EPA-340/1 -80-007
RACT Compliance Guidance for
Carbon Adsorbers on
Perchloroethylene Drycleaners
by
C.M. Harvey and J.E. Spessard
PEDCo Environmental, Inc.
1006 N. Bowen Road, Suite 201
Arlington, Texas 76012
Contract No. 68-01-4147
Task No. 119
EPA Project Officer: John R. Busik
Prepared for
U.S. ENVIRONMENTAL PROTECTION AGENCY
Office of General Enforcement
Division of Stationary Source Enforcement
Washington, DC 20460
May 1980
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DISCLAIMER
This report was furnished to the U.S. Environmental .Protec-
tion Aoency by PEDCo Environmental, Inc., in fulfillment of
retract No 68-01-4147. The contents of this report are repro-
Agency- Mention of company or product names is not to .be con
sidered as an endorsement by the Environmental Protection Agen
cy.
11
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CONTENTS
Disclaimer
Acknowledgment
1. Introduction
Background
Purpose and scope of report
2. Drycleaning Process Description
Coin-operated drycleaning establishments
Commercial drycleaning establishments
Industrial drycleaning establishments
3. Control Technology and Initial Compliance Factors
Discussion of RACT regulations
Factors Affecting initial compliance
4. Compendium of Carbon Adsorber Manufacturers'
Recommendations of Adsorber/Drycleaning Machine
Configurations
Equipment survey
Compatibility of adsorbers with various
drycleaning machines
References
Appendix A
Capacities of drycleaning machines compatible
with available carbon adsorbers
Appendix B Other control systems for perchloroethylene
drycleaners
Page
ii
vi
1
1
1
5
5
6
7
9
10
10
15
21
22
49
ill
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ACKNOWLEDGMENTS
This report was prepared by PEDCo Environmental, Inc.,
under the direction of Mr. Thomas C. Ponder, Jr., and Dr. Mazen
Y? Anastas. Principal authors were Ms. Cynthia M. Harvey and
Dr. John E. Spessard. Task Manager for the U.S. Environmental
Protection Agency was Mr. Robert L. King.
IV
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SECTION 1
INTRODUCTION
BACKGROUND
The Clean Air Act Amendments (CAAA) of 1977 required each
state to report the status of compliance with National Ambient
Air Quality Standards (NAAQS) to the U.S. Environmental Protec-
tion Agency (EPA). Attainment and nonattainment areas in each
state with regard to the control of major pollutants were listed
in the Federal Register on March 3, 1978. According to the 1977
CAAA, nonattainment areas must achieve compliance with NAAQS by
December 31,- 1982, with some possible extensions to 1987.
In December 1978, a Control Techniques Guideline (CTG)1 was
published for control of volatile organic compounds (VOC) from
perchloroethylene (perc) drycleaning systems. Those industries
in areas where standards covering a particular pollutant are not
being met will be required to apply Reasonably Available Control
Technology (RACT), which is discussed in the CTG.
On or before January 1, 1980, all states are required to
submit to the EPA proposed revisions of the State Implementation
Plan (SIP) reflecting RACT for perc drycleaning systems. Prom-
ulgation of the regulations is required by July 1, 1980. The
new regulations will involve state and local agencies with an
industry that to date has received little or no enforcement
effort. Previous state regulations pertaining to organic sol-
vents, specifically Rule 66 of the Air Pollution Control Dis-
trict, County of Los Angeles, California, and Part 205 of the
New York City Metropolitan Area Regulations, Area Regulations,
have always exempted perc from emission limitations. Part 212
of the New York City Metropolitan Area Regulations does provide
some limitations to perc emissions from drycleaning facilities.
PURPOSE AND SCOPE OF REPORT
A recent inventory of drycleaning establishments in the
United States was compiled from the 1976 County Business Pat-
terns publication of the Bureau of Census. This inventory
indicated a total of 19,738 drycleaning facilities using perc,
categorized in three industry sectors as follows: 5,179 in
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coin-operated facilities; 14,366 in commercial facilities; and
193 in industrial facilities. Percentages of establishments
located in nonattainment areas are as follows: coin-operated,
48 percent; commercial, 66 percent; and industrial, 62 percent.
The total 1979 perc emissions from all perc drycleaning plants
is estimated to be 158,000 Mg (174,000 tons) or 0.9 percent of
total VOC emissions from stationary sources. Although the
percentage of total" nationwide VOC emissions is small, perc
drycleaning systems constitute a significant source of VOC
emissions in the urban areas.
Model regulations based on the CTG document were issued in
September 1979. These model regulations are guidelines to be
used by the states in performing revisions of SIP's to be sub-
mitted in July 1980. The regulations apply to all perc dry-
cleaning systems in the three industry sectors. They specify
that the owner or operator must vent the dryer exhaust through a
carbon adsorption system or equally effective control device and
emit no more than 100 parts per million (ppm) of VOC from the
control system; repair all components leaking liquid perc; and
reduce VOC content of residues from diatomaceous earth filters,
solvent stills, and cartridge filters prior to disposal. Cer-
tain facilities are exempt from the provisions pertaining to
carbon adsorption and the associated 100-ppm emission limit;
these include coin-operated facilities and other systems where
space limitations prevent the installation of a carbon adsorber
and/or where steam required for desorption of the carbon bed is
not available. Compliance with the 100 ppm emission limit will
be determined by EPA Test Method 23 outlined in an EPA Guideline
Series document,2 or by verification that equipment demonstrated
to be adequate to meet the 100-ppm emission limit has been pro-
perly installed, operated, and maintained. Existing perc dry-
cleaning systems in nonattainment areas are required to achieve
compliance with the 100-ppm emission limit by January 1, 1982.
Problems may arise in the enforcement of this regulation by
state and local agencies because of the large number of sources.
Testing of approximately 10,000 sources would be an awesome task
for Federal, state, and local EPA personnel. Moreover, the
aggregate emissions from this large number of individual sources
still constitute only a relatively small quantity of VOC emis-
sions. Therefore, the need for a compliance documentation
method that would reduce enforcement effort is apparent. By
reducing initial compliance documentation requirements, enforce-
ment officials can devote more time and attention to the verifi-
cation of continuing compliance.
This report provides a compilation of manufacturers' recom-
mendations of combinations of adsorbers and perc drycleaning
equipment that should comply with RACT regulations. Properly
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sized carbon adsorption systems have been shown to meet the
100-ppm emission limit easily. The recommended combinations,
however, may have to be adjusted based on source testing of the
various configurations. It has not been determined whether
refrigeration and scrubbing systems are equivalent to carbon
adsorption. This report, therefore, deals primarily with carbon
adsorbers as the retrofit control.
A tabular presentation of data for each carbon adsorber is
given in Appendix A. Appendix B gives more information on
refrigeration systems and scrubbers.
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SECTION 2
DRYCLEANING PROCESS DESCRIPTION
The perc drycleaning process consists of three basic steps:
washing, extraction, and drying. Clothes are washed in^ one of
two types of machines, characterized as transfer or dry-to-dry
machines. The transfer machines currently being manufactured
carry out the washing and extraction steps. Clothes are tnen
transferred to the dryer. The dry-to-dry machines perform all
three steps.
The washing step may include one or two solvent baths,
although most commercial cleaners use only one. ^® ^e of a
two-bath system generally improves overall cleaning efficiency.
As an aid in removing water-soluble soils, small amounts of
detergent (and sometimes water) are added to the solvent in tne
one-bath system.
In the extraction step in both machines, the solvent bath
is drained; then the clothes are spun at a high speed to wring
out excess solvent. Most of the newer transfer machines are
washer-extractor types; thus the washing and extraction steps
are the same as in the dry-to-dry machines.
After the extraction step the procedure differs with the
two types of machines. With the transfer machines an operator
transfers clothes to the dryer-reclaimer. Current OSHA regula-
tions require that perc-laden air be drawn away from the opera-
tor when clothes are being transferred from the washer-extractor
to the dryer. This is accomplished by an exhaust fan, which
pulls air into the washer and dryer doors and away from the
operator when the doors are open.
All perc plants use a solvent-reclaiming dryer. Heated air
is blown over the clothes in a closed, recirculating loop to
vaporize the solvent, which is then recovered in a water-cooled
condenser. After a timed drying step (usually 15 to 20 min-
utes), fresh air is blown over the clothes for approximately
5 minutes to complete the drying cycle and aerate the clothes^
During this aeration portion of the drying cycle, the airstream
and perc vapors are to be vented to a carbon adsorption system.
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During the washing cycle, perc is passed through a filter
for removal of suspended matter and dyes. The filter may be
either a paper cartridge type or a regenerative type. The paper
cartridge filter, usually containing some activated carbon for
removal of dyes, is re-used for several wash cycles and is
drained before it is discarded. The regenerative filter is
regenerated by backwashing the filter powder precoat and adding
a new precoat. The backwash contains diatomaceous earth, acti-
vated carbon, suspended matter removed from the perc, and a
considerable amount of perc that must be recovered. Perc re-
covery is usually accomplished in a muck cooker, which is a
distillation unit with direct steam injection.
Removal of nonvolatile residues, such as oils and fats,
from the perc is accomplished in a unit that distills the perc
from the impurities, which are discarded as still bottoms.
Periodic distillation of all or part of the solvent is necessary
to prevent buildup of these soluble impurities.
COIN-OPERATED DRYCLEANING ESTABLISHMENTS
Coin-ops are distinguished from the commercial and indus-
trial drycleaners in that the drycleaning equipment is activated
by the customer. Often the manager or attendant of the coin-op
assists the customer in drycleaning the,clothes. Coin-ops pro-
vide a low cost, self-service type of drycleaning without press-
ing, spotting, or other services provided by commercial dry-
cleaners .
The drycleaning units used in typical coin-ops are dry-to-
dry machines. The units use cartridge filters; no distillation
of the perc is performed at a typical coin-op.
Cartridge filters being marketed for coin-ops include a
fluted paper cartridge with or without a core consisting of
activated carbon, activated carbon and clay, or carbon. Acti-
vated carbon adsorbs the dyes from the perc and the clay adsorbs
nonvolatile residues.
COMMERCIAL DRYCLEANING ESTABLISHMENTS
Commercial drycleaners include small, independent neighbor-
hood shops, franchised shops, and specialty shops that clean
leather and other fine goods. Commercial drycleaners generally
use transfer equipment. To date, the dry-to-dry machine has
been used very little in commercial perc plants because machine
utilization is only half that of the transfer machine, which
allows simultaneous use of the washer and dryer. Interest in
the dry-to-dry machine is increasing, however, because it can
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meet OSHA regulations more easily and requires less attention
during the cleaning cycle than the transfer type. Furthermore,
the equipment manufacturers are increasing their efforts to
improve and sell this type. Presently, about 25 percent of the
commercial plants have dry-to-dry machines.
A typical commercial perc plant would have one washer-ex-
tractor of 25- to 50-lb capacity, one or two reclaiming dryers
of equivalent size, a solvent filter with disposable paper
cartridges, and a distillation unit.
INDUSTRIAL DRYCLEANING ESTABLISHMENTS
Industrial launderers with drycleaning facilities are
enaaged primarily in supplying laundered or drycleaned work uni-
forms, wiping towels, safety equipment, dust control items, and
other selected items to industrial or commercial users. These
items may belong to the industrial launderers and be supplied to
the users on a rental basis, or they may belong to customers.
Work uniforms and executive shirts and slacks are usually
drycleaned because longer wear is achieved by drycleaning than
by laundering, and the aggressive action of the solvents toward
heavily greased items often produces superior results. Launder-
ing, with water and detergent, is nonetheless indispensable in
the removal of water-solubles such as perspiration odors, some
launderers commonly use a dual-phase cleaning process consisting
of an initial water wash followed by a solvent wash and rinse.
A typical industrial system is a transfer type, consisting
of a 250-lb washer/extractor and a matching reclaiming dryer.
Multibath washing is common; that is, the items to be cleaned
are subjected to a water and detergent wash, a solvent wash, ana
a solvent rinse. Solvent filtration is seldom used. Suspended
matter and nonvolatile residues are removed by distillation.
The residue from distillation is further treated in a muck
cooker for removal of solvent.
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SECTION 3
CONTROL TECHNOLOGY AND INITIAL COMPLIANCE FACTORS
DISCUSSION OF RACT REGULATIONS
Model regulations for perc drycleaning facilities based on
RACT were issued in September 1979. They specify that the owner
or operator must accomplish the following:
0 Vent the dryer exhaust through a carbon adsorption
system or equally effective control device and emit no
more than 100 ppm of VOC's from the dryer control
device before dilution.
0 Immediately repair all components found to be leaking
liquid VOC.
0 Cook or treat diatomaceous earth filters so that the
residue contains 25 percent VOC or less.
0 Reduce VOC from all solvent stills to 60 percent or
less from wet waste material.
0 Drain all filtration cartridges in their housing for
at least 24 hours before discarding and, when pos-
sible, dry all drained cartridges without emitting VOC
to the atmosphere.
Facilities exempt from the provisions pertaining to carbon
adsorption and the associated 100-ppm limit are coin-operated
facilities, facilities where an adsorber cannot be accommodated
because of inadequate space, or facilities with insufficient
steam capacity to desorb adsorbers.
For an owner or operator subject to the carbon adsorption
provision and the attendant 100-ppm VOC limit, final compliance
is to be achieved by January 1, 1982. If the control equipment
cannot be delivered prior to November 1, 1981, and the owner or
operator placed the order prior to January 1, 1981, the final
compliance date will be 60 days after delivery of the equipment.
An owner or operator subject to the maintenance provisions of
the regulations must comply by January 1, 1981. The owner or
operator may also submit a proposed alternative compliance
schedule subject to approval by EPA.
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Visual inspection will be the means of determining compli-
ance with the provisions requiring the owner or operator to vent
the dryer exhaust through a control device, to drain filtration
cartridges in the filter housing for at least 24 hours before
discarding, and when possible, to dry all drained cartridges
without emitting VOC to the atmosphere. The following compon-
ents will be visually inspected to determine compliance:
Hose connections, unions, couplings, and valves
Machine door gasket and seating
Filter head gasket and seating
Pumps
Base tanks and storage containers
Water separators
Filter sludge recovery
Distillation unit
Divertor valves
Saturated lint from lint basket
Cartridge filters
All components found to be leaking liquid VOC must be repaired
immediately.
The procedure described by the American National Standards
Institute^ will be used to determine compliance with the re-
quirements for diatomaceous earth filter residues (25 g or less
VOC per 100 kg of wet waste material) and solvent still residues
(60 kg or less VOC per 100 kg of wet waste material).
Compliance with the 100-ppm emission limit from the dryer
control device before dilution is to be determined by either a
test consistent with EPA Test Method 232 or by verification of
the proper installation, operation, and maintenance of equipment
which has been demonstrated to be adequate to meet the emission
limit.The"discussionaccompanyingEPA'smodelregulation
states that the carbon adsorbers tested have achieved much
better control than 100 ppm at the outlet. The EPA further
states that the vendors should be able to demonstrate that their
equipment, if properly installed and operated, will be adequate
to meet the emission limits. Proper maintenance of a carbon
adsorber could provide compliance at a given facility on the
basis of proven performance elsewhere. Hence, the EPA has
established the precedent of equipment equivalency, which is
recognized as a viable alternative to individual source testing.
Nonetheless, the EPA has not totally abandoned source testing
for the drycleaning industry and views it as a tool that can be
used when deemed appropriate on a case-by-case basis.
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FACTORS AFFECTING INITIAL COMPLIANCE
The perc emission limit of 100 ppm in the dryer exhaust
from perc drycleaning systems can be easily achieved by venting
to an adequately designed and properly operated activated carbon
adsorption system. In several EPA tests of these systems, the
outlet perc concentrations were well below.100 ppm.
The activated carbon used in perc adsorbers is made from
either bituminous coal or petroleum coke. The particle size is
in the four- to ten-mesh range with oversize and undersize
fractions not more than 5 percent each. This carbon is used
extensively for solvent vapor adsorption and air purification.
Solvents treated include benzene, toluene, and xylene, as well
as perc. The carbon is readily regenerated by steam stripping.
Its working adsorptive capacity for perc is about 20 percent of
the weight of the carbon. Hence, a 100-kg carbon bed should
adsorb about 20 kg of perc.
The chief factor affecting compliance is the proper sizing
of the carbon bed. Tests by the EPA have shown that 3 to 6 Ib
of perc per 100 Ib of clothes remain in the clothes after drying
and before the beginning of the aeration. Hence, the carbon
must adsorb this amount of perc to prevent violation of the
100-ppm emission limit. Because a carbon bed will hold 20
percent of its own weight in perc, only a limited number of
aeration cycles can be accommodated before breakthrough occurs.
Other factors that may influence initial compliance are:
Insufficient adsorptive capacity of activated carbon be-
cause of manufacturing defects. Inadequate adsorptive
capacity can be detected by noting the amount of perc
desorbed in the first few cycles and comparing with the
expected value.
Leakage in the air recirculation circuit because of lint
accumulation and damaged gaskets on isolation dampers.
Excursions in temperature and concentration of perc in the
airstream to the carbon adsorber.
Variations in humidity of the airstream. In general, water
vapor decreases the adsorptive capacity of carbon for perc.
Thus breakthrough occurs sooner at high relative humidi-
ties.
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SECTION 4
COMPENDIUM OF CARBON ADSORBER MANUFACTURERS'
RECOMMENDATIONS OF ADSORBER/DRYCLEANING MACHINE CONFIGURATIONS
Regulatory agencies should verify compliance on a prelimi-
nary basis by affirming that the control system has been in-
stalled properly and that the carbon beds are being regenerated
on a schedule that is compatible with the specific configuration
of drycleaning machines/control system. In the absence of a
rigorous preliminary inspection that is equivalent to a source
test, some noncomplying systems undoubtedly will slip through.
It is believed, however, that reducing the enforcement efforts
to determine initial compliance will allow greater emphasis on
enforcement efforts to determine continuing compliance, and any
noncomplying sources should be discovered.
EQUIPMENT SURVEY
In design of a method for documenting initial compliance in
the perc drycleaning industry, it is necessary to determine the
available types and capacities of drycleaning equipment and
carbon adsorption systems. Such an equipment survey then serves
as a basis for determining the compatibility of the various
drycleaning units and control systems.
Drycleaning Equipment
Nine companies are currently producing perc drycleaning
reclaimers or dry-to-dry machines that vent either to a control
device or to the atmosphere during aeration. Table 1 shows
these companies and the sizes and types of equipment they sell.
A French machine, Frimair, is to be marketed in the United
States in mid-1980. This machine, however, is a 25-lb dry-to-
dry unit that does not vent to the atmosphere during the aera-
tion phase.
Carbon Adsorber Equipment
Only six firms currently offer carbon adsorbers for sale to
drycleaning plants. Their products are listed in Table 2.
Carbon adsorbers by Hoyt Manufacturing Corp. and Vic Manufactur-
ing Co. are manufactured in the United States. American Permac
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TABLE 1
MANUFACTURERS AND DRYCLEANING EQUIPMENT
Manufacturer/Vendor
Machine sizes, 1b of clothes
Reclaiming dryers
Dry-to-dry machines
American Laundry Machinery, Inc.
American Permac, Inc.
Detrex Chemical Industries, Inc.
The Dexter Company
Hoyt Manufacturing Corp.
Multimatic Corp.
Spencer America, Inc.
Vic Manufacturing Company
Wascomat of America
50,250
• 35, 50, 80
85
20, 30, 40, 70, 140, 240,
330
30, 40, 55, 80, 100
8
25, 35, 45, 85, 90, 140,
280, 330
25, 40, 60, 100, 110,
150, 165, 330
40, 50, 65, 140
15, 25, 30, 45, 75, 100,
150, 300
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TABLE 2
ACTIVATED CARBON ADSORBERS FOR DRYCLEANING ESTABLISHMENTS
Manufacturer
and model
Wascomat
TOO
150
240
400
900
1300
1800
3000
Carbon
weight, Ib
44
66
104
170
275
364
507
838
Spencer American
SS80
r»
750
* vwp
1000
I www-»
1500C
Vic
128
118
r
108°
80
220
280
440
130
300
300
American Permac
A51
ABO
A80
A! 25
• i * *-**rt
A100e
46
99
154
551
551
Perc
capacity,
Ib
7
10
17
28
45
60
82
148
16
43
59
86
24
56
56
10
20
46
110
no
Air
flow,
cfm
176
282
371
565
777
1130
1590
2296
180
750
1000
1500
600
600
600
212
282
424
1342
1342
Regen.
time,
minutes
60
60
60
60
60
60
60
60
15
30
30
30
45
45
45
45
45
45
60
60
Cleaning capacity,
Ib of clothes per
regeneration cycle
Mfr.
rating
270
425
680
1200
2300
2860
3520
6380
165
300
500
700
300
400
400
275
525
925
2650
1000
EPA
estimate0
117
167
283
467
750
1000
1367
2467
N/Ab
717
983
1433
400
933
933
167
333
767
1833
1833
(continued)
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TABLE 2 (continued)
Manufacturer
and model
Hoyt
1
4
8C
12C
AVRS-15
American Lau
Ajax f
Prof.
Carbon
weight, Ib
no
205
350
420
420
Perc
capacity,
Ib
20.9
41.0
70,0
83.5
83.5
idry Machinery
300
56.0
Air
flow,
cfm
fo
N/Ab
N/Ab
N/Ab
600
Regen.
time,
minutes
60
60
60
60
60
k
N/Ab
Cleaning capacity,
Ib of clothes per
regeneration cycle
Mfr.
rating
300
600
900
1200
1200
h
N/Ab
EPA
estimate
348
683
1167
1392
1392
933
? Based on 6 Ib of perc per 100 Ib of clothes.
Not available.
~. Dual-bed unit; parameters given are for each adsorber bed.
Multiple-bed option available on models A51, A60, A80, and A125.
? The A!00 is recommended only for use with PERMAC cleaning equipment.
This unit has a condenser in front of the adsorber, which should increase
the amount of clothes cleaned between regenerations.
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equipment is manufactured in West Germany, Spencer American in
England, and Wasco-Clean in Italy. American Laundry Machinery
of Cincinnati, Ohio, plans to enter the market soon and is now
distributing sales brochures. Marvel Manufacturing o±
San Antonio, Texas, has a unit in the design phase.
These carbon adsorbers are all compatible with standard
drycleaning equipment. Appropriate ductwork must be installed
to connect the dryer and washer vents with the adsorption unit.
Capacities have been defined in terms of weight of carbon in the
unit, perc adsorption capacity, airflow rates, and estimated
pounds of clothes cleaned before desorption.
The rated capacity to adsorb perc is about 20 percent of
the weight of carbon in the adsorber, but there is no correla-
tion between the weight of carbon in the adsorber and the manu-
facturer's recommendations of the quantity of clothes that can
be cleaned between carbon regeneration cycles. The time between
regenerations depends upon the size of each bed, the number o±
carbon beds in a multiple-bed system relative to the given
drycleaning machine size, temperature of the cooling water to
the condenser, and perc content of the clothes.
Beds of activated carbon suitable for use in adsorption of
perc vapors from drycleaning operations are designed according
to the following criteria:
Space velocities of the order of 100 reciprocal minutes.
Space velocity is defined as the ratio of volumetric flow
of treated gas to volume of bed.
A ratio of volumetric flow rate to bed cross-sectional area
of about 328 m3 per minute per m2 of cross sectional area
(100 ft3 per minute per ft2).
A bed working capacity of about 20 percent, which is the
weight of perchloroethylene adsorbed (and also amenable to
desorption) as a percentage of the total weight of acti-
vated carbon.
Carbon bed depths range from 0.23 to 0.81 m (9 to 32 in.).
The volumetric gas flow vented to the carbon bed during aeration
is usually about 0.25 dry standard cnbic meter per minute per kg
of clothes dried (4 dscfm per Ib). Temperatures of thei bed
inlet and outlet gas are about 43°C and 24°C (110°F and 75°F)
respectively. Moisture contents are usually near 1 percent.
The adsorbed perc may be desorbed with steam at the rate of
about 4 kg steam per kg of perc to be desorbed.
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COMPATIBILITY OF ADSORBERS WITH VARIOUS DRYCLEANING MACHINES
For initial compliance the most important factor is the
amount of perc to be adsorbed during each aeration phase. For
comparison of the available carbon adsorbers, a common basis
must be chosen. Tests by the EPA have shown that clothes con-
tain 3 to 6 percent perc by weight after drying and before
aeration. For this compilation of recommended adsorber/dry-
cleaning machine combinations it is assumed that clothes will
contain 6 percent perc by weight and that the carbon adsorber
must adsorb this quantity without breakthrough. It is also
assumed that the maximum perc capacity for each carbon bed is 20
percent of the carbon weight. This factor should ensure that
the 100-ppm outlet concentration limit will not be exceeded.
Drycleaning systems that vent door fan exhausts, floor
pickups, perc/water separators, or other units to the carbon
adsorber might reach saturation sooner than a drycleaning system
that vents only the aeration flow to the bed. These flows,
however/ are usually short in duration or low in perc concentra-
tion, and the emission factor of 6 Ib perc per 100 Ib clothes
should be high enough to account for this small additional perc
load on the adsorber.
Factors such as defective carbon, lint accumulation and
leakage around damaged gaskets, humidity, and temperature excur-
sions will not be addressed for the initial compliance guidance.
Quality assurance procedures for the manufacture of activated
carbon should prevent significant numbers of carbon beds from
containing defective carbon. Proper operation and maintenance
of drycleaning equipment should also prevent lint accumulation,
damaged gaskets, and temperature excursions. High humidity
(above 50 percent) decreases the, adsorptive capacity of the
carbon for perc. At humidities below 50 percent, water vapor
does not affect the carbon bed. High humidity is not be a
significant factor for most drycleaning facilities.
For each bed of the carbon adsorber, it is possible to
estimate for each capacity of drycleaning machine the number of
aeration cycles before regeneration is required, based on the
6-lb perc/100-lb clothes emission factor and the 20 percent
adsorption capacity of the carbon bed. This information is
depicted in Figures 1 through 4 for the commonly found configur-
ations. Each graph shows the number of aeration cycles that can
be vented to the carbon bed for each drycleaning machine/control
system configuration without exceeding the 100-ppm emission
limit. The suitable combinations may have to be adjusted based
on source testing of various configurations. For dual- or
multiple-bed units, it is necessary to contact the adsorber
manufacturer to obtain specific information on how these units
should be operated and with which drycleaning machines they are
compatible.
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As an example, assume a drycleaner has a 30 Ib reclaimer or
dry-to-dry machine and cleans 10 loads of clothes per day. From
Table 1, the suitable carbon adsorbers that allow regeneration
of the carbon bed at the end of the day are the American Permac
A60, the Hoyt 1, the Wasco Clean 400, the VIC 128, and the VIC
118. For a drycleaner having the same size machine but cleaning
14 loads per day, the suitable carbon adsorbers that allow
regeneration of the carbon bed at the end of the day are the
Wasco Clean 400, the Hoyt 4, and the VIC 118. Larger carbon
adsorbers, depicted in Figures 2 through 4, are also compatible
with a 30 Ib reclaimer or dry-to-dry machine. They would
probably not be the economical choice, however.
A tabular presentation of the data for each carbon adsorber
is given in Appendix A; the tables show relationships of dry-
cleaning machine capacities (10 to 400 Ib clothes per load) and
number of aeration cycles (1 to 20).
16
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REFERENCES
.1.
2.
3.
U.S. Environmental Protection Agency. Control of Volatile
Organic Emissions from Perchloroethylene Dry Cleaning
Systems. EPA-450/2-78-050, December 1978. 49 p.
U.S. Environmental Protection Agency. Measurement of
Volatile Organic Compounds. EPA-450/2-78-041. September
1979. 60 p.
American National Standards Institute. Method of Test for
Dilution of Gasoline Engine Crankcase Oils. ANSI/ASTM
D322-67, 1972.
21
-------
APPENDIX A
CAPACITIES OF DRYCLEANING MACHINES COMPATIBLE
WITH AVAILABLE CARBON ADSORBERS
Tables A-l through A-26 show the capacities of drycleaning
machines that are suitable for use with each of the currently
available commercial carbon adsorbers. Where the combination of
adsorber and drycleaning machine is operable for the indicated
number of aeration cycles, an "X" is shown in the table. Com-
binations that are recommended by the adsorber manufacturer are
enclosed in dashed lines on each table.
The American Permac A100 is not shown in the graphs because
the unit is suitable for use only on Permac drycleaning machines
of 140 to 330 Ib capacity.
22
-------
TABLE A-l
CAPACITIES OF DRYCLEANING MACHINES SUITABLE FOR USE
WITH THE WASCO CLEAN TOO
Carbon bed capacity from EPA emission factor - 117 pounds clothes
Regeneration time 60 minutes
Capacity of drycleaning Number of cleaning machine cycles before
machines, pounds regeneration becomes necessary (X = suitable for use)
10
15
20
1
X
X
X
2
X
X
X
3
X
X
X
4
X
X
X
5
X
X
X
6
X
X
8
X
10
X
12 15 20
23
-------
TABLE A-2
CAPACITIES OF DRYCLEANING MACHINES SUITABLE FOR USE
WITH THE WASCO CLEAN 150
Carbon bed capacity from EPA emission factor - 167 pounds clothes
Regeneration, time 60 minutes
Capacity of drycleaning Number of cleaning machine cycles before
machines, pounds regeneration becomes necessary (X = suitable for use)
1 2 3 4 5 6 8 10 12 15 20
X X X X X X X X X X
10
15
20
25
X X X X X
X
X
X
X X
X X
XXX
XXX
24
-------
TABLE A-3
CAPACITIES OF DRYCLEANING MACHINES SUITABLE FOR USE
WITH THE WASCO CLEAN 240
Carbon bed capacity from EPA emission factor - 283 pounds clothes
Regeneration time 60 minutes
Capacity of drycleaning Number of cleaning machine cycles before
machines, pounds regeneration becomes necessary (X - suitable for use)
123 4 5 6 8 10 12 15 20
10 XXXXXXXXXXX
15
20
25
30
35.
40
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X X
X
25
-------
TABLE A-4
CAPACITIES OF DRYCLEANING MACHINES SUITABLE FOR USE
WITH THE WASCO CLEAN 400
Carbon bed capacity from EPA emission factor - 467 pounds clothes
Regeneration time 60 minutes
Capacity of drycleaning Number of cleaning machine cycles before
machines, pounds regeneration becomes necessary (X = suitable for use)
10
15
20
25
30
35
40
45
50
55
60
65
1
X
X
X
X
X
X
X
X
X
X
X
X
2
X
X
X
X
X
X
X
X
X
X
X
X
3
X
X
X
X
X
X
X
X
X
X
X
X
4
X
X
X
X
X
X
X
X
X
X
X
X
5
X
X
X
X
X
X
X
X
X
X
X
X
6
X
X
X
X
X
X
X
X
X
X
X
X
8
X
X
X
X
.X
X
X
X
X
X
10
X
X
X
X
X
X
X
X
12
X
X
X
X
X
X
15
X
X
X
X
X
20
X
X
X
26
-------
TABLE A-5
CAPACITIES OF DRYCLEANING MACHINES SUITABLE FOR USE
WITH THE WASCO CLEAN 900
Carbon bed capacity from EPA emission factor - 750 pounds clothes
Regeneration time 60 minutes
Capacity of drycleaning Number of cleaning machine cycles before
machines, pounds regeneration becomes necessary (X = suitable for use)
10
15
20
25
30
35
40
45
50
55
60
65
75
85
100
120
1
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
2
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
3
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
4
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
5
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
6
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
8
X
X
X
X
X
X
X
X
X
X
X
X
X
X
10
X
X
X
X
X
X
X
X
X
X
X
X
X
12
X
X
X
X
X
X
X
X
X
X
X
15
X
X
' X
X
X
X
X
X
X
20
X
X
X
X
X
X
27
-------
TABLE A-6
CAPACITIES OF DRYCLEANING MACHINES SUITABLE FOR USE
WITH THE WASCO CLEAN 1300
Carbon bed capacity from EPA emission factor - 1000 pounds clothes
Regeneration time 60 minutes
Capacity of drycleaning Number of cleaning machine cycles before
machines, pounds regeneration becomes necessary (X = suitable for use)
10
15
20
25
30
35
40
45
50
55
60
65
75
85
100
120
140
165
1
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
2
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
3
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
4
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
5
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
6
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
8
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
10
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
12
X
X
X
X
X
X
X
X
X
X
X
X
X
15
X
X
X
X
X
X
X
X
X
X
X
X
20
X
X
X
X
X
X
X
X
X
X
28
-------
TABLE A-7
CAPACITIES OF DRYCLEANING MACHINES SUITABLE FOR USE
WITH THE WASCO CLEAN 1800
Carbon bed capacity from EPA emission factor - T367. pounds clothes
Regeneration time 60 minutes " . ' . .
Capacity of drycleaning Number of cleaning machine cycles before
machines, pounds regeneration becomes necessary (X = suitable for use)
10
15
20
25
30
35
40
45
50 '
55
60
65
75
85
100
120
140
165
200
1
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
2
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
3
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
4
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
5
X
X
X
X
X
X
X
X
X
X
X
X
X
X
x
X
X
X
X
6
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
8
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
x-
X
10
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
12
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
15
X
X
• x
X
X
X
X
X
X
X
X
X
X
X
20
X
X
X
X
X
X
X
X
X
X
X
X
29
-------
TABLE A-8
CAPACITIES OF DRYCLEANING MACHINES SUITABLE FOR USE
WITH THE WASCO CLEAN 3000
Carbon bed capacity from EPA emission factor - 2467 pounds clothes
Regeneration, time 60 minutes
Capacity of drycleaning Number of cleaning machine cycles before
machines, pounds regeneration becomes necessary (X = suitable for use)
10
15
20
25
30
35
40
45
50
55
60
65
75
85
100
120
140 '
165
200
250
300
350
1
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
2
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
3
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
4
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
5
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
6
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
8
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
10
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
12
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
15
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
20
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
30
-------
TABLE A-9
CAPACITIES OF DRYCLEANING MACHINES SUITABLE FOR USE
WITH THE SPENCER AMERICAN SS80
Carbon bed capacity from EPA emission factor - 267 pounds clothes
Regeneration time 60 minutes
Capacity of drycleaning Number of cleaning machine cycles before
machines, pounds regeneration becomes necessary (X = suitable for use)
1
6 8 10 12 15 20
10
15
20
25
30
35
40
45
50
55
60
65
75
85
100
120
140
165
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X .
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X X X X X XX
XXX X X .X
X X X X X
X X X X
XXX
XX
X X
X
X
31
-------
TABLE A-10
CAPACITIES OF DRYCLEANING MACHINES SUITABLE FOR USE
WITH THE SPENCER AMERICAN 750
Carbon bed capacity from EPA emission factor - 717 pounds clothes
Regeneration time 30 minutes
Capacity of drycleaning Number of cleaning machine cycles before
machines, pounds regeneration becomes necessary (X = suitable for use)
10
15
20
25
30
35
40
45
50
55
60
65
75
85
100
120
140
165
1
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
2
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
3
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
4
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
5
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
6
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
8
X
X
X
X
X
X
X
X
X
X
X
X
X
X
10
X
X
X
X
X
X
X
X
X
X
X
X
12
X
X
X
X
X
X
X
X
X
X
15 20
X X
X X
X X
X X
XV
A
X X
X
X
32
-------
r
TABLE A-ll
CAPACITIES OF DRYCLEANING MACHINES SUITABLE FOR USE
WITH THE SPENCER AMERICAN 1000
Carbon bed capacity from EPA emission factor - 983 pounds clothes
Regeneration time 30 minutes
Capacity of drycleaning Number of cleaning machine cycles before
machines, pounds regeneration becomes necessary (X = suitable for use)
10
15
20
25
30
35
40
45
50
55
60
65
75
85
100
120
140
165
1
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
2
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
3
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
4
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
5
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
6
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
8
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
10
X
X
X
X
X
X
X
X
X
X
X
X
X
X
12
X
X
X
X
X
X
X
X
X
X
X
X
X
15
X
X
X
X
X
X
X
X
X
X
X
X
20
X
X
X
X
X
X
X
X
33
-------
TABLE A-12
CAPACITIES OF DRYCLEANING MACHINES SUITABLE FOR USE
WITH THE SPENCER AMERICAN 1500
Carbon bed capacity from EPA emission factor - 1433 pounds clothes
Regeneration time 30 minutes
Capacity of drycleaning Number of cleaning machine cycles before
machines, pounds regeneration becomes necessary (X = suitable for use;
10
15
20
25
30
35
40
45
50
55
60
65
75
85
100
120
140
165
1
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
2
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
3
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
4
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
5
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
6
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
8
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
10
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
12
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
15
X
X
X
X
X
X
X
X
X
X
X
X
- x
X
20
X
X
X
X
X
X
X
X
X
X
X
X
34
-------
TABLE A-13
CAPACITIES OF DRYCLEANING MACHINES SUITABLE FOR USE
WITH THE VIC 128
Carbon bed capacity from EPA emission factor - 400 pounds clothes
Regeneration time 45 minutes
Capacity of drycleaning Number of cleaning machine cycles before
machines, pounds regeneration becomes necessary (X = suitable for use)
1 2 3 4 5 6 8 10 12 15 20
10
15
20
25
30
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
35
-------
TABLE A-14
CAPACITIES OF DRYCLEANING MACHINES SUITABLE
FOR USE WITH VIC 118
Carbon bed capacity from EPA emission factor - 933 pounds clothes
Regeneration, time 45 minutes
Capacity of drycleaning Number of cleaning machine cycles before
machines, pounds regeneration becomes necessary (X = suitable for use)
10
15
20
25
30
35
40
45
50
55
60
1
X
X
X
X
X
X
X
X
X
X
X
2
X
X
X
X
X
X
X
X
X
X
X
3
X
X
X
X
X
X
X
X
X
X
X
4
X
X
X
X
X
X
X
X
X
X
X
5
X
X
X
X
X
X
X
X
X
X
X
6
X
X
X
X
X
X
X
X
X
X
X
8
X
X
X
X
X
X
X
X
X
X
X
10
X
X
X
X
X
X
X
X
X
X
X
12
X
X
X
X
X
X
X
X
X
X
X
15
X
X
X
X
X
X
X
X
X
X
X
20
X
X
X
X
X
X
X
X
36
-------
TABLE A-15
CAPACITIES OF DRYCLEANING MACHINES SUITABLE FOR
USE WITH VIC 108 (Double Bed)
Carbon bed capacity from EPA emission factor - 933 pounds clothes
Regeneration time 45 minutes
Capacity of drycleaning Number of cleaning machine cycles before
machines, pounds regeneration becomes necessary (X = suitable for use)
10
15
20
25
30
35
40
45
50
55
60
65
75
85
100
120
140
1
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
2
X
X
X
X
X
X
X
X
X
X
X
X
X;
X
X
X
X
3
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
4
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
5
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
6
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
8
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
10
X
X
X
X
X
X
X
X
X
X
X
X
X
X
12
X
X
X
X
X
X
X
X
X
X
X
X
X
15
X
X
' X
X
X
X
X
X
X
X
X
20
X
X
X
X
X
X
X .
X
37
-------
TABLE A-16
CAPACITIES OF DRYCLEANING MACHINES SUITABLE FOR USE
WITH THE AMERICAN PERMAC A51
Carbon bed capacity from EPA emission factor - 167 pounds clothes
Regeneration time 45 minutes
Capacity of drycleaning Number of cleaning machine cycles before
machines, pounds regeneration becomes necessary (X = suitable for use)
1 2 3 4 5 6 8 10 12 15 20
10
15
20
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X X
38
-------
TABLE A-17
CAPACITIES OF DRYCLEANING MACHINES SUITABLE FOR USE
WITH THE AMERICAN PERMAC A60
Carbon bed capacity from EPA emission factor - 333 pounds clothes
Regeneration time 45 minutes
Capacity of drycleaning Number of cleaning machine cycles before
machines, pounds regeneration becomes necessary (X = suitable for use)
10
15
20
25
30
35
40
45
50
55
60
65
1
X
X
X
X
X
X
X
X
X
X
X
X
2
X
X
X
X
X
X
X
X
X
X
X
X
3
X
X
X
X
X
X
X
X
X
X
X
X
4
X
X
X
X
X
X
X
X
X
X
X
X
5
X
X
X
X
X
X
X
X
X
X
X
X
6
X
X
X
X
X
X
X
X
X
X
8
X
X
X
X
X
X
X
10
X
X
X
X
X
12 15 20
XXX
XXX
XX
X
39
-------
TABLE A-18
CAPACITIES OF DRYCLEANING MACHINES SUITABLE FOR USE
WITH THE AMERICAN PERMAC A80
Carbon bed capacity from EPA emission factor - 767 pounds clothes
Regeneration time 45 minutes
Capacity of drycleaning Number of cleaning machine cycles before
machines, pounds regeneration becomes necessary (X = suitable for use)
10
15
20
25
30
35
40
45
50
55
60
65
75
85
100
120
1
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
2
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
3
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
4
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
5
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
6
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
8
X
X
X
X
X
X
X
X
X
X
X
X
X
X
10
X
X
X
X
X
X
X
X
X
X
X
X
X
12
X
X
X
X
X
X
X
X
X
X
X
15
X
X
X
X
X
X
X
X
X
20
X
X
X
X
X
X
40
-------
TABLE A-19
CAPACITIES OF DRYCLEANING MACHINES SUITABLE FOR USE
WITH THE AMERICAN PERMAC AT25
Carbon bed capacity from EPA emission factor - 1833 pounds clothes
Regeneration time 60 minutes
Capacity of drycleaning Number of cleaning machine cycles before
machines, pounds regeneration becomes neceasary (X = suitable for use)
10
15
20
25
30
35
40
45
50
55
60
65
75
85
100
120
140
165
200
250
300
1
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
2
X
X
X
X
X
X
X
X
X
X
X
X
x •
X
X
X
X
X
X
X
X
3
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
4
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
5
X
X
X
X
X
X
X
X
X
X
X
X
X
X
"X
X
X
X
X
X
X
6
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
8
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
10
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
12
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
15
X
X
• x
X
X
X
X
X
x .
X
X
X
X
X
X
X
20
X
X
X
X
X
X
X
X
X
X
X
X
X
X
41
-------
TABLE A-20
CAPACITIES OF DRYCLEANING MACHINES SUITABLE FOR USE
WITH THE AMERICAN PERMAC AT 00
(SUITABLE FOR USE ON PERMAC CLEANING MACHINES ONLY)
Carbon bed capacity from EPA emission factor - 1833 pounds clothes
Regeneration time 60 minutes
Capacity of drycleaning Number of cleaning machine cycles before
machines, pounds regeneration becomes necessary (X = suitable for use)
10
15
20
25
30
35
40
45
50
55
60
65
75
85
100
120,
140
165
200
250
300
1
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
2
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
3
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
4
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
5
X
X
X
X
X
X
X
X
X
X
.X
X
X
X
X
X
X
X
X
X
X
6
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
8
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
10
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
12
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
15
X
X
X
X.
X
X
X
X
X
X
X
X
X
X
X
X
20
X
X
X
X
X
X
X
X
X
X
X
X
X
X
42
-------
TABLE A-21
CAPACITIES OF DRYCLEANING MACHINES SUITABLE
FOR USE WITH THE HOYT 1
Carbon bed capacity from EPA emission factor - 348 pounds clothes
Regeneration time 60 minutes
Capacity of drycleaning Number of cleaning machine cycles before
machines, pounds regeneration becomes necessary (X = suitable for use)
1 2 3 4 5 6 8 10 12 15 20
10
15
20
25
30
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
43
-------
TABLE A-22
CAPACITIES OF DRYCLEANING MACHINES SUITABLE
FOR USE WITH THE HOYT 4
Carbon bed capacity from EPA emission factor - 683 pounds clothes
Regeneration time 60 minutes
Capacity of drycleaning Number of cleaning machine cycles before
machines, pounds regeneration becomes necessary (X = suitable for use)
10
15
20
25
30
35
40
45
50
55
60
1
X
X
X
X
X
X
X
X
X
X
X
2
X
X
X
X
X
X
X
X
X
X
X
3
X
X
X
X
X
X
X
X
X
X
X
4
X
X
X
X
X
X
X
X
X
X
X
5
X
X
X
X
X
X
X
X
X
X
X
6
X
X
X
X
X
X
X
X
X
X
X
8
X
X
X
X
X
X
X
X
X
X
X
10
X
X
X
X
X
X
X
X
X
X
X
12
X
X
X
X
X
X
X
X
X
X
15
X
X
X
X
X
X
X
X
20
X
X
X
X
X
44
-------
TABLE A-23
CAPACITIES OF DRYCLEANING MACHINES SUITABLE
FOR USE WITH THE HOYT 8
Carbon bed capacity from EPA emission factor - 1167 pounds clothes
Regeneration time 60 minutes
Capacity of drycleaning Number of cleaning machine cycles before
machines, pounds regeneration becomes necessary (X = suitable for use)
10
15
20
25
30
35
40
45
50
55
60
65
75
85
100
120
1
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
2
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
3
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
4
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
5
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
6
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
8
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
10
X
X
X
X
x .
X
X
X
X
X
X
X
X
X
X
12
X
X
X
X
X
X
X
X
X
X
X
X
X
X
15
X
X
' X
X
X
X
X
X
X
X
X
X
X
20
X
X
X
X
X
X
X
X
X
X
45
-------
TABLE A-24
CAPACITIES OF DRYCLEANING MACHINES SUITABLE
FOR USE WITH THE HOYT 12
Carbon bed capacity from EPA emission factor - 1392 pounds clothes
Regeneration time 60 minutes
Capacity of drycleaning Number of cleaning machine cycles before
machines, pounds regeneration becomes necessary (X = suitable for use)
10
15
20
25
30
35
40
45
50
55
60
65
75
85
100
120
140'
165
200
1
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
2
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
3
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
4
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
5
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
6
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
8
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
10
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
12
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
15
X
X
X
X
X
X
X
X
X
X
X
X
. X
X
20
X
X
X
X
X
X
X
X
X
X
X
X
46
-------
TABLE A-25
CAPACITIES OF DRYCLEANING MACHINES SUITABLE
FOR USE WITH THE AVRS 15
Carbon bed capacity from EPA emission factor - 1392 pounds clothes
Regeneration time 60 minutes
Capacity of drycleaning Number of cleaning machine cycles before
machines, pounds regeneration becomes necessary (X = suitable for use)
10
15
20
25
30
35
40
45
50
55
60
65
75
85
100
120
140
165
200
1
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
2
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
3
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
4
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
5
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
6
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
8
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
10
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
12
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
15
X
X
' X
X
X
X
X
X
X
X
X
X
X
X
20
X
X
X
X
X
X
X
X
X
X
X
X
47
~E P A~F orm~2 2 2 0-r( 9 - 7 3 r
-------
------- |