&EPA
               United States

               Agtency
Profile
                                                                I
   SECTOR

                                               *''''-"

  NOTEBOOKS

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                  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)

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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
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Sector Notebook Project
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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
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                                     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

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Sector Notebook Project
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                  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
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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
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                                   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
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                              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
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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
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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
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                     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.
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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
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                     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.
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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 $7.00
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                     per hour. Many dry cleaners have difficulty paying competitive wages and
                     earning any profit.
Exhibit 2: Very Small and Very Large Establishments
Dominate Commercial Dry Cleaning (1993 dollars)
Annual Receipts
($/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).
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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
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                     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
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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
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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
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                     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.
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       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.
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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
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                     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:
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                    (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.
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       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
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                     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.
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                               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.
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                    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).
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           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
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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-
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                     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.
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                              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.
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                               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.
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                              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
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                                 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.
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                     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.
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                     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
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                     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).
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                     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
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                     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
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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
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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
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 Sector Notebook Project
                                                        Dry Cleaning
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September 1995
                       35
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                             Dry Cleaning






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September 1995
36
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                                 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.
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                     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.
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                                  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.
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                               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.
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                     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.
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                     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.
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 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
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                    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
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                           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).
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                    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.
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                            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
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                     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.
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                      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
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                    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.
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                     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
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                    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.
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                     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.
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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
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                     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
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                    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
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                     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)
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 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
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                     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).
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                     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.
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                    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.
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                     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.
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September 1995 64
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 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.
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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.
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       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.
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                     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)
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 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
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                                  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
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                     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.
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                    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.
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                    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.
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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.
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 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
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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.]
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                                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

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