EPA-450/3-76-029
May 1976
STUDY
TO SUPPORT NEW SOURCE
PERFORMANCE STANDARDS
FOR THE DRY CLEANING
INDUSTRY - FINAL REPORT
V'/
U.S. ENVIRONMENTAL PROTECTION AGENCY
Emission Standards and Engineering Division
Office of Land Use Planning and Standards
Research Triangle Park, North Carolina 27711
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EPA-450/3-76-029
STUDY
TO SUPPORT NEW SOURCE
PERFORMANCE STANDARDS
FOR THE DRY CLEANING
INDUSTRY - FINAL REPORT
by
Billy C. McCoy
Environmental Engineering Division
Energy Systems Group of TRW Inc.
800 Follin Lane, S.E.
Vienna, Virginia 22180
Contract No. 68-02-1412, Task Order No. 4
EPA Project Officer: Charles F. Kleeberg
Prepared for
ENVIRONMENTAL PROTECTION AGENCY
Emission Standards and Engineering Division
Office of Land Use Planning and Standards
Research Triangle Park, North Carolina 27711
May 1976
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This report is issued by the Environmental Protection Agency to report
technical data of interest to a limited number of readers. Copies are
available free of charge to Federal employees, current contractors and
grantees, and nonprofit organizations - in limited quantities - from the
Library Services Office (MD35),' Research Triangle Park, North Carolina
27711; or, for a fee, from the National Technical Information Service,
5285 Port Royal Road, Springfield, Virginia 22161.
,
I .
I' ,
This report was furnished to the Environmental Protection Agency by
Environmental Engineering Division, Energy Systems Group of TRW Inc.,
Vienna, Virginia 22180, in fulfillment of Contract No. 68-02-1412, Task
Order No.4. The contents of this report are reproduced herein as received
from Environmental Engineering Division, Energy Systems Group of TRW
Inc. The opinions, findings, and conclusions expressed are those of
,the author and not nec~ssarily those of the Environmental Protection
Agency. Mention of company or product names is not to be considered
as an endorsement by. the Environmental Protection Agency.
Publication No. EPA-450/3-76-029
ii
1-
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DECLARATION
The format of this report is based generally on the Standard
Support-Environmental Impact Statement outline, draft No.6, dated
April 1975. Although some chapters appear to be missing, they were
not, in fact, the contractual obligation of TRW Inc. This document
completes all the deliverable requirements of the Contract Task
Specification..
;ii
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ACKNOWLEDGEMENT
"The preparation of this report required the help of many people in
numerous organizations. The persons and organizations below were particularly
helpful, and TRW wishes to thank them for their assistance:
Amato Solvents, Inc.--Joseph Amato and Robert McLain
Detrex Chemical Industries, Inc.--Joseph Panepinto
Dow Chemical U.S.A.—Robert Lundy and Ken Surprenant
E.I. DuPont de Nemours & Co.--Donald Kjelleren
Hershey Drycleaners and Laundry—Richard Gallagher and John Koch
International Fabricare Institute—William Fisher
Laundry & Cleaners Allied Trade Association—Steven Landon
Neighborhood Cleaners Association (N.Y.C)--William Seitz
Standard Laundry Machinery Co.--Alvin C. Cull ins
Vic Manufacturing Co.--J.W. Barber, Charles Gorman, and Irving Victor
Washex Machinery Corp.--Steven Landon
In addition, special thanks go to the EPA Project Officers, Charles
Kleeberg and James McCarthy, for their guidance and assistance on the project.
IV
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TABLE OF CONTENTS
Page
3.0 THE DRY CLEANING INDUSTRY
3.1 INDUSTRY DESCRIPTION. . . . . . . . . . . . . . . . . . . .. 3-1
3.2 DRY CLEANING PROCESSES AND EMISSIONS. . . . . . . . . . . . . 3-2
3.2.1 The Basic Process. . . . . . . . . . . . . . . . . . . 3-2
3.2.2 Petroleum Solvent Plants. . . . . . . . . . . . . . . . 3-7
3.2.3 Perchloroethylene Plants. . . . . . . . . . . . . . .. 3-11
3.2.4 Fluorocarbon Plants. . . . . . . . . . . . . . . . . . 3-17
3.3 REFERENCES FOR CHAPTER 3.0 . . . . . . . . . . . . . . . . . . 3-21
4.0 EMISSION CONTROL TECHNOLOGY
4.1 TYPES OF CONTROL MEASURES. . . . . . . . . . . . . . . . . . . 4-1
4.2 CONTROL SYSTEM PERFORMANCE . ~ . . . . . . . . . . . . . . .. 4-6
4.3 ALTERNATIVE CONTROL SYSTEMS. . . . . . . . . . . . . . . . . . 4-12
4.4 REFERENCES FOR CHAPTER 4.0 . . . . . . . . . . . . . . . . .. 4-14.
5.0' DRY CLEANING PLANT MODIFICATIONS
5. 1 GENERAL. . . . . . . . . . . . . . . . . . . . . . . . . . . . 5- 1
5.2 SPECIFIC TYPES OF MODIFICATIONS. . . . . . . . . . . . . . . . 5-3
5.3 EFFECTS OF MODIFICATIONS ON EMISSIONS. . . . . . . . . . . .. 5-4
5.4 COMMON ALTERATIONS TO DRY CLEANING PLANTS. . . . . . . . . . . 5-5
5.5 REFERENCES FOR CHAPTER 5.0 . . . . . . . . . . . . . . . . . . 5-6
6.0 ENVIRONMENTAL IMPACT
6.1 AIR POLLUTION IMPACT. . . . . . . . . . . . . . . . . . . . . 6-1
6.2 WATER POLLUTION IMPACT. . . . . . . . . . . . . . . . . . . . 6-4
6.3 SOLID WASTE IMPACT. . . . . . . . . . .. . . . . . . . . . . 6-4
6.4 ENERGY IMPACT. . . . . . . . . . . . . . . . . . . . . . . .. 6-4
6.5 OTHER ENVIRONMENTAL IMPACTS. . . . . . . . . . . . . . . . . . 6-5
6.6 REFERENCES FOR CHAPTER 6.0 . . . . . . . . . . . . . . . . .. 6-6
7.0 ECONOMIC IMPACT
7.1 INDUSTRY ECONOMIC PROFILE. . . . . . . . . . . . . . . . . .. 7-2
7.2 MODEL PLANT SELECTIONS. . . . . . . . . . . . . . . . . . . . 7-13
7.3 ECONOMIC IMPACT ANALYSIS FOR
COMMERCIAL PLANTS. . . . . . .. .. . . . . . . . . . . . .. 7-16
v
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Page
'"
7.4 ECONOMIC IMPACT ANALYSIS FOR
INDUSTRIAL PLANTS. . . . . . . . . . . . . . . . . . . . . ... 7-24
7.5 ECONOMIC IMPACT ANALYSIS FOR
COIN-OPERATED PLANTS. . . . . . . . . . . . . . . . . . . . . 7-35
7.6 REFERENCES FOR CHAPTER 7.0 . . . . . . . . . . .. . . . . . . 7-40
APPENDIX A - EVOLUTION OF PROPO$ED STANDARDS.
APPENDIX B - INDEX TO ENVIRONMENTAL IMPACT
. CONSIDERATIONS. . . . . . . . .
. . . . .
......
. . A-l
. . . . . . . . . . . . . . B-1.
vi
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3.0 THE DRY CLEANING INDUSTRY
3.1
INDUSTRY DESCRIPTION
The dry cleaning industry is a service industry, involved in the cleaning
of apparel or renting of apparel. Basically, the industry is composed of three
categories, segregated by the type of services they offer. These are: (1)
coin-operated facilities, (2) commercial dry cleaning plants; and (3) industrial
dry cl eaners.
Coin-operated dry cleaning facilities are usually part of a "laundromat"
facility (although there are separate installations), and operate on either an
independent or franchise basis. They provide.a "self-service" type of dry
cleaning for the individual consumer. Commercial dry cleaning plants are the
most familiar type of facilities, offering the normal services of cleaning soiled
apparel or other fine goods. They include: the small neighborhood dry cleaning
shops operating on an independent basis ("Mom and POp" dry cleaners); the fran-
chise dry cleaning shops (e.g. "One Hour MartinizingH) and the specialty cleaners,
handling leather and other fine goods. The industrial cleaners are the larger
dry cleaning plants predominantly supplying rental services of uniforms or other
items to business, industrial, or institutional consumers.. The industry's estab-
lishments are principally located in urban areas and numbered 46,992 in 1972.*
The composition of the industry was approximately 37 percent coin-operated, 60
percent commercia:l and 2 percent industrial.l It should be noted, however, that
industrial dry cleaning establishments are generally quite large and account for
a much higher fraction of the total U.S. dry cleaning capacity than their num-
bers would indicate. No data were found which define just how much capacity
the industrial sector does have, however.
During the period between 1967 and 1972, the total number of establishments
in the industry decreased approximately 3 percent. This trend does not pervade
equally throughout the industry.. It is mainly attributable to a decrease in the
number of establishments in the commercial plant category which decreased approx-
imately 8 percent while the coin-operated and industrial plant categories in-
creased approximately 5 and 11 percent, respectively. The decrease in the number
of commercial dry cleaning plants in the past few years has occurred as the result
of the following factors:
* 1972 i~ the latest year for which actual data is available.
3-1
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.. The use of new equipment which has increased productivity and
consequently reduced the need for new plants to supply demand;
. The increasing use of washable synthetic fabrics which has
reduced the demand for dryc1eaning services; and
. The increasing use of coin-operated facilities by consumers.
This trend is reflective of the changing structure of the industry and is
significant since the commercial plant category represents the major propor-
tion of the total industry. A more detailed discussion of the industry struc-
ture, employment, receipts and projected growth is contained in Chapter 7.
3.2 DRY CLEANING PROCESSES AND EMISSIONS
3.2.1
The Basic Process
Dry cleaning is the cleaning of fabrics in an essentially non-aqueous
solvent. The principal steps in the process are identical to those of ordinary
laundering in water; 1) one or more .washes (baths) in solvent; 2) extraction
of excess solvent by spinning; 3) drying by tumbling in an. airstream. The sol-
vents used are categorized into two broad groups: 1) petroleum solvents;
which are' mixtures of hydrocarbons simllar--but, not identical--to kerosene; and
2) synthetic~,Q,~~ei1ts, which are halogenated hydrocarbons. Differences be-
tween the dry cleaning procedures for these two groups of solvents are due pri-
marily to three factors:
. Synthetic solvents are much more expensive than petroleum solvents.
. Petroleum solvents are highly flammable, while synthetic soivents
are nonflammable.
- . The densities of synthetic solvents are about twice that of petro-
leum solvents. -
The distinctions between the various solvents as well as the processes,
are discussed in detail later in this section. By way of illustration, Fi-
gure 3-1 is a schematic of a synthetic solvent-based plant. A petroleum
solvent-based plant would differ from this chiefly in that there would be
no recovery or reclaiming of solvent from the dryer.
3.2.1.1
Washing (Figure 3-2)
Fabrics to be cleaned are placed in the wheel of the cleaning machine,
and the machine is filled to a certain level with solvent. The wheel is then
rotated to tumble the clothes and force solvent through the fabric. Although
some machines use a batch wash operation where the clothes are tumbled in '
3-2
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- . . -
, , ,
FIGURE 3-1. PERCHLOROETHYLENE DRY CLEANING PLANT FLOW DIAGRAM.
VENTILATION
'111111181_11~111111111..lllla
AIR iii
.
.
.
FILTER ..' 0.. . - '
1111_~1118 ' - II~ ~~~~~IMER
SLUDGE iii . '
--.--. ,-_. --- - ,- .. -. III"D-WATER~--
SOLVENT STORAGE TANK, DISTILLED ' , . SEPARATOR'
~1_1111._~III',SOLVENT'FR6M- "
SOLVENT. RECLAIMING DRYER -
. ' . . .
. -. - - .~. III
. .- - - .
. ' . . .
. . . .
= ....~.~ = .
= ' S~m~T STILL =-.0 FiLfEn.1ifCK =,
. . . _II~ COOKER .
= ' SLUDGE . 1'8111~D I
. ' SLUDGE -. WATE~ .
.DIS~gSAL ~III SEPARATOR .
. USABLE' .... ...
, il:18.11.1111111111111~111111111'11'111111'11'1'
SOL VENT'-
FIL TER
W
I
W
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W
I
~
FIGURE 3-2. A TYPICAL DRY CLEANING MACIIINE.
DRY CLEANING
WHEEL
I
+
SOLVENT STORAGE TANK
,
I
~
PUMP
SOLVENT
FILTER
(TUBULAR)
...
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the same solvent throughout the cycle, most new equipment provides for con-
tinuous flow of fresh solvent through the wheel during the wash. There
can be as many as three "baths" or stages in the wash cycle in industrial
plants, but the usual commercial operation makes use of one or two.
3.2.1.2
Extraction
Removal of excess solvent from the fabric by spinning is usually
accomplished in the same equipment used for washing. Older petroleum plants
sometimes have a separate high' speed centrifuge called an extractor. A
major advantage of dry cleaning solvents over water is that the former are
much more readily removed by centrifugal force than is water. Hence, the
quantity of solvent to be removed in the drying step is much less than for
a water-based laundry, 'after equivalent extraction.
3.2.1.3 Drying
After extraction, the cleaned fabrlcs are dried by tumbling in a
heated air stream. In petroleum plants, the air flow to the dryer must be
sufficient to prevent the formation of an explosive mtxture in the exhaust
gases, which are vented to the atmosphere. Because of the much higher costs
and nonflammabiltty of synthetic solvents, some degree of solvent recovery
is always practiced during the drying phase in synthetic plants. ~n addi-
tional advantage of dry cleaning solvents over water cleaning is that the
former have lower heats of evaporation than water, so less energy is required
for drying.
3.2.1.4 Transfer and Dry-to-Dry Operations
There are only two basic types of dry cleaninq machines:
. Transfer machines where washing and drying are performed in
, different machines. After washing, the fabrics must be trans-
ferred to the dryer.
. Dry-to-dry machines in which washing and drying are achieved
in a single unit. In the past, these were tenned "hot"
machines, because they were hot at the end of the complete
cycle. However, the advent of room temperature drying renders
the latter name inaccurate.
All petroleum solvent machines are of the transfer type, but many synthetic
solvent plants can make use of either kind.
3-5
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3.2.1.5 Solvent Treatment
Because economic operation of a dry cleaning plant necessitates at
least partial recovery and reuse of used solvent, some solvent conditioning
steps are required to prevent solvent degradation and to otherwise enhance
the cleaning operation. The steps generally include filtration, distillation,
and "charging".
Some of the soils removed from fabrics are not soluble and must be
strained from the solvent by filtration. The filters sometimes contain acti-
vated carbon for removal of loose dye from the solvent. For drycleaning,
. .
filters are classified into three operational types:
. Single Charge - tube or disc types;
.
Mu1ticharge
powder or paper types;
- braided wire, helical spring, or nylon knit
tube types.
. Regenerative
These classificati-orrsare based on the manner in'which each filter is operated,
and not its physical characteristics, for reasons discussed in the following
mater!jla 1.
In single charge filters, the filter medium is used only once to filter one
batch of solvent, after whith it is discarded. Some of the older coin-operated
dry cleaning machines used single charge filters of the tube type. A new filter
precoat was appl'ied to the tubular substrate after each load of cleaning.
Several batches of solvent are filtered on.the same filter medium when a
multi charge filter is used. The total liquid volume which can be filtered be-
fore the fil ter medium must be renewed is dependent chiefly on the soil content
of the solvent and the size of the filter. Paper cartridge filters, a type of
multicharge filter, first appeared in coin-op machines, but they are becoming of
increasing importance in commercial plants. The principal advantage of cartridge
filters, compared to other multicharge types, is that they do not have to be
changed very frequently, so labor costs are reduced.
The regenerative filter does not fit into either of the above categories.
It may be viewed as a multicharge filter since one batch of filter powder is used
to filter the solvent from several loads of cleaning. However, it ;s a single
charge type in that the filter powder precoat is destroyed by reverse flow and
3-6
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then refor.med after each load, a procedure called bumping.
sion of all three types of filters is found in reference 2.
A detailed discus-
The solids or "muck" removed from the filters contains solvent which is
recovered by distillation in perchloroethylene plants, except where cartridge
filters are used. Cartridge filters are normally just drained and then discard-
ed. In petroleum plants, muck is drained of excess solvent - sometimes a vacuum
press is used - air dried, and then discarded.
In addition to the insoluble residue removed by filtration, a build
up of soluble non-volatile residue (NVR) occurs in the solvent. NVR is com-
posed primarily or oils, fats, and greases cleaned from fabrics. It is eli-
minated by distilling the solvent. In some "perc" plants, a single unit
serves for both distillation and muck cooking.
In order to remove water-soluble materials from fabrics during dry
cleaning, a small amount of detergent and water must be added to the solvent,
a step known as "charging". . Because these materials are removed during dis-
tillation, they must be replaced occasionally.
3.2.2 Petroleum Solvent Plants
Most of the petroleum solvent plants are quite large, and tend to be
located away from residential areas or shopping centers because of their high
emissions and the potential fire hazard. Although there are numerically more
synthetic solvent plants than petroleum plants, the larger siz~ of the latter
gives them about fifty percent of the total U.S. dry cleaning capacity.* On
the basis of d1$cussions with industry and trade association personnel and nu~
merous operators, it appears that most industrial dry cleaning is done with
petroleum solvents.
3.2.2.1
Solvent Characteristics
The principal solvents used are Stoddard or l40-F, both of which
are kerosene-like mixtures of hydrocarbons. Important characteristics are
as foll ows:
. Non-agressive (gentle to clothes);
. Highly flammable;
. Inexpensive (57-60t per gallon, at this time);
. . " . . . H ..
* This figure 1s only approximate and is .based on the estimates given by
several industry representatives.
3-7
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. Lighter than water; and
. 3
. Photochemically reactive, although the degree varles.
Table 3-1 is a compilation of physical properties for both petroleum sol-
vents and the two major synthetic solvents.
3.2.2.2 Equipment Characteristics
The equipment and methods used in drYI cleaning with petroleum solvents
are determined principally by the flammability of the solvents, but the tra-
ditionally low cost of the solvents is also a factor. Because of the fire
hazard, solvent recovery methods which concentrate the vapors and produce
. an explosive mixture--condensation is an examp1e--are avoided. In addition,
the low solvent cost makes recovery less attractive than for the more ex-
pensive synthetic solvents.
Although there are a number of commercial petroleum dry cleaners in
operation, most existing plants and virtually all new plants using petroleum
solvents are large industrial p1ants.8 Because these solvents are less
harsh than synthetic solvents and most of the equipment is made to rugged
industrial standards, petroleum plants have lifetimes of twenty to thirty
years or more.9 This serves to explain the relatively older age distribution
observed for these plants in a survey.10
Cleaning in petroleum solvents consists of the same steps outlined in
the preceding discussion of the general dry cleaning process. The procedure
for a large industrial plant would typically be as follows:
. Wash Phase - Clothes are washed in two or three baths of solvent,
the initial one--termed the "break"--uses solvent from a previous
wash. The second bath--termed the "wash"--uses sol vent charged
with detergent and water and the third bath, when used, is a
rinse cycle. There are other variations of the wash phase, and
one of them, "dual-phase", will be discussed below.
. Extraction - Although a few older plants have separate extractors,
all new petroleum plants utilize combination washer-extractors.
Most of these units have wheel diameters of 28 to 48 inches and
spin at 480 to 800 RPM, generatingextrattion forces of 150 to
250 Gls.l1 Because there is no solvent recovery during the drying
step in these plants, low solvent usage is highly dependent on
proper extraction.
3-8
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TABLE 3-1
CHARACTERISTICS OF DRY, CLEANING SOLVE.NTS4-7
W
I
~
l40-F . Stoddard
P rope rtv 140 - F' R-66 a Stoddard R-66a' Perch 1 oroethvlene " Freon"1l3
lash Point (TCC), of 138.2 143 100 108 non- fl ammab 1 e & non-flammable &
non-conti us ti b 1 e non-corrbus ti b le
Initial Boiling Point, of 357.8 366 305 316 250 117.6
Dry End Point, of 396 400 350 356 254 not known
~pecific Gravity, @ 60 of 0.789 0.8063 0.779 0.788 . 1. 62 3 1. 574
Density,lb/gal 6;57 6.604 6.49 6.56 13.55 13.16
Aromatic Content, Vo1. % 12.1 7.0 11.6 5.9 0 0
Corros i veness None None None None Sli gh~ on metal none
Heat of Vaporization, Btu/lb b. b ",SOOb b 90 63
. ",500 ",500 . . ",500 .
oxicity (TLV) ppm 200 200 200 200 100 1000
Odor Mild Mild Sweet Sweet Li ke ethe r Li ke CCL4
Color Water White Water white Water White Water Whi te Water White Water White
Vapor Dens ity (Air=1.00)c 1.0 1.0 1.0 1.0 1.1 2.5
a This
. b This
~ This
refers to the "old" Los Angeles Rule 66 solvent regulation, which allowed up to 8% aromatic content.
value can be expected to vary depending as it does on the exact composition of the solvent.
is the density of a saturated mixture of the solvent in air. not the pure solvent vapor.
-------
. :Dryin[ - All petroleum plants are transfer operations, so the clothes
must De carried from the washer--or the separate extractor--to the
dryer after extraction. The dryers used are normally about one-
hundred pound capacity units, the number of which depends on the
size of the dry' cleaning operation.* The drying air is heated by
steam coils, passed through the tumbling clothes, and vented
to the 'atmosphere. After the clothing is dry, most tumblers
have a cool-down cycle to prevent wrinkling. Typical exhaust con-
ditions for a 110 pound dryer are as follows:12
Unit--Cisse1l Model 44/42
Exhaust Temperature--100oF initial
2000F peak
15QOF average
Exhaust Air Flow --2200scfm** .
At the present time, a large industrial dry.: cleaner would, probably have a
SOO-lb. capacity washer/extractor and three to six 100-lb. capacity tumblers.
As noted earlier, "dual phase" petroleum machines are now in use in
the industrial drYI cleaning business. The wash cycle includes an initial
bath in petroleum solvent fol)owed by extraction, a bath in water, and a
final ext~action. In spite of the water wash, solvent retention by the
clothes is roughly the same as with' a single phase system.13 However, the pre-
sence of water in the'clothes does fhcrease the drying time.
Dual phase machines have become a major factor in industrial dry
cleaning recently due to the following sequence of events:
1.
Polyester clothes, which replaced cotton in the uniform rental
business, are dry cleaned because of their short lifetimes in the harsh
detergents needed for water washing. ' .
Dry: cleaning of polyester in petroleum solvent alleviated the ex-
cessive fabric degradation, but an odor problem developed in the
clothes after cleaning.
2.
The dual phase process eliminates the odor problem, which was
caused by water soluble soils in the clothes.
4. The increasingly restrictive regulations against sewering of
strong detergents added further impetus to the move toward dual
phase machines. .
3.
* There are dryers with as much as 450-500 pound capacities, but they are
used less frequently.
**This does not include the solvent vapor volume, which varies during the
cycle. Because of the explosion hazard of the solvent, this concentration
cannot exceed about 0.2S% by volume.
3-10
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This process has some advantag~5 over conventional water-based laundering:
. As noted above, water pollution problems are greatly- lessened.
. Load cycle times are reduced because of the shorter drying cycle.
. The energy requirement for drying is much less than for water
washing.
3.2.2.3 Emission Characteristics
Because there is no solvent recovery during the drying cycle and
'. . . 4 . . .. .
the filter muck is not cooked, petroleum plants have much higher solvent losses
than synthetic plants. Typical losses for the various elements in a petro-
leum solvent operation are given in Table 3-2, as reported by the International
Fabricare Institute (IFI).14 - .
TABLE 3-2
Solvent Losses in Petroleum Plants
(Pounds of Solvent per Ton of Clothing)
Source Average Loss
Evaporation at Dryer
. Washer with Separate Extrattor 238
. Washer-Extractor/Front Loading 277
. Washer-Extractor/Side Loading 343
Retention in Filter Muck (Drained)
I Screen or Rigid Tube Filter 191
. Regenerative Filter 102
Retention in Paper Cartridges 16
Retention in Still Residue 20
Miscellaneous Evaporation Losses 13
.- - "- ..
At the present time, no petroleum plant control systems are
in the U.S., but one company has tested a prototype solvent
3.2.3 Perchloroethy1ene Plants
In contrast to petroleum plants which are predominantly large industrial
operations, perch1oroethylene machines find their major use in commercial dry-
cleaning plants. The typical neighborhooddryr cleaner uses a perch16roethy1ene-
based process.
known to be operating
recovery devi ce. 15, 16
3.2.3.1
Solvent Characteristics
Although other chlorinated hydrocarbon solvents have been used for dry
cleaning in the U.S., perchloroethylene is the only chlorinated solvent seeing
3-11
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significant use at this time. *An estimated 400 million pounds of "perc" is
used annually for dry' cleaning purposes.17 The detailed .physica1 data are in
Table 3-5, but the solvent may be generally characterized as follows:
. Usually considered essentially non-reactive photochemica1ly;3
. Non-flammable;
. Very high vapor density;
. High cost ($2.50-3.50/gal);
. Moderate toxicity;
.
~ggressive solvent properties.
In spite of the higher cost per gallon of perc, solvent costs for perc plants
are quite competitive with those for Stoddard plants, because the former are al-
ways used with solvent recovery equipment. Stricter fire codes, increases in
petroleum solvent costs, and environmental..considerations have resulted in the
use of perc-based equipment for most new plants. (See subsection 7.1.3)
3.2.3.2 Equipment.£haracteristi~s
Petroleum dry. cleaning machines are all transfer uni ts, whereas perc
machines may be either transfer or dry~to-dry types. However, the great majori-
ty of perc machines are transfer units for the following reasons:
. Because washing and drying are performed in different pieces of
equipment in transfer machines, these operations can occur simul-
taneously on different cleaning batches, in contrast to the dry-to-
dry machine where a given load must be washed then dried in the
same unit. As a result, transfer machines can handle about twice
as many loads per day as can dry-to-dry machines using the same solvent.
. As the dry-to-dry machine is hot at the end of a drying cycle,
the incoming solvent for the next wash cycle picks up sensible
heat from the hot metal and the solvent temperature can become
quite high, unless a cooler is added to the ~ystem. High solvent
temperatures - the desirable range is 85-100 F - cause two problems:
(1) hot solvent attacks the machine seals and gaskets, ~dding to
maintenance costs; and (2) the higher va~or pressure of the hot sol-
vent can lead to greater solvent losses.18. It should be noted
that at least one manufacturer now has a single pass system Wh1cn
operates at room temperature.
* This is probably because it is less toxic and/or less reactive than most
other chlorinated hydrocarbons.
3-12
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I A dry-to-dry machine costs significantly more than a transfer machine
including both washer-extractor and reclaiming type dryer.
In spite of these disadvantages, dry-to-dry machines are of increasing
interest to the industry as a result of the following advantages:
I Because there is no transfer of solvent-laden clothing between the
washing and drying cycles, there is little chance for perc vapors
to escape into the work area. Therefore, it is relatively easy to
meet the Occupational Safety and Hea.1th Administration standards
for maximum perc concentrations in the work area.
I The machines are basically "push button" operations and require
little attention by the operator during the cleaning cycle. (This
does not imply that they do not require a conscientious maintenance
program, however.)
I When properly maintained, dry-to-dry machines use less solvent per
unit of cleaning than equivalent transfer units.
Regardless of the machine type, transfer or dry-to-dry, perc plants
have the same three process steps as petroleum plants:
I Washing - A few industrial perc plants make use of a two bath wash
cycle as described for petroleum dry cleaning, where an initial wash
bath, in highly charged solvent, is followed by a rinse in fresh
solvent. However, most commercial perc plan~s - ~ost perc plants
are commercial operations - use a single bath system.
I Extraction - All perc extractors now manufactured are combined wash-
er-extractors, but a few very old plants still have separate ex-
tractor units. Good extraction is not so important to solvent con-
servation in perc plants as :it ,is in petroleum plants. because all
perc dryers utilize a solvent recovery system. Extraction forces
in modern washer-extractors are usually in the range of 55-95 G's,
and extraction times are seldom more than about 5-7 minutes. 11
I Drying - Perchloroethylene-based dry cleaning plants always use
reclaiming dryers. In a reclaiming dryer (Figure 3-3), the
evaporated solvent is removed from the exhaust gas by condensation
on a cooling coil. Water is removed from this recovered solvent,
and it is returned to the storage tank. The exhaust gas is returned
to the dryer until the solvent concentration becomes so low that
the cooling coils can no longer condense the solvent vapors. Fresh
air is then used to complete the drying, and aerate the clothes.
This air is vented to the atmosphere. Recovery of solvent from
this air requires a control device of some type. In addition to
their greater ease of extraction, mentioned previously, synthetic
solvents have much lower latent heats of evaporation than water
or petroleum solvents, so the heat required for drying is much less
3-13
-------
-----
FRESH
AIR
VENT
....-- - .. .--.. 0
AIR
VALVE "....
t
w
- I
--'
.$=0
--+
+-
/
FIGURE--l~3,1--A TYPtCAL- RECUHMING DRYER,'
LINT
SCREEN
~
COO[fNG
WATER
OUTLET
SOLVENt-
CONDENSER
COOLING
WATER
INLET
t-
WATER -
SEPARATOR
. . -. ..._+
SOLVENT
AIR
VALVE
!
~_. _.0- .+. ~---
EXHAUST
WATER
-------
on a per-pound basis. For example, perchloroethylene has a la-
tent heat of 90.2 Btu/lb., compared with about 970 Btu/lb for
water and 500 Btu/Tb for petroleum solvents. There is no ex-
haust from a reclaiming dryer during the drying cycle per se,
but during the aeration cycle, typical exhaust conditions are
as fo 11 ows :
Dryer Size - 50-lb capacity
Exhaust Temperature - l400F initial
- 700F final
- lOOoF average
Exhaust Flow - 275 scfm
A typical commercial perc plant has a 30-60 lb. capacity washer-extractor with
a reclaiming tumbler of equivalent size, and about half the plants have carbon
adsorption-type perc collectors to reduce solvent consumption.10 These collectors
are discussed in detail in Section 4.0, Emission Control Technology.
3.2.3.3
Emission Characteristics
Unlike the situation in petroleum plants, where no emission controls
are used, perc plants frequently have vapor adsorbers to reduce solvent usage.
Typical solvent losses for both controlled and uncontrolled perch10roethy1ene
drycleaning plants are shown in Table 3-3, as reported by IFI.14 These are for
well-operated plants.
The usual plant has a regenerative filter with a muck cooker, and this
results in a consumption rate of about l62.6-lb of solvent per ton of clothing.
For an adsorber-equipped plant, the corresponding solvent usage is about 97.6-lb
per ton of clothing, which is equivalent to a 40% loss reduction. It should
be emphasized that these usage levels are for well-operated plants, and the
average losses - including controlled and uncontrolled plants - is estimated to
be about 196.8-lb of solvent per ton of clothes cleaned.10
3-15
-------
TABLE 3-3
Solvent Losses in Perchloroethylene Plants 14
(Pounds of Solvent per Ton of Clothing)
I
I .
Source Pl ants Without Plants With
Vapor Adsorber Vapor Adsorber
Evaporation @ Washer 10.8 0
Evaporation @ Dryer 59.6 0
Vapor Adsorber Exhaust - 5.4
(Properly Operated)
Retention in Filter Muck
8 Rigid tube filter:no cooker 281.8 281 .8
8 Rigid tube filter-muck cooker 32.5 32.5
8 Regenerative filter-muck cooker 19.0 19.0
Retention in Paper Cartridges
8 Drained 35.2 35.2
8 Dried in cabinet vented to - 24.4
adsorber
Retention in Still Residue 32.5 32.5
Miscellaneous Losses 40.7 40.7
..
()
3-16
-------
!-~
I
3.2.4 Fl uorocarbon Pl ants
All fluorocarbon plants utilize the same solvent, 1,1,2-trichlorotri-
fluoroethane (IiFreonll 113), manufactured by DuPont. * The solvent is sold as a
charged dry; cleaning agent called IIValcleneli. At the present time, fluoro-
carbon dry: cleaning machines are used only in corrmercial and coin-pp installa-
tions.
3.2.4.1
Solvent Characteristics
but its
The detailed physical description of solvent 113 appears in
predominant features may be summarized as follows:
. Extremely unreactive;3
Table 3-5,
. Non-flammable;
. Low toxi ci ty;
. High cost ($8-10.gal);
. Very' hi gh vapor dens i ty;
. Liquid~density greater than water; ,
. Non-agressive.
The low agressiveness of this solvent makes it very suitable for' fine cleaning,
and many operators purchase IIValclene~ machines for this reason. In addition,
. ,
the new fire codes and environmental regulations are making its use more advan-
tageous.
3.2.4.2 Equipment Characteristics
Because of the very high cost of IIValclenell solvent, excellent solvent
recovery must be obtained to make the machines competitive wit~ perc or petro-
leum machines. Consequently, all IIValclenell machines are of the dry-to-dry
variety, and all have built-in control devices. In the early fluorocarbon
machines, the solvent recovery unit was a carbon adsorption column which ex-
hausted to the atmosphere, but new machines use refrigeration coils in a closed
loop system similar to the drying stage in a perc reclaiming dryer. Expansion
and contraction of the air stream are accounted for by an elastomeric IIlung".
* Both II Freon " and "Val clene" are trademarks of E. I. DuPont de Nemours and
Company.
3-17
-------
The basic process for fluorocarbon dry' cleaning is identical to that
for perchloroethylene with minor exceptions:
. The machines are sold as complete packages including the washer/
extractor/dryer system~ the solvent distillation system and the
filtration equipment.
. Currently manufactured fluorocarbon machines are fully closed to
the atmosphere during operation.
. Drying is at a low temperature with air entering the cleaning
wheel at about l200F. .
. Because of the rapid evaporation rate of fluorocarbon l13~ the
. drying time is very short and the total cycle time for a load
of clothes is considerably less than for the same load in a perc
dry-to-dry machine of similar size.
Figure 3-4 shows the air flow during the drying cycle.
I
I" -,'
The rapid~ low temperature drying characteristic of solvent 113~ to-
gether with its gentle solvent properties~ make it particularly useful for
cleaning such de)icate items as leather. In addition, 113 has the lowest toxi-
city of any of the' ,common- dry' cle:aning' so.lvents, which makes it a good choice
for applications involving non-professional operators, such as coin-operated
cleaners. As a consequence of these principal areas of use, most fluorocarbon
machines are of relatively small capacity. The most common sizes appear to be
12-lb and 25-1b.
3.2.4.3
Emission Characteristics
Because fluorocarbon dry. cleaning is a recent development compared to
the other basic systems, not a great deal is known about typical solvent losses
at this time. There are several possible solvent loss points in a "Valclene"
machine:
. Losses from the cleaning wheel when the doo~ is opened between
loads. '
. Solvent retained by the solvent filter media.
'. Solvent retained by clothes. '
. Leakage losses due to faulty gaskets and/or seals.
The latter two sources should be negligible in a well-maintained, proper1y-
operated machine. In some machines, solvent retention by filter cartridges can
3-18
-------
AVERAGE T = 120°F.
MAXIMUM T = 17S0F.
AIR
HEATER
W
I
-'
\.0
DRY
VALVE
. REFR I GERA TED
CONDENSER
BLOV!ER
. .
- '." ..
FIGURE 3-4. I A TYPICAL FLUOROCARBON DRYING CIRCUIT.
-------
be minimized by placing them in the wheel and running the unit through a
drying cycle - the wheel is not rotated during this operation - to evaporate
and collect any retained solvent.
Although no definitive data are presently available on solvent losses
from fluorocarbon machines, DuPont has a certification standard for professional
machines corresponding to 60 pounds of solvent losses per ton of clothes cleaned.6
Performance tests carried out in the Vic Manufacturing Co. laboratories gave a
solvent consumption rate of about 37 pounds of solvent per ton of clothes cleaned.15
~
. 3-20
-------
1----
3.3 REFERENCES FOR CHAPTER 3.0
. 8.
1.
U.S. Department of Commerce, Bureau of Census, 1967 and 1972 Census of
Business, Selected Service Industries-Area Statistics.
2.
Martin, A.R. and Smith, William H. "Drycleaning Filter Systems," Inter-
national Fabri~are Institute (IFI), Technical Bulletin T-440, June
1968.
3.
Feldstein, Milton, a critical review of regulations for the control of
hydrocarbon emissions from stationary sources, J. Air Poll. Control
Assoc. 24, No.5, May 1974.
Danielson, John A. "Air Pollution Engineering Manual," 2nd ed., U.S.
Environmental Protection Agency, Report No. AP-42, May 1973.
4.
5.
6.
Martin, A.R., "Valclene", IFI, Technical Bulletin T--458, February 1970.
Anonymous, "Ventilation Recommendations for 'Valclene' Machines," E.!.
DuPont de Nemours & Co., Technical Bulletin V-8, March 1974.
7.
Benning, A.F., and McHarness, R.C., liThe Thermodynamic Properties of
'Freon' 113 (CC12 FCC1F2)'" DuPont Co., Circular T-1l3A, October 1973.
~~Quarterly Machinery Market Report for the Quarter Ended June 30, 1975,"
Laundry and Cleaners Allied Trades Association, 22 August 1975.
9.
Information provided by Mr. Steven Landon, President, Washex Machinery
Corporation, 4 December 1975.
Watt, Andrew, IV, and William E. Fisher, "Results of Membership Survey
of Drycl eaning Operati ons, II IFI Speci al Reporter #3-1'~ January-February
1975. ..- ,
10.
11.
Anonymous, "An Introduction to Industrial Drycleaning Methods," Part One,
IFI Special Reporter #1-3, Winter 1973.
Data courtesy of Mr. Norman Bullock, V.P. of Engineering, W.M. Cissell
Manufacturing Co., Louisville, Ky., 2 February 1976.
12.
13.
Information provided by Mr. Steven Landon, President, Washex Machinery
Corporation, via telephone, 2 February 1976.
Fisher, William E., liThe ABC's of Solvent Mileage, II Part One, IF!
Special Reporter, #3-4, July-August 1975.
14.
15.
Personal discussions with representatives of Vic Manufacturing Company,
13 December 1974, at the Vic offices in Minneapolis, Minn.
16.
Barber, J.W., Research Director, Vic Manufacturing Co., Minneapolis,
Minn., letter to C.F. Kleeberg, U.S. E.P.A., 6 February 1976.
17.
Personal communications with representatives of both Dow Chemical and
PPG Industries.
3-21
-------
...:
18.
Information provided by Mr. Joseph Panepinto, Detrex Sales Repre-
sentative, in TRW Environmental Engineering Division offices, 31
July 1975.
3-22
-------
4.0 Et4ISSION CONTROL TECHNOLOGY
This chapter and Chapter 7.0-Economic Impact are both analyses of avail-
able emission control technology for the dry cleaning industry. However, this
chapter is a technological assessment of demonstrated control systems) while
Chapter 7.0 is an assessment of the costs and economic effects of alternative
controls based on demonstrated control technology. Together these two analy-
ses satisfy the requirement of Section 111 of the Clean Air Act that new source
performance standards be based on lithe best system of emission reduction which
(taking into account the cost of achieving such reduction) the Administrator
determi nes has been adequately demons trated" .
4. 1
TYPES OF CONTROL MEASURES
For the most part, solvent emission controls for dry cleaning plants have
developed out of economic necessity. In order for the more costly synthetic
solvents - chlorinated hydrocarbons and fluorocarbons - to compete with inexpen-
sive petroleum solvents, a substantial degree of solvent recovery is necessary
during the drying operation. This is the reason for the use of recovery dryers
on all synthetic solvent machines. The move towards the use of synthetic sol~'
vents was also abetted by increasingly restrictive fire codes and emission regu-
lations for petroleum solvents.
Because of differences in the dry cleaning processes and the physicochemical
characteristics for the various solvent classes, all control measures are not
appropriate for every type of plant. Table 4-1 shows possible control measures
for the three basic types of cleaning plants, and the following material dis-
cusses both current industrial practice and possible improvements in emission
controls.
TABLE 4-1
POTENTIAL AND APPLIED CONTROL MEASURES
FOR DRY CLEANING PLANTS
Plant TVDe
Contro 1 Measure Petrole'um "Perc" II Valclene"
Carbon Adsorption X Xa- Xa
Housekeepingb Xa Xa Xa
Incineration X
Process Changes XC XC
Refrigeration Condensation X X Xa
a Commonly used' technique.
b Includes record keeping for solvent consumption.
c For example, eliminate transfer machines at new plants.
. 4-1
-------
4. 1 . 1
Perchloroethylene Plants
As noted in Chapter 3, the high cost of perc necessitates a certain
degree of solvent recovery. Although the water-cooled condenser system used
for recovery dryers is actually an integral part of the dryer, it serves the
same function as an emission control device. Additionally, in many plants,
the offgases from the final stages of the drying operation - normally vented
to the atmosphere - are sent to a vapor adsorption unit where perc vapors are
retained on activated carbon.* The solvent is later desorbed with live steam,
condensed, separated from the condensed water, and returned to the storage
tank as distilled solvent. There is usually a floor pick-up located near the
cleaning machine to collect vapors from transfer operations or leakage losses.
The operational performance of carbon adsorbers in perc plants is discussed in
detail in Section 4.2. while reference 1 provides supporting information.
Incineration of chlorinated hydrocarbons can produce hydrochloric acid
(HC1), chlorine (Cl), and phosgene (COC12).3 These compounds can be removed by
water scrubbing, but several factors make incineration a questionable practice:
.; . . . Fuel prices. are very high at this time, and indications are that
they will remain so in the future.
. Considering the toxicity of the combustion gases, a failure in the
scrubber could have severe consequences.
. The scrubber could constitute a potential water pollution hazard.
Refrigeration does not appear to be in use for control of perc emis-
sions, except for the water-cooled condensers used on recovery tumblers. This
is due in large part to the great success enjoyed by carbon adsorption equip-
ment, and the fact that refrigeration cannot achieve the same recovery efficiency
as carbon adsorbtion ona vented system.
In addition to the hardware type controls, good emission control caD be
obtained by maintaining all equipment in good condition and good operating prac-
tices. The International Fabricare Institute (IFI) has suggested the list in
Table 4-2 as. possible causes of excess solvent consumption. A set of operating
. .
procedures based on a list such as this constitutes a useful control measure if
it is coupled with a mandatory record keeping program.
* A membership survey by the International Fabricare Institute indicated that
about 52 percent of the responding perc.plants hav~ vapor adsorbers.2
4-2
-------
TABLE 4-2
CAUSES OF EXCESSIVE LOSS OF PERCHLOROETHYLENE~
l.
2.
3.
4.
S.
6.
7.
8.
9.
10.
11.
Loose bungs on storage drums.
Loose pipe fittings.
Bad gaskets.
Clogged lint filter.
Lint build-up on condenser.
Lint on fan blades.
Lint between basket and shell of dryer.
Water separator malfunction.
Machin~ overloading.
Leakage in air inlet and outlet vents.
Faulty adsnrber operation.
4.1.2 Petroleum Solvent Plants'
In the past, there has been little emphasis on reducing solvent consumption
in petroleum plants because of the low cost of these solvents. However, recent
increases in solvent cost should make solvent recovery much more attractive. Al-
though ,five control measures - carbon adsorption, housekeeping, incineration,
process changes, and refrigeration/condensation - are shown in Table 4-1 as
having potential for petroleum plants, only one of these, housekeeping, is cur-
rently in use in the United States. Table 4-2 is also applicable to petroleum
p1 ants.
4.1.2.1
Carbon Adsorption
A prototype carbon adsorption unit has been developed and tested by Vic
Manufacturing Company, one of the major U.S. manufacturers of dry cleaning equip-
ment and carbon adsorption units.S From a technological standpoint, the petrole-
um solvent test unit was a success. However, the equipment cost is very high
relative to perc adsorbers, for the following reasons:6, 7
.
. High Exhaust Volumes - because petroleum solvents are flammable, a
great deal of dilution air must be used during drying to keep the
solvent concentration in the exhaust below the explosive range.
Hence, the adsorbermust be larger to accomodate the greater flow
rate.
. Non-Reclaiming Dryers - whereas, in perc plants, most of the solvent
from drying is removed by condensation prior to venting, this is not
done in petroleum plants because condensing of the solvent can re-
sult in formation of an explosive mixture. Consequently, the carbon
bed for a petroleum dryer must be sufficiently large to hold all of
the solvent remaining in the clothes after extraction.
4-3
-------
. Low Solvent Cost - because petroleum solvents are very cheap
compared to synthetics the value of the recovered solvent is
lesss which makes annuali~ed operating costs relatively higher
than for synthetic solvents.
. High Exhaust Temperatures - petroleum dryers have considerably
higher exhaust temperatures than perc dryers.* Because the
efficiency of carbon adsorbers is reduced by elevated temperaturess
and the fire hazard is increaseds an intercooler is required
between the dryer and the adsorber.
In spite of its high cost, carbon adsorption is
control for petroleum plants. The economic and
in Section 7.4..
considered a viable means of
cost implications are assessed
4.1.2.2
Incineration
From a strictly technological standpoint, incineration is a feasible
control measure. However, the high exhaust volumes from petroleum dryers and
the current cost of fuel severely handicap its use at this time, whether a
separate incinerator is used or the boiler of the cleaning plant is used for
combustion: 8
. Separate Incinerator - the hdgh volume of ai r woul d requi re a
large quantity of fuel for proper burn-out of the solvent vapors.
. Boirer Incineration - the exhaust volume from a typical petroleum
dryer is too great to be handled by the relatively small boilers
in industrial laundries.
4.1.2.3 Process Changes
Discussions with trade associations, petroleum plant operatorss and
equipment manufacturers disclosed no original recommendations for emission-re-
ducing process changes, which could be implemented in a reasonable period of
time. A representative of one manufacturer indicated that it mig~t be possible
to reduce solvent em)ssions from petroleum plants by as much as 80 to 90%, but
doing so would require considerable research and development of new equipment
1n such areas as: (1) filter muek cooking; (2) improved distillation; (3)
improved liquid and vapor seals; and (4) reclaiming type dryers for petroleum
9 . .
solvents. Study of the solvent loss data in Table 3-2 leads to some other
viable alternatives:
* Both the boiling point and the latent heat of evaporation of petroleum sol-
vents are higher than for peres so higher dryin~ temperatures are needed.
4-4
-------
. Because all of the petroleum solvent remaining in the clothes
after extraction is evaporated at the dryer, differences in
extraction efficiency of washer/extractors have direct effects
on the quantities of emissions. However, emission control by
washer/extractor type is limited because the highest emission
losses result from the most popular washer/extractor, the side
loading mode1.*
. There is a considerable difference in solvent retention by the
various types of filtration systems in use. The replacement of a
regenerative filter by a paper cartridge filter can yield emission
reductions of 18 to 23 percent, depending on the type of washer/
extractor in use. Nevertheless, in industrial plants, the major
users of petroleum machines, the extremely high, soil loadings
would require that the cartridges be changed too frequently for good
operation.l1 Therefore, cartridge filters do not appear to be a '
promising control measure for high soil cleaning applications.
4.1.2.4 Refrigeration/Condensation
As was briefly noted in the discussion of carbon adsorption, this
technique is not considered practicable because of the danger of forming an
explosive mixture as the exhaust gases are cooled.? In addition, the cooling
requirements would be very large in view of the high temperature of petroleum
drye r exhaus ts .
4.1.2.5
Conclusion
As a result of the severe constraints on the use of other techniques,
the best approach for controlling petroleum solvent dry cleaning plants is
considered to be the combination of two control measures:
. Housekeeping - rules for equipment maintenance and operating pro-
cedures should be established that correspond to best current
practice in the industry. Equipment manufacturers' recommendations
provide a good basis for'these rules.
. Carbon Adsorption - in spite of its cost, the vapor adsorber ap-
pears to be the only device suitable for control purposes.
* Side loading, dual phase washer/extractors have distinct advantages over the
other types, as discussed in Section 3.2. Washex Machinery Corp., which
controls an estimated 90 percent of the petroleum machinery market, indicated 10
that 90 percent of their current petroleum machine sales were dual phase models.
4-5
-------
,-
4.1.3 Fluorocarbon Plants
At this time, the only fluorocarbon being used for dry cleaning purposes
is Freon 113, sold by DuPont as a charged solvent named Valclene.* Because
fl uorocarbons are by far the most expensi ve of the ordinary dry cleaning sol-
vents, fluorocarbon machines must show low solvent consumption to be cost com-
petitivewith perc or petroleum machines. Consequently, .all fluorocarbon
machines are of the dry-to-dry type and all have built in control devices,
either a refrigeration/condensation system ora dual canister carbon .adsorber.
All new machines are equipped with refrigeration units, but carbon adsorbers
were formerly used. According to one major manufacturer, the reasons for the
change were as follows:12
. Because fluorocarbon machines are necessarily automatic in coin-op
service, the adsorber control system proved to be overly complex.
. If a fluorocarbon machine is used in the presence of a perc plant -
., frequently t,he case - there i ~ a. chance that perc vapors wi 11 be
adsorbed by the carbon bed and contaminate the fluorocarbon solvent.
. .
. The adsorber-equipped units required too much floor space, and had
high steam consumption, because they required 100 percent distillation.
Regardless of the type of control device, fluoroca~bon machines generally
show very low solvent consumption rates compared to plants using other solvents.
However, poor maintenance and/or operating practices can negate the advantages
of dry-to-dry machinery and built-in control systems. Therefore, housekeeping
measures with record keeping are considered necessary to ensure that low emis-
sions performance of new machinery is maintained.
4.2 CONTROL SYSTEM PERFORMANCE
The dry cleaning plant operator expresses solvent consumption by means of
a term called IImileagell, which is the number of pounds of fabric cleaned per
52 gallon drum of solvent consumed. Therefore, mileage is directly proportional
* Both Freon and Valclene are registered trademarks of the DuPont Company.
4-6
-------
to the reciprocal of the emission rate, usually expressed as pounds of solvent
per ton of fabric cleaned. Mileage depends on many variables, including: the
type(s) of fabric; machine and solvent type; ductwork design; the use of con-
trol equipment; and operating and maintenance procedures. Consequently, mile-
age figures show broad variations between different. dry cleaning plants. The
remainder of this section discusses the mileage performance of emission con-
trols in perchloroethylene, petroleum, and fluorocarbon plants after a brief
description of carbon adsorption, the most prevalent type of control device
found.in.dry cleaning plants.
4.2.1. Carbon Adsorbers
Adsorption is the process by.which gas molecules are concentrated and
retained at a.solid surface. .Although there are two types of adsorption, physi-
cal adsorption and chemisorption, only. the former is considered in the present
context.* Most solid surfaces will adsorb gases, but the ..extent depends on the
gas/surface combination, as well as temperature, pressure, and the surface area
of the solid. The fact that the degree of adsorption decreases with increasing
temperature provides the basis for the use of adsorption as a means of emission
control for dry cleaning plants. Solvent vapors can be collected from exhaust
gases at a low temperature (-lOOoF) and then removed (desorbed) later in a con-
centrated form by application of heat. .
For dry cleaning plants, activated carbon is used as the adsorbent for
the following reasons:
. The material has higher internal surface area than any other material
known, and so it has good capacity for solvent.l
. The adsorption/desorption cycle occurs over a temperature range which
is easily attainable.
. The efficiency of removal of solvent from e~baust gases can be greater
than 99 percent with reasonable bed depths.13
. The carbon bed has long life, fifteen yef3~ or more, and it can be
reprocessed, if it becomes contaminated. -
* Chemisorption involves much higher bonding forces and considerably higher
temperatures are needed to remove adsorbed molecules from the surface than
is true for physical adsorption.
4-7
-------
. Utility costs for,regeneration of adsorbed solvent are low.13'
(See Sections 7.3 through 7.5 for more detail on operating costs.)
The activated carbon is placed in metal shells called canisters, and
solvent vapors are collected by passage of gases from the following sources
through the carbon bed:
.
Cleaning Machine - when the machine door is opened, air is drawn
through the opening by a blower to prevent accumulation of solvent
in the work area.
. Reclaimer - when the dryer switches to the aeration cycle, exhaust
air is drawn by the blower through the bed.
. Pickup Vents - floor and other vents are used to reduce solvent levels
in the working area.
I '.. . .
When the carbon is saturated, the solvent is regenerated by injecting live steam
into the canister. The steam and solvent vapors are collected from the off-
gases by condensation on a water cooling coil, and the solvent is recovered by
means of a water separator.
Carbon adsorption units are available in sizes to fit all commercially-
, 'available dry cleaning machines. The size of the adsorber - commonly called a
"sniffer" by dry ,cleaners - needed is based on the solvent consumption of the
dry cleaning plant. For larger plants, a double unit with two canisters is
recommended, so that one unit can be in the adsorb mode while the other is
being regenerated. In smaller plants, the carbon bed can be steamed out at
the end of the work day. Table 4-3 gives operating parameters for some commonly
used vapor adsorbers.
TABLE 4-3
SPECIFICATIONS OF CARBON ADSORBERS USED
IN PERCHLOROETHYLENE DRY CLEANING PLANTS14
Plant Solvent Adsorber Solvent Exhaust Air Boi 1 e r
Consumption Capaci tya Capacity Requi rements
< 1 drum/mo. 1 3/4 gal. 600 CFM 3~ H.P.
1-2 drum/mo. 4 gal. 600 CFM 3~ H.P.
> 2 drum/mo. 8 gal. 1200 CFM 3~ H.P.
- b 4J2 gal. 1400 C~M 3~ H.P.
a Solvent retention before steam-out is needed.
b This unit is for coin-op facilities where exhaust flow rates are high
to solvent consumption if several machines aerate simultaneously.
relative
4-8
-------
It should be noted that simply installing a carbon adsorber in a plant
is no panacea for poor solvent consumption. Data from several sources indicate
that poor operating procedures and inadequate maintenance can negate the poten-
tial effectiveness of carbon adsorbers, as the material which follows will illus-
t ra te .
4.2.2 Perchloroethylene Plants
. The mileage obtained in a perc plant appears to be more
ed by the competence of the operator than by any other factor.
examples serve to illustrate this situation:
strongly affect-
The following
. Mileage data collected by Dow Chemical - a major perc manufacturer -
in a customer survey indicate that the average perc plant without
an adsorber achieves a mileage of 6,940 pounds per drum, and an ad-
sorber increases this figure to about 8,370 pounds per drum. How-
ever, in both adsorber-equipped plants and non-adsorber-equipped
plants, the range of mileages reported was enormous, and plants in
each category showed both operators with mileages less than 2,000
pounds per drum and others with mileages greater than 15,000 pounds
per drum.15
. The International Fabricare Institute (IFI) gives most of the credit
for either poor mileage performance or exceptional mileage performance
to the plant operator. One plant (without an adsorber) visited had
a mileage of 2,900 pounds per drum. The plant showed obvious mechan-
ical problems which even superficial maintenance should have corrected.
In marked contrast, IFI personnel have obtained mileages Qf 11,000
pounds per drum in transfer machines, without adsorbers.lb
In plant visits and tests made in the course of this study, a wide
range of mileages were reported. 'The following are illustrative:
8,000 pound/drum for an adsorber-equipped, dry-to-dry machine;17
9,700 pound/drum for an adsorber-equipped transfer machine;18 7,500
pound/drum for an adsorber-equipped, transfer machine;19 13,136
pound/drum for an adsorber-equipped, transfer machine;20 and greater
than 20,000 pound/drum for an adsorber-equipped, transfer machine.21
Two important points can be made on the basis of these examples:
.
. Without proper maintenance and operation, even well-equipped perc
plants can exhibit high solvent losses.
It is somewhat meaningless to speak of average mileage for perc
plants, because of the wide range of performance observed.
Table 4-4 summarizes solvent mileage and emission estimates believed to
be somewhat representative of perc plants with different levels of operator
proficiency and equipment. The data for petroleum an'd fluorocarbon plants will
be discussed in the remainder of this section.
.
'4-9
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TABLE 4-4
EMISSION RATES AND SOLVENT CONSUMPTION OF DRY CLEANING PLANTS
~
I
-J
o
Emission Mileageb
Solvent Type Control Technique Ratea Reference
Perchloroethylene Uncontrolled - Poor 486 2,900 16
Uncontrolled - Typi cal 203 6,940 15
Uncontrolled - Good 128 11 ,000 16
Carbon Adsorber - Typical 168 8,369 15
Carbon Adsorber - Good 94 15,000 16
Carbon Adsorber - Best 70 20,000+ 21
Petroleum Uncontrolled - Average 468 1,456 16
Uncontrolled - Good 310 2,200 16,22
Carbon adsorber - Good 173 3,935 6,16
Fl uorocarbon Refri gerati on - Typi ca 1 60 22,800 26
Refri gerati on - Good 37 37,000 5
a Units are pounds of solvent per ton of fabrics cleaned.
b Units are pounds of clothes cleaned per 52-gallon drum of solvent.
-------
4.2.3 Petroleum Plants
Because no emission controls are used on petroleum plants, and all the
solvent remaining in the clothes after extraction i,s lost during drying, the
primary factor governing solvent consumption for any given plant is extraction
efficiency. Other than preventing liquid solvent leaks and ensuring good ex-
traction, there is little an operator can do to bolster his mileage. In view
of this, a narrower range of solvent mileage would be expected for these plants
than was observed for perc plants. Available information seems to support
this:
IFI believes that current average mileage in petroleum plants is
about 1,456 pounds/drum. With good extraction, 1,600-1,700 pounds/
drum is considered attainable with regenerative' filters and 2,200-
2,300 pounds/drum with a cartridge filter.16
. Visits to three plants during the course of this study found mileages
of 1,450-2,200 pound/drum,22 1,299-1,732 pound/drum,23 and 1,039
pound/drum. 24
.
There are no known controlled petroleum plants in the U.S., so estimates
of emissions from a hypothetical controlled plant must be based on several
assumptions:
. Uncontrolled mileage of 1,456 pounds/drum. 16
. Seventy percent of emissions losses.occur at the dryer. 16
. A properly operated carbon adsorber will recover 90 percent of the
dryer losses. 6
Making use of these assumptions, it should be possible to improve the mileage
of the average plant to about 3,935 pounds/drum. The mileages and emission
rates of this controlled plant and some typical uncontrolled plants are shown
in Table 4-4.
4.2.4 Fluorocarbon Plants
Fluorocarbon machines are all dry-to-dry units with built-in controls so
that low solvent consumption is expected of properly operated plants. Because
'fluorocarbon dry cleaning is relatively new, there is little information avail-
able regarding typical solvent consumption. However, the solvent mileage infor-
mation below was obtained:
4-11
-------
.
In tests at the IFI Research Center, average solvent mileage of 39,293
pounds/drum was obtained while cleaning over 8,900 pounds of clothes.
These tests were under laboratory conditions with highly-qualified
personnel so the results should not be considered typical.25
. DuPont, who manufactures IVa1c1ene" fluorocarbon solvent, has a certi-
fication stanrlard for new machines, which corresponds to about 22,800
pounds/drum. 26 .
. In testing their machines in the laboratory, Vic Manufacturing Co.
personnel attained average solvent mileage values of about 37,000
pounds/drum. This shows very good agreement with the IFI work,.
but again it should not be considered typica1.5
. Tests performed by DuPont and EPA personnel on coin-operated fluoro-
carbon units in a plant yielded the following results: 15,519 pounds
per drum for a 12-1b. machine; and 19,219 pounds per drum for a 25-1b.
machine.27 Although these values are lower than the preceding ones,
they are likely to be more representative of performance in the field.
The solvent emissions of new fluorocarbon dry cleaning machines are very
low, based on the preceding examples. Therefore, g09d housekeeping practice
and the maintenance of solvent consumption records appears to be a useful con-
trol mea~u~ for these machines. Solvent mileage and.emissions data for fluoro-
carbon machines are surrmarized in Table 4..:4.
4.3 ALTERNATIVE CONTROL SYSTEMS
Available emission controls and their performance have been discussed in the
preceding sections. The purpose of the present section .is to utilize this
information in compiling a set of alternative emission controls for new dry
cleaning plants. The alternatives will provide the basis for the cost analyses
developed in Chapter 7.0. Table 4-5 summarizes the suggested alternatives for
several categories of dry cleaning plants, including commercial (retail), coin-
operated, and industrial. The type of machine assigned to each plant category.
was chosen on the basis of the machine types found most frequently in each cate-
gory.
4-12
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TABLE 4-5
ALTERNATIVE MILEAGE AND EMISSION CONTROLS FOR DRY CLEANING PLANTS
.;..
I
-..
W
Pl ant Machine Control Standard Additional Additional
Category Type Measure Emissionsa Mi 1 eageb . Investment Cost? Operating Cost?
Coin-Operated Perchloroethylene Housekeeping 176 8,000 No Negligible
(Dry-to-dry) Abo ve+ Ads 0 rb e r 117 12,000 Yes Yes
Fl uorocarbon Housekeeping 68 20,000 No Negligible
(Dry-to-dry)
Commerci a 1 Perchloroethylene Housekeeping 141 10,000 No Negligible
(Dry-to-dry) Above+Adsorber 94 15,000 Yes Yes
Perchloroethylene Housekeeping 141 10,000 No Negligible
(Transfer) Above+Aqsorber 94 15,000 Yes Yes
Industrial Perchloroethylene Housekeeping 141 10,000 No Negligible
(Modular machine) Above+Adsorber 70 20,000+ Yes Yes
Petroleum Housek~eping 310 2,200 No Negligible
(Transfer) Above+Adsorber 173 3,935 Yes Yes
a Pounds of solvent per ton of fabrics cleaned.
b Pounds of clothes cleaned per 52-gallon drum of solvent.
-------
4.4 REFERENCES FOR CHAPTER 4.0
1.
Cannon~ T.E. IIAir Pollution Control Through Carbon Adsorption'"
Plating~ pp. 337-9, (April 1974).
Watt, Andrew, IV and William E. Fisher, IIResults of Membership
Survey of Drycleaning Operations~1I International Fabricare Institute
(IFI)~ Special Reporter #3-1, January-February 1975.
2.
3.
IIChlorinated Solvents: Toxicity~ Handling Precautions, First-Aidll
Dow Chemical U.S.A., Form No. lOO-5449-74R.
4.
Reeves,H.E.,-IICauses of Excessive Loss of Perchloroethylene,1I IF!
Practical Operating Tips Bulletin pp-91, January 1969.
Discussions with Vic Manufacturing personnel, 13 December 1974.
5.
6.
Barber, J.W., Research Director, Vic Manufacturing Co., Minneapolis,
Minn., letter to C. F. Kleeberg, U.S. Environmental Protection Agency,
6 February 1976.
7.
Landon,.Steven, President, Washex Machinery Corp., l-Jichita Falls, Texas,
letter to C;F. Kleeberg, U.S. Environmental Protection Agency~ 27
January 1976.
Discussion with Mr. William Fisher, IFI, concerning some calculations
he had made, 30 January 1975. .
8.
9.
Barber, J.W., Research Director,Vic Manufacturing Co., Minneapolis,
Minn., letter to C.F. Kleeberg~ U.S. Environmental Protection Agency,
5 February 1976.
10.
Information provided by Mr. Steven Landon~ President, Washex Machinery
Corp.~ to Mr. C.F. Kleeberg, U.S. Environmental Protection Agency, 4
December 1975.
11.
Telephone conversation with Mr. Steven Landon, President, Washex
Machinery Corp., 29 March 1976.
Kleeberg, Charles F., IlMeeting Concerning Drycleaning Equipment:t"
memorandum of meeting with Vic Manufacturing personnel in Minneapolis,
Minn., 15 October 1975.
12.
13.
Victor, Irving, Executive Vice President, Vic Manufacturing Co., IICon-
trol of Gases and Vapor Emissions from Industrial and Drycleaning
Processes Comparing Efficiency and Operating Cost of Incineration,
Absorpti on, Condensation and Adsorpti on Methods, II papers presented
at the U.S. Department of Commerce Air and Water Pollution Control
Exhibit, Tokyo, Japan, December 6-11,1971.
"Mileage Boosters," carbon adsorber data sheet, Form No. 325E 669, Vic
Manufacturing Co., Minneapolis, Minn, .
14.
4-14
-------
15. Data provided by Mr. Robert J. Lundy, Dow Chemical U.S.A., Midland,
Michigan, 8 April 1975.
16. Fisher, William L, "The ABC's of Solvent Mileage," Part One, Inter-
national Fabricare Institute Special Reporter, No. 3-4, July-August
1975.
17. McCoy, Billy C., "State Cleaners Visit", trip report, TRW Transportation
. and Environmental Operations, 8 July 1975.
18.
Barnard, A.T., "Visit to Paul's Custom Cleaners," trip report, TRW
Transportation and Environmental Operations, 29 August 1975.
McCoy, Billy C., "Visit to Sterling Laundry," trip report, TRW
Transportation and Environmental Operations, 28 July 1975.
1'9.
20.
Kleeberg, Charles F., "Dry Cleaning Plant Test-Process Description,"
test report, U.S. Environmental Protection Agency, Emission Standards
and Engineering Division, memo to J.F. Durham, 17 March 1976.
Preliminary data from test of industrial perc plant in San Antonio,
Texas, provided by C.F. Kleeberg, Emission Standards and Engineering
Division, u.s. Environmental Protection Agency, via telephone, 9
March 1976.
21.
22.
McCoy, Billy C., "Visit to Sterling Laundry," trip report, TRW
Transportation and Environmental Operations, 28 July 1975.
Haslbeck, J.L., "Plant Visit-Dry Cleaning and Laundry Facility-Rentex
Co., York, Pa." trip report, TRW Transporation and Environmental Oper-
ations, 14 November 1975.
23.
24.
Kleeberg, Charles F., "Plant Visit to. a Petroleum Dry Cleaning Facility,"
trip report, U.S. Environmental Protection Agency, Emission Standards
and Engineering Division, memo to J.F. Durham, 12 December 1975.
Martin, Alber.t R., "Cleaning with a Fluorocarbon," paper presented at
National Institute of Drycleaners/American Institute of Launderers
(now the International Fabricare Institute) Convention & Exhibit,
Las Vegas, Nevada, 24-28 March 1971. .
25.
26.' Anonymous, DuPont certification standard for "Valclene" dry cleaning
machines, from DuPont Co. Bulletin V-8, March 1974.
27.
Kleeberg, C.F., "Testing of Fluorocarbon Dry Cleaning," test report,
Emission Standards and.Engineering Division, U.S. Environmental Pro-
tection Agency, memo to J.F. Durham, 20 February 1976.
4-15
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5.0 DRY CLEANING PLANT MODIFICATIONS
Section 111 of the Clean Air Act requires that the Environmental Protection
Agency develop and promulgate standards of performance for both new and modified
stationary sources of air pollutants. In the case of the dry cleaning industry,
the term "new plant" is sufficiently clear to require no explanation, but "plant
modification" requires precise definition, because of the numerous equipment
changes possible in an existing plant. For the dry cleaning industry, a modifi-
cation is considered to involve one of the following .kinds of alterations:
. Alterations which cause an increase in the emissions of a solvent,
which was in use at the plant prior to the alteration.
. Alterations which change the chemical or physical characteristics of
the solvent emissions so that they have a greater potential to cause
air pollution problems.
The precise meanings of these
cess changes which constitute
thi s chapter.
kinds of modifications .and the equipment and pro-
the modifications are given in the remainder of
5.1
GENERAL
5.1.1
Emission-Increasing Modifications
Any alteration to an existing plant which increases the emissions of a
solvent which had been in use at the plant prior to the alteration is a modifi-
cation in the context of Section 111. This includes such changes as: (1) in-
creasing the capacity of a plant using a particular solvent by replacement of
existing equipment - either the entire dry cleaning machine, the washer/extrac-
tor, or the drying unit - with larger capacity equipment, which uses the same
solvent; .or (2) increasing the capacity of a plant using a particular solvent
by addition of equipment, which uses the same solvent.* Specific examples of
these types of modifications for perchloroethylene, petroleum and fluorocarbon
dry cleaning plants are discussed in Section 5.2. The remainder of this section
concerns modifications, in which a change in the type of solvent used by a plant
is made.
* In this discussion, capacity does not necessarily refer to the per-load
capacity of the equipment, but it is based on the average hourly sustained
production rate of the equipment involved.
5-1
-------
5.1.2 Modifications Involving Solvent Substitution*
The major reason for controlling emissions of organic compounds into
the atmosphere is to reduce the effects of photochemical oxidants. There are
marked differences in the rates at which organic compounds undergo the atmos-
pheric reactions leading to smog formation. As a result of these differences in
reactivity, two forms of control have been exerted for organic solvents used
in dry cleaning:
. Emission limitation, where the absolute quantity of solvent lost
to the atmosphere is controlled.
. Solvent substitution, wherein a less photochemically reactive sol-
vent is substituted for a more reactive one.
For dry cleaning solvents, the general order of reactivities, from least reactive
to most reactive is: fluorocarbon < perchloroethylene < petroleum. According-
ly, some control agencies have accepted emission controls based on substitution
of either of the synthetic solvents for petroleum solvent or of replacement of
one petroleum solvent by another less-reactive solvent.**
Recent evi dencehas gi ven reason to doubt the va Ti dity of the reacti vi ty
approach to smog control.2 These findings indicate that practically all organic
compounds can undergo photolytic reactions, which potentially lead to photo-
chemical smog.*** Consequently, the current policy of the Environmental Protec-
. .
tion Agency is as follows: II... the reactivity concept is useful as an interim
measure for controlling the formation of photochemical oxidants. The ultimate
goal of the SIP [State Implementation Plan], however, must be to reduce emissions
of all non-methane organic compounds in a region to the degree necessary to meet
the NAAQS for oxidantll.3
Because controls for new sources should take a long range viewpoint, this
policy is adhered to in the following ways:
. Sol vent type wi 11 not be a factor in determining whi ch alterati ons are
to be classified as Section 111 modifications.
* Except where otherwise noted, the following material is based on reference No.1.
** This approach is based on the Los Angeles IIRule 6611 approach, so the less re-
. active petroleum solvents are frequently called Rule 66 solvents. .
*** The fluorocarbon solvents are among the very few organic compounds which do
not participate in photochemical smog formation.
5-2
-------
I Any alteration which decreases the emission rate of a plant will not
be termed a modification.
The latter exception is made because emission rates (pounds of solvent per ton
of cleaning) are much less for the synthetic solvents than for petroleum sol-
vents. Hence, substitution of synthetic dry cleaning machinery for petroleum
machinery results in greatly reduced air pollution potential, unless an enormous
capacity increase is involved. Because of this, the dry cleaner who wishes to
up-grade his operation, in this way, should not be penalized.
5.2 SPECIFIC TYPES OF MODIFICATIONS
The general policy presented in Section 5.1 was applied to each of the
three basic types of dry cleaning processes. The results of this application
follow for each process.
5.2.1
Perchloroethylene Plants
The types of plant alterations considered to be modifications according
to Section 111 of'the Clean Air Act are as follows:
I Any capacity expansion of an existing facility including: (1) addition
of a complete new dry cleaning machine; (2) installation of an addition-
al dryer for use with a dry-to-dry machine, to increase production; or
(3) replacement of an existing perc machine with a perc machine of
greater capacity.
I Any installation of a petroleum machine at a plant formerly using
only perchloroethylene, whether for expansion or replacement purposes,
unless the emissions are not increased.
-I Addition of a fluorocarbon machine to an existing perc plant. (Replace-
ment of a perc machine with a fluorocarbon machine of equival€nt capa-
city, is specifically ~xcluded from this category.)
5.2.2 Petroleum Plants
The following alterations are considered modifications according to Section
111 of the Clean Air Act:
I Any capacity expansion of an existing facility including: -(1) addition
of a complete new dry cleaning machine; (2) installation of additional
drying capacity to increase production; or (3) replacement of an exist-
ing petroleum machine with another petroleum machine of greater capacity.
5-3
-------
. Addition of any synthetic solvent machine to an existing petroleum
plant. (Substitution of a synthetic solvent machine for a petro-
leum machine of equivalent capacity is specifically excluded from
this definition.)
5.2.3 Fluorocarbon Plants
The plant alterations below are defined-to be plant modifications accor-
ding to Section 111 of the Clean Air Act:
. Any capacity expansjon of an existing plant whether by addition of
a new fluorocarbon machine or by replacement of an.existing fluoro-
carbon machine with one of greater capacity.
. Any installation of petroleum or perchloroethylene dry cleaning
machinery at an existing fluorocarbon plant, whether for expansion
or replacement purposes. .
5.2.4 Combination Plants
Some plants use more than one type of solvent. If a proposed aiteration
is a modification based on any solvent used at the plant, it shall be considered
a Section 111 modification.
, ,
,',
5.2.5 New Coin~Operated Plants
Any instaTTation of coin-operated dry cleaning machinery at a facility
formerly having no~ dry cleaning macbinery- for example, a laundromat - shall
be considered a new plant. ..
5.3 EFFECTS OF MODIFICATIONS ON EMISSIONS
Changes to dry cleaning plants which are to be considered modifications should
be justified by their propensity to increase solvent emissions. . Some changes
such as simple capacity increases with no change in solvent type can be assumed to
increase the emissions in direct proportion to the capacity increase.* Hence,
such changes should always be considered modifications. Installation of additional
dry cleaning machinery which uses a different solvent than that used by the exist-
ing machinery will obviously increase the emission rate. Here, the amount of
increase can be estimated by use of the emission rates in Table 4-4 and the
* It is realized that this is not strictly true, since new equipment will normally
have lower emission rates than old equipment. However, some simplification is
necessary,~and this adds conservatism to the analysis.
5-4
-------
expected usage of the new equipment.
The effect on emissions of the replacement of a dry cleaning machine of
one type with an equal capacity of another type can be assumed to be proportion-
al to their uncontrolled emission rates for simplicity. Any time the ratio of
the emission rate of the new machine to that of the old machine is greater than
one, the change should be termed a modification. Table 5-1 shows many of the
possibilities. Other replacements can be analyzed by the use of Table 4-4.
Type of Replacementa Emission
Ratiob
Fluorocarbon Machine by Percl Machine 3.4
Fluorocarbon Machine by Petroleum Machine 7.8
Perc Machine by Fluorocarbon Machine 0.30
Perc Machine by Petroleum Machine 2.3
Petroleum Machine by Fluorocarbon Machine 0.13
Petroleum Machine by Perc Machine 0.43
TABLE 5-1
EFFECTS OF DRY CLEANING MACHINE REPLACEMENT
ON SOLVENT EMISSION RATES
a The machines are assumed to be of equivalent capacity
(pounds per hour not pounds per load).
b These ratios are based on the typical or average emission
rates for uncontrolled machines in Table 4-4.
On the basis of discussions with plant operators, a fairly common type of
capacity increase is the addition of a separate dryer to a dry-to-dry perchloro-
ethylene machine. In essence, this converts the machine to a transfer type
when the demand is sufficiently great. This can almost double the plant capacity
and the resulting emissions. Hence, such alterations should always be classed
as modifications.
5.4 COMMON ALTERATIONS TO DRY CLEANING PLANTS
According to a major manufacturer of dry cleaning machines, new units are
'used in the following applications:4
. Perc or Petroleum Machines
{70% - replacements
10% - new plants
20% - expansions
5-5
-------
. Fluorocarbon Machines
{40% - new plants
60% - expansions
As noted, replacement is by far the most common alteration to plants purchasing
perc or petroleum machines. The different usage of fluorocarbon machines is
probably caused by the following factors:
. The machines represent relatively new technology and there are not
many machines old enough for replacement. .
. Fluorocarbon machines are useful for leather cleaning and other
specialty uses, for which they would be added to an existing plant.
No data were available to indicate the frequency with which external drying
capacity is added to dry-to-dry pert plants. However, it was mentioned several
times during the study, and it must be somewhat common.
5.5 REFERENCES FOR CHAPTER 5.0
1.
Feldstein, Milton, "A critical review of regulations-for.the control
of hydrocarbon emissions from stationary sources, II J. Air Poll. Control
. Assoc. 24, No.5, r'.1ay 1974.
2.
"Control of P~otochemical .Oxidants-Technical Basis and Implications
of Recent Findings," Document No. EPA-450j2-75-005, U.S. Environmental
Protection Agency, July 1975.
3.
"policy Statement on Use of the Concept of Photochemical Reactivity
of Organic Compounds. in State.Implementation Plans for Oxidant Control,"
U.S. EnvironmentalProtection:Agency, 29 January 1976.
Information provided by Vic Manufacturing Company to C.F. Kleeberg,
U.S. Environmental Protection Agency, 12 January 1976.
4.
5-6
-------
6.0 ENVIRONMENTAL IMPACT
In order to prevent the promulgation of performance standards demonstra-
ting a myopic view of other environmental effects and energy considerations,
information pertaining to these important elements should be collected through-
out the standard development program. A performance standard for air pollution
which causes extreme degradation of water quality, for example, should not be
promulgated. Likewise,. standards which encourage excessive consumption of
scarce fuels should be avoided, where possible. However, where the decision is
a choice between endangering human health and using more fuel, the latter route
must be chosen.
Totally avoiding conflicts between environmental goals is not possible, in
most cases. However, the severity of any conflicts should be assessed before
emission standards are promulgated so that there will be confidence that the
environmental and/or energy trade-offs required are acceptable ones. The pur-
pose of this Chapter is to discuss the environmental and energy impacts of al-
ternative solvent emission controls for the dry cleaning industry. The alter-
native emission controls are founded on two. control options: . (1) Option 1,
which requires good operating and maintenance procedures, including solvent
consumption and production records, for all new or modified dry cleaning plants;
and (2) Option 2, which combines Option 1 with a requirement for a vapor adsor-
ber on. all new or modified perchloroethylene and petroleum dry cleaning plants.
6. 1
AIR POLLUTION IMPACT
6.1.1
Direct Impact
The effects of the control alternatives on solvent emissions are present-
ed in Table 6-1 in comparison with both uncontrolled plants and with the strict-
est known local regulation, the Maricopa County, Arizona regulation.l The per-
centage emission reductions expected from each of the control options are shown
in Table 6-2. Both of the control options show significant emission reductions
in all cases, except the fluorocarbon case. This is a consequence of the very
low emission rates found for these machines, even with no additional controls.
(See Sections 3.2 and 4.2 for more details concerning fluorocarbon machines.)
6-1
-------
TABLE 6-1
EFFECT OF ALTERNATIVE CONTROLS FOR DRY CLEANING
PLANTS ON SOLVENT EMISSION RATESa
Bas i s for Coin-OD C0lJID1ercia1 Industrial
Control Perc Fluorocarbon I Perc Petroleum
Perch10roethy1ene
None 321c 72d 203c 203c 468e
Maricopa 228c 72 168c 168c 468e
Option 1f 176 68 141 141 310
Option 2f 117 68 94 70 173
:
a Units are pounds of solvent per ton of clothes.
b The bases for the controls are: None - uncontrolled; Maricopa - the
Maricopa cou~ty) Ariz. regulation which requires an adsorber on all
perc plants; Option 1 - housekeeping; and Option 2 - housekeeping
plus a carbon adsorber.
c Obtained from Dow survey.2
d Based on EPA plant test.3 (Fluorocarbon plants are not affected by the Maricopa
e Base-d on IFI data.4 ~. . regulations.)
f See Chapter 4.0 for the derivation of these emission levels.
TABLE 6-2
PERCENTAGE EMISSION REDUCTIONS EXPECTED
- FROM SOLVENT EMISSION CONTROLS FOR THE
DRY CLEANING INDUSTRya
Basis for Coin-Op Commercial Industrial
Con tro 1 Perc Fluorocarbon Perchloroethylene Perc Petroleum
Maricopa 29.0 0 17.0 17.0 0
Opti on.l 45.2 5.6 30.5 30.5 33.8
Option 2 63.6 5.6 53.7 65.5 63.0
a The data in this table are based on Table 6-1.
6-2
-------
As discussed in Section 5.1, organic solvent emissions are controlled
because of their participation in the photochemical reactions leading to
oxidant formation. These processes are highly complex, and, at this time, it
is not possible to determine the impact of a single source on ambient oxidant
levels by means of atmospheric modeling. Because of this, the expected air
quality impact of the alternative controls cannot be estimated.
6.1.2 Indirect Impact
The only indirect emissions from either of the alternative controls
results from the steam consumed in regenerating the solvent from the carbon
adsorber of Option 2. Option 1 generates no additional emissions. The emis-
sions produced by the additional steam generation may be computed for a
commercial perc plant by means of the following assumptions:
. Boiler horsepower required - 3~ or about 117,200 Btujhr.*
.
Daily steam-out time - 1~hr.6
I' Fuel - 1% sulfur distillate oil.
I Operating Cycle - 6 days per week.
To simulate worst case conditions, a 2-hr. steam-out is used:
Total Oil Used =. 117,200Btu. x 2-hr. x .1 gal. x 312days = 522 gal. per yr.
hr. aa:y 140,000 Btu . yr.
Using AP-42,7 the pollutant annual emissions resulting from this operation are:
sulfur oxi des.,.75 pounds; parti cul ates-8 pounds; carbon monoxi de-2 pounds; hydro-
carbons-l~ pounds; and nitrogen oxides-42 pounds. These emissions are considered
totally negligible from an ambient air quality standpoint, because they are
spread over an entire year. Even in an industrialperc operation, where ten
times as many clothes might be cleaned in a year, the emissions of each pollu-
tant should be less than ~ ton per year. This is still considered negligible.
Detailed operating data for the petroleum plant.adsorber are not avail-
able, because the unit is not yet in production. However, a rough estima~e of
fuel and emissions can be made by means of the following assumptions:
. Utility costs are $OA15 per gallon of recovered solvent and all
of this is for fuel.o
. Oil 'costs $0.40 per gallon.
* This horsepower is adequate for a plant doing more than 3000 pounds of
cleanin9 per month. See Table 4-3 and reference 5.
r. -?
-------
juncontrolled - 468 lb./ton
. Solvent usage - controlled - 173 lb./ton
recovery - 295 lb./ton
. Annual plant production - 1,500,000 lb./yr.
Then annual fuel oil usage is:
Total Fuel Oil = $0.15/gal. x 2951b. x 1 ,500,0001b.x . 1 ton x ~
$0.40/gal. ton yr. 2,0001b. O:-5~
= 12,650 gal. per year
The emissions resulting from usage of this quantity of 1% sulfur distillate
oil are: particulates-O.l ton; sulfur oxides-O.g ton; carbon monoxide-0.03 ton;
hydrocarbons-O.02 ton; and nitrogen oxides-0.5 ton. These annual emissions are
considered negligible in terms of the solvent emission reduction achieved.
6.2 WATER POLLUTION IMPACT
Only Option 2 has any potential for water pollution impacts, whatjoever.
During steam-out of the adsorber, the steam and.solvent vapors are passed over
a water-cooled coil, condensed, and then passed through a separator where the
. so'l vent and water are separated ." The separator is a gravi ty-type with no
moving parts, so that it should never create a problem, if properly maintained.
6.3 SOLID WASTE DISPOSAL IMPACT
No solid waste is produced byany.of the control options.
6.4 ENERGY IMPACT
The energy consumption ,of the adsorbers used for Option 2in commercial
perc plants and industrial petroleum plants was calculated in Section 6.1, in
order to estimate the indirect air quality impacts of the controls. The approx-
imate amount of fuel consumed by the other perc plants can be estimated by
assuming that the fuel consumption is proportional to the solvent recovered.
The solvent recovered maybe estimated by multiplying the difference in emis-
sion rates for uncontrolled and controlled plants by the annual production
rates from Table 7-8. The energy consumed is compared with the solvent re-
covered in Table 6-3.* The controls for fluorocarbon plants require no addi-
tional energy consumption.
.. . . . . ~ . - '" ~ "
* Oil is used as the basic energy sour.ce because of the difficulty of
obtaining new natural gas hookups.
6-4
-------
TABLE 6-3
SOLVENT RECOVERY VERSUS ENERGY CONSUMPTION
FOR THE OPTION 2 CARBON ADSORBERS
FOR DRY CLEANING PLANTS
Solvent Fuel Oil
Plant Type Recovered (gal.) Consumed (gal.)
Perchloroethylene
Coin-Op 602 782
Corrmercia-l 402 522
Industri a 1 4,908 6,373
Petroleum
Industrial 33,727 12,650
These estimates indicate no adverse ene~gy impacts. In the
plant, where the most fuel is required, the solvent recovered is
times the volume of the oil burned.
industrial
almost three
6.5 OTHER ENVIRONMENTAL IMPACTS
Other than the impacts already discussed, no environmental impacts should
result from the alternative controls including noise,-radiation or heat. Al-
though some additional heat release will occur during the daily adsorber steam-
out, this is negligible in comparison to the total heat release by a dry
cleaning plant for clothes pressing, solvent distillation, steam cabinets and
other operations.
6-5
-------
6.6 REFERENCES FOR CHAPTER 6.0
'. . 8.
1.
Maricopa County Bureau of Air Pollution Control, Rules and Regula-
tions, Maricopa County Health Dept., Phoenix, Arizona, 1 October 1975.
Data provided by Mr. RobertJ. Lundy, Dow Chemical, U.S.A., Midland,
Michigan, 8 April 1975.
2.
3.
Kleeberg,C.F.,OIlTesting bfFluorocarbon Dry Cleaning, II test report,
U.S. Environmental Protection Agency, Emission Standards and Engineer-
ing Division, memo to J.F. Durham, 20 February 1976.
Fisher, William, liThe ABC's of Solvent Mileage," Part One, Interna-
tional Fabricare Institute, Special Reporter No. 3-4, July-August
1975. 0
4.
5.
II Mil eage Boos ters ," carbon adsorber data sheet, Form No. 325E 669,
Vic Manufacturing Co., Minneapolis, Minn.
"Instruction Manual," Vic Air Pollution Control Systems, VMC 5046,
Vic Manufacturing Co., Minneapolis, Minn. ,February 1973.
6.
7.
"Compilation of Emission Factors," 2nd ed. Publication No. AP-42,
U.S. Environmental Protection Agency, amended December 1975.
Mr. J..W. Barber, Research Director, Vic Manufacturing Co., Minnea-
polis, Minn., letter to Charles F. Kleeberg, dated 6 February 1976.
6-6
-------
7.0 ECONOMIC IMPACT
Chapter 4.0 of this document discusses available control technology for
solvent emissions from the various sectors of the commercial dry cleaning in-
dustry strictly in terms of the expected emission reductions. In addition to
this performance-based analysis, Section 111 of the Clean Air Act requires
that the cost of achieving the reduction(s) be taken into account in defining
demonstrated control technology for new source performance standards. This
chapter is intended to satisfy this requirement for the commercial dry clean-
ing industry. Its contents are arranged as follows:
. 7.1 INDUSTRY ECONOMIC PROFILE - This section describes the qeneral
economic conditions in the industry in terms of growth rates, cash
receipts, employment and other relevant criteria.
. 7.2 MODEL PLANT SELECTIONS - The estimation of control costs for an
industry requires that well-defined plants be available. This section
defines the models used in the present study for cost analysis.
. 7.3 ECONOMIC IMPACT ANALYSIS FOR COMMERCIAL PLANTS - This section in-
cludes the fOllowing material: (1) control cost analysis; (2) other
cost considerations; (3) economic analysis; and (4) socio-economic
and inflation impact analysis.
. 7.4 ECONOMIC IMPACT ANALYSIS FOR INDUSTRIAL PLANTS - This section is
similar to 7.3, but is for the industrial dry cleaning sector.
. 7.5 ECONOMIC IMPACT ANALYSIS FOR COIN-OPERATED PLANTS - This section
is similar to 7.3, but is for the coin-operated dry cleaning sector.
. 7.6 REFERENCES FOR CHAPTER 7.0
7-1
-------
7.1.
INDUSTRY ECONOMIC PROFILE
7.1.1
The Current Status of the Industry
As mentioned briefly in chapter three, the total number of establish-
ments in the drycleaning industry numbered 46,992 in 1972, a total which
represents a 3 percent decrease since 1967. This overall negative growth
is mainly attributable to a decrease 'in the number of establishments in the,
commercial sector, which comprises the major portion of the industry, since
the coin-operated and industrial sectors have, in fact, grown during this
period.
Table 7-1 contains a summary of salient economic statistics for the
drycleaning industry broken down by sector in 1967 and 1972. The data con-
tained in the table and utilized throughout the rest of this section were
available from the U.S. Census for Standard Industrial Classifications
7215, 7216 and 7218.1 These data, which were found to be the best available,
are assumed to be representative of the. changes taking place in the dry-
cleaning industry.
As listed in the table, the makeup of the industry is 37 percent coin-
operated (17,550 establishments), 61 percent commercial (28,422) and 2
percent industrial (1,020). Between 1967 and 1972 the number of establish-
ments increased in the coin-operated sector approximately 5 percent, in-
creased in the industrial sector approximately 11 percent and decreased in
the commercial sector approximately 8 percent. The decline of the commer-
cial sector was mainly a function of the following factors:
. The use of new equipment which has increased productivity and
consequently reduced the need for new plants to supply demand;
. The increasing use of washable synthetic fabrics which has re-
duced the demand for drycleaning services;
. The increasing use of coin~operated facilities by consumers; and.
. General economic conditions during the period, which tended to
affect service industries adversely.
Also indicated i'n Table 7-1, is the fact that total employment in the
industry has declined approximately 12 percent between 1967 and 1972.
7-2
-------
"-
TABLE 7-1
UNITED STATES DRY CLEANING INDUSTRY
SUMMARY OF SALIENT ECONOMIC STATISTICS
., 1967 - 1972
Number of Number of Total Receiptsa
Industry Estab1ishmentsa Paid EmDloveesa ($1000)
Cateaorv 1961 1912 1967 1972 19137 1972
~oin-Ope'rated
Dry cleaningb 15,981 '17 ,550 32,207 46 , 11 0 557,364 673,361
~olTlTlercial
Dry c1eaningC, 30,625 28,422 246,348 186,701 1,938,024 1,759,486'
Industrial
lOry cleaningd 918 1,020 45,183 48,859 561,459 782,228
ndustry
Total 47,524 46,992 323,738 281,670 3,056,847 3,215,075
aEstab1ishments with payroll
bBased on SIC 7215 (Coin-Operated Laundries and Dry Cleaning)
cBased on SIC 7216 (Dry,c1eaning Pl ants, except rUQ c1eani no). Amona the industry' s
three categories, the most 'representative data for the number of establishments
are provided for commercial dry c1eaniDg plants.' These data focus only on dry
cleaning facilities while the remaining two categories include 1aunder"ing
facilities.
dBased on SIC 7218 (Industrial Dry cleaners and Launderers)
Sources:
1967 data -- U.S. Department of Commerce, Bureau of Census, 1967 Census
, of Business, Selected Services, Laundries, Cleaning Plants,
and Related Services.
1972 data -- U.S. Department of Commerce, Bureau of Census, 1972 Census
of Business, Selected Services Industries, Area Statistics,
by State.
7-3
-------
Examining the sector breakdown aga~n indicates a decline in employment in the
commercial sector of approximately 24 percent, and an increase in the coin-
operated and industrial sectors of approximately 43 and 8 percent, respectively.
In 1972, total employment in the dry cleaning industry was 281,670. Approxi-
mately 16 percent (46,110) of the toal workers were employed in the coin-operated
sector, 66 percent (186,701) in the commercial sector and 17 percent (48,859)
in the industrial sector.
Total receipts for the dry cleaning industry show an absolute increase
of about 5 percent over the period between 1967 and 1972. The sector
breakdown indicates that receipts declined 9 percent in the commercial
sector, increased 21 percent in the coin~operated sector and increased 39
percent in the industrial sector. When adjusted for the inflation which
occurred during that period, however, total receipts for the industry show
a relative decrease of about 16 percent when expressed in terms of constant
1967 dollars.* As would be expected, when adjusted for inflation, the de-
cline in receipts in the commercial sector is magnified even further. Com-
mercial receipts in terms of constant 1967 dollars decreased about 27 per-
cent. toin-ope~ated receipts dec;reased approximately 4 percent, an interest-
ing fact, since the coin-operated category grew in establishments and employ-
ment during the same period. This may indicate, in general, that although
the number of plants and employment may be growing due to population growth,
urbanization, and other factors, levels of service may be declining some-
what. It should be noted that it is possible some of the di!ference may
be due to the manner in which the statistics were rec6rded.
The receipts per dry cleaning plant are very important for properly
assessing the economic status of the industry. The data from Table 7-1
were used to calculate the income per plant for both 1967 and 1972, the
'latter being expressed in 1967 dollars. These data an~ the relative change
in income per plant are given in Table 7-2.
*In order to compare receipts in terms of constant 1967 dollars, 1972 receipts
were divided by a price index of 1.205. (U.S. Department of Commerce, Bureau
of Economic Analysis and U.S. Department of Agriculture, Economic Research
Service, 1972 OBERS Projections~Economic Activity in the U.S., Vol. I,
prepared for the U.S. Water Resources Council, April 1974)
7-4
-------
TABLE 7-2
TOTAL RECEIPTS PER PLANT (1967 DOLLARS)l
Industrial Cate or 1967 1972
Coin-operated $34,880 $31,840
Commercial $63,280 $51,370
Industrial 611 610 636 420
-8.7
-18.8
4.1
This characterization of the industry provides a bleaker picture of its
economic health than do the raw data of Table 7-1. On a per-plant basis,
the industrial sector showed modest improvement in receipts, the coin-
operated sector showed a detline in receipts, and the commercial category
suffered a sharp decline in receipts. The negative growth rate of commer-
cialdry cleaning together with this poor income performance are indicative
of an economically unsound industry.
7.1.2 Projection of Growth in the Industry
Simple extrapolations of growth rates, which occurred during the 1967-
1972 period, were performed to project the number of establishments in the
dry cleaning industry by sector in 1975 and 1980. Projections were made on
a regional basis and are contained in Tables 7-4, 7-5, and 7-6. Growth
trends for each sector and the industry on a national level are illustrated
graphically in Figure 7-1 and are summarized below in Table 7-3.
TABLE 7-3
PROJECTED NUMBER OF ESTABLISHMENTS IN THE DRY CLEANING INDUSTRY 1975, 1980
1967 T972 1975 1980
Coin-operated 15,981 17,550 18,564 20,38)
Commercial 30,625 28,422 27 ,179 25,22E
Industrial 918 1,020 1,087 1,207
TOTAL 47.524 46.992 46.830 46.82C
These data indicate that, based on continuation of current trends,. the indus-
try as a whq1e will decline slightly. The total number of establishments
in the industry is projected to be 46,820 in 1980, which represents a less
than one percent decrease from 1972. The number of establishments in the
coin-operated sector is projected to increase to 20,387 in 1980, an increase
of 16 percent from 1972; the commercial sector is projected to decrease to
25,226 establishments in 1980, a decline of 11 percent; and the industrial
sector is projected to increase to 1,207 establishments in 1980, an increase
of 18 percent.
7-5
-------
FIGURE 7-1
'PROJECTED GROWTH IN THE U.S.
DRY CLEANING INDUSTRY BY SECTOR
50,000
. .
. . . . . INDUSTRY TOTAL
~--------~~--------~
45,000
40,000
35,000
30,000
lit
..
C
'"
0: 25,000
It-
a
L.
cv.
~
::J
:z:
20,000
'----.--. "
. -~,..--- COMI~ERCIAL SECTOR
--
---~
-"
COIN-OPERATED SECTOR
..-r.
.-.
. ...
----~?-
----
10,00
. '. ". INDUSTRIAL SipOR
--------~~--------~
1 67
19 2
1975*
1980*
Historical data
Projected
.---
*Based 0" extrapolation of growth trends between 1967 and 1972.
Sources:
1967 data -- U.S. Department of Commerce, Bureau of Census, 1967 Census
of Business, Selected Services, laundries, Cleaning Plants,
and Related Services. .
1972 data -- U.S. Department of Commerce, BUreau of Census, 1972 Census
of Business, Selected Services Industries, Area St~tistics,
by State.
7_~
-------
1967-1972
Regionb ~rowth Rate 1975c 1980c
(%/Yr) 1967 1972
United States +1.89 15,981 17,550 18,564 20,387
New England +1.75 717 782 824 898
Middle Atlantic -0.04 2,559. 2,554 2,551 .2,546 .
.'.- .
East North Central. +2.00 . -. 3,606. . - .3,981 .-. .4,224 4,664
West North Central . +0.53 1 ,449 . .. 1 ,488 1,612 1 ,553 .
South Atlantic +4 . 1 6 2,115 2,998 3,388 4 , 1 54
East South Central +5.29 .1 ,091 1,412 1,648 2,1~3
West South Central . +0.75 2,052 2 , 1 30 2,178 2,261
Mountain +4.07 653 797 898 1,096
Pacific -0.01 1,409 1 ,408 1,407 1,406
TABLE 7~ 4 .
COIN-OPERATED DRY CLEAN.ING PLANTS a
. REGIONAL PROJECTIONS
a Based on SIC 7215 (Coin-Operated Laundries.and Dry Cleaning).
. . .
b U.S. Census regions.
c Projected from 1972 data using the 1967-1972 annual growth rate.
7-7
-------
, TABLE 7- 5
COMMERCIAL DRY CLEANING PLANTSd
REGIONAL PROJECTIONS
1967-1972
Regionb :lrowth Rate 1975c 1980c
(%/Yr) 1967 1972
United States -1.48 30,625 28,422 27,179 25,226
New England, -1. 21 1,621 1,525 1,470 1,383
Middle Atlantic - 1. 89 ' 6 , 1 88 5,625 5,312 4,829
East North Central -1.07 5,195 4,924 4,768 4,518
West North Central ~2.44 2,'347 ' .. 2,074 . 1,926 1,702
South Atlantic -0.27 4,779 4,715 4,677 4,614
. East South Central -1.78 2,163 1 ,977 1,873 1 ,712
West South Central -3.81 3,908 .3,218 2,864 2,358
Mountain -0.77 1 ,140 1,097 1,071 1,031
Pacific -0.11 3,285 3,267 3,256 3,238
-,
.
.' -
a Based on SIC 7216 (Dry Cleaning Plants, Except Ruq Cleaning).
b '
U.S. Census regions.
c Projected from 1972 data using the 1967-1972 annual growth rate.
7-8
-------
TABLE 7-6
INDUSTRIAL DRY CLEANING PLANTSa
REGIONAL PROJECTIONS
19b/-19/~
Regionb rowth Rate
(%/Yr) 1967 1972 1975c 1980c
United States +2.13 918 1,020 1,087 1,207
New England - 1. 42 58 54 : 62 48
Middle Atlantic - 1. 61 167 154 147 131&
East North Central -0.10 197 196> 195 194
West North Central +2.67 64 73 79 9Q
South Atlantic +4.04 128 156 176 214
East South Central +3.66 61 73 81 97
West South Central +3.85 101 122 137 165
Mountain +8.90 32 49 63 97
Pacific +5.39 110 143 167 218
a Based on SIC 7218 (Industrial Launderers).
b U.S. Census regions.
c Projected from 1972 data using the 1967-1972 annual
growth rate.
7-9
-------
The changing structure of the industry is indicated by the percentage
breakdowns contained in Table 7-1. The commercial sector, which constituted
approximately 64 percent of the total establishments in the industry in
1967 and 60 percent in 1972, is projected to represent only 54 percent of
the total in 1980.
TABLE 7-7
PERCENTAGE BREAKDOWN OF ESTABLISHMENTS
1967 1972 1975 1980
Coin-operated 33.6 37.3 39.6 43.5
Commercial 64.4 60.5 48.0 53.9
Industrial 1.9 2.2 2.3 2.6
.
7.1.3 Dry Cleaning Equipment Sales
Another way of assessing the health of the dry cleaning industry is by
means of historical and recent sales data for the industry. Sales data were
obtained from manufacturers and from the Laundry and Cleaners Allied Trade
Associ ati on (LACATA), a leading manufacturers trade organi zati on.
7.1.3.1
Synthetic"Dry Cleaning Units
This category includes both fluorocarbon machines and perchloroethy1ene
machines. The former are solely used for commercial (retail) or coin-operated
dry cleaning, but the latter may be used for industrial cleaning, in addition.
In order to better make use of sales data tabulated by machine size, it is
necessary to determine which size perc machines are used for these different
classes. A member survey by the International Fabricare Institute (IFI) pro-
vides some help.2 The IFI membership is predominantly commercial, and virtually
all of the machines reported in the survey are less than 100 pounds/load capacity.
Hence, for the present ana1ysi s, i"t is. assumed that machines wi.th greater than
100 pounds/load capacity are chiefly industrial units, and machines with less
capacity are mostly commercial units.
The best sales data for synthetic machines were obtained from LACATA.3
Historical sales data for non-coin-operated units are given in Table 7-8.
7-10
-------
TABLE 7-8
SALES DATA FOR SYNTHETIC DRY CLEANING MACHINES
POUNDS/LOAD CAPACITY
- ~100
Year 0-19 20-40 41-55 56-99 Total
1967 a 979 187 112 36 1 ,314
-
1968 a 1 ,047 209 137 56 1 ,449
-
1969 a 1 , 024 167 161 35 1,387
-
1970 a 712 74 99 54 939
-
1971 a 613 a 83 102: 798
- -
1972 a 415 a a 67 482
- - -
1973 a 313 a 37 50 400
- -
1974 a 226 a a 58 284
- - -
a Insufficient participation, ~ot included in total units.
These sales data confirm the earlier comments on the poor economic conditions
in the commercial dry cleaning industry. If the earlier assumption that the
100 pound and larger category is predominantly industrial, this sector appears
to be relatively stable. No data were found for coin-op machines.
7.1.3.2 Petroleum Dry Cleaning Units
Data for petroleum machines were obtained from Washex Machinery Corpor-
ati on, the 1 argest U.S. manufacturer of petroleum dry cleaning machi nery. * Washex
provided the historical sales data listed in Table 7-9.4 The commercial
unit sales data further confirm the weak conditions in that sector. The sales
of industrial units indicate relatively sound economic conditions in that sector.
* Washex estimates that they sell about 90 percent of the industrial units and
50 percent of the commercial units in the United States.4
7-11
-------
TABLE 7-9
SALES DATA FOR PETROLEUM DRY CLEANING MACHINES
Conune rc i a 1 Indus tri g 1
Year Un i ts a Un i ts
1967 55 25
1968 36 96
1969 23 112
1970 23 65
1971 18 88
1972 4 65
1973 0 95
1974 2 88
1975c 2 53
a Average capacity of 100 pounds/] oad.
b Av~rage capacity of 500 pounds/load.
c
Through September.
7-12
-------
7.2 MODEL PLANT SELECTIONS
In making control cost estimates for the dry cleaning industry, it is
necessary to designate model plants, since the cost of control varies with
such factors as rated plant capacity (lb. ~er load), plant type (industrial,
commercial, or coin-op.), solvent type, and the annual production (lb. per
year). Accordingly, the model plants in Table 7-:1Q were selected after study
of technical literature and equipment sales information, and discussions with
industrial and trade association representatives. The models are not inten-
, .
ded to represent particular plants, but they provide a basis for making cost
estimates. The rationale for choosing these plant configurations follows the
table.
TABLE 7-10
MODEL DRY CLEANING PLANTS
P1 ant Machine Capacity Production
Type Sa~'fent Type (l b . pe r 1 oa d) Rate (lb./yr.)
Commercial Perc Dry-to-dry 40 100,000.
Commercial Perc Transfer 40 100,000
Industrial Perc Transfer 250 1,000,000
Industrial Petroleum Transfer 500 1,500,000
(Dual Phase)
Coin-Op Perc Dry-to-dry 4x2Sa 80,000
Coin-Op Fluorocarbon Dry-to-dry 4x12a 80,000
a The numbers 4x25 and 4x12 meQn four 25-1b. capacity and four 12-lb. capacity
units, respectively.
7.2.1
Commercial Plants
The reasons for selecting these particular plant configurations are as
follows:
. Accord~ng to industry representatives and a survey of dry cleaners,
most commercial piants use perchloroethy1ene.2
7-13
-------
. There are two common types of perc machines, dry-to-dry and trans-
fer.. Hence, economic impacts should be assessed for each.
. The 30 to 50 pound sizes were most commonly used in the industry
according to the International Fabriaare Institute (IFI) survey.2
In addition, a representative of a major manufacturer indicated
that the average machine size was about 40 pounds.5
. About two-thirds of the respondents to the IFI survey reported
annual cleaning volumes of 52,000 to 156,000 pounds. Here the
approximate middle of this range was selected as being representative.
7.2.2 Industrial Plants
The characteristics of these model plants were based on the following
factors.
. Either perchloroethylene or petroleum solvent is commonly found in
industrial applications.
. All petroleum machines and most industrial perc machines are trans-
fer ty'pes. .
. According to the major manufacturer of petroleum machinery, the 500-
lb. dual. phase machines are. their biggest sellers at this time.4
. A 250 pound perc machine has almost the same short-term production
rate as a 500 pound dual phase machine. (Paragraph 7.4.1.1 has a
more thorough discussion.) .
. The petroleum machine was assumed to process 10 loads per day, 6
days per week, 50 weeks per year.
. The perc machine was assumed to process about 15 loads per day,
6 days per week, 50 weeks per year.*
7.2.3 Coin-Operated Plants
The defining parameters of the coin-operated model plants were based
on the factors below:
.
Only perc and fluorocarbon machines are used in coin-op service,
and all coin-op units are dry-to-dry types.
. The 12 pound fluorocarbon machine is the most common size for these
units.5 .
* According to the manufacturer's brochures, this machine has a capacity of
, between 200 and 250 pounds per load, depending on the clothing type. Hence,
an average capacity of 225 pounds was used.
7-14
-------
. A fluorocarbon machine has about the same production capacity
as a perc machine twice as large in per load capacity. (See sub-
section 7.5.1 for more detail.)
. Each machine is assumed to process three partial loads - 20-lb.
for the perc units and 10-lb. for the fluorocarbon units - per
day, 7 days per week, 50 weeks per year. (The results are rounded
to 80,000 pounds per year.)
7-15
-------
7.3 ECONOMIC IMPACT ANALYSIS FOR COMMERCIAL PLANTS
The model plants selected for the economic analysis of the commercial
dry cleaning industry are both based on perchloroethylene cleaning machines,
for reasons discussed in the previous section. Two control measures have.
been shown to have excellent potential for reducing solvent emissions from
either new or modified commercial plants: (1) housekeeping procedures, in-
cluding the keeping of production and solvent consumption records; and (2) a
properly installed and operated carbon adsorber. The first measure is con-
sidered essential to the effectiveness of the second, as discussed in Section
4.0.
7.3.1
Control Cost Analysis
7.3.1.1
New Facilities
At the present time, only about 10 percent of perchloroethylene dry
cleaning machine sales are for new pJants, roughly 70. percent are replace-
ment machines, and the remaining 20 percent are for plant expansions.5
T~ble 7.;'11 shows the: re.quired investment for equipment to outfit each of the
, .
model plants. The cost of the vapor adsorber needed to implement the recom-
mended control system is also given. The other component of the system,
housekeeping, requires no capital outlay.
The size of the building needed for either of the model plants can
be estimated using the formula below:8
Required Square Feet = $1.50 Average Weekly Volume(tl
Base Price x 1.2
The base price, which is the cost of cleaning a dress or a 2-piece mans
suit, is currently about $2.25, although it does vary nationally.9 Each
model plant will generate annual receipts of about $125,000, using a dry
cleaning cost of $1.25 per pound and the assumed production volume of 100,000
pounds. Inserting these values in the formula, the required building size
is 1335 square feet. With a building cost of $15 per square foot, suggested
by industry representatives,9,10 the cost of the structure is about $20,000.
A commercial lot for this size building typically costs about $3,500 with uti-
lity connections.ll The total investment costs for the model plants, as
well as the incremental costs of control, are summarized in Table 7-12.
7-16
-------
TABLE 7-11
TYPICAL EQUIPMENT COSTS FOR A COMMERCIAL PERCHLOROETHYLENE DRY CLEANING PLANT7
Item(s)
Cost
1 - 10 H.P. Boiler (oil or gas fired), return system, blow
down tank, and accessories
1 - 3 H.P. Air Compressor
1 - Spotting board with spray tank
1 - Garment steam cabinet
1 - Topper and 1egger with puff iron, complete pants unit
1 - All-purpose utility press, 3-puff irons, form finisher,
complete all-purpose unit.
1 - Tailoring machine
1 - Automatic garment conveyor
1 - Monorail assembly
1 - Garment bagger
- Counters for office
1 - Cash register
Com lete Installation Cost
$3,300
1,200
700
1,200
4,200
3,900
60
2,600
1,80
75
600
1,200
7,500
bove Costs
ransfer 40-lb. machine, 'cartridge filter,
otal Installed Cost Transfer Plant
(installed with either of
still & drier
ry-to-dry 40-lb. machine, cartridge filter & still
otal Installed Cost/Dr -to-dr Plant
7-17
-------
TABLE 7-12
EFFECTS OF EMISSION CONTROLS ON INVESTMENT
COSTS IN COMMERCIAL DRY CLEANING PLANTS
Item Dry-to-Dry Transfer
Plant Plant
Equipment $51,875 $45,875
Building 20,000 20,000
Land 3,500 3,500
Total Cost
(Uncontrolled) 75,375 69,375
Control Device
(Adsorber) 3,300 3,300
Total Cost
(Controlled) 78,675 72,675
Incremental Control
Cost (%) 4.4 4.8
7-18
-------
The calculation of direct operating costs and annualized capital charges
fOr the complete 2-part control system is based on the following assumptions.
. Annualized Capital Charge (based on a sinking fund factor)
- SBA-approved 10% p.a. note (3% above prime rate) for 10 years
- Equipment amortized over 10 yr. period
- Equipment cost of $3300
. Direct Operating Costs
Total maintenance and operating cost is 5% of original equipment
cost without solvent recovery credit.12
- Solvent cost is $2.80 per gallon.
juncontro11ed plant - 6,000 1b./drum
- Solvent mileages housekeeping procedures - 10,000 1b./drum
housekeeping + adsorber - 15,000 1b./drum
Table 7-13 summarizes the annualized costs of meeting the
mileage 'requirement, which corresponds to a perc emission
pe r ' ton.
15,000 1b./drum
rate of about 94 lb.
o
TABLE 7-13
ANNUALIZED COST OF EMISSION CONTROL
FOR MODEL COMMERCIAL DRY CLEANING PLANT
Item Cost
Capital Charges
Interest $ 196
Depreciation 330
Total Capital Charge (C) $ 526
Direct Operating Costs
Maintenance and Operating Expenses $ 165
Solvent Credit -1456
Net Direct Cost (D) -$ 1291
Net Annualized Cost (CtD) -$ 765
7-19
-------
Although dry-to-dry plants are commonly believed to exhibit better mileage per-
formance than transfer plants, no reliable data are available to con~irm any
such differences. Consequently, in the estimation of annualized costs of con-
tr.ol, the same solvent mileage assumptions were made for both model plants.
7.3.1.2 Modified Facilities
For cost estimation purposes, the plant modification considered is the
addition of a new 40-lb. dry cleaning machine to an existing plant. No addition-
al land area or floor space is assumed to be needed for the control equipment.
For the new facilities; installation costs were 16.9% and 19.5% of total equip-
ment costs for the dry-to-dry and transfer plants, respectively. Installation
of equipment in an existing plant is more difficult, so a higher installation
rate of 25 percent is assumed. The total investment cost of the control equip-
ment is about $4125, of which $825 is for installation and $3300 is actual equip-
ment cost. Table 7-14 summarizes the total installed cost of the modified fa-
cil iti es.
. 0
TABLE 7-14
EFFECTS OF EMISSION CONTROLS ON INVESTMENT
COSTS FOR A DRY CLEANING PLANT EXPANSION
Dry-to-Dry Trans fer
Item Plant.. Plant
Cleaning Machine $23,000 $17,000
Installation Cost 4,500 4,500
Total Cost (Uncontrolled) $27,600 $21 ,500
Vapor Adsorber $ 3,300 $ 3,300
Installation Cost 825 825
Total Cost of Control $ 4,125 4,125
Total Cost of Controlled $31 ,725 $25,625
Plant Expansion
Incremental Control
Cost (%) 14.9 19.1
7-20
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In estimating ann"ualized costs of emission controls for new commercial
installations, the capital charges were based on the uninstalled price of the
control device. This was because the incremental cost of installing an adsorber
at a new site was negligible in comparison with total installation costs. How-
. ever, as noted previously, the greater difficulty of placing equipment in an
existing plant requires that these costs be explicitly considered in plant mod-
ifications. Direct operating costs of the control device will be identical to
those for new facilities, since the equipment .and operational parameters are the
same. Table 7-15 summarizes the annualized costs of a control system for an
addition to an existing plant.
TABLE 7-15
ANNUALIZED COST OF EMISSION CONTROL FOR
EXPANSION OF COMMERCIAL DRY CLEANING PLANT
Item Cost
Capital Charges
Interest $ 246
Depreci at ion 412
Total Capital Charge (C) $ 658
Direct Operating Costs.
Maintenance &. Operating Expenses $ 165
Solvent Credit - 1456
Net Direct Cost (D) - $ T29T
Net Annualized Cost (C+D) -$ 633
7.3.2 Other Cost Considerations
For the most part, state solvent emission regulations governing dry clean-
ing plants are based on the Los Angeles "Rule 66" approach or on the control of
hydrocarbons, alone.* Under this type of regulation, perchloroethylene is an
exempt solvent for which there are no emission limitations. Hence, existing
state solvent emission laws are not expected to exacerbate any costs resulting
from the recommended control alternative for commercial perc plants.
"* At least one local agency - the Maricopa County, Arizona Bureau of Air
Pollution Control - requires the use of a vapor adsorber on new perc
plan ts .14
7-21
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Perchloroethylene plants have little potential for causing water pollu-
tion problems and are currently under no costly effluent control guidelines.
Likewise, relatively small amounts of solid waste result from the dry cleaning
process, and disposal costs are minimal. Therefore, no significant cost im-
pacts are expected from either water quality or solid waste regulations.
The principal control costs currently being impos.ed on perc plants are
the Occupational Safety and Health Administration (OSHA) restrictions for sol-
vent vapors in the working environment. At the present time, the allowable
time-weighted-average(TWA) perc leve1s in working areas are as follows:
. 8-hr, TWA - - 100 parts per million (ppm).
. 200 ppm may be exceeded only once every 3-hr. for no more than
5-minutes.
. Never to be exceeded - - 300 ppm.
Although it is possible to meet these standards by ventilation alone, a better.
approach is directing air collected from machine vents and floor pick-ups to
, a vapor- adsorber., This allows ,the dry. cleaner to meet the OSHA requi rements and
reduce his solvent costs. In a survey of IFI members, 52 percent of the perc
plant operators now have vapor adsorbers in their plants.2 Consequently, the
OSHA regulations are not expected to increase the cost of implementing the
proposed control alternative.
7.3.3 Economic Analysis
7.3.3.1
New FaciHties
For the past several years, as indicated in Section 7.1, the commercial
dry cleaning industry has been experiencing sharp declines in both numbers of
plants and in real gross income per plant. Additional evidence of this decline
, ,
is the estimate by one equipment manufacturer that only 10 percent of their new
cleaning machines are being used in new installations.5 Even more discouraging
is the fact that tot~l machine sales in the sizes used for retail cleaning de-
, 3'
creased by about 75 percent between 1970 and 1974. Although no data are avail-
able to confirm the claims, discussions with industry representatives indicate
that the following factors are responsible for the decline:
. The national economic conditions, which tend to affect service
industries, specifically, quite severely.
7-22
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. Increasing usage of synthetic fibers, which do not require
dry cleaning.
. A general IIweeding outll of older less efficient plants which
were built during the IIboom periodsll of the 1940.s and 1950's
but which cannot compete economically with newer installations.
In spite of the weak economic conditions in the commercial sector,' the addi-
tional investment cost of the proposed controls for a new plant is less than
5 percent (Table 7-12) and would not be expected to prevent the construction of
a new plant. The incremental cost of control is considered a minor factor in
comparison with the other economic factors.
The annua1ized.costs of the controls (Table 7-13) show that the con-
trols result in a net savings for the dry cleaner. Although it is possible
that this savings could be passed on to the customer, it is not likely because
a customer survey in the northeast indicated that price is a very minor item
in selecting a dry c1eaner.15 However, it is also unlikely that prices would
be raised as a result of the reduction in costs. The net effect of the con-
trols on price will probably be zero and profits should be ihcreased.
7.3.3.2 Modified Plants
Although, in the case of new plants, the incremental investment cost
of control represents a relatively small part of total investment, the same
cannot be said of additions to existing plants. As Table 7-14 showed, con-
trol equipment adds 14.9 percent and 19.1 percent, respectively, to the
total capital requirement for dry-to-dry and transfer plants adding a new
40-lb. cleaning machine. In view of the poor economic status of the conuner-
cia1 dry cleaning sector at this time, this additional cost could prevent
operators from adding capacity. In the case of an operator who is only con-
sidering adding capacity, the additional cost might well prove decisive in
preventing the addition.
With regard to the annualized cost of the controls, the situation
is similar to that of new facilities: If an operator can afford the initial
cost of control, his annual operating expenses will be reduced. Conse-
quently, no effect on prices is expected~ and'profits should be boosted.
7-23
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7.4 ECONOMIC IMPACT ANALYSIS FOR INDUSTRIAL PLANTS
Two model dry cleaning plant configurations were designated for analysis
of the industrial sector:
. A plant utilizing a 250-lb. capacity industrial perchloroethylene
machine.
. A plant utilizing a 500-lb. dual phase petroleum machine.
A complication arises in defining an entire industrial laundry plant as opposed
to that part of the facility doing dry cleaning per se. Virtually all industrial
dry cleaning facilities are associated with laundering facilities. Hence) in
determining total investment costs for a new plant, the laundry equipment should
be considered as well as the dry cleaning machinery.
The control system believed to be most appropriate for use in each of the
two industrial model plants and for modifications to existing plants consists of
two control measures: (1) housekeeping procedures, including the recording
and retaining of production and solvent consumption data; and (2) a properly in-
stalled and operated carbon adsorber. It should be noted that carbon adsorbers
for petroleum plants are not available commercially at this time, and cost esti-
mates for the device are based on data provi ded by Vi c Manufacturi ng Co.) a major
manufacturer of adsorbers for the industry.
7.4.1
Control Cost Analysis
The assistance of industry spokesmen - including equipment manufacturers)
trade associations, and operators - \.,ras utilized to define typical industrial
laundry facilities, which included the previously-described dry cleaning model
plants as component parts. Equipment costs, installation costs and operating
costs were obtained from these same sources for estimating investment and annual-
ized control costs for new and modified plants.16, 17
7.4.1.1
New Facilities
Complete investment cost data for new industrial plants ~ith perc-based
and petroleum-based dry cleaning machines are shown in Tables 7-16a and 7-16b,
respectively. All of the data are the most current available, as the reference
dates indicate. With the exception of the dry cleaning machinery, these plants
are identical, to allow more meaningful cost comparisons. The paragraphs below
serve to emphasize the differences between the two operations:
7-24
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TABLE 7-16a
INVESTMENT COSTS OF EMISSION CONTROLS IN AN INDUSTRIAL LAUNDRY: CASE 1 -
PERC DRY CLEANING MACHINE
Item { s) Cost Reference
, - 600-lb laundry machines with dryers, com-
plete a~d installed $115,000 10
Boilers for steam and hot water, complete
and installed 90,000 10
Finishing equipment, compressors, and
other ancillary equipment, installed 115,000 10
Building (30,000'sq. ft. @ $lO/sq. ft.) 300,000 10
Land (33,333 sq. ft. @ $2.25/sq. ft.) 75,000 11
1 - 250-lb. Industrial cleaning machine, com-
plete and installed, w. still 94,500 16
h - 250-1b. Reclaiming dryer for the above,
install ed 35,500 16
~ - 40 H.p. BOiler, complete and installed 8,000 16
Total Cost of Uncontrolled Facility $833,000 --
Control device {carbon adsorber, installed 7,000 16
Total Cost of Controlled Facility $840,000 --
Incremental Control Cost (% based on
total plant cost) 0.84 --
Incremental Control Cost (% based only on
dryc1eaning equipment cost) 5. 1 --
7-25
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TABLE 7-l6b
INVESTMENT COSTS OF EMISSION CONTROLS IN AN INDUSTRIAL LAUNDRY: CASE 2 -
PETROLEUM DRY CLEANING MACHINE
Item(s) Cost Reference
2 - 600-lb. laundry machines with dryers,
complete and installed $115,000 10
Boilers for steam and hot water, com-
plete and installed 90,000 10
Finishing equipment, compressors, and
other ancillary equipment, installed 115,000 10
Building (30,000 sq. ft. @ $lO/sq. ft.) 300,000 10
Land (33,300 sq. ft. @ $2.25/sq. ft.) 75,000 11
h - 500-lb. Dual phase cleaning machine, com-
plete and installed, with pumps, filter,
and. vacuum sti 11.. " 80,.500 4
Dryers for above, complete and installed 35,000 4
~ - 40 H. p. Boiler, complete and installed 8,000 16
Total Cost of Uncontrolled Facility $818,500 --
Control device (carbon adsorber, installe( 90,000 17
Total Cost of Controlled Facility $908,500 --
Incremental Control Cost (% based on
total plant cost). 0 11.0 --
Incremental Control Cost (% based
only on drycleaning equipment cost) 72.9 --
7-26
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Perc Installation - The prices of this machinery are based on
a modular dry cleaning system. The very low installation costs -
$1 ,000-4,000 for the en ti re system - are a consequence of the mod-
ular construction and the pre-assembly of many critical elements,
such as wiring harnesses.16 To minimize solvent losses during
transfer of clothing from the washerjextracter to the dryer the
latter is mounted on tracks so that it mates with the former during
transfer. This also reduces labor requirements and reduces the
transfer time. Although this perc machine has only half the capa-
city of the petroleum machine of the other model plant, the pro-
duction rates are similar because the perc machine processes a
load in about half the time required by the petroleum unit.4, 18
. Petroleum Installation - This plant uses the dual phase (solvent
and water) process discussed in Section 3.0. According to the
major manufacturer of petroleum machines, about 80 percent of all
new petroleum units use this system.4 As noted earlier, carbon
adsorbers are not available in the U.S. for petroleum machines at
this time, and the costs shown in Table 7-16b are rough estimates
provided by a manufacturer.17
.
The incremental investment cost of co~tro1 f~r the perc plant-is less
than 1 percent of-total plant cost or about 5 percent of the uncontrolled dry
cleaning equipment cost, values which are considered quite modest. In marked
contrast, the incremental investment cost of control for the petroleum plant
is 11 percent, which represents almost 73 percent of the uncontrolled dry
cleaning equipment cost. The economic impacts of these costs are discussed
later in this section.
Annualized control costs for the two model plants were separated into
the usual two components: (1) capital charges (depreciation and interest);
and (2) direct operating costs and credits. The assumptions used for both
plants are tabulated below:
PERC PLANT
. Annualized Capital Charge (based on a sinking fund factor)
- SBA-approved 10% p.a. note (3% above prime rate) for 10 years
- Amortization period of 10 years
- Equipment cost of $7000
. Direct Operating Costs
- Annual maintenance cost of ~% of equipment cost 17
- Utility charge for solvent recovery of $0.15 per gallon 17
7-27
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- Solvent mileages
{uncontrolled plant - 10,000 lb./drum
housekeeping procedures - 15.,000 lb./drum
housekeeping + adsorber - 20,000 lb;/drum
$2.80 per gallon
- Solvent cost of
PETROLEUM PLANT
. Annualized Capital Charge (based on a sinking fund factor)
- SBA-approved 10% p.a. note (3% above prime rate) for 10 years
- Amortization period of 10 years
- Equipment cost of $90,000
. Direct Operating Costs
- Annual maintenance cost of ~% of equipment cost17
- Utility charge for solvent recovery of $0.15 per gallon17
- Uncontrolled solvent mileage of 1436 lb./drum19
- Losses from tumbler are 70% of total solvent losses 19, 20
- Adsorber recovers 90% of tumbler losses
- Solvent cost of $0.57 per gallon.
More thorough discussions of the technical bases for the emission and control-
related assumpt!Bns may be found in Sections 3.0 and 4.0.
plants.
The annualized control costs are tabulated in Table 7-1'1 for both
The results may be summarized as follows:
. The control equipment on the perc plant reduces annualized costs
by $5,739, a return-on-(original)-investment of 82 percent. This
is a function of the modest cost of th~ control equipment and the
high value of the recovered solvent.
. The annualized cost of control for the petroleum equipment is quite
modest, only $347 per year. This differs from the preceding case
because: (1) the adsorber is much more expensive; and (2) the
recovered solvent has relatively little value.
TABLE 7-17
ANNUALIZED COSTS OF EMISSION CONTROL FOR MODEL
INDUSTRIAL DRY CLEANING PLANTS.
Perc-Based Petroleum-Based
Item Plant Plant
Capital Charges
Interes t $ 416 $ 5,344
Depreci ati on 700 9,000
Total Capital Charge (C) $1 ,116 $ 14~344 ..
7-28
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TAffLE 7-~~ (contd.)
Perc-Based Petroleum-Based
Item Plant Plant
Direct Operating Costs
Maintenance $ 35 $ 375
Utilities 390 5,133
Solvent Credit -7,280 -19,505
Net Direct Cost (D) -$ 6,855 -$ 13,997
Net Annualized Cost (C+D) -$ 5,739 $ 347
7.4.1.2 Modified Facilities
Most modifications to an existing plant will involve one of the follow-
ing changes: (1) replacement of a worn-out machine with a newer one of the
same type; (2) replacement of a machine using one solvent type by one of another
type; or (3) addition of a new machine to increase capacity. Because each of
these modifications involves the addition of a new machine, this is the option
used for cost estimation purposes. I~O additional floor space or land area is
assumed to be needed, and the dry cleaning equipment added is the same as was
used in the new plant estimates. The additional installation costs due to
maneuvering and working in an existin~ plant were based on the following assump-
tions:
. For the modular perc equipment, installation costs were doubled
from $500 per piece of equipment to $1000.
. Installation costs for the petroleum cleaning machine were in-
creased from about 15 percent to 20 percent of base price. The
installation cost of the vapor adsorber was increased from 20
percent of base price to 25 percent.
Table 7-18 shows the effects of the control systems on investment costs for ex-
pansion of both plant types. In summary, the results are as follows:
. For the perc plant expansion, the controls add a modest 5.1 percent
($7,500) to investment costs.
. The controls add 73.2 percent ($94,000) to investment costs in the
petroleum plant expansion. This is a very large, possibly critical,
increase in costs, as discussed later in this section.
7-29
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TABLE 7-18
EFFECTS OF EMISSION CONTROLS ON INVESTMENT COSTS
FOR INDUSTRIAL DRY CLEANING PLANT EXPANSIONS
Perc-Based Petroleum-Based
Item Plant Plant
Cleaning Machine $ 95,000 $ 84,000
Dryer (s) 36,000 36,000
Boiler 8,500 8,500
Total Cost (Uncon"trol1ed) $139,500 $128,500
Vapor Adst>rber $ 7,500 $ 94,000
Total Cost of Controlled $147,000 $222,500
Plant Expansion
Incremental Control Cost 5. 1 73.2
(%)
Estimates" of annualized costs of control for the two plant expansions
were based on the same assumpHons as wer:e the estimates for new plants, with
the exception of fnstalled cost of the equipment. The latter costs were adjust-
ed, as discussed previously, to account for higher installation costs in exist-
ing plants. The results appear in Table 7-19 and may be summarized as follows:
. The control system for the perch1oroethy1ene-based plant reduces
annualized costs sharply. The return on investment is about 75
percent per year.
. Although the petroleum plant control system does not decrease
annualized costs, the estimated increase in these costs is small.
TAB LE 7 - 19
ANNUALIZED COSTS OF EMISSION CONTROL FOR INDUSTRIAL
DRY CLEANING PLANT EXPANSIONS
Perc-Based Petroleum-Based
Item Pl ant Pl ant.
Capital Charges
Interest $ 446 $ 5,582
Depreci at ion 750 9,400
Tota 1 Capital Charge (C) $1 ,196 $14,982
7-30
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'-
r
TABLE 7-19 (contd.)
Perc-Based Petroleum-Based
Item Plant Plant
Di rect Operating Cos ts
Maintenance $ 35 $ 375
Utilities 390 5,133
Solvent Credit -7,280 -19,505
Net Direct Cost (D) ':'$6,855 -$13,997
Net Annualized Cost (C+D) -$5,659 $ 985
7.4.2 Other Cost Considerations
As noted in the discussion for commercial plants, most state solvent
emission regulations for dry cleaning plants are based on the Los Angeles
"Ru1e 66" approach or on control of hydrocarbons, alone. Perc is normally
exempt from the regulations, although a few agencies require use of vapor ad-
sorbers on new plants. As a result, existing state air quality regulations are
not expected to add to the cost of the proposed control system.
The situation is different with regard to petroleum solvents, since these
are frequently subject to regulation by state or local agencies. The regulations
commonly allow compliance by either of the following measures:13
. Limiting daily emissions, or
. Utilizing a non-photochemically reactive petroleum solvent.
The latter approach is preferred by dry cleaners, and the so-called "Ru1e 66"
solvents are generally available at little or no extra cost. The cost of imple-
menting the proposed control alternative should not be affected by these regulations.
Perch1oroethylene plants have little potential for causing water pollution
problems and are currently under no costly effluent control guidelines. Like-
wise, relatively small amounts of solid waste result from the dry cleaning pro-
cess, and disposal costs are minimal. Therefore, no significant cost impacts are.
expected from either water quality or solid waste regulations.
In Section 3.0, it was noted that some of the major forces causing a shift
towards dual phase dry cleaning machines were increasingly restrictive local regu-
lations against discharge of harsh detergents from industrial laundries into sewers.
. 7-31
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Hence, dry cleaning is viewed as a water pollution control measure in this case
and local regulations should not exacerbate the cost of meeting the control al-
ternative. No costly solid waste disposal problems occur in petroleum plants,
so there should be only minimal cost impacts in this area.
As was true for commercial perc plants, the principal control costs
currently being imposed on industrial perc plants are the Occupational Safety
and Health Administration (OSHA) restrictions for solvent vapors in the work-
. . .
ing environment. Although the OSHA requirements can be met be ventilation
alone, the reduction of solvent losses to the atmosphere resulting from emis-
sion controls should help to reduce the ventilation requirements. Although
the OSHA limits are less restrictive for petroleum plants, similar reasoning
applies.
7.4.3 Economic Analysis
On the basis of the industry profile in Section 7.1, the industrial
I
laundry sector appears to be a healthy, but not thriving industry. Some of
the important points are as' follows:
. Nationwide, the industry had a growth rate of 2.13 percent in the
years 1967 through 1972, although there were some regions of the
country showing negative growth. (Table 7-6)
. Total receipts per plant increased by a modest 4.1 percent (constant
1967 dollars) between 1967 and 1972. (Table 7-2)
. Sales of industrial-sized machines have remained stable and strong.
Sales of petroleum machines appear to have peaked in 1969, decreased
sharply during the 1970 recession year, and then recovered with
moderate growth since that time.4 Perchloroethy1ene machines have
shown similar, but not identical trends.3
In view of the modest growth in the industry as a whole, it appears that most
. of the new machines are being used as replacements or add-on units. The replace-
ments can be of two types: (1) replacement of dry cleaning equipment by other
dry cleaning equipment; or (2) replacement of industrial laundry equipment by
dry cleaning machines. The latter type of exchange seems likely to have in-
creased in importance recently as a result of ~ater pollution regulations and
the increasing use of synthetic fabrics in uniform rental operations.*
* For more details, see subsection 3.2.2, Petroleum Solvent Plants.
o
7-32
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However, statistics to support this premise were not available from industry
sources. The following material discusses the potential economic impacts of
the control alternative on the industry in light of its current economic con-
dition.
7.4.3.1
New Facilities
For new plants with perchloroethylene dry cleaning machines, the incre-
mental investment cost of control is less than 1 percent of the uncontrolled
plant cost. In addition to this low investment cost, the control system
reduces annualized costs by almost $6,000. As a result, the proposed
control system is not expected to have any impact on growth in the perc-using
sector of the industry. Because the reduction in annualized costs is relatively
small in comparison with total investment costs and annual average receipts,
no effects on pricing policies are expected. The operating cost savings would
most likely be used to marginally increase profits.
In the case of new plants using petroleum dry cleaning equipment, the incre-
mental investment cost of control is 11 percent of the uncontrolled plant cost.
This is considered a significant impact in this relatively stagnant industry.
The annualized operating cost of control is only $347, a negligible increase.
Although the increased investment cost might prevent the construction of a
. new plant, another possibility seems more likely. Because, for controlled
plants, the perc-based industrial laundry has an investment cost about 7.5
percent ($68,500) less than the equivalent petroleum operation, a shift towards
perc machinery in new facilities seems possible. If a new petroleum plant is
built, the increased annual costs resulting from the control system are
so small that no pricing changes would be expected.
A further comment seems appropriate in regard to the possible shift
towards perc machinery. Although personalized viewpoints abound in this indus-
try, there is no good reason to believe that there would be any change in the
quality of cleaning or increased deterioration of fabrics, as a result of the
(possible) change. . Numerous examples of successful perchloroethylene-based
industrial plants exist at this time.
7.4.3.2 Modified Facilities
For modifications entailing addition of a perc machine, whether for
expansion or replacement, the emissions control increases investment costs by
7-33
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5.1 percent ($7,500), which is considered reasonable. This modest investment
cost, when coupled with a $5,659 reduction in annualized costs is expected
to have little or no impact on future plant modifications. The effect of the
,
reduction in annual costs is not believed to be large enough to significantly
affect prices in the industrial sector.
For the modification of a plant involving the addition of a petroleum machine,
the investment picture is much less encouraging than for the preceding case.
The incremental investment cost of control is 73.2 percent ($94,000), a hi'ghly
significant figure. This makes the cost of a controlled petroleum plant modi-
fication more than 50 percent greater than the equivalent perchloroethylene
plant modification. Hence, most operators would probably choose the latter
option when they modify their plants. If the petroleum machine should be chosen,
the additi~nal annual costs ($985) should not be sufficient to result in any
changes in pricing structure.
From a technical point of view, there are no major difficulties involved
in either of these modifications. However, there are two installation advantages
for the percmachin~:
. The perc machine is modular and less bulky, so it is more easily
. installed'...
. Local fire regulations require underground tanks for petroleum solvent
storage, and it might prove difficult to make this installation in
some cases. .
With these two qualifications, either type of machine should interface well with
either an existing perc plant or a petroleum plant.*
* It should be kept in mind that the dual phase petroleum machine requires a
hot water supply, but in an industrial laundry, this should be no problem.
,)
7-34
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7.5 ECONOMIC IMPACT ANALYSIS FOR COIN-OPERATED PLANTS
Only dry-to-dry machines. are used in coin-operated plants, so all machines
use synthetic solvents, either perchloroethylene or Freon 113~ Like industrial
plants, coin-operated dry cl eani ng machi nes are common ly associ ated wi th 1 aun-
dry facilities, though in the latter case the laundry machinery is also coin-
operated. In view of this, coin-operated plants are considered to be adjuncts
of laundromats, and incremental control costs are assessed in comparison to dry
cleaning equipment costs rather than to total plant costs.
7.5.1
Control Cost Analysis
Because fluorocarbon machines have shorter cycle times, - the solvent is
much more volatile than perchloroethylene -. they have more productive capacity
for a given size machine than perchloroethylene machines. Consequently, .compar-
ison of equivalent plants requires that larger capacity be assigned to the perc
plant. However, machines are not made in every possible size, and the two plants
can only be matched approximately. In the present case, 4-25 lb. perc machines
are compared with 4-12 lb. fluorocarbon units, and the former probably have some-
what more long-term production capacity.
Table 7-20 summarizes the investment costs and the incremental effects of
emission controls for the two model plants. As noted, the fluorocarbon plant
requires no additional equipment for control, since these machines have built-in
control devices.
There are no capital charges for the fluorocarbon plant emission controls,
and no more than manufacturer1s suggested maintenance is needed for retaining the
low emission levels of the machines. In view of this, the annualized cost of
control for fluorocarbon plants is considered negligible.**
The calculation of direct operating costs and capital charges for control
of the perc installation is predicated on the assumptions below:
. Annualized Capital Charge (based on sinking fund factor)
- SBA-approved 10% p.a. note (3% above prime rate) for 10 years
* Freon is a trademark of E.I. DuPont de Nemour and Company.
** The cost of the required record-keeping should be insignificant.
"
J,,1!C
-------
TABLE 7- 20
INVESTMENT COSTS OF EMISSION CONTROLS IN
COIN-OPERATED DRY CLEANING PLANTS
Perchloroethylene Fluorocarbon
, Item(s) Pl ant21 Plant22
4 - Dry-to-dry cleaning machines a $32,000 $31 ,900
4 - Cartridge filter/still units 6,000 Built-in
1 - Air compressor 500 500
Ins ta 11 ati on 8,750 1 ,000b
Total Cost of Uncontrolled Plan1 $47,250 $33,400
Control device (carbon adsorber, . c
installed~ 6,050 -
. 'Total Cost of"Controlled Plant $53,300 $33,400
Incremental Cost of Control (%) 12.8 0.0
a As discussed in the text, the perchloroethyl~ne and fluorocarbon
machines are not precisely equivalent, but they are matched as
well as possible.
b Fluorocarbon machines need no instaJlation other than bolting to
the floor and connections to the power lines and compressed air
source.
c Fluorocarbon machines have built-in refrigeration units which serve
as control devices during the drying/aeration cycle.
"
7-36
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- Equipment amortized over 10 yr. period
- Equipment cost of $6,050.
. Direct Operating Costs
- Total maintenance and operating cost is 5% of installed adsorber
cost without solvent recovery credit.12
- Solvent cost is $2.80 per gallon.
. juncontro11ed plant-4,400 lb./drum23
- Solvent mileages housekeeping-8,000 lb./drum
housekeeping+adsorber-12,000 lb./drum
Table 7-21 summarizes the annualized costs for meeting the 12,000 lb./drum mile-
age requirement, which corresponds to a perc emission rate of about 118 lb. per
ton of cleaning. The value of the recovered solvent more than compensates for
the capital charges and additional operating costs, and annualized costs are re-
duced by $410 compared to the uncontrolled case.
7.5.2 Other Cost Considerations
Existing state and local solvent regulations for coin-operated perc plants
are the same as those for other plants. That is, the solvent is either considered
exempt from the regulations or, in one case,14 a carbon adsorber is required in
new plants. As a.result, these regulations will not exacerbate the costs of imp1e-
8enting the recommended emission control alternative. No regulations are known to
exist for fluorocarbon plants.
Properly maintained coin-op machines have only slight water pollution po-
tenti~l and no costly effluent controls are known to be in effect. Also, only
small amounts of solid waste - chiefly filter cartridges and lint - are produced
by the machines. Cost impacts from these two pollutants are minimal.
For the Occupational Safety and Health (OSHA) limitations on solvent levels
in the working environment, the same considerations apply to coin-op plants as
for commercial plants (subsection 7.3.2). That is, the OSHA standards and the
proposed control system are complementary, and neither should exacerbate the
costs of the other.
7.5.3 Economic Analysis
The industry profile in Section 7.1 indicated that the coin-operated. sec-
tor is a somewhat stagnant industry, as illustrated by the following salient
points:
7~17
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TABLE 7-21
ANNUALIZED COSTS OF EMISSION CONTROL FOR
MODEL COIN-OPERATED PERCHLOROETHYLENE PLANT
Item
Cost
Capital Charges
Interest
Depreci ati on
Total Capital
Charge (C)
$ 359
605
$ 964
Direct Operating Costs
Maintenance & Operating Costs
Solvent Credit
Net Direct Costs (D)
$ 303
- 1,677
-$1,374 .
Net Annualized Costs (C+D)
-$ 410
7-38
-------
. The number of establishments increased by less than 10 percent
between 1967 and 1972, an annual growth rate less than 2 percent.
. Gross receipts per plant decreased by 8.7 percent in the same
five year period.
. The number of paid employees increased by more than 43 percent in
the period, so a larger number of employees are generating less
income.
As a consequence of these general economic conditions in the coin-op sec-
tor, most purchasers of coin-op equipment will probably be trying to minimize
their investment costs. From this standpoint, the fluorocarbon equipment would
probably be chosen, because the model plant costs $19,900 less than the equiva-
lent perc model plant. Even though the controls for the perc plant reduce
annualized costs, it would require about twenty years to make up the initial
difference in costs, if the equipment should last that long.
No matter which type of equipment is chosen for a new or modified plant,
. there would most likely be no change in pricing structure as a result of the
. .
recommended control alternative. The perc plant controls reduce annualized
costs by only a moderate amount, while the fluorocarbon controls should have
an even lesser effect.
7-39
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7.6 REFERENCES FOR CHAPTER 7.0
1.
U.S. Department of Commerce, Bureau of Census~ 1967 and 1972 Census
of Business, Selected Service Industries-Area Statistics.
2. Watt, Andrew, IV and William E. Fisher, IIResults of Membership Survey
of Drycleaning Operati ons, II Internati onal Fabri care Institute (IFI)
Special Reporter #3-1, January-February 1975.
3.
IIQuarterly Machinery Market Report for the Quarter Ended June 30,
1975, IILaundry and Cleaners Allied Trades Association, 22 August
1975.
4.
Informa'tion provided by Mr. Steven Landon, President, \'Jashex Machine-
ry Corporation, 4 December 1975.
Information provided by Mr.J.l'J. Barber, Research Director, Vic Manu-
facturing Co., Minneapolis, Minn., 12 January 1976.
5.
6.
Information provided by Mr. G.H. Smith, General Sales Manager, Ameri-
can Laundry Machinery, Cincinnati, Ohio, 19 February 1976.
Information provided by Mr. A.C. Cullins, Laundry and Dry Cleaning
Consultant, Standard Laundry Machinery Co., Inc., Mt. Ranier, Md.,
25 February 1976.
7.
8.
Anonymous, IIPlant Layout,1I National Institute of Drycleaning (now
part of IFI), Management Bulletin M-106, April 1969.
Conversation with Mr. Ken Faig, International Fabricare Institute,
Joliet, Ill., 20 February 1976.
9.
10.
Conversation with Mr. Steven Landon, President, Washex Machinery Cor-
poration, Wichita Falls, Tex., 2 March 1976.
Marshall-Swift, IIEvaluation & Cost Estimates.1I (This publication
contains property costs for all parts of the U.S., and is updated
monthly. )
11.
12.
Information provided by Mr. J.W. Barber, Research Directo~, Vic
Manufacturing Co., Minneapolis, Minn., 12 December 1974.
Feldstein, Milton, IIA critical review of regulations for the control
of hydrocarbon emissions from stationary sources, II J. Air Poll. Control
Assoc. ..2!:469-78 (1974).' '
14. Maricopa County Bureau of Air Pollution Control, Rules and Regulations,
Maricopa County Health Dept., Phoenix, Arizona, 1 October 1975.
13.
15.
liThe Drycleaner Prepares for the Futurell, a statement by the Neigh-
borhood Cleaners Association, New York, N.Y.
7 -l1n .
-------
16.
Conversation with Mr. Fred H. Smith, General Sales Manager,
American Laundry Machinery Industries, Cincinnati, Ohio, 12
March 1976.
17.
Letter from Mr. J.W. Barber, Research Director, Vic Manufac-
turing Co., Minneapolis, Minn., to Mr. C.F. Kleeberg, U.S.
Environmental Protection Agency, 6 February 1976.
Kleeberg, C.F., "Plant Visit to a Large Industrial Dry Cleaner,"
memo to J.F. Durham, U.S. Environmental Protection Agency, 9 .
December 1975.
18.
19.
Fisher, W.E., liThe ABC's of Solvent Mileage," Part One, IFI
Special Reporter #3-4, July-August 1975.
20.
Landon, Steven, President, Washex Machinery Corp., letter to C.F.
Kleeberg, E.P.A., 27 January 1976.
21.
Information provided by Mr. Harry Oliver, President, State Equip-
ment Co., Inc., Arlington, Virginia, 16 March 1976.
22.
Price List No. 1751T-6, dated 2/10/75, Vic Manufacturing Co.~
Minneapolis, Minnesota.
23.
Customer Solvent Consumption Survey, Dow Chemical U.S.A., Midland,
~1i chi gan.
7-41
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APPENDIX A
EVOLUTION OF PROPOSED STANDARDS
22 November 1974 - Contract Kick-off Meeting
Location:
Attendees:
Agenda:
Comments:
EPA offices, Mutual Building, Durham, N.C.
For Dow Chemical U.S.A. - K.O. Graves and K.S. Surprenant;
for EPA - Thomas Bibb/ESED, Frank Bunyard/SASD, Stanley
Cuffe/ESED, Jim Homolya/CPL-SSMRS; William Johnson/ESED,
ED McCarley/ESED, and David Patrick/ESED; and, for TRW -
Tony Eggleston, Billy McCoy and, William Piske.
General approach to be taken in developing new source per-
formance standards for the vapor degreasingindustry (Dow)
and the dry cleaning industry (TRW).
. William Johnson will be the EPA Project Officer.
.-,.First priority will be location and description of candi-
date emission control systems. (Prototypes can be candi-
dates.)
. A total organlc compound approach will be used, not a re-
active compound approach.
. Development of test methodology will be an EPA responsibility.
. Principal information sources expected to be trade associ-
ations, EPA, and journals.
12 December 1974 - Meeting with Dow Personnel
Dow Chemical U.S.A. offices, Midland, Michigan.
Location:
Attendees: For Dow - primarily Jack Copus, Robert Lundy, Don Ritzema, K.O.
Groves, Lyman Skory, and K.S. Surprenant; for EPA - William
Johnson and David Patrick of ESED; and, for TRW - B.C. IkCoy.
Agenda:
Comments:
General discussions of dry cleaning industry, including the
processes, solvents, health effects, and test methods.
. The meeting provided an extremely valuable introduction to
the industry.
. Process descriptions for perchloroethylene dry cleaning were
obtained.
A-l
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. Proper operation and maintenance of dry cleaning equipment .'.
was considered the major factor in low solvent losses.
. Most common hardware for solvent emission control is carbon
adsorption. The major manufacturer is Vic Manufacturing Co.
of Minneapolis, Minn.
13 December 1974 - Meeting with Vic Manufacturing Co. Personnel
Location:
Attendees:
Agenda:
Commen ts : .
Vic offices, Minneapolis, Minnesota.
For Dow Chemical - K.O. Groves and K.A. Surprenant; for EPA -
William Johnson and David Patrick; for TRW - B.C. McCoy; and,
for Vic - J.W. Barber, Charles Gorman, Irving Victor and Oscar
Vi ctor.
Morning-use of carbon adsorber for reducing solvent losses in
vapor degreasing; afternoon-use of carbon adsorbers for reduc-
ing solvent losses in dry cleaning.
.. Me~ting served as valuable introduction to carbon adsorber
technology.
~~ In perchloroethylene plants, Vic estimated that solvent
losses could be reduced by 50% with carbon adsorbers.
. No adsorbers are commercially available for petroleum
plants, but Vic has operated a test unit.
. Refrigeration is being used as an emission control technique
in fluorocarbon dry cleaning machines.
. Many useful process descriptions, flow sheets, and other
data were provided by Vic.
. K.S. Surprenant (Dow) provided a meeting report to William
Johnson (EPA) on 20 December 1974.
8 January 1975 - Meeting with DuPont
Location:
DuPont offices, Wilmington, Delaware.
Attendees: For DuPont - (various times during the . day) Frank Bower, Joseph
Hoops, Don Kjelleren, and Ray McCarthy; for EPA - Jim .McCarthy;
and, for TRW - B.C. McCoy.
Agenda:
Discussions of DuPont "Valclene" dry cleaning solvent and fluoro-
carbon dr~ cleaning process.
A-?
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Comments:
. A good introduction to both the economics and processes of
fluorocarbon dry cleaning was obtained.
. Jim McCarthy, the new EPA Project Officer, prepared a trip
report dated 20 January 1976.
10 January 1975 - "Strategy Session" for OMB Briefing
Location:
EPA offices, Mutual Building, Durham, N.C.
Attendees: For EPA - Frank Bunyard, Bill Johnson, Jim McCarthy, Dave Patrick,
and John O'Connor; and for TRW - B.C. McCoy.
Agenda:
Commen ts :
Discussions of the scope of a presentation to be made by TRW for
the Office of Management and Budget.
. Presentation should emphasize: the processes; general in-
dustry description; approach to be used for cost analysis;
and data sources.
17 January 1975 -.OMB Briefing'
Location:
Attendees:
Agenda:
Comments:
EPA offices, Waterside Mall, Washington, D.C.
For Council of Wage & Price Stability - Roger Mallet; for EPA -
Frank Bunyard, James McCarthy, David Patrick, and John O'Connor;
for OMB - Vaughan Blankenship and Ben Masse11; and, for TRW -
Kevin Guinaw, B.C. McCoy, and W.E. Piske.
To familiarize the OMBrepresentatives with the dry cleaning
. industry and the approach to be used in developing NSPS.
. A brochure, with somewhat simplified process descriptions
and the general industry structure, was prepared before-
hand by TRW and distributed at the meeting.
. Good rapport was established with OMB, and they seemed satis-
fied with the briefing.
23 January 1975 - Meeting with Neighborhood Cleaners Association (NCA)
Location:
NCA offices, New York, New York.
A-3
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Attendees: For NCA - Frank Pollatsek and William Seitz; and, for TRW -
B.C. McCoy.
Agenda:
Discussions of the general characteristics of the NCA and
commercial dry cleaners.
Comment:
. The meeting providedamuch.clearer picture of the commer-
cial dry cleaner.
. NCA provided some useful economic data for their organization.
. A report was prepared by TRW for the visit.
30 January 1975 - Meeting with International Fabricare Institute (IFI)
Location:
IFI offices, Silver Spring, Md.
Attendees: For EPA - Frank Bunyard, Jim McCarthy, and Dave.Patrick; for IFI -
vIi 11 i am Fi sher and Andrew Watt; and, for TRW - Robert Manson and
B.C. McCoy.
Agenda:
Discussions of the IFI memberships dry cleaning processes, eco-
nomic conditions, and environmental impacts of dryclean;ng .
plan ts .
Comment:
. Good rapport was established with the largest of the dry
cleaning trade associations. This proved useful later in
the study.
. IFI agreed to assist EPA and TRW in locating well-controlled
dry cleaning plants.
. Most of the information provided by IFI was found in three
documents later obtained from IFI and other sources: (1)
IIResu1ts of Membership Survey of Drycleaning Operationsll;
(2) liThe ABC's of Solvent Mileage,1I Part 1; and (3) IIExperi-
mental Study on Solvent Discharge from Drycleaning Establish-
ments to the Environment (Field Study of Selected California
Dryc1eaning Plants)lI.
.. The common means of expressing solvent usage is mileage, the
pounds of clothes cleaned per 52 gal. drum of solvent. IFI
believed 6,500 is about average, 10,000 is obtaining by good
operation without a carbon adsorber, and 14,000-16,000 is
obtainable with an adsorber in perc plants.
A-4
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11 February 1975 - Bi-Monthly Briefing No.1
Location:
EPA offices, Mutual Building, Durham, N.C.
For Dow Chemical - Bob Lundy and Ken Surprenant; for EPA -
Ken Baker, John Bollinger, Bill Grimley, Bill .Johnson, Jim
McCarthy, and David Patrick; and, for TRW - B.C. McCoy and
W.E. Piske.
Attendees:
Agenda:
Discussions of progress made on. the dry cleaning study, poten-
tial problem areas, candidate test sites, future planning and
possible standards.
Comment: .
. Most discussion involved a possible problem in working
through trade associations to obtain potential test sites.
Associations seem to be cautious in this area, because of
possible harm to their relationship with members.
. B.C. McCoy was requested to obtain a complete set of the
IFI library for the dry cleaner, a compilation of IFI re-
ports, for EPA.
14 February 1975:- Interim Report Delivery
An interim report on the study was submitted to EPA by TRW. It was essen-
tially a very early draft of the final report. Possible standards were
only briefly discussed.
19 February 1975 - Letter from IFI
Mr. William Fisher, Development Engineer, gave his formal agreement to
assist in obtaining candidate test sites.
28 February 1975 - Telephone Call
Mr. Julius Hovaney of the National Automatic Laundry and Cleaning Council
provided the names of three coin-op plants whose owners will allow source
testing.
4 March 1975 - Letter from DuPont
Don Kjelleren, Sales Manager, "Valclene" Drycleaning Fluids, provided a
list of eight dry cleaning plants with fluorocarbon machines. They were
taken at random from DuPont files.
A-5
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24 March 1975 - Telephone Conversation with Jim McCarthY, EPA
There will probably be no tests of fluorocarbon plants, and the NSPS
will probably be based on a record keeping and housekeeping requirement.
4 April 1975 - Telephone Conversation with Bill Fisher, IFI
Bill . transmitted the names of.ll candidate.test.sites. See Progress
Report No.4.
8 April 1975 - Bi-Monthly Briefing No.2
Location:
EPA offices, Mutual Building,. Durham, N.C.
Attendees: For Dow - Robert Lundy and K.S. Surprenant; for EPA - Frank
Bunyard, Stanley Cuffe, Bill Johnson, Wayne Kelly, and David
Patrick; and, for TRW - B.C. McCoy.
Agenda:
Progress made, potential problems, and future plans, for the
dry cleaning study.
Comments:
. Robert Lundy provided the results of aDow customer survey
of solvent mileages being obtained by perc plants.
. "Action items" were considered to be: (1) dry cleaning equip-
ment cost data, including control equipment; (2) obtaining
final approval for contacting plants from IFI; (3) making
arrangements for visit to plant in Hershey, Pa.
17 April 1975 - Visit to Hershey Drycleaners' and Laundry
The subject plant was visited, and recommended for possible testing of both
the fluorocarbon machines and the perc machines. See TRW trip report dated
30 April 1975. .
30 April 1975- Visit to State Cleaners, Suitland, Md.
The subject plant was visited, but did not appear to.be appropriate for
testing. See trip report dated 8 July 1975.
21 May 1975 - Telephone Conversation with Jim Mc Carthy, EPA
Dry cleaning NSPS study is being transferred within ESED to the Non-Criteria
Pollutants Section. Charles Kleeberg is the new Project Officer.
A-6
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28 May 1975 - Plant Visit to Country Squire Cleaners, Springfield, Va.
This plant appeared to be an excellent example of a well-operated plant
without a carbon adsorber. It was recommended for a pre-survey and
possible test. See trip report dated 8 July 1975.
6 June 1975 - Organizational Meeting
An informal meeting was held between the EPA Project Officer, Charles
Kleeberg, the former Project Officer, James McCarthy, and the TRW Project
Engineer, B.C. McCoy. The purpose was to facilitate the transfer of the
dry cleaning study within ESED. See Charles K1eeberg's report dated
25 June 1975.
16 June 1975 - Bi-Month1y Briefing No.3
Location:
EPA offices, Mutual Bldg., Durham, N.C.
Attendees: For EPA - Frank Bunyard, John Bollinger, Charles K1eeberg, Jim
McCarthy, and William Johnson; and, for TRW - B.C. McCoy.
Agenda:
Progress made, potential problems, and future plans, for the
dry cleaning study.
Comments:
. Possible standards were discussed. The mileage levels being
considered were: 12,000-15,000 1b./drum for perc; 20,000-
25,000 lb./drum for fluorocarbon; and 8,000-10,000 pounds/
drum for petroleum solvents.
. Control measures would be a housekeeping regulation for all
plants with the addition of a carbon adsorber for the perc
and petroleum plants.
23 July 1975 - Visit to Sterling Laundry, Washington, D.C.
Purpose:
For EPA - Francis A1piser, Region III, Frank Bunyard, Jim Durham;
and Charles Kleeberg, all of ESED, Durham; for Sterling - R.
Jacobson, Jr., Cliff Hale, and Joe Smisek; and, for TRW - B.C.
McCoy.
To tour the subject plant and to assess its suitabil i ty for
testi ng.
Attendees:
Comments:
. The plant had both perc and petroleum equipment and was use-
ful for comparing the two processes.
A-7
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. The plant was not recommended for testing.
report dated 28 July 1975.
See TRW tri p
23 July 1975 - Dry Cleaning Project Meeting
Attendees: For EPA - Frank Bunyard, James Durham, and Charles Kleeberg; for
TRW - B.C. McCoy.
Agenda:
Implementation of dry cleaning emission test program, control
options, and program development.
Comments:
. The major reason for the delay in locating candidate test
sites was the decision made early in the program to work
through trade associations instead of going directly to the
plant operators.
. The principal data expected from a source test of a dry
cleaning plant will be solvent mileage and possibly a
qualitative idea of the major loss points.
25 July 1975 - Visit'to Crystal Valet, Arlington, Va.
The owner, Mr. Robert Smith, of this plant has a chain of 3 stores in the
area. However, the solvent mileage reported (7,000 lb./drum) was not good
enough for recommendation as test sites.
31 July 1975 - Meeting with Detrex Sales Representative
Location:
TRW offices, Vienna, Va.
Attendees: Joseph Panepinto, Detrex, and B.C. McCoy, TRW.
Agenda:
Discussion of mileage performance of dry- to-dry machines, with
a representative of one of the larger manufacturers of these
. units.
Comments:
. Typical solvent mileages of dry-to-dry units were stated
by Mr. Panepinto to be: 8,000-12,000 lb. p~r drum with no
adsorber; and lG,000-20,000 lb. per drum with an adsorber.
. Because of the higher operating temperatures of these units,
maintenance is more critical than for transfer machines.
7 August 1975 - Meeting at International Fabricare Institute (IFI)
Attendees: For Amato Solvents, Bob McClain; for EPA, Charles Kleeberg; for
IF!, William Fisher; and, for TRW,B.C. McCoy.
II 0
-------
Agenda:
Controlling solvent losses from perc machines.
cleaning plants.
Testing dry
Comments:
. 1-2 weeks of testing are needed for an accurate mileage
estimate in a perc plant. Most inaccuracies involve clothes
weighing.
. Most solvent losses are caused by: (1) poor adsorber oper-
ation; (2) poor extraction; or (3)' faulty tumbler operation.
. Inspection check. lists used by Amato in trouble-shooting dry
cleaning plants were provided by Mr. McClain.
28 August 1975 - Visit to Paul's Custom Cleaners
On the basis of this visit, the plant was suggested as a good potential
test site. See TRW trip report dated 29 August 1975.
28 August 1975 - Visit to Morningside Cleaners, Silver Spring, Md.
This plant was not recommended as a potential test site.
report dated 29 August 1975.
See TRW trip
10 September 1975 - Material Balances for Dry Cleaning Plants
On the basis of the 7 August 1975 meeting of EPA, IFI, Amato Solvents, and
TRW personnel, a draft of a methodology for determining solvent mileage
was prepared by EPA and sent to TRW and IFI for review. See memo, C.F.
Kleeberg to J.F. Durham, dated 10 September 1975.
16 September 1975 - Presurvey of Hershey Drycleaners and Laundry Plant
Attendees: For EPA - Francis Alpiser, Region III, Terry Harrison and
. Charles Kleeberg, of ESED,. Durham; for Hershey - Robert
Gallagher, John Koch, and Todd Pagliarulo; and, for TRW -
A.T. Barnard, John Haslbeck, and B.C. McCoy.
Purpose:
To thoroughly assess the suitability of both the fluorocarbon
and the perc machines at this site for test work.
It was decided to test both the fluorocarbon and perc machines,
Commen t-;
30 September 1975 - Receipt of IFI Comments on Mileage Determination Methodology
Mr. William Fisher (IFI) made some recommendations to Mr. C.F. Kleeberg
(EPA) regarding some small changes in the subject mileage test. See letter
dated 30 September 1975.
A-9
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1 October 1975 - Meeting with Detrex Distributor
Location:
State Equipment Co., Arlington, Va.
Attendees: Harry Oliver, of State, and B.C. McCoy of TRW.
.Agenda:
Current status of dry-to-dry percmachines in the dry cleaning
industry. Solvent emission control.
Comments:
. The trend towards transfer units in the past was caused by
the desire to increase through-put. .
. Carbon adsorbers should increase mileage by about 35-40%.
. Hot machines without adsorbers can attain 10,000-11,000 1b./
drum when properly maintained.
10 October 1975 - Visit to Vic Manufacturing
See EPA trip report dated 15 October 1975 by Charles K1eeberg to J.r.
Durham. The major topic of discussion was the use of fluorocarbon machine
technology for reducing. emissions in perc machines.
30 October 1975 - Meeting with DuPont Personnel to Discuss Material Balances
for Fluorocarbon Machines
See meeting report by Charles K1eeberg, EPA, to James Durham, EPA.
3-20 November 1975 - Plant test at Hershey Dryc1eaners and Laundry
Both the fluorocarbon machines and the perc machine were tested during
this period. Because of some problems, the former machines were re-
tested later. See EPA test report dated 17 March 1975.
13 November 1975 - Visit to Rentex Corporation Petroleum Dry Cleaning Plant,
York, Pa.
This plant seemed in exce11ent.operating condition, but showed only average
solvent usage, so it did not seem useful for testing. See TRW trip report
dated 14 November 1975.
25 November 1975 - Meeting with DuPont in Wilmington, Delaware
This meeting was held primarily to discuss the shortcomings in the test
procedures used for the f1 uorocarbon machines at He.rshey on 3-20 November
1975. See EPA meeting report dated 2 December 1975, Charles F. Kleeberg
to James F. Durham. .
A-lO
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26 November 1975 - Meeting with International Fabricare (IFI)
Charles Kleeberg of EPA met with William Fisher of IFI to obtain solvent
test procedures for the samples collected at Hershey on 3-20 November
1975.
3 December 1975 - Visit to Texas Industrial Services Industrial Dry Cleaning
Plant, San Antonio, Texas.
Charles Kleeberg (EPA) visited this large perc unit and found it to be an
excellent candidate for testing. See EPA trip report dated 9 December 1975.
4 December 1975 - Visit to Washex Machinery Corp., Wichita Falls, Texas
This visit was made by Charles Kleeberg (EPA) to the largest manufacturer
of petroleum dry cleaning equipment to obtain information regarding:
(1) industry growth rates; (2) control techniques and equipment; and (3)
economics. Mr. Steven Landon, the President of Washex, was helpful as .he
has been on numerous other occasions during the study. See EPA trip
report dated 12 December 1975.
5 December 1975 - Visit to Industrial Towel and Uniform, Houston, Texas
This industrial petroleum plant, visited by Charles Kleeberg (EPA) was
found to be unsuitable for testing. See trip report dated 12 December
1975.
11 December 1975 - Bi-Monthly Briefing
Location:
Attendees:
EPA offices, Mutual Building, Durham, N.C.
For EPA - Frank Bunyard, James Durham, William Hamilton, and
Chuck Kleeberg; and, for TRW - B.C. McCoy, and W.E. Piske.
Principal topics were: (1) model plants for economic analysis;
(2) control alternatives; and (3) dry cleaning ma.chine sales.
Agenda:
Comments:
. The machines chosen for the economic analysis were: (1) 500-
lb. petroleum unit and 250-lb. perc unit, for industrial
plants; (2) aO-lb. transfer and dry-to-dry perc units for
commercial plants; and (3) 25-lb. perc and fluorocarbon units
for coin-ops. .
. Control alternatives were to be housekeeping alone and house-
keeping plus an adsorber for perc and petroleum and house-
keeping only for fluorocarbon.
20 April 1976 The last part of the draft final report from TRW was submitted
to EPA. (Thi s was Appendi x B.)
29 April 1976 Final comments on draft report received from EPA.
7 May 1976 Revised final report sent to EPA.
-------
APPENDIX B
INDEX TO ENVIRONMENTAL IMPACT CONSIDERATIONS
Agency Guidelines for Preparing Regulatory
Action Environmental Impact Statements
(39 FR 37419)
Location Within the Standards Support
and Environmental Impact Statement
Il.
Background and description of proposed action
Summary of proposed standards
Statutory basis for proposed standards
The proposed standards are summarized in Chapter 1, Sec-
tion 1.1, pages through.
The statutory basis for the proposed standards is summa-
rized in Chapter 2, Section 2.1, pages through.
2.
3.
Relationship to other regulatory agency actions
The various relationships between the proposed standards
and other regulatory agency actions are summarized in
Chapter 2, Section 2.2, pages through.
A discussion of the industry affected by the standards is
presented in Chapter 3, Section 3.1, pages 3-1 through 3-2.
Further details covering the "business/economic" nature of
the indus try are presented in Chapter 7, Secti on 7. 1, pages
7-2 through 7-12.
4.
Industry affected by the proposed standards
5.
Specific processes affected by the standards
The specific processes and facilities affected by the pro-
posed standards are summarized in Chapter 1, Section 1.1,
pages through. A discussion of the rationale for
selecting these particular processes or facilities is pre-
sented in Chapter 8,. Section 8.2, pages through.
A detailed technical discussion of the sources and process-
es affected by the proposed standards is presented in Chap-
ter 3, Section 3.2, pages 3-2 through 3-20.
6.
Emission control technology
A discussion of the alternative emission control systems
and thei.r effectiveness is presented in Chapter. 4, pages
4-1 through 4-13. The costs associated with these systems
are presented in Chapter 7, Section 7.3, pages 7-16.
through 7-23, for commercial dry cleaning plants; Section
7.4, pages 7-24 through 7-34, for industrial dry cleaning
plants; and Section 7.5, pages 7-35 through 7-39, for coin-
operated dry cleaning plants.
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APPENDIX B
(Conti nued)
Agency Guidelines for Preparing Regulatory Location Within the Standards Support
Action Environmental Impact Statements and Environmental Impact Statement
(39 FR 37419)
7. En vi ronmen ta 1 and energy impacts of the proposed A discussion of environmental and energy impacts of the
standards s tanda rds is presented in Chapter 6, pages 6-1 through
6-5.
-------
TECHNICAL REPORT DATA
(Please read I/IIUr.uctions on the reverse before completing)
,. ~~AC:~5~73 -76 -029 12. 3. RECIPIENT'S ACCESSION-NO.
4. TITLE AND SUBTITLE 5. REPORT DATE
Study to Support New Source Performance Nay 1976
Standards for the Dry Cleaning Industry 6. PERFORMING ORGANIZATION CODE
7. AUTHOR(S) 8. PERFORMING ORGANIZATIO", REPORT NO.
Billy C. McCoy
9. PERFORMING ORG '\NIZATION NAME AND ADDRESS 10. PROGRAM ELEMENT NO.
Environmental Engineering Division
Energy Systems Group of TRW, Inc. 11. CONTRACT/GRANT NO.
800 Follin Lane, S.E.
Vienna, Virginia 22180 68-02-1412; Tas k Order No". 4
12. SPONSORING AGENCY NAME AND ADDRESS 13. TYPE OF REPORT AND PERIOD COVERED
U.S. Environmental Protection Agency Final 12/74 - 5/76
Office of Air Quality Planning and Standards 14. SPONSORING AGENCY CODE
Emission Standards and Engineering Division
Research Triangle Park, North Carolina 27711
15. SUPPLEMENTARY NOTES
EPA Project Officer: Charles F. Kl eeberg
16. ABSTRACT
The dry cleaning industry is described in terms of structure, processes, and
emissions, air pollution control techniques used, and typical plant modifications.
Hydrocarbon emissions occur from the evaporation of dry cleaning solvents, which
include trichlorotrifluoroethane, perchloroethylene, and petroleum distillates.
Certain control technique configurations are assumed, and the environmental and
economic impacts of those controls are.assessed.
17. KEY WORDS AND DOCUMENT ANALYSIS
a. DESCRIPTORS b.IDENTIFIERS/OPEN ENDED TERMS C. COSATI Field/Group
Air Po 11 uti on Air Pollution Control 13 B
Control .Equipment Stationary Sources
. Hydrocarbons Hydrocarbon Emission
Dry Cleaning Con tro 1
. Sol vents
18. DISTRIBUTION STATEMENT 19. SECURITY CLASS (This Report) 21. NO. OF PAGES
Unl imited Unclassified 118
20. SECURITY CLASS (This page) 22. PRICE
Unclassified
EPA Form 2220-1 (9-73)
C-l
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