresholds are required to report TRI on-site releases and off-site transfers.
The information presented within the sector notebooks is derived from the
most recently available (1993) TRI reporting year (which then included 316
chemicals), and focuses primarily on the on-site releases reported by each
sector. Because TRI requires consistent reporting regardless of sector, it is
an excellent tool for drawing comparisons across industries.
Although this sector notebook does not present historical information
regarding TRI chemical releases over time, please note that in general, toxic
chemical releases have been declining. In fact, according to the 1993 Toxic
Release Inventory Data Book, reported releases dropped by 42.7 percent
between 1988 and 1993. Although on-site releases have decreased, the total
amount of reported toxic waste has not declined because the amount of toxic
chemicals transferred off-site has increased. Transfers have increased from
3.7 billion pounds in 1991 to 4.7 billion pounds in 1993. Better management
practices have led to increases in off-site transfers of toxic chemicals for
recycling. More detailed information can be obtained from EPA's annual
Toxics Release Inventory Public Data Release book (which is available
through the EPCRA Hotline at 800-535-0202), or directly from the Toxic
Release Inventory System database. (For user support call 202-260-1531)
Wherever possible, the sector notebooks present TRI data as the primary
indicator of chemical release within each industrial category. TRI data
provide the type, amount and media receptor of each chemical released or
transferred. When other sources of pollutant release data have been obtained,
these data have been included to augment the TRI information.
TRI Data Limitations
The reader should keep in mind the following limitations regarding TRI data.
Within some sectors, the majority of facilities are not subject to TRI reporting
because they are not considered manufacturing industries, or because they are
below TRI reporting thresholds. Examples are the mining, dry cleaning,
printing, and transportation equipment cleaning sectors. For these sectors,
release information from other sources has been included.
September 1995
27
SIC 7216
-------
Sector Notebook Project
Dry Cleaning
The reader should also be aware that TRI "pounds released" data presented
within the notebooks is not equivalent to a "risk" ranking for each industry.
Weighting each pound of release equally does not factor in the relative
toxicity of each chemical that is released. The Agency is in the process of
developing an approach to assign lexicological weights to each chemical
released so that one can differentiate between pollutants with significant
differences in toxicity. As a preliminary indicator of the environmental impact
of the industry's most commonly released chemicals, the notebook briefly
summarizes the toxicological properties of the top five chemicals (by weight)
reported by each industry.
Definitions Associated With Section IV Data Tables
General Definitions
SIC Code ~ is the Standard Industrial Classification (SIC) is a statistical
classification standard used for all establishment-based Federal economic
statistics. The SIC codes facilitate comparisons between facility and industry
data.
TRI Facilities -- are manufacturing facilities that have 10 or more full-time
employees and are above established chemical throughput thresholds.
Manufacturing facilities are defined as facilities in Standard Industrial
Classification primary codes 20 through 39. Facilities must submit estimates
for all chemicals that are on the EPA's defined list and are above throughput
thresholds.
Data Table Column Heading Definitions
The following definitions are based upon standard definitions developed by
EPA's Toxic Release Inventory Program. The categories below represent the
possible pollutant destinations that can be reported.
RELEASES — are an on-site discharge of a toxic chemical to the
environment. This includes emissions to the air, discharges to bodies of
water, releases at the facility to land, as well as contained disposal into
underground injection wells.
Releases to Air (Point and Fugitive Air Emissions) ~ Include all air
emissions from industry activity. Point emission occur through confined air
streams as found in stacks, ducts, or pipes. Fugitive emissions include losses
from equipment leaks, or evaporative losses from impoundments, spills, or
leaks.
September 1995
28
SIC 7216
-------
Sector Notebook Project
Dry Cleaning
Releases to Water (Surface Water Discharges) — encompass any releases
going directly to streams, rivers, lakes, oceans, or other bodies of water. Any
estimates for storm water runoff and non-point losses must also be included,
Releases to Land ~ includes disposal of toxic chemicals in waste to on-site
landfills, land treated or incorporation into soil, surface impoundments, spills,
leaks, or waste piles. These activities must occur within the facility's
boundaries for inclusion in this category.
Underground Injection — is a contained release of a fluid into a subsurface
well for the purpose of waste disposal.
TRANSFERS — is a transfer of toxic chemicals in wastes to a facility that is
geographically or physically separate from the facility reporting under TRI.
The quantities reported represent a movement of the chemical away from the
reporting facility. Except for off-site transfers for disposal, these quantities
do not necessarily represent entry of the chemical into the environment.
Transfers to POTWs — are wastewaters transferred through pipes or sewers
to a publicly owned treatments works (POTW). Treatment and chemical
removal depend on the chemical's nature and treatment methods used.
Chemicals not treated or destroyed by the POTW are generally released to
surface waters or landfilled within the sludge.
Transfers to Recycling — are sent off-site for the purposes of regenerating
or recovering still valuable materials. Once these chemicals have been
recycled, they may be returned to the originating facility or sold commercially.
Transfers to Energy Recovery — are wastes combusted off-site in industrial
furnaces for energy recovery. Treatment of a chemical by incineration is not
considered to be energy recovery.
Transfers to Treatment — are wastes moved off-site for either neutralization,
incineration, biological destruction, or physical separation. In some cases, the
chemicals are not destroyed but prepared for further waste management.
Transfers to Disposal ~ are wastes taken to another facility for disposal
generally as a release to land or as an injection underground.
IV.A. EPA Toxic Release Inventory for the Dry Cleaning Industry
The Toxics Release Inventory (TRI) covers only manufacturers categorized
in two-digit SIC codes 20 through 39. Therefore dry cleaning facilities which
are categorized as service industry establishments (SIC 72) are not required
September 1995
29
SIC 7216
-------
Sector Notebook Project
Dry Cleaning
to report to TRI. However, solvent releases from dry cleaners were estimated
by the Agency for two regulatory actions, the 1993 NESHAP for HAPs
(excluding petroleum solvents) and the 1984 Petroleum Dry Cleaners New
Source Performance Standard. The information is explained below.
The TRI database contains a detailed compilation of self-reported, facility-
specific chemical releases. The top reporting facilities for this sector are listed
below. Facilities that have reported only the SIC codes covered under this
notebook appear on the first list. The second list contains additional facilities
that have reported the SIC code covered within this report, and one or more
SIC codes that are not within the scope of this notebook. Therefore, the
second list includes facilities that conduct multiple operations ~ some that are
under the scope of this notebook, and some that are not. Currently, the
facility-level data do not allow pollutant releases to be broken apart by
industrial process.
IV.B. Summary of Selected Chemicals Released
The following is a synopsis of current scientific toxicity and fate information
for the top chemicals (by weight) that facilities within this sector self-reported
as released to the environment based upon 1993 TRI data. Because this
section is based upon self-reported release data, it does not attempt to provide
information on management practices employed by the sector to reduce the
release of these chemicals. Information regarding pollutant release reductions
over time are available from EPA's TRI and 33/50 programs, or directly from
the industrial trade associations that are listed in Section IX of this document.
Since these descriptions are cursory, please consult the sources referenced
below for a more detailed description of both the chemicals described in this
section and the chemicals that appear on the full list of TRI chemicals
appearing in Section IV. A.
The brief descriptions provided below were taken from the 1993 Toxics
Release Inventory Public Data Release (EPA, 1994), and the Hazardous
Substances Data Bank (HSDB), accessed via TOXNET. TOXNET is a
computer system run by the National Library of Medicine. It includes a
number of toxicological databases managed by EPA, National Cancer
Institute, and the National Institute for Occupational Safety and Health.d
HSDB contains chemical-specific information on manufacturing and use,
d Databases included in TOXNET are: CCRIS (Chemical Carcinogenesis Research Information System), DART
(Developmental and Reproductive Toxicity Database), DBIR (Directory of Biotechnology Information Resources),
EMICBACK (Environmental Mutagen Information Center Backfile), GENE-TOX (Genetic Toxicology), HSDB (Hazardous
Substances Data Bank), IRIS (Integrated Risk Information System), RTECS (Registry of Toxic Effects of Chemical
Substances), and TRI (Toxic Release Inventory).
September 1995
30
SIC 7216
-------
Sector Notebook Project
Dry Cleaning
chemical and physical properties, safety and handling, toxicity and biomedical
effects, pharmacology, environmental fate and exposure potential, exposure
standards and regulations, monitoring and analysis methods, and additional
references. The information contained below is based upon exposure
assumptions that have been conducted using standard scientific procedures.
The effects listed below must be taken in context of these exposure
assumptions that are more fully explained within the full chemical profiles in
HSDB. For more information on TOXNET, contact the TOXNET help line
at 800-231-3766.
Pe.rchloroe.thyle.ne. (te.trachloroethylf.nc.) (CAS: 127-18-4)
Toxicity. Chronic exposure to perchloroethylene (PCE) has been linked
to damage to the central nervous system and to a lesser extent, the lungs,
liver, and kidneys. Exposure to PCE is irritating to the eyes, skin, and
respiratory system.
Ecologically, experimental application of PCE to a freshwater pond led to
the local extinction of several phytoplankton and zooplankton species.
Carcinogenicity. PCE is a possible human carcinogen via oral exposure.
Environmental Fate. PCE released to surface water or the soil rapidly
evaporates. PCE is not expected to significantly biodegrade, bioconcentrate
in aquatic organisms, hydrolyze, or significantly adsorb to sediments or soil
particles. PCE released to the atmosphere degrades rapidly in the presence
of sunlight. It may be subject to washout in rain.
IV.C. Other Data Sources
The primary releases from the dry cleaning industry are associated with the
many solvents used. As mentioned in Section III. A., four solvents dominate:
perchloroethylene, petroleum solvents, chlorofluorocarbons and trichloro-
ethane. Estimates of national releases of hazardous air pollutants (HAPs)
(excludes petroleum solvents) from the baseline estimate prior to the 1993
NESHAP are 90,200 tons/year from the commercial sector, 4,800 tons/year
from the industrial sector and 990 tons/year from the coin-operated sector for
a total of 95,900 tons/year. The total quantity of HAPs disposed of off-site
is 47,500 tons per year and is primarily from filtration residue. The recent
NESHAP will reduce the air emissions by prohibiting the sale of new transfer
equipment, requiring control devices on existing equipment, and requiring
new equipment to be fitted with controls. The most recent petroleum solvent
emission data available for the dry cleaning industry are from 1982 in support
of the 1984 New Source Performance Standards. Applying the release factor
September 1995
31
SIC 7216
-------
Sector Notebook Project
Dry Cleaning
of 23 pounds of solvent per 100 pounds of clothes cleaned to the total
petroleum-based facility throughput yields total petroleum solvent releases of
51,000 tons per year. These releases are distributed approximately equally
between commercial and industrial plants (there are no coin-operated
petroleum plants). Over 75 percent of the releases are from dryers with the
remainder from a combination of evaporation from filters, still releases and
fugitive emissions. These values may slightly overestimate current releases
because vapor control technologies such as carbon adsorbers or condensers
may have been added to existing machines.
The Aerometric Information Retrieval System (AIRS) contains a wide range
of information related to stationary sources of air pollution, including the
emissions of a number of air pollutants which may be of concern within a
particular industry. Exhibit 14 summarizes annual releases of carbon
monoxide (CO), nitrogen dioxide (NO2), paniculate matter of 10 microns or
less (PM10), sulfur dioxide (SO2), and volatile organic compounds (VOCs).
September 1995
32
SIC 7216
-------
Sector Notebook Project
Dry Cleaning
Exhibit 14: Pollutant Releases (short tons/year)
Industry Sector
Metal Mining
Nonmetal Mining
Lumber and Wood Production
Furniture and Fixtures
Pulp and Paper
Printing
Inorganic Chemicals
Organic Chemicals
Petroleum Refining
Rubber and Misc. Plastics
Stone, Clay and Concrete
Iron and Steel
Nonferrous Metals
Fabricated Metals
Computer and Office Equipment
Electronics and Other Electrical
Equipment and Components
Motor Vehicles, Bodies, Parts and
Accessories
Dry Cleaning
CO
5,391
4,525
123,756
2,069
624,291
8,463
166,147
146,947
419,311
2,090
58,043
1,518,642
448,758
3,851
24
367
35,303
101
NO 2
28,583
28,804
42,658
2,981
394,448
4,915
103,575
236,826
380,641
11,914
338,482
138,985
55,658
16,424
0
1,129
23,725
179
PM10
39,359
59,305
14,135
2,165
35,579
399
4,107
26,493
18,787
2,407
74,623
42,368
20,074
1,185
0
207
2,406
3
PT
140,052
167,948
63,761
3,178
113,571
1,031
39,062
44,860
36,877
5,355
171,853
83,017
22,490
3,136
0
293
12,853
28
SO2
84,222
24,129
9,419
1,606
541,002
1,728
182,189
132,459
648,155
29,364
339,216
238,268
373,007
4,019
0
453
25,462
152
voc
1,283
1,736
41,423
59,426
96,875
101,537
52,091
201,888
369,058
140,741
30,262
82,292
27,375
102,186
0
4,854
101,275
7,310
Source: U.S. EPA Office of Air and Radiation, AIRS Database, May 1995.
September 1995
33
SIC 7216
-------
Sector Notebook Project
Dry Cleaning
IV.D. Comparison of Toxic Release Inventory Between Selected Industries
The following information is presented as a comparison of pollutant release
and transfer data across industrial categories. It is provided to give a general
sense as to the relative scale of releases and transfers within each sector
profiled under this project. Please note that the following figure and table do
not contain releases and transfers for industrial categories that are not
included in this project, and thus cannot be used to draw conclusions
regarding the total release and transfer amounts that are reported to TRI. In
addition, the dry cleaning industry sector is not subject to TRI reporting and
therefore is not presented in Exhibits 14 and 15. Similar information is
available within the annual TRI Public Data Release Book.
Exhibit 15 is a graphical representation of a summary of the 1993 TRI data for
the dry cleaning industry and the other sectors profiled in these notebooks.
The bar graph presents the total TRI releases and total transfers on the left
axis and the triangle points show the average releases per facility on the right
axis. Industry sectors are presented in the order of increasing total TRI
releases. The graph is based on the data shown in Exhibit 16 and is meant to
facilitate comparisons between the relative amounts of releases, transfers, and
releases per facility both within and between these sectors. The reader should
note, however, that differences in the proportion of facilities captured by TRI
exist between industry sectors.
September 1995
34
SIC 7216
-------
Sector Notebook Project
Dry Cleaning
o
o
o"
o
o
I
2 t
H •§
f? 5
«4-i !-
o ^
S H
I «
WJ 88
t-H «
•<-> ~
3 *
a
o
o
o
CO
-f-
o
o
o_
o"
o
5
o o
o o
r*- VD
o o o
o o o
^ en
o
o
s
^
D
(suotjjnu) spraioj pjoj^
u
u
a
ber
September 1995
35
SIC 7216
-------
Sector Notebook Project
Dry Cleaning
$
• £»
IH
•4^k
CO
J3
•a
1
CO
cS
03
ts
ft
O
1
>
jg
F"1^
So
C3
HB!
13
OS
^^
U
•PM
X
H
•*
r~'
•^
• IM
.Q
jg
* *
%
1
g
i
™
V3
S
P5
M
H
to
Cv
1-1
+ *
§1
"3 « "§
K »• §
IIP
*" H
+
d
•n
Ov
00
CN
00
CN
Inorganic Chem. Mfg.
|
oo"
oo
co"
Ov
00
o
o
o
t£
VO
CN"
"S
"*
o
CD
o
CN
CO
s
in
•— *
OV
CN
oo
1
PH
o
o
o
s
t—
vo
CN
o
o
o
CO
00
Os
CD
CD
O
O
CO
CN
VO
CO
CN"
CO
Fabricated Metals
o
0
00
*-<"
CO
OV
VO
o
o
o
-"
OV
o
vo
g
o
CN
CN
00
00
oo
CO
t— 1
CO
CO
1
CO
Ji
o
o
CD
1
rt
t-
o
oo
CN
CD
§
oo
Ov
o
0
o
f-
00
m
CN
oo
o
CN
CO
co"
CO
CO
Nonferrous Metals
o
o
o
CN"
— '
•3-
oo'
o
o
o
oo
00
vo
f-
vd
00
CN
o
0
o
s
CO
VO_
£
£5
•"si"
Ov
vo
oo
T
VO
CO
CN
Organic Chemical Mfg.
=?
1
g
Q
H
1
!
in
zs
O
Metal Mining
1*
1
Q
•}
I
Ul
1
1
1
2
Nonmetal Mining
BJ)
|
1
H
5
1
f
cn
•*j
!
u
a>
w
i-
1
ve
t-
Dry Qeaning
CO
Ov
Ov
Q
s
1
1?
§
>
1
1
0
2
§
CO
§
CO
September 1995
36
SIC 7216
-------
Sector Notebook Project
Dry Cleaning
V. POLLUTION PREVENTION OPPORTUNITIES
The best way to reduce pollution is to prevent it in the first place. Some
companies have creatively implemented pollution prevention techniques that
improve efficiency and increase profits while at the same time minimizing
environmental impacts. This can be done in many ways such as reducing
material inputs, re-engineering processes to reuse by-products, improving
management practices, and employing substitution of toxic chemicals. Some
smaller facilities are able to actually get below regulatory thresholds just by
reducing pollutant releases through aggressive pollution prevention policies.
In order to encourage these approaches, this section provides both general
and company-specific descriptions of some pollution prevention advances that
have been implemented within the dry cleaning industry. While the list is not
exhaustive, it does provide core information that can be used as the starting
point for facilities interested in beginning their own pollution prevention
projects. When possible, this section provides information from real activities
that can, or are being implemented by this sector — including a discussion of
associated costs, time frames, and expected rates of return. This section
provides summary information from activities that may be, or are being
implemented by this sector. When possible, information is provided that gives
the context in which the technique can be effectively used. Please note that
the activities described in this section do not necessarily apply to all facilities
that fall within this sector. Facility-specific conditions must be carefully
considered when pollution prevention options are evaluated, and the full
impacts of the change must examine how each option affects air, land and
water pollutant releases.
V.A. Pollution Prevention Opportunities for the Dry Cleaning Industry
A number of major changes within the dry cleaning industry are pushing dry
cleaners toward pollution prevention. Projects such as the Design for the
Environment, the import of European technologies, and increased attention
on the part of state and federal regulators to dry cleaning have caused trade
associations, technical assistance offices, and individual establishments to
investigate possible techniques for reducing the environmental releases
associated with dry cleaning. Pollution prevention approaches over the short
term for existing facilities and equipment include: improved operating
practices or "good housekeeping" and process and equipment retrofits. Over
the long-term, there are several new fabric cleaning processes under
development, some of which are commercially available while others are still
in the research stage. Market forces might take longer than command and
control regulations to influence cleaning technologies, as new technologies
will only be adopted as existing equipment is retired and replaced.
September 1995
37
SIC 7216
-------
Sector Notebook Project
Dry Cleaning
As pointed out in Section IV.C, air releases of perchloroethylene and
petroleum solvents used to clean the fabric are the primary environmental
release from dry cleaning. Spills, inadequate storage and drain disposal of
solvents have led to groundwater contamination. In addition, (improper)
disposal of solvent laden material, such as filters, as nonhazardous solid waste
is of concern.
Because chemicals constitute a large cost for dry cleaners, particularly if
drying exhaust is vented directly to the atmosphere, there are significant
opportunities to reduce chemical use and possibly reduce operating costs.
Reduced chemical use can, in turn, reduce the waste management costs
associated with regulatory requirements as well as reduce potential financial
liability. Some pollution prevention strategies may reduce risk but involve a
higher energy consumption.
Several operating practices can reduce potential solvent exposure if they are
used regularly. The practices of importance will vary based on the type of
machine. For example, the major release in a transfer machine occurs when
clothes are transferred. Because dry-to-dry machines wash and dry in a single
container there are no such releases. Listed below are several specific
practices that may reduce releases.
Improved Operating Practices- Specific to Transfer Machines
Conduct transfer of solvent saturated clothes from washer to dryer as quickly
as possible.
Close dryer door immediately upon completion of transfer.
Improved Operating Practices - All Machines
Clean the filters that precede the carbon filters weekly.
Clean lint screens to avoid clogging fans and condensers.
Open button traps and lint baskets only long enough to clean.
Check baffle assembly in cleaning machine bi-weekly.
Use closed containers for collection and storage of recovered or new solvent.
Equipment Maintenance
Clean drying sensors weekly.
September 1995
38
SIC 7216
-------
Sector Notebook Project
Pry Cleaning
Replace seals regularly on dryer deodorizer and aeration valves.
Replace door gasket on button trap.
Replace gaskets around cleaning machine door or tighten enclosure.
Repair holes in air and exhaust duct.
Secure hose connection and couplings.
Clean lint buildup on cooling condenser coils weekly.
Equipment Modification
Use a hamper enclosure or a room enclosure of impermeable construction to
reduce solvent release during transfer. The enclosure should be a complete
vapor barrier, especially if the dry cleaner is located in a mixed use residential
setting.
Use local exhaust ventilation through washer and dryer doors or exhaust
hoods between washer and dryer. The exhaust velocity should be 100 feet per
minute. In addition, a supplemental door fan local exhaust system should be
included on third generation equipment. This should vent through a small
carbon adsorber designed to control PCE emission levels between 5-20 ppmv.
Install general ventilation that changes the air every five minutes.
Place dry cleaning equipment in separate room at negative pressure and
operate a separate exhaust system to control the vapors.
Place washer and dryer close together to minimize solvent losses during
transfer.
Replace the cartridge filters with spin disk filters that can be cleaned without
opening. This would produce fewer fugitive emissions and less hazardous
waste.
Install distillation equipment where the still bottoms can be removed without
opening the still. This reduces fugitive emissions.
Use carbon adsorber that is regenerated with hot air stripping rather than
steam stripping. This reduces the waste stream.
September 1995
39
SIC 7216
-------
Sector Notebook Project
Dry Cleaning
Use double carbon waste water treatment devices to clean up PCE
contaminated waste waters. Recycle the treated waste water to the process
boiler.
Chemical Substitutions
Alternative petroleum solvents are being developed with higher flash points
to reduce the fire hazard.
Alternative petroleum solvents are being developed with lower VOC content
(the drawback, however, is the longer drying time).
Use wet cleaning processes.
Major Equipment Upgrades
Add a refrigerated condenser to the machine for primary control, followed
perhaps by a carbon adsorber for secondary control.
Replace a transfer machine with a dry-to-dry machine.
Upgrade a dry-to-dry machine with additional control equipment such as a
spill container that will catch and recycle solvent spills from the machine.
Replace current machine with a dry-to-dry closed-loop-non-vented machine
that contains an integral refrigerated condenser and an integral carbon
adsorber.
Technological Innovation
The majority of the hazardous solid waste is generated by the carbon
adsorbers. Several technologies are being developed that use a polymer
surface for adsorbing the solvent vapor. The surface can be regenerated by
heating and, unlike carbon, does not need to be replaced, thus reducing the
hazardous waste.
New aqueous processes that do not use organic solvents as the primary
solvent were mentioned in Section III.B. Multiprocess wet cleaning and
machine wet cleaning have both been introduced in several sites in the U.S.
New processes that use other cleaning methods are also under development.
Both ultrasonic cleaning and a clothes cleaning method that uses liquid carbon
dioxide are under development.
September 1995
40
SIC 7216
-------
Sector Notebook Project
Dry Cleaning
Both pollution prevention and end-of-pipe controls have the potential to
substantially reduce the risk from toxic chemical release. The primary
difference is the size of the initial investment. For example, to retrofit a dry-
to-dry perchloroethylene machine with a refrigerated condenser costs about
$7,500 while replacing the existing unit with a fourth generation machine that
is closed-loop with a built-in refrigerated condenser and secondary controls
is about $47,000 (35 pound machine). However, the total cost per pound of
clothes cleaned over a fifteen year lifetime is nearly identical ($0.48 to $0.50)
when the solvent savings are considered. The fourth generation machine also
produces lower solvent releases to air and water and creates less hazardous
waste. However, with 25 percent of commercial dry cleaners taking in annual
receipts of less than $28,000, the initial investment required for a new machine
may be prohibitive. (Information developed for OPPT's Design for the
Environment Program.)
The aqueous processes have recently been introduced to the U.S. market.
They reduce pollution considerably by not introducing toxic chemicals as the
primary solvent. The multiprocess wet cleaning method is cost competitive
with conventional dry cleaning although in preliminary short term testing it is
more labor intensive. The performance of these cleaning methods has yet to
be determined on a broad scale although the Agency's Design for the
Environment (DfE) test site should provide this data within two years.
Liquid carbon dioxide and the ultrasonic cleaning are currently in the
development stage. While neither of these technologies uses toxic chemicals,
the technical and economic feasibility must be demonstrated before they are
true market options.
Most commercial dry cleaners are small shops. Over twenty-five percent of
dry cleaners have owners of Korean descent. Commercial dry cleaners may
not be in compliance with current regulations because of lack of familiarity
with the law or communication barriers. Dry cleaners get much of their
technical information from their trade associations and their equipment
suppliers who may only have information on their products. This could limit
the dissemination of information on innovative alternatives such as machine
wet cleaning which tends to be manufactured by washing machine makers
rather than dry cleaning machine makers.
The Agency's Design for the Environment program has already participated
in a number of outreach activities. These include attending trade shows to
discuss alternatives, conducting a demonstration of multiprocess wet cleaning
and arranging for a demonstration of several alternative technologies over the
next two years. A full description of the program is provided in Section
VIII.A.
September 1995
41
SIC 7216
-------
Sector Notebook Project
Dry Cleaning
Showing the commercial viability of alternatives is likely to produce the
largest leverage for pollution prevention since dry cleaners are skeptical that
new technologies will clean as well as the current process. However, current
fashion trends, the introduction of new washable fabrics and the increased use
of casual (washable) clothes in the work place have created opportunities for
new processes and the increased use of traditional laundry.
Pollution prevention will reduce the releases of solvents to air and water and
reduce the quantity of solid waste produced. Controlling releases will reduce
worker exposure, customer exposure and the exposure of residents in multi
use buildings that contain dry cleaners. Some pollution prevention efforts may
also be cost effective for the dry cleaner if the solvent savings are significant.
Finally, the fact that a dry cleaner is environmentally sound could be used in
marketing. If customers prefer such "green cleaning," the fact that a cleaner
is practicing pollution prevention could increase sales.
September 1995
42
SIC 7216
-------
Sector Notebook Project
Dry Cleaning
VI. SUMMARY OF APPLICABLE FEDERAL STATUTES AND REGULATIONS
This section discusses the Federal regulations that may apply to this sector.
The purpose of this section is to highlight, and briefly describe the applicable
Federal requirements, and to provide citations for more detailed information.
The three following sections are included.
• Section VI. A. contains a general overview of major statutes
• Section VLB. contains a list of regulations specific to this industry
• Section VI.C. contains a list of pending and proposed regulations
The descriptions within Section VI are intended solely for general
information. Depending upon the nature or scope of the activities at a
particular facility, these summaries may or may not necessarily describe all
applicable environmental requirements. Moreover, they do not constitute
formal interpretations or clarifications of the statutes and regulations. For
further information, readers should consult the Code of Federal Regulations
and other state or local regulatory agencies. EPA Hotline contacts are also
provided for each major statute.
VI.A. General Description of Major Statutes
Resource Conservation And Recovery Act
The Resource Conservation And Recovery Act (RCRA) of 1976 which
amended the Solid Waste Disposal Act, addresses solid (Subtitle D) and
hazardous (Subtitle C) waste management activities. The Hazardous and
Solid Waste Amendments (HSWA) of 1984 strengthened RCRA's waste
management provisions and added Subtitle I, which governs underground
storage tanks (USTs).
Regulations promulgated pursuant to Subtitle C of RCRA (40 CFR Parts
260-299) establish a "cradle-to-grave" system governing hazardous waste
from the point of generation to disposal. RCRA hazardous wastes include the
specific materials listed in the regulations (commercial chemical products,
designated with the code "P" or "U"; hazardous wastes from specific
industries/sources, designated with the code "K"; or hazardous wastes from
non-specific sources, designated with the code "F") or materials which exhibit
a hazardous waste characteristic (ignitability, corrosivity, reactivity, or toxicity
and designated with the code "D").
Regulated entities that generate hazardous waste are subject to waste
accumulation, manifesting, and record keeping standards. Facilities that treat,
store, or dispose of hazardous waste must obtain a permit, either from EPA
or from a State agency which EPA has authorized to implement the permitting
September 1995
43
SIC 7216
-------
Sector Notebook Project
Dry Cleaning
program. Subtitle C permits contain general facility standards such as
contingency plans, emergency procedures, record keeping and reporting
requirements, financial assurance mechanisms, and unit-specific standards.
RCRA also contains provisions (40 CFR Part 264 Subpart S and §264.10) for
conducting corrective actions which govern the cleanup of releases of
hazardous waste or constituents from solid waste management units at
RCRA-regulated facilities.
Although RCRA is a Federal statute, many States implement the RCRA
program. Currently, EPA has delegated its authority to implement various
provisions of RCRA to 46 of the 50 States.
Most RCRA requirements are not industry specific but apply to any company
that transports, treats, stores, or disposes of hazardous waste. Here are some
important RCRA regulatory requirements:
Identification of Solid and Hazardous Wastes (40 CFR Part 261)
lays out the procedure every generator should follow to determine
whether the material created is considered a hazardous waste, solid
waste, or is exempted from regulation.
Standards for Generators of Hazardous Waste (40 CFR Part 262)
establishes the responsibilities of hazardous waste generators including
obtaining an ID number, preparing a manifest, ensuring proper
packaging and labeling, meeting standards for waste accumulation
units, and record keeping and reporting requirements. Generators can
accumulate hazardous waste for up to 90 days (or 180 days depending
on the amount of waste generated) without obtaining a permit.
• Land Disposal Restrictions (LDRs) are regulations prohibiting the
disposal of hazardous waste on land without prior treatment. Under
the LDRs (40 CFR 268), materials must meet land disposal restriction
(LDR) treatment standards prior to placement in a RCRA land
disposal unit (landfill, land treatment unit, waste pile, or surface
impoundment). Wastes subject to the LDRs include solvents,
electroplating wastes, heavy metals, and acids. Generators of waste
subject to the LDRs must provide notification of such to the
designated TSD facility to ensure proper treatment prior to disposal.
• Used Oil storage and disposal regulations (40 CFR Part 279) do not
define Used Oil Management Standards impose management
requirements affecting the storage, transportation, burning,
processing, and re-refining of the used oil. For parties that merely
generate used oil, regulations establish storage standards. For a party
considered a used oil marketer (one who generates and sells
September 1995
44
SIC 7216
-------
Sector Notebook Project
Dry Cleaning
off-specification used oil directly to a used oil burner), additional
tracking and paperwork requirements must be satisfied.
• Tanks and Containers used to store hazardous waste with a high
volatile organic concentration must meet emission standards under
RCRA. Regulations (40 CFR Part 264-265, Subpart CC) require
generators to test the waste to determine the concentration of the
waste, to satisfy tank and container emissions standards, and to
inspect and monitor regulated units. These regulations apply to all
facilities who store such waste, including generators operating under
the 90-day accumulation rule.
• Underground Storage Tanks (USTs) containing petroleum and
hazardous substance are regulated under Subtitle I of RCRA. Subtitle
I regulations (40 CFR Part 280) contain tank design and release
detection requirements, as well as financial responsibility and
corrective action standards for USTs. The UST program also
establishes increasingly stringent standards, including upgrade
requirements for existing tanks, that must be met by 1998.
• Boilers and Industrial Furnaces (BIFs) that use or bum fuel
containing hazardous waste must comply with strict design and
operating standards. BIF regulations (40 CFR Part 266, Subpart H)
address unit design, provide performance standards, require emissions
monitoring, and restrict the type of waste that may be burned.
EPA's RCRA/Superfund/UST Hotline, at (800) 424-9346, responds to
questions and distributes guidance regarding all RCRA regulations. The
RCRA Hotline operates-weekdaysfrom 8:30a.m. to 7:30p.m., ET, excluding
Federal holidays.
Comprehensive Environmental Response, Compensation, And Liability Act
The Comprehensive Environmental Response, Compensation, and Liability
Act (CERCLA), a 1980 law commonly known as Superfund, authorizes EPA
to respond to releases, or threatened releases, of hazardous substances that
may endanger public health, welfare, or the environment. CERCLA also
enables EPA to force parties responsible for environmental contamination to
clean it up or to reimburse the Superfund for response costs incurred by EPA.
The Superfund Amendments and Reauthorization Act (SARA) of 1986
revised various sections of CERCLA, extended the taxing authority for the
Superfund, and created a free-standing law, SARA Title m, also known as the
Emergency Planning and Community Right-to-Know Act (EPCRA).
September 1995
45
SIC 7216
-------
Sector Notebook Project
Dry Cleaning
The CERCLA hazardous substance release reporting regulations (40 CFR
Part 302) direct the person in charge of a facility to report to the National
Response Center (NRC) any environmental release of a hazardous substance
which exceeds a reportable quantity. Reportable quantities are defined and
listed in 40 CFR §302.4. A release report may trigger a response by EPA, or
by one or more Federal or State emergency response authorities.
EPA implements hazardous substance responses according to procedures
outlined in the National Oil and Hazardous Substances Pollution Contingency
Plan (NCP) (40 CFR Part 300). The NCP includes provisions for permanent
cleanups, known as remedial actions, and other cleanups referred to as
"removals." EPA generally takes remedial actions only at sites on the
National Priorities List (NPL), which currently includes approximately 1300
sites. Both EPA and states can act at other sites; however, EPA provides
responsible parties the opportunity to conduct removal and remedial actions
and encourages community involvement throughout the Superfund response
process.
EPA'sRCRA/Superfund/UST Hotline, at (800) 424-9346, answers questions
and references guidance pertaining to the Superfund program. The CERCLA
Hotline operates -weekdays from 8:30 a.m. to 7:30 p.m., ET, excluding
Federal holidays.
Emergency Planning And Community Right-To-Know Act
The Superfund Amendments and Reauthorization Act (SARA) of 1986
created the Emergency Planning and Community Right-to-Know Act
(EPCRA, also known as SARA Title III), a statute designed to improve
community access to information about chemical hazards and to facilitate the
development of chemical emergency response plans by State and local
governments. EPCRA required the establishment of State emergency
response commissions (SERCs), responsible for coordinating certain
emergency response activities and for appointing local emergency planning
committees (LEPCs).
EPCRA and the EPCRA regulations (40 CFR Parts 350-372) establish four
types of reporting obligations for facilities which store or manage specified
chemicals:
EPCRA §302 requires facilities to notify the SERC and LEPC of the
presence of any "extremely hazardous substance" (the list of such
substances is in 40 CFR Part 355, Appendices A and B) if it has such
substance in excess of the substance's threshold planning quantity, and
directs the facility to appoint an emergency response coordinator.
September 1995
46
SIC 7216
-------
Sector MiotebookProject
Dry Cleaning
EPCRA §304 requires the facility to notify the SERC and the LEPC
in the event of a release exceeding the reportable quantity of a
CERCLA hazardous substance or an EPCRA extremely hazardous
substance.
• EPCRA §311 and §312 require a facility at which a hazardous
chemical, as defined by the Occupational Safety and Health Act, is
present in an amount exceeding a specified threshold to submit to the
SERC, LEPC and local fire department material safety data sheets
(MSDSs) or lists of MSDS's and hazardous chemical inventory forms
(also known as Tier I and II forms). This information helps the local
government respond in the event of a spill or release of the chemical.
• EPCRA §313 requires manufacturing facilities included in SIC codes
20 through 39, which have ten or more employees, and which
manufacture, process, or use specified chemicals in amounts greater
than threshold quantities, to submit an annual toxic chemical release
report. This report, commonly known as the Form R, covers releases
and transfers of toxic chemicals to various facilities and environmental
media, and allows EPA to compile the national Toxic Release
Inventory (TRI) database.
All information submitted pursuant to EPCRA regulations is publicly
accessible, unless protected by a trade secret claim.
EPA'sEPCRA Hotline, at (800) 535-0202, answers questions and distributes
guidance regarding the emergency planning and community right-to-know
regulations. The EPCRA Hotline operates weekdays from 8:30 a.m. to 7:30
p.m., ET, excluding Federal holidays.
Clean Water Act
The primary objective of the Federal Water Pollution Control Act, commonly
referred to as the Clean Water Act (CWA), is to restore and maintain the
chemical, physical, and biological integrity of the nation's surface waters.
Pollutants regulated under the CWA include "priority" pollutants, including
various toxic pollutants; "conventional" pollutants, such as biochemical
oxygen demand (BOD), total suspended solids (TSS), fecal coliform, oil and
grease, and pH; and "non-conventional" pollutants, including any pollutant not
identified as either conventional or priority.
The CWA regulates both direct and indirect discharges. The National
Pollutant Discharge Elimination System (NPDES) program (CWA §402)
controls direct discharges into navigable waters. Direct discharges or "point
source" discharges are from sources such as pipes and sewers. NPDES
September 1995
47
SIC 7216
-------
Sector Notebook Project
Dry Cleaning
permits, issued by either EPA or an authorized State (EPA has presently
authorized forty States to administer the NPDES program), contain industry-
specific, technology-based and/or water quality-based limits, and establish
pollutant monitoring and reporting requirements. A facility that intends to
discharge into the nation's waters must obtain a permit prior to initiating its
discharge. A permit applicant must provide quantitative analytical data
identifying the types of pollutants present in the facility's effluent. The permit
will then set forth the conditions and effluent limitations under which a facility
may make a discharge.
A NPDES permit may also include discharge limits based on Federal or State
water quality criteria or standards, that were designed to protect designated
uses of surface waters, such as supporting aquatic life or recreation. These
standards, unlike the technological standards, generally do not take into
account technological feasibility or costs. Water quality criteria and standards
vary from State to State, and site to site, depending on the use classification
of the receiving body of water. Most States follow EPA guidelines which
propose aquatic life and human health criteria for many of the 126 priority
pollutants.
Storm Water Discharges
In 1987 the CWA was amended to require EPA to establish a program to
address storm water discharges. In response, EPA promulgated the NPDES
storm water permit application regulations. Storm water discharge associated
with industrial activity means the discharge from any conveyance which is
used for collecting and conveying storm water and which is directly related to
manufacturing, processing, or raw material storage areas at an industrial plant
(40 CFR 122.26(b)(14)). These regulations require that facilities with the
following storm water discharges apply for an NPDES permit: (1) a discharge
associated with industrial activity; (2) a discharge from a large or medium
municipal storm sewer system; or (3) a discharge which EPA or the State
determines to contribute to a violation of a water quality standard or is a
significant contributor of pollutants to waters of the United States.
The term "storm water discharge associated with industrial activity" means a
storm water discharge from one of 11 categories of industrial activity defined
at 40 CFR 122.26. Six of the categories are defined by SIC codes while the
other five are identified through narrative descriptions of the regulated
industrial activity. If the primary SIC code of the facility is one of those
identified in the regulations, the facility is subject to the storm water permit
application requirements. If any activity at a facility is covered by one of the
five narrative categories, storm water discharges from those areas where the
activities occur are subject to storm water discharge permit application
requirements.
September 1995
48
SIC 7216
-------
Sector Notebook Project
Dry Cleaning
Those facilities/activities that are subject to storm water discharge permit
application requirements are identified below. To determine whether a
particular facility falls within one of these categories, the regulation should be
consulted.
Category i: Facilities subject to storm water effluent guidelines, new source
performance standards, or toxic pollutant effluent standards.
Category ii: Facilities classified as SIC 24-lumber and wood products (except
wood kitchen cabinets); SIC 26-paper and allied products (except paperboard
containers and products); SIC 28-chemicals and allied products (except drugs
and paints); SIC 291-petroleum refining; and SIC 311-leather tanning and
finishing.
Category iii: Facilities classified as SIC 10-metal mining; SIC 12-coal mining;
SIC 13-oil and gas extraction; and SIC 14-nonmetallic mineral mining.
Category iv: Hazardous waste treatment, storage, or disposal facilities.
Category v: Landfills, land application sites, and open dumps that receive or
have received industrial wastes.
Category vi: Facilities classified as SIC 5015-used motor vehicle parts; and
SIC 5093-automotive scrap and waste material recycling facilities.
Category vii: Steam electric power generating facilities.
Category viii: Facilities classified as SIC 40-railroad transportation; SIC 41-
local passenger transportation; SIC 42-trucking and warehousing (except
public warehousing and storage); SIC 43-U.S. Postal Service; SIC 44-water
transportation; SIC 45-transportation by air; and SIC 5171-petroleum bulk
storage stations and terminals.
Category ix: Sewage treatment works.
Category x: Construction activities except operations that result in the
disturbance of less than five acres of total land area.
Category xi: Facilities classified as SIC 20-food and kindred products; SIC
21-tobacco products; SIC 22-textile mill products; SIC 23-apparel re'lated
products; SIC 2434-wood kitchen cabinets manufacturing; SIC 25-fijrniture
and fixtures; SIC 265-paperboard containers and boxes; SIC 267-converted
paper and paperboard products; SIC 27-printing, publishing, and allied
industries; SIC 283-drugs; SIC 285-paints, varnishes, lacquer, enamels, and
allied products; SIC 30-rubber and plastics; SIC 31-leather and leather
September 1995
49
SIC 7216
-------
Sector Notebook Project
Dry Cleaning
products (except leather and tanning and finishing); SIC 323-glass products;
SIC 34-fabricated metal products (except fabricated structural metal); SIC 35-
industrial and commercial machinery and computer equipment; SIC 36-
electronic and other electrical equipment and components; SIC 37-
transportation equipment (except ship and boat building and repairing); SIC
38-measuring, analyzing, and controlling instruments; SIC 39-miscellaneous
manufacturing industries; and SIC 4221-4225-public warehousing and
storage.
Pretreatment Program
Another type of discharge that is regulated by the CWA is one that goes to a
publicly-owned treatment works (POTWs). The national pretreatment
program (CWA §307(b)) controls the indirect discharge of pollutants to
POTWs by "industrial users." Facilitie > regulated under §307(b) must meet
certain pretreatment standards. The goal of the pretreatment program is to
protect municipal wastewater treatment plants from damage that may occur
when hazardous, toxic, or other wastes are discharged into a sewer system
and to protect the quality of sludge generated by these plants. Discharges to
a POTW are regulated primarily by the POTW itself, rather than the State or
EPA.
EPA has developed technology-based standards for industrial users of
POTWs. Different standards apply to existing and new sources within each
category. "Categorical" pretreatment standards applicable to an industry on
a nationwide basis are developed by EPA. In addition, another kind of
pretreatment standard, "local limits," are developed by the POTW in order to
assist the POTW in achieving the effluent limitations in its NPDES permit.
Regardless of whether a State is authorized to implement either the NPDES
or the pretreatment program, if it develops its own program, it may enforce
requirements more stringent than Federal standards.
EPA's Office of Water, at (202) 260-5700, will direct callers with questions
about the CWA to the appropriate EPA office. EPA also maintains a
bibliographic database of Office of Water publications which can be
accessed through the Ground Water and Drinking Water resource center, at
(202) 260-7786.
Safe Drinking Water Act
The Safe Drinking Water Act (SOWA) mandates that EPA establish
regulations to protect human health from contaminants in drinking water.
The law authorizes EPA to develop national drinking water standards and to
create a joint Federal-State system to ensure compliance with these standards.
September 1995
50
SIC 7216
-------
Sector Notebook Project
Dry Cleaning
The SDWA also directs EPA to protect underground sources of drinking
water through the control of underground injection of liquid wastes.
EPA has developed primary and secondary drinking water standards under its
SDWA authority. EPA and authorized States enforce the primary drinking
water standards, which are, contaminant-specific concentration limits that
apply to certain public drinking water supplies. Primary drinking water
standards consist of maximum contaminant level goals (MCLGs), which are
non-enforceable health-based goals, and maximum contaminant levels
(MCLs), which are enforceable limits set as close to MCLGs as possible,
considering cost and feasibility of attainment.
The SDWA Underground Injection Control (UIC) program (40 CFR Parts
144-148) is a permit program which protects underground sources of drinking
water by regulating five classes of injection wells. UIC permits include
design, operating, inspection, and monitoring requirements. Wells used to
inject hazardous wastes must also comply with RCRA corrective action
standards in order to be granted a RCRA permit, and must meet applicable
RCRA land disposal restrictions standards. The UIC permit program is
primarily State-enforced, since EPA has authorized all but a few States to
administer the program.
The SDWA also provides for a Federally-implemented Sole Source Aquifer
program, which prohibits Federal funds from being expended on projects that
may contaminate the sole or principal source of drinking water for a given
area, and for a State-implemented Wellhead Protection program, designed to
protect drinking water wells and drinking water recharge areas.
EPA 's Safe Drinking Water Hotline, at (800) 426-4791, answers questions
and distributes guidance pertaining to SDWA standards. The Hotline
operates from 9:00 a.m. through 5:30 p.m., ET, excluding Federal holidays.
Toxic Substances Control Act
The Toxic Substances Control Act (TSCA) granted EPA authority to create
a regulatory framework to collect data on chemicals in order to evaluate,
assess, mitigate, and control risks which may be posed by their manufacture,
processing, and use. TSCA provides a variety of control methods to prevent
chemicals from posing unreasonable risk.
TSCA standards may apply at any point during a chemical's life cycle. Under
TSCA §5, EPA has established an inventory of chemical substances. If a
chemical is not already on the inventory, and has not been excluded by TSCA,
a premanufacture notice (PMN) must be submitted to EPA prior to
manufacture or import. The PMN must identify the chemical and provide
September 1995
51
SIC 7216
-------
Sector Notebook Project
Dry Cleaning
available information on health and environmental effects. If available data
are not sufficient to evaluate the chemical's effects, EPA can impose
restrictions pending the development of information on its health and
environmental effects. EPA can also restrict significant new uses of chemicals
based upon factors such as the projected volume and use of the chemical.
Under TSCA §6, EPA can ban the manufacture or distribution in commerce,
limit the use, require labeling, or place other restrictions on chemicals that
pose unreasonable risks. Among the chemicals EPA regulates under §6
authority are asbestos, chlorofluorocarbons (CFCs), and polychlorinated
biphenyls (PCBs).
EPA's TSCA Assistance Information Service, at (202) 554-1404, answers
questions and distributes guidance pertaining to Toxic Substances Control
Act standards. The Service operates from 8:30 a.m. through 4:30 p.m., ET,
excluding Federal holidays.
Clean Air Act
The Clean Air Act (CAA) and its amendments, including the Clean Air Act
Amendments (CAAA) of 1990, are designed to "protect and enhance the
nation's air resources so as to promote the public health and welfare and the
productive capacity of the population." The CAA consists of six sections,
known as Titles, which direct EPA to establish national standards for ambient
air quality and for EPA and the States to implement, maintain, and enforce
these standards through a variety of mechanisms. Under the CAAA, many
facilities will be required to obtain permits for the first time. State and local
governments oversee, manage, and enforce many of the requirements of the
CAAA. CAA regulations appear at 40 CFR Parts 50-99.
Pursuant to Title I of the CAA, EPA has established national ambient air
quality standards (NAAQSs) to limit levels of "criteria pollutants," including
carbon monoxide, lead, nitrogen dioxide, paniculate matter, ozone, and sulfur
dioxide. Geographic areas that meet NAAQSs for a given pollutant are
classified as attainment areas; those that do not meet NAAQSs are classified
as non-attainment areas. Under §110 of the CAA, each State must develop
a State Implementation Plan (SIP) to identify sources of air pollution and to
determine what reductions are required to meet Federal air quality standards.
Title I also authorizes EPA to establish New Source Performance Standards
(NSPSs), which are nationally uniform emission standards for new stationary
sources falling within particular industrial categories. NSPSs are based on the
pollution control technology available to that category of industrial source but
allow the affected industries the flexibility to devise a cost-effective means of
reducing emissions.
September 1995
52
SIC 7216
-------
Notebook Project
J)ry Cleaning
Under Title I, EPA establishes and enforces National Emission Standards for
Hazardous Air Pollutants (NESHAPs), nationally uniform standards oriented
towards controlling particular hazardous air pollutants (HAPs). Title III of
the CAAA further directed EPA to develop a list of sources that emit any of
189 HAPs, and to develop regulations for these categories of sources. To
date EPA has listed 174 categories and developed a schedule for the
establishment of emission standards. The emission standards will be
developed for both new and existing sources based on "maximum achievable
control technology" (MACT). The MACT is defined as the control
technology achieving the maximum degree of reduction in the emission of the
HAPs, taking into account cost and other factors.
Title II of the CAA pertains to mobile sources, such as cars, trucks, buses,
and planes. Reformulated gasoline, automobile pollution control devices, and
vapor recovery nozzles on gas pumps are a few of the mechanisms EPA uses
to regulate mobile air emission sources.
Title IV establishes a sulfur dioxide emissions program designed to reduce the
formation of acid rain. Reduction of sulfur dioxide releases will be obtained
by granting to certain sources limited emissions allowances, which, beginning
in 1995, will be set below previous levels of sulfur dioxide releases.
Title V of the CAAA of 1990 created a permit program for all "major
sources" (and certain other sources) regulated under the CAA. One purpose
of the operating permit is to include in a single document all air emissions
requirements that apply to a given facility. States are developing the permit
programs in accordance with guidance and regulations from EPA. Once a
State program is approved by EPA, permits will be issued and monitored by
that State.
Title VI is intended to protect stratospheric ozone by phasing out the
manufacture of ozone-depleting chemicals and restrict their use and
distribution. Production of Class I substances, including 15 kinds of
chlorofluorocarbons (CFCs), will be phased out entirely by the year 2000,
while certain hydrochlorofluorocarbons (HCFCs) will be phased out by 2030.
EPA's Control Technology Center, at (919) 541-0800, provides general
assistance and information on CAA standards. The Stratospheric Ozone
Information Hotline, at (800) 296-1996, provides general information about
regulations promulgated under Title VI of the CAA, and EPA's EPCRA
Hotline, at (800) 535-0202, answers questions about accidental release
prevention under CAA §112(r). In addition, the Technology Transfer
Network Bulletin Board System (modem access (919) 541-5742)) includes
recent CAA rules, EPA guidance documents, and updates of EPA activities.
September 1995
53
SIC 7216
-------
Sector Notebook Project
Dry Cleaning
VLB. Industry Specific Regulatory Requirements
The dry cleaning industry is becoming increasingly regulated at the Federal,
State and local levels. Some of the regulations are directed specifically at dry
cleaners such as the new National Emission Standard for Hazardous Air
Pollutants (NESHAP) for Perchloroethylene Dry Cleaning. Other regulations
are more general but are also likely to affect a significant part of the industry
such as standards on underground tank storage. The major Federal laws that
affect dry cleaners are identified below, as well as a few state regulations that
may be indicators of national trends.
Occupational Safety and Health Act
The Occupational Safety and Health Administration proposed a 25 part per
million permissible exposure level (PEL) for perchloroethylene that was to
take effect on January 19, 1989. Before December 31, 1993, the PEL could
be met by using personal protective equipment; however, after that date the
PEL needed to be met by controls. Development of new dry cleaning
machines (fourth generation) with recycling air and additional controls was
underway to meet the requirement when the proposed limit was remanded in
March 23, 1993, because of legal and administrative technicalities. The PEL
reverted to 100 ppm; however, some states have already included the 25 ppm
level in their regulations.
Clean Air Act Amendments of 1990
A number of provisions of the Clean Air Act Amendments (CAAA) of 1990
affect the dry cleaning industry. The most recent is the September 1993
promulgation of the National Emission Standards for Hazardous Air
Pollutants (NESHAP) for the Perchloroethylene Dry Cleaning Industry
covering the 80 percent of the industry that uses perchloroethylene solvent.
These standards prohibit the sale of new transfer machines (although existing,
those machines installed prior to December 1993, transfer machines are
allowed), require retrofitting of existing (defined as installed prior to
December 1993) dry cleaning equipment with control devices (if they fall
under the large area and major source classifications) and require new
machines to be sold with such technology (40 CFR §63.320). Title VI of the
Clean Air Act Amendments of 1990 calls for a ban on chlorofluorocarbons in
the year 2000 and on trichloroethane in 2002 because of their ozone depleting
potential. In February of 1992, President Bush announced that the ban on
CFCs and TCA would be effective in the United States on December 31,
1995. The Agency also issued New Source Performance Standards (NSPS)
for petroleum-based dry cleaners in 1984 (petroleum-based dry cleaners
represent less than 15 percent of the market) (49 FR 37328). These are
applicable in CAA non-attainment areas and may also have been adopted by
September 1995
54
SIC 7216
-------
Sector Notebook Project
Dry Cleaning
individual states. They set limits on solvent loss from drying, set standards on
the use of filters, and require leaks to be repaired in a timely fashion. Dry
cleaners must add control devices to reduce solvent loss from the washer and
dryer as well as the filters. In addition, they must monitor their machines
more closely for leaks.
Comprehensive Environmental Response, Compensation and Liability Act (1980) and Superfund
Amendments and Reauthorization Act (1986)
Dry cleaners or their landlords may be held joint and severally liable for
perchloroethylene contamination of the site under the Comprehensive
Environmental Response, Compensation and Liability Act (Superfund) (40
CFR §305). The contamination may occur by having PCE containing waste
water leak through sewer pipes or by leaks of PCE during normal operation.
Resource Conservation and Recovery Act
Under the Resource Conservation and Recovery Act (RCRA) dry cleaners
who generate 100 kilograms (220 pounds) or more of perchloroethylene solid
wastes (hazardous waste code D039) such as still bottoms, cartridge filters
and filter muck each month are regulated under RCRA and must dispose of
their wastes at a licensed hazardous waste facility (40 CFR. §260-270). Small
quantity generators are defined as those who generate less than 100 kilograms
and are exempt from this regulation (40 CFR §261.5). The slightly
contaminated waste water generated by dry cleaners from various sources is
considered hazardous waste under RCRA because it was derived from an
F002 waste. The toxicity characteristic leaching procedure (TC) cutoff for
perchloroethylene is 0.7 ppm. Typical separator water contains about 150
ppm and is therefore considered hazardous because it exceeds the TC level.
Underground Storage Tanks
Dry cleaning facilities that store either petroleum or perchloroethylene in an
underground storage tank are subject to the Agency's underground storage
tank regulations which require that the tank must be protected from
corrosion, be equipped with devices that prevent spills and overfills and must
have a leak detection method that provides monitoring for leaks at least every
30 days (40 CFR §265.190-196).
Clean Water Act
Discharges to a POTW - Facilities discharging wastewater to a sewer are
often subject to restrictions required under the Clean Water Act (CWA).
These restrictions are established by the local sewerage authority to prevent
significant interference with the treatment facility or pass-through of
September 1995
55
SIC 7216
-------
Sector Notebook Project
Dry Cleaning
pollutants not removed by treatment (40 CFR §125). The specific
requirements include: notifying the POTW of discharges that could cause
problems at the POTW, monitoring and record keeping as established by the
POTW and a one-time notice of the discharge of hazardous waste, specifically
if more than 33 pounds/month.
State Regulations
New York
California
Several states have developed additional dry cleaning regulations. New York
and California serve as examples.
A negotiating committee of organizations representing dry cleaners,
equipment manufacturers, consumer interests and regulatory agencies reached
conceptual agreement in March 1994 on revised regulations to control
emissions from dry cleaning facilities in New York State. The regulations
include requirements for operator training and certification, equipment
certification, inspection and monitoring., and stringent new equipment
standards which include the retrofitting of existing equipment. A finalized
draft will be released before the end of the year for public comment.
The agreement calls for the phased replacement of older dry cleaning
equipment with state-of-the-art closed-loop machines that use a refrigerated
condenser and an integrated carbon adsorber. The regulations call for the
complete phase out of older transfer machines by 1996, the addition of vapor
barriers or room enclosures by late 1995 for dry cleaners using older
machines, and room ventilation systems providing a complete air exchange
every five minutes.
The agreement specifies that manufacturers and/or vendors of new dry
cleaning equipment must have their equipment tested and certified that it
meets certain standards before it can be installed. The committee is
developing new standards covering the operation and maintenance of dry
cleaning facilities that will go into effect in 1996. (Contacts: Lenore Kuwik
518-457-2224 and Michael Barylski 607-753-3095 at the NY State
Department of Environmental Conservation)
The California regulations are contained in the Airborne Toxic Control
Measure (CATCM) for Emissions of Perchloroethylene from Dry Cleaning
Operations (17 and 25 CCR §93109). The requirements for existing and new
facilities regarding dry cleaning equipment include initial notification of
installation, annual reporting to the state, maintenance of good operating
September 1995
56
SIC 7216
-------
Sector Notebook Project
Dry Cleaning
practices to reduce emissions, and fugitive emissions control when applying
water repellent using PCE as the solvent. Existing facilities must use either
a converted closed-loop machine with a primary control system or a closed-
loop machine with a primary control system. New facilities are required to
use a closed-loop machine with both primary and secondary control systems
once their district's have approved the ATCM.
Districts within California are allowed to supersede the ATCM if district
regulations are more stringent than State regulations. At this time, only the
Bay Area and the South Coast Air Quality Management Districts have
proposals to supersede the ATCM; other districts are assumed to be following
the ATCM. (Contact: Todd Wong, California Air Resources Board 916
322-8285)
The Bay Area Air Quality Management District (BAAQMD) has
proposed stricter controls than the ATCM including secondary controls and
vapor barrier rooms in residential facilities and ventilation systems in non-
residential facilities. They also allow evaporators to be used with certain
minor criteria attached. (Contact: Scott Lutz, Bay Area Air Quality
Management District, 415-749-4676)
The South Coast Air Quality Management District (SQAQMD) Proposal
1421 includes the control requirements in California's ATCM while keeping
the NESHAP requirements for record keeping, inspection, and repair.
Reporting requirements are derived from a combination of both the NESHAP
and the ATCM. Specifically, Proposal 1421 requires that relocating facilities
obtain a permit as if they were new facilities, waste water elimination systems
be used, and facilities keep records of their solvent use for five years.
The SCAQMD is also creating the requirements for establishing a list of
approved equipment. The basic structure is that the manufacturers/
distributors will demonstrate the 1421 compliance of their equipment. Once
the equipment has been approved, it will be added to the list of equipment
considered in compliance with the regulations. The SCAQMD hopes this will
facilitate dry cleaner adherence to the regulations. (Contact: Pierre Sycip,
South Coast Air Quality Management District, 909-396-3095)
VI.C. Pending and Proposed Regulatory Requirements
Petroleum solvents are currently regulated under the new source performance
standards for VOCs and will be listed as a source category for toxic
substances in the year 2000. (Contact: Steve Shedd U S EPA, 919-541-
5397)
September 1995
57
SIC 7216
-------
-------
Sector Notebook Project
Dry Cleaning
VH. COMPLIANCE AND ENFORCEMENT HISTORY
Background
To date, EPA has focused much of its attention on measuring compliance
with specific environmental statutes. This approach allows the Agency to
track compliance with the Clean Air Act, the Resource Conservation and
Recovery Act, the Clean Water Act, and other environmental statutes. Within
the last several years, the Agency has begun to supplement single-media
compliance indicators with facility-specific, multimedia indicators of
compliance. In doing so, EPA is in a better position to track compliance with
all statutes at the facility level, and within specific industrial sectors.
A major step in building the capacity to compile multimedia data for industrial
sectors was the creation of EPA's Integrated Data for Enforcement Analysis
(IDEA) system. IDEA has the capacity to "read into" the Agency's single-
media databases, extract compliance records, and match the records to
individual facilities. The IDEA system can match Air, Water, Waste,
Toxics/Pesticides/EPCRA, TRI, and Enforcement Docket records for a given
facility, and generate a list of historical permit, inspection, and enforcement
activity. IDEA also has the capability to analyze data by geographic area and
corporate holder. As the capacity to generate multimedia compliance data
improves, EPA will make available more in-depth compliance and
enforcement information. Additionally, sector-specific measures of success
for compliance assistance efforts are under development.
Compliance and Enforcement Profile Description
Using inspection, violation and enforcement data from the IDEA system, this
section provides information regarding the historical compliance and
enforcement activity of this sector. In order to mirror the facility universe
reported in the Toxic Chemical Profile, the data reported within this section
consists of records only from the TRI reporting universe. With this decision,
the selection criteria are consistent across sectors with certain exceptions.
For the sectors that do not normally report to the TRI program, data have
been provided from EPA's Facility Indexing System (FINDS) which tracks
facilities in all media databases. Please note, in this section, EPA does not
attempt to define the actual number of facilities that fall within each sector.
Instead, the section portrays the records of a subset of facilities within the
sector that are well defined within EPA databases.
As a check on the relative size of the full sector universe, most notebooks
contain an estimated number of facilities within the sector according to the
Bureau of Census (See Section II). With sectors dominated by small
businesses, such as metal finishers and printers, the reporting universe within
September 1995
59
SIC 7216
-------
Sector Notebook Project
Dry Cleaning
the EPA databases may be small in comparison to Census data. However, the
group selected for inclusion in this data analysis section should be consistent
with this sector's general make-up.
Following this introduction is a list defining each data column presented
within this section. These values represent a retrospective summary of
inspections and enforcement actions, and solely reflect EPA, State, and local
compliance assurance activities that have been entered into EPA databases.
To identify any changes in trends, the EPA ran two data queries, one for the
past five calendar years (August 10, 1990 to August 9, 1995) and the other
for the most recent twelve-month period (August 10, 1994 to August 9,
1995). The five-year analysis gives an average level of activity for that period
for comparison to the more recent activity.
Because most inspections focus on single-media requirements, the data
queries presented in this section are taken from single media databases. These
databases do not provide data on whether inspections are state/local or EPA-
led. However, the table breaking down the universe of violations does give
the reader a crude measurement of the EPAs and states' efforts within each
media program. The presented data illustrate the variations across regions for
certain sectors.6 This variation may be attributable to state/local data entry
variations, specific geographic concentrations, proximity to population
centers, sensitive ecosystems, highly toxic chemicals used in production, or
historical noncompliance. Hence, the exhibited data do not rank regional
performance or necessarily reflect which regions may have the most
compliance problems.
This section provides summary information about major cases that have
affected this sector, and a list of Supplementary Environmental Projects
(SEPs). SEPs are compliance agreements that reduce a facility's stipulated
penalty in return for an environmental project that exceeds the value of the
reduction. Often, these projects fund pollution prevention activities that can
significantly reduce the future pollutant loadings of a facility.
The final part of this section provides highlights from interviews with several
knowledgeable EPA inspectors. These interviews provide the inspector's
viewpoint on where compliance problems occur, why they occur, and possible
solutions to eliminate these problems. The reader should not reach any
definitive conclusions about an industry sector's ability or willingness to
c EPA Regions include the Mowing states: I (CT, MA, ME, RI, NH, VT); H (NJ, NY, PR, VI); III (DC, DE, MD, PA, VA,
WV); IV (AL. PL, GA, KY, MS, NC, SC, TN); V (IL, IN, MI, MN, OH, WI); VI (AR, LA, NM, OK, TX); VII (IA, KS,
MO, ME); VIII (CO, MT, ND, SD, UT, WY); IX (AZ, CA, HI, NV, Pacific Trust Territories); X (AK, ID, OR, WA).
September 1995
60
SIC 7216
-------
Sector Notebook Project
Dry Cleaning
comply based on these interviews. These interviews provide only anecdotal
information about the interactions occurring between inspectors and the
facilities they inspect.
Compliance and Enforcement Data Definitions
General Definitions
Facility Indexing System (FINDS) - this system assigns a common facility
number to EPA single-media permit records. The FINDS identification
number allows EPA to compile and review all permit, compliance,
enforcement and pollutant release data for any given regulated facility.
Integrated Data for Enforcement Analysis (IDEA) - is a data integration
system that can retrieve information from the major EPA program office
databases. IDEA uses the FINDS identification number to "glue together"
separate data records from EPA's databases. This is done to create a "master
list" of data records for any given facility. Some of the data systems
accessible through IDEA are: AIRS (Air Facility Indexing and Retrieval
System, Office of Air and Radiation), PCS (Permit Compliance System,
Office of Water), RCRIS (Resource Conservation and Recovery Information
System, Office of Solid Waste), NCDB (National Compliance Data Base,
Office of Prevention, Pesticides, and Toxic Substances), CERCLIS
(Comprehensive Environmental and Liability Information System, Superfund),
and TRIS (Inventory System). IDEA also contains information from outside
sources such as Dun and Bradstreet and the Occupational Safety and Health
Administration (OSHA). Most data queries displayed in notebook sections
IV and VII were conducted using IDEA.
Data Table Column Heading Definitions
Facilities in Search - are based on the universe of TRI reporters within the
listed SIC code range. For industries not covered under TRI reporting
requirements, the notebook uses the FINDS universe for executing data
queries. The SIC code range selected for each search is defined by each
notebook's selected SIC code coverage described in Section II.
Facilities Inspected ~ indicates the level of EPA and state agency facility
inspections for the facilities in this data search. These values show what
percentage of the facility universe is inspected in a 12 or 60 month period.
This column does not count non-inspectional compliance discharge reports.
Number of Inspections -- measures the total number of inspections
conducted in this sector. An inspection event is counted each time it is
entered into a single media database.
September 1995
61
SIC 7216
-------
Sector Notebook Project
Dry Cleaning
Average Time Between Inspections — provides an average length of time,
expressed in months, that a compliance inspection occurs at a facility within
the defined universe.
Facilities with One or More Enforcement Actions — expresses the number
of facilities that were party to at least one enforcement action within the
defined time period. This category is broken down further into federal and
state actions. Data are obtained for administrative, civil/judicial, and criminal
enforcement actions. Administrative actions include Notices of Violation
(NOVs). A facility with multiple enforcement actions is only counted once
in this column (facility with three enforcement actions counts as one). All
percentages that appear are referenced to the number of facilities inspected.
Total Enforcement Actions ~ describes the total number of enforcement
actions identified for an industrial sector across all environmental statutes. A
facility with multiple enforcement actions is counted multiple times (a facility
with three enforcement actions counts as three).
State Lead Actions — shows what percentage of the total enforcement
actions are taken by state and local environmental agencies. Varying levels
of use by states of EPA data systems may limit the volume of actions
accorded state enforcement activity. Some states extensively report
enforcement activities into EPA data systems, while other states may use their
own data systems.
Federal Lead Actions -- shows what percentage of the total enforcement
actions are taken by the United States Environmental Protection Agency.
This value includes referrals from state agencies. Many of these actions result
from coordinated or joint state/federal efforts.
Enforcement to Inspection Rate — expresses how often enforcement actions
result from inspections. This value is a ratio of enforcement actions to
inspections, and is presented for comparative purposes only. This measure
is a rough indicator of the relationship between inspections and enforcement.
This measure simply indicates historically how many enforcement actions can
be attributed to inspection activity. Reported inspections and enforcement
actions under the Clean Water Act (PCS), the Clean Air Act (AFS) and the
Resource Conservation and Recovery Act (RCRA) are included in this ratio.
Inspections and actions from the TSCA/FDFRA/EPCRA database are not
factored into this ratio because most of the actions taken under these
programs are not the result of facility inspections. This ratio does not account
for enforcement actions arising from non-inspection compliance monitoring
activities (e.g., self-reported water discharges) that can result in enforcement
action within the CAA, CWA and TSCA.
September 1995
62
SIC 7216
-------
Sector Notebook Project
Pry Cleaning
Facilities with One or More Violations Identified ~ indicates the number
percentage of inspected facilities having a violation identified in one of the
following data categories: In Violation or Significant Violation Status
(CAA);ReportableNoncompliance, Current Year Noncompliance, Significant
Noncompliance (CWA); Noncompliance and Significant Noncompliance
(FIFRA, TSCA, and EPCRA); Unresolved Violation and Unresolved High
Priority Violation (RCRA). The values presented for this column reflect the
extent of noncompliance within the measured time frame, but do not
distinguish between the severity of the noncompliance. Percentages within
this column may exceed 100 percent because facilities can be in violation
status without being inspected. Violation status may be a precursor to an
enforcement action, but does not necessarily indicate that an enforcement
action will occur.
Media Breakdown of Enforcement Actions and Inspections ~ four
columns identify the proportion of total inspections and enforcement actions
within EPA Air, Water, Waste, and TSCA/FIFRA/EPCRA databases. Each
column is a percentage of either the "Total Inspections," or the "Total
Actions" column.
VILA. Dry Cleaning Industry Compliance History
Exhibit 17 provides an overview of the reported compliance and enforcement
data for the dry cleaning industry over the past five years (August 1990 to
August 1995). These data are also broken out by EPA Region thereby
permitting geographical comparisons. A few points evident from the data are
listed below.
• Within the limited universe of dry cleaning facilities retrieved from the
database search, the number of dry cleaning facilities inspected was
only 26 percent of those identified. In the past five years, the facilities
identified were inspected on average every seven to eight years.
• A significantly larger proportion of facilities identified in the database
search had been inspected than had enforcement actions brought
against them.
• State lead enforcement actions accounted for almost all of the
enforcement actions brought against dry cleaning facilities over the
five year period.
September 1995
63
SIC 7216
-------
Dry Cleaning
61
S3
S
U
ft
S
S
n
00
•rr
-
S
o
o
I
*
cs
00
CO
es
^
8
«/p
>
S
o
o
1
^
1—4
1
,
ON
OO
oo
^
1
,
1
o
o
0)
o
VO
oo
hM
i>
i
i
i
0
0
8
oo
vo
3
H""
^
!$
o
0
>/i
^
0)
^H
?s
in
-<
ts
.
ft
!
i
0
0
§
CO
CO
S
X
» — 1
o
r-H
ON
o\
8
ON
00
OO
CO
CO
VO
cs
CO
CO
H
H
September 1995 64
SIC 7216
-------
Sector Notebook Project
Dry Cleaning
VII.B. Comparison of Enforcement Activity Between Selected Industries
Exhibits 18 and 19 allow the compliance history of the dry cleaning industry
to be compared to the other industries covered by the industry sector
notebooks. Comparisons between Exhibits 18 and 19 permit the identification
of trends in compliance and enforcement records of the industry by comparing
data covering the last five years to that of the past year. Some points evident
from the data are listed below.
• Of those sectors listed, the dry cleaning industry has been the least
frequently inspected industry over the past five years. The average
time between inspections for the facilities identified is 88 months.
• The industry has a relatively small percentage of facilities with
violations and enforcement actions, in comparison to the other
sectors.
• The rate of enforcement actions per inspection over the past five years
is relatively high for the industry, but has decreased over the past year.
Exhibits 20 and 21 provide a more in-depth comparison between the dry
cleaning industry and other sectors by breaking out the compliance and
enforcement data by environmental statute. As in the previous Exhibits
(Exhibits 18 and 19), the data cover the last five years (Exhibit 20) and the
last one year (Exhibit 21) to facilitate the identification of recent trends. A
few points evident from the data are listed below.
• The number of inspections carried out under each environmental
statute as a percent of the total number of inspections has changed
only slightly between the average of the past five years and that of the
past year.
• The number of enforcement actions taken under RCRA dominate both
the percentage of inspections as well as the percentage of enforcement
actions.
• In the past year there has been a significant drop in the proportions of
enforcement actions taken under RCRA from the average of the past
five years, primarily resulting from an increase in enforcement actions
taken under CWA.
September 1995
65
SIC 7216
-------
Sector Notebook Project
Dry Cleaning
•4-J
CA
3
«
r™~5
&
S
o
u
H3
CS
1
W
c
«
0>
>
to
co
-*-
s
M
X
*-»
1— 1
W
O
fe
W
Q
U
M
^
c- O
B T: o
g ° |«
"g j|
w
ag-oS
Si3|
•o
•»£ cs w
C =i C
W >J o
E « «
£B3
W
1
1 §1
*"* <2 •<;
w
€ **
^ 2 g «
^ ^^ u >r*
tc ^^ ti *•*
i3 o tS •<£
|rt rH fl
fe ^
0 d S
2t£j ej ^C
? 8 1 §,
"* "I
•s a
fc, 0
S tc
r\ u
il
ii
=i i.
Ss
l-g
^ J
ta.S
Industry Sector
en
0
cs
oo
S
2
m
VO
VO
m
m
S
CO
Pulp and Paper
r— 1
O
°->
0?
m
oo
in
vo
cs
in
m
"*
m
en
o
i — t
vo
o
•*
bO
_c
1
en
O
1
1
CS
ON
ON
i — t
i — t
en
o
en
oo
ON
OO
in
crt
"ca
o
Inorganic Chemi
ON
0
en
0?
VO
VO
f-
CS
m
vo
vS
oo
en
vo
en
cs
i— i
*ca
Organic Chemic
in
O
en
vo
r-
ON
r-
o
en
m
cs
en
in
vo
bO
C
Petroleum Refini
^.
o
g
CS
CS
r-
ON
ON
m
vo
CO
•— '
F*
.1
1 Non-Metallic M
Mining
cs
o
CS
0s
ON
CS
en
cs
oo
c-
m
ON
00
1—1
1 — 1
o
en
1
•8
|| Lumber and Wo
vo
O
O
0?
ON
0?
T— t
ON
t — 1
ON
en
|~~]
en
j~t
en
t-H
CS
en
ON
cs
Furniture
CS
o
0?
CS
CS
=?
00
r-
r— 4
ON
en
vo
o
en
vo
00
en
en
ON
en
r-
in
vo
r~t
c
Rubber and Plas
CS
i — i
0
en
1
o
en
en
r-
^
m
cs
00
VO
CS
00
GO
V.
&
s
f
R
>
C
m
o
i
0?
O
OO
o
o
s
£
ON
o
m
o
en
cs
Fabricated Meta
2
0
CS
g
^
1— 1
VO
r-
ON
?
OO
Nonferrous Met
^
o
CS
r-
cs
CS
oo
VO
T— I
en
c-
cs
cs
cs
m
Electronics
1 |
o
i
cs
1
o
1—4
OO
s
vo
cs
o
ON
en
oo
ON
|| Automobiles
September 1995
66
SIC 1216
-------
Sector ISotebook Project
Dry Cleaning
1*3
.2
+•>
j3
H^
Jfl
*G
*
JX3
.
£
c3
^
3
cc
i
1
g
1
w
id
o
•w3
ft
c3
>H
-------
Sector Notebook Project
Dry Cleaning
8
I
p
•8
w
««« "3 S3
0 -S .2
§
Si
Ii
<2i
II
Si
s;
s
i
i
3
a
<*- rS S
0 -2 .2
ii
o a,
s;
Si
Si
<« —j a
0 -2 .2
•s
Si
S?
Si
I
J-!
«
all
S
g
•a
•4^
O
c—
•*
cs"
i I
u &
(25
1
I
41
m
Ind
O
etallic
l ini
o
-------
Sector Notebook Project
Pry Cleaning
0)
B
56
-d
n
en
so
0s-
VO
eS
5
7
S
§
O
h
d
cs
d
o
U
#1
I
^
OS
VO
SP
0s-
OO
s=
OS
1 1
sD
in
sP
0s-
OS
VO
5?
1
JH
9$
d
O
1
en
in
es
CO
a
&
pi
g
Dry Cle
ber
F
Rubber and P
Nonfe
September 1995
69
SIC 7216
-------
Sector Notebook Project
Dry Cleaning
VII.C. Review of Major Legal Actions
This section provides summary information about major cases that have
affected this sector, and a list of Supplementary Environmental Projects
(SEPs). SEPs are compliance agreements that reduce a facility's stipulated
penalty in return for an environmental project that exceeds the value of the
reduction. Often, these projects fund pollution prevention activities that can
significantly reduce the future pollutant loadings of a facility.
VH.C.1. Review of major cases
Historically, OECA's Office of Regulatory Enforcement does not regularly
compile information related to major cases and pending litigation within an
industry sector. The staff are willing to pass along such information to
Agency staff as requests are made. In addition, summaries of completed
enforcement actions are published each fiscal year in the Enforcement
Accomplishments Report. To date, these summaries are not organized by
industry sector. (Contact: Office of Enforcement Capacity and Outreach,
202-260-4140)
VU.C.2. Supplementary Environmental Projects (SEPs)
Each Region's summary of Supplemental Environmental Projects (SEPs)
undertaken in federal fiscal years 1993 and 1994 were reviewed. None was
identified as being applied to a dry cleaning operation or establishment. Many
process changes have been demonstrated which may be suitable for use as
SEPs (see Pollution Prevention Opportunities - Section V.). However,
because federal enforcement actions within the dry cleaning industry are few
(one during the period from 1989-1994), the chances that SEPs are
recommended or adopted for dry cleaners is reduced.
September 1995
70
SIC 7216
-------
Sector Notebook Project
Dry Cleaning
COMPLIANCE ASSURANCE ACTIVITIES AND INITIATIVES
This section highlights the activities undertaken by this industry sector and
public agencies to voluntarily improve the sector's environmental
performance. These activities include those independently initiated by
industrial trade associations. In this section, the notebook also contains a
listing and description of national and regional trade associations.
VHI.A. Sector-related Environmental Programs and Activities
Design for the Environment
The Environmental Protection Agency's Design for the Environment (DfE)
program uses a non-regulatory, voluntary, and pro-active approach in
working with industry and environmental and human health groups to reduce
risk. The Design for the Environment (DfE) program was created by the
Office of Pollution Prevention and Toxics of the U.S. Environmental
Protection Agency in 1992 to promote the incorporation of pollution
prevention principles in the design of products and processes through
voluntary partnerships with industry, professional organizations, state and
local governments, other federal agencies, and the public. The DfE provides
businesses with the information needed to design for the environment and to
help businesses use this information to make environmentally informed
choices. The DfE program also works to make sure that the information
reaches the people who make the choices - from buyers to industrial design
engineers.
The Dry Cleaning (DfE) program has identified control technologies and
alternative solvents and processes that might be used to reduce solvent
releases from the industry. The Agency is evaluating the risks, costs and
benefits of each alternative (including setting up an alternative process
demonstration) and will publicize the results so that individual dry cleaners
can understand the pros and cons of each alternative. Examples of the DfE's
work in the dry cleaning industry include the following:
The DfE convened the International Roundtable of Pollution Prevention and
Control in the Dry Cleaning Industry. Researchers, industry representatives,
and government officials met to exchange information on issues related to the
dry cleaning industry, including exposure reduction, regulation, and
information dissemination.
The DfE program is producing a Cleaner Technologies Substitute Assessment
(CTS A) for the dry cleaning industry to examine both existing and emerging
technologies. The Agency expects to release a draft CTSA on existing
technologies and another on emerging technologies sometime in 1995. The
first phase of the CTSA will examine traditional, solvent-based technologies.
September 1995
71
SIC 7216
-------
Sector Notebook Project
Dry Cleaning
The new or alternative technologies, such as multiprocess wet cleaning,
machine wet cleaning, liquid carbon dioxide technology, and microwave
drying will be addressed in the second phase of the CTSA.
In November and December of 1992, the DfE program, in collaboration with
the dry cleaning industry, conducted a short term, high volume demonstration
to compare the costs and performance of an aqueous alternative process
(multiprocess wet cleaning) to the traditional dry cleaning method that uses
perchloroethylene.
As part of the Agency's outreach program, the DfE partnership produced a
wet cleaning brochure entitled Summary of a Report on Multiprocess Wet
Cleaning, to assist dry cleaners and consumers in learning more about how
their choices and actions can affect the environment. The Agency also has
distributed brochures and fact sheets on alternative cleaning processes,
compiled case studies and success stories, and produced exhibits at trade
shows to keep the public and the dry cleaning industry informed of the DfE
project's activities.
To further test the viability of the wet cleaning process, the Agency has
launched a two-year demonstration project in three demonstration sites
around the United States that will establish the performance of wet cleaning
methods under "real world" conditions. Two demonstration sites will test the
full range of garments typically handled by professional clothes cleaners using
only various wet cleaning technologies/techniques; while the one site will offer
both wet and dry cleaning services. Technologies to be tested include:
multiprocess wet cleaning; machine-based wet cleaning; and microwave
drying to be used in combination with both cleaning methods.
The DfE project is developing a certification program centered around solvent
use reduction, worker safety, and consumer awareness.
The Agency currently is working with the Federal Trade Commission on the
labeling of "Dry Clean Only" garments. Public comments are being reviewed
regarding proposed changes that attempt to allow for other forms of cleaning
without increasing the liability of the dry cleaner. Currently, if a "Dry Clean
Only" garment is damaged when cleaned using an alternative method, the dry
cleaner is held liable. If the same garment is damaged during the dry cleaning
process, the manufacturer is held liable. Proposed changes will make the
garment label less restrictive and allow other forms of cleaning to be used
without penalty. (Contact: Pollution Prevention Clearinghouse, PPIC, 202-
260-1023)
September 1995
72
SIC 7216
-------
Sector Notebook Project
Dry Cleaning
VTH.B. EPA Voluntary Programs
33/50 Program
The "33/50 Program" is EPA's voluntary program to reduce toxic chemical
releases of eighteen chemicals from manufacturing facilities. Participating
companies pledge to reduce their toxic chemical releases by 33 percent as of
1992 and by 50 percent as of 1995. Certificates of Appreciation have been
given out to participants meeting their 1992 goals. The list of chemicals
includes seventeen high-use chemicals reported (including perchloroethylene)
in the Toxics Release Inventory and dioxin. Because dry cleaning is a service,
dry cleaners are not eligible for the 33/50 program even though
perchloroethylene is covered by the program. (Contact: Mike Burns 202-260-
6394 or 33/50 Program 202-260-6907)
Environmental Leadership Program
Project XL
The Environmental Leadership Program (ELP) is a national initiative piloted
by EPA and state agencies in which facilities have volunteered to demonstrate
innovative approaches to environmental management and compliance. EPA
has selected 12 pilot projects at industrial facilities and federal installations
which will demonstrate the principles of the ELP program. These principles
include: environmental management systems, multimedia compliance
assurance, third-party verification of compliance, public measures of
accountability, community involvement, and mentor programs. In return for
participating, pilot participants receive public recognition and are given a
period of time to correct any violations discovered during these experimental
projects. At this time, no dry cleaning operations are ELP participants.
(Contact: Tai-ming Chang, ELP Director, 202-564-5081 or Robert Fentress,
U.S. EPA, 202-564-7023)
Project XL was initiated in March 1995 as a part of President Clinton's
Reinventing Environmental Regulation initiative. The projects seek to
achieve cost effective environmental benefits by allowing participants to
replace or modify existing regulatory requirements on the condition that they
produce greater environmental benefits. EPA and program participants will
negotiate and sign a Final Project Agreement, detailing specific objectives that
the regulated entity shall satisfy. In exchange, EPA will allow the participant
a certain degree of regulatory flexibility and may seek changes in underlying
regulations or statutes. Participants are encouraged to seek stakeholder
support from local governments, businesses, and environmental groups. EPA
hopes to implement fifty pilot projects in four categories including facilities,
sectors, communities, and government agencies regulated by EPA.
Applications will be accepted on a rolling basis and projects will move to
September 1995
73
SIC 7216
-------
r
Sector Notebook Project
Dry Cleaning
implementation within six months of their selection. For additional
information regarding XL Projects, including application procedures and
criteria, see the May 23, 1995, Federal Register Notice, or contact Jon
Kessler at EPA's Office of Policy Analysis 202-260-4034.
Green Lights Program
EPA's Green Lights program was initiated in 1991 and has the goal of
preventing pollution by encouraging U.S. institutions to use energy-efficient
lighting technologies. The program has over 1,500 participants which include
major corporations; small and medium sized businesses; federal, State and
local governments; non-profit groups; schools; universities; and health care
facilities. Each participant is required to survey their facilities and upgrade
lighting wherever it is profitable. EPA provides technical assistance to the
participants through a decision support software package, workshops and
manuals, and a financing registry. EPA's Office of Air and Radiation is
responsible for operating the Green Lights Program. (Contact: Maria Tikoff
at 202-233-9178 or the Green Light/Energy Star Hotline at 202-775-6650)
WasteWiSe Program
The WasteWiSe Program was started in 1994 by EPA's Office of Solid Waste
and Emergency Response. The program is aimed at reducing municipal solid
wastes by promoting waste minimization, recycling collection and the
manufacturing and purchase of recycled products. As of 1994, the,program
had about 300 companies as members, including a number of major
corporations. Members agree to identify and implement actions to reduce
their solid wastes and must provide EPA with their waste reduction goals
along with yearly progress reports. EPA, in turn, provides technical
assistance to member companies and allows the use of the WasteWiSe logo
for promotional purposes. (Contact: Lynda Wynn 202-260-0700 or the
WasteWiSe Hotline at 800-372-9473)
Climate Wise Recognition Program
The Climate Change Action Plan was initiated in response to the U.S.
commitment to reduce greenhouse gas emissions in accordance with the
Climate Change Convention of the 1990 Earth Summit. As part of the
Climate Change Action Plan, the Climate Wise Recognition Program is a
partnership initiative run jointly by EPA and the Department of Energy. The
program is designed to reduce greenhouse gas emissions by encouraging
reductions across all sectors of the economy, encouraging participation in the
full range of Climate Change Action Plan initiatives, and fostering innovation.
Participants in the program are required to identify and commit to actions that
reduce greenhouse gas emissions. The program, in turn, gives organizations
early recognition for their reduction commitments; provides technical
September 1995
74
SIC 7216
-------
Sector ISotebook Project
Dry Cleaning
assistance through consulting services, workshops, and guides; and provides
access to the program's centralized information system. At EPA, the program
is operated by the Air and Energy Policy Division within the Office of Policy
Planning and Evaluation. (Contact: Pamela Herman 202-260-4407)
Office of Enforcement Compliance Assurance
The Office of Compliance is compiling a list of resource materials on pollution
prevention and contacts in the dry cleaning industry. This is the first of
several projects planned to help reduce risk from dry cleaners. (Contact:
Joyce Chandler 202-564-7073)
VHI.C. Trade Association/Industry Sponsored Activity
Vm.C.l. Environmental programs
Several trade associations including the Neighborhood Cleaner's Association,
the International Fabricare Institute (IFI) and the state and regional affiliates
of IFI have instituted environmental programs. Theses include: introducing
an environmental certificate program that provides members information on
good environmental practices and then tests them on this knowledge, training
sessions in alternative technologies, and information pamphlets on
environmental laws and compliance. The additional trade association
activities are listed below.
Vm.C.2. Summary of trade associations
Neighborhood Cleaners Association (NCA)
252 West 29th Street
New York, NY 10001-5201
Tel: (212) 967-3002
Contact: Bill Seitz
The NCA is a worldwide trade organization with over 4,000 members. NCA
provides outreach to its members through monthly bulletins, through the
NCA's Consumer Education Program, and educational courses on dry
cleaning issues. NCA also offers representation for its members at all levels
of government including the Federal Trade Commission.
September 1995
75
SIC 7216
-------
Sector Notebook Project
Dry Cleaning
Federation of Korean Drycleaners Association (FKDA)
25606 Alicia Pkwy
Lagona Hills, CA 92653
Tel: (714) 770-8613 Contact: Hank Kim
The FKDA was founded in 1986 and is an umbrella organization representing
30 regional Korean dry cleaning associations throughout the U.S. It
represents approximately 12,000 members, and educates its members by
providing FKDA newsletters as well as organizing educational seminars on
subjects such as pollution prevention and other critical issues.
International Fabricare Institute (EFI)
12251 Tech Road
Silver Spring, Maryland 20904
Tel: (301) 622-1900
Contact: Joe Meijer
The association is a worldwide organization of dry cleaners and launderers as
well as organizations and individuals concerned with professional garment
cleaning, care and serviceability. There are currently over 12,000 members.
The association provides publications to aid members technically and in
business, represents cleaners' interest in legislative activities, as well as
provides testing services for products and training for employees.
State Fabricare Institutes
Many states or regions have trade associations that are affiliated with the
International Fabricare Institute. For more information call the EFI.
Textile Care Allied Trade Association, Inc. (TCATA)
200 Broadacres Drive
Bloomfield, NJ 07003
Tel: (201) 338-7700 Contact: David Cotter
TCATA has existed since 1920 and represents manufacturers and distributors
of commercial laundry and dry cleaning equipment and supplies. There are
currently 275 members. Its primary concern is addressing issues that affect
the industry's allied trades exclusively. The association provides newsletters
to its members; coordinates an annual convention; co-sponsors a biennial
trade show; and provides information on machinery requirements and certain
market information.
September 1995
76
SIC 7216
-------
Sector Notebook Project
Dry Cleaning
Fabricate Legislative And Regulatory Education (FLARE)
P.O. Box 5157
Naperville, IL 60567-5157
Tel: (708) 416-6221 Contact: Manfred Wentz
FLARE is a volunteer organization led by members of International Fabricate
Institute, Neighborhood Cleaners Association, R.R. Streets and Co.( a dry
cleaning supply company), and the Textile Care Allied Trade Association.
FLARE is committed to ensuring favorable treatment by local media and
providing representation at all levels of government. The majority of their
attention currently is given to environmental legislation and regulation
affecting the fabric care industry; however, the FLARE organization is
designed to address a much broader spectrum of legislation and regulation as
well as public relations issues affecting the industry.
Center for Emission Control (CEC)
2001 L Street, N.W.
Suite 506A
Washington, DC 20036
Tel: (202) 785-4374
Contact: Steve Risotto
The CEC is an independent not-for-profit organization established in October
1990 to act as a clearinghouse for information about, and to encourage the
development and use of, safe and effective work practices, process
modifications, control technologies, and other methods to reduce emissions
of chlorinated solvent. The CEC has developed a control option document
on solvent applications in the dry cleaning industry. The organizations also
may undertake and support research and development projects for the
creation or application of new technologies or products that will reduce
emissions of chlorinated solvents.
September 1995
77
SIC 7216
-------
Sector Notebook Project
Dry Cleaning
IX. CONTACTS/ACKNOWLEDGMENTS/RESOURCE MATERIALS/BIBLIOGRAPHY
For further information on selected topics within the Dry Cleaning Industry
a list of publications and contacts are provided below:
Contacts!.
Name
Joyce Chandler
Ohad Jehassi
George Smith
Organization
EPA/OECA
EPA/OPPT
EPA/OAQPS
Telephone
(202)564-7073
(202)260-6911
(919)541-1549
Subject
Regulatory requirements and
compliance assistance
Design for the Environment
Regulatory requirements (air)
OECA: Office of Enforcement and Compliance Assurance
OAQPS: Office of Air Quality Planning and Standards
OPPT: Office of Pollution Prevention and Toxics
General Profile
Brown, Richard R. 1993. TVS Emission Reduction Technology for Dry cleaning. Presented at the
Air and Waste Management Association, 86th Annual Meeting and Exhibition, Denver Colorado,
1993.
Proceedings of the International Roundtable on Pollution Prevention and Control in the Dry Cleaning
Industry, United States Environmental Protection Agency, EPA/774/R-92/002.
Environmental Reporter, 1992. EPA solicitation of comment, notice of information availability on
unregulated perchloroethylene emissions from dry cleaning industry. Bureau of National Affairs, Inc.,
Washington, D.C. October 9.
International Fabricare Institute. 1988. (IFI, 1988). Fundamentals of Dry cleaning.
International Fabricare Institute. 1989. (IFI, 1989). Equipment and Plant Operations Survey. Focus
on Dry cleaning. Vol 13(1). March.
Meijer. 1995. Personal communication between Jon Meijer, IFI and Alice Tome, Abt Associates,
April.
SRRP. 1990. Source Reduction and Recycling of Halogenated Solvents in the Dry Cleaning
Industry-Technical Support Document.
f Many of the contacts listed above have provided valuable background information and comments during the development
of this document. EPA appreciates this support and acknowledges that the individuals listed do not necessarily endorse all
statements made within this notebook.
September 1995
78
SIC 7216
-------
Sector Notebook Project
Dry Cleaning
Smith. 1995. Memorandum from George Smith, Office of Air Quality Planning and Standards,
USEPA to Joyce Chandler, Office of Enforcement and Compliance Assurance, USEPA, May 30.
Torp, Richard. 1994. Personal communication between Richard Torp of the Coin Laundry
Association and Alice Tome of Abt Associates, Inc. February.
U.S. Environmental Protection Agency. 1982. (USEPA, 1982). Petroleum Dry Cleaners
Background Information for Proposed Standards. Draft EIS. EPA 45 0/3-82-012a. Office of Air
Quality Planning and Standards, USEPA, November.
U.S. Environmental Protection Agency. 1990. (USEPA, 1990). Drycleaning and Laundry Plants,
RCRA information sheet, EPA/530-SW-90-027b.
U.S. Environmental Protection Agency. 1991a. (USEPA, 1991a). Dry Cleaning Facilities -
Background Information for Proposed Facilities. Draft EIS. EPA-450/3-91-020a. Office of Air
Quality, Planning and Standards, U. S. Environmental Protection Agency. November.
U.S. Environmental Protection Agency. 1991b. (USEPA, 1991b). Economic impact analysis
of regulatory controls in the dry cleaning industry. Final. EPA-450/3-91-021. Office of Air
Quality, Planning and Standards, U. S. Environmental Protection Agency.
U.S. Environmental Protection Agency. 1993 a. Economic Analysis of Regulatory Controls in the
Dry Cleaning Industry. Final. EPA 450/3-91-021b. September.
U.S. Environmental Protection Agency. 1993b. (USEPA, 1993b). National Emission Standards for
Hazardous Air Pollutants for Source Categories - PCE Dry Cleaning Facilities, Final Rule (58 FR
49354).
Trade Journals.
American Drycleaner published monthly by American Trade Magazines, Chicago, Illinois.
The National Clothesline published monthly by BPS Communications, Philadelphia, Pennsylvania.
Drycleaners News published by Zackin Publications, Inc. Waterbury, Connecticut.
Process Descriptions and Chemical Use Profiles
Kirk-Othmer Encyclopedia of Chemical Technology. 1984. Drycleaning and Laundering.
Regulatory Profile-
Department of Environmental Conservation New York State. (Undated) Draft Part 232 Dry
Cleaning Inspection Report. Form listing the information required for a complete facility audit.
September 1995
79
SIC 7216
-------
Sector Notebook Project
Dry Cleaning
U.S. Environmental Protection Agency. 1993c. (USEPA, 1993c). Multiprocess Wet Cleaning: Cost
Performance Comparison of Conventional Dry Cleaning and an Alternative Process, Office of
Pollution Prevention and Toxics, EPA 744-R-93-004, September.
Wolf, Katy, 1992. Case Study: Pollution Prevention in the Dry Cleaning Industry: A Small Business
Challenge for the 1990s. Pollution Prevention Review, Summer.
Health Effects.
U.S. Department of Health, Education and Welfare, National Institute of Occupational Safety and
Health. 1976. Criteria for a recommended standard. Occupation Exposure to Tetrachloroethylene
(Perchloroethylene). HEW Publication No. (NIOSH) 76-185.
U.S. Environmental Protection Agency. 1992. Proceedings of the International Roundtable on
Pollution Prevention and Control in the Drycleaning Industry. Fact sheet: Air Contamination Above
Dry Cleaners. EPA/774/R-92/002.
Pollution Prevention.
U.S. Environmental Protection Agency. USEPA 1989.
EPA/625/4-89/021.
Solvent Waste Reduction Alternatives.
U.S. Environmental Protection Agency. USEPA 1991c. Preventing Pollution in the Dry Cleaning
Business. USEPA Region I Groundwater Management Section and USEPA Headquarters, Office
of Groundwater and Drinking Water. (Contains list of contacts for Region I)
Tennessee Department of Environment and Conservation et al. (Undated.) Clearing the Air on Clean
Air: Strategies for Perc Dry Cleaners Compliance, Risk Reduction and Pollution Prevention.
(Contains a state by state listing of contacts for help on air regulation compliance.)
[Note that several publications by OPPT's Design for the Environment Program on alternative dry
cleaning technologies are expected in 1995. Contact: Ohad Jehassi, 202-260-6911, for publication
dates.]
September 1995
80
SIC 7216
-------
APPENDIX A
INSTRUCTIONS FOR DOWNLOADING THIS NOTEBOOK
Electronic Access to this Notebook via the World Wide Web (WWW)
This Notebook is available on the Internet through the World Wide Web. The Enviro$en$e
Communications Network is a free, public, interagency-supported system operated by EPA's Office
of Enforcement and Compliance Assurance and the Office of Research and Development. The
Network allows regulators, the regulated community, technical experts, and the general public to
share information regarding: pollution prevention and innovative technologies; environmental
enforcement and compliance assistance; laws, executive orders, regulations, and policies; points of
contact for services and equipment; and other related topics. The Network welcomes receipt of
environmental messages, information, and data from any public or private person or organization.
ACCESS THROUGH THE ENVIROSENSE WORLD WIDE WEB
To access this Notebook through the Enviro$en$e World Wide Web, set your World Wide
Web Browser to the following address:
http://eS.inel.gov/OCCa - then select "EPA Sector Notebooks"
Or after 1997, (when EPA plans to have completed a restructuring of its web site) set
your web browser to the following address:
WWW.epa.gOV/OeCa - then select the button labeled Gov't and Business
Sectors and select the appropriate sector from the menu.
The Notebook will be listed.
HOTLINE NUMBER FOR EJWWW: 208-526-6956
EPA ESWWW MANAGERS: Louis Paley 202-564-2613
Myles Morse 202-260-3151
(This page updated June 1997)
Appendix A
-------
-------
United States Government
INFORMATION
PUBLICATIONS * PERIODICALS * ELECTRONIC PRODUCTS
Charge your order.
It's easy!
fas*
Order Processing Code:
*3212
Fax your orders (202) 512-2250
Phone your orders (202) 512-1800
Qty.
Stock Number •
055-000-00512-5
055-000-00513-3
055-000-00518-4
055-000-00515-0
055-000-00516-8
055-000-00517-6
055-000-00519-2
055-000-00520-6
055-000-00521-4
055-000-00522-2
055-000-00523-1
055-000-00524-9
055-000-00525-7
055-000-00526-5
055-000-00527-3
055-000-00528-1
055-000-00529-0
055-000-00514-1
Published in 1995 Title
Dry Cleaning Industry, 1 04 pages
Electronics and Computer Industry, 160 pages
Fabricated Metal Products Industry, 164 pages
Inorganic Chemical Industry, 136 pages
Iron and Steel Industry, 128 pages
Lumber and Wood Products Industry, 136 pages
Metal Mining Industry, 148 pages
Motor Vehicle Assembly Industry, 1 56 pages
Nonferrous Metals Industry, 1 40 pages
Non-Fuel, Non-Metal Mining Industry, 108 pages
Organic Chemical Industry, 152 pages
Petroleum Refining Industry, 1 60 pages
Printing Industry, 1 24 pages
Pulp and Paper Industry, 156 pages
Rubber and Plastic Industry, 1 52 pages
Stone, Clay, Glass and Concrete Industry, 1 24 pages
Transportation Equipment Cleaning Industry, 84 pages
Wood Furniture and Fixtures Industry. 1 32 oaaes
Price
Each
$ 6.50
11.00
11.00
9.00
8.00
9.00
10.00
11.00
9.00
6.50
11.00
11.00
7.50
11.00
11.00
7.50
5.50
8.00
Total
Price
i^ssscssEiaassis^ias^ •<•• -ua^j. v-v,^ ^.,-,, ,--,,«..,s- -«-,«, ?!•«*. , ,-.,-„.,, r .„-»•. - , .*., ,,
Qty.
Stock Number
055-000-00570-2
055-000-00571-1
055-000-00572-9
055-000-00573-7
055-000-00574-5
055-000-00575-3
055-000-00576-1
055-000-00577-0
055-000-00578-8
055-000-00579-6
Published in 1997 Title
Air Transportation Industry, 90 pages
Ground Transportation Industry, 130 pages
Water Transportation Industry, 90 pages
Metal Casting Industry, 150 pages
Pharmaceutical Manufacturing Industry, 1 47 pages
Plastic Resin & Man-made Fiber Industry, 180 pages
Fossil Fuel Electric Power Generation Industry, 160 pages
Shipbuilding and Repair Industry, 1 20 pages
Textile Industry, 130 pages
Sector Notebook Data Refresh -1997, 210 pages
Price
Each
$ 7.50
10.00
7.50
13.00
13.00
15.00
14.00
9.50
10.00
17.00
Total for Publications
Total
Price
The total cost of my order is
Price includes regular shipping and handling and is subject to change.
Company or personal name
(Please type or print)
Additional address/attention line
Check method of payment:
O Check payable to Superintendent of Documents
Q GPO Deposit Account I I I I
Q VISA Q MasterCard Q Discover/NOVUS
Street address
City, State, Zip code
(expiration date) Thank you for your order!
Daytime phone including area code
7/97
Authorizing signature
Mail to: Superintendent of Documents
P.O. Box 371954, Pittsburgh, PA 15250-7954
Purchase order number (optional)
Important: Please include this completed order form with your remittance.
-------
------- |